DECLARATION OF M. DENNIS SCULIMBRENE

I, M. Dennis Sculimbrene, wish to make the following statement:

  1. I was a 23-year veteran Special Agent of the Federal Bureau of Investigation (FBI). For the last 11 years of my FBI career (1985-1996), I was assigned to The White House where I performed background checks on White House personnel. I was first detailed to The White House in 1980. I thus worked in The White House during 4 separate administrations -- Carter, Reagan, Bush, and Clinton. I was the senior FBI Special Agent in the White House when the Clinton Administration commenced.
  2. A March, 1993 report (Exhibit 1 hereto) memorializes an interview I conducted with White House Counsel Bernard Nussbaum, as part of a background check on Craig Livingstone, Director of the Office of Personnel Security (OPS). The report states in pertinent part:

The following investigation was conducted by SA M. Dennis Sculimbrene regarding DAVID CRAIG LIVINGSTONE on 3/1 -3/99...

BERNARD NUSSBAUM, Counsel to the President, advised that he has known the appointee for the period of time that he has been employed in the new administration. He had come highly recommended to him by HILLARY CLINTON, who has known his mother for a longer period of time....

  1. This report or "insert" is consistent with my standard practice of accurately reflecting and reporting upon investigative interviews in my official FBI reports. Following FBI procedures, which prohibit agents from maintaining notes of interviews (if the information was not derogatory) for more than ninety days, I did not maintain handwritten notes of my interview with Nussbaum.
  2. Because potentially conflicting information was uncovered during the course of Livingstone’s background investigation, I was required by FBI procedures to interview Livingstone several times. During the course of one of these interviews, Craig Livingstone told me of a personal connection between himself, his mother, and Hillary Rodham Clinton. Contemporaneous notes from my 1993 desk calendar corroborate and reflect Livingstone’s account of his relationship to Hillary Clinton. The purpose of making this note was to advise my supervisor.
  3. After completing Craig Livingstone’s background check, Associate White House Counsel William H. Kennedy III called me to his office to discuss Livingstone. Kennedy indicated his personal concerns with Livingstone and asked me for an opinion regarding Livingstone’s continued employment. I offered an opinion, albeit hesitatingly because my obligations did not include making recommendations. I told Kennedy that Jackie Dinwiddie, who had been Director of the White House Office of Personnel Security during the Carter Administration (then known as the Security Office), was interested in Livingstone’s position. Kennedy inferred to me that he was "stuck" with Craig Livingstone as Director of OPS. I inferred that Mrs. Clinton wanted Livingstone for the position.
  4. In early March, 1993, William H. Kennedy, David Watkins (Director of White House Management and Administration) and Jeff Eller (Deputy White House Communications Director) attempted to question me about the backgrounds and political views of the staff of the White House Travel Office. Because the Privacy Act prohibited me from revealing information about specific persons, I advised Kennedy, Eller, and Watkins that, based upon my memory of previous background investigations, I was not aware of any derogatory information about any persons employed in the White House Travel Office.
  5. I notified my supervisor about being questioned by Kennedy, Eller and Watkins. I suggested to my supervisor that The Clinton White House was looking for an excuse to fire the Travel Office employees and that the FBI would be "used" to provide an excuse. Travel Office employees were fired May 19, 1993.
  6. It had been a long-standing policy that FBI agents detailed to The White House interact routinely with OPS personnel. Beginning with the Reagan Administration, I also had a mail box in OPS, where I would receive copies of requests for FBI background investigations sought by OPS. This procedure avoided unnecessary investigations sought by OPS. In May, 1993 I was advised that the long-standing White House policy of providing me with "courtesy" copies of requests for FBI background files was to be ended and that I was to avoid liaison activity with OPS. My mail box in OPS was no longer used. The practice of providing me with copies of OPS requests for FBI background files would not be resumed until late fall-early winter of 1994. During the time from May, 1993 to late fall-early winter, 1994, I understand that hundreds of FBI files were improperly requested by The Clinton White House. If standard prior procedure had been followed, I would have been informed, through documents at least, that the FBI files of former Reagan and Bush staffers and others were being improperly requested during this time period.
  7. During Craig Livingstone’s tenure as OPS director, particularly during the first year, there were instances when I observed the OPS office unoccupied and the door to its vault, which contained FBI files and other confidential government information, wide open. During Livingstone’s tenure as OPS Director, I complained to my supervisors about the management of OPS, delays in the clearance process for White House employees and the fact that many persons, including employees, were being given access to The White House complex without proper passes.
  8. I testified truthfully at Billy Ray Dale’s "Travelgate" trial in November, 1995 – a trial which resulted with Mr. Dale being acquitted. Part of my testimony detailed how, after the Travelgate controversy had broken, I had witnessed unknown individuals in the Travel Office going through files and throwing items away, some of which appeared to be official documents.
  9. Shortly before I testified in the Dale Trial, White House Presidential Personnel requested that I submit my name as a candidate for Inspector General of Veteran’s Administration. My name was officially submitted. Shortly after I testified as a Defense witness for Billy Dale, former director of the White House Travel Office, I was advised that I was no longer a viable candidate. Furthermore, I became the subject of an investigation of the Federal Bureau of Investigation’s (FBI) Office of Professional Responsibility Inquiry (OPR) based on one anonymous letter which was officially discredited. I was so emotionally distraught that I had to take two weeks sick leave because of my emotional reaction to this unwarranted and baseless investigation.
  10. When I returned, I attempted an informal discussion with my new supervisor. I requested that informal reasonable accommodations granted in October 1994 when I returned to work after a skull fracture in January 1994 be continued at that time. At the time of the informal discussion with my new supervisor (in April, 1996), I still I suffered from cognitive and physical deficits. Yet the consequence of this conversation was not the continuance of the informal reasonable accommodation for my medical condition, but the removal of all work assignments, on April 24, 1996.
  11. Press reports were leaked about my testimony with the U.S. Senate Judiciary Committee, in late June, 1996. One of the questions asked of me pertained to my assignment at the time. I answered truthfully that I had none. The FBI had not assigned me any work since April. After my testimony, they attempted to assign me work that conflicted with the recommendation of their own psychologist.
  12. On June 28, 1996, my White House Pass was canceled, without written reason, although I requested such. My supervisor at the time verbally advised that my pass was being revoked for my own safety and because my presence "made the First Family uncomfortable." I would note that a request by The White House for a background reinvestigation regarding myself was made after I was removed from The White House.
  13. I have no other explanation for the events that I have witnessed and been subjected to other than retaliation for my testimony at the Dale Trial and unwillingness to change truthful testimony that, among other things, links First Lady Hillary Clinton to the hiring of Craig Livingstone and Filegate.
  14. On July 16, 1996, two FBI agents arrived at my home. The FBI agents began to question me about the three-year-old insert (Exhibit 1) memorializing my interview with Bernard Nussbaum. During the course of the interview, the FBI agents asked me approximately thirty times if I had any notes of my three-year-old interview with Bernard Nussbaum. I repeatedly informed them that I had not maintained these notes, as per FBI procedures.
  15. Also during the course of the interview, the FBI agents repeatedly told me that President Clinton, Hillary Rodham Clinton and former White House Counsel Bernard Nussbaum had contradicted my three-year-old insert (Exhibit 1). The FBI agents pitted my credibility against the credibility of President Clinton, Hillary Rodham Clinton and White House Counsel Bernard Nussbaum approximately four times. While the stated purpose of the interview was to "clarify" certain issues, my efforts to provide clarification were rebuffed by the FBI agents. Based on their actions and on my experience as a law enforcement officer, I felt the FBI agents were sent to my home and attempted to intimidate me.
  16. Based on my experience as a FBI agent, and on my considerable training in security matters, it is considered a violation of established law and procedure to remove an individual’s FBI background file, summaries, or raw data from government premises.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on August ___, 1999 _____________________________

M. Dennis Sculimbrene