401
1 anybody in the White House?
2 A Mr. Klayman, I don't remember
3 having a discussion. I may have. I don't
4 remember the discussion, so I'm not
5 testifying that I never had it. I'm
6 testifying that that was something that
7 happened, probably, two years and what, nine
8 months ago? A year and nine? Whatever it
9 is.
10 I don't remember conversations from
11 that period of time, and if I testified that
12 I remember those conversations, it just
13 wouldn't be -- that would be the case.
14 Q But you are aware that there is a
15 database in the White House, are you not?
16 MS. MARSH: Objection. Asked and
17 answered.
18 THE WITNESS: Again, I'm sure I'm
19 aware, because I do remember reading the
20 story about some sort of a database.
21 BY MR. KLAYMAN:
22 Q If there is a database that deals
402
1 with political matters in the White House
2 paid for by taxpayers, would that not be
3 improper, based on your knowledge of what's
4 proper?
5 A Well, Barry Toiv says -- this is a
6 comment of Barry Toiv from the White House:
7 "There's definitely nothing illegal here."
8 Q I asked you.
9 A Well, I don't know what the White
10 House says. If Mr. Toiv's correct, and
11 again, let me just say this: I'm not a
12 lawyer. So I don't know the answer.
13 But if the White House has a thing
14 that they keep records of people that go to
15 social events, you know, if they want to get
16 people on a certain sort of issue, it seems
17 to me to be legitimate use.
18 Q Based on your experience as a
19 Democratic party and political consultant, is
20 it not your view that it would be illegal to
21 have a database in the White House for
22 political purposes?
403
1 MS. MARSH: Objection. He's not
2 going to --
3 THE WITNESS: I am a political
4 strategist. I'm not a lawyer. I don't know
5 the criminal statutes of the United States.
6 I'm not going to testify to it. I have
7 testified with a great deal of candor that I
8 am not an expert in the law.
9 BY MR. KLAYMAN:
10 Q You are aware that this issue came
11 up during the campaign finance hearings?
12 A I do not remember it coming up.
13 But if you say it did, I'm sure you know what
14 you're talking about. I don't dispute.
15 Q Are you saying you've never
16 discussed with anybody in the White House or
17 outside the White House the issue of whether
18 or not such a database exists?
19 MS. MARSH: Objection. Asked and
20 answered.
21 THE WITNESS: I've already asked
22 and said I don't have a recollection, but I
404
1 can't say that I didn't.
2 BY MR. KLAYMAN:
3 Q I refer to Exhibit 10. This is the
4 Judicial Watch file.
5 MR. GAFFNEY: Would you provide me
6 of a copy of that, Mr. Klayman?
7 MS. MARSH: Again, I would request
8 that the original of the file we just talked
9 about --
10 MR. KLAYMAN: You can have it now.
11 I'm going to request that it stays in the
12 custody of the court, all the originals.
13 MS. MARSH: On what basis?
14 MR. KLAYMAN: Because that's
15 generally where original exhibits be
16 retained.
17 MS. MARSH: The rules allow -- we
18 told you at the beginning of the deposition
19 there was such a need.
20 MR. KLAYMAN: Why is there a need?
21 MS. MARSH: They're records of
22 Mr. Carville that he uses. They're records
405
1 in his office.
2 MR. KLAYMAN: We're going to ask
3 that they be kept in the custody of the court
4 reporter until we can ask the judge how to
5 deal with it.
6 MS. MARSH: The rules allow us to
7 substitute copies. There's no reason in this
8 case not to do. So you have had a chance to
9 look at the originals and compare them. In
10 fact, you made the copies. It seems to me --
11 MR. KLAYMAN: Will you keep these
12 copies in a secured place, Ms. Marsh, in your
13 office?
14 MS. MARSH: The originals?
15 MR. KLAYMAN: Yes.
16 MS. MARSH: I can do that, yes.
17 MR. KLAYMAN: I'll agree. But
18 we'll need to conform the copies before you
19 leave to make sure we have all the pages.
20 MS. MARSH: I would assume that you
21 had done that when you copied them.
22 MR. KLAYMAN: No, because we were
406
1 doing it quickly.
2 BY MR. KLAYMAN:
3 Q Looking at this file entitled
4 "Judicial Watch."
5 A I don't have it. Ms. Marsh has
6 mine.
7 MS. MARSH: No. I just have a
8 copy. You should be looking at the one
9 that's marked, which is the one he has in his
10 hand and is carrying away.
11 THE WITNESS: Okay.
12 BY MR. KLAYMAN:
13 Q When was this file made?
14 A I have no idea.
15 Q Whose handwriting is that on the
16 file tab, "Judicial Watch"?
17 A I don't know.
18 Q Do you have files about other
19 public interest groups in your office?
20 A I don't know. All this is sort of
21 pretty recent. I guess they started it
22 when -- you know, there are a number of
407
1 things in it.
2 Q Did you pull anything out of the
3 Judicial Watch file before you came over here
4 today?
5 A No.
6 Q Did anyone else?
7 A No. There would be nothing to pull
8 out. It's all I got.
9 Q Do you have files on press people
10 in your office?
11 A No.
12 Q Do you have files on individuals or
13 entities who are conceived to be adverse to
14 the Clinton administration in your office?
15 MS. MARSH: By whom?
16 BY MR. KLAYMAN:
17 Q By anyone.
18 A I don't know, you know what I mean?
19 I don't know if somebody is, you know,
20 adverse. I mean, it's just the really broad
21 statements.
22 Some people think that
408
1 Mr. Stephanopoulos is now adverse to the
2 Clinton administration or something.
3 Q Why is that? Because he told the
4 truth?
5 MS. MARSH: Objection. He doesn't
6 know why other people think what they think.
7 BY MR. KLAYMAN:
8 Q He's adverse because he told about
9 the Ellen Rometsch strategy?
10 MS. MARSH: Objection. Same
11 objection.
12 Q Is that why?
13 MS. MARSH: Objection. Same
14 objection. He can't testify as to what other
15 people think.
16 THE WITNESS: I must have read ten
17 stories about it.
18 BY MR. KLAYMAN:
19 Q The reason that George
20 Stephanopoulos is considered adverse is
21 because he's now a snitch, right?
22 MS. MARSH: Objection. Same
409
1 objection. We've gone over ���� for hours
2 today.
3 BY MR. KLAYMAN:
4 Q Is that right, Mr. Carville?
5 A Again, there are any number of
6 stories that -- you said "adverse." My point
7 I was trying to make to you is, that is a
8 broad term that I don't have any meaning -- I
9 don't have a way to sort of put it in
10 context. So if I see -- and by the way, I
11 might add, this so-called file that we
12 discuss is a copy of a press release and two
13 news stories. It's hardly anything that --
14 sort of innocuous. I don't know, you know.
15 Q Who told you that George
16 Stephanopoulos is now adverse to the Clinton
17 administration?
18 MS. MARSH: Objection.
19 THE WITNESS: Well, I said people
20 can characterize it. There was an article in
21 The New Yorker. There was an article in The
22 Washington Post. There was an article in The
410
1 New York Times. There was an article in
2 about everything.
3 I'll be glad to run a Lexis/Nexis
4 and print you a file of things that thick. I
5 didn't say that he was. I was attempting to
6 make the point that the term "adverse" is a
7 very broad term.
8 BY MR. KLAYMAN:
9 Q Who inside the Clinton
10 administration has used the term that George
11 Stephanopoulos is adverse to it now?
12 MS. MARSH: Objection. Assumes
13 facts not in evidence.
14 THE WITNESS: I don't know.
15 BY MR. KLAYMAN:
16 Q Ron Emanuel?
17 MS. MARSH: Objection.
18 BY MR. KLAYMAN:
19 Q Paul Begala?
20 A I've never heard anybody say he's
21 adverse to the Clinton administration.
22 Q He's now done things that are
411
1 harmful?
2 A I testified earlier, Mr. Klayman,
3 that I heard people vehemently object to his
4 use of the sort of Ellen Rometsch thing. I
5 was very up-front about that.
6 Q Have you ever talked about the
7 Ellen Rometsch thing with Torricelli?
8 A No.
9 Q Congressman John Conyers?
10 A No.
11 Q Have you been in contact with them
12 in the last three months, either one?
13 A No.
14 Q Excuse me?
15 A I've not spoken to either one in
16 the last three months.
17 Q Have you received correspondence or
18 sent correspondence to them?
19 A Not that I can remember.
20 Q Have you sent any documents to
21 them?
22 A No.
412
1 Q They send any documents to you?
2 A No. Let me qualify and say not
3 that I can remember. I'll be awfully
4 surprised if they did. I don't know, to tell
5 you the truth if I've ever talked to
6 Congressman Conyers, but I do know Senator
7 Torricelli.
8 Q Excuse me?
9 A I said that I don't know that I
10 know Congressman Conyers. I do know Senator
11 Torricelli.
12 MR. KLAYMAN: I'll show you what
13 I'll ask the court reporter to mark as
14 Exhibit 20.
15 (Carville Deposition Exhibit
16 No. 20 was marked for
17 identification.)
18 BY MR. KLAYMAN:
19 Q Have you ever seen Exhibit 20
20 before?
21 A I'm sure I have, but I don't recall
22 where. It's a pretty full authorizing paper
413
1 by the DNC. I assume it was for general
2 distribution.
3 Q Have you ever seen a document that
4 looks like Exhibit 20?
5 MS. MARSH: Looks like it in what
6 way?
7 BY MR. KLAYMAN:
8 Q Any way.
9 A I have seen any number of times
10 people talk about the Republicans having
11 subpoena power. I don't know that I've seen
12 a document in this detail with as many
13 different people. But let me add, for the
14 record, at the bottom of it, it says,
15 "Authorized and paid for by the Democratic
16 National Committee," so I don't remember
17 seeing it.
18 I do remember seeing any number of
19 quotes by the Speaker about using the
20 subpoena power.
21 Q Look at number 3, where it refers
22 to McCain, Arizona.
414
1 A Mm-hmm.
2 Q Last sentence: "The House Commerce
3 Committee may look into the same allegations,
4 and a private group, Judicial Watch, has
5 filed lawsuits to investigate the Commerce
6 Department."
7 MS. MARSH: Read the whole
8 paragraph, please.
9 BY MR. KLAYMAN:
10 Q Have you read that?
11 A No. So what's your question?
12 Q Have you seen any documents, other
13 than the ones you showed me in the Judicial
14 Watch file that we just identified, that make
15 reference to Judicial Watch, other than the
16 Judicial Watch file and this?
17 A Mr. Klayman, in all honesty, this
18 is probably something that the Democratic
19 National Committee faxed to my office that I
20 never saw and put it in a file.
21 You requested documents from me. I
22 went and conducted a search of the files to
415
1 the best of my ability. I don't know that
2 anything else does or doesn't seem -- and it
3 is a document that is authorized and paid for
4 by the Democratic National Committee, and,
5 you know, I don't know. I mean, it's --
6 Q Did you give this document to Paul
7 Begala?
8 A If I don't remember seeing it, I
9 can hardly testify that I gave it to
10 somebody.
11 But depending on when the document
12 was made, I'm sure that it got wide
13 distribution, because it says, "Authorized
14 and paid for by the Democratic National
15 Committee." It wasn't like someone was
16 trying to keep it secret.
17 MR. KLAYMAN: I'll show you what
18 I'll ask the court reporter to mark as
19 Exhibit 21.
20 (Carville Deposition Exhibit
21 No. 21 was marked for
22 identification.)
416
1 BY MR. KLAYMAN:
2 Q I'm showing you Exhibit 21. Have
3 you seen this before? It's titled "Selected
4 Investigations of The Clinton
5 Administration."
6 MS. MARSH: If you'd wait till it
7 goes around this way.
8 THE WITNESS: I am almost sure I've
9 seen this. I have seen things that go into
10 the sort of -- but I haven't seen this.
11 BY MR. KLAYMAN:
12 Q Did you give such a document to
13 Paul Begala?
14 A I don't know. I can't testify to
15 that one way or another.
16 Q Mr. Carville, going back to these
17 objections -- let's take them now -- that
18 your counsel provided them this morning.
19 MS. MARSH: You marked them with an
20 exhibit number, did you not? Will you tell
21 us what number that is, please, Mr. Klayman?
22 MR. KLAYMAN: If you'll hold your
417
1 horses there, it's No. 3.
2 MS. MARSH: I think your assistant
3 took all the original exhibits back. I'd
4 like him to look at the original of it.
5 MR. KLAYMAN: He just did, Ms.
6 Marsh.
7 MS. MARSH: Where is it?
8 MR. KLAYMAN: You want to see the
9 number of it?
10 MS. MARSH: No. I want him to look
11 at the one that's been marked. He's the
12 witness. That's what he should be looking
13 at.
14 BY MR. KLAYMAN:
15 Q Let's compare it up against the
16 subpoena.
17 MR. KLAYMAN: Mr. Bustion, why
18 don't you give him the subpoena and let me
19 have a copy of it? I have a copy of it.
20 BY MR. KLAYMAN:
21 Q Look at the subpoena. What exhibit
22 is that?
418
1 A Exhibit Number 3.
2 MS. MARSH: Exhibit Number 1.
3 BY MR. KLAYMAN:
4 Q You didn't go through each one of
5 these document requests with your counsel
6 before you came here today, did you?
7 MS. MARSH: Objection. He's not
8 going to tell you what he went through with
9 me and what he did not. That's attorney
10 client.
11 BY MR. KLAYMAN:
12 Q I'm not asking what was discussed.
13 MS. MARSH: He's not telling you
14 what was discussed, and it bears on
15 discussions that we may or may not have had.
16 MR. KLAYMAN: This was issued to
17 him, not you, Ms. Marsh.
18 MS. MARSH: I understand that.
19 MR. KLAYMAN: Certify it.
20 BY MR. KLAYMAN:
21 Q Did you go through each one of
22 these document requests before you responded
419
1 to the subpoena?
2 A I did.
3 Q Document request number 1 on the
4 subpoena, did you produce documents pursuant
5 to number 1?
6 A I've never had a grand jury
7 subpoena, a congressional subpoena, in my
8 life.
9 Q Again, you didn't check your house
10 in the Shenandoah Valley?
11 MS. MARSH: He checked his house.
12 He testified to that. You're
13 mischaracterizing totally.
14 BY MR. KLAYMAN:
15 Q Did your lawyer check your house in
16 Shenandoah Valley?
17 MS. MARSH: He's not going to
18 testify to that.
19 MR. KLAYMAN: Certify that.
20 MS. MARSH: Certify that and
21 everything else. You know that's improper.
22 it's privileged information, Mr. Klayman.
420
1 MR. KLAYMAN: I didn't ask about
2 you, but I will.
3 BY MR. KLAYMAN:
4 Q Mr. Carville, did your assistant go
5 out to check your house in the Shenandoah
6 Valley before you told him to do that this
7 morning?
8 A When you said that, I called him
9 and said, "You know, maybe there's something
10 there." I said, "Take that document out, go
11 look through there, and see if you can find
12 anything ����." And then I called him out
13 there. You said there could something be out
14 there, you know. I'm going to go out and
15 search it.
16 Q Where did you tell him to look?
17 A I told him to scour the house. We
18 don't have a place that we keep -- it could
19 be something that somebody faxed out there
20 and he was unable to find it.
21 Q How big is the house?
22 A It's big.
421
1 Q How many rooms?
2 A Five, I guess -- wait a minute.
3 Seven, eight.
4 Q Has your assistant ever worked out
5 there with you before?
6 A Yeah.
7 Q What assistant's that?
8 A Todd. Let me start on number 1
9 here. I have never gotten --
10 Q I'm asking the questions here.
11 Has he worked with you out there?
12 A Yes.
13 Q And when did you make this request?
14 Was it by phone?
15 A Yeah.
16 Q Where did you do that?
17 A Right out there (indicating).
18 Q Where? In the side library room
19 there?
20 A Yeah.
21 Q And when did you hear back from
22 Todd?
422
1 A I said, "Go out there and take that
2 subpoena and conduct a thorough search,
3 because we searched the entire office, and be
4 sure that" -- "and see if there's anything."
5 Q I said, when did you hear from
6 Todd?
7 A An hour ago, I guess.
8 Q When was that?
9 A An hour ago. I don't know. I'm
10 just giving you --
11 Q During a bathroom break or what?
12 A Yeah.
13 MS. MARSH: On a break that you
14 were on a break as well. He went in and used
15 the phone in the library.
16 BY MR. KLAYMAN:
17 Q How long did you talk to Todd? A
18 few seconds?
19 A Not very long. Man brought up a
20 point. I want to be sure that we -- I think
21 the word I used was "due diligence," and you
22 said was that -- but I'll search myself, too.
423
1 Q You didn't have time to thoroughly
2 inquire with him as to whether he searched
3 every room and every drawer and every file
4 cabinet?
5 A I know Mr. DeLorenzo, you know.
6 He's going to give it a good look. I doubt
7 if I'd look in the kitchen cabinet for this
8 kind of stuff myself. If you want to go
9 through each one of them --
10 Q Are there any other documents that
11 you brought to the deposition today that
12 haven't been produced?
13 MS. MARSH: Nonresponsive to the
14 subpoena.
15 MR. KLAYMAN: There are other
16 documents, Ms. Marsh?
17 MS. MARSH: Yes, documents I
18 brought.
19 MR. KLAYMAN: Are they documents
20 that were gathered in searching for documents
21 requested by the subpoena by Mr. Carville?
22 MS. MARSH: No.
424
1 BY MR. KLAYMAN:
2 Q Now, you've written a book, haven't
3 you?
4 A I have. Two of them. Well, half
5 of one and another one.
6 Q In those books, did you ever make
7 reference to Filegate?
8 A I doubt. The other one came out --
9 they both come out before it came -- that one
10 was published in March of '96.
11 Q Did you ever make reference to
12 doing opposition research in those books?
13 A Could be. Show me "All's Fair."
14 I'll be glad to --
15 MR. KLAYMAN: Will you let the
16 witness answer, Ms. Marsh, please?
17 MS. MARSH: I'm trying to make a
18 suggestion to make this go faster. If you
19 throw him the book, he can look in the book
20 and let you know quickly.
21 MR. KLAYMAN: I'm referring to the
22 book "All's Fair," Mary Matalin and James
425
1 Carville. It's the photograph section in the
2 middle, and we'll mark it. We'll mark it as
3 Exhibit 22, with the page as Exhibit 22-A.
4 (Carville Deposition Exhibit
5 No. 22 was marked for
6 identification.)
7 BY MR. KLAYMAN:
8 Q And it says here, "In the 'War
9 Room' in Little Rock, speechwriter Michael
10 Waldman; George Stephanopoulos, director of
11 communications; James; and Diane Blair,
12 campaign researcher; (rear) Roger Martin,
13 researcher; and Heidi Chapman, press
14 assistant."
15 So the two researchers, Diane Blair
16 and Roger Martin?
17 A Right. Diane Blair, as I testified
18 earlier, did all of the work on the
19 Governor's Arkansas record. It was her
20 almost sole role in the campaign. She is a
21 teacher. She teaches a class at the
22 University of Arkansas, and I became a very
426
1 close friend of hers. That was her job.
2 But Roger Martin, I remember --
3 well, we did a variety of sort of things. He
4 was sort of the younger kind of war-room
5 type.
6 Q And they gathered information on
7 opponents and those that spoke out against
8 the administration, correct?
9 A You know, Mr. Klayman, it's your
10 time. It's your nickel. I testified twice
11 that Diane Blair's job was to gather
12 information about the governor's record as
13 Governor of Arkansas, and that was -- her
14 sole was gathering information about the
15 then-Governor Clinton.
16 Q Now, during the course of your
17 professional life, you have taken notes, have
18 you not, Mr. Carville?
19 A No. I never took notes in college.
20 I can't even read my own handwriting.
21 Q Do you use a computer now?
22 A As I testified earlier, there's a
427
1 better chance I could turn on a 747 than a
2 computer. I am not a person that has ever
3 been given to that kind of thing. I've
4 always said that the shortest book ever
5 written would be to select the complete
6 memoranda of one J. Carville.
7 Q Have you ever tape-recorded
8 someone's telephone conversation with their
9 permission?
10 MS. MARSH: About anything or any
11 person?
12 MR. KLAYMAN: About anything.
13 MS. MARSH: I don't think that's
14 relevant.
15 BY MR. KLAYMAN:
16 Q You can respond, with their
17 permission.
18 A I'm sure I have. That's not
19 something that I do as a matter of course.
20 Q And you've kept those tapes?
21 A I doubt if I -- you know, more
22 often than not someone -- when I have a
428
1 conversation, oftentimes, with a reporter,
2 they will, you know, ask if it's okay to sort
3 of tape a conversation. That's not -- I
4 don't have -- this is not something we sort
5 of do.
6 Q But you have kept those tapes?
7 A No, sir.
8 MS. MARSH: He just testified he
9 had not.
10 BY MR. KLAYMAN:
11 Q Have you ever had a discussion with
12 President Clinton about what skeletons he
13 might have had in his closet, ever?
14 MS. MARSH: Objection. Asked and
15 answered.
16 THE WITNESS: I guess in 1992 I
17 did.
18 BY MR. KLAYMAN:
19 Q And what did he tell you?
20 A I don't remember.
21 Q Not important?
22 A I don't remember. If I don't
429
1 remember, I don't know whether it's not
2 important.
3 Q Was it anything to do with women?
4 MS. MARSH: Objection. Asked and
5 answered ad infinitum this morning.
6 THE WITNESS: It's 5 o'clock.
7 BY MR. KLAYMAN:
8 Q Have you ever recommended anyone
9 for a White House job?
10 A I'm sure that there were campaign
11 people that I recommended. There would have
12 to be. I mean, well, many of the people have
13 got White House jobs who didn't really need
14 my recommendation. But some of the people,
15 you know, sort of mid-level people or
16 something, I probably recommended.
17 Q Did you ever meet Bernie Nussbaum?
18 A I have met Bernie. I don't think
19 I've ever had a phone conversation with him,
20 or I haven't talked to Bernie in, I would
21 guarantee, the last four or five years.
22 Q Close friend of the First Lady,
430
1 though, right?
2 A He is.
3 Q Did you ever talk to Bernie about
4 Filegate?
5 A No. I haven't talked to Bernie
6 since June of 1996.
7 Q Have you ever talked to any of Mrs.
8 Clinton's secretaries or chiefs of staff
9 about Filegate?
10 A Not that I can remember.
11 Q Have you ever been advised that any
12 of the documents taken out of Vince Foster's
13 office had anything to do with Filegate?
14 A No, sir.
15 Q Who made the decision to revoke
16 your White House pass other than Mr. Panetta?
17 Do you know of anyone else who played a role?
18 A I do not.
19 Q You are aware that there's an FBI
20 file on you?
21 A I'm not surprised that there is.
22 Q You've asked to see it?
431
1 A No. I don't have that much time to
2 read that much, Mr. Klayman.
3 Q You wouldn't want that released
4 publicly, would you?
5 A I would not.
6 Q Have you ever had any discussions
7 about the firing of the White House travel
8 office with anyone in the White House or
9 anywhere else?
10 A Oh, I mean I -- you know, I'm sure
11 that I had discussions. When I first heard
12 of that, I don't exactly where I was. In
13 ����, Pennsylvania, riding in a car with
14 Governor John Sununu.
15 Q And what did you say?
16 A I said, "What is this?" I didn't
17 know what the travel office was or anything.
18 I was asking him.
19 Q Have you ever had any discussions
20 with the President about the firing of Billy
21 Ray in the travel office?
22 A No.
432
1 Q The First Lady?
2 A No.
3 Q With anyone in the White House?
4 A I'm sure I have.
5 Q Who?
6 A I don't remember but any number of
7 people.
8 Q Have you ever conducted any
9 research on senator Fred Thompson, you or
10 your staff?
11 A I never have.
12 Q Jesse helms?
13 A No.
14 Q Do you know of anyone who has
15 conducted research on Fred Thompson?
16 A No. I'm sure that somebody at the
17 DNC has. I'm sure who ran against him for
18 the senate.
19 Q Judge Sentelle?
20 A Somebody sent me something out of a
21 sort of, you know, directory of American
22 judges or something like that. But that's
433
1 about it. That's not the title of it, but
2 it's one of those kinds of things.
3 Q Who sent that to you?
4 A I don't even remember, but I do
5 remember --
6 MR. KLAYMAN: Just wait.
7 (Discussion off the record)
8 BY MR. KLAYMAN:
9 Q Who sent you that information about
10 Judge Sentelle? Where did it come from?
11 A I remember seeing something from a
12 thing. There's a book that they put out,
13 like a biography of different judges.
14 Q Jesse Helms?
15 MS. MARSH: You already asked about
16 that.
17 THE WITNESS: I don't have any --
18 BY MR. KLAYMAN:
19 Q Anybody send you any information
20 about him?
21 A Not that I can remember. You know,
22 it's sort of possible. I haven't been much
434
1 involved in North Carolina politics.
2 Q Dig some information up on him
3 yourself?
4 A No.
5 Q ����?
6 A ����, you mean?
7 Q Yeah. Chris Matthews?
8 A Chris, that talk show Chris
9 Matthews?
10 Q Yes.
11 A No.
12 Q Susan ����
13 A No.
14 Q Chris Ruddy?
15 A No.
16 Q ���� Goldberg?
17 A No.
18 Q Monica Lewinsky?
19 A No.
20 Q Dan Burton?
21 A Yeah.
22 Q Where did you get information about
435
1 Dan Burton?
2 A Well, I know that I got -- I read
3 an article about shooting up watermelons or
4 cantaloupes or something like that, and --
5 MR. GAFFNEY: Are we done, Jill?
6 MR. KLAYMAN: We'll attach as
7 Exhibit 22 a letter from David S. Cohen, who
8 walked off with the original Exhibit 11. He
9 says he's sending it back by Federal Express.
10 MS. MARSH: What is Exhibit 11, do
11 you recall?
12 MR. KLAYMAN: I ask this be marked
13 Exhibit 22.
14 (Carville Deposition Exhibit
15 No. 23 was marked for
16 identification.)
17 MS. MARSH: If we have copies of
18 these, we can leave the originals with you,
19 as long as I have copies of all of them. And
20 I think they were all marked, were they not?
21 I'm leaving the originals with you.
22 I just need copies, that's all.
436
1 MR. GAFFNEY: That's 23.
2 MR. KLAYMAN: Twenty-three, excuse
3 me.
4 Before we break, we are going to
5 leave this deposition open.
6 MS. MARSH: And we will object.
7 You gave us a time of six hours. Six hours
8 you got.
9 MR. KLAYMAN: For the reasons set
10 forth on the record, particularly with regard
11 to documents and objections and matters of
12 that nature.
13 MS. MARSH: We will object.
14 (Whereupon, at 5:03 p.m., the
15 deposition of JAMES CARVILLE was
16 continued.)
17 * * * * *