251 1 A It was definitely not Erskine 2 Bowles. 3 Q The two guys down there in the 4 research office? 5 A I can't verify, but I seriously 6 doubt it was either one of them. 7 Q You ever talked to Dick Morris? 8 A Not in a long, long time. 9 Q But you have talked to him? 10 A Unfortunately. 11 Q Why do you say unfortunately? 12 A He's a very unlikable man. 13 Q In what respect? 14 A I'm sure there are many ways to 15 address that, but my own personal way to 16 address it is that I just didn't appreciate 17 his phone manner when I worked in George's 18 office. 19 Q Which was? 20 A He wasn't very pleasant. 21 Q Did you ever discuss anything 22 dealing with the FBI with Mr. Morris? 252 1 A No, I have not. 2 Q Are you aware that he's told his 3 former girlfriend, Sherry ����, that Hillary 4 Clinton is the master mind? 5 A I'm not aware of that. 6 Q Did you ever read that anywhere? 7 A No, to the best of my memory. 8 Q Have you ever talked with Leon 9 Panetta? 10 A It hasn't been since he was chief 11 of staff and then only exchanging 12 pleasantries. 13 Q Were you ever in a meeting with 14 Mr. Panetta, one on one? 15 A Never. 16 Q Have you ever talked with Alex 17 Herman? 18 A Yes, I have. 19 Q Do you know Alexis Herman pretty 20 well? 21 A No, I don't. 22 Q How many times have you talked to 253 1 Alexis Herman? 2 MS. SHAPIRO: Object to the 3 relevancy of this. 4 BY MR. KLAYMAN: 5 Q You can respond. 6 A I've talked to her on occasion when 7 I was volunteering or interning and she was 8 at the White House. When I did advance, she, 9 she went to the, to the debate preps and so 10 in the course of helping her out, I talked to 11 her about things like getting the room that 12 she wanted or just the kind of things that I 13 would do with her in the course of doing my 14 job as an advance person. And that's all -- 15 that's all I remember. 16 Q Did you ever discuss FBI files with 17 her? 18 A No, I have not. 19 Q David Watkins? 20 A I don't remember meeting 21 Mr. Watkins. 22 Q Joanne Hilly? 254 1 A I don't know who that is. 2 Q George Sanders? 3 A I don't know who that is. 4 Q Christine Varnie. 5 A I don't remember Ms. Varnie. 6 Q Ever talk to her? 7 A I don't remember. 8 Q Cheryl Mills? 9 A I've only spoken with Ms. Mills 10 when she's called for Paul. 11 Q What was she calling about? 12 A I don't know. 13 Q William Kennedy? 14 A I don't know who that is. 15 Q Vince Foster? 16 A I never had occasion to speak with 17 Mr. Foster. 18 Q You ever seen him in the office? 19 A I have -- I have faint memory of 20 Mr. Foster coming in maybe -- I, I barely 21 remember. But I don't ever remember him 22 making appointments. I really don't remember 255 1 that. 2 Q Jeffrey Undercoffer? 3 A I don't know who that is. 4 Q John Lee Bonatti? 5 A I don't know who that is. 6 Q Jack Martin? 7 A I've only spoken with him when he 8 on case has called for Paul. You know what, 9 I take that back. I think he has a secretary 10 who places the call. I don't -- I think 11 maybe once, I've spoken to him. 12 Q Have you ever overheard 13 conversations between Mr. Begala and 14 Mr. Martin? 15 A Only once. 16 Q What was that about? 17 A He was calling him to let him know 18 that he had mentioned him in his deposition. 19 Q Paul was calling Mr. Martin? 20 A Uh-huh. 21 Q What did he say to Mr. Martin? 22 A That he had mentioned him in his 256 1 deposition. 2 Q Clearly he must have said more than 3 that? 4 A I remember him saying something 5 about good republicans or republicans that he 6 likes. 7 Q And what else did he say? 8 A It's kind of vaguely remember him 9 saying that he had to mention PSI. 10 Q Did Paul say something that you now 11 expect a subpoena? 12 A I don't remember him saying that. 13 Q Did you ever meet Ron Brown? 14 A I don't believe so. 15 Q You might have? 16 A I may have been in the same room, 17 but I was never introduced to him. 18 Q What room was that? 19 A I mean, it would have been -- it 20 would have been maybe in the west lobby or 21 something. I really don't have a memory of 22 being with Mr. Brown. I'm just -- I mean 257 1 it's just in the realm of the possibility 2 that he was in the building at the same time 3 I was. 4 Q Was there ever discussion of FBI 5 files in and around Ron Brown? 6 A Not that I'm aware of. 7 Q Do you know whether or not Paul 8 Begala prepared an affidavit for submission 9 in this case? 10 A No, I am not. 11 MR. KLAYMAN: I'll show you what 12 I'll ask the Court reporter to mark as 13 Exhibit 3. 14 (Parker Deposition Exhibit No. 3 15 was marked for identification.) 16 MR. KLAYMAN: Number 3 are you 17 aware of whether Paul Begala prepared a 18 document called the declaration in this case? 19 A I believe -- I know that Paul may 20 have been preparing something. I don't know 21 what it was. I don't know if it was ever 22 submitted. 258 1 Q I'll show you what the Court 2 reporter has marked as Exhibit 3. 3 THE WITNESS: Thank you. 4 Q Have you seen this document before? 5 A No, I have not. 6 Q Have you ever been aware of Paul 7 going down to see the office of personnel 8 security or talking with them on the phone? 9 A Not that I'm aware of. 10 Q Have you ever heard Paul talking on 11 the phone with Hillary Rodham Clinton? 12 A No, I have not. To the best of my 13 knowledge of who he was talking to. 14 Q You are aware that the two are 15 pretty close? 16 A I am not aware of the extent of 17 their relationship. 18 Q Paul ever talked to you about 19 Hillary Clinton? 20 A He's never talked about 21 Mrs. Clinton. 22 Q What do you mean. That was a 259 1 rather a quick response? 2 A I mean, there was one time where he 3 had a gift for her birthday and so we talked, 4 like, oh, we have to make an appointment so 5 he could go give the gift to Mrs. Clinton. I 6 mean -- 7 Q What did he buy her? 8 MS. SHAPIRO: Is that relevant? 9 MR. KLAYMAN: Yes. 10 THE WITNESS: He didn't buy her 11 anything. There was a cartoon that he 12 looked -- liked and he had the cartoonist 13 send in the -- I guess it was the original 14 draft of it and he had it framed so I guess 15 he paid for the frame. 16 Q Did the cartoon have anything to do 17 with file gate? 18 A Not that I'm aware of. 19 Q What kid the cartoon have something 20 to do with? 21 A I believe it was Mr. Starr. 22 Q And was Mr. Starr investigating 260 1 anything in this cartoon? 2 A Not that I'm aware of. No. It was 3 something about Starr eventually being 4 fostered. I don't remember exactly how the 5 cartoon went. 6 Q Was it recently? 7 A I don't remember her birthday was. 8 Q Last birthday? 9 A It was her last birthday. 10 Q Did you go to deliver it with him? 11 A No, I did not go. 12 Q He went by himself? 13 A I mean I saw him leave the office 14 by himself. Whether someone else went with 15 him at the time, I don't know. 16 Q Did he tell you whether he met with 17 the First Lady or not? 18 A He told me that she liked it. 19 Q Was anybody else there when he 20 presents the gift? 21 A I don't know. 22 Q Did he tell you whether he had any 261 1 discussions with her at the time he gave her 2 the gift? 3 A All I remember is that he said that 4 she liked it. 5 Q Did you ask him whether or not he 6 discussed this lawsuit with Judicial Watch at 7 the time? 8 A I did not -- I did not ask him 9 about this lawsuit. 10 Q Did you ask him whether he 11 discussed any of the so called Clinton 12 scandals at the time with her? 13 A No, I did not. 14 Q Has the First Lady ever called your 15 office? 16 MS. SHAPIRO: Asked and answered. 17 BY MR. KLAYMAN: 18 Q You can respond? 19 THE WITNESS: I mean, the operator 20 has called on her behalf. 21 Q When was the last time? 22 A This week. 262 1 Q How many times did she call? 2 A Only a couple of times I'm aware of 3 since I've been there. 4 Q A couple of times this week? 5 A No, a couple of times since I've 6 been here. 7 Q The operator called, was the call 8 put through to Paul. I take it it was? 9 A No, Paul wasn't in the office. I 10 had to take -- 11 Q You took a message for the first 12 lay the? 13 A No, I did not. The operator asked 14 me where I thought Paul would be and I told 15 her. 16 Q Are you on instructions not to make 17 notations when the First Lady calls? 18 A No, I'm not. 19 Q Have you decided on your own not to 20 record incoming calls from the First Lady or 21 the President to make a notation on your 22 computer? 263 1 A I've never -- it never occurred to 2 me that that would be something that we 3 should do. 4 Q Should not do? 5 A Should do, it never occurred to me 6 that that is something one should do. 7 Q Have you ever heard anyone say in 8 the White House we need to dig up some dirt 9 on these people? 10 A I've never heard that. 11 Q Have you ever heard anyone use a 12 four letter word against somebody in the 13 White House? 14 A To the best of my knowledge, no. 15 Q Have you ever discussed with Paul 16 Begala or anybody else any judge of a court 17 of law? 18 A Could you repeat that please. 19 Q Have you ever discussed a judge 20 while you've been at the White House or heard 21 anybody discussing a judge? 22 A Have I, are you asking if I or have 264 1 I heard anyone? 2 Q Both. 3 A I think I have on occasion 4 discussed a judge. 5 Q What judge did you discuss? 6 A I don't know this judge's name. 7 But it's the judge who has jurisdiction over 8 these proceedings. 9 Q What did you discuss about him? 10 A I believe I may have said once that 11 someone asked -- I think Paul was frustrated 12 with the line of questioning and that there 13 wasn't so much recourse for it because we 14 didn't have the most sympathetic judge. 15 Q Who did you say that to? 16 A I believe I said it to my 17 boyfriend. 18 Q What else did you tell your 19 boyfriend? 20 A I tell him lots of things. 21 Q About this case? 22 A No. I've done my best and I'm 265 1 doing my best not to because I'm not 2 interested in having to recount it here. 3 Q Do you think that what's recounted 4 here is something that you'll get to decide 5 whether you're interested in doing or not? 6 MS. SHAPIRO: Objection. 7 BY MR. KLAYMAN: 8 Q Is that for you to decide? 9 MS. SHAPIRO: She's answering your 10 questions. 11 BY MR. KLAYMAN: 12 Q When did you say this to your 13 boyfriend? 14 A Over the last week. 15 Q Was anyone else present? 16 A No. 17 Q Was it by phone or in person? 18 A Phone. 19 Q From the office? 20 A No. 21 Q From your home? 22 A Uh-huh. 266 1 Q How long was the conversation? 2 A We probably talked about the case 3 for one or two minutes. 4 Q How did the issue arise? 5 A Well, when I was subpoenaed, I told 6 him. 7 Q What led you to believe that the 8 judge is not sympathetic? 9 A See, I have to guess as far as to 10 know exactly where I heard that. I don't 11 want to guess. 12 Q That wasn't your thought. That was 13 somebody else's? 14 A It was something that I was 15 recounting. 16 Q It came from Paul Begala, didn't 17 it? 18 A I don't know. 19 Q You realize you're under oath? 20 A I realize I'm under oath. 21 MS. SHAPIRO: Objection. I don't 22 know why you keep trying to badge her and 267 1 oppress her with these constant threats of 2 being under oath. 3 MR. KLAYMAN: It sounds to me like 4 you're doing that, Ms. Shapiro. I just asked 5 her if she knew she was under oath. 6 MS. SHAPIRO: For of course. 7 BY MR. KLAYMAN: 8 Q It was obviously an important 9 question or you wouldn't have said it to your 10 boyfriend, correct? 11 A I say lots of things to my 12 boyfriend. 13 Q It was an important comment that 14 you heard, was it not? 15 MS. SHAPIRO: Asked and answered. 16 A I can't gauge the importance of it. 17 Q The reason it was important was 18 because you yourself had to give testimony in 19 this case, correct? 20 A I say lots of things during the 21 course of the day. I wouldn't say that 22 everything I say was important. 268 1 Q This one was important, wasn't it? 2 A That's your judgment. 3 MS. SHAPIRO: Asked and answered. 4 Q No I'm asking you. You don't get 5 to ask the questions? 6 MS. SHAPIRO: Objection. 7 BY MR. KLAYMAN: 8 Q It was important, wasn't it? 9 A It was something to be considered. 10 Q It concerned you, did it not? 11 A I mean, it's a concern, but a lot 12 of things are concerns. 13 Q I didn't ask you about a lot of 14 things. Did you hear this comment at work? 15 MS. SHAPIRO: Asked and answered. 16 BY MR. KLAYMAN: 17 Q You can respond. 18 A I don't know where I heard it. 19 MR. KLAYMAN: I'm going to show you 20 what I'll ask the Court reporter to mark as 21 Exhibit 4. 22 (Parker Deposition Exhibit No. 4 269 1 was marked for identification.) 2 BY MR. KLAYMAN: 3 Q Have you ever erased anything off 4 of your computer hard drive? 5 A Define what do you mean by -- you 6 mean erase. 7 Q Delete it. 8 A On occasion, yes. 9 Q Have you ever seen Paul Begala 10 delete anything from his computer? 11 A I've seen him delete E-mails. But 12 that's not -- I mean -- 13 Q Did he tell you why he was deleting 14 them? 15 A No. 16 Q Have you seen him delete anything 17 else? 18 A No. I've never seen him do it. 19 MR. KLAYMAN: Let's take a 2-minute 20 break. 21 THE VIDEO SPECIALIST: We're going 22 off video record at 3:07. 270 1 (Recess) 2 THE VIDEO SPECIALIST: We're back 3 on video record at 3:18. 4 BY MR. KLAYMAN: 5 Q I'll show you what I'll ask the 6 Court reporter to mark as Exhibit 4. This is 7 a notice of deposition Duces Tecum with 8 regard to Paul Begala have you seen this 9 before? 10 A I may have seen it on his desk, but 11 I don't remember reviewing it at any time. 12 Q He never gave you a copy of 13 Exhibit 4, did he? 14 A No, he did not. 15 Q And did he ever give you any 16 written instructions with regard to exhibit 17 4? 18 A Exhibit -- oh, he gave me verbal 19 instructions. 20 Q I asked for written instructions? 21 A I guess I gave you more than you 22 asked for. No, he did not. 271 1 Q What verbal instructions did he 2 give you with regard to exhibit 4? 3 A He asked me to search, search any 4 of our files that may have anything in it 5 that had the word FBI files or file gate or 6 any other kind of mix of the words files and 7 scandal. Anything that might have those 8 kinds of words on it and to produce them. 9 Q That's all he told you? 10 A That is what he told me. 11 Q Did he tell you where to look? 12 A He told me to look in the, not 13 files and, and if there was anything on the 14 computer, but I remember just on our files. 15 Q He didn't help you look, did he? 16 You did the looking, right? 17 A I believe he -- he didn't help 18 me -- when he gave me the direction, it was 19 look into the files that what kind of -- on 20 my side of the office and -- because there 21 are some things that we have on his desk so 22 what was on my side of the office, no, he did 272 1 not help me. 2 Q You don't know of him looking 3 himself, do you? 4 A I'm not aware of what he did for a 5 search. 6 Q No one else helped you to do a 7 search, did they, notwithstanding Paul 8 Begala, nobody assisted you in your search? 9 A No. 10 Q Did you keep any notices as to how 11 you conducted your search? 12 A No, I did not. 13 Q Did you find anything as a result 14 of your search? 15 A Yes, I did. 16 Q What did you find? 17 A I believe I found two pages that 18 had mention of FBI files probably. 19 Q Two documents? 20 A They believe they were documents, 21 yes. 22 Q What did you do with them when you 273 1 found them? 2 A Actually, I'm going to take that 3 back. Actually, I found a -- the way the 4 search went, I, I took out any documents that 5 had anything to do with, with -- that could 6 possibly have anything to do with this and I 7 gave him all that in a file, and then -- I 8 don't remember if I pointed him to two items 9 or if he picked them out himself, but from 10 there, we came up with two pieces of paper 11 with dimensions. 12 Q How thick was the file of documents 13 that you gave him in that file folder? 14 A Maybe, maybe that thick. Maybe -- 15 I mean, for the record -- 16 Q Could you hold that up for the 17 camera? 18 A Well, say maybe like three quarters 19 of an inch thick. 20 Q And you gave them to Mr. Begala? 21 A Yes, I did. 22 Q He reviewed them himself? 274 1 A Yes, he did. 2 Q You don't know whether he produced 3 all that stuff to Judicial Watch or not? 4 A I mean, I'm aware of two documents 5 we thought could be problematic and that was 6 produced to Judicial Watch. 7 Q You don't whether the stack of 8 documents that you gave to Mr. Begala were 9 ultimately produced or not? 10 A I believe they weren't. 11 Q How do you know that? 12 A Well I know that he -- there were 13 two items that were produced and therefore -- 14 and I know that there were other items in 15 that stack, so therefore those other items 16 were not produced. 17 Q Do you know what happened to that 18 file that you gave Mr. Begala? 19 A I went back and I put some of it 20 into two other files. I gave him the two 21 other files. One that I labeled on have 22 search or another one that I named Arlington 275 1 or Arlington cemetery and so after he did his 2 search and the two pieces were produced, I 3 went ahead and put them back into the files 4 that came back. 5 Q Had you labeled the file that was 6 labeled "Opposition Research"? 7 A Yes, I did. 8 Q And Mr. Begala told you to use that 9 label? 10 A No, he did not. No he did not. 11 Q Why did you label that file 12 opposition research? 13 A I came up with it. It was the best 14 way for me personally to describe the kind of 15 things that were in there. 16 Q What kinds of things were in there? 17 A Press clippings, quotes -- lots of 18 quotes with different issues that -- 19 different quotes of what different people 20 have said on things. That's what I primarily 21 remember. 22 Q Why did you use the word opposition 276 1 research? 2 A It was a catch word, catch phrase 3 in my head. What's important to me when I 4 file things is so I can kind of remember 5 where things are and to me that stood out as 6 a way to identify what these things were. 7 Q Where had you learned that catch 8 phrase? 9 A I mean, I've been aware of it ever 10 since I've been in Washington. 11 Q What in your mind is opposition 12 research? 13 A Well, it's quotes and it's votes. 14 Q It's quotes and it's what? 15 A Quotes and votes. 16 Q Does that mean? 17 A What people say on the record, how 18 people vote on the record, just things that 19 you can find out about your opponent and the 20 public record. 21 Q Who are the opponents whose 22 information is referred to in that file? 277 1 A I remember a lot of things act 2 people in committees and Congress. 3 Q Which particular people in 4 Congress? 5 A I mean, I have a memory of the 6 speaker. I don't -- I don't remember 7 specifically because a lot of these 8 documents, I reviewed them enough to classify 9 them. I didn't read the whole document. 10 Q Tell me all the names you can 11 remember of persons or committees or entities 12 that are referred to in that file folder? 13 A Sir, I don't remember. I remember 14 again ����. I remember different committees 15 and the amount of money that they spent on 16 investigating the administration. 17 Q Bob Barr, Congressman Bob Barr? 18 A Barr could be in there. 19 Q Congressman Geraldson? 20 A I have no recollection. 21 Q Senator Fred Thompson? 22 A That's -- probably. I don't know 278 1 for sure. 2 Q Trent Lott. 3 A I don't remember. 4 Q Henry Hyde? 5 A No recollection. 6 Q Any public interest groups? 7 A I have no recollection. 8 Q Judicial Watch? 9 A I have no recollection. 10 Q Is everything back in that file 11 today? 12 A To the best of my knowledge. 13 Q So everything was put back? 14 A To the best -- yes. 15 Q And where is that file stored? 16 A In my desk. 17 Q Where in your desk? 18 A To the right of me. I mean, in a 19 drawer that I put files. 20 Q I'm going ask you do secure that 21 file. We will be requesting it. Hopefully 22 we'll get it voluntarily, if not, we'll make 279 1 it very explicit that we want the file? 2 MS. SHAPIRO: She's not required to 3 do anything. We responded to your document 4 request. There's absolutely nothing in that 5 fail that pertains to this patter. We've 6 rejected it in the proper way and that's all. 7 MR. KLAYMAN: Have you seen that 8 file, Ms. Shapiro. 9 MS. SHAPIRO: Yes, I have. 10 MR. KLAYMAN: And you're going to 11 certify that there's nothing in there. 12 MS. SHAPIRO: Well, there are 13 papers in there. I'll willing to make the 14 representation as her attorney that it has 15 absolutely nothing to do with the FBI files. 16 MR. KLAYMAN: That's your search 17 phrase, FBI files. 18 MS. SHAPIRO: I'm not going to 19 answer questions. I will make a 20 representation to you that there is nothing 21 in there that is responsive, except to the 22 extent that it's been rejected to in the 280 1 document response that you have. 2 MR. KLAYMAN: Do we have a 3 privilege log on those documents? 4 MS. SHAPIRO: They have been 5 objected to. I don't understand. First of 6 all, I'm not answering questions about our 7 production. You have a document production 8 in front of you, a response. 9 BY MR. KLAYMAN: 10 Q What led you to believe that those 11 documents might be responsive such that you 12 handed to Mr. Begala? 13 A Actually, I don't remember his 14 exact phrase. I don't remember exactly. 15 Q No, but I'm asking you when you 16 looked at those documents, what was it about 17 them that you thought was responsive to the 18 notice of deposition Duces Tecum that 19 Mr. Begala asked you to go search for 20 documents in response to? 21 A I believe it was first of all I was 22 just trying to find anything that spoke about 281 1 our opponents. 2 Q How do you define the phrase "our 3 opponents"? 4 A Hmm, I don't -- I mean, I take that 5 back. I mean, I don't really want to 6 characterize all these people as our 7 opponents. 8 Just any -- people involved with 9 the, with the investigations, just the things 10 that have happened, a lot of things have 11 happened since Paul and I have started and to 12 me it all kinds of blurs together in my head, 13 all this stuff. 14 So you know I can't really define 15 "opponents" because I -- I really don't -- I 16 really don't think of these people as our 17 opponents. 18 Q These are documents that people 19 obtained and handed you to file? 20 A No. 21 Q Where did the documents come from? 22 A They're documents that people have 282 1 either delivered to Paul or they have been 2 sent to our office or Paul has brought in by 3 himself, and I have made the judgment or on 4 occasion he tells me that maybe we need to 5 keep these because maybe he's going to want 6 to see them again. 7 There are a lot of files that I 8 could very well throw out because he'll 9 probably never want to see -- he'll probably 10 never need them. 11 Q Who delivered them to the office? 12 A I don't know. 13 Q Who sent them? 14 A I don't know. 15 Q Can you name a few names after the 16 top of your head? 17 A I mean, no, you'd have to ask me 18 about each specific one for me to do that. 19 Q When you file documents, do you 20 staple the envelope of where it came from? 21 A The only time I do that is for 22 incoming correspondence. And usually I just 283 1 do that are constituents only for the purpose 2 of -- if their address and name isn't on the 3 letter. 4 Q So some of these documents may 5 contain envelopes? 6 A I can't imagine a situation where 7 someone would send a document, a working 8 document with an envelope. 9 Q But you're not sure? 10 A I mean, if someone's sending in our 11 office mail, the -- 12 Q I just asked you a simple question, 13 you're not sure will some of the document in 14 that opposition research file have envelopes 15 attached to them, correct? 16 A I mean, no I'm not sure, but I 17 don't remember ever stapling envelopes -- 18 Q I just asked you whether you were 19 sure or not. Did you look at that file 20 before you came over here today? You looked 21 at it in the last week? Did you look at it? 22 A I've -- yes, I've looked at it. 284 1 Q How did you look at it? 2 A On occasion I open my file drawer 3 and it's there, and my counsel asked to 4 review it. 5 Q When did she ask to review it? 6 MS. SHAPIRO: I'm just going to 7 just caution the witness not to reveal the 8 substance of the conversations and please let 9 me finish what I'll saying first. 10 MR. KLAYMAN: I thought you stopped 11 again. 12 BY MR. KLAYMAN: 13 Q When did you ask to review it? 14 When did your counsel ask to review it? 15 MS. SHAPIRO: You can answer that. 16 THE WITNESS: Okay. Today. 17 Q Did she know about it before today? 18 MS. SHAPIRO: Objection. She's not 19 going to get into the substance of any 20 communications. I instruct her not to answer 21 that question. 22 MR. KLAYMAN: Certify it. 285 1 Q Mr. Begala has conducted opposition 2 research himself, hasn't he? 3 A It matters how you define 4 opposition research. 5 Q As you define it? 6 A Yes. 7 Q Mr. Begala has a file which is 8 similar, which he keeps in his desk where he 9 keeps information about individuals or 10 groups. 11 A Not that I'm aware of. 12 Q May be important? 13 A Not that I'm aware of and I'm 14 pretty much aware of things the are on his 15 desk. 16 Q Where is your desk in come par stop 17 to his? Is it right up against his? 18 A No. 19 Q How far away is it? 20 A A couple of feet. 21 Q Is there anything in that research 22 file about Joseph diGenova? 286 1 A Not that I'm aware of. 2 Q You're not sure? 3 A I can't verify it. 4 Q Anything in there about Ken Starr? 5 A I'm not sure. 6 Q Anything in there about Mr. Rudolph 7 of Ken Starr's office? 8 A Not that I'm aware of. 9 Q You don't know one way or the 10 other? 11 A Not that I'm aware of. 12 Q Mr. Merrick? 13 A I don't know who that is. 14 Q Working with Ken Starr? 15 A Not that I'm aware of. 16 Q Any of the deputies? 17 A Not that I'm aware of. 18 Q Anything in there about Kathleen 19 Willey? 20 A Not that I'm aware of. 21 Q Monica Lewinsky? 22 A Not that I'm aware of. 287 1 Q Southeastern legal foundation? 2 A Not that I'm aware of. 3 Q So you can't remember what's in 4 there? 5 A I'm not aware of those persons or 6 institutions that you mentioned being in 7 there. 8 Q You can't remember? 9 A I can't remember those names of 10 those institutions being mentioned in that 11 file. 12 Q This morning when your counsel went 13 through that file, were you present? 14 A Yes, I was. 15 Q You went through each document with 16 her, didn't you? 17 MS. SHAPIRO: Objection. She's not 18 going to testify as to what she did with her 19 counsel. 20 MR. KLAYMAN: It's highly relevant. 21 It is not in any way getting into 22 attorney-client privilege. Did you review 288 1 this document with her. 2 MS. SHAPIRO: It is both privileged 3 and it's not relevant in the slightest. 4 Q Did you review this document with 5 her? 6 MS. SHAPIRO: I'm instructing her 7 not to answer. 8 MR. KLAYMAN: Certify it. This is 9 highly, highly sanctionable. 10 The reason those statements are 11 made is so you'll have an opportunity to 12 retract the instruction not to have her 13 reanswer. Would you retract that 14 instruction? 15 MS. SHAPIRO: There is an attorney 16 client privilege she is not require to veal 17 in fact discussions or anything she did with 18 counsel to prepare for this deposition and 19 that's final. 20 MR. KLAYMAN: Certify it. 21 I demand production of that file. 22 It's necessary for her deposition. Will you 289 1 go get that file right now? 2 MS. SHAPIRO: No, we've responded 3 to your document request. 4 MR. KLAYMAN: Certify it. 5 I'll show you what I'll ask the 6 Court reporter to mark as Exhibit 5. This is 7 a notice of deposition Duces Tecum to Ms. 8 Stacy Parker. 9 (Parker Deposition Exhibit No. 5 10 was marked for identification.) 11 MR. KLAYMAN: 12 Before I ask you about that 13 Ms. Parker, have you ever discussed this file 14 called opposition research with Mr. Begala in 15 the context of Judicial Watch's lawsuit? 16 A I don't believe so. 17 Q Has Mr. Begala told h told you 18 whether or not he revealed the existence of 19 this file during his deposition? 20 A We didn't discuss it. 21 Q You are aware that he did not 22 reveal the existence of this file during his 290 1 deposition? 2 A I'm not aware of that. 3 Q Looking at exhibit 5, have you seen 4 this before? 5 A Yes, I have. 6 Q When did you see it? 7 A When it was served to me. And I've 8 had it and -- 9 Q It is dated March 11, 1998? 10 A Yes. 11 Q Is that when you got it? 12 A I don't remember exactly which day 13 I received it. But it was last week. 14 Q Early in the week, late in the 15 week? 16 A Second half of the week. 17 Q Did someone bring it to your 18 attention? 19 A Yes. 20 Q Who did? 21 A My, my counsel. 22 Q Who is that? 291 1 A Why? 2 Q You can respond. 3 MS. SHAPIRO: You can say who 4 brought it to your attention. 5 THE WITNESS: Okay. Ms. Shapiro 6 and Ms. Paxton brought it to my attention. 7 BY MR. KLAYMAN: 8 Q How did they bring it to your 9 attention? Were they both present in your 10 office? 11 A My only my clear memory is of 12 Ms. Paxton coming into the office to tell me 13 that -- 14 MS. SHAPIRO: Don't reveal the 15 substance of what she told you. 16 THE WITNESS: I'm sorry. I don't 17 remember exactly how I got the document into 18 my hands. 19 BY MR. KLAYMAN: 20 Q Did Ms. Shapiro come into the 21 office with you? 22 A I'm sorry. 292 1 Q Did Ms. Shapiro come into the 2 office at the same time? 3 A No. 4 Q Did you talk to Ms. Shapiro by 5 phone when Ms. Paxton was there? 6 A No. 7 Q So you talked to them at different 8 times? 9 A No. 10 Q But you said both of them brought 11 this to your attention. How is that so if 12 Ms. Paxton is the only one who came into your 13 office? 14 A I was referring to the fact that I 15 had been subpoenaed and called for 16 deposition. 17 Q You say you found out from both of 18 them, is that the case? In midweek of last 19 week? 20 A There was one person who told me 21 first. 22 Q Who was that? 293 1 A Ms. Paxton. 2 Q Ms. Paxton met with you first? 3 A I don't remember if the first time 4 we actually met, if it was just Ms. Paxton 5 and I or if it was the three of us. 6 Q What do you mean the three of you, 7 three including you? 8 A Including me. 9 Q When Ms. Paxton came in and gave 10 you this notice of deposition Duces Tecum, 11 was she with Ms. Shapiro? 12 A When she told me, I was not given 13 the document. I don't remember exactly how I 14 was given the document. 15 Q Did Paul Begala give you the 16 document? 17 A I don't believe so. 18 Q Did someone else other than 19 Ms. Paxton or Ms. Shapiro give you the 20 document; is that possible? 21 A 99.99 percent, no. 22 Q How did you get the document? 294 1 MS. SHAPIRO: Asked and answered. 2 BY MR. KLAYMAN: 3 Q You can respond? 4 A I told you I can't -- I don't 5 remember exactly what were the circumstances 6 when this actual document or the likeness of 7 it was given to me. 8 Q How did you get the document? 9 MS. SHAPIRO: Asked and answered. 10 THE WITNESS: I don't. 11 MR. KLAYMAN: Did it come through a 12 course your, did it come to a pouch, hand 13 delivered, by mail? 14 A Hand delivered. 15 Q And what date was that? Do you 16 want to change your testimony? 17 A Midweek. 18 Q What happened when you got 19 document, if anything, with regard to the 20 document? 21 A What do you mean? 22 Q Did you review it with anybody? 295 1 A I've only reviewed this document 2 with my counsel. 3 Q When was that? 4 MR. KLAYMAN: I object to noises 5 while she's testifying. 6 MS. SHAPIRO: Okay. Then we'll 7 take a break. 8 MR. KLAYMAN: No, we won't take a 9 break. I want an answer to the question. 10 She didn't ask for consultation. 11 MS. SHAPIRO: I'm speaking to my 12 client and that's entirely appropriate. 13 MR. KLAYMAN: It's inappropriate. 14 You're right. 15 MS. SHAPIRO: It's appropriate. 16 MR. KLAYMAN: Certify it. 17 BY MR. KLAYMAN: 18 Q When did your counsel go through it 19 with you? 20 MS. SHAPIRO: Objection. I'm not 21 going to let her answer that question because 22 that would reveal part of the attorney-client 296 1 privilege. You can ask her when she reviewed 2 the document, but not -- 3 MR. KLAYMAN: Outrageous. Certify 4 it. 5 BY MR. KLAYMAN: 6 Q It was just today, wasn't it? 7 MS. SHAPIRO: She is not going to 8 answer that question. I instruct her not to 9 answer? 10 MR. KLAYMAN: Certify it. 11 BY MR. KLAYMAN: 12 Q Tell me did anyone go through each 13 paragraph with you and explain what each 14 paragraph meant ever? 15 MS. SHAPIRO: You can answer the 16 question if anybody did that. 17 THE WITNESS: Yes. 18 BY MR. KLAYMAN: 19 Q When was that? 20 A Over the last week. 21 Q Who did that with you? 22 A My counsel. 297 1 Q Were any instructions provided on 2 how to search for documents? 3 MS. SHAPIRO: Objection. 4 BY MR. KLAYMAN: 5 Q You can respond? 6 MS. SHAPIRO: No, she can't. That 7 goes precisely -- 8 MR. KLAYMAN: I didn't ask for 9 instructions. Whether instructions were 10 given. 11 MS. SHAPIRO: She's not going to 12 reveal privileged information. 13 MR. KLAYMAN: Certify it. It's not 14 privileged. I just asked if instructions 15 were given not for the nature of the 16 instructions. Do you want her to 17 reconsideration. 18 MS. SHAPIRO: Ask the question 19 again and I'll consider. 20 BY MR. KLAYMAN: 21 Q Did your counsel give you 22 instructions on how to look for documents? 298 1 MS. SHAPIRO: Objection. 2 BY MR. KLAYMAN: 3 Q You can respond? 4 MS. SHAPIRO: No, she can't, I'm 5 instructing her not to answer. 6 MR. KLAYMAN: Certify it. 7 BY MR. KLAYMAN: 8 Q Did you subsequently do a search 9 for documents? 10 A No, I did not do a physical search. 11 Wait, no. I take that back. I did produce 12 calendars. Paul's monthly calendars and his 13 daily schedules. 14 Q But other than that, you did no 15 search? 16 A Correct. 17 MR. KLAYMAN: I'll show you what 18 I'll ask the Court reporter to mark as 19 Exhibit 6, which is a March 19, '98 calendar 20 for Mr. Begala. 21 (Parker Deposition Exhibit No. 6 22 was marked for identification.) 299 1 BY MR. KLAYMAN: 2 Q Exhibit 7 is a March 1998 planner, 3 was this taken off of your computer? 4 A Yes, it was. 5 Q You're the one who did this? 6 A Yes, I was. 7 Q Now I take it there are some 8 calendars for April, May and June and going 9 into the year, were there not; were this 10 appointments? 11 A There is one for April. 12 Q Why did you only produce March and 13 not the other ones? 14 MS. SHAPIRO: Objection. 15 BY MR. KLAYMAN: 16 Q You can respond? 17 MS. SHAPIRO: No, she can't 18 respond. The document response speaks for 19 itself. 20 BY MR. KLAYMAN: 21 Q Why didn't you produce the April, 22 May, June, July and the remainder of the 300 1 year. You do have appointments on those, 2 don't you? 3 MS. SHAPIRO: You have document 4 response in front of you. 5 BY MR. KLAYMAN: 6 Q You can respond. 7 A I personally don't know why the 8 April calendar isn't here, but there's only 9 one event on it and I believe it -- well, 10 I'll just leave it at that. 11 Q Are there any events on the May 12 calendar? 13 A No. 14 Q June? 15 A No. 16 Q July? 17 A No. 18 Q August through December? 19 A No. 20 Q Did someone tell you not to produce 21 the April calendar? 22 A No.
Goto
of this deposition