1
1 UNITED STATES DISTRICT COURT
DISTRICT OF COLUMBIA
2
-------------------------x
3 CARA LESLIE ALEXANDER :
et al., :
4 Plaintiffs, :
:
5 :
v. : Civil No. 96-2123 (RCL)
6 :
FEDERAL BUREAU OF :
7 INVESTIGATION et al., :
:
8 Defendants :
-------------------------x
9 MICHAEL JOHN GRIMLEY :
et al., :
10 :
Plaintiffs, :
11 :
v. : Civil No. 97-1288 (RCL)
12 :
FEDERAL BUREAU OF :
13 INVESTIGATION et al., :
:
14 Defendants. :
-------------------------x
15 Washington, D.C.
16 Thursday, May 7, 1998
17 Deposition of
18 MARI LYNNE ANDERSON
19 a witness, called for examination by counsel
20 for Defendants pursuant to notice and
21 agreement of counsel, beginning at
22 approximately 9:38 a.m. at the offices of the
2
1 United States Department of Justice, 901 E
2 Street N.W., Washington, D.C., before Joan V.
3 Cain, notary public in and for the District
4 of Columbia, when were present on behalf of
5 the respective parties:
6 APPEARANCES:
7 On behalf of Plaintiffs:
8 LARRY KLAYMAN, ESQUIRE
Judicial Watch
9 501 School Street S.W., Suite 725
Washington, D.C. 20024
10 (202) 646-5172
11
On behalf of Defendants Executive Office of
12 the President, Federal Bureau of
Investigation:
13
TIMOTHY P. GARREN, ESQUIRE
14 JAMES J. GILLIGAN, ESQUIRE
ELIZABETH J. SHAPIRO, ESQUIRE
15 DIANNE SPELLBERG, ESQUIRE
Federal Programs Branch
16 Civil Division
United States Department of Justice
17 901 E Street N.W., Room 988
Washington, D.C. 20530
18 (202) 514-5302
19 JON PIFER, ESQUIRE
Federal Bureau of Investigation
20 935 Pennsylvania Avenue N.W.
Washington, D.C.
21 (202) 514-3358
22
3
1 APPEARANCES (CONT'D):
2 On behalf of Defendant Hillary Rodham
Clinton:
3
PAUL B. GAFFNEY, ESQUIRE
4 Williams & Connolly
725 Twelfth Street N.W.
5 Washington, D.C. 20005
(202) 434-5803
6
On behalf of Defendant Livingstone:
7
DAVID S. COHEN, ESQUIRE
8 Miller Cassidy Larroca & Lewin, L.L.P.
2555 M Street N.W.
9 Washington, D.C. 20037-1302
(202) 833-6503
10
On behalf of Defendant Nussbaum:
11
ROBERT B. MAZUR, ESQUIRE
12 Wachtell Lipton Rosen & Katz
51 West 52nd Street
13 New York, New York 10019-6618
(212) 403-1000
14
On behalf of The White House:
15
SALLY PATRICIA PAXTON, ESQUIRE
16 Special Associate Counsel to the President
The White House
17 Washington, D.C. 20500
(202) 456-5079
18
19
20 * * * * *
21
22
4
1 C O N T E N T S
2 EXAMINATION BY: PAGE
3 Counsel for Defendants 8
4 Counsel for Plaintiffs 177
5 FURTHER EXAMINATION BY:
6 Counsel for Defendants 426
7 ANDERSON DEPOSITION EXHIBITS:
8 No. 1 - FBI Liaison Request Form 65
9 No. 2 - Green-Striped Paper 89
10 No. 3 - Gemmell Declaration, 104
Attachment
11
No. 4 - White House Operations 157
12 Personnel List
13 No. 5 - Senate Judiciary Committee 194
Testimony Transcript
14
No. 6 - Fact Sheet, Attachment 220
15
No. 7 - Redacted FBI Liaison Requests 266
16
No. 8 - Visitation Logs 295
17
No. 9 - Letter, Freeh to Livingstone, 333
18 Attachments
19 No. 10 - Investigation Report 340
20 No. 11 - White House Personnel 364
Security Files Staff List
21
22
5
1 ANDERSON DEPOSITION EXHIBITS (CONT'D): PAGE
2 No. 12 - Memorandum, Kennedy to Hilty, 369
Attachment
3
No. 13 - Background Investigation 382
4 Check-Out Log
5
6 * * * * *
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
6
1 P R O C E E D I N G S& Connolly, for Mrs. Clinton.
12 MR. MAZUR: Robert Mazur for
13 Bernard Nussbuam.
14 MS. SHAPIRO: Elizabeth Shapiro for
15 the EOP and FBI.
16 MR. KLAYMAN: Larry Klayman for
17 Judicial Watch.
18 MR. FITTON: Tom Fitton, legal
19 assistant for Judicial Watch.
20 MR. MARINBERG: Dan Marinberg,
21 legal assistant for Judicial Watch.
22 THE VIDEOGRAPHER: Will the witness
8
1 please be sworn?
2 Whereupon,
3 MARI ANDERSON
4 was called as a witness and, having been
5 first duly sworn, was examined and testified
6 as follows:
7 EXAMINATION BY COUNSEL FOR DEFENDANTS
8 BY MR. GARREN:
9 Q Now, Ms. Anderson, before we get
10 started today, I'd like to give you just a
11 few instructions about the process. Your
12 deposition is being taken today in this case
13 entitled Alexander v. FBI. This deposition
14 is just an opportunity for the assembled
15 masses here today to take your testimony
16 about the matter under oath. Do you
17 understand?
18 A Yes.
19 Q Now, when your deposition is taken,
20 your testimony will be sworn and under oath.
21 It can be used in the eventual trial of the
22 proceeding, so it is very important, since
9
1 your testimony is under oath and can be used
2 in the case, that you answer truthfully and
3 directly to the questions presented to you.
4 Do you understand that?
5 A Yes.
6 Q Now, if you have any questions
7 about any question put to you, if there's
8 anything confusing about it, please speak up.
9 A I will.
10 Q Let us know that you have a
11 question about it. Don't speculate about
12 what it may be that we're trying to ask you.
13 If you don't understand what we're asking
14 you, please speak up, and I will be very
15 happy to rephrase the question or clarify
16 anything that's confusing to you.
17 Understand?
18 A Yes.
19 Q If at any time in the course of the
20 proceeding you become distracted or you need
21 to take a break for any reason, please speak
22 up and we'll take a break.
10
1 A I will.
2 MR. KLAYMAN: Before you go on let
3 me just put a few things on the record as
4 long as you're in the instructional mode
5 here. We have a continuing objection to the
6 participation of Ms. Paxton in this
7 proceeding and that's a matter before the
8 court. You may proceed.
9 BY MR. GARREN:
10 Q Please state your full name for the
11 record, Ms. Anderson.
12 A Mari Lynne Anderson.
13 Q And where do you reside?
14 A I reside 9585 Juniper Street,
15 Apartment 4319, Atlanta, Georgia.
16 Q And how long have you resided in
17 Atlanta, Georgia?
18 A How long have I resided in Atlanta,
19 Georgia, or how long at that residence?
20 Q How long have you resided in
21 Atlanta, Georgia?
22 A In Atlanta, Georgia, since the
11
1 summer of '95.
2 Q You've resided there continuously
3 since the summer of '95?
4 A Yes.
5 Q Now, Ms. Anderson, I'd like you to
6 basically summarize your educational
7 background beginning with college.
8 A Graduated from the University of
9 Georgia in, I believe, 1991 in June. I then
10 went to paralegal school thinking I was going
11 to be an attorney. That's not going to
12 happen. Then I am now currently enrolled at
13 Georgia State University.
14 Q Now, you mentioned you graduated
15 from the University of Georgia in 1991. Did
16 you receive a degree from the University of
17 Georgia?
18 A Bachelor's of Art in political
19 science.
20 Q And when did you start paralegal
21 school?
22 A After graduation. I believe it was
12
1 in the fall, but I could be mistaken.
2 Q The fall after you --
3 A The fall of '91, but I could be
4 mistaken. I believe it was the fall.
5 Q Did you complete paralegal school?
6 A With honors.
7 Q And where did you go to paralegal
8 school?
9 A I don't remember the name of the
10 school. It was the National Paralegal
11 Institute or something like that.
12 Q And where was it located?
13 A Atlanta, Georgia.
14 Q You mentioned you're currently at
15 Georgia State University; is that correct?
16 A Yes.
17 Q And are you in an undergraduate
18 program there?
19 A Currently.
20 Q And what's the nature of that
21 program?
22 A Marketing.
13
1 Q And when do you expect to graduate?
2 A This coming spring.
3 Q Now, let me ask you to summarize
4 your work history post-graduation from the
5 University of Georgia.
6 A Worked at a law firm, Jenkins &
7 Eells, since dissolved and then went to
8 Little Rock. From there I went to
9 Washington, D.C., and worked on the inaugural
10 committee in 1992 and then went to The White
11 House when the inaugural was finished.
12 Q Let's go back through that a little
13 bit. When you graduated from University of
14 Georgia, you worked for a law firm; is that
15 correct?
16 A After the paralegal school.
17 Q And what law firm was that?
18 A Jenkins & Eells.
19 Q And where is that located?
20 A It's no longer. It's now defunct,
21 but it was in Atlanta, Georgia.
22 Q And do you remember generally what
14
1 your dates of employment were at Jenkins &
2 Eells?
3 A I have no earthly idea. I know it
4 was after my first degree, but I specifically
5 do not remember.
6 Q And did you do paralegal kind of
7 work for Jenkins & Eells?
8 A I did filing, serving of summonses,
9 and stuff like that.
10 Q You mentioned in 1992 you went to
11 Little Rock; is that right?
12 A Yes.
13 Q Why did you go to Little Rock?
14 A I thought that I was going -- I was
15 planning on going to law school and that I
16 might want to get into politics.
17 Q You were contemplating going to law
18 school in Little Rock?
19 A No. The politics is what I was
20 contemplating.
21 Q Now, did you subsequently work on
22 the Clinton campaign in 1992?
15
1 A Yes.
2 Q Tell me how you obtained a position
3 with the Clinton campaign in 1992.
4 A I obtained a position -- I had a
5 name, and I went and I called that name and
6 began volunteering.
7 Q And how did you get the name?
8 A From Craig Livingstone.
9 Q And what was the name that you had?
10 A James Day.
11 Q Do you remember when you started
12 volunteering for the campaign?
13 A I believe it might have been either
14 June or July. Specifically, I'm not certain.
15 It may have been August.
16 Q And did you stay with the campaign
17 throughout the campaign until the election?
18 A Yes.
19 Q Now, did you have a paying position
20 with the Clinton campaign?
21 A Not initially.
22 Q When, if ever, did you obtain a
16
1 paying position?
2 A A week before the election.
3 Q So, except for the week before the
4 election, it was all volunteer work; is that
5 correct?
6 A Yes.
7 Q What was the nature of the work
8 that you did for the Clinton campaign?
9 A I primarily worked with the advance
10 office for -- at that time Senator Gore
11 working with his correspondence and archiving
12 the day trips, the schedules, and stuff like
13 that.
14 Q Now, you mentioned that you had a
15 name and you called this James Day; is that
16 correct?
17 A Yes.
18 Q And you mentioned that Craig
19 Livingstone played some role in that?
20 A Yes.
21 Q Could you explain that further?
22 A In 1998 -- I'm sorry, 1988 -- when
17
1 I was still an undergrad at the University of
2 Georgia, I -- when the National Democratic
3 Convention was in Atlanta, did sort of an
4 internship there, and they had put me in
5 Chairman Kirk's office where I had met Craig
6 Livingstone. When the convention had ended,
7 he said if you ever want to get into politics
8 give me a call and gave me a card and
9 ultimately I gave him in a call in the summer
10 of '92.
11 Q Where was he at that time?
12 A Ross Perot campaign.
13 Q Craig Livingstone was working for
14 the Ross Perot campaign at the time that you
15 called him?
16 A That was my understanding.
17 Q And he mentioned someone to you
18 that you could call to volunteer for the
19 Clinton campaign?
20 A No.
21 Q Explain further how that happened.
22 A He said he would try and get me on
18
1 with the Ross Perot campaign and then
2 Mr. Perot announced that he was pulling out
3 of the presidential race and the next time I
4 talked to Craig he said he was going to
5 Little Rock and he was going to be doing the
6 advance school for the Clinton/Gores, and he
7 would try and get me in. That did not happen
8 and he said or, if you want, here's the name
9 James Day.
10 Q And you called Mr. Day?
11 A Yes.
12 Q And what happened there?
13 A He said if I wanted I could -- I
14 went to Little Rock, and I spoke to him and
15 he said if I wanted I could do some volunteer
16 work, but he couldn't promise anything.
17 Q Now, after the election in 1992,
18 where did you next work?
19 A After the election I came up to
20 D.C. and worked for the Airline Pilots
21 Association for a few days and then worked at
22 the inaugural committee.
19
1 Q And the Airline Pilots Association,
2 was that a temporary position?
3 A Yes.
4 Q And then you mentioned you work for
5 the inaugural committee; is that right?
6 A Yes.
7 Q Do you recall when you went to work
8 for the inaugural committee?
9 A Specific date, no, but I believe it
10 was right before that Thanksgiving.
11 Q And did you stay with the inaugural
12 committee through the inauguration?
13 A Yes.
14 Q So approximately from right before
15 Thanksgiving until January 20; is that
16 correct?
17 A No, until mid-February.
18 Q And what was the nature of the work
19 that you did for the inaugural committee?
20 A I was staff assistant for the
21 security office.
22 Q Did you work with Mr. Livingstone?
20
1 A Yes.
2 Q And what did you do with
3 Mr. Livingstone? What kind of work did you
4 perform with him?
5 A I was staff assistant and basically
6 helped other members in the office and
7 ultimately became responsible for making sure
8 that those who needed to a pass to the
9 inaugural headquarters had one, working in
10 conjunction with the federal police at that
11 location.
12 Q Now, after the inaugural, where did
13 you next work?
14 A The White House.
15 Q And what kind of job did you obtain
16 with The White House?
17 A Initially staff assistant.
18 Q Staff assistant with what office?
19 A White House -- Office of White
20 House Personnel Security.
21 Q And how did you obtain that job?
22 A Craig Livingstone offered it to me.
21
1 Q Do you recall approximately when
2 that offer was made?
3 A Approximately the last week that I
4 was working at the inaugural committee.
5 Q And what were your approximate
6 dates of employment with The White House
7 Office of Personnel Security?
8 A Approximately February of '93
9 through August/September of '94.
10 Q And did you have a job title during
11 your employment with the Office of Personnel
12 Security?
13 A Executive assistant.
14 Q Were you executive assistant
15 initially when you started with the office?
16 A No.
17 Q What was your first position?
18 A As stated before, staff assistant.
19 Q And approximately how long after
20 you started did you become the executive
21 assistant?
22 A When Nancy Gemmell departed The
22
1 White House.
2 Q And do you recall approximately
3 when that was?
4 A I believe that was August of '93.
5 Q And did you remain executive
6 assistant until you left the Office of
7 Personnel Security?
8 A Yes.
9 Q Now, what was the nature of your
10 general job duties with the Office of
11 Personnel Security?
12 A Office manager and just
13 facilitating the processing of White House
14 employees and those who needed access to The
15 White House.
16 Q And what was your approximate
17 salary during that period of time, when you
18 were working with the Office of Personnel
19 Security?
20 A Average I would say was probably
21 about 28.
22 Q 28,000?
23
1 A Yes.
2 Q A year?
3 A Yes.
4 Q Now, you mentioned you left in
5 September of '94; is that correct?
6 A Yes.
7 Q And why did you leave that
8 position?
9 A I had decided that politics was not
10 really what I wanted to continue doing with
11 the rest of my life and nor was security, and
12 I wanted to move on.
13 Q What job did you take after you
14 left the Office of Personnel Security?
15 A After I left the Office of
16 Personnel Security, I did some advance work
17 for Senator -- I'm sorry -- Vice President
18 Gore, and I did that off and on for about a
19 year after until I figured out what I wanted
20 to do.
21 Q What was the nature of the advance
22 work that you would do for Vice President
24
1 Gore?
2 A When there was an event, they would
3 select a team to go to the various cities to
4 set up his appearance or what was going to
5 happen in that city.
6 Q And what would you do?
7 A Mostly motorcade.
8 Q Was this a continuous job that you
9 had with the Vice President's office, or what
10 was the nature of how you were assigned work
11 in that job?
12 A It was not continuous. What would
13 happen is I would either call them or they
14 would call me and they would say we have a
15 trip, can you fit it into your schedule or
16 can you do this trip?
17 Q And how were you paid for that?
18 A Per diem.
19 Q What do you mean, per diem?
20 A It was paid through the National
21 Democratic Committee, and it would be $30 a
22 day.
25
1 Q Since you mentioned that you left
2 the Office of Personnel Security because you
3 wanted to leave politics and pursue another
4 line of work, why did you go to work for Vice
5 President Gore?
6 A As I stated earlier, I hadn't yet
7 figured out what exactly I wanted to do, and
8 I needed some time to figure that out.
9 Q Do you recall approximately how
10 many trips you made during the period of time
11 that you were working for Vice President
12 Gore?
13 A No.
14 Q Now, you mentioned you worked for
15 Vice President Gore in that capacity assigned
16 jobs for approximately a year; is that
17 correct?
18 A Off and on. It wasn't continuous.
19 Q But you did this for how long?
20 What was the general period of time?
21 A Primarily the fall and winter is
22 when I did that.
26
1 Q What was the next job that you had
2 after leaving that job?
3 A After leaving that job, I moved to
4 Atlanta and was trying to get on with the
5 Olympics, which I achieved in 1996. I
6 believe it was May.
7 Q Do you recall the approximate date
8 that you went back to Atlanta?
9 A That would have been, I believe,
10 September of '95.
11 Q And when you got back to Atlanta,
12 you pursued a job with the Atlanta Olympic
13 Committee; is that correct?
14 A Yes.
15 Q How long did it take you to get a
16 job with the Atlanta Olympic Committee?
17 A Until May of '96.
18 Q What was the nature of the job you
19 had with Atlanta Olympic Committee?
20 A Initially I was bus coordinator and
21 then became assistant manager for venue and
22 transportation.
27
1 Q Now, did anyone from The White
2 House assist you in any way with getting a
3 job with the Atlanta Olympic Committee?
4 A No.
5 Q And you worked for the committee
6 for how long?
7 A Until I believe it was mid-August
8 of '96.
9 Q That was right after the Olympics
10 ended; is that right?
11 A Yes.
12 Q What did you do after you completed
13 that job?
14 A Answered questions for Independent
15 Counsel.
16 Q What was your next employment?
17 A I have none. Oh, I'm sorry.
18 Currently, I have an internship with Melissa
19 Libby & Associates in Atlanta.
20 Q After you finished with the Atlanta
21 Olympic Committee job, shortly thereafter did
22 you start back to school?
28
1 A In January of '97.
2 Q And is that when you started back
3 to Georgia State University?
4 A Yes.
5 Q And you're still at Georgia State
6 University, you testified?
7 A Yes.
8 Q And do you work part-time while you
9 go to school?
10 A This quarter I am.
11 Q And tell me about the nature of
12 that job.
13 A Melissa Libby & Associates, it's an
14 internship for a public relations firm that
15 deals with restaurants.
16 Q And where is this job located?
17 A Atlanta, Georgia.
18 Q Now, Ms. Anderson, I want you to
19 focus your attention on your employment with
20 The White House Office of Personnel Security.
21 During your time with the Office of Personnel
22 Security, who was the director of the office?
29
1 A Craig Livingstone.
2 Q You mentioned you were there from
3 approximately February of '93 till September
4 of '94; is that correct?
5 A Yes.
6 Q That's approximately 19 months; is
7 that right?
8 A I don't know the calculation but,
9 yes.
10 Q During that entire time that you
11 were there, was Craig Livingstone always the
12 director of the office?
13 A Yes.
14 Q What was the position you had
15 initially with the office?
16 A Staff assistant.
17 Q And then you moved up to another
18 position?
19 A Executive assistant.
20 Q And that transition took place
21 approximately how many months after you
22 started working there?
30
1 A About seven to eight. I'm not sure
2 but I think seven to eight.
3 Q During your time with the office,
4 were there other staff assistants in the
5 office?
6 A Yes.
7 Q How many other staff assistants
8 were usually in the office during your
9 employment there?
10 A On average the whole time or when I
11 left?
12 Q On average the whole time.
13 A One.
14 Q Now, were there other people
15 detailed to the office from other agencies
16 within the federal government?
17 A Yes.
18 Q How many detailees were in the
19 office during your tenure in the office?
20 A One.
21 Q Who was that?
22 A Tony Marceca.
31
1 Q Were there interns assigned to the
2 office during your tenure with the office?
3 A Yes.
4 Q And during your tenure there how
5 many interns were assigned to the office? Do
6 you recall?
7 A Approximately five or six.
8 Q Do you recall their names?
9 A Melissa Evantas, Anthony Aoudi,
10 Erin Bertucci, Ed Hughes, Lisa Wetzel, and I
11 believe that's all. I can't remember others
12 -- oh, Gina Gibson.
13 Q Were these interns all there at the
14 same time or did they overlap or how did that
15 work?
16 A They were not all there at the same
17 time, and there was another one, Luis, but I
18 don't remember his last name. But they would
19 come in quarterly or semester shifts as their
20 schedules allowed.
21 Q Were there volunteers in the office
22 on occasion during your tenure with the
32
1 Office of Personnel Security?
2 A Initially.
3 Q How many volunteers were there
4 during your tenure that you can recall?
5 A Two.
6 Q And who was that?
7 A Steve Pollack and the second one
8 was Kara Gerhardt.
9 Q Were they both there at the same
10 time or were they there at different times?
11 A I'm not sure if they were there at
12 the same time or not. I know Steve was there
13 initially. Maybe Carol worked one day with
14 him, but she wasn't in the office that much.
15 Q Now, considering employees of the
16 office, the detailees, interns, volunteers,
17 on average how many people would be assigned
18 to the office at any given day during your
19 tenure in the office?
20 A On average approximately four.
21 Q What would you say was the largest
22 number of people who were assigned to the
33
1 office on any given time during your tenure
2 with the office?
3 A Maybe six.
4 Q And what was the least number that
5 was ever there during your tenure with the
6 office?
7 A Three.
8 Q Now, I want you to basically
9 describe the physical structure in which the
10 Office of Personnel Security was located.
11 Where was the office?
12 A Ground floor of the Old Executive
13 Office Building.
14 Q And basically, what was the size of
15 the office? Describe the office.
16 A The office was approximately 20 by
17 20 feet. It had six desks, maybe initially
18 the old Wang computer and then another
19 desktop computer, initially. Ultimately,
20 there was an additional computer.
21 Q Was there a vault room attached to
22 the office?
34
1 A Yes, there was. It was a sealed
2 skiff that only office members had the
3 combination to, office staff.
4 Q And how would you enter the vault?
5 Could you enter the vault without going into
6 the Office of Personnel Security?
7 A No.
8 Q So you had to enter it from inside
9 the Office of Personnel Security; is that
10 correct?
11 A Yes.
12 Q How large is the vault, during your
13 tenure there?
14 A With or without the ferris wheel
15 files?
16 Q Without the ferris wheel files.
17 A I would say a little bit smaller
18 than the office, maybe 18 by 18.
19 Q And how much of that distance did
20 ferris wheel files take up?
21 A I would say probably a third.
22 Q Did people during your tenure in
35
1 the office, that is, the employees assigned
2 to the office, have separate offices within
3 the Office of Personnel Security?
4 A No.
5 Q Did people have separate cubicles?
6 A There were no physical cubicles,
7 but there were partitions.
8 Q Describe the partitions that
9 existed?
10 A Basically, they were about four by
11 six feet tall blocks that were just put in
12 front of the desks, my desk and Craig's desk,
13 so that my desk -- when you opened the door,
14 it swung inward and my desk was the desk that
15 you would see, so we put up a partition
16 there, and we put up a partition in front of
17 Craig's desk so that he could have some
18 privacy.
19 Q Was your desk located inside a
20 cubicle?
21 A No, it was located behind the
22 partition.
36
1 Q Was Mr. Livingstone's desk located
2 inside a cubicle?
3 A No.
4 Q Now, from your desk in the Office
5 of Personnel Security, could you see other
6 people in the office?
7 A Yes.
8 Q What other desks could you see in
9 the office?
10 A I could see Ed Hughes's desk and
11 Tony Marceca's desk. I could see Craig's
12 desk -- I could see half of the office. I
13 could not see Lisa's desk.
14 Q So on a daily basis when you're
15 sitting at your desk you could look across
16 the room and see Mr. Livingstone?
17 A Yes.
18 Q Is that also true with respect to
19 Mr. Marceca?
20 A Yes.
21 Q What was the distance between your
22 desk and Mr. Livingstone's desk,
37
1 approximately?
2 A I would say approximately ten feet.
3 Q And approximately what was the
4 distance between your desk and Mr. Marceca's
5 desk when he was in the office?
6 A Four to five feet, but I'm not
7 exactly sure of the distance.
8 Q Now, were Mr. Livingstone and
9 Mr. Marceca within earshot so that you could
10 hear them where they were at their desk?
11 A The whole office was in earshot of
12 everybody.
13 Q When Mr. Livingstone was on the
14 telephone, could you hear him on the
15 telephone?
16 A Yes.
17 Q Was that also true with
18 Mr. Marceca?
19 A Yes.
20 Q Was it a fairly regular experience
21 in the office that you could overhear each
22 other talking on the telephone?
38
1 MR. KLAYMAN: Objection. Leading.
2 BY MR. GARREN:
3 Q You can answer the question.
4 A Yes.
5 Q Would you say that there was much
6 opportunity for privacy in the office during
7 your tenure there?
8 A No.
9 MR. KLAYMAN: Objection. Vague and
10 ambiguous.
11 BY MR. GARREN:
12 Q During your tenure in the office,
13 did everyone employed by the office have
14 separate telephone lines?
15 A No.
16 Q Tell me the nature of the telephone
17 lines that existed in the office during your
18 tenure there.
19 A Initially, probably the first year
20 that I worked there, we had those Nixonian-
21 age phones where they were the old phones
22 that had the big inch-diameter cord coming
39
1 out of the back that you had to do the -- you
2 had to press down the button to pick up the
3 line, and the little light would go on.
4 To put somebody on hold, you had
5 the big red button, and there were only two
6 lines that went to every phone in the office.
7 Q So there were only two incoming
8 lines with separate telephone numbers when
9 you first began working in the office?
10 A If I remember correctly, yes.
11 Q Did that change later?
12 A Yes.
13 Q Describe how it changed?
14 A Ultimately, The White House
15 received a new phone system. I believe it
16 was AT&T. I'm not sure. And it was -- I
17 don't remember how many lines we had coming
18 into the office. I believe it might have
19 been four; it could have been more, and we
20 all had voice mail.
21 Q Approximately how long after you
22 started at the office did that change take
40
1 place?
2 A About a year later, maybe earlier,
3 maybe later.
4 Q So for the first year when you were
5 in the office there were only two telephone
6 lines going into the office; is that correct?
7 A Approximately, yeah.
8 Q Now, let me ask you about
9 Mr. Livingstone. You mentioned that
10 Mr. Livingstone was the director of the
11 Office of Personnel Security throughout your
12 tenure there; is that accurate?
13 A Yes.
14 Q When did you first meet
15 Mr. Livingstone?
16 A As I stated before, when I did an
17 internship type thing in 1988 at the Atlanta
18 -- the National Convention of the Democratic
19 Committee in Atlanta.
20 Q And how well did you get to know
21 Mr. Livingstone during that period of time?
22 A Not very well. We were in and out
41
1 of the same office.
2 Q Was he much more than an
3 acquaintance during that period of time?
4 MR. KLAYMAN: Objection. Vague and
5 ambiguous.
6 THE WITNESS: No.
7 BY MR. GARREN:
8 Q Now, you mentioned that at a later
9 date, in 1992, when you decided that you
10 wanted to volunteer for the Clinton campaign,
11 that you gave Mr. Livingstone a telephone
12 call; is that correct?
13 A Yes.
14 Q Now, between those times, that is,
15 between the time that you worked for the
16 Democratic National Committee in 1988 and the
17 time when you called Mr. Livingstone in 1992,
18 were you in routine contact with
19 Mr. Livingstone?
20 MR. KLAYMAN: Objection. Vague and
21 ambiguous.
22 THE WITNESS: No.
42
1 BY MR. GARREN:
2 Q How often between 1988 Democratic
3 National Convention in Atlanta and 1992 would
4 you say that you spoke to Mr. Livingstone?
5 A None, to my memory.
6 Q So the first contact that you had
7 with Mr. Livingstone after the Democratic
8 convention in 1988 was your contact in 1992
9 about volunteering for the Clinton campaign;
10 is that right?
11 A Yes.
12 Q Now, was Mr. Livingstone your
13 immediate supervisor in the Office of
14 Personnel Security?
15 A Yes.
16 Q You mentioned at some point,
17 approximately August of '93, you became the
18 executive assistant in the office; is that
19 correct?
20 A Yes.
21 Q When you became the executive
22 assistant in the office, were you the
43
1 number-two person in the office?
2 A Yes.
3 Q If Mr. Livingstone was out of the
4 office, were you the boss in the office?
5 A Quasi, yes.
6 Q During your time with the Office of
7 Personnel Security, did you work closely with
8 Mr. Livingstone?
9 A Define "closely."
10 Q Did you work with him generally on
11 a daily basis?
12 A In the same office, yes.
13 Q And did you feel that you were in a
14 good position to observe his work activities
15 in the office?
16 MR. KLAYMAN: Objection. Vague and
17 ambiguous. Lacks foundation.
18
19 BY MR. GARREN:
20 Q You can answer the question.
21 A Yes.
22 Q At any time during your work in the
44
1 Office of Personnel Security, did you see or
2 hear anything that suggested to you that
3 Mr. Livingstone might be involved in some
4 sort of political conspiracy to obtain
5 confidential information on prior
6 administration employees?
7 MR. KLAYMAN: Objection.
8 Multi-compound question. Lacks foundation.
9 Vague and ambiguous. Leading.
10 BY MR. GARREN:
11 Q And you can answer the question.
12 A No.
13 MR. KLAYMAN: Other than that, it's
14 a great question.
15 MR. GARREN: I'm glad you liked the
16 question.
17 BY MR. GARREN:
18 Q At any time during your tenure with
19 the Office of Personnel Security, did you
20 hear or see anything that suggested to you
21 that Mr. Livingstone had any desire or
22 intention to misuse the personnel security
45
1 files held by the Office of Personnel
2 Security?
3 MR. KLAYMAN: Objection. Vague and
4 ambiguous. Lacks foundation. Leading and
5 vague.
6 BY MR. GARREN:
7 Q Do you understand the question?
8 A Yes.
9 Q And what's your answer to the
10 question?
11 A No. I'm assuming you were asking
12 me if I saw any signs of a conspiracy?
13 Q The first question was did you see
14 any signs of a conspiracy?
15 A No.
16 MR. KLAYMAN: Same objection.
17 BY MR. GARREN:
18 Q The second question is did you ever
19 see any signs that Mr. Livingstone intended
20 or desired to misuse the security files of
21 the office?
22 MR. KLAYMAN: Same objection.
46
1 THE WITNESS: No. Same answer.
2 BY MR. GARREN:
3 Q Now, Ms. Anderson, are you aware of
4 Mr. Livingstone or any member of his family
5 having any type of friendship with the First
6 Lady?
7 A No.
8 MR. KLAYMAN: Objection. Vague and
9 ambiguous. Lacks foundation.
10 THE WITNESS: No.
11 BY MR. GARREN:
12 Q Did Mr. Livingstone at any time
13 ever suggest to you that he had any type of
14 personal friendship or relationship with the
15 First Lady?
16 MR. KLAYMAN: Objection. Leading.
17 Vague and ambiguous. Lacks foundation.
18 BY MR. GARREN:
19 Q You can answer.
20 A No.
21 Q During your tenure with the Office
22 of Personnel Security, Ms. Anderson, were you
47
1 aware of the First Lady ever expressing any
2 interest whatsoever in the work of the Office
3 of Personnel Security?
4 A No.
5 MR. KLAYMAN: Objection. Leading.
6 THE WITNESS: No.
7 MR. KLAYMAN: And vague and
8 ambiguous.
9 BY MR. GARREN:
10 Q To your knowledge, did the First
11 Lady at any time during your tenure with the
12 office ever come to the office?
13 MR. KLAYMAN: Objection. Leading.
14 Vague and ambiguous. Imprecise as to time.
15 BY MR. GARREN:
16 Q You can answer.
17 A No.
18 Q Well, let's make sure it's clear as
19 to time. During your tenure with the Office
20 of Personnel Security, are you aware of the
21 First Lady ever coming to the Office of
22 Personnel Security?
48
1 MR. KLAYMAN: Objection. Same
2 objection.
3 BY MR. GARREN:
4 Q You can answer the question.
5 A Between February of '93 to August
6 of '94, no.
7 Q During your tenure with the Office
8 of Personnel Security, were you aware of
9 anything suggesting that Mr. Livingstone
10 might have personally communicated in any
11 fashion with the First Lady?
12 MR. KLAYMAN: Objection. Vague and
13 ambiguous. Lacks foundation.
14 THE WITNESS: No.
15 MR. KLAYMAN: And leading.
16 BY MR. GARREN:
17 Q Now let me turn your attention to
18 Tony Marceca. Do you know Mr. Marceca?
19 A Yes.
20 Q When did you first meet him?
21 A I first met Mr. Marceca when I
22 began work for the inaugural committee.
49
1 Q Did you work with Mr. Marceca
2 during the inaugural committee?
3 A I worked in the same office with
4 him.
5 Q Do you know the kind of work that
6 he performed in the inaugural committee?
7 A Vaguely.
8 Q What do you know about that?
9 A He did the -- he worked with the
10 command center that was set up for the
11 inaugural and what exactly he did, I'm not
12 sure.
13 Q Did the two of you work together at
14 any time on any kind of project or
15 assignment?
16 A No.
17 Q Were you aware at the time that you
18 worked for the inaugural committee that
19 Mr. Marceca was employed by the Defense
20 Department?
21 A Yes.
22 Q Did you know what he did for the
50
1 Defense Department?
2 A I believe he was in the criminal
3 investigations.
4 Q And how did you learn that?
5 A He told me.
6 Q What did he tell you that you can
7 recall about his work at the Defense
8 Department?
9 A That he worked in the criminal
10 investigations unit.
11 Q You can't remember anything else he
12 said?
13 A No.
14 Q Now, did you later learn at some
15 point about efforts to have Mr. Marceca
16 detailed to the Office of Personnel Security?
17 MR. KLAYMAN: Objection. Leading.
18 Provides facts not in evidence. Vague and
19 ambiguous.
20 BY MR. GARREN:
21 Q You can answer the question.
22 A What exactly is the question?