1             UNITED STATES DISTRICT COURT
                       FOR THE DISTRICT OF COLUMBIA
         3     CARA LESLIE ALEXANDER et al.,    :
         4                       Plaintiffs,    :
         5                      v.              : No. 96-2123-RCL
               et al.,                          :
         7                                      :
                                 Defendants.    :
         8     ---------------------------------x

         9                                    Washington, D.C.

        10                               Monday, March 9, 1998

        11     Video deposition of

        12                 GEORGE STEPHANOPOULOS

        13     a witness, called for examination by counsel

        14     for Plaintiffs, pursuant to notice and

        15     agreement of counsel, beginning at

        16     approximately 10:36 a.m., at the offices of

        17     Judicial Watch, 501 School Street S.W.,

        18     Washington, D.C., before Shari R. Broussard,

        19     notary public in and for the District of

        20     Columbia, when were present on behalf of the

        21     respective parties:



         1     APPEARANCES:

         2        On behalf of Plaintiffs:

         3           LARRY KLAYMAN, ESQUIRE
                     DON BUSTION, ESQUIRE
         4           Judicial Watch
                     501 School Street S.W.
         5           Washington, D.C.  20024
                     (202) 646-5172

         7        On behalf of the White House:

                     Special Associate Counsel to the President
         9           The White House
                     (202) 456-5079

        11        On behalf of Hillary Clinton:

        12           PAUL B. GAFFNEY, ESQUIRE
                     MARCIE ZIEGLER, ESQUIRE
        13           Williams & Connolly
                     725 12th Street N.W.
        14           Washington, D.C.  20005
                     (202) 434-5874

        16        On behalf of Witness and Executive
                     Office of the President:
                     ELIZABETH J. SHAPIRO, ESQUIRE
        18           U.S. Department of Justice
                     901 E. Street N.W.
        19           Washington, D.C.  20630
                     (202) 616-8202




         1        On behalf of Craig Livingstone:

         2           DAVID S. COHEN, ESQUIRE
                     Miller, Cassidy, Larroca & Lewin
         3           2555 M Street N.W.
                     Washington, D.C.  20037-1302
         4           (202) 833-6503


         6        On behalf of the Witness:

         7           STANLEY M. BRAND, ESQUIRE
                     Brand, Lowell & Ryan
         8           923 Fifteenth Street, Northwest
                     Washington, D.C. 20005
         9           (202) 662-9700

               ALSO PRESENT:
                     Don Fitton

        13                    C O N T E N T S

        14     EXAMINATION BY:                            PAGE

        15        Counsel for Plaintiffs                     6

        16     *Instructions to Certify:

        17     Page       Line           Page       Line

        18      63         10            205          13
                71         18            215           5
        19      80         18            258          17
                81         14            282          20
        20      82          7            290          10, 16, 22
                83          2            292          17
        21      83         20            301           5, 11, 20
                84         15            302          21
        22      95          7            303           7
                96         19            305          20


         1     *Instructions to Certify (Cont'd):

         2     Page       Line           Page       Line

         3      106          5            307          8, 21
                112         13            310          5
         4      116          8            322         16
                117         19            323         19
         5      118          4, 10, 19    325         13
                131         13            327         16
         6      133         19            328         11
                134         20            330         15
         7      168          4            331         15
                169         11, 18        342         16
         8      170         18            347         15
                173         22            403         17
         9      198         16            418         10
                199         14            429         20
        10      204         21            430         10


        12     No.  1 - 3-9-98, Letter,                      7
                         Klayman to Shapiro
               No.  2 - Chart                                8
               No.  3 - Re-Notice of Deposition             13
               No.  4 - Document, Bates 000152             155
               No.  5 - FBI Document                       216
               No.  6 - Washington Post, Article           249
               No.  7 - Weekly Roundtable, Transcript      274
               No.  8 - The Dark Side of Camelot,          285
        20               Excerpt

        21     No.  9 - This Week, Transcript              318

        22     No. 10 - Western Journalism Center,         339
                         Special Report


               No. 11 - Press Review                       342
               No. 12 - Selected Investigations of the     355
         4               Clinton Administration

         5     No. 13 - Gingrich Keeps His Promise         357

         6     No. 14 - Pittsburgh Post, Article           370

         7     No. 15 - Documents CGE 046221-4             377

         8     No. 16 - Deposition of George               388
                         Stephanopoulos, Excerpts
               No. 17 - White House Press Release          394
               No. 18 - Morris Affidavit                   410
               No. 19 - Unlimited Access, Photocopy        420

                               *  *  *  *  *










         1                 P R O C E E D I N G S

         2               VIDEOGRAPHER:  Good morning.  This

         3     is the video deposition of George

         4     Stephanopoulos taken by the counsel for the

         5     Plaintiff in the matter of Cara Leslie 

         6     Alexander, et al. versus Federal Bureau of 

         7     Investigation, et al.  The U.S. District

         8     Court for the District of Columbia, Case

         9     Number 96-2123(RCL) held in the offices of

        10     Judicial Watch, 501 School Street S.W.,

        11     Washington D.C. on this date, March 9, 1998,

        12     and at the time indicated on the video screen

        13     which is 10:36 a.m.

        14               My name is Ann Castellow.  I am the

        15     videographer from Hunt Reporting Company.

        16     The court reporter today is Michele Howell

        17     from the firm of Beta Reporting.

        18               Will counsel, please, introduce

        19     themselves?

        20               MR. KLAYMAN:  My name is Larry

        21     Klayman on behalf of Judicial Watch.

        22               MR. FITTON:  Tom Fitton, legal


         1     assistant, Judicial Watch.

         2               MR. BOSTION:  Don Bostion,

         3     attorney, Judicial Watch.

         4               MR. GAFFNEY:  Paul Gaffney on

         5     behalf of The First Lady.

         6               MR. BRAND:  Stan Brand for the

         7     witness.

         8               THE WITNESS:  George

         9     Stephanopoulos.

        10               MS. SHAPIRO:  Elizabeth Shapiro for

        11     the witness and for the Executive Office of

        12     the President.

        13               MS. PAXTON:  Sally Paxton, the

        14     White House.

        15               MR. COHEN:  David Cohen for Craig

        16     Livingstone.

        17               VIDEOGRAPHER:  Our witness is

        18     Mr. George Stephanopoulos and will now be

        19     sworn in by the court reporter.

        20     Whereupon,

        21                 GEORGE STEPHANOPOULOS

        22     was called as a witness, and having been


         1     first duly sworn, was examined and testified

         2     as follows:

         3               VIDEOGRAPHER:  Thank you.  Witness

         4     sworn.  Mr. Klayman?


         6               MR. KLAYMAN:  As a preliminary

         7     matter, I'm going to ask that the letter of

         8     March 9th, 1998, be marked as Exhibit 1 to

         9     this deposition.  It's addressed to Ms.

        10     Shapiro, but it could be addressed to

        11     everybody in the room.  I will give everybody

        12     a copy.

        13                    (Stephanopoulos Deposition.

        14                    Exhibit No. 1 was marked for

        15                    identification.)

        16               THE WITNESS:  Unbelievable.

        17               MR. KLAYMAN:  Let the record

        18     reflect what the letter says is, "Upon

        19     reviewing the deposition of Paul Begala taken

        20     by plaintiffs on March 3rd, 1998, as well as

        21     other materials including congressional

        22     documents concerning Filegate, we have


         1     determined that Sally Paxton, Esquire, of the

         2     White House Counsel's Office, is a material

         3     witness in this case.

         4               Thus, while we appreciate the

         5     defendant Executive Office of the President

         6     is entitled to legal representation of its

         7     own choosing, we intend to invoke the rule in

         8     connection with the presence of Ms. Paxton at

         9     any future occasions in the taking of

        10     testimony in this case.  Thank you for your

        11     cooperation."

        12               I will ask further that the

        13     following document be marked as Exhibit 2.

        14                    (Stephanopoulos Deposition

        15                    Exhibit No. 2 was marked for

        16                    identification.)

        17               BY MR. KLAYMAN:

        18          Q    Let the record reflect that

        19     apparently there is a lot of laughing around

        20     the table.  I didn't mean to be funny.  Here

        21     is Exhibit 2.

        22          A    You don't have to try.


         1          Q    What's that?

         2          A    You don't have to try.

         3          Q    I would appreciate the sarcasm.

         4     We're going to try to conduct this in a

         5     professional manner.

         6          A    That will be a welcome change.

         7          Q    You will not get sarcasm from me,

         8     Mr. Stephanopoulos, and I would request some

         9     level of respect here today.

        10          A    I would like the same level of

        11     respect.

        12          Q    You will get that.

        13          A    Terrific.

        14          Q    This is a document which was

        15     produced in document production which

        16     reflects that Sally Paxton was one of the

        17     people contacted by Jane Sherburne after the

        18     FBI files matter broke.  It also lists

        19     Mr. David Cohen, who is in the room, who

        20     represents Mr. Livingstone.

        21               Mr. Cohen is counsel presently for

        22     Mr. Livingstone and I respectfully request


         1     that with regard to the testimony given here

         2     today by Mr. Stephanopoulos, I'm not going to

         3     seek to exclude Ms. Paxton from the

         4     deposition given the notice that we provided

         5     just here this morning, nor, Mr. Cohen, nor

         6     am I going to seek to exclude you from this

         7     deposition.

         8               But I do ask, since both of you are

         9     witnesses in this case, that you not consult

        10     with Mr. Stephanopoulos about his testimony

        11     that he's providing here today given the fact

        12     that you are material witnesses and we do

        13     intend to call you during the discovery

        14     process at a minimum.

        15               Will you abide by that?

        16               MS. SHAPIRO:  No.

        17               MR. COHEN:  I certainly don't

        18     intend to.

        19               MR. KLAYMAN:  You're going to be

        20     discussing Mr. Stephanopoulos' testimony?

        21               MR. COHEN:  I may or may not, but

        22     your request is not one that I intend to


         1     honor in any way.

         2               MR. KLAYMAN:  What about

         3     Ms. Paxton?

         4               MS. SHAPIRO:  No.  Ms. Paxton is

         5     here on behalf of the Executive Office of the

         6     President and she's entitled to act in her

         7     capacity as counsel.

         8               MR. KLAYMAN:  Are you saying she's

         9     entitled to discuss factual matters with

        10     Mr. Stephanopoulos about his testimony during

        11     the course of this deposition?

        12               MS. SHAPIRO:  We're not going to

        13     discuss the legal grounds.  You asked a

        14     question about whether we would abide by your

        15     request and the answer is no.

        16               MR. KLAYMAN:  You will not either,

        17     Mr. Cohen.

        18               MR. COHEN:  I have informed you of

        19     my position.

        20               MS. SHAPIRO:  Can we also just for

        21     the record identify is Mr. Fitton here in his

        22     capacity as a reporter or as a legal


         1     assistant for Judicial Watch?

         2               MR. KLAYMAN:  He works for Judicial

         3     Watch.

         4               THE WITNESS:  Is he a reporter?

         5               MS. SHAPIRO:  Yes, he is.

         6               THE WITNESS:  For whom?

         7               MS. SHAPIRO:  I want to be sure the

         8     record is clear on that.  Opinion, Inc. I

         9     believe, but he can clarify that if --

        10               MR. KLAYMAN:  He's not under

        11     deposition here, today, in any way.  If you

        12     wish to seek any clarification, that's fine.

        13     He works for Judicial Watch, Inc.

        14               MS. SHAPIRO:  That's fine, just as

        15     part of the Executive Office's responsibility

        16     in defining who he is.

        17               THE WITNESS:  Whoa.  Excuse me.

        18               MR. KLAYMAN:  I'm going to show you

        19     what I will ask the court reporter to mark as

        20     Exhibit 3.  This is a Notice of Deposition,

        21     corrected Re-Notice of Deposition of George

        22     Stephanopoulos.


         1                    (Stephanopoulos Deposition

         2                    Exhibit No. 3 was marked for

         3                    identification.)

         4               BY MR. KLAYMAN:

         5          Q    Showing you your corrected Notice

         6     of Deposition, Mr. Stephanopoulos, have you

         7     seen this document before?

         8          A    I believe so.

         9          Q    Are you appearing pursuant to this

        10     Notice of Deposition Duces Tecum?  You did

        11     receive a subpoena, construct?

        12          A    Yes.

        13          Q    In this corrected Notice of

        14     Deposition Duces Tecum it requires you to

        15     bring certain documents to this deposition.

        16     Have you brought some documents with you?

        17          A    I don't have any.

        18          Q    Let's run through the various

        19     requests. Have you had an opportunity to read

        20     the section that deals with defining what the

        21     word "document" means?  If not, you can have

        22     an opportunity to review that.


         1          A    My lawyer reviewed it.

         2          Q    That's Exhibit A?

         3          A    Yes.

         4          Q    Have you read it?

         5          A    I skimmed it, but my lawyer

         6     reviewed it carefully.

         7          Q    In determining whether you produced

         8     documents here today, did your lawyer go

         9     through each of the various categories in

        10     this Notice of Deposition Duces Tecum with

        11     you?

        12          A    Yes.

        13          Q    When did he do that?

        14          A    Sometime after -- a day or two

        15     after we got it.  I don't remember the exact

        16     day.

        17          Q    Can you tell me whether it occurred

        18     in the last week?

        19          A    A week ago or two weeks ago?

        20          Q    You're not entitled to ask your

        21     attorney questions.

        22          A    It was sometime between --


         1          Q    You have to answer.

         2          A    It was sometime between the time I

         3     got the subpoena and today.

         4          Q    Roughly speaking.

         5          A    Last week or two.

         6          Q    You're aware that this case is

         7     about the FBI Filegate controversy, correct?

         8          A    Yes.

         9          Q    That's a matter which you take

        10     seriously?

        11          A    Quite seriously and I've been

        12     deposed on it several -- on several occasions

        13     by several official bodies.  In each one of

        14     those I have said that I don't have any

        15     documents related to this case.

        16          Q    Well, you're aware that this is a

        17     private lawsuit, are you not?

        18          A    I am aware of that and my answer to

        19     the private lawsuit is the same as to the

        20     other investigations.  I don't have any

        21     documents --

        22          Q    Well, you're aware we have separate


         1     rights, are you not?

         2          A    Right.  The answer is still the

         3     same.  I don't have any documents.

         4          Q    Well, if it's a serious matter,

         5     then wouldn't you remember when you reviewed

         6     this Notice of Deposition Duces Tecum better

         7     than saying the last two weeks?

         8          A    Sometime in the last two weeks.  I

         9     don't remember the exact date.

        10          Q    Was it last week?

        11          A    It was probably the week before if

        12     I had to pin it down.

        13          Q    Did you meet with Mr. Brand?

        14          A    I've talked to him.

        15          Q    How was Exhibit 3 conveyed to you?

        16     Did you actually have a copy of it when you

        17     reviewed it with him?

        18          A    Yes.

        19          Q    Where did the review take place?

        20          A    It was probably in my office.  I

        21     don't know if I was in my home office or in

        22     my office at Columbia, but I was in one of my


         1     offices.

         2          Q    Where is your home office?

         3          A    My home.

         4          Q    Where is that?

         5          A    Do I have to answer that?

         6          Q    Yes, you do.

         7          A    Riverside Drive, New York.

         8          Q    What's the address?

         9          A    417 Riverside Drive.

        10          Q    That's in New York City?

        11          A    Yes.

        12          Q    Manhattan?

        13          A    Yes.

        14          Q    How was the document, Exhibit 3,

        15     sent to you?

        16          A    I think I got it at ABC two Sundays

        17     ago perhaps.

        18          Q    We're talking here about the

        19     original subpoena that you got in ABC,

        20     correct?

        21          A    Uh-huh.

        22          Q    Now this corrected Re-Notice of


         1     Deposition, have you ever seen this before?

         2          A    Yeah, I'm sure I have.  This was

         3     probably sent to my office.

         4          Q    Who sent it to your office?

         5          A    I don't know.  My secretary opens

         6     the mails and gives me packets of my

         7     materials.

         8          Q    Was this at your office at

         9     Riverside Drive?

        10          A    No, it was probably at my office at

        11     Columbia.

        12          Q    You don't know?

        13          A    No, I don't.

        14          Q    What did you do when you got it at

        15     your office in Columbia, Columbia University?

        16          A    I looked at it and I called my

        17     lawyer.

        18          Q    You went through each point with

        19     your lawyer?

        20          A    Yeah.

        21          Q    Did you read Exhibit A, the

        22     instructions section?


         1          A    Sure.

         2          Q    Are you aware that the definition

         3     of "document" is broader than just an actual

         4     piece of paper, that it goes into

         5     recordations, like cassettes and tapes and

         6     things like that?

         7          A    Sure.

         8          Q    You're intimately familiar with

         9     these instructions under Exhibit A?

        10          A    I'm familiar with them.

        11          Q    Have you been deposed before other

        12     than the times that you just mentioned?

        13          A    Other than the times I just

        14     mentioned?

        15          Q    Yes.

        16          A    No.  I think that's plenty.

        17          Q    When were you deposed before by the

        18     Government Reform and Oversight Committee,

        19     roughly speaking?  Within the last few years?

        20          A    Yeah.

        21          Q    The Government Reform and Oversight

        22     Committee deposed you on the Filegate matter?


         1          A    Sure.

         2          Q    Is that Mr. Ted Olson who took that

         3     deposition?  Do you remember that?

         4          A    I think it was his wife.

         5          Q    Barbara Comstock?

         6          A    I believe so.

         7          Q    You were deposed on the Travelgate

         8     controversy.

         9          A    Yeah, sure.

        10          Q    Who were you deposed by in that

        11     controversy?  Lori Taylor?  Does that name

        12     ring a bell?

        13          A    Possibly.

        14          Q    Have you been deposed more than

        15     those two occasions?

        16          A    Sure.

        17          Q    Tell me when else you have been

        18     deposed.

        19          A    I don't know the exact dates, but

        20     over the course of my time at the White House

        21     I was called for several different kinds of

        22     interviews.  Maybe not -- maybe they weren't


         1     formal depositions.  They were some kind of

         2     legal proceedings.

         3          Q    Was there a stenographer present

         4     when they took your testimony?

         5          A    Sure.

         6          Q    In what context did that occur?

         7     See if you can identify it so we'll be able

         8     to locate that testimony.

         9          A    Yeah, it's Grand Jury testimony.

        10          Q    Are we talking about the Grand Jury

        11     in the Ken Starr?

        12          A    There have been Grand Juries, there

        13     have been senate committees, there have been

        14     house committees, there have been Office of

        15     Government Ethics.  I mean there have been

        16     several.

        17          Q    Have you ever been deposed in a

        18     private lawsuit?

        19          A    I don't think so.

        20          Q    You're not sure?

        21          A    I don't think so.

        22          Q    Have you ever been charged with any


         1     crime?

         2          A    No.

         3          Q    You've never been convicted of a

         4     crime?

         5          A    Exactly.

         6          Q    Including traffic offense?

         7          A    I have probably been convicted of

         8     traffic offenses, yes.

         9          Q    When was that?

        10          A    I don't remember.

        11          Q    In what state?

        12          A    Including my speeding tickets?

        13          Q    Yes.

        14          A    I've probably gotten speeding

        15     tickets in California and Virginia to my

        16     recollection.

        17          Q    I'm not asking you if you didn't

        18     plead guilty.  I'm just saying is there any

        19     you have pled guilty to a crime however

        20     minor.

        21          A    Frankly, I have no idea what this

        22     is leading to, whether I've ever had speeding


         1     tickets.  I didn't drive here today.  I took

         2     a cab.

         3          Q    I didn't ask you that question,

         4     Mr. Stephanopoulos.

         5          A    Well, also your questions have

         6     nothing to do with FBI files.

         7          Q    You're going get respect from me

         8     and I suggest that you give me respect.

         9          A    I would suggest --

        10          Q    This is court process.

        11          A    I would suggest if you're asking me

        12     about if I've ever had a speeding ticket,

        13     you're not showing me respect.  If you'd like

        14     to get to the matter of the FBI files, of

        15     which I have no independent knowledge, I'm

        16     happy to answer.

        17          Q    There are speeding tickets and then

        18     there are speeding tickets.  Answer the

        19     questions to the best of your ability and

        20     let's move on.

        21          A    I already did.

        22          Q    I'm asking you to answer the


         1     question.

         2          A    I just answered the question.

         3          Q    I'm asking you whether you've pled

         4     guilty or been convicted of a crime.

         5          A    I told you I probably had speeding

         6     tickets in the State of Virginia and the

         7     State of California.  I couldn't swear to it.

         8     I don't know the dates.  I answered that four

         9     minutes ago.

        10          Q    I'm going to ask you for respect,

        11     Mr. Stephanopoulos.  It's going to be a long

        12     day.

        13          A    It's going to be a very long day

        14     and I'm going to ask you for respect.

        15          Q    You've got it.

        16               Have you ever been involved in

        17     litigation yourself?

        18          A    No.

        19          Q    Any kind of a legal proceeding,

        20     private nature?

        21          A    No.

        22          Q    Whether it's a lease, breaking a


         1     lease?

         2          A    No.

         3          Q    A bank loan?

         4          A    No.

         5          Q    Student loans?

         6          A    No.

         7          Q    Possession of any type of substance

         8     or anything to that effect?

         9          A    No.  I will note for the record

        10     that this is so far afield from having

        11     anything to do with the FBI files, of which I

        12     have no knowledge --

        13          Q    At a break you can consult with

        14     your lawyer and find out why it's not so far

        15     afield.

        16          A    Have you ever tried drugs?  Have

        17     you ever been convicted of substance abuse?

        18     Have you ever had it in your background?

        19     Have you ever had a speeding ticket?  What

        20     is -- what possible relevance does that have

        21     to do with FBI files?

        22               MR. KLAYMAN:  Let's just take a


         1     two-minute break to give people the coffee

         2     that they want to have.

         3               VIDEOGRAPHER:  This is the video

         4     operator.  We're going off the record.  The

         5     time now is approximately 10:52 a.m.

         6                    (Discussion off the record)

         7               VIDEOGRAPHER:  This is the video

         8     operator.  We're going back on the record.

         9     The time now is approximately 10:55 a.m.

        10     Mr. Klayman?

        11               BY MR. KLAYMAN:

        12          Q    Is the answer to the question no?

        13          A    Yes, sir.

        14          Q    Let's go through the schedule of

        15     documents.  Number one, which requests, "any

        16     all records, correspondence, notes,

        17     communications or other documents produced

        18     pursuant to a congressional subpoena, Grand

        19     Jury subpoena, or a voluntary agreement with

        20     the Department of Justice, or other official

        21     investigatory agency of the United States,

        22     including the Office of Independent Counsel


         1     Kenneth Starr, concerning or relating to the

         2     disclosure to White House personnel,

         3     including employees, detailees, volunteers

         4     and interns, or to other persons in the White

         5     House, including Hillary Rodham Clinton, of

         6     FBI background investigation files or summary

         7     reports on former Reagan and Bush

         8     administration appointees and employees and

         9     others."

        10               Did you search for any such

        11     documents?

        12          A    Yes.

        13          Q    Did you find any?

        14          A    No.

        15          Q    How did you search for those

        16     documents?

        17          A    I know what I have.  I looked in my

        18     office. I didn't have any.

        19          Q    When you left the White House, when

        20     was that?

        21          A    December 31st, 1996.

        22          Q    Did you take any documents or other


         1     types of recordations with you?

         2          A    I took my personal documents.  I

         3     didn't have anything related to FBI files.

         4          Q    What types of personal documents

         5     did you take?

         6          A    Personal documents, personal

         7     letters. Frankly, my secretary did most of

         8     the -- she filed the things that needed to be

         9     filed.  I boxed a few of the documents and

        10     took them home.

        11          Q    Who was your secretary?

        12          A    Laura Capps.

        13          Q    Is she still working in the White

        14     House?

        15          A    No.

        16          Q    Where does she work?

        17          A    She works in California.

        18          Q    Where in California?

        19          A    Santa Barbara.

        20          Q    Who does she work for?

        21          A    Her mom.

        22          Q    Her mother?


         1          A    Yes.

         2          Q    What's her mother's name?

         3          A    Louis Capps.

         4          Q    Do you know where the work place is

         5     that they work at?

         6          A    No.

         7          Q    Is it at home?

         8          A    I have no idea.

         9          Q    Do you know what her mother's

        10     business name is?

        11          A    Louis Capps.

        12          Q    Louis Capps?

        13          A    She's running for congress.

        14          Q    What did you tell her to box up

        15     before you left the White House?

        16          A    The official documents.  We were

        17     supposed to -- you know, I -- I don't know.

        18     I just made sure the procedures were

        19     followed.

        20          Q    What constitutes official

        21     documents?

        22          A    Whatever the White House counsel


         1     says is official documents.  I don't know.  I

         2     can't --

         3          Q    Well, did you or Ms. Capps review

         4     any type of listing for official documents

         5     before you made that instruction?

         6          A    Yes.

         7          Q    What listing did you review?

         8          A    I don't remember.

         9          Q    What was the nature of the listing?

        10     Generically speaking, what did you look at?

        11          A    I don't remember.

        12          Q    Are you aware you're under oath?

        13          A    Yes.  I literally don't remember.

        14          Q    Was it a book?  Was it a pamphlet?

        15          A    I don't remember.

        16          Q    What did you tell Ms. Capps about

        17     what constituted an official document?

        18          A    I just said just follow the rules

        19     we have to follow.

        20          Q    What are those rules?

        21          A    Whatever the White House counsel

        22     said the rules are.


         1          Q    Can you think of one rule?

         2          A    Supposed to send the official

         3     documents to the archives.  You can take

         4     personal ones.

         5          Q    What are official documents?

         6          A    Whatever pamphlet, book or whatever

         7     it was.

         8          Q    Mr. Stephanopoulos, where did you

         9     attend university?

        10          A    Columbia University.

        11          Q    What did you graduate in?  What did

        12     you graduate with your degree?

        13          A    Political science.

        14          Q    When did you graduate?

        15          A    1982.

        16          Q    Were there any honorary or anything

        17     of that nature, cum laude, magna cum laude,

        18     summa cum laude?

        19          A    Summa cum laude, salutatorian, phi

        20     beta kappa.

        21          Q    During your period at Columbia, did

        22     you take courses in history, American


         1     history?

         2          A    I'm -- actually, no.  No, I did

         3     not.

         4          Q    Did you take that in high school?

         5          A    I wish I would have.  Yes, I took

         6     it in high school.

         7          Q    Did you do any graduate studies

         8     after Columbia?

         9          A    Yes.

        10          Q    Where was that?

        11          A    Oxford University.

        12          Q    When did you go to Oxford?

        13          A    '84 to '86.

        14          Q    Did you graduate with a degree?

        15          A    Yes.

        16          Q    What did you study there?

        17          A    I studied theology and ethics.

        18          Q    Theology and ethics?

        19          A    Yes.

        20          Q    What does ethics entail?  What is

        21     that?

        22          A    Just what it says.


         1          Q    What type of ethics?

         2          A    I studied Christian political

         3     thought, moral theology and ethics.

         4          Q    What kinds of courses did you take

         5     on ethics specifically?

         6          A    It was, basically, independent.  I

         7     studied a number of writers and thinkers.

         8               I'd wonder what relevance that has,

         9     but I studied a lot of different things.

        10          Q    You worked in the White House, when

        11     was that?

        12          A    1993 to 1996.

        13          Q    Were you aware, during that period,

        14     that it was improper to remove official

        15     documents from the premises of the White

        16     House, correct?

        17          A    Sure.

        18          Q    In fact, to do so would constitute

        19     a crime?

        20          A    Yes.

        21          Q    Are you telling me that before you

        22     removed these documents from the White House,


         1     when you left, that you had no idea what was

         2     an official document and what was not?

         3          A    I don't think I removed any

         4     official documents.

         5          Q    Did you actually go through the

         6     documents with your secretary, Ms. Capps,

         7     before you removed them when you left?

         8          A    Some of them, sure.

         9          Q    You didn't go through all of them,

        10     did you?

        11          A    I'm sure it was reviewed properly.

        12          Q    But you didn't review it, did you?

        13          A    I didn't take home any official

        14     documents.

        15          Q    But you didn't review them all, did

        16     you?

        17          A    I think it was all reviewed

        18     properly.  I reviewed the ones I took home.

        19          Q    You don't know that you removed

        20     official documents, do you?

        21          A    Yes, I do.  I don't believe I

        22     reviewed any -- I mean I don't think I took


         1     out any official documents.

         2          Q    Then tell me the definition of an

         3     official document.

         4          A    An official document is an official

         5     document.  I mean it's all in the White House

         6     counsel's guidelines.

         7          Q    Who did you meet with at the White

         8     House Counsel's Office to review the

         9     documents that you were leaving with, if

        10     anyone?

        11          A    I was briefed.  I don't remember.

        12          Q    Who briefed you?

        13          A    I don't remember.  I'm sure

        14     somebody did, but I don't remember who.

        15          Q    Are you saying that you had no such

        16     meeting?

        17          A    No, I didn't say that.  I said I

        18     don't remember the exact meeting.  I said I

        19     know that I was briefed.

        20          Q    Who did you meet with, generally

        21     speaking?  What office in the White House

        22     Counsel's Office, what suboffice?


         1          A    I don't remember.

         2          Q    Mr. Stephanopoulos, are you aware

         3     that telling the truth means telling

         4     everything that you know?

         5          A    Yes, and I'm trying to.

         6          Q    Are you aware it means not

         7     forgetting?

         8          A    Well, sir, you know, this happened

         9     over a year ago.  I don't know what the

        10     relevance is to this and if I don't remember,

        11     I don't remember.

        12          Q    Before being deposed here today did

        13     you talk to anyone about the fact that

        14     Judicial Watch was requiring your testimony

        15     other than your counsel?

        16          A    Other than my counsel, I -- yeah, I

        17     probably mentioned it to a few people to

        18     explain why I was in Washington today.

        19          Q    Who did you mention it to?

        20          A    I don't know exactly.  I mentioned

        21     it to my parents.  I mentioned it to the

        22     person I'm having lunch with today.


         1          Q    Who is that?

         2          A    William Safire.

         3          Q    When did you mention it to William

         4     Safire?

         5          A    When I called him to see if he

         6     wanted to have lunch.

         7          Q    When was that?

         8          A    Sometime last week.

         9          Q    What did you say to Mr. Safire?

        10          A    I said I'm going to be in

        11     Washington on Monday.  Now it's possible, now

        12     that I think of it, that maybe I did not

        13     mention this to him.

        14               I might have said I'm just in

        15     Washington, but it's also very possible,

        16     since you want the whole truth, that in the

        17     course of that I probably said why I was

        18     going to be in Washington today because I'm

        19     normally in New York on Monday.

        20          Q    What did you tell him?  Simple

        21     question.

        22          A    If I --


         1          Q    We have taken four to get to a

         2     simple question.  If you want to move it

         3     along, move it along.

         4          A    I think I answered it the first

         5     time.

         6          Q    I don't think you did.

         7          A    I said I may have.  I may not have.

         8     If I did, I said I'm going to be doing a

         9     deposition on the FBI files case.

        10          Q    Did you tell him anything else?

        11          A    No.

        12          Q    Did Mr. Safire ask you anything

        13     about that deposition?

        14          A    No.

        15          Q    Your lawyer told me that you had to

        16     give a speech today at lunch.  Is that not

        17     true?

        18          A    Well, you can call it speech.  I

        19     mean --

        20               MR. KLAYMAN:  Stanley, is this a

        21     speech, Mr. Brand?

        22               MR. BRAND:  I'm not going to go


         1     into what I talked to George about.  At the

         2     time the deposition was called

         3     Mr. Stephanopoulos had a prior engagement.

         4               MR. KLAYMAN:  I have no problem if

         5     you want to take an hour lunch, but if it

         6     takes longer, I do object because the reason

         7     that you asked me if George could go to a

         8     speech was, in fact, he had a commitment.

         9     This doesn't appear to me to be a legitimate

        10     reason.

        11               MR. BRAND:  Larry, he could have

        12     had a commitment to go to National Airport.

        13     It doesn't matter as long as it's within the

        14     time frame we agreed to.  I don't know why

        15     we're wasting time here about whether it's

        16     lunch or a speech.

        17               MR. KLAYMAN:  If he wants to take

        18     lunch for an hour, that's fine, but that's

        19     what I want to keep it limited to.

        20               THE WITNESS:  Fine.  It will be an

        21     hour and-a-half.

        22               MR. KLAYMAN:  That's not for you to


         1     decide, Mr. Stephanopoulos.

         2               THE WITNESS:  I came here at 10:05

         3     for a 10:00 deposition, and you weren't ready

         4     until 10:35.

         5               BY MR. KLAYMAN:

         6          Q    No.  In fact, you were giving press

         7     conferences downstairs, weren't you?

         8          A    As a matter of fact, no.  Since you

         9     brought it up, why was the press here?

        10     Because you called them for your publicity?

        11     I didn't call them.

        12          Q    We didn't start until 10:30,

        13     correct?

        14          A    I believe we started at 10:35.

        15          Q    You were on the phone when I walked

        16     into the conference room, correct?

        17          A    I asked if we were ready to start.

        18     I came in ready to start.  You -- I was told

        19     by your employees or your contractors today

        20     that you were not prepared to start.  I said

        21     come get me when you're ready.  I am ready to

        22     start right now.


         1          Q    You were not told that by my staff

         2     and I was here waiting for you.

         3          A    That's not true and then since

         4     we're -- I mean I guess you should probably

         5     be under oath as well because that's not

         6     true.

         7               When I walked in the room, you were

         8     not here.  I was told that your people were

         9     not prepared to have a deposition.  I think

        10     truth works both ways as well.

        11          Q    I'm not going to quibble with you,

        12     but that is not the instruction that they

        13     were provided and I was ready the whole time.

        14          A    Well, I'm going to quibble with

        15     you.  You were not in the room when I came

        16     here when I was prepared to answer your

        17     questions.

        18          Q    I will ask the questions.  If you

        19     want to quibble with me, write legal briefs.

        20     Right now we're asking questions.

        21          A    I'm answering them.

        22          Q    I've seen your attitude thus far.


         1     I hope we can establish a different course of

         2     conduct here.

         3               Who else did you talk to about this

         4     deposition?

         5          A    I probably mentioned it to

         6     Elizabeth Drew because I was scheduled to

         7     have lunch with her as well.

         8          Q    What did you say to Ms. Drew?

         9          A    That I'm giving a deposition on the

        10     FBI files.

        11          Q    What did she ask you?

        12          A    Nothing about this.

        13          Q    Did you discuss your deposition

        14     with anyone else?

        15          A    I probably mentioned it to

        16     Carville.

        17          Q    When did you talk to Carville about

        18     it?

        19          A    I talk to him all the time.  I may

        20     have mentioned it last week when it happened.

        21          Q    How frequently do you talk to

        22     Carville?


         1          A    Several times a day.

         2          Q    What did you tell Mr. Carville

         3     about this deposition?

         4          A    That I have to waste a day on this

         5     deposition.

         6          Q    What else did you tell him?

         7          A    That's probably all.

         8          Q    I want to know what you told him,

         9     not probably.

        10          A    I talk to him all the time.  About

        11     this, that's probably all I said.

        12          Q    I want to know what you told him.

        13     I'm not here to speculate.  What did you tell

        14     him?

        15          A    Well, I probably mentioned

        16     something of how -- how I considered your

        17     actions frivolous and partisan and

        18     prejudicial.

        19          Q    You consider having to give

        20     testimony in something as important as

        21     Filegate to be frivolous, partisan?

        22          A    I consider your activity in this


         1     whole matter to be frivolous, partisan and

         2     prejudicial, yes.

         3          Q    Why is that so?

         4          A    Because you have consistently

         5     acted, to my reading of the newspapers in

         6     this case, not as someone determined to get

         7     the truth, not as someone determined to carry

         8     out a serious proceeding, but as someone

         9     looking to make headlines and raise funds for

        10     his organization so that you can harass

        11     people.

        12          Q    Are you saying that I don't have a

        13     right to be an attorney for the employees

        14     whose files were taken by the FBI and

        15     provided to the White House?

        16          A    I'd be happy to ask the court

        17     reporter to repeat what I said, but that's

        18     not what I said.

        19          Q    But is that your position, that I

        20     don't have the right to be an attorney in a

        21     private lawsuit?

        22          A    My position is that you're not an


         1     honorable attorney, that you are a partisan

         2     attorney, that you are looking to raise money

         3     for your organization.

         4          Q    How do you come to that conclusion

         5     other than press reports, if at all?

         6          A    Well, the press reports are enough.

         7          Q    Have you had me investigated?

         8          A    No, I have not.

         9          Q    Do you know of anyone who has?

        10          A    I don't care enough about you to

        11     have you investigated.

        12          Q    Do you know of anyone who has?

        13          A    No.

        14          Q    You don't care enough about me?  Do

        15     you consider me to be less than human?

        16          A    I didn't say that.  Why don't -- we

        17     can go to my words exactly.  I consider you

        18     to be a dishonorable attorney conducting a

        19     frivolous, partisan, prejudicial

        20     investigation.

        21          Q    In fact, we never met before today,

        22     did we?


         1          A    Not to my knowledge, no.

         2          Q    In fact, you never talked with me,

         3     did you?

         4          A    Thank goodness, no.

         5          Q    Have you ever looked into my

         6     background?

         7          A    No, beyond reading press reports in

         8     the newspaper when your name happens to

         9     appear.

        10          Q    Do you always believe press

        11     reports?

        12          A    No.  In this -- in this case,

        13     though, it seems to hold up.

        14          Q    In fact, what I have done to you

        15     this morning that in any way leads you to

        16     believe that it holds up?

        17          A    Oh, I think if we go back over the

        18     course of these questions, rather than ask me

        19     about the FBI files, which I would be happy

        20     to answer and was able to give the sum total

        21     of my knowledge in the FBI files in the

        22     35-second press question.


         1               I would add, that you called -- on

         2     the way in, rather than getting to that you

         3     choose to ask me about my background, you

         4     choose to ask me if I've ever been arrested

         5     for speeding, the relevance of which I find

         6     almost impossible to determine.

         7               You choose to come in late, you

         8     choose to question the integrity of my

         9     attorney and you choose to try to dictate how

        10     long I can have lunch.  That's for beginners.

        11          Q    Well, what about beginners that

        12     your attorney advised you that whether you've

        13     been convicted of a crime is relevant to the

        14     issues of your credibility under the rules of

        15     evidence?  Did he advise you of that?

        16          A    He said that you were allowed

        17     to ask the questions you wanted to, but I

        18     think if you were truly interested in getting

        19     my testimony in this matter, you would ask

        20     the questions that had to do with this

        21     matter.

        22          Q    Did you discuss this deposition


         1     with anybody else?

         2          A    Not to my knowledge, no.

         3          Q    Did you discuss it with Paul

         4     Begala?

         5          A    I might have mentioned it to his

         6     secretary.  I might have mentioned it to him,

         7     but I don't know.  I couldn't swear to it.

         8          Q    Have you spoken with Paul Begala

         9     since the date you received your subpoena?

        10          A    Sure.

        11          Q    Did you mention this lawsuit to

        12     Paul Begala?

        13          A    From what I remember, I think I

        14     called him when he was testifying and I left

        15     a message with his secretary saying ah, just

        16     tell him to hang in there.  Something like

        17     that.

        18          Q    Have you ever talked to him about

        19     your appearance here today?

        20          A    Beyond mentioning it, if I

        21     mentioned it, no.  I couldn't swear that I

        22     mentioned it.


         1          Q    How many times do you talk to

         2     Mr. Begala weekly or daily?

         3          A    Two, three times a week.

         4          Q    You talk to Carville several times

         5     a day?

         6          A    Yeah.  We're not as busy as Paul.

         7          Q    Why do you talk to Carville several

         8     times a day?

         9          A    Because I like him.

        10          Q    Do you talk to him about what's

        11     going on in Washington?

        12          A    Sure.

        13          Q    Clinton administration?

        14          A    Again, I mean I -- I don't know the

        15     relevance of asking me questions about my

        16     conversations with my friends, but I talk to

        17     him about a lot of different things.

        18          Q    You talk to him about the ongoing

        19     scandals?

        20          A    Would you like to ask me about the

        21     FBI files or not?

        22          Q    You're not here asking the


Next Section
of this deposition