351
1 it hasn't been produced yet you're not
2 letting her testify as to whether she saw a
3 different list with you, then that strongly
4 presumes there is another list.
5 MR. GILLIGAN: If your question is
6 are there any WAVES lists of this nature that
7 we know of that we haven't produced to you,
8 the answer to that question categorically is
9 no. We have produced them all to you to the
10 extent we have them.
11 MR. KLAYMAN: The why won't you let
12 her answer?
13 MR. GILLIGAN: You're asking
14 questions about attorney-client discussions.
15 MR. KLAYMAN: I'm asking her
16 whether there's another list that looks like
17 that that has things crossed out that you've
18 seen that hasn't been produced to us.
19 BY MR. KLAYMAN:
20 Q You, Ms. Anderson?
21 A I do not know what has been given
22 to you.
352
1 Q That's a good point. Have you seen
2 another list that has things crossed out?
3 MR. GILLIGAN: If the question is
4 general, ever, fine.
5 BY MR. KLAYMAN:
6 Q That's not Exhibit 4?
7 A I have seen lists where names were
8 crossed out. If it was this list or another
9 list I do not know. I've seen many, many
10 lists.
11 THE WITNESS: At this point, I'd
12 like to go get some water.
13 MR. GILLIGAN: Let's take a break.
14 THE VIDEOGRAPHER: We're going off
15 video record at 4:16.
16 (Recess)
17 THE VIDEOGRAPHER: We're back on
18 video record at 4:29.
19 BY MR. KLAYMAN:
20 Q Just for the record, you've
21 requested that we break at no later than
22 5:30, correct?
353
1 A So I can make my flight.
2 Q We're going to ask whether you'll
3 come back at a later date?
4 A After June 6.
5 Q After June 6 you will agree to come
6 back?
7 A If somebody paid for it, yes.
8 Q We will see if we can work that
9 out, either voluntarily or ask the court to
10 work open out.
11 Now, we were talking about --
12 A Can I make one statement? I would
13 also like to -- I am willing to come back as
14 long as it's after June 6 and before the next
15 session of classes which is a two-week
16 period.
17 Q When is that?
18 A Unfortunately, I do not know off
19 the top of my head, but it's a shorter
20 session since the University of Georgia
21 regents system is moving over to semesters,
22 so they're cramming everything into a shorter
354
1 span of time.
2 Q Do you have a general idea?
3 A I believe mid-June but I don't know
4 a specific date.
5 Q So sometime between June 6 and
6 mid-June?
7 A Yeah.
8 Q If you'll let your counsel know and
9 then they'll let us know?
10 A I will let them know.
11 Q You were aware at the time that you
12 picked up that list or shortly thereafter
13 that there were people's names on that list
14 who were not current employees of The White
15 House, correct?
16 A Yes.
17 Q And you brought that to somebody's
18 attention, did you not?
19 A Yes.
20 Q Whose attention did you bring it
21 to?
22 A Craig Livingstone's.
355
1 Q And what did you say to
2 Mr. Livingstone?
3 A I said, Craig, look, we have James
4 Baker, Marlin Fitzwater, and the Bushes still
5 on the list, and he said you can't be
6 serious. This is, of course, just the gist
7 of the conversation, and I said yeah, they're
8 still here. He said they can't be on there,
9 so we decided we need to go through the list,
10 see who else on there we might recognize
11 still had a pass or was still listed as what
12 we had assumed active to the Secret Service
13 and take them off of the active pass list.
14 Q And how did you do that?
15 A We went through it and we read down
16 the list and said James Baker does not need
17 access, wrote his name down, and then went
18 through and submitted it to Secret Service.
19 Q And did you do that at the
20 direction of Mr. Livingstone or did you do
21 that on your own?
22 A Mr. Livingstone.
356
1 Q At the time didn't you comment to
2 Mr. Livingstone and to Tony Marceca that you
3 were striking out Baker and Fitzwater's names
4 because those were the only names you could
5 remember of the previous Republican
6 administration?
7 A It was Baker and Fitzwater and the
8 Bushes and the Quayles.
9 Q Those four groupings?
10 A I think it was more than -- yeah,
11 those four groupings.
12 Q And those names -- and Marceca was
13 aware of that as well at the time, correct?
14 A Well, if you notice the date on
15 this list, speaking generally, this list is
16 August 1, and Tony, I believe, it was not in
17 the office at that time, so that might have
18 been a mistaken memory, but I do know I did
19 say it to Craig.
20 Q I take it Craig expressed shock?
21 A Yes.
22 Q And what occurred after you struck
357
1 the names off the list, if anything?
2 A I'm not sure.
3 Q Were the names struck off the list?
4 A We marked through them on our list
5 and then we sent a memo over to Secret
6 Service asking them to strike the names from
7 their list.
8 Q What happened after that?
9 A I believe -- I'm not a hundred
10 percent certain, but I think some of the
11 names may have still appeared, some of them
12 may have disappeared. I can't remember. But
13 I know that we did send a memo over to Secret
14 Service.
15 Q And in fact another list came back,
16 did it not, which did not have their names
17 struck?
18 A I do not remember at this time.
19 Q Well, tell me what happened after
20 that, what you remember at this time?
21 A What I remember is that we sent the
22 memo over, and then as we became aware of
358
1 more people who were on the list who were
2 inactive, we sent other memos to Secret
3 Service asking them to strike those names as
4 well.
5 Q What happened after that?
6 A The process continued.
7 Q But ultimately some of the files
8 whose names had been stricken wound their way
9 into The White House nevertheless, correct?
10 A I do not know. I did not see those
11 files.
12 Q You are aware from talking with
13 others that some of them were ultimately
14 delivered from the FBI to The White House?
15 A I am aware that -- I have been told
16 that they have.
17 Q How did you learn that?
18 MR. GILLIGAN: Direct the witness
19 not to reveal any attorney-client
20 communications.
21 BY MR. KLAYMAN:
22 Q How did you learn that?
359
1 MR. GILLIGAN: Same instruction.
2 THE WITNESS: I'm going to defer to
3 his instruction.
4 BY MR. KLAYMAN:
5 Q You remember testifying about this
6 before the Senate, correct?
7 A I remember testifying before the
8 Senate that we did see the names and that we
9 did strike them.
10 Q But you remember also being advised
11 by the Senate lawyers that in fact the files
12 of Baker and of Fitzwater did ultimately come
13 from the FBI to The White House?
14 A That could be possible.
15 Q And you expressed surprise at that,
16 correct?
17 A That would be very true, if they
18 had said that, I would have been very
19 surprised.
20 Q Now, do you know how that came
21 about? Have you learned since your Senate
22 testimony how those files made their way to
360
1 the White House?
2 A No.
3 Q Now, you don't know whether, after
4 you were privy to striking the names
5 Fitzwater and Baker off the list, that
6 someone else didn't change the list to put
7 their names back on, do you?
8 A I have no knowledge of anybody
9 requesting to add those names back to the
10 list.
11 Q But you don't know for a fact that
12 someone didn't do it, correct?
13 A I just said I have no knowledge of
14 it.
15 Q One way or the other?
16 A One way or the other.
17 Q Are you aware that Craig
18 Livingstone had a criminal complaint filed
19 against him for allegedly trying to smash in
20 the face of his next-door neighbor?
21 MR. GILLIGAN: Object to the
22 relevance.
361
1 BY MR. KLAYMAN:
2 Q Are you aware of that?
3 A No.
4 Q Did you ever hear that?
5 A No.
6 Q Do you know of any other
7 allegations of wrongdoing with regard to
8 Mr. Livingstone, other than the FBI files
9 matter, what I just told you?
10 A When you say wrongdoings, how do
11 you --
12 Q Alleged illegal behavior.
13 A No.
14 Q Who did you see him most with in
15 The White House when you worked there? Who
16 was he around the most?
17 A He was mostly in the office. He
18 wasn't really hanging out with anybody.
19 Q Do you know who his friends were,
20 any of his friends?
21 A I know who some of them were.
22 Q Who are they?
362
1 A One of them would have been Mike
2 Jones.
3 Q Do you know where Mike is today?
4 A No.
5 Q Where was he at the time? Was he
6 living in Washington?
7 A He was.
8 Q And what's his full name? Do you
9 know his middle name?
10 A No.
11 Q And do you know what he was doing
12 at the time?
13 A Last time I knew of Mike, he was at
14 Department of Agriculture, I believe. I'm
15 not sure but I think it was.
16 Q What was his position?
17 A I do not know.
18 Q Any other friends?
19 A Jim Denbo.
20 Q And what was Jim doing at that
21 time?
22 A I'm not sure. I believe he was a
363
1 labor lawyer, but I'm not sure.
2 Q In Washington?
3 A Yes.
4 Q Do you know where Jim is today?
5 A No.
6 Q Who else?
7 A Those are the only ones I can
8 remember.
9 Q Did Mr. Livingstone have a
10 girlfriend at the time?
11 A At the time, no.
12 Q Do you know whether he's had one
13 since?
14 A I have no idea what he's done
15 since.
16 Q You never met any?
17 A Not since.
18 Q Who were Mr. Marceca's friends, to
19 the best of your knowledge?
20 A I do not know. Craig. I do not
21 know other than that.
22 Q Did Craig Livingstone and
364
1 Mr. Marceca sometimes spend time together in
2 the evening? Did they go drinking or
3 anything like that with a group of people?
4 A I do not know if they went out
5 after the office.
6 MR. KLAYMAN: I'll show you what
7 I'll ask the court reporter to mark as
8 Exhibit 11.
9 (Anderson Deposition Exhibit
10 No. 11 was marked for
11 identification.)
12 BY MR. KLAYMAN:
13 Q Showing you Exhibit 11, this is a
14 document, Bates number 023441. On the top,
15 "White House Personnel Security File Staff
16 Prior to 1/20/93." It spans to Bates number
17 023450. Have you ever seen this document
18 before?
19 A I do not remember.
20 Q What kind of a list is this? I
21 take it it's a list?
22 A I do not know.
365
1 Q Do you see where it talks about
2 James Addison Baker on the first page?
3 A Yes.
4 Q His name is not struck out?
5 A Yes.
6 Q You don't know whether this list
7 was ultimately submitted to the FBI that led
8 to procuring Mr. Baker's file, do you?
9 A I do not know, but, since it was
10 prior to 1/20/93, I would assume we were not
11 in office.
12 Q Well, you were in office on
13 1/20/93?
14 A In the afternoon.
15 Q Well, you wasted no time, I guess,
16 right?
17 A I wasn't there. I wouldn't know.
18 Q You weren't there at the time?
19 A No.
20 Q So you don't know whether this list
21 was ultimately used to prepare requisition
22 forms later to get files from the FBI?
366
1 A I don't recognize this list, no.
2 Q You don't know one way or the
3 other?
4 A (Shaking head)
5 Q Do you see the handwriting on the
6 first page?
7 A Yes.
8 Q Do you know whose handwriting that
9 is?
10 A No.
11 Q So the question was -- I don't
12 believe I heard a response -- you don't know
13 whether this was the list that was used to
14 prepare the requisition forms to get the file
15 of Mr. Baker from the FBI?
16 A I do not know.
17 Q Look at the last page, 023450. Do
18 you see the handwriting on there?
19 A Yes.
20 Q Is that Mr. Marceca's handwriting?
21 A I do not know. It looks too
22 legible, but I'm not sure.
367
1 Q Whose handwriting is that?
2 A I do not know.
3 Q Is that a woman's handwriting?
4 A I do not know.
5 Q Is that yours?
6 A No.
7 Q Have you ever heard of a Joan
8 Hilty, Joanne Hilty?
9 A Yes.
10 Q Who is Joanne Hilty?
11 A She worked in the office of the
12 Vice President.
13 Q How did you get to know Ms. Hilty?
14 A Through the course of working in
15 office of White House personnel.
16 Q And how did you come to be in
17 contact with her, specifically?
18 A She was the one in the Office of
19 Vice President who was to handle the initial
20 contact of who the employees worked for, the
21 Office of Vice President, and I believe, but
22 I could be mistaken, she handled their
368
1 security.
2 Q Now, persons in your office
3 sometimes took FBI files over to the Vice
4 President's office, correct?
5 A I do not remember.
6 Q You're not saying it didn't happen?
7 A I do not remember us taking files
8 over to his office.
9 Q The Vice President's office.
10 A I do not believe that we ever did.
11 Q You are aware, however, that files
12 were requested from the Vice President's
13 office, FBI files, for you to get?
14 A I am not aware of that. I am aware
15 that Joanne Hilty would be our contact person
16 when we needed information from -- as to who
17 was in the office, who we needed an SF-86 on.
18 That's as far as I remember Joanne.
19 Q Do you know of any direction by
20 anyone at The White House, whichever told the
21 Vice President's office, you can't get FBI
22 files?
369
1 A I do not remember that.
2 MR. KLAYMAN: I'll show you what
3 I'll ask the court reporter to mark as
4 Exhibit 12.
5 (Anderson Deposition Exhibit
6 No. 12 was marked for
7 identification.)
8 BY MR. KLAYMAN:
9 Q Exhibit 12 consists of two pages,
10 one June 19, 1993. It's unredacted, and the
11 second page bearing handwriting which says
12 "Redacted," Bates number are 19666 and 19665.
13 Have you ever seen this document before?
14 A It looks familiar.
15 Q What leads you to believe it looks
16 familiar? I'm talking about the first page
17 which has June 19, 1993, written on it?
18 MR. GAFFNEY: Excuse me, Larry.
19 Could you provide me a copy of that?
20 MR. KLAYMAN: We gave a whole bunch
21 there. Maybe they'll pass you one.
22 MR. GAFFNEY: Thank you.
370
1 THE WITNESS: The White House,
2 Washington, up at the top and the names.
3 BY MR. KLAYMAN:
4 Q You think you've seen this
5 particular document before?
6 A I may have.
7 Q Memorandum for Joanne Hilty, Office
8 of the Vice President, from William Kennedy
9 III, associate counsel to the President,
10 subject, FBI background summaries, SCI
11 clearances. What are SCI clearances?
12 A That would be clearances granted by
13 the CIA above top secret.
14 Q Even higher than top secret?
15 A Yes.
16 Q Is it the highest clearance one can
17 get?
18 A I do not know.
19 Q It then says, "The FBI has informed
20 me that you've requested copies at the time
21 of delivery to this office of background
22 summaries prepared for this administration.
371
1 I've instructed the FBI not to do so for a
2 variety of reasons. Please contact me if you
3 have questions.
4 "In addition, in the future please
5 direct any requests for SCI code word
6 clearance for persons working in The White
7 House complex to the office of counsel to the
8 president further to my attention for
9 handling."
10 Copies to Bernard Nussbuam, Counsel
11 to the President; Craig Livingstone, Director
12 White House Personnel Security; and Bob
13 Manzanares, Director, NSC Administration.
14 Now, I take it that based on your
15 experience in that office, what's happening
16 here is that William Kennedy is telling the
17 Vice President's office that you've just
18 incorrectly requested SCI clearances? You
19 shouldn't be doing this, correct?
20 MR. GILLIGAN: Object to the form.
21 BY MR. KLAYMAN:
22 Q You can respond.
372
1 A I'm not sure what he was telling
2 them. If I understand this correctly, he was
3 saying that you cannot have copies of the
4 background investigations.
5 Q Do you remember this particular
6 instance? Does this refresh your
7 recollection?
8 A Vaguely.
9 Q And why was it that the Vice
10 President's office was asking for these super
11 top secret FBI files?
12 A I do not know why they were asking
13 for them -- for the -- it seems to me they
14 were asking for the files in preparation for
15 asking for SCI from the CIA and as to why the
16 Vice President's office would ask that, I do
17 not know.
18 Q Did this request have anything to
19 do with people from Communist China at all?
20 A I have no earthy idea.
21 Q Did it have anything to do with
22 John Huang?
373
1 A I have no clue.
2 Q Did it have anything to do with
3 Republicans or others who were politically
4 different from the Clinton Administration?
5 A Again, I have no idea why the
6 Office of Vice President or Mr. Kennedy would
7 say yes or no or why they would even ask.
8 Q You were aware at the time,
9 however, that what the vice president's
10 office had requested was not proper?
11 A I was not aware of that at the
12 time, no.
13 Q But you're aware of it now?
14 A Yes, I've got the memo in front of
15 me.
16 Q And you're aware that William
17 Kennedy on behalf of the counsel to the
18 president told the Vice President's office,
19 you can't do this. We will handle it in the
20 future. Correct?
21 A That does seem to be --
22 MR. GILLIGAN: Object. The
374
1 document speaks for itself.
2 MR. KLAYMAN: I'm going based on
3 what she knew at the time.
4 MR. GILLIGAN: Objection stands.
5 BY MR. KLAYMAN:
6 Q You can respond.
7 A Based on what I'm reading before
8 me, the gist is you cannot have the FBI
9 files.
10 Q Now, the direction to have this
11 matter referred to the office of counsel to
12 the president, that's consistent with your
13 understanding that it's The White House
14 counsel who ultimately controls the
15 requisitioning of FBI files, correct.
16 A They are the ones who ultimately
17 control who has access, yes.
18 Q And in this case it was Bernard
19 Nussbuam, correct?
20 MR. MAZUR: Objection to the form.
21 THE WITNESS: I don't know if he
22 saw this or not but I would assume.
375
1 BY MR. KLAYMAN:
2 Q Who is Bob Manzanares?
3 A I believe it says under his name,
4 director of NSC administration.
5 Q Had you ever met him before?
6 A He had come down to the office now
7 and then.
8 Q On what occasion?
9 A He was not the director of the NSC
10 when we first moved into the office, and he
11 was later -- I don't remember, but he
12 replaced somebody, and when he did come in,
13 he came down and said hi, I'm Bob Manzanares,
14 and every now and then he would come down to
15 the office.
16 Q Did you have a lot of contact with
17 him?
18 A No.
19 Q Now, you don't know whether these
20 files were ultimately provided to the Vice
21 President's office, do you, those referenced
22 in this document?
376
1 A I do not remember.
2 Q Turn to the second page, which
3 redacts out that the memorandum's for Joanne
4 Hilty, Office of the Vice President.
5 MR. GILLIGAN: Objection. You
6 can't possibly know what was redacted out.
7 MR. KLAYMAN: Well, it's quite
8 evident here what's removed.
9 BY MR. KLAYMAN:
10 Q Take a look at this document,
11 Ms. Anderson.
12 Do you see this document?
13 A Yes.
14 Q It's the same document as the
15 earlier document except --
16 MR. GILLIGAN: I object to the
17 characterization because you can't possibly
18 know what's been redacted out.
19 MR. KLAYMAN: Well, the document
20 speaks for itself, but have you ever seen
21 this document that doesn't bear memorandum
22 for Joanne M. Hilty office of the Vice
377
1 President? Have you ever seen a copy like
2 this that doesn't have that designation?
3 A I do not remember.
4 Q Do you see the handwriting at the
5 top where it says "FBI background summaries"?
6 A Yes.
7 Q Is that Craig Livingstone's
8 handwriting?
9 A No.
10 Q Whose handwriting is it?
11 A I'm not sure but I think it might
12 be Lisa's.
13 Q Lisa Wetzl?
14 A Yes.
15 Q Is she still working at The White
16 House? Do you know?
17 A I believe I stated earlier that
18 last I heard she was at the Department of
19 Defense. Where she's at now, I do not know.
20 Q Do you know when she left and
21 joined the Department of Defense?
22 A No.
378
1 Q On the right-hand side it says date
2 and -- there's nothing on the right-hand
3 side.
4 A No.
5 Q This is our own notation on our
6 copy, so strike that. Do you see at the
7 bottom it says, "cc Nussbuam Bernard, Counsel
8 to the President"? It's checked off,
9 Nussbaum?
10 A Yes.
11 Q That means that this letter was
12 sent to Bernard Nussbuam?
13 MR. GILLIGAN: Objection. Calls
14 for speculation.
15 BY MR. KLAYMAN:
16 Q You can respond.
17 A I have no idea what it means.
18 Q You've seen other correspondence,
19 have you not, at the White House where
20 Bernard Nussbuam's name was checked on a cc?
21 A I do not remember.
22 Q That was standard procedure, that,
379
1 if you're going to send a copy to somebody,
2 you'd check off the name at the bottom?
3 A I do not remember.
4 Q Both of these versions of the
5 documents were produced by Defendant
6 Executive Office of the President in this
7 case. Do you have any idea why one did not
8 have the designation "Memorandum for Joanne
9 M. Hilty, Office of the Vice President"?
10 MR. GAFFNEY: I object to the form
11 of the question, Larry. I think, if you hold
12 it up, it sure looks like a different
13 document, different signature, so to the
14 extent you're going to characterize it as a
15 copy --
16 MR. KLAYMAN: Why is that
17 necessary, Mr. Gaffney, for you to spew forth
18 that kind of information on the record?
19 MR. GAFFNEY: I'm entitled to
20 object to the form of the question.
21 MR. KLAYMAN: Did you hear me
22 objecting this morning?
380
1 MR. GAFFNEY: Yes.
2 MR. KLAYMAN: Did I ever provide
3 testimony?
4 MR. GAFFNEY: I'm am not testifying
5 Mr. Klayman.
6 MR. KLAYMAN: That's the way you're
7 supposed to object to a question.
8 MR. GAFFNEY: You have your way of
9 objecting and I have mine.
10 MR. KLAYMAN: And this will be
11 certified and brought before the court.
12 BY MR. KLAYMAN:
13 Q Do you have any knowledge as to why
14 Ms. Hilty's name was removed from the second
15 page of this exhibit?
16 MR. GILLIGAN: Objection. Assumes
17 facts not in evidence.
18 BY MR. KLAYMAN:
19 Q You can respond.
20 A I have no idea how these were
21 prepared or who prepared them or for what
22 reason they were prepared.
381
1 Q Has anyone besides me ever
2 discussed these documents with you before?
3 A No.
4 Q First time you've seen them in a
5 long while?
6 A Probably the first time I've seen
7 them in five years.
8 Q But you never saw the document that
9 was page 2, did you, that had Ms. Hilty's
10 name removed?
11 MR. GAFFNEY: Objection to the form
12 of the question.
13 BY MR. KLAYMAN:
14 Q You never saw that, did you, five
15 years ago?
16 A I do not know. I did not remember
17 seeing these documents until just now.
18 MR. KLAYMAN: I'll show you what
19 I'll ask the court reporter to mark as
20 Exhibit 13.
21 (Anderson Deposition Exhibit
22 No. 13 was marked for
382
1 identification.)
2 BY MR. KLAYMAN:
3 Q What is Exhibit 13?
4 A It looks to be the log.
5 Q Log of what?
6 A The log of the BIs that we had
7 checked out.
8 Q This is when the system was
9 implemented to check out FBI files, correct?
10 A Yes.
11 Q And this was the same log that you
12 previously testified that you didn't know why
13 there was a gap in it when you testified
14 before the Senate, correct?
15 A No, I do not know why there is a
16 gap.
17 Q And during the period of the gap,
18 you don't know whether files were taken out
19 without signing them out, correct?
20 A I believe I have testified before
21 that I remember entering things into the log,
22 and I believe I've also testified that I
383
1 don't know where those pages would be.
2 Q Now, you previously testified about
3 the laptop computer of Mr. Marceca, correct?
4 A Yes.
5 Q Do you know where that laptop is
6 today?
7 A No.
8 Q What computer did Craig Livingstone
9 use in your office?
10 A He didn't.
11 Q Did he use any computers?
12 A Not in our office.
13 Q I take it, then, he kept notes?
14 A As to what? Notes to what?
15 Q When he had to write something
16 down, he took notes?
17 A I assume he had to.
18 Q And you handled the filing for him,
19 didn't you?
20 A We all did in the office.
21 Q Who's we all?
22 A The staff, the interns. If he had
384
1 something to be filed, he would -- we had a
2 bin that you put it in the file -- in the bin
3 to be filed, and it would go into the vault
4 and that is where they would remain till they
5 went into the file of the individual.
6 Q And what kinds of notes were put in
7 that file that Mr. Livingstone generated?
8 A I do not know that he ever wrote
9 handwritten notes to put into files such as
10 you're describing.
11 Q When did you leave, again, the
12 office? What was the date?
13 A In the fall of '95 -- I'm sorry,
14 '94.
15 Q When you left there were those
16 files that were being kept of notes in the
17 vault?
18 A No, I don't know what you're
19 talking about.
20 Q But there were files with notes. I
21 think that's what you just testified; isn't
22 that right?
385
1 A No, I just testified that you had
2 said if Craig had written something -- I'm
3 sorry, you had just said that if Craig had
4 something to be filed I would file it. I
5 said no, if Craig had something to be filed
6 it would be put in a bin inside the vault to
7 be filed and it would be a staff member or
8 intern who would file it. I never said it
9 would be those handwritten notes.
10 Q What kinds of files were kept in
11 the office when you were there?
12 A Personnel --
13 Q What were the categorizations of
14 the files that were kept?
15 A Personnel files.
16 Q Of who?
17 A Current employees of The White
18 House.
19 Q What else?
20 A The only other files would be
21 procedural files that Nancy had prepared.
22 Q And what was the nature of those
386
1 procedural files?
2 A If we had a question after Nancy
3 had left The White House, that would be where
4 we would refer to.
5 Q So, if files were being requested
6 of people that no longer worked at The White
7 House and there was a procedural recordation,
8 what would you put in that file? An issue
9 dealing with procedure you'd put in that
10 file?
11 MR. GILLIGAN: Object for the form.
12 THE WITNESS: Can you rephrase?
13 I'm not sure what you're asking.
14 BY MR. KLAYMAN:
15 Q Well, if something was written down
16 as to why certain files were being requested
17 from the FBI and others weren't you'd make a
18 recordation for the reasons of that and put
19 it in one of those files, correct?
20 A I still don't understand when you
21 say recordation of why files were --
22 Q Let's say the situation where you
387
1 discovered that former Reagan and Bush
2 employees' names were listed on the list? We
3 just went through that?
4 A Mm-hmm.
5 Q That was irregular, correct?
6 That's why you suggested that those names be
7 taken off, correct?
8 A Yes, names that we recognized.
9 Q Was it not the case that a notation
10 was made as to what had happened so you'd
11 have a memo that explained what happened,
12 from time to time, something like that?
13 A I am not sure -- what we would do
14 is if we received a file of someone who was
15 not currently at The White House and we found
16 out that they were not, we took that file and
17 put it in the archive bin, as I have
18 testified to before.
19 Q But what I'm saying is that, when
20 you took these actions, was it not the case
21 in the office that a record would be made as
22 to what was done so in case anybody ever
388
1 questioned you you'd have a record of what
2 was done?
3 A A record of which files we
4 archived?
5 Q Yes.
6 A Yes, we did, we kept a list of the
7 records that we archived.
8 Q But if a decision was to made as to
9 whether to send the files to archives or back
10 to the FBI, wouldn't you write a memorandum
11 to make a record of what was decision was so
12 in case someone asked you in the future you'd
13 have a record of that?
14 A I believe I've just testified that
15 we would make a memorandum saying which files
16 we archived.
17 Q And where was that memorandum kept?
18 A I do not remember specifically. I
19 believe it was in an either file or another
20 logbook.
21 Q And who kept that file or logbook?
22 A I believe it was in the general --
389
1 it would probably either in the procedural
2 files or where we kept the three-ring logbook
3 of what we checked out. I do not remember
4 specifically.
5 Q And who maintained those filing
6 systems?
7 A The whole filing system or the ones
8 that we archived?
9 Q Where that memorandum would have
10 been stored. Who would have been the one
11 that actually put it in some kind of filing
12 system?
13 A Whoever typed it up.
14 Q And who generally typed stuff up
15 for Craig Livingstone?
16 A It would either be me or Lisa or
17 Ed.
18 Q And did he give you what he wanted
19 typed up handwritten out from time to time?
20 A From time to time.
21 Q And you would then keep the copy of
22 what he had written out for your records?
390
1 A If he had written out and I had
2 already typed it up, no. There was no need.
3 It had already been typed up.
4 Q Now, you did keep a chron file of
5 what you typed up for him though, right?
6 A What do you mean by chron file?
7 Q A backup copy?
8 A I kept it on the computer.
9 Q On your computer?
10 A If I had typed it up, I kept it on
11 my computer on a disk that said "Craig
12 Memos."
13 Q And did Lisa ever type stuff for
14 Craig, too?
15 A Yes.
16 Q Did others in the office?
17 A Yes. I believe I've already stated
18 that either me, Ed, or Lisa would have typed
19 it up.
20 Q Which computer did you use?
21 A My computer.
22 Q What kind was that?
391
1 A I believe it would have been a 386,
2 but I'm not certain.
3 Q Do you remember the brand?
4 A No.
5 Q Was it an IBM or Dell or something
6 like that?
7 A It was IBM format.
8 Q Was it a desktop?
9 A Yes, they were all desktop except
10 for the Wang.
11 Q And what kind did Lisa use?
12 A A 286, I believe. IBM format.
13 Brand name I do not know.
14 Q When you created a document you
15 were aware it was going into a central server
16 at The White House as well, correct?
17 A Yes.
18 Q A backup system?
19 A Yes. We were aware everything we
20 created on our computer system was
21 presidential records, so, therefore, it was
22 recorded.
392
1 Q When you left the office, do you
2 know what happened to your computer?
3 A It stayed in the office.
4 Q How do you know that?
5 A I didn't physically remove it and
6 when I left I believe either Ed or Lisa was
7 moving to that spot. I do not remember who.
8 Q Do you know where that computer is
9 today?
10 A I have no clue. I'm sure Office of
11 Administration could probably tell you.
12 Q Who in the Office of
13 Administration?
14 A I'm not sure but you'd have to
15 check with whoever's in charge of that
16 office.
17 Q Who when you were there at The
18 White House would have been the person to go
19 to see about that?
20 A Sharon, but I don't know her last
21 name.
22 Q Were there any dictaphones in your
393
1 office?
2 A No.
3 Q Any recordation devices?
4 A No, I don't type that fast.
5 Q Now, you were aware, were you not,
6 that there were security systems in your
7 office, correct?
8 A When you say "security systems,"
9 what do you mean?
10 Q Video surveillance?
11 A I was not aware of video
12 surveillance.
13 Q Did you ever see video surveillance
14 at The White House?
15 A I did not see it, no.
16 Q You never saw cameras in the
17 hallways or anything like that?
18 A I do not remember. It might just
19 be I might have seen it and just became
20 accustomed to it, but I do not remember it.
21 Q Was there ever any discussion as to
22 whether there were surveillance systems in
394
1 The White House from any source while you
2 were there?
3 A I do remember there was a
4 discussion that there was type of
5 surveillances over the vault.
6 Q Who participated in that
7 discussion, Craig?
8 A I believe maybe Craig but I'm not
9 sure.
10 Q Who else participated in that
11 discussion?
12 A I am not sure and when we talked
13 about it it was the surveillance that the
14 vault was alarmed. I'm not sure if we
15 mentioned video cameras or not but that it
16 was alarmed.
17 Q You assumed that video cameras were
18 involved?
19 A No, I did not.
20 Q How would you have a surveillance
21 system without video cameras?
22 A Because an alarm would go off
395
1 wherever the Secret Service guys were would
2 say that somebody had broken into either the
3 window or through the main door of the vault.
4 Q Who locked the vault each night, if
5 anyone?
6 A Staff members.
7 Q Is it a combination?
8 A Yes.
9 Q Did you have a combination?
10 A I think I've already stated that I
11 had a combination.
12 Q Craig Livingstone had the
13 combination?
14 A All staff members had a
15 combination.
16 Q So anybody who stayed late could
17 have gotten into that vault without others
18 knowing?
19 A They had have had to have notified
20 Secret Service.
21 Q But they could have gotten in
22 without notifying Secret Service because they
396
1 had the combination, correct?
2 A No, they could not have because, as
3 I stated before, there was an alarm that went
4 out wherever the Secret Service guy was
5 sitting that you had to call and you had to
6 be on the list to have authorization to go
7 into that vault, and the only members who had
8 that authorization were Craig, myself, Lisa,
9 and Ed.
10 Q Did you ever go into the vault
11 without anyone else being present?
12 A I worked in the vault sometimes
13 when people were not there, yes.
14 Q And how did you notify the Secret
15 Service that you were going to get into the
16 vault at that time?
17 A When I opened the vault, I called
18 them on the phone and said this is Mari
19 Anderson. I've just opened the vault.
20 Q So you have a certain amount of
21 time to deactivate the system; is that what
22 you're saying?
397
1 A No. Well, there is no system that
2 we can deactivate. You do your combination.
3 You walk into the vault, you go over to the
4 phone, you call them and say this is Mari
5 Anderson, White House personnel security
6 office. We just opened the vault.
7 Q Who did you deal with, Secret
8 Service, that would then be informed?
9 A Whoever was at the other end of the
10 phone line at Secret Service Land.
11 Q Name some names when you were
12 there.
13 A I do not know.
14 Q Did your office keep records of the
15 alarm ever going off?
16 A I do not remember the alarm going
17 off.
18 Q While you were at The White House,
19 you did hear people talk about some type of
20 surveillance, didn't you, besides alarms,
21 that perhaps conversations were being
22 recorded?
398
1 A There were jokes, but I don't
2 remember the specific conversation.
3 Q Who made the jokes?
4 A I do not remember specifically. I
5 know it was in relation to Oliver Stone and
6 his conspiracy theories.
7 Q Now, Craig Livingstone made the
8 jokes in part, correct?
9 A As I just said, I do not remember
10 who made the -- I just remember we were
11 joking around in the office. Who was in
12 there specifically, I do not know.
13 Q You're aware that when you go into
14 your local 7-11 they have a video camera,
15 correct?
16 A I'm aware of many places I go into
17 there's a video camera.
18 Q The bank?
19 A The ATM. Yes, many places.
20 Q Any place that requires security,
21 correct?
22 A Any place where they deem they want
399
1 the security, yes.
2 Q So, based on your prior experience
3 you always assume there must be some
4 surveillance systems in The White House?
5 A I never, as I stated before,
6 assumed that there were surveillance systems.
7 I assumed that there was the alarm system in
8 the vault. I did not assume that there was
9 surveillance in our office. I did not assume
10 that somebody was recording every word that
11 we said.
12 Q Did you ever go into any office,
13 Secret Service office or any other office,
14 and see television monitors?
15 A I do remember that there were
16 television monitors at some Secret Service
17 desk, like WAVES desk and when you walked
18 into The White House, but The White House was
19 a different horse than the OEOB.
20 Q And you saw in fact on some of
21 those monitors your office while you were
22 there?
400
1 A I never paid -- never saw my
2 office, and you're asking me about things
3 that I really don't know about. I never saw
4 our office on a monitor. I never stopped to
5 look at the security guard desk and see what
6 pictures were being shown.
7 Q You were told to be careful about
8 what you said in the office, were you not,
9 not just to blurt anything out?
10 A I was told to be aware of who was
11 in the office when we were speaking of what
12 was our daily functions.
13 Q And Mr. Livingstone did tell you be
14 careful because your conversation may be
15 recorded?
16 A No, I'm saying that he said be
17 careful because there may be someone in the
18 office who is not authorized to hear some of
19 the information which we had in our
20 possession that we needed to say hey, did you
21 get so and so's BI? It's dated XYZ, or can
22 you read this? I can't read this person's
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