401
1 Civility and Society, I believe that is it.
2 It is a remarkable group of mostly
3 academics, and Justice Breyer was addressing
4 them that night in Washington. They
5 generally met in Pennsylvania. They came to
6 Washington to be addressed by Justice Breyer.
7 I had to miss it. I can't remember why.
8 Q Is he related to Breyer's ice
9 cream?
10 A I don't know. I missed that event.
11 Q Is he from Philadelphia?
12 A Breyer. No, I don't think so.
13 Q Who is Rick Dunham?
14 A He is a writer for Business Week
15 magazine.
16 Q Before that at 4:00 p.m., you had
17 some called Ethics Training?
18 A Yes, sir.
19 Q Who provided that training?
20 A I think the office of White House
21 counsel.
22 Q What were they teaching?
402
1 A They were teaching the ethical
2 rules of travel, of gifts, of post-employment
3 restrictions, that sort. They do it in a
4 very entertaining way.
5 Q Do they teach you how to clean out
6 your documents from time to time?
7 MS. SHAPIRO: Objection.
8 THE WITNESS: It is really a
9 terrific course.
10 BY MR. KLAYMAN:
11 Q You have heard of document
12 retention; have you not?
13 A No, I don't know that term.
14 Q Has anybody provided any advice in
15 the White House how long you should keep
16 documents?
17 A No, my assistant turns over to
18 records management whatever she does not keep
19 that are not active.
20 Q Who at records management gets your
21 documents?
22 A I have not the slightest idea.
403
1 Q What is the criteria?
2 A Something I am not using any more,
3 not current or active. A classic example
4 would be a speech that the President had
5 already given, that the event was over.
6 Q Is there any directive in your
7 office to shred documents or throw them away?
8 A No.
9 Q So everything would be turned over
10 to records management?
11 A Any schedule of the President's is
12 but in a burn bag. That is a security rule.
13 Q Any other directives on destroying
14 documents?
15 A I don't know if I am allowed to say
16 that.
17 MS. PAXTON: You already have.
18 BY MR. KLAYMAN:
19 Q Any other directives on destroying
20 documents?
21 A No, I don't have a shredder.
22 Q In response to Judicial Watch's
404
1 notice of deposition, you did not ask records
2 management to do a search; did you?
3 A I asked my assistant. I don't know
4 if she looked to records management or not.
5 Q You're not sure?
6 A I'm not sure.
7 Q You didn't specifically tell her to
8 look to records management?
9 A I impressed upon her that this was
10 a serious matter, and we needed to find
11 everything. I hold forth as a good example
12 that in good faith, that even passing
13 references in larger documents were
14 discovered and provided to you.
15 Q You didn't specifically tell her
16 make sure you check with records management?
17 A I can not recall.
18 Q Yes or no?
19 A I can't recall.
20 MR. KLAYMAN: I will make a request
21 that we search records management.
22 MS. SHAPIRO: Records management
405
1 has been searched.
2 MR. KLAYMAN: Not with response to
3 his deposition.
4 MS. SHAPIRO: I think our response
5 to his most recent document request speaks
6 for itself. You have that document.
7 MR. KLAYMAN: It does speak for
8 itself. It has not been searched. I am
9 asking you to do it. If I have to move, I
10 will ask for attorneys fees and costs.
11 MS. SHAPIRO: Again, it speaks for
12 itself.
13 MR. KLAYMAN: It does, and he came
14 up with documents that were not produced the
15 first time.
16 MS. SHAPIRO: I will not get in a
17 legal argument with you. That is on the
18 record.
19 BY MR. KLAYMAN:
20 Q January 29, 1998, who is Joe
21 Rosapeppi?
22 A He is America's ambassador to
406
1 Rumania.
2 Q Who is Joy Howell?
3 A I did not meet with her. She works
4 for Senator Torricelli, but I did not meet
5 with her.
6 Q Who met with her?
7 A Nobody. It just didn't come
8 together.
9 Q Have you met with Senator
10 Torricelli in the last several months?
11 A I have seen him, I think; I can't
12 remember. Ms. Howell is from Texas and knows
13 friends of mine in Texas. I don't her very
14 well, but she called me at one point and said
15 we have a lot of friends in common in Texas,
16 and we ought to get together. It never came
17 together.
18 Q Torricelli has been enlisted to
19 push for an investigation of Starr in the
20 Senate?
21 A I don't know about enlisting. He
22 has been outspoken.
407
1 Q You met with him about that?
2 A Not to my recollection.
3 Q You have talked to him about that?
4 A I've probably seen him. I might
5 have called him if he made a good appearance
6 on TV. I can't remember. I know him. I
7 never worked for him. I like him.
8 Q You discussed his counter attack on
9 Ken Starr; haven't you?
10 A I can't recall. I might have
11 called him again to thank him or congratulate
12 him for a particular good performance on TV.
13 As you know, some of those things are
14 stressful.
15 Q He is a White House ally?
16 A I wouldn't rule that out. He is a
17 United States Senator from an important
18 state.
19 Q And a White House ally.
20 A On some things, and on other
21 issues, no. He is a very independent person.
22 Q Ann Lewis, is she a White House
408
1 ally?
2 A No, she is a White House employee.
3 She is a communications director.
4 Q How do you define White House
5 alley?
6 A I don't. It is not my phrase.
7 Q Anybody friendly with the White
8 House?
9 A It is not my phrase. I don't want
10 to be called upon to define somebody else's
11 phrase.
12 Q Did you ask George Stephanopoulos
13 what he meant by that?
14 A No, sir, I did not.
15 Q Did you ever ask anybody else?
16 A No, sir, I did not.
17 Q Did you have any conversations with
18 John Conyers in the last three months?
19 A I saw him at a Democratic retreat,
20 had a very brief conversations with him. I
21 see him from to time at events in the White
22 House. I haven't been to his office or
409
1 anything like that.
2 Q Have you discussed his attack on
3 Ken Starr?
4 A I can't recall with specificity. I
5 have run into him at various occasions.
6 Q Have others discussed the strategy
7 against Ken Starr with Congressman Conyers?
8 A I do not know.
9 Q He is a White House ally; isn't he?
10 A He is very powerful member of
11 Congress.
12 Q He is a White House ally?
13 A On some issues he agrees with us,
14 on some he disagrees.
15 Q Congressmen do have the ability to
16 get FBI files; don't they?
17 A I have no idea. I have no idea how
18 FBI files are used or misused.
19 Q February 4th, 2 p.m. meeting with
20 Hong Kong business people?
21 A Never came together.
22 Q Who were the Hong Kong business
410
1 people you were going to meet with?
2 A I don't know who they were. They
3 were business people. From time to time I
4 will speak with groups who are coming but
5 beginning something must have come up that
6 day and I never did it. I have nothing
7 against it, I give speeches from time to
8 time. I just never did that particular
9 event.
10 Q Was Charlie Trieh going to be part
11 of that group?
12 A Not to my knowledge, no, sir.
13 Q Friday February 6th, Ambassador
14 Bagley and Streisand dinner? What's that?
15 A I attended a dinner at Ambassador
16 Bagley's house in honor of the singer and her
17 new boyfriend.
18 Q Who is Elizabeth Wood?
19 A She -- I wound up not having lunch
20 with her. She is a friend of my priest if
21 Texas who has newly moved to Washington. In
22 part because of the garbage I have been drawn
411
1 into lately I have not had time to take her
2 to lunch.
3 Q Who is your priest in Texas?
4 A Do I need to name my priest? I
5 have no knowledge of FBI files. I have a
6 lovely friend who is a priest in LaPort,
7 Texas who is a source of comfort, inspiration
8 and support to me.
9 Q You may have talked to the priest
10 about important things?
11 MS. SHAPIRO: I object that is
12 ridiculous. Not only are you really into the
13 realm of the absurd, even if he communicated
14 with his priest, that is privileged anyway.
15 MR. KLAYMAN: It is not privileged.
16 Not in Texas.
17 MS. SHAPIRO: It is --
18 MR. KLAYMAN: It is not privileged
19 in D.C. either.
20 MS. SHAPIRO: He is not going to
21 name his priest.
22 BY MR. KLAYMAN:
412
1 Q You are not going to name your
2 priest?
3 A I would like have some scrap of
4 privacy. This guy is not political.
5 Q Name your priest, I will name my
6 rabbi?
7 A I am very aware of the fact that
8 this is public. I don't want a nice guy in a
9 small town bothered. That is all.
10 Q Is it going to besmirch your
11 priest?
12 A It might actually. The truth is
13 there are a lots of people who don't like the
14 President, don't like me. He ought to have
15 at least his life to himself.
16 Q We will certify that. Who is
17 Secretary Dalton?
18 A Secretary of the Navy.
19 Q Who is Vicki Radd?
20 A She was departing the White House,
21 White House staffer.
22 Q Is that the same Radd that drew up
413
1 your partnership agreement?
2 A Yes, it is.
3 Q What was she doing at the White
4 House?
5 A She most recently had been
6 assistant to the Chief of Staff working on
7 Fast Track. Before that she worked on other
8 issues.
9 Q Did you get her her job?
10 A No, sir I did not. She got that on
11 her own. She had been in communications
12 department before then, and was working with
13 Erskin when I came on.
14 Q You have kept in contact with her;
15 haven't you?
16 A Not since she left.
17 Q Before then?
18 A Sure, yes, she is a friend of mine.
19 Q Where is she located?
20 A D.C.
21 Q What is her office address?
22 A I don't know. She just --
414
1 Q What part of town?
2 A I don't know. She just left the
3 White House a few weeks ago. I don't know
4 what she is doing for a living.
5 Q The 12th of February, Texas
6 executive Barbara Jordan, Patton Boggs?
7 A Right. Texas Exes which is the
8 alumni groups of my college had an event at
9 the law firm of Patton Boggs in which I spoke
10 in honor of Barbara Jordan.
11 Q Have you had any contact with
12 Michael Brown in the last 6 months?
13 A I saw him in passing. He came to
14 the White House in some event in honor of his
15 father's memory.
16 Q You ever have talked to him about
17 the Clinton so-called scandals?
18 A No, not to the best of my
19 recollection.
20 Q February 20th, Emily's Lists,
21 campaign management. Who is Emily?
22 A Emily's List is a democratic or
415
1 progressive, I don't know what their
2 particular stripe is, it is a political
3 organization that brought people to
4 Washington for -- to train them how to work
5 in politics, and I spoke to them.
6 Q Who is Steve Rigley?
7 A Steve Rigley is the Chief of Staff
8 of the Governor of Georgia.
9 Q Sell Miller?
10 A Governor of Georgia.
11 Q Ellen Tousher, T-o-u-s-h-e-r?
12 A She is a Congressman from the State
13 of California.
14 Q Larry Summers?
15 A Assistant secretary of the
16 Treasury.
17 Q March. Jim Angle, A-n-g-l-e, who
18 is he?
19 A He is a reporter for the Fox
20 network.
21 Q The 18th of March, Madhu Chugh,
22 M-a-d-h-u, last name C-h-u-g-h. Who is that?
416
1 A She is a former student of mine
2 from the University of Texas coming up here
3 in search of a job.
4 Q Have you ever recommended any White
5 House interns for jobs?
6 A Yes, sir, I have. My intern I
7 recommended for a job.
8 Q The one working for you?
9 A The one who worked me when I began
10 in the White House.
11 Q Who was that?
12 A Melissa Prober. I gave you her
13 name this morning.
14 Q Where does she located?
15 A She lives here in Washington, she
16 is here in the metropolitan are.
17 Q Tom Johnson Conrad Black?
18 A I have not attended that yet. Tom
19 Johnson is the president of Cable News
20 Network. I don't know who Conrad Black is.
21 Bob Novak has invited me to a dinner with
22 him, in honor of the gridiron. Truth is, I
417
1 probably won't be attending.
2 Q Who is George Condon?
3 A He is the White House correspondent
4 for the Copley News Services invited me to
5 the gridiron dinner.
6 Q Who invited you, if anyone, to the
7 Women's Leadership Forum?
8 A Whoever runs the Women's Leadership
9 Forum. I can't recall her name.
10 Q Who is Terry Hunt?
11 A Terry Hunt is the Washington bureau
12 chief of the Associated Press.
13 MR. KLAYMAN: I will show you what
14 I will ask the court reporter to mark as
15 Exhibit 16.
16 (Begala Deposition Exhibit
17 No. 16 was marked for
18 identification.)
19 BY MR. KLAYMAN:
20 Q Showing you Exhibit 16, this is a
21 memorandum from Craig Livingstone to William
22 Kennedy, Associate Counsel, dated
418
1 March 17, 1993 concerning procedures to
2 receive a permanent pass.
3 Mr. Begala, have you ever seen this
4 document before?
5 A Not to the best of my recollection.
6 Q But you may have seen it?
7 A It doesn't look familiar.
8 Q Take an opportunity to review this
9 document.
10 A I have looked at it. It is not
11 familiar to me.
12 Q Does this refresh your recollection
13 as to how you get a permanent security pass
14 in the White House?
15 A Not really. It sets out some
16 procedures. I don't know if those are the
17 actual procedures.
18 Q Have you ever known how you get a
19 permanent security pass in the White House?
20 A I went for an FBI security check.
21 I filled out a number of forms of great
22 complexity and detail and was issued a pass.
419
1 MR. KLAYMAN: I will show you what
2 I ask the court reporter to mark as Exhibit
3 17.
4 (Begala Deposition Exhibit
5 No. 17 was marked for
6 identification.)
7 BY MR. KLAYMAN:
8 Q Showing you Exhibit 17, Mr. Begala,
9 have you ever seen this document before?
10 A Not that I recall, no, sir.
11 Q You see on the second page it has
12 your name, Paul Begala?
13 A I see it, sir.
14 Q At 1/23/98 it says EOP access list?
15 A Yes, sir.
16 Q What is EOP access list?
17 A I don't know. It is not a term I
18 am familiar with.
19 Q 1/26/93 temp White House pass; do
20 you know what that means?
21 A I am not familiar with any of these
22 terms.
420
1 Q 6/7/93 temp NGS pass; what does NGS
2 mean?
3 A I don't know. I am sorry. It is
4 not my area of specialty.
5 Q February 13, 1995 it says pass
6 deleted.
7 A I don't know what that means
8 either.
9 Q Does that mean that you passed out?
10 A It may be when my pass was
11 reclaimed. I don't know. I am speculating.
12 Q That was around the time that it
13 was reclaimed?
14 A I can't remember. It was '95. I
15 left in the middle of that year. It might
16 have been the beginning of that year.
17 Q 3/21/94, SF-86 signed. What does
18 that refer to?
19 A I don't know.
20 Q 6/16/94, BI completed. What does
21 BI mean?
22 A I don't know.
421
1 Q 12/26/93 temporary residence pass.
2 Does that mean you have a temporary residence
3 pass?
4 A I'm sorry. I don't see that.
5 Q Next page.
6 A That is not under my name.
7 Q That is somebody else?
8 A Yes.
9 Q Did you ever have any contact with
10 a Christopher D. Cerf?
11 A No. The name does not ring a bell.
12 Q Kathleen M. Whalen, W-h-a-l-e-n?
13 A I think there was a person in the
14 White House counsel's office by that name,
15 but I can't recall with any specificity.
16 Q To the best of your knowledge, has
17 Mr. Carville ever been arrested?
18 A I have no idea.
19 Q Has he ever been convicted of a
20 crime?
21 A Not in the time I have known him.
22 Q Have you ever been convicted of a
422
1 crime?
2 A No, sir. Speeding.
3 Q You were convicted of a speeding
4 crime?
5 A Sure, speeding, driving too fast, a
6 violation of the --
7 Q Did you plead guilty?
8 A Sure, I was speeding.
9 Q We have certain requests
10 outstanding during this deposition,
11 Mr. Begala. I am asking your counsel if you
12 will comply, if you can let me know by noon
13 tomorrow whether you will comply voluntarily
14 to those requests and we will send to you, we
15 will send to you tomorrow morning what
16 specifically those requests are and ask that
17 you respond to us say by noon.
18 MS. SHAPIRO: You know, if at all
19 possible, I would like until Thursday,
20 because we have a brief due tomorrow in this
21 case, and I am extraordinarily busy having
22 spent the entire day here today. I would
423
1 appreciate that courtesy. I will respond to
2 you.
3 MR. KLAYMAN: How about noon on
4 Thursday?
5 MS. SHAPIRO: That is fine.
6 BY MR. KLAYMAN:
7 Q Did there come a point in time,
8 Mr. Begala, when you were banned from the
9 White House because of a book written by Bob
10 Woodward called The Agenda?
11 A I don't think I was banned, but I
12 was certainly not Leon Pinetta's favorite
13 person.
14 Q What was it about that book that
15 irritated Pinetta?
16 A I called him a poster child for
17 economic constipation.
18 Q Is Leon constipated?
19 A Economically, I shouldn't make fun,
20 it caused me some consternation. I said it.
21 It was in the book. Leon was angry.
22 Q What did he do to retaliate against
424
1 you?
2 A I don't know. He was angry with
3 me. As a general matter, he had a different
4 view than Mr. McClarety did about the access
5 that political consultants ought to have. I
6 don't want to paint Leon as being just sort
7 of vindictive. He was clearly angry with me.
8 I was not in his good graces when he was
9 Chief of Staff.
10 But I think he issued a blank
11 declaration, my recollection is, that none of
12 the political consultants should have
13 permanent passes.
14 Q Why did they bring you back to the
15 White House given that consternation of Leon
16 Pinetta?
17 A First of all, I don't know how long
18 Leon stays mad. Second of all, the President
19 asked me to.
20 I would say I had great
21 reservations only because I have seen the
22 abuse people use with the legal process to
425
1 people in the political system.
2 That has been born out, today, but
3 you have to ask the President and Chief of
4 Staff what their reasons were for hiring me.
5 My understanding was that they
6 wanted me to come to work on their agenda for
7 the American people.
8 Q I have been quite courteous to you;
9 have I not?
10 A I wouldn't say -- you have been
11 courteous to me.
12 Q Do you consider your having to give
13 a deposition today an abuse?
14 A I consider the fact that all of
15 this is based about something which I have no
16 knowledge, and it is predicated on the fact
17 that I told a joke on C Span, I find it to be
18 remarkable.
19 Q It is also predicated upon the fact
20 that you know many of the actors in the White
21 House?
22 A I know precious few, if any, of any
426
1 of the people in involved in the matter that
2 you are pursuing.
3 Q You have also been in a position of
4 responsibility where you have had contact
5 with Hillary Clinton, the President,
6 Mr. Pinetta, Mr. Erskin Bowles and others?
7 A That I have.
8 Q If something had been said with
9 regard to FBI files, that would have been a
10 legitimate reason to question you, correct?
11 A None of whom, to my knowledge, have
12 ever done anything wrong, particularly in
13 regards to any use or misuse of FBI files.
14 Q If something had been said with
15 regard to FBI files, that would have been a
16 legitimate reason to question you, correct?
17 A I am sorry, I don't understand.
18 Q It is legitimate to ask you
19 questions --
20 MS. SHAPIRO: I object to you
21 getting in legal colloquy on the briefs.
22 MR. KLAYMAN: I want to know what
427
1 he means --
2 BY MR. KLAYMAN:
3 Q Is it abusive to bring someone in
4 and ask them questions in a courteous way?
5 A No, it is not.
6 Q I have been courteous to you?
7 A You have been courteous to me. I
8 would say you were rude to the court
9 reporter.
10 Q And, in fact, anytime you asked for
11 water I gave you water? Is this the court
12 reporter defense?
13 A If you are done.
14 Q During the course of this
15 deposition, you have not had recollection
16 many, many times, correct?
17 A I have responded to the best of my
18 recollection.
19 Q You haven't had recollection many
20 times?
21 A I have responded as best as can.
22 MS. SHAPIRO: Asked and answered.
428
1 BY MR. KLAYMAN:
2 Q Isn't it true that perhaps you had
3 had some memory, we might have gotten some
4 information?
5 A That is not true at all, I have
6 answered ever every question.
7 MS. SHAPIRO: That is an absolutely
8 inappropriate line of questioning. I think
9 we have wrapped up, this is superfluous.
10 MR. KLAYMAN: We will wrap up when
11 I tell you I am wrapping up.
12 BY MR. KLAYMAN:
13 Q When you were asked to come back to
14 the White House, did the President call you
15 personally?
16 A Yes, he did.
17 Q When was that?
18 A On or about the 13th of June.
19 Q Why did he tell you he wanted you
20 back in the White House?
21 MS. SHAPIRO: I object to that. I
22 am not allowing the witness to disclose any
429
1 conversations between --
2 MR. KLAYMAN: He was not an
3 employee of the White House at that time.
4 There was no so called executive privilege.
5 MS. SHAPIRO: I am instructing the
6 witness not the reveal any of the specific
7 conversations between himself and the
8 President.
9 MR. KLAYMAN: On what basis?
10 MS. SHAPIRO: The basis of
11 deliberative process and potentially
12 executive privilege.
13 MR. KLAYMAN: What deliberative
14 process privilege are you talking about? He
15 was a private citizen in Austin, Texas.
16 MS. SHAPIRO: The subject of his
17 conversation with the President of the United
18 States are potentially privileged, and I am
19 not going to allow him to speak about them.
20 You can certify that.
21 MR. KLAYMAN: What is the basis for
22 executive privilege?
430
1 MS. SHAPIRO: I will repeat myself.
2 He is not authorized to disclose the subjects
3 of conversation that he had spoken with the
4 President about.
5 MR. KLAYMAN: Certify it.
6 BY MR. KLAYMAN:
7 Q What did you say to the President
8 during that conversation?
9 MS. SHAPIRO: I thought this was
10 specifically the question I asked not be
11 asked. If you wait a minute while I consult.
12 (Witness conferred with
13 counsel)
14 MS. SHAPIRO: Move on.
15 BY MR. KLAYMAN:
16 Q What did you say to the President
17 during that conversation?
18 MS. SHAPIRO: I instruct the
19 witness not to answer or disclose the
20 conversation that he had with the President
21 of the United States.
22 MR. KLAYMAN: For the record,
431
1 please, tell me what constitutes deliberative
2 process privilege here.
3 MS. SHAPIRO: I am asserting
4 privilege that this could be a Presidential
5 communication. I myself don't know the
6 answer to the question, and I am not
7 authorized to potentially allow a waiver of
8 that privilege, and deliberative process is a
9 subset under the law of Presidential
10 communications.
11 MR. KLAYMAN: What case law do you
12 have?
13 MS. SHAPIRO: In re: Sealed, D.C.
14 Circuit.
15 MR. KLAYMAN: What's the citation?
16 MS. SHAPIRO: I don't have a
17 citation. But you can find it.
18 MR. KLAYMAN: What is the basis of
19 the claim of Executive privilege?
20 MS. SHAPIRO: Presidential
21 communication is a subset of part of the
22 Executive privilege, and that case will lay
432
1 out the law very specifically for you. I
2 don't think we need to take up time with the
3 legal privilege. I have asserted a
4 privilege, and I'm instructing the witness
5 not to answer.
6 MR. KLAYMAN: Are you saying
7 anytime the President talks to anybody it
8 could be privileged?
9 MS. SHAPIRO: Potentially, at least
10 until I know what has been discussed. If I
11 allow him to answer a question he potentially
12 waives something that is privileged.
13 BY MR. KLAYMAN:
14 Q Mr. Begala, at the time that the
15 President called you, who were you employed
16 for?
17 A Public Strategies Incorporated.
18 Q You were not employed by the White
19 House?
20 A That's correct.
21 Q You were not employed by President
22 Clinton personally; were you?
433
1 A No.
2 Q You were not employed by anyone
3 inside or related to the White House; were
4 you?
5 A Right.
6 Q Certify it, we will move for
7 sanctions, attorneys fees and costs.
8 I have no further questions. We
9 will leave the deposition open subject to the
10 various matters that are outstanding,
11 including the certified questions.
12 MS. SHAPIRO: That is fine. We
13 object, for the record, to leaving the
14 deposition open. We don't agree to that. We
15 will not be producing Mr. Begala without
16 order of the Court. Pursuant to the court's
17 own order limiting these depositions --
18 MR. KLAYMAN: Let me ask one more
19 question in that regard. Mr. Begala, I want
20 to ask you one more question.
21 MS. SHAPIRO: We have closed the
22 deposition.
434
1 MR. KLAYMAN: I have not closed.
2 It is still open as a matter of fact.
3 BY MR. KLAYMAN:
4 Q One more question, please have a
5 seat.
6 MS. SHAPIRO: One more question,
7 and then we will let you go.
8 MR. KLAYMAN: You won't decide.
9 MS. SHAPIRO: The judge will
10 decide.
11 MR. KLAYMAN: I am afraid he will
12 for you. We have a history here of
13 litigation with your Justice Department
14 walking out of depositions.
15 MS. SHAPIRO: We have not walked
16 out of this deposition, although we have had
17 due cause to walk out of this deposition.
18 MR. KLAYMAN: For which your
19 Justice Department has been sanctioned.
20 MS. SHAPIRO: I don't believe that
21 is so.
22 MR. KLAYMAN: If you want to see
435
1 the opinion, I will be happy to send it to
2 you.
3 MS. SHAPIRO: Thank you.
4 BY MR. KLAYMAN:
5 Q Mr. Begala, while you were still
6 employed by Public Strategies, did you have
7 any conversations with anyone else at the
8 White House about your returning to your
9 current positions?
10 A Yes, I did.
11 Q Who did you have the conversations
12 with?
13 A Erskin Bowles and Robert Magnum, to
14 the best of my memory.
15 Q Did Erskin Bowles call you?
16 A I saw him when I was visiting
17 Washington.
18 Q You, subsequently, visited
19 Washington?
20 A I was in town for others reasons.
21 Q When was that?
22 A I can't remember.
436
1 Q Was that after you talked to the
2 President?
3 A No, before.
4 Q You were not employed by the White
5 House at that time?
6 A No, that's right.
7 Q What was discussed with Erskin
8 Bowles?
9 A He raised his interest in me coming
10 to work in the White House.
11 Q What did he tell you the reason was
12 he wanted you back?
13 A He said that he wanted -- he said
14 he wanted me. He said he wanted me to work
15 particularly on communications and policy
16 issues, and he had a sense that it was as
17 much a personal thing. I know Erskin. I
18 worked with him.
19 There was a certain comfort level.
20 That some of the other President's senior
21 advisors were leaving. He thought I would be
22 a good fit.
437
1 It was a conversation also where he
2 had enormous influence on me because I know
3 how much he loves North Carolina about as
4 much as I love Texas. So he was the best
5 person to try to coerce me into taking this.
6 Q He told you he needed you to come
7 back because they needed someone to spin the
8 various scandals?
9 A No, sir. That is not my
10 recollection at all.
11 Q Was there a mention of any
12 scandals?
13 A No, not to my recollection. My
14 recollection was generally about the strains
15 of public service, on people like me and
16 Bowles, not the scandals.
17 Q No recollection?
18 A My recollection was that he wanted
19 me to come to work here. He talked about the
20 comfort level he had with me, the team that
21 he had in place and his style of management.
22 I have always been very impressed with him.
438
1 Q Did he tell you they needed someone
2 to be a hatchet man on Clinton adversaries?
3 A No, sir.
4 VIDEOGRAPHER: We are going off
5 video record at 5:51.
6 (Discussion off the record)
7 VIDEOGRAPHER: We are back on video
8 record at 5:53.
9 BY MR. KLAYMAN:
10 Q Did you have more than one
11 conversation with Erskin Bowles about your
12 return to Washington?
13 A I might have, but probably not many
14 more than one.
15 Q Did you discuss anything other than
16 what you just described with Mr. Bowles in
17 any other conversation?
18 A Not that I can recall.
19 Q Where did you have a conversation
20 with Rahm Emanuel about your return to
21 Washington?
22 A In his office, and by phone as
439
1 well.
2 Q What did you discuss with Rahm
3 Emanuel? Did Rahm Emanuel tell you why you
4 were wanted back in the White House?
5 A His sense was that others were
6 moving on, there was a slot opening, and he
7 wanted me to be there. He is a friend of
8 mine. We work well together.
9 Q Did he tell you what particular
10 skills that you had gave him an interest in
11 having you back?
12 A No, he talked about his
13 self-interest in having a friend in the key
14 spot in the White House.
15 Q Rahm Emanuel is a good friend?
16 A Yes.
17 Q You talked to him about George
18 Stephanopoulos's comment about Ellen
19 Rometsch; didn't you?
20 A I can't remember. Specifically, I
21 would hope I had, because he was one of the
22 many people called upon to comment to the
440
1 press.
2 Q So you probably did?
3 A I probably did.
4 Q You probably talked to Sidney
5 Blumenthal about that?
6 A I can't remember specifically. As
7 I said, there is a cadre of people like
8 myself who respond to the press. It would be
9 important for them to know that George made a
10 point to me of saying it did not come from
11 the White House.
12 Q You probably talked to Blumenthal,
13 too?
14 A I may have.
15 Q Who else?
16 A I can't recall. The communication
17 team, the people regularly asked by the press
18 to respond to these kinds of questions.
19 Q You talked to the President about
20 it; didn't you?
21 A Not to best of my recollection.
22 No.
441
1 Q You don't remember?
2 A No, I don't remember.
3 Q You talked to the First Lady about
4 that comment of George Stephanopoulos?
5 A Not to the best ever my
6 recollection.
7 Q You can't remember?
8 A No, sir.
9 Q You talked to Erskin Bowles about
10 that comment?
11 A No, sir, not to the best of my
12 recollection.
13 Q You can't remember?
14 MS. SHAPIRO: I object to you
15 mischaracterizing him saying not to the best
16 of his recollection and you saying you don't
17 remember.
18 MR. KLAYMAN: He is responding.
19 There is no reason to object.
20 MS. SHAPIRO: The objection is that
21 you are mischaracterizing what his testimony
22 is.
442
1 THE WITNESS: Let me be clear as
2 well. When I say no, not to the best of my
3 recollection, that is what I am saying. I am
4 not simply saying I can't remember. That is
5 your characterization, not mine, Mr. Klayman.
6 BY MR. KLAYMAN:
7 Q Now that your attorney told you
8 what to say, that is obviously your
9 characterization. Certify this.
10 In terms of Rahm Emanuel, did he
11 tell you that he wanted you back because
12 there were going to be lots of investigations
13 and a lot of heat being place on this White
14 House, and he needed somebody with good
15 communication skills?
16 A No, sir. My recollection was quite
17 the opposite. Rham wanted a friend in a key
18 position in the White House.
19 Q Anyone else that you talked about
20 coming back to the White House?
21 A Not that I recall.
22 Q Did you talk to James Carville?
443
1 A I may have. I can't recall. I
2 would likely have.
3 Q What did you talk to Carville
4 about?
5 A I would imagine my personal
6 trepidations of coming back into Washington
7 at a time when I think that people are
8 abusing the political process.
9 Q In other words, you didn't want to
10 come back to a situation where the White
11 House was under siege?
12 A No, sir, I didn't want to come back
13 to a place where I would be hauled in front
14 of being deposed for making a joke. I didn't
15 have that specifically in mind, obviously,
16 but the way that American politics generally
17 has turned, where we are turning away from
18 resolving issues to the ballot box and
19 turning everything over in a courtroom. It
20 is not to my liking.
21 Q So I take it you are criticizing
22 the court for ordering your deposition?
444
1 A No, sir, I am not. I am here on
2 very short notice and with full cooperation.
3 Q No further questions at this time.
4 We will leave the deposition open.
5 A Thank you very much.
6 MS. SHAPIRO: Let me state for the
7 record, we object to that.
8 VIDEOGRAPHER: We are going off
9 video record at 5:57.
10 (Whereupon, at 5:57 p.m., the
11 deposition of PAUL E. BEGALA
12 was continued.)
13 * * * * *