301
1 your lie hypothetical, I am not going to
2 accept the hypothetical as real.
3 In other words, the President has
4 said that his testimony, which is under seal
5 and I have never seen, and his comments in
6 the '92 campaign are not inconsistent. I
7 have seen nothing, I have seen suggestion and
8 allegations to the contrary, but I have no
9 knowledge.
10 BY MR. KLAYMAN:
11 Q Suppose I have the deposition and I
12 showed it to you and it said in that
13 deposition --
14 A Wouldn't that be a violation?
15 Wouldn't that be a violation?
16 MS. SHAPIRO: Objection.
17 THE WITNESS: Wouldn't that be a
18 violation?
19 MR. KLAYMAN: Of what?
20 THE WITNESS: Rule 68?
21 BY MR. KLAYMAN:
22 Q I don't have it, but I say suppose
302
1 I did. It wouldn't be a violation if
2 somebody gave it to me in the proper way. We
3 moved to get that deposition. The judge may
4 grant our request to get it.
5 If I was to show it to you --
6 A Sealed depositions can just go to
7 people who are not party to --
8 Q Sure, if it as public record.
9 A Apparently, everybody leaks
10 everything except to me. I have not seen
11 anything of the deposition. I have seen all
12 kinds of wild speculation about it, but I
13 have seen the President say, what I said
14 in '92 and what I said under oath are not
15 inconsistent.
16 MR. KLAYMAN: I am asking a simple
17 question. I want to know what your ethical
18 responsibility is vis-a-vis your
19 responsibility to the President. I am
20 entitled to know, based upon, not just your
21 general course of conduct, but statements
22 here that you do try to do what is right and
303
1 truthful.
2 What I am asking you is simple.
3 Whether you actually saw the deposition and
4 saw in black and white that the President had
5 said I had had an affair with Jennifer
6 Flowers, would you then, on your own, correct
7 that with the media?
8 MS. SHAPIRO: Object to form.
9 THE WITNESS: The hypothetical
10 requires me to assume something that I know
11 is false, that I believe is false.
12 BY MR. KLAYMAN:
13 Q Under law you have to assume it to
14 be true?
15 A Why?
16 Q For purposes of this answer.
17 A I am literally mystified. Why do I
18 have I to assume something as true with all
19 of the information that I have tells me that
20 it is false.
21 Q Are you refusing to answer the
22 question?
304
1 A I am trying to understand the
2 question.
3 Q Are you refusing to answer the
4 question?
5 A I am trying to understand the
6 question. You asked me about a general
7 course of practice, which I am perfectly
8 willing to outline. That is again -- as a
9 general course of practice, any good
10 spokesperson with the press would want to
11 correct the record.
12 If it might indulge myself, if you
13 found out that I told a joke and you went on
14 national television and told them that I
15 committed a felony, would you correct that?
16 Because MSNBC did.
17 Q I am taking the deposition.
18 A I know. You have particular
19 knowledge of this as well. You deal with the
20 press, too.
21 Q Will you answer my question or not?
22 MS. SHAPIRO: Let's calm down and
305
1 stop shouting and let's try to resolve these
2 issues.
3 If you can phrase your question in
4 a way that doesn't improperly pose the
5 question, I think Mr. Begala can answer.
6 MR. KLAYMAN: Either he answers the
7 question or I am moving for sanctions. I
8 will certify this question. Are you telling
9 him not to answer?
10 MS. SHAPIRO: He answered the
11 question.
12 MR. KLAYMAN: He has not answered
13 the question. Certify it, we will be moving
14 for sanctions. I will ask it again. Let's
15 see if he comes up with it now.
16 BY MR. KLAYMAN:
17 Q If, in the course of your duties at
18 the White House, you learned that the
19 President had testified in the Jones case
20 that he did have an affair with Jennifer
21 Flowers, would you feel duty bound to correct
22 that?
306
1 A As a general practice, anyone who
2 deals with the press ought to have a duty to
3 correct the record where there is inaccurate
4 information.
5 Again, I just will not buy the
6 assumption in your question that what I
7 believe to be true is, in fact, false,
8 because I have seen nothing that would lead
9 me to that.
10 Q Have you asked anyone whether, in
11 fact, the President did have an affair with
12 Jennifer Flowers?
13 MS. SHAPIRO: Objection, relevancy.
14 BY MR. KLAYMAN:
15 Q You can respond.
16 A I been asked, I remember in 1992
17 the President saying -- the Governor then --
18 saying that this woman's allegations were
19 false.
20 Q Have you asked recently, this year?
21 A I cannot remember raising it
22 recently. It is a long time ago this
307
1 allegation was made.
2 Q You can't remember that one either?
3 A I remember the President saying
4 that what he said under oath and said in 1992
5 are not inconsistent. I have seen nothing
6 that would disabuse me of that.
7 Q But you haven't asked recently?
8 A I have been asked by the press --
9 Q Have you asked recently?
10 A The President has been asked.
11 Q Have you been asked? Have you
12 asked recently whether there was an affair
13 with Monica Lewinsky?
14 MS. SHAPIRO: That was not the
15 question that was asked.
16 BY MR. KLAYMAN:
17 Q I am sorry, Jennifer Flowers. Have
18 you asked recently whether the President had
19 an affair--
20 A I have been asked. I cannot
21 remember asking anyone because there is a
22 deposition that is under seal that is the
308
1 subject of an enormous amount of speculation.
2 So I am asked about it quite a bit.
3 I remember the President saying,
4 what I said in 1992 and what I said under
5 oath are not inconsistent. I have not seen
6 anything to the contrary. To take your idea
7 should something come up to the contrary, the
8 record ought to be corrected, yes, sir.
9 But I have not seen, I don't want
10 your hypothetical to allow the suggestion or
11 implication that I believe the assumption
12 that you --
13 Q No one ever asked you to do that.
14 Unfortunately it took half an hour to get the
15 response.
16 A It is very important to me.
17 Q It is a cathartic experience.
18 A It important to me that people
19 understand that you understand that.
20 Q You are aware, aren't you that
21 pleadings have been filed in the Jones case
22 where the President's deposition is quoted
309
1 publicly? Are you aware of that?
2 MR. ANDERSON: Do you want to --
3 MR. KLAYMAN: This not for you to
4 interrupt my deposition.
5 MS. PAXTON: I would like to confer
6 with counsel, please?
7 MR. KLAYMAN: You are not counsel
8 of record here.
9 MS. SHAPIRO: She is the client.
10 MS. PAXTON: I would like to confer
11 with my counsel. We will take a very brief
12 break.
13 VIDEOGRAPHER: We are going off
14 video record at 3:57.
15 (Discussion off the record)
16 VIDEOGRAPHER: We are back on video
17 record another 4:02.
18 BY MR. KLAYMAN:
19 Q I just asked a simple question. If
20 you were aware that there were pleadings
21 filed in the Jones case on the public record
22 that contained portions of the President's
310
1 deposition?
2 A No, sir. I thought the deposition
3 was under seal.
4 Q Did you ever discuss politics with
5 Craig Livingstone?
6 A Not that I can recall, no, sir. I
7 thought he was on permanent staff of the
8 White House security team.
9 Q Was there a controversy that brewed
10 over the issuance of your temporary pass
11 during the first administration?
12 A Yes, sir.
13 Q What was that controversy about?
14 A My the recollection is that
15 Congressman Wolfe raised an objection that I,
16 and other political consultants, had access
17 to the White House and had not been through
18 an FBI background check. He made reference
19 to the Alger James spy situation and said, we
20 don't know if these people are spies.
21 The press raised questions as to
22 whether we had lobbied. We didn't lobby.
311
1 Obviously we are not spies.
2 I thought, and so did James and the
3 Chief of Staff, that actually Congressman
4 Wolfe made a fair point and we should subject
5 ourselves to FBI background checks. I
6 voluntarily, as did Carville and the others
7 disclose to the press all of our sources of
8 income and clients in the interest of full
9 disclosure.
10 Q In that context, did you ever have
11 any contact with Craig Livingstone or Anthony
12 Marceca?
13 A Not that I remember. Much later
14 when I turned in my pass I may have turned it
15 over to Livingstone, but I don't remember.
16 Q Did you ever talk about the issue
17 of the temporary passes with Hillary Clinton?
18 A With Mrs. Clinton?
19 Q Yes.
20 A Not that I can recall, sir.
21 Q During all of your conversations
22 with her, have you ever heard her use
312
1 Livingstone's name?
2 A Not that I can recall, sir.
3 Q Can't remember?
4 A Not that I can recall. I didn't
5 know the guy very well, so it would be
6 unlikely.
7 Q Who was the one who made the
8 decision to revoke your temporary White House
9 pass?
10 A I think it was Leon Pinetta, Chief
11 of Staff.
12 Q Did you ever discuss Livingstone or
13 Marceca with Leon Pinetta?
14 A Not that I recall.
15 Q You don't remember?
16 A I can't imagine that I did.
17 Q You have discussed the FBI files
18 matters with Leon Pinetta?
19 A Not that I recall.
20 Q Do you recall him giving an apology
21 to the American people over the files matter?
22 A No, sir, but I was living in Texas
313
1 at the time, and I wasn't following it very
2 closely. Nor was I in very close touch with
3 Leon.
4 Q You and I have debated each other
5 on television from time to time, correct?
6 A Yes.
7 Q We debated even when you were down
8 in Texas living there?
9 A Yes.
10 Q So you could keep up to date on
11 what was going on in Washington.
12 A I tried to as best I could. I
13 found my greater strength though was that I
14 wasn't immersed in the minutia of the
15 Beltway. I did a better job, maybe its
16 hubris, but I thought I did a better job
17 being further away and less tied down to
18 every insider angle.
19 Q What newspapers did you read in the
20 ordinary course when you were in Texas?
21 A The Austin American Statesmen,
22 which is my local paper. I read the Dallas
314
1 Morning News, would generally read the New
2 York Times and occasionally, infrequently
3 read the Wall Street Journal.
4 Q You continued to consult with the
5 White House during the period you were down
6 in Texas?
7 A No, sir, I did not. I was a friend
8 of people who worked there, but no, I did not
9 consult with the White House while I was in
10 Texas.
11 Q Have you ever met an FBI agent?
12 A Yes, sir.
13 Q Which one or ones have you met?
14 A I can't remember the names, but I
15 have had security checks.
16 Q In context of your working with the
17 White House, Clinton White House?
18 A Yes, sir.
19 Q Do you remember, have you ever met
20 Gary Aldridge?
21 A Not to my knowledge.
22 Q Did you ever meet Dennis
315
1 Scolengreenie?
2 A Not to my knowledge, no, sir. You
3 asked me that this morning.
4 Q Have you ever discussed with
5 anybody in the White House the issue of Gary
6 Aldridge's book, Unlimited Access?
7 A I remember Stephanopoulos going on
8 TV and criticizing it. I can't remember if I
9 talked to him about it. Again, I was living
10 a long way away.
11 Q Has the issue come up recently at
12 the White House, Gary Aldridge's book?
13 A No, sir, not that I recall.
14 Q Has anyone planning to file a
15 lawsuit again Mr. Aldridge?
16 A Not that I am aware of. No, sir.
17 Q It has been threatened in the past?
18 A That is news to me.
19 Q Do you know Howard Shapiro of FBI
20 fame?
21 A Not that I know of.
22 Q You never met him?
316
1 A Not that I can recall.
2 Q You are not sure, you may have met
3 him?
4 A Again, in the course of public life
5 you meet a lot of people, but I don't
6 remember meeting Howard Shapiro from the FBI.
7 Q Did you ever go into the vault in
8 the office of personnel security?
9 A No, sir. I never heard of any such
10 thing.
11 Q Do you know of anyone who did?
12 A No, sir, I didn't know that there
13 was one.
14 Q Are you aware that Craig
15 Livingstone an Anthony Marceca had a bunch of
16 interns that worked with them?
17 A No, sir, I was not.
18 Q Have you ever met Monica Lewinsky?
19 A No, sir, not to my knowledge.
20 Q How often do you see the President
21 on a weekly basis, currently, roughly
22 speaking?
317
1 A Most business days.
2 Q Once or twice or how many times?
3 A A week or a day?
4 Q A day?
5 A Generally, once or twice a day.
6 Q When do you generally see him the
7 first time during the day?
8 A Before his first public or press
9 appearance.
10 Q What is the purpose of your seeing
11 him?
12 A I am part of a team of people who
13 help prepare him before he makes public and
14 press announcements, speeches, press
15 conferences, those sorts of events.
16 Q What time of the day do you
17 generally meet with him initially?
18 A It varies depending upon what time
19 an event has been scheduled for.
20 Q Is it generally early?
21 A No, no, sir. He is not a morning
22 person.
318
1 Q What time does he generally arrive
2 to work?
3 A He doesn't meet with anybody or us,
4 I don't really know. But we try to schedule
5 news events around 10:00 a.m. to 2:00 p.m.
6 which is a slot which makes it most
7 convenient for the news people covering us.
8 Q The press reports that he gets up
9 at 5:00 a.m. are incorrect?
10 A Oh, I don't know. When I traveled
11 with him, that was not the case. That was
12 six years ago though.
13 Q How long do you meet with him
14 generally in preparing him, just roughly
15 speaking?
16 A Roughly 10 to 15 minutes.
17 Q If you meet with him later in the
18 day, when is that?
19 A Only if there would be some
20 subsequent public event. There are days that
21 we do more than one event in a day.
22 Q What is your working day? When do
319
1 you start?
2 A I start work about 7:30, I come in
3 much earlier so I can run.
4 Q When do you leave generally?
5 A Generally about 7:15, 7:30 in the
6 evening. Some nights, later.
7 Q In your office do you have a
8 television?
9 A Yes.
10 Q Do you have more than one?
11 A No, sir.
12 Q Split screen or anything so you
13 could see all of the those at the same time?
14 A No, just a little, maybe 13 inch.
15 Q What is your favorite show during
16 the day?
17 A I generally watch CNN, but I
18 sometimes watch MSNBC and am surprised by
19 what I see.
20 Q Whenever I am on, you watch.
21 A I happened to catch you.
22 Q Thank you, I appreciate that.
320
1 That is part of your job is to
2 monitor what is being said in the press?
3 A It is important for me to know what
4 is going on TV, I think.
5 Q Since you returned to the White
6 House, have you ever heard of the phrase FBI
7 files from any source inside the White House?
8 A I can't remember conversation about
9 FBI files or their use or misuse. I do know
10 that there is an ongoing controversy. In the
11 last few days I have obviously learned a lot
12 more about it from you. But I can't remember
13 any other conversations about that topic.
14 Q Have you ever discussed opposition
15 research with Mrs. Clinton?
16 A Not that I can recall.
17 Q The President?
18 A I imagine before he was President,
19 for his campaign in 1992.
20 Q During the time that you have been
21 with the White House, beginning this year?
22 A Not that I can recall. But again
321
1 let me -- one more time restate what I mean
2 by that.
3 What I mean is statements and votes
4 and quotes on the public record. That is the
5 opposition research that wins elections and I
6 think that is the opposition research or
7 favorable positive research that advances
8 public issues.
9 I do not like any of the attacks on
10 the people's private lives. I have seen the
11 President subjected to more of that than
12 anybody ever ought to survive or ought to go
13 through and still survive. So I don't want
14 to see anybody else dragged through that.
15 Q So you will never, ever, for the
16 rest of your life in Washington, ever mention
17 any aspects of an adversary's private life?
18 A I try very hard. We all fall
19 short. I try very hard for that. I'm sure
20 you will, if you talk to the people that I
21 work with or reporters that I deal with, I
22 think they will tell you that I don't traffic
322
1 in people's private lives.
2 I work on, I hit very hard, we have
3 been on TV against each other. I believe in
4 rough, tough politics, but I don't like the
5 direction that some people are trying to
6 take --
7 Q I believe you called me a right
8 wing nut?
9 A Yes, to me that is sort of
10 acceptable hyperbole. It is not about your
11 private life.
12 Q It is all right to call me a nut?
13 A You have probably called me a lot
14 worse.
15 Q I never called you a name.
16 A Yeah right. Ad hominum, you bet.
17 I think the body politic is very resilient, I
18 think we can take that.
19 I do not, though, endorse the kinds
20 of attacks that have been made against the
21 President.
22 Q I guess that is left to Sidney
323
1 Blumenthal to discuss private lives?
2 A Not to my knowledge, no, sir.
3 Q Have you ever discussed opposition
4 research with James Carville during the
5 period after you returned to the White House?
6 A It is a campaign function. Again,
7 by which you mean --
8 Q Carville made a statement recently
9 that it was time to wage war against
10 Clinton's adversaries, correct?
11 A No, my recollection was he was
12 specific about Ken Starr.
13 Q You discussed that with him, the
14 statement with Ken Starr?
15 A I can't remember discussing it with
16 him. But I remember James saying that.
17 Q What did he say about how he was
18 going to wage war?
19 A He has been very public in his
20 criticisms of Judge Starr.
21 Q You did discuss with him how he was
22 going to wage war, did you not?
324
1 A I don't remember talking that
2 particular phrase with him. He made no
3 secret. You don't have to talk to him to
4 though the criticisms he has about Ken Starr.
5 Q How is he going to wage war?
6 A He has taken to the public air
7 waves. He goes on any number of TV shows.
8 He attended a breakfast with 30 reporters, in
9 the last couple of weeks. By publicly
10 mounting the podium and speaking out.
11 Q Now, he made statements in the last
12 week and a half, mocking Ken Starr's
13 religious beliefs, has he not?
14 A I would rather let James talk about
15 that.
16 Q You have read that, have you not?
17 A I don't know if I would
18 characterize them that way.
19 Q The Style section of the Washington
20 Post?
21 A I don't want to characterize.
22 Q That Ken Starr was going to, in the
325
1 context of his religion, drive all of the
2 fornicators out of Washington?
3 A I don't know if that was about his
4 religion but I think many critics have seen,
5 what the Washington Post reported was Starr's
6 effort to probe into the President's private
7 life, months ago -- six months ago.
8 Q Were you present when Carville made
9 those remarks?
10 A No, it was, I think at a press
11 conference of some sort.
12 Q Do you approve of making fun of
13 someone's religion?
14 A I don't think James was making fun
15 of someone's religion. He is a religious
16 person himself. We all try our best. I
17 don't want to characterize him, though.
18 Q So if he is making fun of the
19 worship of subpoenas, that is not making fun
20 of religion?
21 A No. I think that there have been
22 too many subpoenas thrown around. I think
326
1 that is a fair criticism. I don't see how
2 that gets to anybody's religious beliefs.
3 Q Did you discuss with James Carville
4 the war against Ken Starr by using
5 investigators?
6 A No, sir. I don't recall any such
7 conversation.
8 Q You may have had one, but you don't
9 remember?
10 A I don't remember ever having one.
11 Again, James' comments have been as public as
12 they can be. This is not a private thing
13 that he is doing. It is a public as it can
14 possibly be.
15 Q It makes it okay because it is
16 public?
17 A It makes its public. I have not
18 heard any discussion -- had any discussion
19 about anything except what he said in public.
20 Q Have you ever met Randy Turk?
21 A The name does not ring a bell.
22 Q Lawyer of Mr. Livingstone?
327
1 A No.
2 Q Gary Cohen, lawyer of
3 Mr. Livingstone?
4 A Not that I can recall, no, sir.
5 Q Have you ever talked to David
6 Watkins? Do you know David Watkins?
7 A David Watkins who used to work in
8 with White House?
9 Q Yes.
10 A I remember him.
11 Q How do you remember him?
12 A I remember he worked in the White
13 House.
14 Q Did you ever meet him?
15 A Yes, sir, I did.
16 Q In what context?
17 A I met him in the '92 campaign.
18 Q What was his job in '92 campaign?
19 A I can't remember. Some
20 administrative function. Carville and I as
21 consultants were not in the direct line of
22 administrating. Campaign, particularly
328
1 presidential, are enormous management
2 undertaking.
3 James and I are better at
4 consulting than managing. So he had some
5 management function, is my recollection.
6 Q Did you ever discuss FBI files with
7 David Watkins?
8 A No, sir, not to my knowledge or
9 recollection at all.
10 Q Are you aware that he has made a
11 statement that Hillary Clinton is the master
12 mind of Filegate or something to that effect?
13 A No, sir, I am not aware any such
14 statement.
15 Q Have you ever met a George
16 Saunders, S-a-u-n-d-e-r-s?
17 A That name does not ring a bell.
18 Q Have you ever met Joanne Hilty,
19 H-i-l-t-y?
20 A The name does not ring a bell. No,
21 sir.
22 Q Do you know Christine Varney?
329
1 A Yes, sir. I do.
2 Q Who is Christine Varney?
3 A She is a commissioner, I think on
4 the Federal Trade Commission.
5 Q Have you ever discussed Craig
6 Livingstone with Christine Varney?
7 A Not to my knowledge or
8 recollection.
9 Q Have you ever discussed FBI files
10 with Christine Varney?
11 A Not to my knowledge or
12 recollection.
13 Q You just don't remember?
14 A I have no recollection of any
15 conversation about the FBI file matter. It
16 was an issue that erupted when I was living a
17 long way away. While I like her, I have not
18 kept up our friendship over the years.
19 Q Do you know whether Ms. Varney has
20 retained Mr. Livingstone as a an employee?
21 A I have no idea. I thought she was
22 on the Federal Trade Commission.
330
1 Q Do you know whether Ms. Varney ever
2 hired or interviewed Mr. Livingstone?
3 A I have no idea. No, sir.
4 Q Do you know Cheryl Mills?
5 A Yes.
6 Q When did you first get to know her?
7 A I guess when she was working in the
8 White House. I can't recall.
9 Q What was her position at the time?
10 A I can't recall. She is in the
11 office of White House counsel now, maybe she
12 was then. I can't remember.
13 Q Did you ever discuss
14 Mr. Livingstone with her?
15 A Not to my knowledge or
16 recollection.
17 Q Did you ever discuss the FBI files
18 matter with her?
19 A Not to my knowledge or
20 recollection.
21 Q You can't remember?
22 A No, I do not recall any
331
1 conversations about the FBI file matter. It
2 was not a matter I worked on and I have no
3 knowledge of the use or misuse of FBI files.
4 Q Do you know who Mari, M-a-r-i,
5 Anderson is?
6 A The name does not ring a bell.
7 Q If I told you that she worked in
8 the Inspector General's office of the
9 Treasury Department, does that refresh your
10 recollection?
11 A No, sir, it does not.
12 Q Are you aware of two FBI agents
13 that she ordered investigated at the Treasury
14 Department?
15 A No, sir, I am not.
16 Q I am sorry.
17 Have you ever heard of Valerie
18 Lowe?
19 A The name does not ring a bell.
20 Q I inserted names. If I were to
21 tell you she worked in the Inspector
22 General's office of the Treasury Department,
332
1 would that refresh your recollection?
2 A No, sir.
3 Q Are you aware of two FBI agent that
4 were involved in the Filegate matter being
5 investigated at Treasury?
6 A No, sir, I was not aware of that.
7 Q I will show you what I will ask the
8 court reporter to mark as Exhibit 12.
9 (Begala Deposition Exhibit
10 No. 12 was marked for
11 identification.)
12 BY MR. KLAYMAN:
13 Q Showing you Exhibit 12, this is an
14 article from the Washington Post, Steven Barr
15 is the author dated January 17, 1998. Take
16 an opportunity to read that quickly.
17 A Yes, sir.
18 Q Does that refresh your recollection
19 about whether you know a Valerie Lowe or have
20 ever talked with her?
21 A No, sir.
22 Q Know of her existence on earth?
333
1 A I can never remember hearing about
2 her before.
3 Q Have you ever heard about an FBI or
4 Secret Service agent by the name of John
5 Libonati, L-i-b-o-n-a-t-i?
6 A No, sir. The name does not ring a
7 bell.
8 Q Another Secret Service agent by the
9 name of Jeffrey Undercoffer,
10 U-n-d-e-r-c-o-f-f-e-r?
11 A No, sir, the name does not ring a
12 bell.
13 Q What is Public Strategies, Inc.?
14 A PR -- a strategic communication
15 firm, they would prefer to be called rather
16 than PR. A strategic communication firm in
17 Austin, Texas.
18 Q Until recently joining the White
19 House, in August, 1997, is that where you
20 worked?
21 A Yes, sir.
22 Q Did you also teach school at
334
1 University of Texas?
2 A I taught journalism, believe it or
3 not, at the University of Texas.
4 Q Did you teach your students to
5 correct the record if they had inaccurate
6 information?
7 A We discussed a number of ethical
8 conundrum, including, I can't remember that
9 particular topic, but any number of things.
10 And I team taught with a career
11 reporter of great distinction, so the
12 students would get both sides of the
13 practical press politics relationship.
14 Q Who was that team reporter?
15 A Dave McNeely.
16 Q Where does he work?
17 A The Austin American Statesman, he
18 is their chief political writer.
19 Q How is that spelled?
20 A M-c-N-e-e-l-y.
21 Q Did you ever discuss the Clinton
22 White House?
335
1 A Yes, sir. In our class we talked
2 about issues of the day which invariably
3 revolved around the '96 campaign and press
4 coverage thereof.
5 Q Were any of the classes which you
6 taught taped?
7 A I don't know. Perhaps.
8 Q Do you know whether the White House
9 has a taping system in common areas?
10 A Not to my knowledge. No, sir.
11 Q Do you know whether there is a
12 video surveillance system in the White House?
13 A Not to my knowledge, no, sir.
14 Q Has anyone asked that question
15 recently, to the best of your knowledge?
16 A No, sir, not to the best of my
17 knowledge.
18 Q I am starting to talk like you to
19 the best of your knowledge. After this is
20 over I am not going to be able to ask a
21 question without, to the best of your
22 knowledge.
336
1 A I am trying to be as perfectly
2 accurate as I can.
3 Q Who owns Public Strategies, Inc.?
4 A Jack Martin.
5 Q Who is Jack Martin?
6 A The guy who owns the company. I
7 don't mean to be flip. There are a few other
8 small -- 5 percent or so, but Jack owns, to
9 my knowledge, 85 percent of it. He is a very
10 successful businessman in Austin.
11 Q Have you ever discussed the Clinton
12 White House with Jack Martin?
13 A Yes, sir.
14 Q Have you ever discussed the FBI
15 files matter with him?
16 A No, sir. Not to my knowledge or
17 recollection.
18 Q Did you recount your experiences
19 from time to time with Jack Martin at the
20 Clinton White House?
21 A From time to time. He is an
22 experienced political person himself.
337
1 Q Are you still in contact with him?
2 A Occasionally.
3 Q Does he call you from time to time
4 at the White House?
5 A Once or twice in the last six
6 months.
7 Q Do you tell him what is going on?
8 A Just, he calls and checks in. He
9 is a friend of mine, former colleague.
10 Q Is this firm dedicated to helping
11 Democrats as opposed to others?
12 A No, sir. They do no political
13 work. Many of the senior people there worked
14 for President Bush. That is one of the
15 reasons I do say there are some good
16 Republicans out there, because some of the
17 senior people in that firm were senior people
18 in the Bush White House. I came to find them
19 to be people of very high integrity.
20 Q Besides Mary Matalin, who are the
21 good Republicans.
22 A I can name you a few. David Bates,
338
1 Fred McLure, Jean Johnson Phillips. Three
2 top people either with Governor Bush, or
3 Bates and McLure's case, President Bush.
4 Q Was Bob Barr on of the good
5 Republicans?
6 A I don't know Congressman Barr. I
7 am not a fan of his however.
8 Q Henry Hyde?
9 A I have met Henry Hyde just once and
10 I was very impressed with him.
11 Q I guess you are a fan of Newt
12 Gingrich?
13 A You have to admire his skill, but I
14 do not agree with his ideology.
15 Q His skill to weasel his way out of
16 difficulty?
17 A No, sir, but for him I don't think
18 they could have recaptured the House, the
19 Republicans. I admire talent.
20 MR. KLAYMAN: I will show you what
21 I ask the court reporter to mark as
22 Exhibit 13.
339
1 (Begala Deposition Exhibit
2 No. 13 was marked for
3 identification.)
4 BY MR. KLAYMAN:
5 Q I will show you Exhibit 13. We
6 will staple it later.
7 Look at the last page. James
8 Carville Just Itching for a Subpoena.
9 This is a report that is contained
10 in Exhibit 13 from The Reliable Source of the
11 Washington Post, February 27, 1998. I am
12 reading the last page.
13 "James Carville has had a bad case
14 of subpoena envy. The former political
15 consultant for President Clinton has been the
16 leading basher of Ken Starr for years, but
17 who gets the subpoena for mud slinging?
18 White House aide Sidney Blumenthal. It is
19 not fair.
20 "So Carville has practically been
21 begging Starr for a subpoena of his own. On
22 Tuesday he mocked Starr's worship practices
340
1 during the reporter's breakfast chortling
2 about the prosecutor listening to him and
3 praying to `wash all of the sodomized and
4 fornicators out of town'."
5 You are aware Mr. Carville made
6 those statements?
7 A I am.
8 Q Do you approve of them?
9 A It is not for me to pass judgment
10 on James.
11 Q Would you make a statement like
12 that?
13 A I probably would not.
14 Q He is mocking Starr's worship
15 practices?
16 A I don't think so. He is pointing
17 out something that I do find chilling, and I
18 have commented on. Six months ago the
19 Washington Post reporter, Bob Woodward, that
20 Starr was investigating, had Bill Clinton's
21 private life. His sex life and the sex life
22 of innocent Americans.
341
1 I find that deeply problematic and
2 troubling. I think James is trying to call
3 attention to an unfair inquisition into
4 people's private lives.
5 Q What does that have to do with
6 Starr's worship practices?
7 A You ought to ask James, he is,
8 believe me, more capable than I am, of
9 defending himself.
10 Q You would not do that, would you?
11 A It is different strategies.
12 Q I am trying to figure out --
13 A He is trying to calling attention
14 to what I think is a very important issue.
15 Six months before anybody had heard the
16 current accusations Bob Woodward reported,
17 and he may be wrong, but Bob reported, and it
18 was unchallenged, that Starr and his
19 investigators were prying into people's
20 private lives.
21 I do not approve of that any more
22 than prying into anybody's private life. I
342
1 think James is trying to call attention to it
2 there. He is doing it is in the classic
3 Carvillian fashion. It gets attention.
4 Q Did you know, before James, I guess
5 it is Carville not Bond -- did you know he
6 was going to make this statement?
7 A No, sir, I did not. I assure you
8 he had no idea he was going that make it
9 until it fled out of his mouth. I have been
10 in business with him 12 or 13 years and --
11 Q Is he on retainer?
12 A Not that I know of.
13 Q He might be?
14 A I would doubt it, I would doubt it.
15 Q Has the White House issued any
16 statement disclaiming Carville's mocking of
17 Starr's religious practices?
18 A Not that I know of.
19 Q Has that been discussed?
20 A No, sir, not that I know of.
21 Q Are you aware that Carville has
22 called me a little twerp?
343
1 A That is more fair. You know, he
2 ought to be able to, I am for name calling.
3 I am not going to sanctimonious. I do it
4 myself. I think people out to be robust and
5 have a thick skin.
6 Q Did you agree I am a little twerp?
7 A I am under oath.
8 Q In which case you should be
9 emboldened to answer?
10 A I am under oath.
11 Q What did you do for the Democratic
12 National Committee between January of '93 and
13 August of '95?
14 A A variety of tasks. Principally
15 advised the President and his political aides
16 on politics.
17 Q Were you in any way involved in
18 fundraising?
19 A I attended fundraisers or would
20 speak at them but did not solicit
21 contributions.
22 Q Did you deal at all with Marvin
344
1 Rosen?
2 A I met him.
3 Q You mean recently in Miami when you
4 were down there talking about FBI files?
5 A I did not talk to him in Miami when
6 I was making jokes that were absurd in their
7 falsity.
8 Q Have you ever been met John Wong?
9 A Not to my knowledge.
10 Q You are not sure?
11 A Not to my knowledge. I have no
12 recollection of meeting him.
13 Q Did you ever meet Charlie Trie?
14 A Not to my knowledge.
15 Q Johnny Chung?
16 A Not to my knowledge.
17 Q You state that you were special
18 government employee while you assisted in
19 efforts to pass the President's economic
20 plan.
21 What is a special government
22 employee in your opinion?
345
1 A In my opinion is someone who
2 directs employees of the White House or has
3 some management or line authority, who has a
4 phone and/or a desk someplace where he or she
5 works. That is a distinction that I was
6 told, as opposed to a consultant which I have
7 generally been.
8 There were a few weeks where my
9 involvement was so heavy, that counsel's
10 office at the time thought it would be best
11 that I be designated as a special government
12 employee.
13 Q As a special government employee,
14 who told you that you should be designated as
15 a special government employee?
16 A White House counsel at the time,
17 one of the deputy councils.
18 Q Was it Hillary Clinton?
19 A My recollection was its was Beth
20 Noland.
21 Q Does Hillary Clinton, based upon
22 your experience with her, consider herself to
346
1 be a special government employee?
2 A I have no idea. I have never had
3 that conversation. This was in furtherance
4 of the President's economic plans which is
5 not something Mrs. Clinton was front and
6 center on.
7 Q You state in your affidavit,
8 paragraph 5, "in fact, I have no information
9 to suggest that any individual in the White
10 House has used FBI background files for any
11 improper purpose."
12 A Yes, sir.
13 Q Did you write that yourself?
14 A I reviewed it and signed it.
15 Q Who wrote it?
16 A I don't know.
17 Q Who handed it to you to sign?
18 A Ms. Paxton from counsel's office.
19 Q Did you ask her who wrote it?
20 A No, sir.
21 Q Did you meet with anyone in the
22 counsel's office before this affidavit was
347
1 prepared?
2 A Yes, sir.
3 Q Who was that?
4 A Ms. Paxton.
5 Q When did you meet with her?
6 A Last day or two when that was --
7 after you served notice, before I came here.
8 Yesterday. Before that, when we executed the
9 affidavit.
10 Q Where did your meeting take place?
11 A In her office.
12 Q Where is that, in the White House?
13 A In the Old Executive Office
14 building.
15 Q How long did you meet for?
16 A I can't recall. I went over that
17 at some -- I mean I wanted to make sure that
18 this did reflect my knowledge. Again I will
19 say it and I signed an oath. I don't have
20 any knowledge of the use or misuse of the FBI
21 files.
22 Q I am just staying on these issues,
348
1 we will get to that.
2 A That is what you asked about.
3 Q You said it 100 times.
4 A It is very important, because that
5 is what I have been called here for.
6 Q It's on the record. I know you
7 know nothing, that is what you claim. I am
8 asking a different question.
9 How long did you meet with
10 Ms. Paxton, that first meeting?
11 A I can't recall.
12 Q Was anyone else present?
13 A No.
14 Q What happened after that, in terms
15 of the affidavit?
16 A It was drafted and presented to me
17 subsequent to that.
18 Q When it was presented to you, who
19 did you meet with?
20 A Ms. Paxton.
21 Q How long was the meeting?
22 A Less than an hour. I can't recall.
349
1 Q Were there any changes suggested to
2 the affidavit?
3 A I remember making changes. I can't
4 tell you what they were, but I remember
5 making some changes.
6 Q What happened at that point?
7 A Someone incorporated them and it
8 was brought back to me.
9 Q Did you make notes of your meeting
10 with Ms. Paxton?
11 A No.
12 Q Did you make notes of either
13 meeting with Ms. Paxton, the first one or the
14 second one when the affidavit was presented
15 to you?
16 A No.
17 Q Was Ms. Paxton making notes?
18 A Not that I recall.
19 Q This was a few days ago? Are you
20 telling me you can't remember if she had a
21 noted pad?
22 A I don't think she was, but I don't
350
1 remember.
2 Q Did you see her with a pen in her
3 hand?
4 A She had an affidavit in front of
5 her and I was going over it with her
6 saying --
7 (Pause)
8 BY MR. KLAYMAN:
9 Q Did you take notes during these
10 meetings with Ms. Paxton?
11 A No, sir.
12 Q Did you make any kind of notations
13 on the affidavit?
14 A I may well have, or she may have.
15 Q Have you kept drafts of those
16 affidavits?
17 A I have not.
18 Q Who has the drafts?
19 A I left them in her office.
20 Q Who brought you back the affidavit?
21 A I don't know.
22 Q When you signed it? Was it