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.

 

 

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