151
1 but I didn't have --
2 Q And she reported to you sometimes
3 about the problems with the various women,
4 correct?
5 A Not really --
6 MS. MARSH: Objection as to
7 relevance.
8 BY MR. KLAYMAN:
9 Q You can respond.
10 A I mean, she was very kind of tight-
11 lipped about that and whatever her role was
12 she I think enjoyed -- she did not talk to me
13 a lot about that.
14 Q Are you saying that throughout the
15 campaign you never were informed of the
16 efforts to research the pasts of the various
17 women who were alleged to have had affairs
18 with the President?
19 MS. MARSH: Objection. You're
20 assuming facts not yet in evidence.
21 THE WITNESS: I don't recall
22 anybody researching, "Jennifer Flowers'
152
1 past." Now, I could be -- I'm not saying it
2 didn't happen. I don't recall. I mean, it
3 was not a -- I mean --
4 BY MR. KLAYMAN:
5 Q During the war room, my having
6 taken a look at it yesterday evening, I saw
7 most sitting around the table working with
8 you --
9 A Who?
10 Q People I saw most sitting around
11 the table working with you in the war room
12 were you, George Stephanopolous, Paul Begala,
13 Mickey Cantor --
14 A No. No.
15 Q Harold Ickes?
16 A Harold Ickes was not --
17 Q And Rodney Slater were the people I
18 recognized?
19 A No.
20 Q And ���� Emanuel, correct?
21 A No. Harold Ickes was in the movie
22 one time and it was at a meeting at the
153
1 Democratic National Committee. He didn't
2 even work in Little Rock for the campaign.
3 Rodney Slater was on the road the entire
4 time. I don't even know if Rodney -- he may
5 have -- if he appeared in the movie The War
6 Room it was for a very brief period of time.
7 Paul was in there some. We were -- George
8 Stephanopolous, certainly, Stan Greensburg,
9 certainly. Mandy Grunwald, certainly. Those
10 were the people that I was around most.
11 I might add one thing about the war
12 room is those people had complete access, and
13 they were able to film anything they wanted,
14 and we didn't take one thing out of the
15 movie. But Rodney -- I would be surprised --
16 I mean, I'd have to look at it. It would be
17 hard for me to be definitive but I doubt if
18 Rodney was in that movie very much.
19 As I recall, it was one scene that
20 was screamingly funny with Harold and I guess
21 Bob ���� or somebody arguing what kind of
22 placards they were going to have at the
154
1 convention. George was in there all the
2 time. He and I would talk 25 times a day.
3 I'm trying to answer your question.
4 Q You worked closely with Begala,
5 Stephanopolous, Grunwald, Greenberg, et
6 cetera?
7 A Yes, I did.
8 MS. MARSH: You said "et cetera."
9 BY MR. KLAYMAN:
10 Q Remove the "et cetera." What was
11 the purpose of the war room?
12 A The purpose of the war room was
13 that -- it was twofold. We thought that --
14 one of the things was said on Democrats in
15 '92 is that the Bush campaign hit Dukakis
16 early and often and they didn't respond. The
17 philosophy of the war room is there are
18 concentrated news cycles and that campaigns
19 have to realize -- we used to have a sign
20 there called "Speed Kills - Bush." It was a
21 way of saying that in a news cycle you have
22 to be out and basically it is my theory that
155
1 a presidential campaign essentially occurs
2 between 9 and 3 Eastern, and we wanted to
3 gear up for that.
4 So what we did is we set up a
5 24-hour operation where people would get all
6 of the clips from around the country. People
7 would fax in all of the newspaper stuff.
8 They would call out to the field to see what
9 was going on. We had people checking --
10 every morning at 7 o'clock we would have a
11 meeting of which there must have been 75-100
12 people in to try to set the course of the
13 day.
14 And the other philosophy behind the
15 war room was is that these vertical campaign
16 structures were antiquated in that what we
17 needed was a way to react more quickly and to
18 be able to -- to be able to sort of get
19 inside the news cycle and I think a lot of it
20 was -- you know, a lot of it was sort of
21 predicated on what we thought that Bush was a
22 lot quicker and sort of pounded Dukakis and
156
1 they didn't respond quickly enough and that
2 we were going to be very quick and very
3 responsive and we were going to, you know,
4 try to stick with a sort of strategy and try
5 to implement it. You know, try to be faster
6 and simpler, I guess, was the whole
7 philosophy behind this.
8 Q The purpose of --
9 MS. GILES: I object to this whole
10 line of questioning about the war room on
11 grounds of relevance.
12 MR. GAFFNEY: I join the objection.
13 MS. MARSH: I do, too.
14 BY MR. KLAYMAN:
15 Q The purpose of the war room was to
16 be able to respond quickly to dirt that was
17 thrown at you by the Bush campaign?
18 A No. The purpose of the war room
19 was to be able to respond quickly to whatever
20 the Bush campaign through at us and it was he
21 raised taxes a hundred and whatever or the
22 environment in Arkansas was full of chicken
157
1 do-do from somewhere else or whatever. I
2 mean, I don't know -- I mean, in a
3 presidential campaign, a gubernatorial
4 campaign, most of the charges -- one of the
5 things we were proud of we said we're just
6 going to do this. We're going to have
7 somebody get a copy of Bush's announcement
8 speech and we're going to dissect it into
9 teams and be able to respond to his speech
10 before he finishes giving it. Okay? That's
11 the kind of stuff that we did.
12 There were film makers there to
13 record what we did, and in the whole --
14 again, I go back to the central philosophy of
15 it. The whole thing was to be able to
16 respond and act quickly because we thought
17 that news cycles are very compressed in
18 modern American politics and I am also a big
19 believer that's important that you get in
20 with the first take. If you let things
21 fester, if you don't respond to them, that
22 they tend to more likely infective.
158
1 Q Mr. Carville, I see that this
2 camera's trained on me. Am I understood that
3 you wanted the video camera to film the
4 deposition?
5 MS. MARSH: I'm bringing in a
6 camera to film the proceedings.
7 MR. KLAYMAN: Are you filming my
8 notes?
9 MS. MARSH: I don't think so.
10 MR. KLAYMAN: This was not the
11 understanding I have. My understanding was
12 to bring in a court reporter to film the
13 deponent.
14 MS. MARSH: Why don't you get on
15 with the deposition?
16 MR. KLAYMAN: I object to this
17 because I have notes out here as well as work
18 product.
19 MS. MARSH: I have absolutely no
20 interest in your notes, believe me.
21 MR. KLAYMAN: This is an improper
22 procedure, Ms. Marsh.
159
1 MS. MARSH: Call the court,
2 Mr. Klayman, or go on with the deposition.
3 MR. KLAYMAN: I will call the
4 court. We'll take an adjournment.
5 MR. GAFFNEY: While we're on the
6 record, if you're going to call the court, I
7 assume that that counsel to the other parties
8 will be on the phone call.
9 MR. KLAYMAN: That's fine unless
10 you cease filming me.
11 MS. MARSH: Are you filming his
12 notes? He's not filming your notes,
13 Mr. Klaman.
14 MR. KLAYMAN: This is still
15 improper because I'm not being deposed.
16 MS. MARSH: You're asking the
17 questions. He's filming the proceedings.
18 MR. KLAYMAN: I don't think it's
19 proper to have a camera sitting over me when
20 I'm looking at notes and conferring with
21 counsel.
22 MS. MARSH: He's not filming your
160
1 notes Mr. Klayman. He just said that.
2 MR. KLAYMAN: I find it
3 inappropriate.
4 MS. MARSH: Either go on with the
5 deposition or call the court. We want to get
6 on with this deposition. Mr. Carville has a
7 plane to catch. You know that.
8 MR. KLAYMAN: We're going to call
9 the court.
10 MS. MARSH: It's not improper to
11 film the person asking the questions at the
12 deposition.
13 MR. KLAYMAN: We'll raise it with
14 the court.
15 MS. MARSH: Raise it right here so
16 we can all hear the call and on the record,
17 please.
18 MR. KLAYMAN: I'm going off the
19 record to call the court.
20 MS. MARSH: I don't want it off the
21 record. I want the conversation with the
22 court on the record.
161
1 MR. KLAYMAN: Let the record
2 reflect that we're breaking at 12:40. We've
3 been going now for two hours and 20 minutes.
4 VIDEOGRAPHER: We're going off
5 video record at 12:40.
6 MS. MARSH: Can we stay on the
7 stenographic record, please? I want to stay
8 in here so it can be on the record.
9 MR. GAFFNEY: Why don't we bring
10 the stenographer with us?
11 (Recess)
12 MR. KLAYMAN: This is Larry
13 Klayman. I just realized we were in the
14 course of the deposition. We got a notice
15 last Friday from Ms. Marsh on behalf of
16 Mr. Carville that they wanted to bring their
17 own videographer to the deposition which we
18 had no objection to their doing, but it
19 wasn't until just a few moments ago that I
20 realized that that videographer had his
21 camera trained on me and in fact I had my
22 notes out in front of me. It's my belief
162
1 that that's been trained on me from the start
2 but I didn't see it because I was occupied
3 trying to do the testimony.
4 MR. GAFFNEY: For the record,
5 Larry, the camera did pan from time to time.
6 MS. MARSH: Also for the record the
7 videographer has stated that he did not have
8 his video camera trained at any time on
9 Mr. Klayman's notes.
10 MR. KLAYMAN: I doubt that
11 seriously because they are right out in front
12 of me and I'm sitting there. This is my
13 concern. We'd like to address it with the
14 court. It's not in our view a proper use of
15 the Rules of Federal Procedure to be able to
16 bring a video camera into a deposition to
17 film the person who's asking the questions
18 and that's as a legal matter but as a
19 practical matter.
20 I did have notes out there. I was
21 discussing things in terms of work product
22 with other counsel, and if this is what they
163
1 intended to do, they certainly should have
2 given notice to us. It's inappropriate and I
3 just happened to notice it when I looked
4 around. So we'd like to discuss it, if
5 possible, with the judge when he comes back
6 from lunch.
7 MS. MARSH: Just so you have our
8 view on that, there is nothing improper about
9 having a videographer here to record the
10 proceedings. Part of the proceedings are
11 Mr. Klayman's questions which are not
12 recorded on the record of the deposition
13 because Mr. Klayman's videographer never
14 turns to Mr. Klayman. There is no intention
15 to film Mr. Klayman's notes. I have
16 absolutely no interest in Mr. Klayman's notes
17 and this is certainly much more valid use of
18 a video than to take it and play it on
19 Geraldo.
20 CLERK: Almost certainly he won't
21 entertain anything over the phone and if the
22 parties wish to come to court that will
164
1 probably be what he requests that they do.
2 MR. KLAYMAN: I ask that it not be
3 trained on us during the deposition. I don't
4 know whether the notes are being taken or
5 not. We do have a videographer here. I have
6 been identified on the record. So I would
7 ask counsel to agree on that.
8 MS. MARSH: I will agree that the
9 videographer will not video any of his notes,
10 but I will not agree that the videographer
11 will not put the video camera on him. That
12 is part of the proceedings.
13 MR. KLAYMAN: I would ask then that
14 the video not be released until we can
15 confirm that there's no photographing of our
16 notes.
17 MS. MARSH: You have the
18 videographer's word on that.
19 MR. KLAYMAN: I'm afraid I can't
20 take that.
21 MS. MARSH: I would agree to do
22 that if Mr. Klayman will agree not to release
165
1 Mr. Carville's testimony to any other media
2 outlet until we have resolved this question.
3 CLERK: The only thing that I can
4 suggest is that when the judge comes back if
5 you leave me a phone number I can call you
6 all back, and again I can say nearly with 100
7 percent certainty that if this is -- if you
8 feel the need to address the judge, it's
9 going to be in court and not over the phone.
10 MR. KLAYMAN: We don't want to take
11 up the time because we want to finish the
12 deposition but I am putting the other side on
13 notice not to photograph and I do take issue
14 if they have photographed our notes. So we
15 will continue. We're not requesting a
16 hearing at this time but I'm putting
17 everybody on notice.
18 MS. MARSH: Just so I can let you
19 know I'm putting you on notice that the
20 videographer has not videotaped any of the
21 knows. We have no interest in those notes.
22 Thank you.
166
1 VIDEOGRAPHER: We're back on video
2 record at 12:51.
3 BY MR. KLAYMAN:
4 Q Now that I know I'm being filmed,
5 maybe I need to comb my hair.
6 A Could I borrow it?
7 MS. MARSH: Just proceed with the
8 deposition.
9 MR. KLAYMAN: I do proceed under
10 protest as I said with the court but I want
11 to move this thing along, and I do ask that
12 my notes or discussions with counsel not be
13 filmed or recorded.
14 MS. MARSH: As I told you, that was
15 never our intent.
16 MR. KLAYMAN: Respectfully, Ms.
17 Marsh, I don't accept that.
18 MS. MARSH: I don't need the
19 comments, Mr. Klayman. Let's proceed.
20 BY MR. KLAYMAN:
21 Q Before I realized that I was being
22 filmed, Mr. Carville, I had asked you about
167
1 the war room, and I believe that what you
2 advised me was the war room was a quick
3 action type course, correct?
4 A That was one of the things that I
5 said.
6 Q And one of the things that the war
7 room had to be able to do was to be able to
8 respond to negative information as being put
9 out by the other campaign, correct?
10 A We did.
11 Q And to do that, you had to know
12 exactly what negative information was out
13 there, correct?
14 A Well, we --
15 Q Calls for yes or no.
16 MS. MARSH: If he can.
17 THE WITNESS: If you can ask a
18 question, I can answer it. I'll let you ask
19 the question. I'm trying to give you as
20 accurate an answer as I can.
21 What we tried to do was to have in
22 force a way to respond when we were attacked.
168
1 If you give me a specific attack, I could
2 tell you how we responded to a specific
3 attack, to the best of my memory in the war
4 room.
5 Q Well, I'm just talking generally.
6 A Well, I guess -- one of the things
7 is -- one of the things that stands out it
8 was 124 tax increases and then --
9 Q I don't want a discourse on tax
10 increases, so let me just reask the question
11 and when we resumed we had gone 220 minutes
12 into this deposition. I'm just asking this
13 simple question: To know how to respond you
14 have to know what the other side's saying
15 about you? Yes or no as a general rule?
16 MS. MARSH: He'll answer it yes or
17 no if he can.
18 THE WITNESS: Again, Mr. Klayman
19 what I'm trying to do is help illuminate you
20 here, and it depends on -- we tried to
21 anticipate what people would say and, you
22 know, the best we could we tried to have a
169
1 way to respond to it because, again, we
2 saw -- I think I will -- our searing memory
3 is we saw what happened to Dukakis in '88.
4 BY MR. KLAYMAN:
5 Q And to be able to respond you have
6 to do research about some of the individuals
7 who were saying negative things about the
8 campaign, correct?
9 MS. MARSH: Some research about
10 what? The individual or about what they were
11 saying?
12 BY MR. KLAYMAN:
13 Q About the individual. Isn't that
14 part of it?
15 A Certainly we did exhaustive
16 research on President Bush. We did
17 exhaustive research on Vice President Quale.
18 We did -- I remember -- I don't know why but
19 I have -- well, if I don't remember it, I'll
20 not say it.
21 Q In effect you have to have arrows
22 in your quiver, correct?
170
1 MS. MARSH: Objection.
2 THE WITNESS: You have to be
3 able -- I would rather characterize it as
4 this. You have to have -- you try to know as
5 much as you possibly can about your
6 opponent's record.
7 Q And about people that your
8 opponents are using to try to harm your
9 campaign, correct?
10 A Yeah -- really, not so much of
11 that. If you give me -- you know, if you
12 have some examples, I'd be glad to respond to
13 sort of a specific person that you feel like
14 was wronged, and I'll be -- you know. But I
15 don't remember that -- you know, we had
16 research on Bob ���� or something like that.
17 Q During the campaign, did you ever
18 talk to Governor Clinton or Mrs. Clinton
19 about some of the allegations that were being
20 lodged against them?
21 A Yes.
22 Q And you talked to them frequently
171
1 about that?
2 A More -- it was more concentrated in
3 February or January, either late January or
4 February around the Jennifer Flowers thing
5 and it was pretty concentrated around -- I
6 mean, that was -- what other kind of -- I
7 mean, we talked to them also about -- you
8 know, we have a debate. If he says this, you
9 say that kind of thing, too -- but sure.
10 Q And you talked to them about the
11 research that Betsy Wright was doing?
12 A I didn't. You know, I mean, the
13 best -- I mean, I just wasn't -- that wasn't
14 sort of my deal. Betsy Wright -- the part of
15 Betsy Wright's thing that I was involved in
16 was the sort of Arkansas record stuff.
17 Q What's the Arkansas record stuff?
18 A What he did -- his record as
19 Governor of Arkansas. She kept -- and there
20 was a woman that worked for her by the name
21 of Dianne Blair who was involved in that, and
22 I was very -- I actually worked with Dianne
172
1 Blair way more than I worked with Betsy. If
2 the truth be known, Betsy and I were not
3 particularly close.
4 Q So is what you're saying that you
5 never discussed with the president or first
6 lady --
7 A I don't know. I can't tell you.
8 Q Or both the issues of sexual
9 infidelity?
10 MS. MARSH: Objection as to
11 relevance.
12 THE WITNESS: I can't testify to
13 conversations that Betsy Wright had with then
14 Governor Clinton or the then Mrs. Clinton.
15 BY MR. KLAYMAN:
16 Q I'm asking about you. Did you ever
17 have conversations about that?
18 MS. MARSH: Objection as to
19 relevance.
20 MR. GAFFNEY: I object on relevance
21 grounds as well.
22 BY MR. KLAYMAN:
173
1 Q You can respond.
2 A Certainly, I had conversations. As
3 I remember, Mr. Klayman, it's in my book.
4 I'd be glad if you got it. I could submit
5 the pages. When the charge came I was with
6 the governor in Georgia now in Arkansas, and
7 they went out to do it. I took the phone
8 call, waited by to tell Mrs. Clinton that
9 these charges would come forward.
10 Q And you discussed them with her?
11 MS. MARSH: Objection as to
12 relevance.
13 BY MR. KLAYMAN:
14 Q Yes or no?
15 A If I told her, I discussed it.
16 It's in my book.
17 Q With the President and Mrs.
18 Clinton?
19 MS. MARSH: Objection as to
20 relevance. Asked and answered.
21 BY MR. KLAYMAN:
22 Q You can answer.
174
1 A Of course, I did.
2 Q And you discussed gathering
3 research about these so-called women, did you
4 not?
5 A No, I did not.
6 MS. MARSH: Objection. Asked and
7 answered and also as to relevance.
8 BY MR. KLAYMAN:
9 Q And in fact you discussed hiring
10 private investigators to dig up dirt on these
11 women, didn't you?
12 MS. MARSH: Objection as to
13 relevance. Asked and answered.
14 BY MR. KLAYMAN:
15 Q You can respond. With the
16 President and First Lady?
17 A Mr. Klayman, I have never discussed
18 hiring a private investigator with the
19 President and First Lady or anyone else in
20 the campaign. Let me be clear. Never
21 discussed hiring any private investigator
22 with the President or First Lady or anyone
175
1 else.
2 Q During the campaign?
3 A The first I heard was a news
4 account -- I don't even know if it came in
5 the campaign or after the campaign that Betsy
6 had hired some guy from San Francisco.
7 Q Paladino, Jack Paladino?
8 A That sounds like the name.
9 Q Ever meet Jack Paladino?
10 A I never met Jack Paladino.
11 Q Ever talk to him?
12 A With the caveat that I get, that if
13 somebody's has a picture of me shaking hands
14 at a fund raiser, I never met Jack Paladino.
15 Q There is a picture in existence
16 where you're shaking hands?
17 MS. MARSH: Objection. That's not
18 what he said.
19 THE WITNESS: That's not what I
20 said. That's not what I said. I meet a lot
21 of people over the course in the last five or
22 six years. I've never received -- I never
176
1 called him. I never talked to him on the
2 phone or discussed anything with him.
3 Q You ever meet anyone by the name of
4 Terry Lenzner?
5 A I do not know Terry Lenzner.
6 Again, he's a guy from what I read has been
7 involved in Democratic politics in
8 Washington. If I met him, I don't have
9 any -- I have absolutely no recollection of
10 doing so. I think that I can safely say,
11 unless someone is, that I don't even know a
12 private investigator.
13 Q Have you ever talked with anyone
14 about Mr. Lenzner?
15 A Well, yeah.
16 MS. MARSH: Objection.
17 BY MR. KLAYMAN:
18 Q When did you talk to somebody about
19 him?
20 A When something came in the paper --
21 it was a big old brouhaha in the paper.
22 Q Who did you talk to?
177
1 MS. MARSH: Objection to relevance
2 to all questions regarding Mr. Lenzner.
3 THE WITNESS: I must have had six,
4 seven reporters call me. It was a topic of
5 conversation.
6 BY MR. KLAYMAN:
7 Q You've discussed with people in The
8 White House, haven't you, Mr. Lenzner?
9 MS. MARSH: Objection as to
10 relevance. He's not Mr. Lenzner.
11 MR. KLAYMAN: You don't have to
12 make relevance objections. They're
13 preserved.
14 MR. GAFFNEY: I have a standing
15 relevance objection.
16 BY MR. KLAYMAN:
17 Q Who did you discuss it with in The
18 White House?
19 A I would be -- I would assume I
20 discussed it with Mr. Begala or Mr. Emanuel,
21 for sure.
22 Q Did you discuss Mr. Paladino with
178
1 Mr. Begala and Mr. Emanuel?
2 MS. MARSH: Objection.
3 THE WITNESS: I mean, I could have,
4 but other than to say that I -- you know,
5 maybe when the story came out, who is this
6 guy? I don't know who he is. And there was
7 another --
8 BY MR. KLAYMAN:
9 Q Go on.
10 A I remember that there was a guy
11 that did some tests on the Jennifer Flowers
12 tape called ���� who I never met and he was
13 hired by ABC or something out in Los Angeles.
14 Q Did you ever talk to him?
15 A No.
16 Q Ever receive any correspondence
17 from Lenzner, ����, or Paladino?
18 A No. I thought that Paladino -- I
19 thought Paladino and ���� were the same sort
20 of person. I didn't realize until sometime
21 that they were different people.
22 Q And you discussed all of these
179
1 various private investigators with Begala and
2 Emanuel?
3 MS. MARSH: Objection as to these
4 various private investigators.
5 THE WITNESS: I know Mr. Lenzner
6 but the other two I don't know but I know I
7 talked about Mr. Lenzner because everybody
8 in Washington was talking about him.
9 BY MR. KLAYMAN:
10 Q And you discussed it with
11 Mr. Kendall, haven't you?
12 MS. MARSH: "It" being Mr. Lenzner?
13 BY MR. KLAYMAN:
14 Q Mr. Lenzner?
15 MS. MARSH: Objection as to
16 relevance.
17 THE WITNESS: I doubt it. I could
18 have but I doubt it.
19 MS. MARSH: Just tell him what you
20 did or didn't do.
21 BY MR. KLAYMAN:
22 Q You discussed Mr. Lenzner,
180
1 Mr. Paladino or Mr. ���� with Mr. Bob
2 Bennett?
3 MS. MARSH: Objection as to
4 relevance.
5 THE WITNESS: I think I discussed
6 it with Mr. Bennett, yes.
7 BY MR. KLAYMAN:
8 Q When did you discuss it with
9 Mr. Bennett?
10 A I don't know.
11 Q Did you call Mr. Bennett or did he
12 call you or was it in person?
13 A My guess is I called him and said
14 the press is asking me something, and he
15 said, look, best I can remember said he was
16 interviewing -- you know, wasn't tracking
17 down -- you know what I mean? In every big
18 law case you have this. That's the best I
19 can remember.
20 Q He told you he had retained
21 Mr. ����, Mr. Lenzner or --
22 A No. He never said -- the only
181
1 conversation I think I had was about
2 Mr. Lenzner, if I remember. I never brought
3 up --
4 Q What did you say to Bennett?
5 A I said what is this stuff I read in
6 the paper.
7 Q And Mr. Bennett confirmed that he
8 had hired Mr. Lenzner?
9 MS. MARSH: Objection.
10 THE WITNESS: I think what he said
11 was in every big piece of litigation law
12 firms typically hire investigators to -- and
13 I said all right and I'd get a press call I'd
14 say it was a -- my answer was I've been
15 assured this is a sort of routine thing.
16 Q And Mr. Bennett confirmed that he
17 had hired Lenzner?
18 MS. MARSH: Objection. Asked and
19 answered.
20 THE WITNESS: I think he just said
21 he didn't -- best I can remember it was a
22 confirmation as a routine thing.
182
1 BY MR. KLAYMAN:
2 Q Based on your testimony before you
3 had never hired a private investigator on a
4 campaign, had you?
5 A I don't even know one.
6 Q And you hadn't hired one in terms
7 of your consultancy with the Clinton
8 administration, had you?
9 A No, sir.
10 Q So, from your perspective it wasn't
11 a routine thing?
12 MS. MARSH: Objection.
13 THE WITNESS: Let the record show
14 that as bad a lawyer as bad a student as I am
15 there's a difference between a lawsuit and a
16 political campaign. You know? You know,
17 one's an apple. One's an orange.
18 MR. KLAYMAN: I show you what I'll
19 ask the court reporter to mark as Exhibit 13.
20 (Carville Deposition Exhibit
21 No. 13 was marked for
22 identification.)
183
1 BY MR. KLAYMAN:
2 Q Have you ever seen Exhibit 13
3 before?
4 MS. MARSH: Give him a chance to
5 look at it, please.
6 THE WITNESS: Oh, yes.
7 BY MR. KLAYMAN:
8 Q Is that a response? When did you
9 see it?
10 A I don't remember.
11 Q Around the time it was written,
12 February 24?
13 MS. MARSH: Objection. We don't
14 know if that's when it was written or not.
15 MR. KLAYMAN: That's the date on
16 the top.
17 THE WITNESS: You know, I say I saw
18 it. I mean, I don't remember seeing it, but
19 it certainly is possible that I did.
20 BY MR. KLAYMAN:
21 Q Where did you see it?
22 A I don't remember it so I can't tell
184
1 you if I don't remember it but when I called
2 this was probably read to me.
3 Q Mr. Bennett read it to you?
4 A No. It was probably Mr. Emanuel,
5 but I don't know. I mean, I just don't know,
6 Mr. Klayman, but I'm not -- the information
7 contained herein was information that was
8 known to me because when I read this I asked
9 about it.
10 Q So you called Mr. Emanuel about the
11 reports that the Clinton lawyers had hired
12 private investigators?
13 MS. MARSH: Objection as to
14 relevance.
15 THE WITNESS: I don't know who
16 called who.
17 BY MR. KLAYMAN:
18 Q But you talked to Mr. Emanuel?
19 A I'm sure I did.
20 Q Did you talk to him more than once
21 about this?
22 MS. MARSH: About this press
185
1 release?
2 BY MR. KLAYMAN:
3 Q About the issue of hiring private
4 investigators?
5 A I don't know how many times I
6 talked to him. Could have been once, could
7 have been three times.
8 Q Tell me what was discussed. Tell
9 me everything you remember.
10 MS. MARSH: Don't guess.
11 THE WITNESS: Best I can remember
12 is somebody better get a statement out about
13 this because it's -- you know, and explain
14 what happened. That's best I can remember
15 which he agreed.
16 BY MR. KLAYMAN:
17 Q Because it looks bad, right?
18 MS. MARSH: Objection.
19 THE WITNESS: I don't think it --
20 you know, I think if it comes out -- from
21 what I am told that in the practice of law,
22 hiring investigators are common in large
186
1 civil or criminal cases, and if that was the
2 fact, then my opinion was -- is that they
3 needed to get that out there, but the person
4 to -- I would say someone who was getting --
5 you have to understand the position I was in.
6 I was getting press calls about
7 this and I just needed to sort of answer what
8 people were saying to me and once I was told
9 what happened I could say, well, this is in
10 the normal course of large civil and criminal
11 cases that investigators are hired. That was
12 my entire --
13 BY MR. KLAYMAN:
14 Q Then why bother to get a press
15 release if it's so routine?
16 MS. MARSH: Objection.
17 THE WITNESS: I don't know if I got
18 it. Someone called me. I wanted something
19 official. Don't take my word. I wasn't the
20 person that hired them. They needed to be --
21 statement from the lawyers. I mean, the
22 press wasn't interested in me. They knew I
187
1 didn't hire him.
2 BY MR. KLAYMAN:
3 Q Begala, you talked to him about
4 these investigators, too, didn't you?
5 MS. MARSH: Which investigators?
6 MR. KLAYMAN: Any of them.
7 MS. MARSH: Mr. Klayman, you have
8 to make the questions clear so that he can
9 answer them and fair to him. I want to know
10 which investigators you mean.
11 BY MR. KLAYMAN:
12 Q Any of them.
13 A I think I asked Mr. Begala would I
14 have any reason to know Mr. Lenzner, and he
15 said he didn't know him and didn't think I
16 would, either, and there was another -- you
17 know, Mr. Klayman, like I said, somehow I
18 know it seems like a year ago but it wasn't
19 that long ago that this -- it was a story for
20 a couple or three days.
21 Q And you were concerned about it,
22 correct?
188
1 MS. MARSH: Objection as to
2 relevance.
3 THE WITNESS: Yes.
4 BY MR. KLAYMAN:
5 Q Why were you concerned about it?
6 MS. MARSH: Objection.
7 THE WITNESS: Because I thought
8 that we needed to get out and say what
9 exactly -- what the facts were, and I think
10 once we did it was okay but I think that
11 there was some -- any time you're always
12 concerned about sort of misunderstanding that
13 we were -- there was some -- that they were,
14 like, tracking -- doing something that you
15 would find not in the normal scope of a
16 lawsuit, and I was assured that they were
17 not, but I have no idea.
18 BY MR. KLAYMAN:
19 Q You were concerned because the
20 implication is that these investigators were
21 hired to ruin people's lives, correct?
22 MS. MARSH: Objection.
189
1 THE WITNESS: No. No. I was
2 concerned that it would be portrayed the
3 wrong way if we didn't get out and tell
4 people what the facts were, and we did.
5 BY MR. KLAYMAN:
6 Q Now you've accused Kenneth Starr of
7 conducting a gestapo-like investigation?
8 A I don't think I said gestapo.
9 Q You accused him of conducting a
10 KGB-type operation?
11 MS. MARSH: Objection as to
12 relevance.
13 THE WITNESS: I don't know --
14 BY MR. KLAYMAN:
15 Q You've been critical of Mr. star,
16 have you not?
17 A I have, repeatedly.
18 MS. MARSH: I want to put a
19 continuing objection on the record as to any
20 questions regarding Kenneth Starr or his
21 investigators.
22 MS. GILES: I join in that
190
1 objection. It's now after 1 o'clock. Are we
2 going to get any questions relating to the
3 FBI files matter or the Alexander litigation?
4 MR. KLAYMAN: Ms. Giles, your
5 position has been clear from the start that
6 there's nothing I could ask that's relevant,
7 so why don't you just stay posted?
8 MS. GILES: Objection to your
9 characterization of my objections.
10 MR. PIFER: I join in these
11 objections, Mr. Klayman, but my understanding
12 is that I don't need to do that? I have a
13 continuing joinder of any other relevance
14 objection.
15 MR. KLAYMAN: You can join
16 anybody's objection. I don't care.
17 BY MR. KLAYMAN:
18 Q Mr. Carville, you've been critical
19 of Starr, have you not?
20 A Repeatedly.
21 Q And you've said that he's abusing
22 his power as a prosecutor?
191
1 A I have.
2 Q That he's improperly looking into
3 the private lives of people in the Clinton
4 administration, including the President,
5 correct?
6 A I don't know if I used the word
7 "improper." I may have. I can't --
8 Q Probably an understatement, right?
9 A If you give me a quote that I
10 give --
11 Q I'm just trying to characterize it.
12 A Yes, I am not a fan of Mr. Starr's.
13 Q You even make fun of his religion?
14 A No, I did not.
15 Q You made fun of him praying on the
16 banks of the Potomac to rid the town of all
17 fornicators?
18 A Were you at the ���� breakfast? I
19 was and I said that and John Harris of The
20 Washington Post said are you mocking Mr.
21 Starr's religion, and I said no, I was
22 mocking his self-piety.
192
1 Q It's your practice to make fun of
2 people's religion?
3 MS. MARSH: Objection.
4 THE WITNESS: No, I thought it was
5 self-piety. That was my point, and I do
6 think that people's spending this money
7 investigating people's private lives is not
8 the course of action you ought to take and
9 I've been very forceful speaking out against
10 it.
11 BY MR. KLAYMAN:
12 Q And consequently you were concerned
13 about this report about the Clinton's
14 administration use of private investigators
15 because that implies that the Clinton
16 administration was looking into the private
17 lives of others just as you've criticized
18 Starr for doing?
19 MS. MARSH: Objection.
20 BY MR. KLAYMAN:
21 Q Correct?
22 A I wanted to get an answer. I said
193
1 you just can't let this thing -- you've got
2 to put a statement out saying what the facts
3 are, and once I was told what the facts were,
4 I was not concerned about it anymore.
5 Q Wasn't that your concern, that you
6 didn't want there to be any kind of
7 suggestion that the Clinton administration
8 was trying to look into the private lives of
9 people?
10 MS. MARSH: Objection to
11 mischaracterizing testimony.
12 THE WITNESS: Mischaracterizing my
13 testimony. What I was concerned about was
14 getting facts out as fast as we could because
15 we would not have -- the best way to combat
16 this kind of stuff is to get facts out as
17 fast as you can. I was urging people to get
18 the facts out.
19 BY MR. KLAYMAN:
20 Q So you didn't have any concern
21 about any reports the Clinton administration
22 was looking into the private lives of
194
1 individuals by investigators?
2 MS. MARSH: Asked and answered.
3 THE WITNESS: If they would have
4 been I would have had a concern but they
5 weren't.
6 BY MR. KLAYMAN:
7 Q Are you now denying that private
8 investigators have been hired by Williams &
9 Connolly and Skadden, Arps?
10 A No. Have been retained since April
11 1994. How am I going to deny something when
12 I'm looking at a press statement right in
13 front of me saying that they have been.
14 Q So the private investigators aren't
15 hired to book your airline flight to Buenos
16 Aires, are they?
17 A No.
18 Q They're hired to look into the
19 lives of peoples and entities?
20 A This is a statement by David E.
21 Kendall and Robert S. Bennett. "Mr. Terry
22 Lenzner and his firm, Investigative Group
195
1 International, had been retained since April
2 1994 by the law firms of Williams & Connolly
3 and Skadden Arps Slate Meagher & Flom to
4 assist in defense of matters related to the
5 President. Is commonplace for private
6 counsel to retain commercial investigative
7 services to perform legal and appropriate
8 tasks to assist in the defense of a client.
9 Public officials deserve and from those two
10 law firms will receive no less vigorous
11 defense than private citizens under similar
12 circumstances," and go on from there. And
13 based on that paragraph that I just read I
14 wasn't concerned any more.
15 Q Based on your considerable
16 experience private investigators investigate
17 people and companies and things don't they?
18 MS. MARSH: Objection. He told you
19 he doesn't know any private investigators.
20 THE WITNESS: To my knowledge I
21 don't know a private investigator.
22 BY MR. KLAYMAN:
196
1 Q Do you know what they do?
2 A I wouldn't -- you know, if you
3 watch TV they do all kind of stuff from
4 finding lost kids to, you know, track down
5 witnesses to, you know, I mean Sam Spade or
6 whatever. I don't know what they do. I
7 mean, I suspect that they do a lot of
8 different things.
9 Q Among which is to investigate
10 people and companies and things, correct?
11 MS. MARSH: Objection.
12 BY MR. KLAYMAN:
13 Q Correct?
14 A I'm sure that they do.
15 Q You don't have a clue do you what
16 Paladino, Lenzner, and ���� were hired to do?
17 You don't have one clue?
18 A I know what I see on this
19 statement. I suspect -- look, why ask me? I
20 don't even know Paladino, Lenzner, or ���� or
21 any of these people and you keep asking me
22 about people that I don't know and I'm
197
1 sitting here trying to testify to the best of
2 my knowledge.
3 It's like asking me about astro-
4 physics or something. I don't know these
5 people. I don't know any private
6 investigators. I may know someone who's a
7 private investigator. I don't know that. I
8 don't know what certify somebody as a private
9 investigator. You pass a board with the
10 state or what makes it --
11 Q You ever watch TV?
12 MS. MARSH: Objection,
13 argumentative.
14 THE WITNESS: Infrequently.
15 BY MR. KLAYMAN:
16 Q Ever watch private detective shows?
17 MS. MARSH: Objection. Come on?
18 Let's ask him real questions.
19 BY MR. KLAYMAN:
20 Q You ever watch --
21 A Are any on now? If they were I
22 wouldn't know.
198
1 Q Ever watch Columbo?
2 A Yeah.
3 Q Did that tell you what private
4 detectives do?
5 A Columbo was a cop, wasn't he?
6 MR. GAFFNEY: I think Columbo was a
7 policemen --
8 BY MR. KLAYMAN:
9 Q Hawaii-50, do you watch that?
10 You've seen detective shows so you know what
11 they do?
12 MS. MARSH: On TV.
13 MS. GILES: Mr. Carville is not
14 here as an expert on the roles and
15 responsibilities of private investigators.
16 MS. MARSH: He's telling you,
17 Mr. Klayman, you just don't like it.
18 THE WITNESS: Mr. Klayman, again,
19 Hawaii-50 or Columbo or whatever, I can tell
20 you again I don't know any private
21 investigators, and -- well, it's not my place
22 to -- you ask what you want and I'll answer.
199
1 BY MR. KLAYMAN:
2 Q Has any private investigator ever
3 sent information to you?
4 A Not that I can ever remember but
5 somebody might have sent me information and
6 they were a private investigator and I didn't
7 know they were. So it's a hard thing for me
8 to answer because I don't even know what
9 constitutes a private -- I mean, if you're a
10 doctor you go to medical school and you get a
11 thing and you're an MD and you pass a bar. I
12 don't know what a private -- I mean, I assume
13 is there a licensing authority for these
14 people? I don't know. And I don't know what
15 constitutes somebody and somebody may be
16 private investigator and I didn't know they
17 were a private investigator.
18 Q You recently made a statement that
19 in your view Ken Starr had done something
20 criminal with regard to a case involving
21 General Motors, correct?
22 A I don't know if I said -- I did --
200
1 I was faxed information that based on the
2 facts that I read that seemed pretty
3 suspicious and I told people they ought to
4 look into it.
5 Q You made a statement on national
6 television stating that Ken Starr had done
7 something criminal with regard to GM?
8 A Would you repeat my statement? If
9 I have the statement in front of me, let me
10 see what I said.
11 Q Where did you get that information?
12 MS. MARSH: What information?
13 BY MR. KLAYMAN:
14 Q About GM and Ken Starr.
15 A It was an article in Mother Jones
16 magazine or something and it was -- and it
17 was something in the Miami Herald, I believe.
18 There was a thing that had a time line. As I
19 recall, it was the facts of the case were in
20 1973 the plaintiff was killed because of a
21 defective gas tank, and there was a man that
22 worked for GM by the name of Ivy, and Ivy did