201
1 answers that I've said there because that's
2 not what you're interested in. What you're
3 interested in is harassing people, taking up
4 their time going on this frivolous lawsuit,
5 but I'll continue to try to answer your
6 questions.
7 Q Your position is any deposition I
8 take is harassment?
9 A My position is I'm answering the
10 questions to the best of my ability.
11 Q Is that your position, that all I'm
12 doing is I'm taking up time and wasting
13 money? That there's not one deposition I can
14 take in this lawsuit that would make any
15 sense?
16 A I think all the material you could
17 have -- needed from me you could have gotten
18 from the transcript from the House Government
19 Oversight Committee transcript, but it is my
20 duty, as you point out, pursuant to the
21 orders of the judge and the jury toe come
22 here and answer your questions, so that is
202
1 exactly what I'm doing.
2 Q Did you keep a diary while you were
3 at the White House?
4 A No.
5 Q Have you ever kept a diary?
6 A College.
7 Q Did you keep any notes on a
8 dictaphone or any kind of recordation device
9 of what you were doing at the White House
10 when you were there?
11 A I have no diary.
12 Q Have you done that since?
13 A I have done a lot of different
14 things since I left the White House.
15 Q Have you done that since? Have you
16 reconstructed what you did at the White
17 House?
18 A Not everything. There are things
19 I'm going to write about.
20 Q That you're reconstructed.
21 How did you reconstruct it? What
22 sorts of material did you look to?
203
1 A A lot of different things.
2 Sometimes I just read newspaper reports, rood
3 books on the administration, refresh my
4 recollection.
5 Q Have you looked at notes that you
6 took when you were at the White House?
7 A Sure, sometimes.
8 Q Have you looked at correspondence
9 that you wrote when you were at the White
10 House since you have left?
11 A Conceivable some that I might have
12 received. I never had any on the FBI files.
13 Q Have you looked at E-mail?
14 A I never did E-mail at the White
15 House.
16 Q Looked at others E-mail?
17 A No.
18 Q Since you left the White House, has
19 the White House given you access to look
20 through their records for your book?
21 A No. I haven't asked.
22 Q Do you still visit the White House
204
1 from time to time?
2 A Not lately. I -- last time I was
3 at the White House was sometime in December.
4 Q Do you have a White House pass?
5 A No.
6 Q Who did you visit in December?
7 A I saw Paul Begala, I saw Rham
8 Emanuel and I briefly spoke to the President.
9 Q December of 1997?
10 A Yes.
11 Q When did you visit the White House
12 before that in '97?
13 A I don't remember exactly, but a
14 couple of times.
15 Q Roughly speaking?
16 A Two or three times over the course
17 of 1997.
18 Q Were you invited or did you ask to
19 go there?
20 A Do you think I broke in?
21 MR. KLAYMAN: Certify this.
22 THE WITNESS: I -- yeah, I met with
205
1 people, was cleared in appropriately just
2 like any other person would be.
3 BY MR. KLAYMAN:
4 Q Who did you meet with on those
5 other two occasions?
6 A I think I meet with Gene Sperling
7 once, I mean with Rham Emanuel once. I think
8 my going away party was in '97, as well.
9 Q Did you ever discuss the FBI files
10 matter when you went back to the White House
11 on those trip?
12 A No, but thank you for asking.
13 MR. KLAYMAN: Certify it.
14 BY MR. KLAYMAN:
15 Q We haven't finished the issue of
16 the briefing session.
17 A I don't know that there was any
18 briefing session.
19 Q Was Mr. McCurry present at the
20 briefing session?
21 A Could have been. I don't know.
22 Q What did he say then?
206
1 A I don't know that there was a
2 single briefing session. I'm assuming that
3 there was because I know the President
4 answered questions and, as a general matter,
5 before the President went to the press and
6 answered questions I would be part of a
7 briefing as he was briefed.
8 Q Well, you have your calendars when
9 you were at the White House, correct?
10 A Not all of them, not necessarily.
11 Q You have some of them, right?
12 A I don't know that.
13 Q You would mark up when there would
14 be a meeting or a briefing session from time
15 to time?
16 A No.
17 Q But sometimes you did, right?
18 A Perhaps.
19 Q If you had those calendars, that
20 might refresh your recollection, correct?
21 A If I had a calendar relating to the
22 FBI files, you would have it.
207
1 Q If you had a calendar, it would
2 refresh your recollection as to when the
3 briefing session occurred, would it not?
4 A No, not necessarily. If you told
5 me the day the President gave the press
6 statement, that might refresh my
7 recollection.
8 Q But it might?
9 A No, probably not.
10 Q But you did record things in your
11 calendar such as meetings, correct?
12 A Not always, no. I wouldn't --
13 probably wouldn't record a press briefing
14 actually.
15 Q Did your secretary keep a schedule
16 in her computer for you?
17 A Sometimes.
18 Q Did she use some kind of software
19 program to mark up your schedule?
20 A I don't know.
21 Q Did you have a computer in your
22 office?
208
1 A Yeah. I rarely used it.
2 Q But you used it sometimes?
3 A Not really. I mean I might have
4 used it a handful of times in my time at the
5 White House to tell you the truth. I never
6 used it for the FBI files matter.
7 Q Your memory is quite good about
8 that?
9 A Oh, yes.
10 Q What type of computer was that?
11 A I don't know.
12 Q Was it a desktop computer?
13 A I guess, yeah.
14 Q Did you store documents on the hard
15 drive or on floppy disks?
16 A I didn't know how to use a floppy
17 disk at the time.
18 Q You put it on the hard drive?
19 A I assume, yes.
20 Q Was there a printer hooked up to
21 it?
22 A Somewhere. I don't know where the
209
1 printer was. I really didn't used it that
2 much. No more than a handful of times.
3 Q Did you erase the files when you
4 left?
5 A Never touched it.
6 Q You didn't erase anything?
7 A No.
8 Q You left the computer right where
9 it was when you left?
10 A Yeah.
11 Q What room were you in when you
12 left?
13 A In the office.
14 Q What was the room number?
15 A It wasn't a room number.
16 Q Was it the Old Executive Office
17 Building?
18 A No.
19 Q Right inside the White House?
20 A Yes.
21 Q Where was that office located?
22 A In the West Wing.
210
1 Q It was located right next to the
2 President, correct?
3 A Uh-huh.
4 Q Right off his suite?
5 A You knew. Yeah.
6 Q My name is Monica Lewinsky.
7 A Certify that.
8 Q Please do.
9 Where was your office?
10 A Next to the President's.
11 Q What's the room number?
12 A There is no number.
13 Q There's no room number?
14 A That's what I said. As far as I
15 know, yeah.
16 Q Was there an area for a secretary
17 to sit?
18 A Uh-huh.
19 Q Where was that?
20 A In the front.
21 Q That was your secretary?
22 A Yeah.
211
1 Q That was Ms. Capps at the time?
2 A Yes.
3 Q Did she have a computer on her
4 desk?
5 A Uh-huh, yes.
6 Q Did you ever ask her to erase
7 anything from that computer?
8 A No.
9 Q Now, during that first briefing
10 session what was decided upon the President
11 would say about the FBI file matter?
12 MS. SHAPIRO: I object. There was
13 never established that there was a first
14 briefing session.
15 BY MR. KLAYMAN:
16 Q During the briefing session that
17 you identified?
18 A I didn't identify a single briefing
19 session. What I said, and I will repeat
20 again, is that if the President spoke
21 publicly, I assumed there was a briefing
22 session. I have no specific memory of that
212
1 briefing session.
2 What you can -- what you can do is
3 go back to the public record, which I'm sure
4 you have since this is what you do, go back
5 to the public record and see what the
6 President said and you can assume that that
7 was discussed in the briefing.
8 Q Did there come a point in time when
9 you had other meetings concerning the files
10 matter with the President or anyone else at
11 the White House?
12 A Not that I remember.
13 Q No other meetings?
14 A It's conceivable that I did, but I
15 don't remember.
16 Q Did there come a point in time when
17 you had any discussions with Hillary Clinton
18 over the files matter?
19 A No, not that I remember.
20 Q Did there come a point in time when
21 you had discussions with Leon Panetta over
22 the files matter?
213
1 A I assume that when it was breaking,
2 when it was in the press, it might have come
3 up at a daily staff meeting and what the
4 responses were beyond that, no.
5 Q It really didn't warrant your time?
6 A It wasn't my job to investigate it.
7 Q It didn't warrant your time in
8 giving the President advice?
9 A Well, I didn't say that. I said
10 that -- I said that based on what I knew at
11 the time, it was a mistake. That's what the
12 President said.
13 The President said it was a mistake
14 and he was outraged by the mistake and he was
15 going to take steps to make sure it never
16 happened again. As I said, that was
17 discussed in press briefings I assume before
18 he went out in public.
19 Hold on a second. I also said that
20 it was discussed at staff meetings because it
21 was a topic of conversation and, to use your
22 word, some controversy at the time. So, yes,
214
1 I can state with some certainty that it was
2 discussed in staff meetings and perhaps at
3 press briefings at that time.
4 I cannot remember the specific
5 meetings and I don't have any information
6 other than what was supplied in the press.
7 Q The White House line was it was a
8 mistake, correct?
9 A I -- as far as I know, that's what
10 it was.
11 Q Now, how was it determined that it
12 was a mistake, the file matter?
13 A I don't know.
14 Q You just took that on face value?
15 A I think that was the testimony of
16 the people involved.
17 Q Who told you it was a mistake
18 inside the White House?
19 A I assume somebody in the White
20 House Counsel's Office.
21 Q Who was it?
22 A If anybody, it was probably Jane
215
1 Sherburne, but I don't know that.
2 MS. SHAPIRO: He's not going to
3 testify about the substance of conversations
4 with counsel.
5 MR. KLAYMAN: Certify it.
6 BY MR. KLAYMAN:
7 Q Did you ask for any proof that it
8 was a mistake?
9 A I didn't do any independent
10 investigation, as you asked you asked several
11 minutes ago. I wouldn't have said it was a
12 mistake if I weren't confident it was.
13 Q Did anyone raise in all of these
14 meetings how do we know it was a mistake,
15 suppose this thing blows up in our face,
16 anything to that effect?
17 MS. SHAPIRO: Objection. He's not
18 going to answer with respect to the substance
19 of conversations with counsel.
20 BY MR. KLAYMAN:
21 Q You can respond.
22 MS. SHAPIRO: No, he can't. I'm
216
1 asserting a privilege that calls for
2 attorney-client communications.
3 MR. KLAYMAN: I'm not asking for
4 attorney-client communications. I'm talking
5 about others.
6 MS. SHAPIRO: Who?
7 MR. KLAYMAN: To the extent the
8 information comes from counsel itself is not
9 privileged. We're not talking about legal
10 advice.
11 MR. BRAND: Discussions among
12 Presidential aids are privileged under the
13 Presidential privilege.
14 MR. KLAYMAN: Is it your position,
15 Mr. Brand, that any information that would
16 deal with the matter that may give rise to a
17 crime is privileged as long as it's discussed
18 among Presidential aids?
19 MR. BRAND: No, my position is
20 ensconced in Fed 2nd 121 In Re: Grand Jury in
21 the case of Michael Espy, that the
22 deliberations among White House staff, which
217
1 ultimately form part of the advice they give
2 the President about a matter within the
3 official duties of the White House, are
4 privileged.
5 MR. KLAYMAN: Even if it involves a
6 crime?
7 MR. BRAND: That's a self-serving
8 conclusion that you're making that has
9 nothing to do with whether their conversation
10 is privileged.
11 MR. KLAYMAN: I'll show you what I
12 will ask the court reporter to mark as
13 Exhibit 5.
14 (Stephanopoulos Deposition
15 Exhibit No. 5 was marked for
16 identification.)
17 BY MR. KLAYMAN:
18 Q Have you ever seen this document
19 before, Mr. Stephanopoulos? This is a press
20 release of the U.S. Department of Justice,
21 Federal Bureau of Investigation, dated
22 June 14th, 1996.
218
1 A I'm sure I have, yeah.
2 Q Did you see it in and around
3 June 14th, 1996?
4 A I'm sure I didn't see it before it
5 was released to the public, but after it was
6 I probably did.
7 Q Did you have any communication, you
8 or anyone else in the White House, with the
9 FBI concerning the preparation of this press
10 release?
11 A I certainly didn't.
12 Q Do you know if anyone else did?
13 A As far as I know, no one did.
14 Q Were you aware that this press
15 release was going to issue before it issued?
16 A No.
17 Q I turn your attention to paragraph
18 three of the first page of this press
19 release. This is a statement of Director
20 Louis Freeh. "The inquiry shows the FBI gave
21 inadequate protection to the privacy
22 interests of persons in FBI files,' Freeh
219
1 said. The inquiry also found the Bureau
2 failed to make certain that agencies
3 receiving files followed exacting privacy
4 procedures.
5 "Freeh said that the inquiry's
6 discovery of egregious violations of privacy
7 required that the FBI move promptly and
8 firmly to reform procedures and solve the
9 problems. The new protective measures are
10 being put in place at once.
11 "The FBI inquiry also discovered,
12 Freeh said, that the White House has
13 identified 408 files sought and received by
14 the White House without justification."
15 Now, given those statements did
16 those cause alarm at the White House after
17 this press release issued by Director Louis
18 Freeh?
19 A That wouldn't be the right word. I
20 think it's not inconsistent with what I
21 testified to today. Another way of saying
22 without justification, it is received by the
220
1 White House by mistake. It was a mistake.
2 It should have never happened.
3 Beyond that this statement also, I
4 think quite rightly, points out that the FBI
5 gave inadequate protection in sending
6 those -- those files over. Again, a mistake.
7 Bureaucratic error, a screw-up. That is not
8 the same as a crime.
9 Q Do you see the words "egregious
10 violations of privacy"?
11 A Sure.
12 Q What does the word "egregious" mean
13 to you?
14 A Egregious means what it says. It
15 means severe.
16 Q Do you see the words "without
17 justification"?
18 A I think I already -- I think I
19 repeated them, so I must have seen them.
20 Q You saw those statements at the
21 time, correct, in and around June 14th, 1996,
22 correct?
221
1 A Probably.
2 Q Now, without justification, you
3 took that to mean without legal
4 justification, did you not?
5 A I took it to mean exactly what I
6 said, that it meant it was a mistake which I
7 believe at the time and I believe now.
8 Q Now, when this press release hit,
9 were there discussions about it inside the
10 White House?
11 A I'm sure there were. There were
12 lots of newspaper articles about it.
13 Q As part of your job as advisor to
14 the President on policy and politics, you
15 discussed this press release with him?
16 MS. SHAPIRO: Objection.
17 BY MR. KLAYMAN:
18 Q Freeh's press release.
19 MS. SHAPIRO: You can ask him
20 whether he spoke to the President, but the
21 substance of those conversations he's not
22 going to testify to, if there were any such
222
1 conversations.
2 BY MR. KLAYMAN:
3 Q Let's take the first question. Did
4 you talk the Freeh's press release, the one
5 I've just identified, Exhibit 5, with the
6 President?
7 A I may have. I don't specifically
8 remember it.
9 Q This was a pretty serious matter as
10 related in Exhibit 5, it was not?
11 A It was a bad story.
12 Q In fact, in all of the
13 controversies thus far, this one appeared in
14 your mind at the time to be the worst, did it
15 not?
16 A Why do you say that?
17 Q Because of Freeh's statement here
18 that it was an egregious violation of privacy
19 without justification.
20 A What does that have to do with my
21 mind?
22 Q I'm asking you.
223
1 A Well, then ask your question.
2 Q Wasn't this considered to be a very
3 series matter by you at the time?
4 A I considered it potentially serious
5 and certainly the -- the mistake of turning
6 over the documents was serious, but serious
7 is not the same as criminal.
8 Q At that time you brought it to the
9 President's attention, did you not?
10 A I don't think he even needed me to
11 bring this to the President's -- bring it to
12 his attention. The whole world knew about
13 it.
14 Q You discussed this with the
15 President, this press release.
16 MS. SHAPIRO: Object.
17 THE WITNESS: I said I don't
18 remember the specific --
19 BY MR. KLAYMAN:
20 Q You can respond.
21 MS. SHAPIRO: He's asked and
22 answered.
224
1 BY MR. KLAYMAN:
2 Q You discussed it with Hillary
3 Clinton, did you not?
4 A Same answer for the President. I
5 may have, but I don't remember specific
6 conversations.
7 Q Now, for something so serious you
8 would have a memory, wouldn't you?
9 A No. Specific memory? I said I may
10 have discussed it. I don't remember what
11 happened on the -- on the very day.
12 Q Did you discuss this Freeh press
13 release with anyone else at the White House?
14 A I assume I did.
15 Q Who did you discuss it with?
16 A Whoever was around that day.
17 Q Who was that?
18 A I don't remember.
19 Q Did you discuss it with anyone
20 after that day?
21 A Probably. It was the news story --
22 Q Who did you discuss it with?
225
1 A -- for that day. Anybody I
2 probably ran into.
3 Q Who was that?
4 A Anywhere from 12 to 400 people.
5 Q Well, let's start with 12. What
6 are the 12 you would have discussed it with?
7 A I'm not saying I did discus it with
8 them, but it's conceivable that if it came up
9 at a staff meeting, there were 12 people at
10 the staff meeting, you would consider that I
11 discussed it at the staff meeting. My guess
12 is that probably happened.
13 Q Who was at the staff meeting?
14 A Generally it was Leon Panetta,
15 Evelyn Lieberman, Erskine Bowles, Rham
16 Emanuel, Gene Sperling, Pat Griffin, Bob
17 Grogan, Harold Ickes to name a few. May have
18 been Mike McCurry.
19 Q What did any of those individuals
20 say about Freeh's press release?
21 A I don't remember, but I'm sure we
22 talked about it.
226
1 Q At those staff meetings from time
2 to time you observed people taking notes,
3 didn't you?
4 A Not really.
5 Q You're saying no one ever took a
6 note of the staff meeting?
7 A I didn't say that. I said not
8 really. I don't have any specific memory of
9 people taking notes at staff meetings.
10 Q Were those staff meetings ever
11 recorded by an electronic device?
12 A No.
13 Q Was there a stenographer there to
14 take down what was occurring at the staff
15 meeting?
16 A No.
17 Q Did the President attend the staff
18 meetings from time to time?
19 A No.
20 Q Did the First Lady?
21 A No.
22 Q During the time you worked in the
227
1 White House, did Hillary Rodham Clinton have
2 entry privileges into meetings? Could she
3 come into any meetings?
4 A Entry privileges?
5 Q Whatever you want to call it.
6 A I assume the First Lady could go to
7 a meeting if she wanted to. She didn't make
8 it a general practice.
9 Q But she did go to some meetings,
10 did she not?
11 A I think it's a pretty safe -- safe
12 thing to say, yes, the First Lady in the
13 course of my years at the White House came
14 into some meeting, yes.
15 Q Sometimes she would come into those
16 meeting unannounced, correct?
17 A Not generally, no.
18 Q But sometimes?
19 A It's conceivable. That's not
20 announced. Just because I didn't know about
21 it didn't mean it was unannounced.
22 Q Did she join the meeting on
228
1 Filegate, a staff meeting?
2 A I don't remember a specific staff
3 meeting on Filegate. I said we had daily
4 staff meetings. Because this was a matter in
5 the press at the time, it may have been
6 discussed.
7 Q Did you ever discuss Freeh's press
8 release with anyone at the FBI?
9 A No.
10 Q Did you ever discuss the files
11 matter with anybody at the FBI?
12 A No.
13 Q Did you ever discuss the files
14 matter with anyone from the Secret Service?
15 A No.
16 Q Any federal law enforcement
17 official?
18 A No, other than --
19 Q Other than when you were called to
20 testify?
21 A Other than I was called to testify,
22 which you could have read anyway, no.
229
1 Q Did you ever discuss the files
2 matter with Josh Steiner?
3 A No.
4 Q Where was Robert Rubin working at
5 the time of the staff meeting?
6 A He was probably Secretary of the
7 Treasury.
8 Q Had he been reassigned to the White
9 House?
10 A No, he was Secretary of the
11 Treasury.
12 Q Robert Altman, where was he? Did
13 he ever sit on the staff meetings?
14 A His name is Roger Altman.
15 Q Roger Altman.
16 A Robert Altman, BCCI, was married to
17 Wonder Woman. Roger Altman is the former
18 deputy treasury secretary.
19 Q Thank you. Thank you. Was he
20 sitting in on any of these meetings?
21 A No, he had left the White House by
22 that time, which, again, I mean if you're
230
1 going to do some preparation, you know, at
2 least get your dates and times right. I
3 think this is one more piece of evidence that
4 you're on a fishing expedition, not that
5 you've done any homework.
6 Q Are you offering your consulting
7 services, Mr. Stephanopoulos?
8 A You can't afford me.
9 Q What's your hourly rate?
10 A I don't have one.
11 Q Turn to page three of this press
12 release, fourth paragraph from the bottom.
13 "Freeh said the prior system of providing
14 files to the White House relied on go faith
15 and honor. Unfortunately, the FBI and I were
16 victimized. I promise the American people
17 that it will not happen again on my watch."
18 Was there any discussion at the
19 White House about the prior system of
20 obtaining files relying on good faith and
21 honor?
22 A I don't know about those specific
231
1 words, but the President did announce
2 publicly subsequent to this -- when the story
3 broke that he would revise the system, so I
4 assume it was, yes.
5 Q Was the system subsequently revised
6 to the best of your knowledge?
7 A Yes.
8 Q When was it revised?
9 A I don't remember the exact date,
10 but right around this time.
11 Q Who was in charge of revising it?
12 A I assume White House Counsel's
13 Office.
14 Q How was it revised?
15 A I don't remember, but you could ask
16 the counsel's office what they did.
17 Q Was it revised during the period
18 you were still at the White House?
19 A Oh, I think so, sure. It was
20 revised right around this time.
21 Q From time to time you got inquiries
22 from the press asking how it was revised, did
232
1 you not?
2 A Others did not. I think I answered
3 you specifically I knew they had been
4 revised.
5 Q But you didn't get inquiries from
6 the press about how it was revised?
7 A I might have. I might have said
8 call Jack Quinn.
9 Q Were you not prepared to answer the
10 questions?
11 A I didn't think it was appropriate
12 for me to give the official answer because it
13 was a matter for the White House Counsel's
14 Office.
15 Q Did you buck all the questions over
16 to Jack Quinn?
17 A Generally, or the press secretary,
18 but I probably knew at the time what they
19 were. I simply don't remember what the
20 precise changes were now on March 9th, 1998.
21 Q Did you ever get inquiries from the
22 press asking whether the FBI files that were
233
1 improperly obtained were ever sent back to
2 the FBI?
3 A Again, that wasn't my job.
4 Q But you did get those inquiries?
5 A I didn't say that. If I did, I
6 didn't -- I referred them to the appropriate
7 person who could answer their -- answer with
8 authority.
9 Q You do remember such an inquiry, do
10 you not?
11 A I didn't say that. I said if I
12 did, I would have bucked it to the person who
13 had the appropriate authority to answer.
14 Q Do you remember that inquiry?
15 A No, I don't.
16 Q Do you have any knowledge that FBI
17 files improperly obtained were sent back to
18 the FBI?
19 A I assume they were, but I don't
20 know. I think he said here that they were.
21 Yeah, he says in the letter here.
22 Q I'm asking you.
234
1 A Well, this letter says they were,
2 so I assume they were.
3 Q Where does it say that?
4 A "Freeh said those files have been
5 voluntarily surrendered by the White House to
6 the FBI, including 333 files on June 6; and,
7 following a further query from the FBI,
8 71 more improperly-sought files yesterday,
9 June 13th."
10 Q There are 900 files?
11 A You read that -- you read that to
12 me, but you had to ask me to repeat it back
13 to you. Look who is wasting time.
14 Q I'm entitled to ask you anything
15 that I want that's relevant or which may lead
16 to relevant evidence and the very fact that
17 Freeh says it's so doesn't mean it's so,
18 correct?
19 A Well, but Freeh would certainly be
20 in a better position to know than I would.
21 Q Well, I don't know unless I ask you
22 the question, do I?
235
1 A If you want me to read his press
2 release, I'm happy to do it.
3 Q I'm asking for your knowledge. Do
4 you have any knowledge of those files going
5 back to the FBI?
6 A I have no independent knowledge
7 beyond that. I know that's what's reported
8 in the press, I know that's what Mr. Freeh
9 said in his press release. I assume it to be
10 true.
11 Q Do you know anyone else in the
12 White House who has knowledge of these files,
13 these 400 or so files going back to the FBI?
14 Yes or no?
15 A If a person -- if people at the
16 White House could read this press release or
17 did read this press release or did read the
18 newspaper reports the day after if happened,
19 then they would have that same knowledge.
20 Q But do you have any knowledge the
21 files went back?
22 A I answered that three questions
236
1 ago.
2 Q Does George Stephanopoulos have any
3 knowledge himself that the files were
4 actually sent back?
5 A What does that mean? I answered
6 that.
7 MR. BRAND: It's been asked and
8 answered.
9 BY MR. KLAYMAN:
10 Q Based on your work at the White
11 House. I'm not talking about press reports.
12 MR. BRAND: It's been asked and
13 answered, Larry.
14 BY MR. KLAYMAN:
15 Q Do you know specifically that the
16 files went back?
17 MR. BRAND: It's been asked and
18 answered.
19 MR. KLAYMAN: It wasn't asked that
20 way.
21 MR. BRAND: It's been asked and
22 answered. You can respond.
237
1 THE WITNESS: I read the press
2 reports that said it went back. I believe
3 them.
4 BY MR. KLAYMAN:
5 Q Now, you aware that, in fact,
6 subsequent to this press release it was
7 determined that more than 400 files were sent
8 over from the FBI to the White House; in
9 fact, closer to 900, correct?
10 A If you say so.
11 Q Do you have any knowledge of those
12 other 500 and so files going back from the
13 White House to the FBI, you, George
14 Stephanopoulos?
15 A Yeah, I've read a million things
16 since then. I assumed if they came over,
17 they went back.
18 I did not do an independent
19 investigation. I've never seen an FBI file
20 in my life. I never directed anyone to open
21 one up. I've never looked at one. I don't
22 know why they were collected. The fact that
238
1 they were collected was a mistake.
2 Q Have you ever seen your own FBI
3 file on George Stephanopoulos?
4 A I'd love to, but I haven't.
5 Q Have you ever requested it?
6 A Have you?
7 Q Have you ever requested it?
8 A No.
9 Q Did you ever discuss the FBI files
10 matters with Howard Shapiro?
11 A No.
12 Q Have you ever met Howard Shapiro?
13 A I may have, but I'm not -- I
14 couldn't swear to. I assume I have because
15 he's a friend of Gene Sperling and he might
16 have come through the White House.
17 Q Have you ever discussed the FBI
18 files matter with Larry Potts?
19 A I don't believe I've met Larry
20 Potts.
21 Q Do you know where Larry Potts is
22 working today?
239
1 A I don't actually. Where is he
2 working? Is he still at the FBI?
3 Q I believe he's reported to be
4 working for Mr. Lenzner, the investigator.
5 A Really?
6 Q Are you aware of that?
7 A Didn't know that, no.
8 Q Are you aware that Howard Shapiro
9 is working for Mr. Lenzner, Terry Lenzner?
10 A I've seen his picture in the
11 newspaper.
12 Q Have you had any contact with
13 Mr. Lenzner ever?
14 A Ever?
15 Q Yeah.
16 A Sure.
17 Q When did you meet Mr. Lenzner?
18 A Oh, sometime in -- sometime
19 in 1994, '95 or '96 because his daughter
20 Emily was an intern and assisted my office.
21 Q His daughter Emily was an intern in
22 your office?
240
1 A (Nodding)
2 Q What did she do?
3 A Answer the phones, help prepare my
4 schedule, that of thing.
5 Q She worked with your secretary?
6 A Uh-huh.
7 Q Ms. Capps?
8 A Or I think she actually worked with
9 Heather and I can't remember. She might have
10 had a paying job for a portion of the time as
11 well. I think she did.
12 Q Did she interview with you to get
13 the job?
14 A Uh-huh.
15 Q Was she compensated for that job?
16 A I just answered that. I think she
17 started out as an intern and that turned into
18 a paying job. I couldn't swear to it though.
19 Q Aside from doing your scheduling,
20 she did your filing?
21 A Probably not, photocopying, opening
22 my mail, that kind of thing.
241
1 Q Did she type out documents for you?
2 A I didn't produce any documents, no.
3 Q Did she type out any?
4 A I don't think so, no.
5 Q Did Terry Lenzner ask you to give a
6 job to his daughter?
7 A No.
8 Q I'm not sure how you met
9 Mr. Lenzner and how Emily came to be
10 employed.
11 MR. BRAND: You didn't ask.
12 BY MR. KLAYMAN:
13 Q How did you come to meet
14 Mr. Lenzner?
15 A I think I met him at -- once Emily
16 was working for me, parents come and visit
17 their kids at the White House all the time.
18 I assume that happened. I -- I can swear
19 that I met her mother because I was at her
20 going-away party with her mother. I do
21 remember that.
22 I assume I saw Mr. Lenzner at some
242
1 point, either at a party or on a tour. I
2 couldn't tell you the date or the time.
3 Q Did someone in the White House tell
4 you that we want you to interview Emily
5 Lenzner?
6 A No.
7 Q How did she find her way to your
8 office?
9 A I don't know. My assistant was
10 looking for an assistant. She said Emily is
11 the best one of the people I've looked at. I
12 interview Emily and one or two other people
13 and I thought Emily was terrific and I don't
14 regret at all.
15 Q When did you ultimately meet Terry
16 Lenzner?
17 A I just said I don't remember.
18 Q Have you ever talked to Terry
19 Lenzner about anything related to the White
20 House other than his daughter?
21 A No.
22 Q Did he visit more than once while
243
1 his daughter was working there?
2 A I doubt it.
3 Q You don't remember?
4 A I didn't say that. I said I doubt
5 it.
6 Q Have you ever met with Mr. Lenzner
7 other than having him come to visit his
8 daughter?
9 A No, with the possible exception of
10 maybe I've have been at parties that he was
11 at and we might have said hello. To get to
12 the meat of the matter, I've never discussed
13 the FBI files matter with him at all.
14 Q Did you ever discuss any other
15 White House matter with Mr. Lenzner?
16 A I think I already answered that.
17 Q Have you ever sat in on meetings
18 with White House people or any administration
19 people where Terry Lenzner was present?
20 A No.
21 Q Have you ever had any contact with
22 Mr. Lenzner since you've left the White
244
1 House?
2 A No.
3 Q Are you aware that he's an
4 investigator for Williams & Connolly?
5 A I've read the press reports.
6 Q Have you obtained that information
7 anywhere else?
8 A I already answered your question.
9 Q Did you come upon that information
10 talking with anybody at Williams & Connolly?
11 A No.
12 Q Have you ever seen him at Williams
13 & Connolly?
14 A No.
15 Q Is he a White House ally?
16 A I don't know what that means
17 exactly.
18 Q He is an ally of the White House,
19 isn't he?
20 A You have to ask him.
21 Q In your opinion?
22 A I think he's generally sympathetic
245
1 to the goals of the President, sure.
2 Q The answer is yes?
3 A No, the answer is what I said.
4 Q Are you aware of him conducting
5 investigations into any perceived adversaries
6 of the Clinton administration?
7 A I only know what I've read in the
8 newspapers.
9 Q Have you ever heard of anybody by
10 the name of Jack Palladino?
11 A Sure.
12 Q Have you ever met Mr. Palladino?
13 A Maybe, but I couldn't swear to it.
14 Q Where may you have met him?
15 A I may have met him sometime in the
16 1992 campaign.
17 Q What was he doing at that time?
18 A I don't know exactly.
19 Q What was it your understanding that
20 he was doing?
21 A I've read reports that he was an
22 investigator. It wasn't my area exactly. I
246
1 always mix him up with Pelicano ���� too,
2 and I can't remember which one of the two I
3 met or talked to on the phone.
4 Q What did he do in the 1992
5 campaign?
6 A You have to ask him.
7 Q What was your understanding of what
8 he did?
9 A He might have done some
10 investigating, but I don't have the specific
11 facts of that.
12 Q He did investigating on women who
13 were alleged to have had affairs with the
14 President?
15 A I don't know that. I just answered
16 the question.
17 Q During that 1992 campaign, did you
18 ever deal with that issue at all, the
19 Gennifer Flowers issue or the issue of people
20 who had affairs with the President, as
21 alleged?
22 A Yeah.
247
1 Q What specifically did you do on
2 that issue?
3 MR. BRAND: What relevance does
4 that have to do? You're wasting your own
5 time, Larry, now.
6 BY MR. KLAYMAN:
7 Q You can respond.
8 A As little as possible, but, you
9 know, it was a matter of some controversy in
10 the course of the campaign.
11 Q Was Mr. Palladino hired to look
12 into those other women?
13 A I already answered that question.
14 Q Have you had any contact with
15 Mr. Palladino, since the 1992 campaign?
16 A No.
17 Q Are you aware of anyone who has?
18 A No.
19 Q Are you aware that he has been
20 hired to investigate perceived Clinton
21 adversaries up to the present point in time?
22 A I have seen some newspaper reports
248
1 about that, but I don't know anything beyond
2 that.
3 Q Who paid Mr. Palladino in 1993?
4 A I don't know. I don't know if he
5 got paid to tell you the truth.
6 Q Do you know where Mr. Palladino is
7 located?
8 A No.
9 MS. SHAPIRO: Could we take a quick
10 break?
11 MR. KLAYMAN: Yeah, I got a couple
12 of questions.
13 BY MR. KLAYMAN:
14 Q He's friendly to the White House,
15 isn't he?
16 A I don't know. I don't know him.
17 Q He's not adverse to the Clinton
18 administration that you know if, is he not.
19 A I don't know. I don't him.
20 Q In fact, he's a White House ally,
21 isn't he?
22 A I don't know. I don't know him.
249
1 MR. KLAYMAN: Take a break.
2 VIDEOGRAPHER: This is the video
3 operator. We're going off the record. The
4 time now is approximately 3:28 p.m.
5 (Recess)
6 VIDEOGRAPHER: This is video
7 operator. We're going back on the record.
8 The time now is approximately 3:36 p.m.
9 Mr. Klayman?
10 BY MR. KLAYMAN:
11 Q Mr. Stephanopoulos, how long did
12 Terry Lenzner's daughter work with you at the
13 White House?
14 A I don't remember exactly. It was
15 probably about a year.
16 Q Did you already testify to the
17 dates? I don't want to have you go over
18 that.
19 A I don't remember.
20 Q Do you remember, roughly, what
21 year?
22 A Somewhere between '94 and '96.
250
1 Q Why did she leave?
2 A She wanted to try another job. She
3 moved west I believe.
4 Q Do you know who she went to work
5 for?
6 A I believe she went to work for a
7 television station either in Seattle or
8 Portland.
9 MR. KLAYMAN: I will show you what
10 I will ask the court reporter to mark as
11 Exhibit 6.
12 (Stephanopoulos Deposition
13 Exhibit No. 6 was marked for
14 identification.)
15 BY MR. KLAYMAN:
16 Q I show you Exhibit 6. This is an
17 article that appeared in the Style Section of
18 The Washington Post, March 2nd, 1998,
19 "Private Eye or Public Enemy."
20 Turning your attention to page two,
21 bottom of the page, second column -- this is
22 an article about Terry Lenzner -- where it