151
1 Q You did have discussions with
2 Hillary Clinton?
3 A At what time?
4 Q After the campaign, after the
5 President took his oath of office?
6 A Yes, sir, from time to time.
7 Q And did you meet with her from time
8 to time?
9 A From time to time.
10 Q Did you meet with her in the
11 presence of Mr. Carville?
12 A I would think so.
13 Q Did you meet with her occasionally
14 in the presence of Mr. Stephanopoulos?
15 A I don't have a specific
16 recollection, but I would think so, yes.
17 Q Did you meet with her in the
18 presence of the President from time to time?
19 A I would think so, yes. I don't
20 have a specific memory, but yes, I would
21 think so.
22 Q And during those meetings, you
152
1 would discuss issues involving the
2 administration?
3 A Yes, sir.
4 Q You now meet with the President and
5 First Lady from time to time, correct?
6 A The President frequently. The
7 First Lady occasionally.
8 Q Have you ever discussed the FBI
9 files matter with the First Lady?
10 A Not to the best of my recollection
11 or knowledge, no, sir.
12 Q Are you saying you haven't?
13 A I have no memory of that
14 whatsoever, that's correct.
15 Q Now, the FBI files matter, that is
16 a very significant matter, is it not, in
17 terms of the allegations?
18 A It is a very serious allegation.
19 Q That is something you would
20 remember, wouldn't you, if you discussed it
21 with the First Lady?
22 A I would think so, but I have no
153
1 memory of that.
2 Q So is your answer no, I have never
3 discussed that with the First Lady?
4 A I just want to be very careful,
5 because this is a formal legal proceeding. I
6 want to tell you I have absolutely no memory
7 of that, nor do I have any memory of
8 discussing it with anybody.
9 Again, it is a story that came up
10 when I lived a long way away and was living a
11 different life and was not advising on those
12 kinds of issues at the time.
13 Q Since you became back to the White
14 House, when was that?
15 A August 11th.
16 Q Have you discussed the FBI files
17 matter with anyone?
18 A Not to my recollection.
19 Q Is the answer no?
20 A Not to my recollection, no, sir.
21 Q The answer is no?
22 A Not to my recollection, sir.
154
1 MS. SHAPIRO: I have to object.
2 MR. KLAYMAN: I don't know if he is
3 saying "I don't remember" or "no."
4 MS. SHAPIRO: May I state my
5 objection?
6 MR. KLAYMAN: Yeah.
7 MS. SHAPIRO: My objection is
8 simply that he can only testify to the best
9 of his knowledge, and you are continuing to
10 ask that type of question, and it is
11 harassment.
12 MR. KLAYMAN: Well, because you
13 see, there is a very clever way of answering
14 questions has developed during the last
15 several years which is, "to the best of my
16 recollection." And then people say whatever
17 they want to say.
18 I am telling you, Mr. Begala, and I
19 think you understand this as a lawyer, that I
20 am not asking you to testify as to anything
21 that you don't remember. But to put the
22 qualifier in is quite unnecessary.
155
1 So I will take a stipulation from
2 counsel that everything is based on what you
3 remember, and therefore you won't have to
4 qualify your answers.
5 Can I take a stipulation on that?
6 MS. SHAPIRO: Yeah.
7 MR. KLAYMAN: Okay. Fine.
8 MS. SHAPIRO: We are willing to
9 make a stipulation that he can only testify
10 to the best of his memory.
11 MR. KLAYMAN: I don't want to hear
12 qualifiers "to best of my memory."
13 MR. ANDERSON: He is answering as
14 best he can. You ask your questions.
15 MR. KLAYMAN: I forget your name.
16 I'm sorry.
17 MR. ANDERSON: David Anderson.
18 MR. KLAYMAN: Mr. Anderson, please,
19 one counsel here. There is one counsel.
20 BY MR. KLAYMAN:
21 Q I am asking you a question. I
22 don't want it with a qualifier.
156
1 A I have to answer it to the best of
2 my recollection.
3 Q And I am stipulating everything you
4 say is to the best of your recollection. So
5 I am asking you to answer without, pursuant
6 to stipulation, those qualifiers.
7 Have you ever discussed the FBI
8 files matter with anyone since you have come
9 back to the White House?
10 A I have no recollection of any such
11 conversations with anyone in the White House
12 since I've come back.
13 Q So the answer is no?
14 A I feel, because I am under oath,
15 that I need to be as accurate as I can. So I
16 wanted to say "to the best of my
17 recollection." If you stipulate that, then,
18 the answer is --
19 MS. SHAPIRO: We are withdrawing
20 the stipulation, because it clearly is not
21 going to work. The witness can answer the
22 question to the best of his ability and if he
157
1 wants to say "to the best of my
2 recollection," that is accurate.
3 BY MR. KLAYMAN:
4 Q So you can't answer yes or no?
5 A Again, I take your point that this
6 is something that I would likely remember,
7 and I have no memory of any such
8 conversations.
9 It is not an issue that I have ever
10 worked on. It is not an issue that I have
11 ever dealt with.
12 Q My question was, you can't answer
13 yes or no?
14 A I myself am in the surreal world
15 where I am sworn under oath in a deposition
16 in a lawsuit because I told a joke, Mr.
17 Klayman. So I hope you will understand, if
18 in the first deposition of my life, I treat
19 it with some gravity, and try as forthrightly
20 as I can to tell you that I have absolutely
21 no memory of that whatsoever.
22 Q My question is, you can't answer
158
1 yes or no; is that correct?
2 A I am telling you to the best of my
3 memory -- we have been over this several
4 times -- it is very important that you know
5 this and the record reflect that I have no
6 memory whatsoever of the use or misuse of FBI
7 files, nor do I recall discussing this matter
8 with anyone in the White House.
9 This is not an issue that I have
10 worked on. It is in part why I am so
11 frustrated to have been called here, based on
12 what was obviously an absurd and farcical
13 joke.
14 Q Have you saying this deposition is
15 an absurd and farcical joke?
16 A No, sir, I am saying that my
17 statement in that speech which prompted your
18 service was absurd and farcical. It was a
19 joke, my statement in that speech.
20 Q My question is -- just give me a
21 simple answer -- you can't answer yes or no
22 to my question?
159
1 A I am telling you to the best of my
2 recollection. This is a topic that I believe
3 I would recall if I ever had a conversation
4 about it, and I recall no such conversations,
5 Mr. Klayman.
6 Q Do you understand my question?
7 MS. SHAPIRO: He's answered your
8 question.
9 BY MR. KLAYMAN:
10 Q I want an answer to my question.
11 You cannot answer either yes or no? Correct?
12 Correct? Correct?
13 A Because -- may I answer?
14 Q I am asking you for a yes or no.
15 A Because I am extraordinarily
16 cognizant of the fact that I am under oath, I
17 want to make sure that I tell you everything
18 to the best of my memory.
19 To the best of my memory, no, sir.
20 Q Is the reason why you can't answer
21 yes or no because you don't want to be pinned
22 down, because you recognize that, according
160
1 to what you understand, it is very hard to
2 hold anyone accountable for perjury if you
3 don't remember?
4 A No, sir. It is because I am
5 searching my memory as very best as I can,
6 and I have no such recollection.
7 MR. KLAYMAN: I will show you what
8 I will ask the court reporter to mark as
9 Exhibit 7.
10 (Begala Deposition Exhibit
11 No. 7 was marked for
12 identification.)
13 BY MR. KLAYMAN:
14 Q This is a document which you
15 produced today, Mr. Begala, is it not?
16 A Yes, sir.
17 Q Where did this document come from
18 in your files?
19 A It was in a file. I don't
20 understand. It was in my office.
21 Q It was in your office? Where was
22 it kept in your office?
161
1 A My assistant kept it.
2 Q Who is your assistant?
3 A Stacey Parker.
4 Q Where does she generally keep
5 files?
6 A I think she keeps them around her
7 desk, in a credenza or behind her desk. I
8 think so; I am not sure.
9 Q Was it in a file folder?
10 A No, sir.
11 Q Who found the document?
12 A The document itself?
13 Q Yes.
14 A I did.
15 Q You went through her files to see
16 if there was anything responsive to this
17 subpoena today?
18 A I went through a particular folder.
19 Q The notice today? You did?
20 A Yes, sir.
21 Q Was there a label on the folder
22 that this document came out of?
162
1 A I can't remember one.
2 Q But you are not sure?
3 A I am not sure.
4 Q I asked for the production of the
5 folder. I would like to see whether at the
6 next break that could be faxed over, the
7 label on that folder.
8 MS. SHAPIRO: Where did you ask for
9 the production of the folder?
10 MR. KLAYMAN: If it contains a
11 notation that may be -- you can take a look
12 at it. It may contain a notation that says
13 "Filegate." It may contain a notation that
14 makes a reference to Filegate. He can't
15 remember.
16 MS. SHAPIRO: Well, can you show me
17 where you asked for it?
18 MR. KLAYMAN: We asked for any and
19 all documents that deal with Filegate.
20 THE WITNESS: I would have noticed
21 if it had --
22 MR. KLAYMAN: As you know.
163
1 THE WITNESS: It is not a question.
2 I can try to clarify if you like.
3 BY MR. KLAYMAN:
4 Q Please.
5 A I would feel certain if the file
6 itself had any notations that said anything
7 like "Filegate" or "FBI" or your name or
8 anything like that, I would have noticed that
9 and brought that in as well.
10 I noticed a very obscure reference,
11 you know, in a three-page document, and made
12 sure to turn that over to counsel. I am not
13 entirely certain it is responsive, but I
14 wanted to be as forthright as I could be.
15 MR. KLAYMAN: I am on record, and I
16 am requesting the production of the file
17 folder this came out of. I would like you to
18 check at the break.
19 BY MR. KLAYMAN:
20 Q Are there files at the White House
21 that list Filegate or file matter?
22 A Not that I know of.
164
1 Q Are there files that read Larry
2 Klayman or Judicial Watch?
3 A No, sir, not that I know of.
4 Q Are is there anyone in charge of
5 keeping files on those issues?
6 A No, sir, not that I know of.
7 Q Who prepared this document,
8 Exhibit 7?
9 A I don't know who.
10 Q How did it come to your possession?
11 A It was faxed to me.
12 Q Who faxed it to you?
13 A I don't know.
14 Q There is a fax notation at the top,
15 "November 26, '97, Wednesday, 11:45," and
16 it's page 2.
17 Does that refresh your recollection
18 as to where this document came from?
19 A No, sir.
20 Q Where is the first page of this
21 document?
22 A I don't know, sir.
165
1 Q Did you pull it off before you
2 provided it to counsel for production?
3 A No, sir.
4 Q Did you check your files to see
5 where page 1 may be?
6 A I checked that file. I didn't see
7 anything -- I didn't notice the pagination,
8 but I was quite proud to find a rather
9 obscure reference, and was --
10 Q You were proud to find it?
11 A Well, in that it proves how
12 forthright that I am trying to be in
13 cooperation with, again, what I think is not
14 a very fair request for my deposition,
15 because it is based on a joke.
16 Q Are you taking issue with the
17 court's ruling.
18 A No, sir, I am taking issue -- I am
19 pointing out, rather, that the fact that I
20 was able to find this ought to be some
21 evidence that I am trying to be as fully
22 cooperative as I can be.
166
1 Q Are you taking an issue with Judge
2 Lamberth?
3 A No, sir, I am not.
4 Q I am going to request that a search
5 be made for page 1 of this document.
6 Obviously, there is a page 1.
7 Now, looking at the first page of
8 this document, read down to entry number 12.
9 A Yes, sir.
10 Q "Bill Klinger's FBI files
11 investigation" refers to the file matter,
12 right, Filegate?
13 A Yes, sir.
14 Q Now, who did you discuss this
15 document with?
16 A I brought it to counsel's attention
17 as soon as I found it.
18 Q Well, this document was sent to you
19 for a purpose, was it is not?
20 A Yes, sir, I'm sure.
21 Q What was the purpose?
22 A I would think it would be part of
167
1 explaining the cost and distraction of a
2 variety of investigations that are going on
3 into this President. It is an important
4 political point, I think, as well as a
5 governmental one: The cost and time that has
6 been expended in what I believe are partisan
7 enterprises to investigate the President.
8 Q Oh, and among the various
9 investigations is the Filegate investigation?
10 A It is listed on there, yes, sir.
11 Q So you would have discussed the
12 Filegate investigation in the context of this
13 document?
14 A No, sir, I would not have pulled
15 that particular one out, because it does not
16 contain any dollar amount, and wasn't a
17 particularly high-profile investigation.
18 MS. SHAPIRO: I'd also object,
19 because you are assuming something that he
20 did not testify to. He testify that he
21 didn't discuss this with anybody,
22 necessarily.
168
1 MR. KLAYMAN: He didn't testify to
2 that, Ms. Shapiro. Please hold your
3 statements, because they are inappropriate as
4 counsel. You can make objections; I have no
5 problems with that. But don't give him
6 testimony, please.
7 We have been through this before in
8 other Justice Department cases, and it is not
9 something which is appropriate.
10 THE WITNESS: I have no doubt that
11 I made the larger point many times, and will
12 again, that this President has been subjected
13 to a remarkable level of investigation.
14 I believe, and it is my opinion,
15 that a good bit of this is driven by partisan
16 motivation. And I certainly believe that a
17 good bit of this is very expensive, and
18 probably not what taxpayers might want to --
19 BY MR. KLAYMAN:
20 Q That was not my question. If you
21 want to make speeches, perhaps we can have a
22 special session at the end where you can make
169
1 a speech, Mr. Begala.
2 A I am trying to be as helpful as I
3 can be.
4 Q I have no question pending, and I
5 would like to move along here.
6 A Yes, sir.
7 Q Who did you discuss this document
8 with?
9 A I brought it to counsel's attention
10 as soon as I found it.
11 Q Well, when you got it. I am not
12 talking about producing it here. What was
13 the purpose of the document?
14 A I don't remember specifically using
15 it, but I certainly have made the larger
16 political point that there are an
17 extraordinary number of investigations going
18 on; that they're extraordinarily expensive;
19 and that I believe there is a partisan axed
20 to grind behind some of them.
21 Q You have also made the statement
22 that Kenneth Starr is corrupt, correct?
170
1 A In the sense that Lord Acton meant.
2 Q Did you make take statement to the
3 press in the sense, too, in the sense that
4 Lord Acton meant?
5 A Yes, sir, absolutely I did. I
6 said --
7 Q How is Kenneth Starr corrupt?
8 MR. ANDERSON: Would you let him
9 finish his answers, please?
10 MR. KLAYMAN: Would you let her
11 object for you, because there is one counsel
12 here.
13 THE WITNESS: Lord Acton made a
14 famous statement that "Absolute power
15 corrupts absolutely."
16 My own belief is that the
17 independent counsel statute conveys an
18 extraordinary amount of power. I said that
19 it may be that, as Lord Acton meant it,
20 "Absolute power corrupts absolutely."
21 BY MR. KLAYMAN:
22 Q Did you give that statement to the
171
1 press?
2 A Yes, sir, I did.
3 Q Or did you just say, "In my
4 opinion, Ken Starr is corrupt"?
5 A No, sir, I never said that.
6 Q So you have been misquoted?
7 A No, sir, I was quoted -- it was a
8 broadcast interview. It was on "Meet the
9 Press." Later, reporters took that word out
10 of context.
11 I believe that absolutes power
12 corrupts absolutely. I believe the
13 independent counsel has too much power. And
14 I think that he is seen by the American
15 people as someone who uses excessive amounts
16 of power.
17 I this that in the Anglo-American
18 tradition, that that is a frightening
19 spectre.
20 Q Are you that you never commented on
21 the Filegate scandal publicly?
22 A I can't remember. I may have as
172
1 part of a larger sense that Republicans
2 running the Congress or Republicans in other
3 places have a partisan motive in their
4 investigations and attacks on the President.
5 Q Who did you discuss this document
6 with at the White House?
7 A Counsel.
8 Q Anybody other than counsel?
9 A No, sir. Not that I can recall. I
10 want to be careful.
11 Q So you might have discussed it with
12 somebody else?
13 A I might have, but I can't recall.
14 I found it; I took it to counsel's office
15 immediately. I don't recall discussing it
16 with anybody else.
17 MR. KLAYMAN: I will show you what
18 I ask the court reporter to mark as
19 Exhibit 8.
20 (Begala Deposition Exhibit
21 No. 8 was marked for
22 identification.)
173
1 BY MR. KLAYMAN:
2 Q Exhibit 8 is a document which was
3 also produced by you today, Mr. Begala, which
4 contains the heading, "Gingrich Keeps his
5 Promise: Speaker 620 Taxpayer Funded
6 Committees on Democrats."
7 This is a document you produced
8 today, correct?
9 A Yes, sir.
10 Q Where was this document found in
11 your files?
12 A In that same file that the previous
13 document was found.
14 Q What else was in that file?
15 A Mostly it was documents about
16 Arlington National Cemetery.
17 Q Larry Lawrence?
18 A There was a larger issue that had
19 been raised in investigation that had gone on
20 that suggested -- Insight Magazine, is my
21 recollection, suggested that the President
22 had sold burial plots at Arlington Cemetery.
174
1 Part of my job on that job, when
2 issue was raised, was to respond to it in the
3 press. I found these documents in the file
4 that contained mostly issues on Arlington
5 Cemetery.
6 Q How thick is that file, roughly
7 speaking? Maybe you can show the video
8 camera.
9 A Not very -- you know. It looks
10 like it was an inch. I am just guessing.
11 But it not a voluminous file.
12 Q Had you asked your assistant to
13 prepare such a pile?
14 A I can't recall. I may have. I
15 can't recall.
16 Q What other kinds of files does she
17 keep for you?
18 A As I went through the budget
19 process, there were perhaps documents on the
20 budget that she might have saved for me. The
21 issues of the day as they arise are what I
22 tend to deal with.
175
1 I myself don't generate very many
2 documents, but when I attend meetings, again,
3 for example on the budget or the State of the
4 Union, there would be documents generated
5 from that that I would just hand over to her
6 when I was done.
7 Q Do you take notes at meetings?
8 A As general matter, no, sir.
9 Q From time to time?
10 A Not very often, no, sir.
11 Q But from time to time?
12 A I am more of a -- like a "to do"
13 list guy.
14 Q Are you saying you never have taken
15 a note?
16 A No, I am saying that. I am more of
17 a "to do" list guy.
18 Q I'm asking you, have you ever taken
19 notes at meetings?
20 A What I mean is, if by "notes" you
21 mean a "to do" list, to remember to call Jim
22 Smith about blah blah, sure. But I don't
176
1 write down what people say in meetings.
2 Q You are saying that you have never
3 done that?
4 A I may have, but it is not my
5 practice as a general rule.
6 Q Do you write down your own
7 thoughts?
8 A As a general rule, I don't. I am
9 more of a "to do" list kind of person.
10 Q I am not asking you as a general
11 rule. I am saying, do you ever write down --
12 A I would hate to rule out, but I am
13 not a big doodler. I am not a big note
14 taker. I prefer "to do" lists.
15 Q Do you ever write down your
16 thoughts?
17 A I may have. I would hate to rule
18 that out. It is not my general practice.
19 Q So in your entire life, you have
20 never written down any thoughts?
21 MS. SHAPIRO: He answered the
22 question.
177
1 BY MR. KLAYMAN:
2 Q You are not sure in your entire
3 life whether you have ever written down one
4 thought?
5 A What I have said is, generally, I
6 do not take notes at meetings. I generally
7 will write down reminders to do certain
8 things.
9 Q And I asked you a simple question,
10 Mr. Begala. Have you ever taken one note of
11 any of your thoughts in your entire life?
12 A Well, I would hate to rule that
13 out. But I do not sit in meetings and write
14 down what I am thinking or what other people
15 are saying. I often will write down tasks
16 that I want to remind myself to do.
17 Q So then, what you are basically
18 telling me is, you don't remember whether you
19 have ever written down one thought in your
20 entire life?
21 A No, sir, I am not. I am saying, my
22 practice in meetings is to make more of a "to
178
1 do" list, rather than write down my own
2 thoughts or the thoughts of others.
3 Q I am not going to give up on this
4 question until you give me a response, and I
5 don't care if I am here for three weeks.
6 A Yes, sir. That is my best
7 response, is that as a practice, I write down
8 the tasks that I want to remind myself to
9 perform. I generally do not -- I don't want
10 to say I have absolutely never, because,
11 again, I am conscious of the fact that I am
12 under oath, so I would hate to rule something
13 out in the absolute.
14 But my general practice is to write
15 down tasks that I remember that I need to do,
16 if I'm in a meeting.
17 Q And have you ever written down one
18 thought on a piece of paper about a meeting,
19 about someone that you have had to --
20 A I answered that to my best of my
21 ability.
22 MS. SHAPIRO: Objection again.
179
1 That has been asked and answered.
2 BY MR. KLAYMAN:
3 Q Yes or no?
4 A I answered to the best of my
5 ability.
6 MR. KLAYMAN: Certify it.
7 BY MR. KLAYMAN:
8 Q Do you keep your notes filed in any
9 kind of binder or folder?
10 MS. SHAPIRO: Objection. He has
11 not testified about any notes.
12 MR. KLAYMAN: You can respond.
13 I know, because he has refused to
14 answer the question. I am asking another
15 question.
16 THE WITNESS: I am not a note-taker
17 or note-keeper.
18 BY MR. KLAYMAN:
19 Q But you do keep notes, don't you?
20 A Not generally. I may have, for
21 example, edits on a speech draft. I don't
22 know if my assistant keeps them or not.
180
1 Q Where are they kept?
2 A I give them to my assistant. As a
3 general matter, I think she turns them over
4 to records management things that are no
5 longer topical.
6 I do a good bit of editing on
7 speeches, and I do not know if my assistant
8 saves those edits or if she throws them away.
9 They are not particularly --
10 Q Do you have a computer in your
11 office?
12 A Yes, sir.
13 Q Do you use a computer?
14 A Uh-huh.
15 Q Do you type correspondence on that
16 computer?
17 A Not often, but occasionally.
18 Q Do you type memoranda to file on
19 that computer?
20 A No, I don't type memoranda to file.
21 I will occasionally write a memo, but not
22 very often.
181
1 Q What kind of computer do you have?
2 A A desktop. I don't know the brand.
3 You know, a desktop PC.
4 Q Do you record document creation on
5 floppy disks?
6 A No, sir.
7 Q It's kept on a hard drive?
8 A I think so.
9 Q It goes into a central White House
10 data system?
11 A I don't know.
12 Q Is there someplace you can store
13 the document in some kind of backup system in
14 the White House?
15 A I don't know enough about how the
16 computer system works.
17 Q You do know how to work your
18 computer, correct?
19 A Sure.
20 Q You know how to store a document,
21 correct?
22 A Yes.
182
1 Q Well, how is it stored?
2 A I hit a save button and it is
3 stored somewhere. I don't use disks.
4 Q Are chron files, chronological
5 files, kept in your office?
6 A I don't know what that is.
7 Q Files of everything that you have
8 written or others have written?
9 A I don't understand.
10 Q Do you keep photocopies of letters,
11 for instance, that you have written? Backup
12 photocopies?
13 A I don't know. Not that I know of.
14 My assistant might. I don't know.
15 Q Have you ever asked her to do that?
16 A I can't -- not that I remember.
17 Q Well, explain to me. If you write
18 a letter on your computer, is that the way
19 you do it? Or do you dictate it to the
20 assistant?
21 A Not very often.
22 Q How do you write a letter?
183
1 A Actually, I write a lot of
2 handwritten notes: "Good to see you today,"
3 or "Thanks for supporting us on this issue."
4 Q But you have written a letter on
5 your computer?
6 A I would think so, yes, sir.
7 Q How does that generally work after
8 it is put on your computer and stored? Who
9 types it out?
10 A General correspondence, my
11 assistant does for me. On occasions, I will
12 write out a letter myself on my computer, but
13 not very often.
14 Q Who prints it out?
15 A If I have written it, I do, or if
16 she has written it, she does.
17 Q And if it is typed out by her, does
18 she bring it in for you to sign?
19 A Yes.
20 Q What happens to that letter? How
21 is it transmitted? Say, if it is mailed, who
22 handles the mailing?
184
1 A I don't know. My assistant does.
2 Q She keeps a photocopy for your
3 records of what was sent?
4 A I don't know that.
5 Q You have never discussed that with
6 her?
7 A No, sir.
8 Q Is it your position that you don't
9 want records of anything that you write?
10 A No. I don't generate a lot of
11 letters. I write, as I say, note cards or
12 cards, thanking people for this or that. But
13 again --
14 Q Is there any kind of directive in
15 the White House not to create paper or
16 recordations?
17 A I don't know.
18 Q Have you ever seen any such
19 directive?
20 A I can't recall one, no, sir.
21 Q Do you have a shredder in your
22 office?
185
1 A No, sir, I don't.
2 Q Have you ever shredded documents at
3 the White House?
4 A No, sir, I have not.
5 Q Have you ever asked anyone to shred
6 documents?
7 A No, sir, I have not. To the best
8 of my recollection. I want to be careful on
9 that, because I'm under oath.
10 Q Are your handwritten notes
11 photocopied?
12 A My handwritten notes to people?
13 Q When you thank people?
14 A I don't know. They may be.
15 Q Turning to Exhibit 8, who prepared
16 this document?
17 A I don't know.
18 Q How did it come into your
19 possession?
20 A I think it was faxed to me, but I
21 don't know. I don't see fax marks on it. I
22 don't know. It might have been mailed. I
186
1 don't know how it came to me.
2 Q What was this document intended to
3 do?
4 A I would have used this -- I don't
5 have specific recollection, but I would tell
6 you how I would use a document like this: In
7 talking to members of the press or maybe
8 talking to the Democratic loyalists, to be
9 able to make a point, which I find
10 extraordinary, that before he came to power
11 as Speaker, Speaker Gingrich said he was
12 going to assign 20 subcommittees or task
13 forces to investigate the White House. Sure
14 enough, he has.
15 I think that makes a powerful point
16 about the partisan motives of some of these
17 accusations.
18 Q Turn to the last page. It says,
19 "Authorized and paid for by the Democratic
20 National Committee"?
21 A Yes, sir.
22 Q Does that refresh your recollection
187
1 of where you got this document?
2 A It would suggest that it comes from
3 the Democratic National Committee.
4 Q Who sent it to you?
5 A I don't have a recollection of
6 actually receiving this document. But this
7 is the sort of thing I would have used, for
8 example, in defending the President against
9 these attacks on Arlington Cemetery, by
10 saying this is part of a larger pattern of
11 the Republican trying to investigate the
12 President for their partisan ends.
13 Q So your job basically is to spin
14 these investigations?
15 A No --
16 Q To be able to deflect criticism
17 from all of the Clinton scandals by saying
18 the Republicans and others are spending a lot
19 of money to smear the President?
20 That's your approach, isn't it?
21 A It is not my principal job, but it
22 is one argument that I use. I believe it to
188
1 be true.
2 Q I didn't ask you whether you
3 believed it to be true. I asked you whether
4 that is part of your job?
5 A I do that willingly. I believe
6 that part of the motive of a number of these
7 attacks is deeply partisan.
8 Q But some of the attacks are
9 warranted, are they is not?
10 A I guess anybody is certainly
11 justified in criticizing their President. It
12 is an American tradition.
13 Q Well, investigation as to whether
14 files came from the FBI for improper use,
15 that is warranted, isn't it?
16 A I would think so, yes, sir. Again,
17 I want to say for the record, I don't mean to
18 belabor it, but I have no knowledge of the
19 use or misuse of FBI files. It is a very
20 important thing for you to know.
21 I am trying to be cooperative as
22 you go afield from that. But I don't want
189
1 the lose sight of the central point that I
2 have absolutely no knowledge or recollection
3 of any use or misuse of FBI files at the
4 White House.
5 Q That is a very serious matter, is
6 it not, whether files were used or misused?
7 A Yes, sir, and I say that with all
8 due gravity.
9 Q And you can't say categorically
10 that FBI files were not misused?
11 A I can only say what I know, and I
12 have no knowledge of that. I can't speak to
13 things I don't know.
14 Q But given your lack of knowledge,
15 you can't vouch that, in fact, those FBI
16 files were used illegally?
17 A I can only speak to what I know.
18 That's correct.
19 Q Now, look to number 3, where it
20 says --
21 A On this item, "Gingrich Keeps His
22 Promise"?
190
1 Q On Exhibit No. 8, it says, item
2 number 3, "McCain, Arizona," the last
3 sentence: "The House Commerce Committee may
4 look into the same allegations, and a private
5 group, Judicial Watch, has filed lawsuits to
6 investigate the Commerce Department."
7 Have you ever commented to the
8 media about Judicial Watch, other than what
9 you testified this morning?
10 A I may have. I don't have any
11 recollection. I didn't notice that until
12 just now. I am a little disappointed that
13 the Democrats didn't characterize you in a
14 more negative fashion, not personally, but as
15 a partisan group, because you are private,
16 but I also think you are partisan.
17 Q I fully suspect you will correct
18 that error.
19 A I might do that. Again, not in a
20 personal sense, but I do think you are
21 partisan. I am too. I am proud of my
22 partisanship. I suspect you are too.
191
1 Q We are not partisan. We are not.
2 But again, I am not testifying.
3 A I know, not yet.
4 Q In terms of FBI files, have you
5 ever seen an FBI file?
6 A Not to my knowledge, no, sir.
7 Q Did you undergo a background
8 investigation by the FBI before you began to
9 work during the Clinton administration as a
10 consultant?
11 A As I was working for -- after Bill
12 Clinton became President and while I was a
13 consultant to the party, yes, sir.
14 Q Do you know who the FBI interviewed
15 in conducting that investigation? Any of
16 your friends or acquaintances or anyone?
17 A Give me just a minute.
18 MS. SHAPIRO: Give us one moment,
19 please.
20 THE WITNESS: Excuse me.
21 (Witness conferred with
22 counsel)
192
1 MS. SHAPIRO: You had a question
2 pending, Mr. Klayman, and I wanted just to
3 make the general statement that because this
4 deposition is not under seal, that if the
5 direction you are going is to ask him about
6 his own background investigation, that I am
7 sure --
8 MR. KLAYMAN: I am not asking about
9 if information was provided. I was asking
10 who was interviewed by the FBI concerning
11 you, Mr. Begala.
12 MS. SHAPIRO: I understand what the
13 question was. I am just saying generally
14 that the subject of his own background
15 investigation is not something that should be
16 explored in a public deposition, as I am sure
17 you are sensitive.
18 BY MR. KLAYMAN:
19 Q Based on your knowledge. I not
20 asking the FBI; I am not asking for
21 government information.
22 Based on your knowledge, who did
193
1 the FBI talk to about you?
2 A I don't know who they talked to. I
3 gave them names of the people with whom I
4 worked, and I don't know who they did or did
5 not contact. I never followed up.
6 Q Did anyone ever contact you and
7 say, "I just have been talked to by an FBI
8 agent about you, Mr. Begala"?
9 A Yes, sir.
10 Q Who?
11 A A guy who runs a magazine that I
12 did some writing for.
13 Q Who is that?
14 A John Kennedy.
15 Q George Magazine?
16 A Yes, sir.
17 Q Anybody else?
18 A He called me. It was a brief
19 conversation. He said, "Hey, the FBI came
20 by. It was sort of a noteworthy thing."
21 Q Was it to do a background
22 investigation, or did they come by on another
194
1 matter as related to you by John Kennedy Jr.?
2 A He didn't say, as I recall. I
3 presumed that it was because I had listed his
4 name as one of several people who employed
5 me.
6 Q Is that recently, since you
7 rejoined the White House?
8 A Yes, sir.
9 Q Did he tell you what they asked
10 him?
11 A No, sir.
12 Q Did you ask him what they asked
13 him?
14 A No, sir.
15 Q You weren't interested?
16 A No. I think I did pretty good work
17 for the magazine, but I didn't ask him what
18 they had gotten into.
19 Q You were not curious?
20 A No.
21 Q Have you ever seen your own FBI
22 file?
195
1 A No, sir.
2 Q Have you ever asked to see it?
3 A No, sir.
4 Q Have you ever heard of Ellen
5 Rometsch, R-o-m-e-t-s-c-h?
6 A Not recently.
7 Q When did you hear about that?
8 A When George Stephanopoulos made a
9 comment about her on TV.
10 Q Were you watching that day?
11 A Yes, I was, I think I was. If I
12 wasn't watching, I was made aware of it
13 shortly thereafter. I think I was watching.
14 MR. KLAYMAN: I show you what I
15 will ask the court reporter to mark as
16 Exhibit No. 9.
17 (Begala Deposition Exhibit
18 No. 9 was marked for
19 identification.)
20 BY MR. KLAYMAN:
21 Q I show you Exhibit 9. This is a
22 transcript of Mr. Stephanopoulos' appearance
196
1 on "This Week with Cokie and Sam" on ABC,
2 February 8, 1998.
3 MS. SHAPIRO: What number exhibit
4 is this?
5 MR. KLAYMAN: Number 9.
6 (Discussion off the record)
7 BY MR. KLAYMAN:
8 Q Turn to page 2 of this transcript,
9 reading from George Stephanopoulos, about
10 half way down. Excuse me, starting with Sam
11 Donaldson: "We know what the White House
12 tactics are. I mean, they have been almost
13 open about it. Attack the press, and perhaps
14 with good reason, attack the independent
15 counsel, perhaps for some good reason, and
16 stonewall on the central issue, which is the
17 President of the United States. And if he
18 has nothing to hide, why is he hiding?"
19 George Stephanopoulos: "I agree
20 with that. And there is a different
21 long-term strategy which I think would be far
22 more explosive. White House allies are
197
1 already starting to whisper about what I will
2 call the Ellen Rometsch strategy."
3 Sam Donaldson: "I remember her."
4 George Stephanopoulos: "You
5 remember her?"
6 Sam Donaldson: "Yes."
7 George Stephanopoulos: "She was a
8 girlfriend of John F. Kennedy who also
9 happened to be an East German spy, and Robert
10 Kennedy was charged with getting her out of
11 the country and also getting J. Edgar Hoover
12 to go to the Congress and say, 'Don't you
13 investigate this, because you if you do, we
14 are going to open up everybody's closets.'
15 And I think that in the long run, they have a
16 deterrent strategy on getting a lot of..."
17 George Will: "Monica Lewinsky is a
18 East German spy?"
19 Sam Donaldson: "No, but that is a
20 good point. Are you suggesting for a moment
21 that what they are beginning to say is that
22 if you investigate this too much, we will put
198
1 all of your dirty linen right on the table?
2 Every member of the Senate, every member of
3 the press corps."
4 George Stephanopoulos:
5 "Absolutely. The President said he would
6 never resign, and I think some around him are
7 willing to take everybody down with him."
8 Sam Donaldson: "Well, may I just
9 say, let the games begin."
10 George Will: "It is called
11 mutually assured destruction in strategic
12 language."
13 Cokie Roberts: "Or MAD, M-A-D."
14 You heard Mr. Stephanopoulos make
15 those comments?
16 A Yes, sir.
17 Q Had you ever discussed Ellen
18 Rometsch with George Stephanopoulos before he
19 made that appearance?
20 A No, sir.
21 Q Have you ever discussed with George
22 Stephanopoulos J. Edgar Hoover and his
199
1 obtaining FBI files about Kennedy and members
2 of Congress?
3 A No, sir. I called him after that
4 appearance, however, and talked to him about
5 that comment.
6 Q You called him immediately after
7 that?
8 A No, it would have been the next day
9 or during the next week.
10 Q Where did you call him from? Your
11 office in the White House?
12 A Yes, sir.
13 Q How long was the conversation?
14 A Brief, but -- I don't know, but
15 George doesn't stay on the phone a long time.
16 Q And what did you say to George?
17 A I was outraged. I was very angry,
18 because I was getting calls from reporters
19 suggesting this, saying, "You guys are trying
20 to do this."
21 Q Do what, to use FBI files?
22 A They didn't say "FBI files." The
200
1 reporter said, "You guys are" -- "George says
2 you guys are interested in trying to smear
3 your opponents."
4 I called George. It was after that
5 TV show during that next week. I can't
6 remember the day. But I remember the
7 conversation with some clarity, because I was
8 quite angry about it.
9 I said, "George, you know, this is
10 not true." First off, everybody in the press
11 corps know that George and I are friends, so
12 I was the likely person to get these calls.
13 And so I was particularly incensed that
14 people would think that I would do something
15 like that.
16 And George said, "Get the
17 transcript. It says 'White House allies.'"
18 And I said, "Well, that is not what
19 I heard. That is not what people heard.
20 People heard you say 'White House.'"
21 And he said, "Get the transcript.
22 'White House allies.'"