301
1 A I do not know.
2 Q The next entry is October 18, 1994,
3 Craig Livingstone, visitee, that's the
4 President, POTUS, right?
5 A Yes.
6 Q Requestor Spangler, residence. Do
7 you know whether Craig Livingstone took FBI
8 files to the residence that day?
9 A No, I do not.
10 Q Now, you were his executive
11 assistant at the time, correct?
12 A Yes.
13 Q And you were his executive
14 assistant at the earlier times I've just
15 identified with regard to Exhibit 8, correct?
16 A Yes.
17 Q First page, the very first entry is
18 an Ellen Livingstone, do you know who that
19 is?
20 A I believe that might be his mother.
21 Q Did you ever meet his mother?
22 A Yes.
302
1 Q It says visitee, Zwally. What is
2 that?
3 A I don't know.
4 Q Do you know what room 360 is?
5 A No.
6 Q You have no idea?
7 A No.
8 Q You don't know whether Craig
9 Livingstone had given FBI files to his mother
10 that day?
11 A I don't think so, but -- no, I
12 don't know.
13 Q Why was she visiting room 360? Do
14 you know?
15 A I don't know.
16 Q Was she visiting Mrs. Clinton that
17 day?
18 A I do not know. She could have been
19 there to help answer the mail.
20 Q You are aware that she knows
21 Mrs. Clinton, correct?
22 A That's what I have heard in the
303
1 news.
2 MR. GAFFNEY: Objection to form.
3 MR. COHEN: Just to help everybody
4 out here, Craig's mother's name is not Ellen.
5 MR. KLAYMAN: I don't think that
6 helps anybody, Mr. Cohen, except it may help
7 you and your client. You're not even a
8 participant at this deposition.
9 MR. COHEN: I'm just trying to help
10 you, Larry, get a clear record.
11 MR. KLAYMAN: I don't think I need
12 your help, Mr. Cohen. Please certify this.
13 I don't think it's appropriate.
14 MR. COHEN: Fine, disregard it, but
15 that's not her name.
16 MR. KLAYMAN: I object to your
17 claiming that you're not a party to this case
18 yet interjecting in my deposition and you
19 know we have a motion pending to have you
20 excluded from this deposition, yet you've
21 chosen to give this person testimony. That's
22 wholly inappropriate and sanctionable.
304
1 Certify it.
2 MR. COHEN: Move on.
3 BY MR. KLAYMAN:
4 Q Third page, 4885, there's a
5 reference to a Gloria Livingstone. Do you
6 see that?
7 A Mm-hmm.
8 Q Who's Gloria Livingstone?
9 A I do not know. I would assume it's
10 his mother, but, again, I do not know.
11 Q You just said Ellen was his mother?
12 A I don't know. It could have been
13 his brother's wife. I've never met her but I
14 do not know.
15 Q Is it your assumption that may be
16 his mother based on what Mr. Cohen just said?
17 A It may be. It also may be Ellen,
18 but based on what Mr. Cohen said Ellen is not
19 his mother.
20 Q Do you know whether Craig
21 Livingstone's mother ever answered mail in
22 the White House?
305
1 A I do not know.
2 Q Now, the reference to Gloria
3 Livingstone, it says that she's going to Room
4 84. Do you know what Room 84 was?
5 A That was our office.
6 Q There's a reference to Craig
7 Livingstone visiting State F that day, which
8 is December 16, 1995. Do you know what State
9 F is, as a room?
10 A No.
11 Q And you don't know whether Craig
12 Livingstone was carrying FBI files at the
13 time when he visited State F?
14 A No.
15 Q There is a reference to Deanna
16 Livingstone. Who is Deanna Livingstone?
17 A I do not know.
18 Q And, of course, there's a reference
19 to Nathan Marceca, the date being December 3,
20 1995, visiting POTUS, that's the President,
21 correct?
22 A (Nodding)
306
1 Q Correct? POTUS was the president?
2 A Yes, as I've stated before.
3 Q Is that Anthony Marceca?
4 A No, that would be Tony's son,
5 Nathan.
6 Q Do you know why he was going to the
7 President's residence?
8 A I'm assuming that there was an
9 event over at The White House.
10 Q But you don't know?
11 A I don't know.
12 Q How often did you see Nathan
13 Marceca in The White House when you worked
14 there?
15 A I believe I only saw him once.
16 Q Was it on that day?
17 A I do not know what day it was on.
18 Q Do you know why he came?
19 A I do know he came over for an
20 event.
21 Q Do you know what Nathan did for a
22 living at the time?
307
1 A I know he worked on the Hill.
2 Q Do you know who he worked for?
3 A I believe he worked for Speaker
4 Foley.
5 Q Did you ever see Anthony Marceca
6 provide files or folders or any kind of
7 document to Nathan Marceca?
8 A No.
9 Q Do you know of anyone who did?
10 A No.
11 Q Do you know whether Nathan Marceca
12 professionally was a private investigator at
13 the time?
14 A No. No. I believe he was a staff
15 assistant for -- in the House -- in the
16 Speaker of the House.
17 Q Was he doing investigations?
18 A I do not know.
19 Q Turn to the next page, 4875, where
20 it says David Livingstone. Do you see that?
21 A Yes.
22 Q The date is March 6, 1996, correct?
308
1 A Yes.
2 Q David Marceca, is that a reference
3 to Craig Marceca? Is that the same person,
4 to the best of your knowledge?
5 A I do not know. I would not have
6 been there.
7 Q I'm sorry. Livingstone. Do you
8 know who David Livingstone is? Is that a
9 reference to Craig?
10 A That may have been.
11 Q His name is Craig David
12 Livingstone?
13 A David Craig Livingstone.
14 Q And that person is shown as
15 visiting The White House residence again,
16 correct?
17 A That's what it says.
18 Q And you don't know whether Craig
19 Livingstone was taking FBI files to show
20 people in the residence, do you?
21 A That would be after my tenure.
22 Q Did you ever see Craig Livingstone
309
1 in the presence of Hillary Clinton?
2 A In the presence, no.
3 Q Presence?
4 A No.
5 Q Did you ever hear Craig Livingstone
6 speaking to Mrs. Clinton over the phone?
7 A No.
8 Q Do you know of others who did?
9 A Speak to Mrs. Clinton?
10 Q Heard Craig Livingstone speaking to
11 Mrs. Clinton.
12 A No.
13 Q Now, Craig Livingstone did tell you
14 that he knew Mrs. Clinton, didn't he?
15 A No.
16 Q He told you he'd met her?
17 MR. GAFFNEY: Objection to form.
18 THE WITNESS: No. He never told me
19 he met her. He told me he had done advance
20 trips for the president.
21 BY MR. KLAYMAN:
22 Q And he did tell you that he had
310
1 been recommended for the job of White House
2 security director by Mrs. Clinton, correct?
3 A No.
4 MR. GILLIGAN: Objection to form.
5 BY MR. KLAYMAN:
6 Q He must have talked to you about
7 how he got his job?
8 A No.
9 Q You never asked him?
10 A No.
11 Q Do you know of others in the office
12 who asked him that?
13 A No.
14 Q Never had any curiosity to ask him
15 how he got his job?
16 A He never said that.
17 Q Well, did you have curiosity?
18 A I had curiosity but I never asked.
19 Q Why didn't you ask him?
20 A I thought it would be
21 inappropriate.
22 Q Why is it inappropriate?
311
1 A Because I thought that would have
2 been going over the bounds.
3 Q Why?
4 A Because I thought it would have
5 been rude.
6 Q Why?
7 A Because it is.
8 Q Why is it rude?
9 A That's the way I was raised.
10 Q I'm trying to get an understanding
11 as to your state as to why asking someone how
12 they came into that position that would be
13 rude.
14 A That was the way I was raised, that
15 it's rude to be intrusive into someone else's
16 personal life.
17 Q You called Mr. Livingstone when you
18 wanted a job, right?
19 A But it was not into his personal
20 life.
21 Q You asked him to recommend you for
22 the job based upon his contact with the
312
1 administration, correct?
2 A No.
3 Q You knew he had contacts with the
4 administration?
5 A He had already extended the
6 invitation.
7 Q Now, you were aware, however, that
8 Mr. Livingstone had done other things before
9 he became security director, correct?
10 A Yes.
11 Q And what other things had he done?
12 A He had done advance. He had done
13 other political campaigns. He had done
14 various work that he had told me about.
15 Q You were aware that he also played
16 the role of Chicken George, correct?
17 A No.
18 Q He never told you he wore a chicken
19 suit?
20 A No.
21 Q You're aware that he had worked in
22 a bar at one time as a bar bouncer?
313
1 A Yes.
2 Q He told you that, right?
3 A Yes.
4 Q And he told you that over dinner or
5 over lunch or something like that?
6 A In passing.
7 Q You asked him, in fact, what have
8 you done before you came here, correct?
9 A In fact, I did not.
10 Q So he just blurted out I was a bar
11 bouncer?
12 A It was in the course of a
13 discussion that we were just having.
14 Q And what was the nature of the
15 discussion?
16 A I do not remember specifically.
17 Q You were talking about what both of
18 you had done before you came to The White
19 House, right?
20 A No, we were not. I do not remember
21 the specifics of the discussion.
22 Q He was proud of the fact that he'd
314
1 been a bar bouncer, correct?
2 A I cannot speak to the state of his
3 mind.
4 Q In fact, what he said to you was
5 isn't it amazing I'm White House security
6 director having been a bar bouncer?
7 A You would be incorrect.
8 Q So what did he say?
9 A He mentioned in passing that at one
10 time he had been working in a bar as a
11 bouncer.
12 Q And it was your understanding that
13 Mr. Livingstone had a great deal of
14 responsibility in that office, was it not?
15 A In which office?
16 Q The White House Office of Personnel
17 Security?
18 A It was my understanding that he was
19 director.
20 Q And as director, he had control of
21 highly confidential FBI files, correct?
22 A Yes.
315
1 Q And you found it strange that they
2 would put a bar bouncer in that job, didn't
3 you?
4 A No.
5 MR. GILLIGAN: Object to the form.
6 BY MR. KLAYMAN:
7 Q Why didn't you find that strange?
8 A He was director of security at the
9 inaugural.
10 Q Did he ever tell you that he'd
11 received formal training in how to be a
12 security person?
13 A No.
14 Q Did you ever ask him?
15 A No.
16 Q Did you ever ask him for advice on
17 security matters?
18 A Yes.
19 Q What advice did you ask him for?
20 A In the course of the office, would
21 this be a violation or do we need to do this
22 or what is the procedure we should follow
316
1 with this.
2 Q So basically, Craig Livingstone was
3 the one who was calling the shots as to what
4 to do with FBI files, correct?
5 A As far as requesting them or
6 reviewing them? I'm not sure what you're
7 saying.
8 Q Let's start with reviewing them.
9 A Yes, he reviewed them.
10 Q That was his decision on whether to
11 review them?
12 A That was his understanding from
13 previous administration, that he was to
14 review all the files that came in.
15 Q And in fact you saw him on many
16 occasions reviewing files, did you not?
17 A Of current investigations that had
18 come in, yes.
19 Q And also of individuals who no
20 longer worked in The White House, correct?
21 A Of files that we had requested
22 believing that they were working at The White
317
1 House.
2 Q But who in fact weren't?
3 A To our later understanding, yes.
4 Q To your later understanding,
5 correct?
6 A To the later understanding of the
7 office after we had determined that they had
8 no longer been working there, yes.
9 Q Well, that was your understanding,
10 was it not?
11 A That after he had reviewed them,
12 yes, we learned they were no longer working
13 at The White House.
14 Q But you can't put yourself inside
15 Mr. Livingstone's mind to tell me whether he
16 knew?
17 A No, I can't but I can tell you that
18 in the general office the understanding was
19 we did not know who specifically had already
20 left.
21 Q Now, you understood that
22 Mr. Livingstone had no formal training in
318
1 security, correct?
2 A No.
3 Q You knew that?
4 A No.
5 Q He led you to believe that he did
6 have training, formal training?
7 A I was under the -- I knew that he
8 had gone through some of the training courses
9 that they had offered just as other staff
10 members had.
11 Q He told you that?
12 A Yes.
13 Q What courses did he say he went to?
14 A I believe there was one at the CIA,
15 the National Security Council. I'm not sure
16 exactly which ones. I think maybe the Secret
17 Service had talked to him, but I don't know
18 specifically.
19 Q Did he ever show you any
20 certificates that he attended those courses?
21 A No.
22 Q So, having understood that in fact
319
1 he did have security training, you considered
2 him to be as knowledgeable as Ms. Gemmell,
3 right?
4 A No, we considered Nancy to be the
5 authority.
6 Q But Mr. Livingstone was also an
7 authority?
8 A He was an authority within the
9 office, yes.
10 Q So, if he told you that this is the
11 way it was, you accepted that?
12 A Yes.
13 Q And many times you saw him
14 reviewing FBI files in the vault, did you
15 not?
16 A Sometimes he would review files in
17 the vault.
18 Q And sometimes he'd sit there
19 reviewing the files at the desk in the vault,
20 looking at them, correct?
21 A If he had a question, he went into
22 the vault to review something he had already
320
1 read. Initially, he would review the files
2 as they came into the office before they were
3 put into the files.
4 Q Sometimes you'd see him sitting
5 there in the vault with a stack of FBI files,
6 correct?
7 A No.
8 Q More than one?
9 A No.
10 Q He looked at them one at a time?
11 A I only remember seeing him in the
12 vault reviewing one that he had already read
13 and he had a question about and he was going
14 back to look at it.
15 Q There were times that you were not
16 in the office when Mr. Livingstone was there,
17 correct?
18 A Yes.
19 Q And you don't know whether he
20 reviewed files when you were out of the
21 office, do you?
22 A I have no idea what he did while I
321
1 was out of the office.
2 Q And you don't know whether, having
3 reviewed files he then provided information
4 orally to other people, do you?
5 A No, I do not.
6 Q Same question with regard to
7 Mr. Marceca?
8 A No, I do not.
9 Q You are aware that Mr. Marceca
10 reviewed files in the vault from time to
11 time?
12 A I am aware that he would review the
13 files of the update project as they came in,
14 yes.
15 Q And you're also aware that
16 Mr. Marceca had contact with other people in
17 the White House, correct?
18 A Yes.
19 Q And you're aware that he sometimes
20 visited the residence as well, correct?
21 A Yes, he would go to see Nancy and I
22 can't remember her last name.
322
1 Q Nancy ����?
2 A No, Nancy who was over the
3 residence staff. She was their personnel --
4 I think it was Nancy Mitchell, maybe.
5 Q Do you know what she did?
6 A She was in charge of their
7 personnel staff, of the hiring and firing.
8 Q And you don't know whether
9 Mr. Livingstone and Mr. Marceca ever spoke
10 with Mrs. Clinton, do you?
11 A No.
12 Q And you don't know whether they
13 ever spoke with the president, do you?
14 A No.
15 Q And you don't know whether either
16 of them ever shared FBI information with him,
17 do you?
18 A No.
19 Q Who is Regina Livingstone?
20 A I do not know.
21 Q Do you know what the Room WW is?
22 This is an entry on March 14, 1996.
323
1 A What page would that be on?
2 Q That's page number 4875.
3 A WW, I would assume, would be the
4 West Wing, but I do not know for certain.
5 Q Who's in the West Wing?
6 A Offices of the President.
7 Q But you never heard of someone by
8 the name of Regina Livingstone?
9 A I could have. I don't remember
10 specifically.
11 Q Did you meet several family members
12 of Mr. Livingstone?
13 A I met his parents and his brother.
14 Q Do you remember his brother's name?
15 A Steve, I believe.
16 Q Do you know what Steve was doing at
17 the time professionally?
18 A He was an engineer with someone. I
19 do not know who.
20 Q Did he live in Washington or
21 someplace else?
22 A I'm not sure of his exact location,
324
1 but I know it was in the Washington area.
2 Q Your lawyer, what's his name? Your
3 private lawyer?
4 A Mark Srere.
5 Q Mark Srere has talked with Craig
6 Livingstone, hasn't he, since this scandal
7 broke in 1996?
8 A I'm not going to answer that.
9 Q That's not covered by any
10 privilege.
11 A I don't know the answer to that, so
12 I'm not going to answer it.
13 Q But Mr. Srere has told you he's
14 talked to Mr. Livingstone?
15 A I'm not going to answer that.
16 Q Why aren't you going to answer that
17 one?
18 A Because that's a discussion between
19 my and my attorney.
20 Q Have you been told not to answer
21 that? Did someone tell you?
22 A No, but my gut's telling me not to.
325
1 Q Certify it. In fact, your
2 attorney's been in contact with
3 Mr. Livingstone quite frequently, hasn't he?
4 A Not going to answer it.
5 Q How's your attorney's last name
6 spelled?
7 A S-r-e-r-e.
8 Q Your attorney doesn't represent
9 Mr. Livingstone, does he?
10 A Not to my knowledge. I believe you
11 would have to ask Mr. Cohen that.
12 Q I'm not asking Mr. Cohen anything
13 here.
14 MR. COHEN: I'd be happy to tell
15 you, Larry.
16 MR. KLAYMAN: I'm sure you would.
17 MR. GILLIGAN: Is it possible we've
18 all shared a smile on this occasion?
19 MR. KLAYMAN: It's nice to share.
20 BY MR. KLAYMAN:
21 Q Your attorney's spoken with
22 Mr. Marceca since this scandal broke,
326
1 correct?
2 A I do not know.
3 Q You don't know or you don't want to
4 tell me?
5 A Both.
6 Q But, if you don't know, then you
7 can tell me, right?
8 A No, because I don't know. I cannot
9 give you information I do not have.
10 Q Who is an Andrea Marceca, do you
11 know?
12 A That would be Tony's daughter.
13 Q Do you know what she was doing in
14 The White House on March 27, 1996?
15 A I believe -- oh, '96, no, I do not
16 know.
17 Q Where is Room 457?
18 A I do not remember.
19 Q Is that in the residence?
20 A I would believe that that would be
21 in the OEOB.
22 Q What's OEOB?
327
1 A OEOB, Old Executive Office
2 Building.
3 Q Do you have any understanding as to
4 whose office that might be?
5 A No.
6 Q David Marceca, is that his son,
7 Tony's son?
8 A I do not know.
9 Q Bonnie Marceca?
10 A Do not know.
11 Q Do you know what all these Marcecas
12 were doing in the White House?
13 A Again, that is after I left.
14 Q Room 8002, where is that? This is
15 the last page, 4891.
16 A I do not know. By the numbers, it
17 looks to be the NEOB, New Executive Office
18 Building.
19 Q Any indication or feeling for who
20 might be in that office?
21 A No.
22 Q Then it says Nathan and Tony
328
1 Marceca. These are entries on October 26,
2 1995. That says something grounds. Do you
3 see that, the room.
4 A Yes.
5 Q Is that S?
6 A I do not know.
7 Q Do you know what S Grounds is?
8 A I do not know.
9 Q Room 182, do you know where that
10 is?
11 A What page are you on?
12 MR. GILLIGAN: Are you on a
13 different page, Mr. Klayman?
14 BY MR. KLAYMAN:
15 Q Different page, 4958, Room 182?
16 A I do not know what that would be.
17 Q Room 84?
18 A That would be our office, as
19 previously stated.
20 Q Do you know who David Richman is?
21 A No.
22 Q Eric Thomas?
329
1 A No.
2 Q You ever heard of Patty Kinoshita?
3 A No.
4 Q George Kinoshita?
5 A No.
6 Q You don't know who those people
7 are?
8 A No.
9 Q Kimberly Kinoshita? Ever hear of
10 any Kinoshitas?
11 A No.
12 Q You ever meet Lewis Freeh, director
13 of the FBI?
14 A Once.
15 Q Where did you meet him?
16 A At the FBI headquarters.
17 Q What were you doing there?
18 A When he was being sworn in, Craig
19 did the advance.
20 Q You are aware that Craig
21 Livingstone and others in your office were
22 sometimes in contact with Mr. Freeh?
330
1 A I'm not aware of direct contact
2 with Mr. Freeh, but I do know that they
3 exchanged a thank-you note. That was all.
4 Q Have you ever met any of
5 Mr. Freeh's family members?
6 A No.
7 Q Have you ever heard them spoken of?
8 A Only in the context of Director
9 Freeh in his capacity as director of the FBI.
10 Q You ever heard of a Brendon Freeh?
11 A No.
12 Q Connor Freeh?
13 A No.
14 Q Lewis Freeh? Marilyn or Justin
15 Freeh?
16 A Lewis Freeh, director of the FBI.
17 Q Right.
18 A That was the only one I had heard
19 of.
20 Q I'll turn your attention to page
21 number 4952.
22 MR. GILLIGAN: Keep going forward.
331
1 They're not in order.
2 BY MR. KLAYMAN:
3 Q Now, you see on this page that you
4 are actually the requesting party to allow
5 these people into Room 84?
6 A Yes.
7 Q So you actually had heard of these
8 people before?
9 A Probably.
10 Q Does this refresh your recollection
11 as to who they are?
12 A Yes.
13 Q Tell me who they are.
14 A The family of Mr. Freeh.
15 Q What were they doing in Room 84
16 that day?
17 A I cannot tell you. Do not
18 remember.
19 Q Next page, page 4904, Randy Turk,
20 you ever hear of Randy Turk before?
21 A When you previously mentioned him,
22 yes.
332
1 Q It says the requester is Hughes,
2 the visitee is Livingstone? Who is Hughes?
3 A I would have to assume that's Ed,
4 but this is after my tenure.
5 Q Then it lists David Cohen, entry
6 May 5, 1995; 84, that was your office,
7 correct?
8 A Yes.
9 Q What is the room number for
10 Mrs. Clinton?
11 A I do not know.
12 Q What is the room number for her
13 offices?
14 A I do not know.
15 Q Have you ever heard of a Floyd
16 Clarke?
17 A Not to my memory.
18 MR. KLAYMAN: I'll show you what
19 I'll ask the court reporter to mark as
20 Exhibit 9.
21 (Anderson Deposition Exhibit
22 No. 9 was marked for
333
1 identification.)
2 BY MR. KLAYMAN:
3 Q Have you ever seen this document
4 before?
5 A It looks familiar.
6 Q It's more than one document.
7 MR. GAFFNEY: Would you hand me an
8 extra copy of that?
9 MR. KLAYMAN: Sure.
10 BY MR. KLAYMAN:
11 Q First page of this document is
12 dated November 18, 1993, from Lewis Freeh to
13 Craig Livingstone. You were there at the
14 time, weren't you, in The White House Office
15 of Personnel Security?
16 A Yes.
17 Q And you remember receiving this
18 letter in and around that time period?
19 A I remember Craig showing me the
20 letter, yes.
21 Q Does this refresh your recollection
22 as to who Floyd Clarke is?
334
1 A No.
2 Q Turn to the second page. That's
3 number F 01077, photograph of ceremony, from
4 Craig Livingstone, Director, White House
5 Security. Do you know what ceremony's being
6 referred to, December 28, 1993?
7 A I believe it's Director Lewis
8 Freeh's swearing-in ceremony.
9 Q I take it that Craig Livingstone
10 attended that ceremony?
11 A As I had stated previously, we did
12 advance for that ceremony.
13 Q Mr. Livingstone was pretty close
14 with director Freeh when you were there,
15 correct?
16 A No.
17 Q In fact, he told you that he'd
18 become friendly with him, correct?
19 A No.
20 Q Did he tell you he'd never met him
21 before?
22 A No.
335
1 Q So you don't know one way or the
2 other?
3 A I know that there was an
4 acquaintance but I do not know if he was
5 friends with him, no.
6 Q Sometimes Craig Livingstone would
7 visit Director Freeh at the FBI headquarters
8 on Pennsylvania Avenue, correct?
9 A I do not know.
10 Q You did see director Freeh in the
11 office, did you not, in the White House from
12 time to time?
13 A No.
14 Q Did you see any representatives of
15 Director Freeh from time to time in your
16 office?
17 A If by that you mean do I remember
18 seeing FBI agents in our office, yes.
19 Q Correct. Which agents?
20 A The one agent, Gary, can't remember
21 his last name --
22 Q Gary Aldridge?
336
1 A Yes, he just wrote a book?
2 Q Did you ever read his book?
3 A No.
4 Q Did you get to know Gary Aldridge
5 pretty well?
6 A I got to know who he was.
7 Q And he spent some time with Craig
8 Livingstone and Anthony Marceca? You are
9 aware of that?
10 A I'm aware that he wrote it. I
11 don't remember specifically. I know he came
12 into our office from time to time.
13 Q You are aware that Craig
14 Livingstone and Anthony Marceca had lunch
15 with him at least once?
16 A I don't remember that but it's
17 possible.
18 Q During the time that you were at
19 The White House, did you hear anyone say that
20 Gary Aldridge was not an honest person?
21 A Not to my memory.
22 Q Did you hear anyone say that he had
337
1 a reputation for not being honest?
2 A Not to my memory.
3 Q Did you hear anyone say that Gary
4 Aldridge ever told a lie?
5 A Not to my memory.
6 Q Did you hear anyone say that Gary
7 Aldridge was not reputable?
8 A Not to my memory.
9 Q Was that his reputation?
10 A His reputation was that he was an
11 FBI agent. He seemed rather nice but I don't
12 remember anything other than that.
13 Q Did you ever hear him say anything
14 that was inappropriate, in your opinion?
15 A Did I ever hear who say anything?
16 Q Gary Aldridge.
17 MR. GILLIGAN: Object to the
18 vagueness of the question.
19 BY MR. KLAYMAN:
20 Q You can respond.
21 A I don't remember much of what Gary
22 said.
338
1 Q Did you ever see him express any
2 animosity towards the Clinton Administration
3 while he was at The White House?
4 A Not to my memory.
5 Q Did you ever meet special agent
6 Dennis Sculimbrene?
7 A Yes.
8 Q Where did you meet Agent
9 Sculimbrene?
10 A I believe it was in the same manner
11 that I met Gary Aldridge.
12 Q In the course of your work in the
13 Office of Personnel Security?
14 A Yes, they were the two FBI agents
15 assigned to The White House.
16 Q And why did they visit your office
17 from time to time?
18 A The initial reason they visited our
19 office was to say hello, we are the FBI
20 agents who will be doing the investigations
21 for The White House staff, and then a few
22 other times but not very often, once in a
339
1 while, Mr. Aldridge would drop in or
2 Mr. Sculimbrene would drop in to say we have
3 a question, we're having problems contacting
4 this person, can you help us out.
5 Q You never heard anyone say that
6 Special Agent Sculimbrene was dishonest, did
7 you?
8 A Not to my memory.
9 Q You never heard anyone accuse him
10 of lying, did you?
11 A Not that I remember.
12 Q His reputation was not someone who
13 was disreputable, was it?
14 A I don't remember his reputation.
15 Q Did he ever tell you anything that
16 was untrue?
17 A I barely had any conversations with
18 him so I could not say if -- attest to the
19 veracity of anything that he said to me.
20 Q Did you ever hear anyone say that
21 he had prepared an FBI report that was false
22 or misleading?
340
1 A Not that I remember.
2 Q Was he a good FBI agent?
3 A I have no basis to give you an
4 answer.
5 Q You had seen Anthony Marceca with
6 Special Agent Sculimbrene from time to time,
7 hadn't you?
8 A Not to my memory.
9 Q I'll show you what I'll ask the
10 court reporter to mark as Exhibit 9 --
11 MR. GILLIGAN: Ten.
12 THE WITNESS: Are we finished with
13 9?
14 MR. KLAYMAN: Yes.
15 (Anderson Deposition Exhibit
16 No. 10 was marked for
17 identification.)
18 BY MR. KLAYMAN:
19 Q This is a memorandum written by
20 Special Agent Dennis Sculimbrene regarding
21 Craig Livingstone on March 13, 1993. Have
22 you ever seen this before?
341
1 A No.
2 Q Turn to the second paragraph. It
3 says, "Bernard Nussbuam, Counsel to the
4 President, advised that he has known the
5 appointee for a period of time that he has
6 been employed in the new administration. He
7 had come highly recommended to him by Hillary
8 Clinton, who has known his mother for a
9 longer period of time. He was confident that
10 the appointee lives a circumspect life and
11 was not aware of any illegal drug or alcohol
12 problems. He said that the appointee will
13 work at The White House on security matters.
14 He said that in the short period of time that
15 the appointee has worked for him he has been
16 completely satisfied with his performance,
17 conduct, and productivity. He recommended
18 the appointee for continued access in his
19 current capacity."
20 Is there anything in this paragraph
21 that I just read to you that you can tell me
22 based on your knowledge is false?
342
1 A Considering I had no knowledge of
2 anything you've just read, no.
3 Q Have you ever heard anyone else say
4 anything that would lead you to believe that
5 any part of the paragraph I just read to you
6 is false?
7 A I have no knowledge of any of the
8 facts in that paragraph.
9 Q The answer's no?
10 A No.
11 Q Now, you previously testified that
12 there did come a point in time when files
13 were discovered --
14 MR. GILLIGAN: Are you referring to
15 her Senate testimony or --
16 MR. KLAYMAN: I'm not referring to
17 anything. I'm just playing around here.
18 BY MR. KLAYMAN:
19 Q You did testify previously that
20 there came a point in time when people in the
21 Office of Personnel Security discovered that
22 files had come over from the FBI concerning
343
1 previous employees, not current employees,
2 correct?
3 A No.
4 Q What did you testify to?
5 A I testified previously today that
6 we realized we were receiving files of people
7 who had left the White House.
8 Q Those are previous employees,
9 aren't they?
10 A Who had fallen under the Clinton
11 Administration, yes.
12 Q And what persons did you uncover or
13 did you learn of that files were obtained
14 from the FBI of individuals who left The
15 White House?
16 A I do not remember specific names.
17 Q Do the names Marlin Fitzwater and
18 James Baker ring a bell?
19 A I know who they are, but I don't
20 remember those files.
21 Q You are aware that you testified to
22 that before the Senate?
344
1 A Yes.
2 Q That those were the person whose
3 files came over among others?
4 A No, I did not testify to that.
5 What I testified in the Senate was that I
6 remember seeing a list that had Mr. Baker's
7 name on it, the Bushes' name on it, and the
8 Quales' name on it and also Mr. Fitzwater's
9 name on it and that rang a bell that we
10 needed to delete those names from that list.
11 Q And you saw that list before you
12 became aware that their files came over to
13 the office, correct?
14 A I never saw their files come over
15 to the office.
16 Q And how did you come to see the
17 list?
18 A I remember going down to pick up
19 the list.
20 Q Who sent you down to pick it up?
21 A They had called because we had --
22 if I remember correctly, we had requested a
345
1 list of all active passholders.
2 Q Who had requested it in your
3 office?
4 A The request would have gone out
5 under Craig's name.
6 Q Did you prepare that request, under
7 his name?
8 A Probably but I don't remember.
9 Q And you had him sign it, correct?
10 A If I remember -- if it's the
11 appropriate procedures where I normally did
12 have him sign it.
13 Q And that request was ultimately
14 authorized by someone else in The White
15 House, correct? They had ordered Craig to
16 get that list?
17 A I do not know.
18 Q You don't know one way or the
19 other?
20 A I do not know. My understanding
21 was it was from Craig.
22 Q Craig's the one who told you to
346
1 prepare the authorization form, correct, to
2 get the list?
3 A Yes.
4 Q But you don't know whether someone
5 else had told him to do that?
6 A I do not know.
7 Q You were the one that went down to
8 get the list, correct?
9 A If my memory was correct, yes.
10 Q Where did you go to get the list?
11 A The WAVES operations office.
12 Q Who did you see there?
13 A I believe it was either J. C.
14 Pierson or Sergeant Morris Kraft.
15 Q Who was J. C. Pierson?
16 A She was a sergeant in the WAVES
17 office.
18 Q And the other person's name is?
19 A Sergeant Morris Kraft.
20 Q And who was that?
21 A Also a person in the WAVES office.
22 Q And you took the requisition form
347
1 with you when you went?
2 A No, it had already been sent down.
3 Q How did you send it down?
4 A Probably walked it down or sent it
5 down at the end of the day when we sent down
6 the access list.
7 Q And they called you to come get the
8 list?
9 A Yes. If I remember correctly, that
10 was generally the way that it occurred.
11 Q How was the list provided to you?
12 A I'm sorry. I don't understand what
13 you mean.
14 Q How was the list provided to you?
15 Was it just given to you as a list?
16 A It was given to me on this paper
17 that was generally about an inch thick folded
18 in half, "this paper" being Exhibit 2.
19 Q It wasn't in an envelope, was it?
20 A Not to my memory.
21 Q In fact, it was out in the open so
22 anybody could read it, correct?
348
1 A It was not kept out in the open,
2 no. You had to go down to the WAVES office
3 to pick it up. Where they kept it in their
4 office, I do not know.
5 Q Let me show you Exhibit 4. Is
6 Exhibit 4 an example of the list? Is that
7 the list?
8 A It looks like the list where I did
9 mark out their names, yes.
10 Q But that wasn't the list that was
11 actually provided on that day, was it?
12 A It could have been.
13 Q But you're not sure?
14 A I'm not sure. It could have been.
15 Q It might have been a different
16 list?
17 A It might have been a different
18 list, but I think it was probably this list.
19 Q Did any of the counsel that
20 questioned you before I've had the
21 opportunity show you a list that looks like
22 the one you picked up that day?
349
1 MR. GILLIGAN: Objection.
2 Attorney-client privilege. I instruct the
3 witness not to answer that.
4 BY MR. KLAYMAN:
5 Q So you've been shown a list like
6 that before that you haven't seen today?
7 MR. GILLIGAN: Objection to any
8 questions --
9 MR. KLAYMAN: Mr. Gilligan, we
10 demand a copy of that list. You basically
11 just told us that there's another list.
12 There's an example of where your intervening
13 actually gave us helpful information. Thank
14 you.
15 MR. GILLIGAN: I don't follow any
16 of that, Mr. Klayman. The only thing I do
17 know is that you've just asked a question
18 that is objectionable on the grounds of
19 attorney-client privilege.
20 MR. KLAYMAN: It would appear based
21 on what just happened that the list she
22 looked at today is not the actual list, that
350
1 you've actually gone over the actual list
2 with her, yet you've not produced it to us.
3 MR. GILLIGAN: Mr. Klayman, you've
4 drawn mistaken inferences before in this
5 case; you may draw any inferences you want.
6 MR. KLAYMAN: Is there such a list?
7 MR. GILLIGAN: I'm not under oath
8 to answer any questions.
9 MR. KLAYMAN: If you're with-
10 holding, you have an obligation as an officer
11 of the court to advise the court.
12 MR. GILLIGAN: Of what?
13 MR. KLAYMAN: Because we've
14 requested it in discovery.
15 MR. GILLIGAN: Everything that we
16 found that's responsive and nonprivileged to
17 your discovery request, we've produced.
18 Again, I'm having trouble following your
19 train of thought, Mr. Klayman.
20 MR. KLAYMAN: Unfortunately, you're
21 the beholder of what's privileged. If we
22 don't even know that something exists because
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