1
1 UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
2
---------------------------------x
3 CARA LESLIE ALEXANDER et al., :
:
4 Plaintiffs, :
:
5 v. : No. 96-2123-RCL
:
6 FEDERAL BUREAU OF INVESTIGATION :
et al., :
7 :
Defendants. :
8 ---------------------------------x
9 Washington, D.C.
10 Tuesday, March 3, 1998
11 Video deposition of
12 PAUL E. BEGALA
13 a witness, called for examination by counsel
14 for Plaintiffs, pursuant to notice and
15 agreement of counsel, beginning at
16 approximately 10:15 a.m., at the offices of
17 Judicial Watch, 501 School Street S.W.,
18 Washington, D.C., before Michele M. Howell,
19 notary public in and for the District of
20 Columbia, when were present on behalf of the
21 respective parties:
22
2
1 APPEARANCES:
2 On behalf of Plaintiffs:
3 LARRY KLAYMAN, ESQUIRE
DON BUSTION, ESQUIRE
4 TOM FITTON, ESQUIRE
Judicial Watch
5 501 School Street S.W.
Washington, D.C. 20024
6 (202) 646-5172
7
On behalf of Defendants:
8
ELIZABETH J. SHAPIRO, ESQUIRE
9 DAVID J. ANDERSON, ESQUIRE
U.S. Department of Justice
10 901 E. Street N.W.
Washington, D.C. 20630
11 (202) 616-8202
12
On behalf of Hillary Clinton:
13
MARCIE ZIEGLER, ESQUIRE
14 Williams & Connolly
725 12th Street N.W.
15 Washington, D.C. 20005
(202) 434-5874
16
17 ALSO PRESENT:
18 Sally Patricia Paxton
19
20 * * * * *
21
22
3
1 C O N T E N T S
2 EXAMINATION BY: PAGE
3 Counsel for Plaintiffs 6
4 BEGALA DEPOSITION EXHIBITS:
5 No. 1 - White House Press Release 26
6 No. 2 - Judicial Watch Press Release 62
7 No. 3 - New York Times Report 78
8 No. 4 - Transcript of Speech 86
9 No. 5 - February 3, 1998, Press Account 136
10 No. 6 - Peter Yost Press Account 143
11 No. 7 - November 26, 1997, Fax 160
12 No. 8 - Document 172
13 No. 9 - Stephanopoulos Transcript 195
14 No. 10 - Dark Side of Camelot, Excerpt 210
15 No. 11 - Dennis Casey Testimony 259
16 No. 12 - Washington Post Article 332
17 No. 13 - Washington Post Report 339
18 No. 14 - Begala Affidavit 351
19 No. 15 - Monthly Calendar 379
20 No. 16 - Memorandum, Livingston to Kennedy 417
21 No. 17 - EOP Access List 419
22 * * * * *
4
1 P R O C E E D I N G S
2 VIDEOGRAPHER: Good morning. This
3 is the video deposition of Paul Begala taken
4 by the counsel for the Plaintiff in the
5 matter of Cara Leslie Alexander, et al.
6 versus Federal Bureau of Investigation, et
7 al. The U.S. District Court for the District
8 of Columbia, Case Number 96-2123(RCL) held in
9 the offices of Judicial Watch, 501 School
10 Street S.W., Washington D.C. on this date,
11 March 3, 1998, and at the time indicated on
12 the video screen which is 10:15 a.m.
13 My name is Sylvanus Holley. I am
14 the videographer. The court reporter today
15 is Michele Howell from the firm of Beta
16 Reporting.
17 Will counsel, please, introduce
18 themselves?
19 MR. KLAYMAN: My name is Larry
20 Klayman. I am general counsel of Judicial
21 Watch.
22 MR. BUSTION: Don Bustion, attorney
5
1 Judicial Watch.
2 MR. FITTON: My name is Tom Fitton,
3 I am legal assistant for Judicial Watch.
4 MS. SHAPIRO: Elizabeth Shapiro,
5 counsel for Mr. Begala, and Executive Office
6 of the President.
7 MR. ANDERSON: David J. Anderson,
8 counsel for Mr. Begala and the defendants.
9 MS. PAXTON: Sally Paxton with the
10 White House.
11 MS. ZIEGLER: Marcie Ziegler, for
12 the defendant, Hillary Clinton.
13 MR. KLAYMAN: Mr. Anderson, are you
14 with the government or are you in a private
15 law firm?
16 MR. ANDERSON: FBI.
17 MS. SHAPIRO: Working with the
18 Department of Justice.
19 MR. KLAYMAN: You are working with
20 the Department of Justice?
21 MR. ANDERSON: Yes.
22 MR. KLAYMAN: Swear the witness.
6
1 THE VIDEOGRAPHER: Would the court
2 reporter, please, swear in the witness?
3 Whereupon,
4 PAUL E. BEGALA
5 was called as a witness and, having been
6 first duly sworn, was examined and testified
7 as follows:
8 EXAMINATION BY COUNSEL FOR
9 PLAINTIFFS
10 BY MR. KLAYMAN:
11 Q Mr. Begala, please, state your
12 name?
13 A Paul Begala.
14 Q When were you born?
15 A May 12, 1961.
16 Q Where you attended high school?
17 A Sugarland, Texas.
18 Q Is that where you were born, in
19 Texas?
20 A No, I was born in New Jersey.
21 Q When did you graduate from high
22 school?
7
1 A 1979.
2 Q What did you do at that time?
3 A I don't understand.
4 Q Did you go to college?
5 A Yes.
6 Q Go into the military?
7 A I went on to college.
8 Q Where you attended college?
9 A University of Texas at Austin.
10 Q What did you major in?
11 A Government.
12 Q When did you graduate from
13 University of Texas at Austin?
14 A 1983.
15 Q During the time that you were at
16 the University of Texas, were you ever
17 subject to any kind of disciplinary
18 proceedings or anything to that effect?
19 A No.
20 Q Were you active in politics?
21 A Yes.
22 Q What did you do at the University
8
1 of Texas in that regard?
2 A I was a student body president.
3 Q Were you a member of any democratic
4 party organizations?
5 A I don't remember.
6 Q When you graduated from the
7 University of Texas, what did you do at that
8 time?
9 A I worked in a political campaign.
10 Q What campaign was that?
11 A Lloyd Doggett for U.S. Senate.
12 Q Is he from Texas?
13 A He is, from Austin.
14 Q What was your position working for
15 Lloyd Doggett?
16 A I was his travel aide.
17 Q Did there come a point in time when
18 you left Mr. Doggett and went to work for
19 someone else?
20 A We lost the campaign to Senator
21 Graham.
22 Q What happened at that time?
9
1 A I went to law school at the
2 University of Texas. I began there and
3 continued to do campaign work on the side.
4 Q Same law school at Austin or
5 different branch?
6 A University of Texas at Austin.
7 Q Did you graduate from the
8 University of Texas at Austin?
9 A I did.
10 Q In what year?
11 A I got my law degree in 1990.
12 Q What years did you go to the
13 University of Texas?
14 A From '89 to '90 intermittently,
15 concluded in 1990.
16 Q During that period you didn't
17 experience any disciplinary problems at the
18 University of Texas?
19 A That's correct.
20 Q Did you take the bar exam?
21 A I did.
22 Q Where did you take it?
10
1 A Pennsylvania.
2 Q Did you pass?
3 A I did.
4 Q What year did you pass the bar
5 exam?
6 A I think 1991, but I am nor sure.
7 Q Are you a member of any other state
8 bar associations?
9 A No.
10 Q What caused you to take the bar
11 exam in Pennsylvania?
12 A I was living in Northern Virginia
13 at the time. It was nearby. It had a
14 reputation, frankly, for being easier than
15 some others.
16 Q What caused you to move from Texas
17 to Northern Virginia?
18 A I was offered a job in Washington.
19 Q What job were you offered?
20 A Working for Congressman Gephardt.
21 Q What did you do for Congressman
22 Gephardt?
11
1 A I was a speech writer.
2 Q What year did you begin working for
3 Congressman Gephardt?
4 A In 1989, as a speech writer on
5 Capitol Hill.
6 Q How long did you stay with
7 Congressman Gephardt?
8 A Again, intermittently until 1991.
9 Q What happened in 1991?
10 A I left Congressman Gephardt's
11 employ to run a political campaign.
12 Q Which political campaign was that?
13 A Harris Wofford for the United
14 States Senate.
15 Q This was a campaign for Senate,
16 correct?
17 A Correct.
18 Q Mr. Wofford had been the president
19 of Bryn Mawr College, is that where he came
20 from?
21 A That was one of many previous jobs.
22 He was appointed to the Senate on the death
12
1 of Senator Hines.
2 Q What did you do for Mr. Wofford?
3 A I was his campaign manager.
4 Q Did you have any prior experience
5 as being a campaign manager before you went
6 to work for Mr. Wofford?
7 A No, not as a campaign manager.
8 Q Up to that point in time, had you
9 ever met a James Carville?
10 A Oh, yeah.
11 Q When did you meet James Carville?
12 A 1983.
13 Q What were the circumstances of your
14 meeting him?
15 A He is was hired to be Lloyd
16 Doggett's campaign manager.
17 Q At the time that you accepted this
18 position as campaign manager for Mr. Wofford,
19 were you in business with Mr. Carville?
20 A Yes.
21 Q When did you first go into business
22 with Mr. Carville?
13
1 A He and I have done a variety of
2 campaigns together over the years.
3 Q What other campaigns had you done
4 over the years with him?
5 A With him, now Congressman, then
6 candidate Doggett in 1984. In 1986, I worked
7 with James on Bob Casey's campaign for
8 governor of Pennsylvania.
9 I worked with James for awhile, for
10 Wilkinson for governor of Kentucky, I can't
11 remember the year.
12 In '88, I worked with James for
13 Frank Lautenberg, the U.S. Senator from New
14 Jersey who was up for reelection.
15 In '90, I worked with James on Zell
16 Miller's campaign for governor of Georgia.
17 Q Any other campaigns that you worked
18 with James?
19 A Not that I recall at the top of my
20 mind, but we did a variety of campaigns.
21 Q Were there any or campaigns up
22 to 1991, when you went to work as campaign
14
1 manager for Mr. Wofford, that you worked on,
2 with or without James?
3 A I worked for Congressman Gephardt,
4 when he ran for president as his speechwriter
5 in 1987 and '88.
6 I have done spot consulting work
7 and occasional speech for different
8 candidates. I think that is about it, but I
9 don't have my resume in front of me, so I
10 don't want to --
11 Q During the period up to the point
12 that you we went to work for Mr. Wofford, had
13 you ever been in charge of any campaign in
14 gathering information about opponents?
15 A No.
16 Q Did you work with people who were
17 in charge with that function?
18 A Research department, every campaign
19 has one.
20 Q Let's discuss for, for instance,
21 the campaign concerning Bob Casey. Who was
22 in charge with gathering information about
15
1 opponents in that campaign?
2 A We didn't have a department that
3 gathered information about opponents. We had
4 research both on Mr. Casey's issues and
5 positions, and on the opponents's issues and
6 positions. At the top of my mind, I cannot
7 remember who ran that division of the
8 campaign. It has been almost twelve years.
9 Q Were any outside investigators
10 employed in the Casey campaign?
11 A Not that I know of.
12 Q Did you ever work on a campaign
13 after working with Mr. Wofford where outside
14 investigators were employed?
15 A Not that I knew of.
16 Q That didn't mean that there weren't
17 investigators, correct?
18 A I can only speak to what I know. I
19 never was aware of any.
20 Q Up to the point that you went to
21 work for Mr. Wofford as campaign manager, had
22 you ever come in contact with a Craig
16
1 Livingstone?
2 A No.
3 Q Are you aware that Craig
4 Livingstone was involved in Pennsylvania
5 politics?
6 A I have heard that from newspaper
7 accounts, from press accounts.
8 Q At the time that you went to work
9 for Mr. Wofford, have you ever been in
10 contact with Mr. Anthony Marceca?
11 A No.
12 Q Up to the time that you went the
13 work for Mr. Wofford, had you ever met
14 President Bill Clinton?
15 A No.
16 Q I'm talking 1991?
17 A Up until the time I went to work
18 for Senator Wofford.
19 Q Same question with regard to
20 Hillary Clinton?
21 A Correct.
22 Q You had not met her?
17
1 A Not that I can recall, no.
2 Q Aside from Mr. Casey and Mr.
3 Wofford, had you ever worked for other
4 Pennsylvania candidates or politicians?
5 A No.
6 Q Up to that point in time?
7 A Right, I have not.
8 Q Do you know of anyone who has
9 worked with Mr. Livingstone or Marceca prior
10 to time that they joined the White House?
11 A No.
12 Q Do you know what I meant by that?
13 A If you could clarify it.
14 Q Up to the point that Livingstone
15 and Marceca became employees at the White
16 House, are you aware of them having worked
17 with other people up?
18 A I don't know anything about them,
19 so no.
20 Q Tell me what your duties and
21 responsibilities were as campaign manager for
22 Harris Wofford?
18
1 A To manage and direct the campaign,
2 which included the staff, the scheduling of
3 the candidate, hiring and supervising
4 consultants who ran political ads and
5 conducted polls. The business of running a
6 campaign.
7 Q Did Harris Wofford have a research
8 department as well?
9 A Um-hum.
10 Q Who ran that research department?
11 A My recollection is that Eric Berman
12 ran it.
13 Q Who is Eric Berman?
14 A He is the guy who ran the research.
15 Q Where is he now?
16 A I think he is in New York.
17 Q What does he do?
18 A I think he does public relations,
19 but I am not sure.
20 Q Was anyone else in that research
21 department with Mr. Berman?
22 A I am sure, but I cannot remember
19
1 particulars.
2 Q Did the Wofford campaign employ any
3 investigators either in house or out house?
4 A No, sir.
5 Q Do you know whether Mr. Carville
6 has ever employed outside investigators in
7 political campaigns?
8 A No, I don't.
9 Q How long did you work for Harris
10 Wofford?
11 A Well, I ran his campaign from, my
12 recollection is May of '91 to the election in
13 November, and worked on his reelection which
14 was in 1994.
15 In between then, I did some
16 consulting for Senator Wofford in the
17 Pennsylvania democratic party.
18 Q When you worked for Senator
19 Wofford, were you employed individually or
20 were you employed by virtue of being a member
21 of some corporation or company?
22 A I was a part of a firm called
20
1 Carville and Begala.
2 Q When was that firm founded?
3 A You know, we never real had
4 articles of incorporation. We had never had
5 a formal signed agreement. We worked
6 together on and off since '84.
7 Q Did you have an office?
8 A Yes.
9 Q Where was the office?
10 A On Capitol Hill.
11 Q What was the address?
12 A 329 Maryland Avenue.
13 Q Is that office still used by
14 Mr. Carville?
15 A No.
16 Q What did the lease say on terms of
17 who rented that space?
18 A I don't know.
19 Q When did you take that lease out?
20 A I didn't, James did.
21 Q What year was that?
22 A I don't know.
21
1 Q Roughly speaking?
2 A I don't remember. I am sorry.
3 Q Presumably, you started the firm
4 before you went to work for Harris Wofford,
5 correct?
6 A We are very close friends so it was
7 a very informal -- we had a letterhead that
8 said Carville and Begala, but we never
9 executed any papers. It was a handshake.
10 Q Did you have anything written down
11 as to how compensation would be divided among
12 the two of you?
13 A No. We had a lawyer once draft a
14 partnership agreement. Neither of us took
15 the time to read it or sign it. We are just
16 friends.
17 Q Who was the lawyer?
18 A An attorney we hired. Can I take a
19 moment?
20 (Witness conferred with
21 counsel)
22 THE WITNESS: The lawyer's name was
22
1 Victoria Radd.
2 BY MR. KLAYMAN:
3 Q Victoria Rath?
4 A Radd.
5 Q Where was she located in
6 Washington, D.C.?
7 A Yes.
8 Q Is she still in this vicinity?
9 A I think so.
10 Q Aside from that lease agreement,
11 have you ever consulted with her on any other
12 mater?
13 A That was not a lease agreement.
14 She drafted a partnership agreement that we
15 never used. I didn't want to embarrass her.
16 I am sure it was good. We just never read
17 it.
18 Not that I recall. Yes, I do
19 recall. I asked her once to give us advice.
20 MS. SHAPIRO: Objection.
21 MR. KLAYMAN: The general subject
22 matter. I'm not going to ask him the advice
23
1 that was given, just the general subject
2 matter.
3 THE WITNESS: The general subject
4 matter was whether doing a campaign in
5 another country would require a foreign
6 agent's registration act.
7 BY MR. KLAYMAN:
8 Q What country was that?
9 A Greece.
10 Q Did there come a point in time when
11 you met a George Stephanopoulos?
12 A Yes.
13 Q When did you meet George
14 Stephanopoulos?
15 A To the best of my recollection,
16 1989.
17 Q How did you meet him?
18 A He was hired at then majority
19 leader Gephardt's office, about the same
20 time -- that was about the same time Gephardt
21 became majority leader.
22 Q What was Mr. Stephanopoulos hired
24
1 to do?
2 A To be the floor manager, manager of
3 the floor personnel. I don't know the formal
4 title. To work the floor of the House for
5 the majority leader.
6 Q Did you work closely with
7 Mr. Stephanopoulos?
8 A Yes.
9 Q You got to know him very well?
10 A Yes.
11 Q Saw him socially?
12 A I don't see very many people
13 socially, but I suppose.
14 Q Are you married?
15 A Yes.
16 Q When were you married?
17 A 1989.
18 Q What is the name of your wife?
19 A I find that invasive. I am happy
20 to help you, Mr. Klayman, but --
21 Q That is a standard question. I
22 didn't ask you for your address or anything
25
1 like that, just what your wife's name is?
2 MS. SHAPIRO: Is it necessary?
3 MR. KLAYMAN: Yes.
4 MS. PAXTON: Why?
5 MS. SHAPIRO: What is it?
6 MR. KLAYMAN: It may lead to
7 relevant evidence.
8 MS. SHAPIRO: Like what? In what
9 way?
10 MR. KLAYMAN: I think it is pretty
11 apparent, Elizabeth, it is a very innocuous
12 question.
13 THE WITNESS: I do want to be
14 helpful, but it is a personal question. If I
15 am instructed to answer, I will.
16 BY MR. KLAYMAN:
17 Q I don't think the name of your wife
18 is personal. I am sure it, probably, is
19 published in White House directories?
20 A Not that I know of.
21 Q I would think so.
22 MS. PAXTON: Let's take a minute.
26
1 (Witness conferred with
2 counsel)
3 VIDEOGRAPHER: We are going off
4 video records at 10:31 a.m.
5 MR. KLAYMAN: It was pointed out to
6 me that, in fact, we have a press release
7 from the White House which lists the name of
8 your wife, whose name is Diane.
9 We ask that this be marked as
10 Exhibit 1 to Mr. Begala's deposition.
11 MS. SHAPIRO: Our objection to the
12 relevancy still stands. We are not
13 instructing him not to answer.
14 (Begala Deposition Exhibit
15 No. 1 was marked for
16 identification.)
17 BY MR. KLAYMAN:
18 Q During the period that you worked
19 for Harris Wofford, did you work for any
20 other political candidates?
21 A Not that I can remember, although
22 we might have -- I think we had an ongoing
27
1 consulting relationship for the Governor of
2 Georgia, who is Zell Miller.
3 Q I take it that Mr. Carville also
4 worked on the Wofford campaign?
5 A Yes, he did.
6 Q It was a campaign where health care
7 became an issue?
8 A Right.
9 Q It led to later discussions, in the
10 Clinton administration, about making that an
11 issue as well?
12 A It led to Senator Wofford's
13 election, which was what I was concerned
14 about.
15 Q What, if anything, did you do in
16 terms of political campaigns after the first
17 Wofford campaign?
18 A Carville and I were signed on to
19 consult for Senator Glenn, John Glenn of Ohio
20 who was up for reelection.
21 In December of '91, we signed on to
22 go to work for Governor Clinton, Governor of
28
1 Arkansas, presidential campaign. The Glenn
2 contract was short-lived -- because we were
3 too busy with the Clinton contract.
4 Q What did you do specifically for
5 John Glenn?
6 A Met with him several times and
7 talked with him about his upcoming
8 reelection. As I said, we wound up ending
9 the contract because we were too busy with
10 the Clinton contract.
11 Q During the period that you worked
12 for Senator Glenn, did you ever have any
13 discussions about the Keating 5 scandal?
14 A Not that I can recall.
15 Q That doesn't mean that you didn't.
16 You realize that you are under oath and you
17 have to tell the whole truth?
18 A Yes, sir, that is why I don't want
19 to guess.
20 MS. SHAPIRO: Objection.
21 BY MR. KLAYMAN:
22 Q Are you saying that was a not a
29
1 relevant issue in the campaign?
2 A I did very little work for him. I
3 would have loved to, because I considered him
4 a man of great integrity. I was so
5 overwhelmed with the burdens of the
6 presidential campaign. I just don't recall
7 specifically.
8 Q Do you know what the Keating 5
9 scandal is about?
10 A Vaguely.
11 Q What was it about?
12 A Vaguely it was about allegations of
13 savings and loans.
14 Q The payoffs by Charles Keating to
15 John Glenn in part, correct, as well as some
16 Republicans?
17 A Not that I know of.
18 Q For special favors, correct?
19 A I have the highest respect for John
20 Glenn.
21 Q I didn't ask you whether you had
22 high respect for him. I asked you whether
30
1 you knew what the allegations of the scandal
2 were about?
3 A I know vaguely.
4 Q Do you consider that to be an
5 important allegation, a Senator received
6 payoffs in exchange for favors to the savings
7 and loan industry?
8 MS. SHAPIRO: Objection to the
9 relevancy.
10 MR. KLAYMAN: I want to get to the
11 witness' state of mind here.
12 Is that a serious allegation?
13 THE WITNESS: It is certainly
14 serious.
15 BY MR. KLAYMAN:
16 Q That is certainly something that as
17 someone who worked on the campaign, you would
18 want to know about?
19 A I am sure. I don't remember if it
20 became an issue in his '92 reelection. I
21 didn't wind up working for him, but only
22 because I got so busy with Bill Clinton.
31
1 Q Was it James Carville who dealt
2 with that issue on behalf of John Glenn?
3 A Not that I recall.
4 MS. SHAPIRO: Objection. Assumes
5 facts not in evidence. He has not testified
6 he knows anything about that issue.
7 MR. KLAYMAN: He can respond.
8 THE WITNESS: I have.
9 BY MR. KLAYMAN:
10 Q What issues, if any, did you
11 discuss with Senator Glenn?
12 A I can't remember. It is just a
13 nascent stage of a reelection effort. I
14 can't remember any particulars that we got
15 into back then. It was just a campaign --
16 Q Are you aware of any sources of
17 Senator Glenn's campaign contributions?
18 A No.
19 Q Are you aware that he has taken
20 money from the Riadys and John Wan?
21 A I have no idea.
22 Q How did you and Mr. Carville get
32
1 involved with the Clinton campaign? What
2 lead up to that? How did you make the
3 contact?
4 A Governor Miller of Georgia called
5 one day in the fall of '91, and said that his
6 friend, the Governor of Arkansas, had been in
7 Atlanta to visit him, was considering a run
8 for the presidency, and that Governor Miller
9 had told Governor Clinton that he should talk
10 to us about working for him.
11 So, Miller then called us and urged
12 us to go meet with him.
13 Q Up to that point in time, had
14 either you or Mr. Carville either met
15 Mr. Clinton and his wife?
16 A I don't know with James but I do
17 not recall meeting Governor Clinton or his
18 wife prior to that time.
19 Q Did you then call Governor Clinton?
20 A No, I think he called us, but we
21 met with him.
22 Q Where were you working at the time
33
1 that he called you? On Capitol Hill?
2 A We had an office on Capitol Hill.
3 Q Is that where he called you?
4 A I don't remember. We might have
5 been in Pennsylvania.
6 Q Did you subsequently meet with
7 Governor Clinton?
8 A We did.
9 Q Where did you meet with him?
10 A In Washington.
11 Q He came to see you?
12 A He was in Washington on other
13 business.
14 Q Did he come with anyone? Was he
15 present with Hillary Clinton?
16 A He was not with Mrs. Clinton.
17 Q Was he with anyone else?
18 A I can't remember precisely.
19 Q Where did you meet him?
20 A At a hotel he was staying in.
21 Q What was discussed?
22 MS. SHAPIRO: Can we take a moment,
34
1 please?
2 MR. KLAYMAN: For what?
3 MS. SHAPIRO: Because I am
4 considering inserting an objection and I
5 would like to take a moment to discuss it
6 before making a formal decision.
7 MS. PAXTON: Why don't we step
8 outside?
9 VIDEOGRAPHER: We are going off
10 video record at 10:38.
11 (Discussion off the record)
12 VIDEOGRAPHER: We are back on video
13 record at 10:41.
14 BY MR. KLAYMAN:
15 Q What was raised by Mr. Clinton
16 during that meeting?
17 A I was struck that he raised the
18 issues and ideas that he wanted to run on,
19 not the strategy that he could win on.
20 Carville and I, at the time, were
21 talking to several people over the next few
22 months, talking to several people thinking
35
1 about running for President.
2 I was struck this guy did not talk
3 strategy with strategists, he talked
4 substance.
5 Q Just briefly, I don't want to
6 belabor it, it what was the general nature of
7 the different substance that he raised with
8 you?
9 A He talked about his ideas to revive
10 the economy and to mend the social fabric. I
11 remember that because those are the two
12 things that he talks about, he talked about
13 at every occasion in that campaign.
14 I was struck that he was focused on
15 ideas and not strategy. Strategists are,
16 often, sort of just not dealt with about
17 substance.
18 Q He, obviously, discussed with you
19 who his likely opponents would be, correct?
20 A Not that I recall, that was what
21 was so striking. Most politicians when they
22 meet with a guy like me first time talk about
36
1 strategy. I think, I can place in the top
2 three in New Hampshire, then I can win in
3 California. I don't remember any of that.
4 I was struck by that he was talking
5 about ideas and substance. I was impressed.
6 Q Where did the meeting take place?
7 A In a hotel lobby.
8 Q Which hotel?
9 A I can't remember.
10 Q How long was the meeting?
11 A Maybe a couple of hours, I don't
12 remember.
13 Q At that point in time, you and
14 Mr. Carville had already developed a
15 reputation as good democratic party political
16 consultants, correct?
17 A Probably, not much of one. Clinton
18 had never heard of us.
19 Q But the success with Wofford
20 obviously was a big success.
21 A This was before Wofford's election.
22 Q This was before Wofford?
37
1 A This was while we were working on
2 that campaign.
3 Q During the first campaign?
4 A I remember clearly, my final
5 comment to him was that the best thing we can
6 do to help anybody elect is to not go to work
7 for you, is to help Harris Wofford get
8 elected to Senate. That is the only thing we
9 were thinking about.
10 Q That is because that was a test
11 campaign?
12 A That was because that was the only
13 client that we had. We never put
14 in ���� consequence. We had to win that
15 particular race in order to serve that client
16 well.
17 Q Who was it that Wofford ran against
18 the first time?
19 A Governor Thornberg.
20 Q Did there come a point in time
21 where you had a later meeting or conversation
22 with Mr. Clinton, or anyone associated with
38
1 Mr. Clinton, about handling his political
2 campaign for President?
3 A Um-hum.
4 Q When did that occur?
5 A After Senator Wofford's election,
6 which was November of '91.
7 Q Where did that conversation take
8 place? And how did it take place?
9 A I don't recall.
10 Q Was it by telephone or in person?
11 A I don't remember.
12 Q But you know you had one?
13 A I am sure.
14 Q Who was present during the
15 conversation, who participated?
16 A I remember talking to David
17 Wilhelm, who was the Governor's campaign
18 manager, and then later meeting with the
19 Governor, agreeing to go to work for him.
20 Q Up to that point in time, including
21 that point in time, had you ever talked with
22 Hillary Clinton?
39
1 A No.
2 Q Was there anyone else besides
3 Mr. Wilhelm and the governor that you met
4 with or talked with?
5 A Stephanopoulos had signed on with
6 him.
7 Q Excuse me?
8 A George Stephanopoulos was working
9 for Governor Clinton at the time.
10 Q You talked with him before that
11 second conversation with President Clinton?
12 A I think so.
13 Q Where did you talk to
14 Stephanopoulos?
15 A My recollection is Washington.
16 Q Was it over lunch? Was it a series
17 of telephone conversations? How much contact
18 was there?
19 A I don't remember. I remember
20 talking to him George, being impressed with
21 him. I do want to help, I mean, let me
22 finish.
40
1 Q Sure.
2 A George was very impressed with him.
3 He urged me to go to work for him.
4 Q During those conversations, surely
5 you must have discussed the potential
6 opponents of the Governor for President?
7 A I can't remember that. At that
8 time, I was meeting with some of his
9 potential opponents, so I wasn't eager to be
10 swapping information.
11 Q What potential opponents were you
12 meeting with?
13 A Senator Harkin, Senator Carey of
14 Nebraska. I think that is all.
15 Q Were they approaching you in terms
16 of possibly hiring you and James Carville?
17 A Yes.
18 Q Was Governor Clinton aware that you
19 were talking with others?
20 A I don't know. I would guess,
21 because I think it was in the paper, but I
22 don't remember.
41
1 Q Did there come a point in time when
2 you had another conversation with Governor
3 Clinton and anyone associated with Governor
4 Clinton?
5 A Sure.
6 Q When was that?
7 A If you can be more specific. I
8 went to work for him.
9 Q See, I can't tell because only you
10 know. When did you have the next
11 conversation, roughly speaking?
12 A I started working for him on
13 December 1 of 1991.
14 Q You and Mr. Carville?
15 A Right, as a firm.
16 Q Did you have a series of meetings
17 up to that point in time?
18 A I think, I remember one other time
19 talking to him. It was more James and I
20 talking to each other about who we wanted to
21 work for.
22 Q What did you and James discuss in
42
1 terms of who you wanted to work for?
2 A James was deeply impressed with Bob
3 Carey, I was very impressed with Senator
4 Harkin. In the end both of us were most
5 impressed with Governor Clinton.
6 Q Is that because he had the greatest
7 potential to win in your eyes?
8 A I don't know that. Certainly that
9 played a role in it. But also, he had, in my
10 eyes, the right message. That is what I care
11 most about in the campaigns, what a candidate
12 says, what he or she stands for and runs on.
13 Q In evaluating whether you wanted to
14 work for Governor Clinton to run for
15 President in 1992, clearly you must have
16 discussed what the pros and cons of his
17 candidacy were, correct?
18 A With whom?
19 Q With Governor Clinton?
20 A I will repeat, I remember being
21 struck that he seemed to be more interested
22 in talking about substance than strategy.
43
1 Q As a political campaign consultant,
2 is it not your business to know whether a
3 political candidate has what we call
4 skeletons in their closet that may prevent
5 them from ultimately being elected?
6 A Not when I am about to go to work
7 for them. It is not a very good way to get a
8 job.
9 Q Isn't it the case that you would do
10 research, at least a nexus search or some
11 kind of research to see if this potential
12 candidate, before you accept a position on
13 their campaign, would have skeletons that
14 could bring them down before they could be
15 elected?
16 A That is not how James an I operate.
17 We were more visceral, more emotional. We
18 only wanted to work for a very few people.
19 We did not take on lots of clients.
20 We limited ourselves, purposely, to only a
21 very few who we really believed in. So, we
22 more operated, with the consensus between the
44
1 two of us, on who we really wanted to work
2 for.
3 Neither of us began the process of
4 wanting to work in a presidential campaign,
5 frankly.
6 Q Are you saying that you did no
7 research on Governor Clinton before you
8 decided to work for him?
9 A I can't remember doing any nexus
10 searches or anything of that sort.
11 Q I just gave that as an example.
12 A I am sure the popular press, but I
13 had a chance to talk to him, so I didn't -- I
14 don't remember doing any other research and,
15 frankly, Zell Miller is someone who is quite
16 a hero to me. He was urging us to work for
17 Bill Clinton.
18 Q Are you saying that on all the
19 campaigns that you worked on, you never asked
20 the candidate whether there are skeletons in
21 their closet? Whether there are political
22 enemies that may seek to destroy them?
45
1 A No.
2 Q You never asked them that question?
3 A I am not saying that.
4 Q Who have you asked that question
5 that you worked for, or questions similar to
6 that?
7 A When I am trying to get a job, I
8 don't try to get the candidate to say bad
9 things about himself or herself.
10 Q Here in the presidential campaign,
11 let's back up.
12 Who have you discussed issues such
13 as skeletons with, of all of the people that
14 you have represented, you or James Carville,
15 to the best of your knowledge?
16 A If you could define skeletons, that
17 would be useful.
18 Q Jennifer Flowers, something like
19 that?
20 A It didn't come up until the
21 tabloids or the --
22 Q The issues involving possible
46
1 payoffs to public officials? Issues
2 involving affairs? Issues involving military
3 war records? I mean, I am just giving you
4 some examples.
5 Clearly, you must have discussed
6 these kinds of things with the candidates
7 that you have represented over the years?
8 Are you saying that you didn't?
9 A No, I am not saying I didn't. In
10 any campaign, you try to make sure that you
11 know what your strengths and your weaknesses
12 are.
13 Q Who did you discuss such things
14 with who you represented over the years? I
15 am not limiting them just to those
16 categories. I group them together as
17 skeletons and political adversaries that may
18 attack the candidate to try to inhibit his
19 candidacy or her candidacy?
20 A I would try to talk to the
21 candidate about shortcomings in his or her
22 record.
47
1 My own view, in my own experience,
2 is that votes and quotes, as I call it,
3 speeches, public acts, are always much more
4 of interest to voters than what you have
5 described as skeletons.
6 So, I make it is my business to be
7 sure that I know a good bit about my
8 candidate's record and, yes, at times, I
9 guess, I have learned about or asked about
10 other things as well.
11 But it is not my focus.
12 Q I understand. My question was,
13 names? Who have you discussed these things
14 with over the years?
15 A Again, by these things, you mean
16 the potential things that people might attack
17 you on?
18 Q Right.
19 A Again, it is much more general --
20 Q I am asking you for names of
21 candidates?
22 A I would suspect most of the people
48
1 that I have worked with have talked to me
2 about things that they might have been
3 attacked on.
4 Q Including Governor Clinton?
5 A Yes.
6 Q Up to the point that you were
7 retained by Governor Clinton, did you discuss
8 with Governor Clinton, or anyone associated
9 with Governor Clinton, things that he might
10 be attacked on?
11 A Not that I recall.
12 Q Does that mean no?
13 A Not that I recall.
14 Q Does that mean no or yes?
15 MS. SHAPIRO: Asked and answered,
16 not that he recalls.
17 BY MR. KLAYMAN:
18 Q Does that mean your memory has gone
19 blank, is that what that means?
20 A I recall no such discussions.
21 Q Prior to this deposition today,
22 have you spoken with anyone about being
49
1 deposed by Judicial Watch?
2 A Yes.
3 Q Who have you spoken with?
4 A The attorneys.
5 Q Which attorneys?
6 A The two women present. I have
7 talked to a couple other lawyers.
8 Q What other lawyers?
9 A Do I have to mention the names?
10 Q Yes, you do.
11 A I talked to a friend of mine who is
12 a lawyer, Richard Ben-Veniste.
13 Q Just general subject matter, did he
14 give you advice?
15 A It was, maybe, just a one minute
16 phone conversation.
17 Q What was the nature of that
18 conversation?
19 A He was not favorably impressed with
20 the fact that I had been called here.
21 Q What did he say specifically?
22 MS. SHAPIRO: Objection.
50
1 MR. KLAYMAN: That is not advice,
2 so there is no attorney-client privilege,
3 that he is not favorably impressed.
4 BY MR. KLAYMAN:
5 Q What did he say specifically?
6 MS. SHAPIRO: He is not authorized
7 to disclose the specifics of discussions he
8 had between himself and counsel.
9 MR. KLAYMAN: This is a statement
10 by Mr. Ben-Veniste, not by him. He has
11 already revealed that Mr. Ben-Veniste was not
12 favorably impressed.
13 MS. SHAPIRO: That's right. He
14 doesn't need to discuss.
15 BY MR. KLAYMAN:
16 Q Did Mr. Ben-Veniste tell you how
17 you could --
18 MS. SHAPIRO: May I assert my
19 objection before you interrupt?
20 MR. KLAYMAN: Please, feel free.
21 BY MR. KLAYMAN:
22 Q Did Mr. Ben-Veniste tell you --