1
1 UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
2
---------------------------------x
3 CARA LESLIE ALEXANDER et al., :
:
4 Plaintiffs, :
:
5 v. : No. 96-2123-RCL
:
6 FEDERAL BUREAU OF INVESTIGATION :
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:
22
2
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
6
7 On behalf of the White House:
8 SALLY PATRICIA PAXTON, ESQUIRE
Special Associate Counsel to the President
9 The White House
(202) 456-5079
10
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
15
16 On behalf of Witness and Executive
Office of the President:
17
ELIZABETH J. SHAPIRO, ESQUIRE
18 U.S. Department of Justice
901 E. Street N.W.
19 Washington, D.C. 20630
(202) 616-8202
20
21
22
3
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
5
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
10
ALSO PRESENT:
11
Don Fitton
12
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
4
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
11 STEPHANOPOULOS DEPOSITION EXHIBITS:
12 No. 1 - 3-9-98, Letter, 7
Klayman to Shapiro
13
No. 2 - Chart 8
14
No. 3 - Re-Notice of Deposition 13
15
No. 4 - Document, Bates 000152 155
16
No. 5 - FBI Document 216
17
No. 6 - Washington Post, Article 249
18
No. 7 - Weekly Roundtable, Transcript 274
19
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
5
1 STEPHANOPOULOS DEPOSITION EXHIBITS PAGE
(CONT'D):
2
No. 11 - Press Review 342
3
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
9
No. 17 - White House Press Release 394
10
No. 18 - Morris Affidavit 410
11
No. 19 - Unlimited Access, Photocopy 420
12
13
* * * * *
14
15
16
17
18
19
20
21
22
6
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
7
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
8
1 first duly sworn, was examined and testified
2 as follows:
3 VIDEOGRAPHER: Thank you. Witness
4 sworn. Mr. Klayman?
5 EXAMINATION BY COUNSEL FOR PLAINTIFFS
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
9
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.
10
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
11
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
12
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
13
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.
14
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.
15
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 --
16
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
17
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
18
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
19
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?
20
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?
21
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
22
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
23
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
24
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
25
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
26
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
27
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
28
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
29
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?
30
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
31
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.
32
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
33
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.
34
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,
35
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
36
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?
37
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.
38
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 --
39
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
40
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
41
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.
42
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.
43
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?
44
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
45
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
46
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?
47
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.
48
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
49
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.
50
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