51
1 Florida. I went through each of the things
2 he asked for and got like a filing system in
3 there. It's not very elaborate or anything
4 like that. I don't keep -- you know, we have
5 anything in there if I've got -- all kinds of
6 different stuff.
7 Q Since you began to work for
8 Governor Clinton in 1992, have you kept
9 documents about your involvement with
10 Governor Clinton and then President Clinton
11 and the Clinton administration?
12 A Not really.
13 Q But you kept some, correct?
14 A Yeah, some.
15 Q Are all of those documents in that
16 file cabinet or are some stored elsewhere?
17 A No. I mean, everything that I
18 would have would be in that file cabinet.
19 Q You have another residence, do you
20 not, out in the Shenandoah Valley?
21 A I do.
22 Q Where is that located?
52
1 A In Warrentown, Virginia.
2 Q What's the address?
3 A 325 Fischer's Road.
4 Q You have a little office in that
5 residence, too, don't you?
6 A I wouldn't call it an office. I'm
7 not the type of person that really has a -- I
8 don't have a desk in my office in Washington.
9 I just don't do that kind of thing.
10 Q You don't have a desk in your
11 office in Washington?
12 A I don't, no, sir.
13 Q You work on the couch?
14 A Yes.
15 Q What do you have? Chairs in there?
16 A Well, I got two sofas and I think
17 there's a couple of chairs, and some people
18 come in to talk, we just take some chairs
19 where people that work for me sit.
20 Q Do you have a desk out in
21 Shenandoah valley?
22 A No, sir.
53
1 Q Do you have a fax machine?
2 A I do.
3 Q Sometimes you get faxes there from
4 your office in Washington, don't you?
5 A Sometimes.
6 Q Sometimes you get faxes from other
7 people, correct?
8 A Sometimes.
9 Q And you have gotten faxes from the
10 White House there from time to time in
11 Shenandoah Valley?
12 A Maybe, but I doubt it.
13 Q And you get faxes in your office or
14 home on Capitol Hill from The White House
15 from time to time, don't you?
16 A I do.
17 Q And you've gotten faxes from Paul
18 McGowan, George Stephanopolous at both
19 residences as well, have you not?
20 A I don't know. I would doubt if I
21 got very much but I obviously couldn't -- you
22 know, I couldn't say categorically that I did
54
1 not.
2 Q Where is the paper kept that comes
3 into your farm?
4 A I throw it away or I take it back.
5 It's usually -- when I get faxes is like
6 newspaper articles or something even if I get
7 that and I wouldn't -- most everybody if they
8 were going to fax me something would fax it
9 to the office.
10 Q Take it back where?
11 A To the office. In other words, I
12 get mail. That's where I live, you know, out
13 there but if I get mail I just take it into
14 the office.
15 Q You cart it into the office on
16 Capitol Hill?
17 A Let me just say if I got any faxes
18 out there -- I can't tell you that I didn't
19 because it's possible that somebody faxed me
20 something. If they did, 99 percent of the
21 time I would throw it away. It would be, you
22 know, a thing in the paper.
55
1 It would be something from Newsweek
2 or something like that. If it was something
3 that required -- like if it was a bill or
4 something -- it wouldn't be an instance where
5 somebody would fax that kind of thing to me,
6 but I don't keep stuff there. I mean, I'll
7 be -- you know, I'll be glad to do a due
8 diligence thing to see, but I know there's
9 nothing out there. I just don't -- it's just
10 not --
11 Q What is a due diligence thing?
12 A I don't know. It's just kind of a
13 word I heard.
14 Q Is that what private investigators
15 do, due diligence?
16 MS. MARSH: Objection.
17 Q Where do you get that word?
18 A I know it from law school
19 somewhere. I don't have a file out there or
20 anything, okay?
21 Q But you may have some paper out
22 there and you didn't search, correct?
56
1 A I haven't been out there. I
2 haven't been in town. I haven't been to the
3 thing, but I could say I would be more than
4 delighted to -- I don't have any paper. I
5 wouldn't know where to look for a file out
6 there.
7 Q You'd be delighted to do that?
8 A Yeah.
9 Q Now, in terms of paper that comes
10 into your Capitol Hill office, have you kept
11 some from the 1992 campaign?
12 A Not really. I didn't, you know --
13 I don't have anything in the office from the
14 '92 campaign. Most of that stuff is boxed
15 up, and when I left Little Rock I didn't take
16 anything with me.
17 Q Do you have anything from the 1992
18 campaign forward that you've kept? Surely
19 you must have?
20 MS. MARSH: You mean from the end
21 of the campaign?
22 BY MR. KLAYMAN:
57
1 Q Your interaction with the Clinton
2 administration and its friends since then?
3 A Yeah.
4 Q And where is that kept?
5 A In Washington.
6 Q So everything would be in the
7 office up there on Capitol Hill?
8 A Mm-hmm.
9 Q Any other place where it might be
10 stored?
11 A I would have to ask Todd, you know,
12 I can't -- I mean, he would --
13 Q Todd's the guy that would know?
14 A Mm-hmm.
15 Q You previously were in business
16 with Paul Begala, correct?
17 A Yes, sir.
18 Q Did you ever have a partnership
19 agreement or anything in writing?
20 A I don't think that we ever -- I
21 think somebody drew one up, and I don't think
22 we ever signed it or anything like that. I
58
1 think we just kind of operated in a non --
2 Q Did you have an office?
3 A Yeah.
4 Q In Washington?
5 A Mm-hmm.
6 Q Or elsewhere?
7 A Just one in Washington.
8 Q Where was your office?
9 A 329 Maryland Avenue in Northeast.
10 Q And who leased that? Whose name
11 was on the lease?
12 A Me.
13 Q Just you?
14 A Yeah.
15 Q And you must have had file cabinets
16 in that office, correct?
17 A I guess I did. Yeah, I mean, I'm
18 sure.
19 Q How long did you have that office?
20 A From November of '88 -- I used to
21 live there -- well, actually, no, because it
22 was in the basement where I lived, and then I
59
1 moved upstairs, and I can't tell you -- I
2 can't remember when I moved upstairs. It was
3 all the same building.
4 Q Did Begala live there, too?
5 A No.
6 Q Anybody else?
7 A No.
8 Q And you had file cabinets there?
9 A I don't think we had file cabinets.
10 I think we had like some things like a
11 bookcase or something. I don't know that. I
12 really --
13 Q Now, did you take the paper that
14 you stored at that office and take it over to
15 your newer office?
16 A Yeah, we moved over here. I mean,
17 maybe they --
18 Q And when did you move?
19 A I think it was November of '97.
20 Q And then you took everything that
21 you had in files there?
22 A Yeah. Todd, yeah -- yeah.
60
1 Q Todd's the guy?
2 A Yeah.
3 Q Did Mr. Begala take any paper?
4 A He was gone when I moved. He was
5 in Texas.
6 Q Did he take any paper?
7 A Not that I know of.
8 Q Clearly Mr. Begala has collected
9 paper over the years about his involvement
10 with Governor Clinton and the campaign?
11 MS. MARSH: I don't know.
12 THE WITNESS: I don't know what
13 Mr. Begala's done or not done or took or not
14 took.
15 Q You sent him faxes over the years
16 when he was back in Texas, didn't you?
17 A I'm sure I did.
18 Q And you sent him letters sometimes?
19 A No.
20 Q And you sent faxes and other kinds
21 of written communications to other people
22 around town, don't you, from time to time?
61
1 A Sure, sometimes I do. Yeah.
2 Q You would have sent some faxes to
3 George Stephanopolous from time to time,
4 wouldn't you?
5 A It's possible but if it is it's not
6 very many. I mean, if there was a --
7 MS. MARSH: Can we get some more
8 water for the witness, please?
9 BY MR. KLAYMAN:
10 Q Want some more water?
11 A Yeah.
12 MR. KLAYMAN: Do you want a break
13 or --
14 MS. MARSH: No, let's keep going.
15 BY MR. KLAYMAN:
16 Q Have you brought any documents with
17 you today?
18 MS. MARSH: He's brought documents
19 but they're all covered by the objection.
20 MR. KLAYMAN: So you're not
21 producing any documents?
22 MS. MARSH: Not unless you have a
62
1 court order.
2 MR. KLAYMAN: Well, we will seek
3 one, Ms. Marsh.
4 MS. MARSH: I'm sure you will,
5 Mr. Klayman.
6 MR. KLAYMAN: And our position is
7 that no such objection was ever served, and
8 we will be seeking more than that.
9 MS. MARSH: No doubt you will.
10 BY MR. KLAYMAN:
11 Q What types of documents did you
12 bring here today? Just subject matter? What
13 do they relate to?
14 A To --
15 MS. MARSH: They relate to filegate
16 and to Judicial Watch.
17 BY MR. KLAYMAN:
18 Q What specifically with regard to
19 filegate?
20 A Well, I don't know --
21 MS. MARSH: Let me consult with him
22 for just a minute.
63
1 (Witness conferred with counsel)
2 MS. MARSH: He's willing to waive
3 the objection to that request, which I
4 believe on the subpoena was request number
5 36, and produce to you this file. And we
6 need this file back. So you can mark it and
7 make copies and have those attached to the
8 deposition transcript. That is the original
9 file.
10 MR. KLAYMAN: What documents do you
11 have with regard to Judicial Watch?
12 I'll ask that the court reporter
13 mark as Exhibit 9 the file that says
14 miscellaneous Gary Aldridge book, Filegate.
15 MS. PAXTON: Mr. Klayman, what's
16 Exhibit 8?
17 MR. KLAYMAN: Exhibit 8 is this
18 file folder. Exhibit 8 is the map of the
19 office on Capitol Hill. Filegate is number 9
20 and Judicial Watch is Number 10.
21 (Carville Deposition Exhibits
22 Nos. 8, 9 and 10 were marked for
64
1 identification.)
2 MR. KLAYMAN: I'm just going to
3 identify before we have a copy the documents
4 which are contained in Exhibit 9. I'll show
5 them to you, Mr. Carville. If you want, if
6 you can't see them, I'll have them handed
7 across the desk.
8 MS. MARSH: Do you want him just to
9 read the titles of them?
10 MR. KLAYMAN: That will be fine if
11 Mr. Fitton can be next to him just to make
12 sure we get everything.
13 BY MR. KLAYMAN:
14 Q I'd like each piece of paper to be
15 lettered A through whatever it comes out if
16 you could do that?
17 A There's a title page unlimited --
18 the Gary Aldridge book.
19 MR. KLAYMAN: Mark that 9A.
20 MS. MARSH: Don't you want the
21 court reporter to mark it?
22 MR. KLAYMAN: That's fine. He can
65
1 mark it with his initials next to it. He can
2 do it later. 9A with your initials, JC. And
3 you can date it. Date it.
4 MS. MARSH: This going to take
5 forever, Mr. Klayman.
6 MR. KLAYMAN: It will not take
7 forever. Unfortunately, very little paper
8 was produced.
9 THE WITNESS: What's the date
10 today?
11 MR. KLAYMAN: 16th.
12 BY MR. KLAYMAN:
13 Q Next page.
14 A Acknowledgments of the Gary
15 Aldridge book, which is 9B.
16 Q 9B with your initials and the date.
17 A "Gingrich pushes FBI file story."
18 Q 9C and the date.
19 A FBI files look what I found in
20 mine, an article by Linda Chavez, 9D, initial
21 and a date. "Three hundred more files."
22 Looks like an editorial from The Washington
66
1 Times, 9E.
2 MS. MARSH: Initials.
3 THE WITNESS: "White House agrees
4 to say hand over papers."
5 MS. MARSH: That's a 2-page
6 article. Do you want each page marked
7 separately?
8 MR. KLAYMAN: Yes.
9 THE WITNESS: 9F.
10 MS. MARSH: G.
11 THE WITNESS: G. All right.
12 Travel office --
13 MS. MARSH: Read the title.
14 THE WITNESS: "Travel office staff
15 targeted before firings." Looks like a
16 George Archibald story from the Washington
17 Times, 9H.
18 MS. MARSH: It's two pages. You
19 got to do each page.
20 THE WITNESS: I'm sorry. 9H still?
21 MS. MARSH: No, 9I. He wants each
22 separate.
67
1 THE WITNESS: Oh, okay. All right.
2 "Inside the Beltway" from Washington Times --
3 BY MR. KLAYMAN:
4 Q What's the date of that?
5 A I don't see a date on that.
6 Q What's the heading, first article
7 on the page?
8 A "Hoover File," "Family File,"
9 "Separated at Birth."
10 Q All right. That's fine. I just
11 want you to identify it. What are you
12 numbering now?
13 MS. MARSH: 9J.
14 BY MR. KLAYMAN:
15 Q 9-J.
16 MS. MARSH: Date.
17 THE WITNESS: All right.
18 MS. MARSH: The second page of it
19 you got to label K.
20 BY MR. KLAYMAN:
21 Q Second page is 9K, initials and
22 date. Next page?
68
1 A Is -- it's a continuation of --
2 Q 3-page --
3 A I guess it must be. 9K -- L?
4 Q 9L.
5 A This is "Inside Politics" again, 9
6 what, M? 9N.
7 MS. MARSH: Tell him what it's
8 called.
9 THE WITNESS: This is "Undercover
10 Operator" from The Washington Post, "In the
11 Loop."
12 BY MR. KLAYMAN:
13 Q 9N?
14 A Yes, 9N.
15 Q Next one?
16 A 9O, "Clinton liberal backers are
17 testy," Don Lambreau. This is pages of
18 statements of William Kennedy, Tony Coelho,
19 Lloyd M. Cutler, Dee Dee Myers, Janet V.
20 Green, statement of Ann S. Stock, White House
21 social secretary and statement of Bob
22 Lehrman.
69
1 Q Why don't you number each one of
2 those consecutively?
3 MS. MARSH: You're on P.
4 THE WITNESS: 9P.
5 MS. MARSH: Q.
6 THE WITNESS: 9Q, R, S, T, U, V.
7 BY MR. KLAYMAN:
8 Q Next?
9 A "White House improperly obtained
10 the FBI files of more than 600 people, new
11 documents show," W. 9X -- what's the date?
12 MS. MARSH: Sixteenth. Read the
13 title.
14 THE WITNESS: "Secret system
15 computerizes personal data." 9 -- this is
16 9-Y.
17 MS. MARSH: The last article is
18 three pages long.
19 THE WITNESS: Three pages long and
20 it's, "Secret system computerizes personal
21 data."
22 BY MR. KLAYMAN:
70
1 Q You've now numbered everything in
2 Exhibit 9, correct?
3 A Yes, sir.
4 Q With your initials, J.C?
5 A Yes, sir.
6 Q With the date?
7 A Yes, sir.
8 Q I show you what has been marked as
9 Exhibit 10 on the folder. This is the
10 Judicial Watch file. I'd like you to do the
11 same thing, identify each piece of paper and
12 just start 9A through whatever comes out.
13 MS. MARSH: Ten.
14 THE WITNESS: 10A, "Begala insists
15 he had no knowledge of FBI files misuse."
16 MR. KLAYMAN: You have a loose
17 article there. It hasn't been copied there.
18 MS. MARSH: Same thing.
19 BY MR. KLAYMAN:
20 Q Same thing as the copy that was
21 just made, 10A?
22 A Yeah, it's the same thing.
71
1 Q Make that 10B.
2 A All right. "Stephanopolous,
3 Begala, and Carville subpoenaed in filegate."
4 That would be 10C. And New Republic October
5 reprint of an article about Larry Klayman of
6 October 6, 1997, which is D.
7 Q While you're on that, Mr. Carville,
8 where did you get that?
9 A This?
10 Q The one you just marked about New
11 Republic.
12 A It was faxed to me by Dalit
13 Toledano, who used to work for me as a law
14 student at NYU law school.
15 Q Where does she work now?
16 A She's at law school.
17 Q At NYU?
18 A Yes.
19 Q How did she know to fax that to
20 you?
21 A When I got the thing, she has a
22 Lexis/Nexis, and I said see if you find
72
1 anything about a Klayman and fax it down to
2 me.
3 Q Was anything else faxed to you?
4 A No.
5 Q About Klayman or anyone else?
6 A My lawyer faxed it.
7 Q Is it a legal document that was
8 faxed or is it some other type of
9 documentation?
10 MS. MARSH: You can tell him what
11 it is.
12 THE WITNESS: Some court of appeal
13 decisions.
14 BY MR. KLAYMAN:
15 Q Which ones do you have?
16 MS. MARSH: He didn't bring them
17 here but I can tell you what they are.
18 There's one from the Court of International
19 Trade. There's one from the Second Circuit
20 and I think one from the Ninth Circuit, if I
21 recall correctly.
22 BY MR. KLAYMAN:
73
1 Q When were those faxed to you?
2 A I don't remember.
3 Q Recently?
4 A Yeah. Yeah.
5 Q About a week and a half ago?
6 A I don't know. I don't know.
7 Q Which lawyer faxed them to you?
8 Ms. Marsh?
9 A Yes.
10 Q And they were faxed within the last
11 two weeks, correct?
12 A Yeah.
13 Q And was anything else faxed to you
14 by Ms. Marsh about Larry Klayman or Judicial
15 Watch?
16 MS. MARSH: Anything that's not
17 privileged?
18 MR. KLAYMAN: He can respond.
19 THE WITNESS: No.
20 BY MR. KLAYMAN:
21 Q On this last document here that
22 you've marked --
74
1 A Where it says more to come?
2 Q 10D, it says, "For James and Kevin.
3 More on the way, Dalit." James, is that you?
4 A That's me.
5 MR. GAFFNEY: I'm going to make an
6 objection Mr. Klayman. You are questioning
7 the witness regarding exhibits and I don't
8 have a copy of them.
9 MR. KLAYMAN: We're going to make
10 them right now.
11 MR. GAFFNEY: I appreciate it if
12 you withhold your questions till after we
13 have the documents.
14 MR. KLAYMAN: We'll have a lot more
15 questions. We'll have six copies of each
16 made.
17 BY MR. KLAYMAN:
18 Q Mr. Carville, have you disseminated
19 those 9th and 2d Circuit opinions to anyone?
20 Have you given them to anyone that Ms. Marsh
21 sent to you?
22 A No, I don't think so.
75
1 Q Pretty recently, isn't it, that you
2 got them?
3 A Mm-hmm.
4 Q So who did you give them to? Who
5 did you send them to?
6 A I don't think I faxed them to
7 anybody.
8 MS. MARSH: He just said he didn't
9 sent them to anybody.
10 Q Did you mail them to anybody?
11 A No.
12 Q Did you have anybody hand them to
13 anybody?
14 A No.
15 Q Did you mention them to anybody?
16 A Yeah.
17 Q Who did you mention them to?
18 A I mentioned them to David Kendall.
19 Q In the last few weeks?
20 A Yeah.
21 Q Anyone else?
22 A Probably Bob Barnett, but I don't
76
1 know, and ���� to Mr. Begala.
2 Q Excuse me?
3 A To Mr. Begala.
4 Q And who else?
5 A Probably Mr. Emanuel, probably
6 Mr. Stephanopolous.
7 Q ���� Emanuel?
8 A Mm-hmm.
9 Q Mr. Stephanopolous?
10 A Mm-hmm.
11 Q Anyone else?
12 A Highly probable that I did but I
13 just can't think of anybody right now.
14 MS. MARSH: I can give you copies,
15 Mr. Klayman, that I have, and I can represent
16 to you and Mr. Carville can confirm that
17 these are exactly what he got from me of
18 these opinions, if you'd like to have them
19 marked.
20 MR. KLAYMAN: Let's mark them as
21 Exhibit 10.
22 MS. MARSH: Eleven.
77
1 MR. KLAYMAN: Eleven.
2 MS. MARSH: Do you want to mark
3 each one separately or altogether?
4 MR. KLAYMAN: Altogether. Let me
5 see them first, please. One is opinion Wire
6 Rope Importers' Association v. United States,
7 slip op 9486, May 26,1994. Another one is
8 Baldwin Hardware v. Franksu, 78 Fed. 3d. 550,
9 and the last one is United States Court of
10 Appeals for the Second Circuit, 1998 U.S.
11 Appeals Lexis 2595 printed in full format.
12 We'll ask that these be marked as Exhibit 11
13 and we'll staple them together and make
14 copies.
15 MS. MARSH: And I need those back,
16 please, as with the other exhibits.
17 (Carville Deposition Exhibit
18 No. 11 was marked for
19 identification.)
20 BY MR. KLAYMAN:
21 Q Mr. Carville, why did you mention
22 these opinions to Mr. Kendall, Mr. Barnett,
78
1 Mr. Begala, Mr. Stephanopolous, and everyone
2 else you've just named?
3 A Just thought they would be
4 interesting.
5 Q Your purpose was to have them
6 disseminated to the media and to others, was
7 it not?
8 A No, if I wanted to disseminate them
9 to the media I would have disseminated them
10 by the media.
11 Q You were told by one or more of
12 those individuals that they were going to
13 disseminate that information?
14 A No. They figured if I wanted to I
15 would. I don't know that they did or didn't,
16 you know, but they're public record.
17 Q Did you also provide information
18 about these decisions which are Exhibit 11 to
19 the Democratic National Committee.
20 MR. GAFFNEY: I'm going to object
21 once again, Mr. Klayman, to your questioning
22 of a witness without providing copies of an
79
1 exhibit.
2 MR. KLAYMAN: You were reading them
3 the other day.
4 MR. GAFFNEY: I don't care whether
5 I was reading them the other day or not. Are
6 you going to continue to question a witness
7 about exhibits that you haven't provided --
8 MR. KLAYMAN: I just identified
9 them you know what they are. I'll be happy
10 to give you a copy.
11 MR. GAFFNEY: I would appreciate it
12 if you withhold the questioning till you
13 provide me a copy.
14 MR. KLAYMAN: Do you want to see
15 them right now?
16 MR. GAFFNEY: Well, I'd like you to
17 provide the opportunity for the other counsel
18 to review them if you're going to be asking
19 questions.
20 BY MR. KLAYMAN:
21 Q Did you talk to Mr. Gaffney about
22 those decisions, Exhibit 11?
80
1 A No, sir.
2 Q Just Mr. Kendall?
3 A And maybe Mr. Barnett.
4 Q You are aware that Mr. Gaffney
5 works with Mr. Kendall and Mr. Barnett?
6 A I am.
7 Q Your purpose in letting these
8 people know about it so they could smear
9 Larry Klayman and Judicial Watch?
10 MS. MARSH: Objection.
11 THE WITNESS: No. My purpose was I
12 called Mr. Kendall and I said how common is
13 this kind of thing. He said it was very
14 rare, and I think there was a judge by the
15 name of Winter on the court of appeals that
16 used to teach him in law school. Mr. Kendall
17 told me that Judge Winter was a pretty
18 conservative guy, and he told that trial
19 judge atta boy, and he said it is not a very
20 common thing that a court of appeals would
21 write an opinion upholding sanctions from a
22 trial court.
81
1 BY MR. KLAYMAN:
2 Q Did Mr. Kendall tell you whether
3 that opinion was under court seal? In other
4 words --
5 MR. GAFFNEY: Objection. Assumes
6 facts not in evidence.
7 BY MR. KLAYMAN:
8 Q You can respond.
9 MR. GAFFNEY: As you know,
10 Mr. Klayman, that order is not under court
11 seal.
12 BY MR. KLAYMAN:
13 Q You can respond.
14 A He did not. I assume somebody got
15 it out of the Federal Reporter or whatever.
16 Q Did Mr. Kendall tell you that Larry
17 Klayman had sought to keep that opinion under
18 court seal until all the appeals were heard?
19 A He didn't.
20 Q Did he tell you that?
21 A No.
22 Q Did he tell you that in fact there
82
1 was an order entered in that case of last
2 year which sealed the files?
3 MS. MARSH: Is that the order
4 that's been vacated?
5 BY MR. KLAYMAN:
6 Q You can respond.
7 A No, he didn't tell me. I don't
8 know nothing about that.
9 Q Did he tell you that the matter is
10 subject for a petition for rehearing in front
11 of the same court?
12 A No, he did not.
13 Q Did he tell you the matter can be
14 appealed to the Supreme Court?
15 A He didn't have to tell me that. I
16 assumed that it could be. I can tell you
17 right now I hadn't practiced law in a long
18 time, and I called and said did the Supreme
19 Court accept it, but what the heck, what do I
20 know?
21 Q Did he tell you that the judge who
22 issued the sanctions, Denny Chin, that he was
83
1 an appointee of the Clinton administration?
2 A I can read the opinion and know
3 that.
4 Q Did Mr. Kendall tell you that?
5 A I don't remember but it would be
6 superfluous.
7 Q Did he tell you that the judge's
8 name was found in the files of John Huang?
9 A No. He did say that Winter was a
10 highly respected guy. I remember that.
11 Q I didn't ask you about Winter.
12 A I'm just telling you he told me.
13 You keep asking me things he didn't tell me.
14 I just thought I'd tell you something he told
15 me.
16 MR. GAFFNEY: Mr. Klayman I would
17 like to object to the extent and I can't tell
18 from your questioning that the order you are
19 referring to is simply the order from Judge
20 Chin and you're not suggesting that there was
21 an order prohibiting the dissemination of the
22 two other opinions which imposed sanctions on
84
1 you; am I correct in that?
2 MR. KLAYMAN: We'll deal with the
3 legal issues at a later date.
4 MR. GAFFNEY: I just want to be
5 clear.
6 MR. KLAYMAN: We'll deal with them
7 in court. That's where we'll deal with them.
8 BY MR. KLAYMAN:
9 Q You know John Huang, don't you?
10 A I don't think I do.
11 Q Did you ever meet him?
12 A If you ever ask me if I ever met
13 someone I'll tell you that I meet a lot of
14 people that I don't remember but if I had met
15 John Huang I would be surprised. I would say
16 that.
17 Q You know John Huang, don't you?
18 A Sure.
19 Q And you knew he was working at the
20 Commerce Department?
21 A I did.
22 Q And you knew that he moved over to
85
1 the DNC to handle campaign contributions?
2 A I did.
3 Q And you are aware that John Huang
4 was responsible for recommending Asian
5 American appointees in the Clinton
6 administration do you not?
7 A No, I don't know that.
8 Q You've seen reports, have you not,
9 in New York times and Los Angeles times
10 that --
11 A I don't recall that -- I mean, if
12 you told me they're there, I wouldn't be
13 surprised at all, but I don't recall reading
14 that and all that I know is about this Judge
15 Winter.
16 Q Well, you were close to the Clinton
17 administration, were you not, and you still
18 are, aren't you?
19 A I have friends over there but I
20 never knew John Huang.
21 Q And you have friends at the
22 Democratic national committee?
86
1 A Not very many.
2 Q But you have some?
3 A Boy, who's left over there? I'm
4 sure I do have some. I just don't know who's
5 over there any more.
6 Q And you are aware that John Huang
7 recommended Denny Chin to the bench, aren't
8 you?
9 A I'm not aware that.
10 Q Judge Denny Chin was recommended by
11 John Huang. You know that, don't you?
12 A I don't know that. The only thing
13 I know of is judge Winter's highly thought of
14 person according to Mr. Kendall, that he was
15 his law teacher so I don't know how this
16 judge got to be on a district court or who
17 recommended him or anything else.
18 Q Are you aware that there were
19 articles written in the Los Angeles Times and
20 New York Times that said John Huang decide
21 who would be appointed in the Asian American
22 community to judgeships and other things?
87
1 A I'm not aware of that. The only
2 thing Mr. Kendall told me was that Judge
3 Winter was considered to be a top-flight
4 jurist.
5 MS. GILES: I object to this whole
6 line of questioning has having no relevance
7 to the FBI files.
8 BY MR. KLAYMAN:
9 Q It does have relevance to documents
10 that were produced, and it does have
11 relevance and you know what that relevance
12 is?
13 A What is it? I'd just be curious to
14 know what a public opinion from the court has
15 got to do with the FBI files.
16 Q Maybe you'll learn someday. I'm
17 asking the questions.
18 A I understand.
19 Q You are aware that Larry Klayman
20 and Judicial Watch were the individuals and
21 groups that discovered John Huang in its case
22 against the Commerce Department?
88
1 A I am.
2 Q And you did see me on the news back
3 in October and November of 1997 when we took
4 the deposition of John Huang, did you not?
5 A I might have. I don't remember.
6 Q You've talked to me from time to
7 time with your wife Mary, haven't you?
8 A I think I did a show with you.
9 Q Right, around the time of John
10 Huang?
11 A You and I talked other than that
12 time on the show?
13 Q That wasn't my question.
14 A I recall doing -- I think it was a
15 Burden of Proof show that you were on and I
16 recall that you sent my wife a fruit basket
17 for the holidays.
18 Q And you agree I've been on your
19 show several times, correct?
20 A I haven't heard you but she said
21 that you've been on the show. I asked her
22 why did you send her --
89
1 Q She knows me, doesn't she?
2 A Yes. I mean, you sent us -- you
3 sent her -- I guess you didn't send me -- but
4 you sent her some kind of fruit basket for
5 the holidays. You don't go around sending
6 something to strangers.
7 Q Is that why you called me a little
8 twerp? You didn't get a fruit basket?
9 MS. MARSH: Objection. Not a real
10 question.
11 Q Still mad about that?
12 A I'm not mad about the fruit basket.
13 Q If I'd send it to you you wouldn't
14 have called me a little twerp?
15 A No, I ate it. We share things in
16 common.
17 MS. MARSH: Objection.
18 BY MR. KLAYMAN:
19 Q Mr. Carville, you are aware that
20 John Huang still remains under investigation,
21 are you not?
22 MS. MARSH: I'm going to put an
90
1 objection on the record to all questions
2 about John Huang.
3 BY MR. KLAYMAN:
4 Q You can respond.
5 A Let me just tell you something. I
6 don't know John Huang. I assume that he's
7 still under investigation. To the best of my
8 knowledge, I have never met John Huang. I
9 know I've never spoken to him on the phone or
10 had any communication with him whatsoever,
11 but, if you say he's still under
12 investigation, he's still under
13 investigation.
14 Q Now, assume the facts I told you
15 are true, that this judge's name was found in
16 the files of John Huang.
17 MS. MARSH: Which judge?
18 Q Judge Denny Chin?
19 A Based on what Mr. Kendall told me
20 that I have eminent respect for and that
21 three courts of appeal judges with the same
22 jurist like this to write that kind of
91
1 opinion, you ask me how I feel if one judge
2 wrote something, I guess that needs to be --
3 I did not read that to be a complimentary
4 opinion is what my opinion is.
5 Q You read that one to be
6 uncomplimentary, correct, the one about me?
7 A Yeah, I did.
8 Q And about my colleague
9 Mr. Orfanedes, correct?
10 A Yeah. I didn't pay attention --
11 Q But you didn't read the one that
12 was issued about you last Friday by Judge
13 Lamberth to be uncomplimentary, did you?
14 MS. MARSH: Objection. Asked and
15 answered.
16 BY MR. KLAYMAN:
17 Q That one was fine, right?
18 MS. MARSH: Objection. That's
19 argumentative.
20 BY MR. KLAYMAN:
21 Q Let's take the hypothetical,
22 Mr. Carville.
92
1 A No, let's don't take the
2 hypothetical.
3 Q You're going to have to answer the
4 question.
5 MS. MARSH: Maybe he is. Maybe he
6 isn't.
7 BY MR. KLAYMAN:
8 Q Let us assume that this judge's
9 name was found in the files of John Huang.
10 Let us assume that he was recommended for
11 appointment to the bench by John Huang and
12 the Clinton administration. Under those
13 circumstances, you're a lawyer, is there
14 anything wrong in asking the judge whether he
15 has some association with John Huang?
16 MS. MARSH: Wait. Let me put an
17 objection on the record before you answer.
18 James, let me put the objection on the record
19 first. Don't fight with me.
20 MR. KLAYMAN: He's a big boy.
21 MS. MARSH: He's a lawyer here and
22 I am I'm entitled to put an objection on the
93
1 record. I object to the question. I object
2 to the assumptions that it makes. I object
3 to you asking Mr. Carville as a lawyer. He's
4 not called as a lawyer today. He can answer
5 you as James Carville, but this question is
6 irrelevant and assumes facts not in evidence.
7 MR. GAFFNEY: I would also like to
8 object Mr. Klayman as representing a party to
9 this litigation. I object to relevance of
10 this question. I cannot see, moreover, it
11 leading to the admissibility of relevant
12 evidence as to what he thinks about the judge
13 who imposed these sanctions on you.
14 BY MR. KLAYMAN:
15 Q You can respond.
16 A I could tell you what the fact is.
17 The fact is that I think it was three judges
18 on the Court of Appeals for the 2d Circuit.
19 One of them that a highly respected attorney
20 told me was a highly respected judge. I have
21 no reason to doubt the other two are not
22 highly respected judge. Reviewed the record
94
1 in this case. I assume everybody had a
2 chance to submit everything and it was a
3 public document that my lawyer sent me and I
4 spoke to people about it, but my
5 understanding is that it -- let me see the
6 thing.
7 Can I see that thing a second?
8 Thank you. Hand it here. It's been a while
9 since I've been in law school. Is it the top
10 one? I assume that this is some kind of a
11 U.S. appellate Lex1s 2595 or something. I
12 assume it's some kind of public record. I
13 don't think anybody got it from anywhere
14 that -- Judge Winter, Judge Altimari, and
15 Cabranes, opinion by Winter. I assume that's
16 a public thing. I mean, I didn't know that I
17 was -- that there's anything nefarious about
18 me talking to people about this.
19 Q And in fact you talked to a lot of
20 people about it, correct?
21 A Well, not all of them were talked
22 to about it. I probably talked to some more
95
1 about it.
2 Q Who else?
3 A Again, I told you the ones I can
4 remember, but I'm sure I probably talked to
5 more people than I did.
6 Q Well, tell me who else.
7 A The ones I told are the ones I can
8 remember.
9 Q During that conversation with
10 Mr. Kendall did you ever ask whether anyone
11 at his law firm had ever been sanctioned?
12 A No, I didn't.
13 Q Did you ever do a check on that,
14 Nexis search?
15 MS. MARSH: Objection as to
16 relevance.
17 THE WITNESS: No, but if they were
18 deposing me I might.
19 Q Did you watch the O. J. Simpson
20 trial?
21 A Not very much.
22 MS. MARSH: Objection.
96
1 Q Remember how many times Marcia
2 Clark and Johnny Cochran and company were
3 sanctioned?
4 MS. MARSH: Objection.
5 THE WITNESS: Let me just say right
6 here this is an appeal from the 2d Circuit.
7 I don't know about Marcia Clark or anybody
8 else before three judges unanimously saying
9 we affirm, but if you do let me know. But,
10 again, if Johnny Cochran or Marcia Clark were
11 deposing me, and my lawyer sent me something
12 where they were sanctioned, I probably would
13 talk about it.
14 BY MR. KLAYMAN:
15 Q And in fact your practice has been
16 to take anything that you could find and
17 disseminate that about any perceived
18 adversaries of the Clinton administration,
19 correct?
20 MS. MARSH: Objection.
21 THE WITNESS: No.
22 Q In fact, what you master in,
97
1 Mr. Carville, is to spread anything you can
2 about adversaries of the Clinton
3 administration?
4 MS. MARSH: Objection.
5 Q That's part of what you do, right?
6 A First of all, what I "spread" here
7 was an appellate court decision. I mean, I
8 don't know what could be a more public thing
9 which you can Shepardize the thing, you know
10 what I mean? You can get the key number and
11 all that kind of stuff. It's all that kind
12 of -- this is not some little, you know,
13 secret document here.
14 Q Well, it's nice to know that you
15 still remember the fact that you're a lawyer.
16 That's good. That's good. We've established
17 that now, good.
18 A But, yeah, and what's this Baldwin
19 Hardware case?
20 Q I'll ask the questions and we will
21 get back to these documents, but let me ask
22 you now whether you've ever done these kinds
98
1 of Nexis searches on people like Ken Starr.
2 You ever do that?
3 A Sure. I mean, I haven't done it --
4 Q You've done them on judges, too,
5 haven't you?
6 A Well, Ken Starr was a judge.
7 Q Have you done one on the judge in
8 this case?
9 A No.
10 Q Have you done one on other judges?
11 MS. MARSH: A Nexis search?
12 THE WITNESS: I would doubt it but
13 if you can illuminate me.
14 BY MR. KLAYMAN:
15 Q You were involved, weren't you, in
16 setting strategy with the Democrats with
17 regard to Judge Bork's nomination?
18 MS. MARSH: Objection as to
19 relevance.
20 THE WITNESS: None.
21 Q Judge Clarence Thomas, you never
22 had any input?
99
1 MS. MARSH: Objection as to
2 relevance.
3 THE WITNESS: No -- wait a minute.
4 If I remember correctly, when Judge Thomas
5 was up for confirmation I was working for --
6 do you remember I was working for Senator
7 Wofford then, but I never did any -- I mean,
8 I wasn't -- I wasn't involved in that. No.
9 In fact, I've been to Justice Thomas' house.
10 Q This Judicial Watch file that we
11 just went over, which is Exhibit 11, was any
12 of the information in there disseminated to
13 any hosts on TV talk shows?
14 A No.
15 Q You don't know if anybody else did
16 that you informed about it, do you?
17 A I don't think I informed anybody.
18 Only thing is I faxed a copy of your press
19 release about our deposition to Mr. Begala.
20 Q You don't know what other people
21 did once you told them about this stuff, do
22 you?
100
1 A Do I know what other people did?
2 Q Did with the information.
3 A I didn't tell anybody -- excuse me,
4 I'm sorry. I didn't tell anybody anything
5 Judicial Watch that I know of other than
6 Mr. Begala.
7 Q I'm talking about these court
8 decisions that I've just shown you. You
9 don't know what other people did with them,
10 do you?
11 A No.
12 Q Now, let's get that exhibit back
13 and we'll make some copies. Did you discuss
14 these decisions with your wife?
15 A I'm sure I did. I assume I did.
16 Q Did you ever discuss these
17 decisions with Bob Bennett?
18 MS. MARSH: I think he said he did.
19 THE WITNESS: No. I said Barnett.
20 I don't think I discussed it with Bennett.
21 BY MR. KLAYMAN:
22 Q Tell me what else you said during