201
1 very close with James Carville, are you not?
2 A I'm -- your characterization. My
3 characterization is that he worked for James
4 for part of 1997.
5 Q Do you know how he got his job?
6 A I do not.
7 Q Glen Weiner has told you that he
8 worked for Carville, correct?
9 A I'm sure he has. It's not a
10 secret.
11 Q And what did he tell you he did for
12 James Carville?
13 A He worked on James' project or
14 whatever it was -- education project or
15 something. It was some group that James had
16 set up and --
17 Q Education Information Project?
18 A That would sound right.
19 Q EIP. Tell me what you know about
20 that project.
21 A What I know about it. I read quite
22 a bit about it when James set it up. It was
202
1 in the newspapers. It was James defending
2 the President and that's my -- it was,
3 basically, James, my recollection of it.
4 Q You talked to Mr. Carville about
5 that project, have you not?
6 A I don't believe I have actually.
7 Q You've had conversations with
8 Mr. Carville within the last year. Have you
9 not?
10 A I don't have any -- I'm trying to
11 be -- I don't have any specific recollection
12 of having done so, although I wouldn't say
13 that it would have been -- you know, it may
14 have happened that I spoke to him.
15 Q Where did you hear the phrase
16 specific recollection? Where do you come up
17 with that?
18 A My testimony.
19 Q Is that a White House phrase? Have
20 they taught people in the White House to use
21 that phrase when you can't remember?
22 A No, sir.
203
1 Q Where did you hear it before?
2 A I don't know. I've heard it
3 before.
4 Q Have you ever been deposed before?
5 A No, sir.
6 Q Have you ever provided testimony in
7 court?
8 A No, sir.
9 Q Have you ever seen any
10 documentation passed around the White House
11 or anywhere else that tells you how to answer
12 tough questions at depositions?
13 A Never.
14 Q Why didn't you just say I have no
15 recollection? What's the difference between
16 no recollection and specific recollection?
17 A It's my best attempt at an honest
18 answer. It would not have been completely
19 unheard of if I had spoken to James Carville
20 in the past year, but I have no specific
21 recollection of having done so.
22 Q Is that your phrase, "specific
204
1 recollection"?
2 A Yes, it is, it just came out of my
3 mouth.
4 Q Do you have any legal training?
5 A No, sir.
6 Q Did you read any deposition
7 transcripts in this lawsuit that you're here
8 on today before you came in here this
9 morning?
10 A Yes, I did.
11 Q What did you read?
12 A I read James Carville's deposition,
13 Paul Begala's deposition and Stacey Parker's
14 deposition.
15 Q Where did you get those
16 depositions?
17 A From my attorneys.
18 Q Did they ask you to read them?
19 MS. GILES: Objection. You're not
20 to answer any questions about what your
21 attorneys told you or asked you to do.
22 MR. KLAYMAN: How is that
205
1 attorney/client?
2 MS. GILES: Any conversation
3 between his attorneys either from us to him
4 or from him to us are privileged and we
5 instruct him not to answer.
6 MR. KLAYMAN: That's an
7 instruction. That is not the conveyance of a
8 piece of confidential information. It has to
9 confidential to constitute attorney/client.
10 MS. GILES: I'm instructing him not
11 to answer.
12 MR. KLAYMAN: Certify it.
13 BY MR. KLAYMAN:
14 Q Did they tell you why they wanted
15 you to read those deposition?
16 MS. GILES: Objection. Instruct
17 the witness not to answer. You're free to
18 ask him whether he's ever --
19 MR. KLAYMAN: Certify it.
20 BY MR. KLAYMAN:
21 Q They wanted to make sure that your
22 testimony conformed with the testimony
206
1 previously given in this case.
2 MS. GILES: Objection.
3 BY MR. KLAYMAN:
4 Q Isn't that what they told you?
5 MS. GILES: That's privileged and
6 he can hardly speak to other people s
7 knowledge or understanding.
8 MR. KLAYMAN: Certify it.
9 BY MR. KLAYMAN:
10 Q Ms. Paxton specifically, is she the
11 one that told you to read those deposition?
12 MS. GILES: Objection. Instruct
13 the witness not to answer.
14 MR. KLAYMAN: Certify it.
15 MS. GILES: Can we move on beyond
16 topics he's had that --
17 MR. KLAYMAN: Well, this wouldn't
18 be attorney/client information. I mean
19 you're obviously telling him not to answer,
20 but I'm getting it on the record so I can
21 then file an appropriate motion.
22 BY MR. KLAYMAN:
207
1 Q Before you came here to testify
2 today did you talk to James Carville Carville
3 about your deposition?
4 A No, sir.
5 Q When was the last time you talked
6 to Mr. Carville?
7 A The last time I recall even, you
8 know, being around him or seeing him was at a
9 Christmas party, but I don't even know that I
10 spoke with him at that point. That's my
11 recollection.
12 Q Did you speak with Mr. Begala about
13 your deposition today?
14 A No, sir.
15 Q Did you speak with
16 Mr. Stephanopoulos about your deposition
17 today?
18 A No, sir.
19 Q Ms. Parker?
20 A No, sir.
21 Q When was the last time you spoke
22 with Mr. Stephanopoulos?
208
1 A Probably, general, Spring -- Spring
2 of 1997.
3 Q When was the last time you spoke
4 with Mr. Begala?
5 A Probably last week.
6 Q What did you speak with Mr. Begala
7 about last week?
8 A I have not -- let me clarify. I
9 have not spoken with him since I was served.
10 I may have ran into him last Monday in the
11 course of the workday. I don't have any
12 specific recollection of --
13 Q What did you speak with him about?
14 A I think I may have said hello to
15 him last Monday in the hallway when I bumped
16 into him.
17 Q Do you ever interact with
18 Mr. Begala over your job functions? Do you
19 provide information to his office?
20 A Certainly.
21 Q Tell me in the course of your
22 duties and responsibilities how your office
209
1 researches information and how it processes
2 that information, how it disseminates the
3 information.
4 How does your office work? What's
5 it set up to do? How does it take a request
6 to do research? How does it then do that
7 research and how does it then give the
8 research back?
9 A Do you want to maybe break those
10 down?
11 Q Sure, but I'm just laying it out so
12 you can tell me in your words.
13 A What's the specific --
14 Q I want to find out how your office
15 works and what everybody's job is, if you
16 would?
17 A There are, I'd say four -- four
18 different things that the office does. First
19 is to track the administration record on
20 issues, accomplishments, criticisms both, on
21 issues and to maintain a set of
22 accomplishment documents that are up to date
210
1 and accurate. Secondly, the vetting process
2 that I described. Thirdly, we do a lot of
3 paper for events like Presidential -- if the
4 President is going, you know, to do an event
5 on education, we might help provide paper for
6 that event. And then, fourth, there are just
7 general other -- other things that come up
8 that we're asked to -- to help with. Those
9 are the -- the bulk of my what my office
10 does. I'd say 98, 99 percent.
11 Q As part of your duties and
12 responsibilities, do you process requests by
13 other persons in the White House to do
14 opposition research?
15 A I don't understand.
16 Q Let's say can Mr. Begala call down
17 to you and ask you to research a particular
18 matter?
19 A Well, first of all, when you refer
20 to opposition research, I don't do what I
21 consider by my definition to be opposition
22 research at the White House. Is that your
211
1 question?
2 Q No. My question was, if someone in
3 the White House wants to get something
4 researched, is it within the purview of your
5 duties and responsibilities, your office's,
6 to do that research for them?
7 A It may or may not be actually. It
8 depends on what it is and what else is going
9 on.
10 Q Have you ever been requested to do
11 any type of research by Paul Begala's office?
12 A Probably. I'm sure we have.
13 Q And what specifically was your
14 office requested to research?
15 A There are a lot of times where
16 Paul -- I'm sure there are occasions where
17 Paul is looking for a particular transcript
18 or a past speech or something from the '92
19 campaign like a speech that the President
20 made that he'll remember, but be looking for
21 a copy of. Or he may be working on a
22 particular issue and -- like, you know, an
212
1 education event and ask for something
2 specific to that -- to that issue.
3 Q Has Mr. Begala ever asked you to do
4 any research on Mr. Richard Scaife?
5 A No, sir. I mean, no, I don't
6 believe during the time --
7 Q When I say you, I mean your office.
8 A In the capacity as director of the
9 office, I have no -- no knowledge of that.
10 Q Let me ask the question this way:
11 Has anyone ever asked your office to do
12 research on Mr. Scaife?
13 A No, I have no recollection of that.
14 Q You don't remember? Is that what
15 you're telling me?
16 A No, I don't -- I don't have any
17 recollection of anyone having asked me to do
18 any research on Mr. Scaife.
19 Q Has anyone asked not you, your
20 office?
21 A My office.
22 Q Has anyone asked that your office
213
1 do any research on Ken Starr?
2 A No, sir, with -- again, just so
3 that I'm being fully forthcoming, I'm not
4 saying that it isn't possible that someone
5 asked me for a transcript or a press article
6 or something like that that had -- that was
7 relevant to that, but I don't specifically
8 remember that. But that would have been --
9 if that had happened, it wouldn't surprise
10 me.
11 Q Bob Barr?
12 A What about him?
13 Q Has anyone ever asked you to do any
14 research, you meaning your office, on Bob
15 Barr?
16 A Not to my recollection. I believe
17 on one occasion someone asked -- asked to
18 pull up his remarks that he made on the
19 floor. I believe that's the only occasion I
20 can recall.
21 Q Judicial Watch?
22 A No, not to my recollection.
214
1 Q Larry Klayman?
2 A No, sir.
3 Q Senator Fred Thompson?
4 A Again, I don't -- it's possible
5 that someone may have been looking for an
6 article or a transcript. He certainly was
7 someone who was in the news and all, but I --
8 I don't have any specific recollection and
9 I've certainly never done. You know, any
10 work on him personally, no.
11 Q When I say you, your office.
12 A My office. That's how I'm
13 answering it.
14 Q John Fund?
15 A No, sir.
16 Q Michael Issikoff?
17 A Have I ever done research on
18 Michael Issikoff.
19 Q Has your office ever been asked to
20 do research on Michael Issikoff or have you
21 ever done research on Michael Issikoff?
22 A Well, can we -- maybe if we can
215
1 clarify the term "research." Again, I would
2 say it's possible that someone had asked me
3 for an article that he had written, but I --
4 beyond that I cannot think of anything, no.
5 Q Susan Schmidt of The Washington
6 Post?
7 A Same answer.
8 Q Did you talk to Ann Lewis about
9 your being deposed here today?
10 A No, sir.
11 Q Have you ever been asked to do any
12 research or did you do any research
13 concerning Linda Tripp?
14 A No, sir, although, as I already
15 told you, when I searched my files, there
16 were two public documents that came up which
17 I believe just the nature of the fact that
18 they were transcripts, they were in my files.
19 Q Kathleen Willey?
20 A No sir.
21 Q John Whitehead of the Rutherford
22 Institute?
216
1 A No, sir.
2 Q Paula Corbin Jones?
3 A No, sir.
4 Q Landmark Legal Foundation?
5 A No, sir.
6 Q Larry Patterson?
7 A No, sir.
8 Q L.D. Brown, State Trooper,
9 Arkansas?
10 A I have no recollection of anyone in
11 my office having ever done research on any of
12 them.
13 Q Pat Robertson?
14 A No, sir. No, the only thing that
15 is possible is that one of the functions we
16 have is to do a calendar of upcoming events.
17 So, again, as broadly answered, it's
18 possible. Like his Web site with a list of
19 events. Like if -- if the Christian
20 Coalition had a major event coming up, that
21 might go up on the, like, calendar of
22 upcoming events. Beyond that, no, I don't
217
1 believe there's ever been any research done.
2 Q Jerry Falwell?
3 A I'm not sure.
4 Q Newt Gingrich?
5 A I'm sure that Newt Gingrich is, in
6 his capacity as speaker of the house, is all
7 over -- I mean he's probably in our -- his --
8 I don't think -- no specific research on Newt
9 Gingrich, but I'm sure that his position on
10 issues is something that we've been asked for
11 or have provided to people.
12 Q Joe DiGenova?
13 A No, sir.
14 Q Do you know who Joe DiGenova is?
15 A I have a vague sense that he's an
16 attorney Beyond that --
17 Q Victoria Toensing?
18 A No, sir.
19 Q Christopher Ruddy?
20 A No, sir, although I --
21 Q Well, you started to nod. What
22 have you --
218
1 A No, I know he is and it's -- it's
2 possible that on one occasion there was some
3 articles that we pulled down that he had
4 written and that we shared with people.
5 Q Pat Buchanan?
6 A Yeah, I -- I don't recall having
7 ever done any research on him. May have
8 pulled down something he wrote.
9 Q Gennifer Flowers?
10 A No, sir I don't.
11 Q Rush Limbaugh?
12 A No, sir.
13 Q Dick Morris?
14 A No, sir.
15 Q You're aware, are you not, that
16 James Carville currently keeps a number of
17 files on individuals and entities which are
18 the conservative movement? You're aware of
19 that, aren't you?
20 A I'm not aware of how -- you know,
21 what files Mr. Carville keeps, no.
22 Q Glen Weiner has told you that,
219
1 hasn't he? That Mr. Carville has a lot of
2 files about perceived adversaries of the
3 Clinton administration like Mr. Scaife and
4 Bob Barr and others?
5 A No, and I would not say -- I'm,
6 generally, aware of what the organization was
7 set up for and that, you know, that was the
8 kind of work that Glen did while he was
9 there, but I have no specific knowledge of
10 how the files are kept or who is in his files
11 and who's not in his files.
12 Q In your office there is a list of
13 the files that Glen set up for James
14 Carville, is there not?
15 A Not to my knowledge, no. I don't
16 believe that there is such a list.
17 Q And, in fact, your office has
18 communicated with Carville's office from time
19 to time to determine what information they
20 have; isn't that correct?
21 A I don't believe so with the -- I
22 would say that it's my vague recollection
220
1 that -- that when Glen started working for
2 me, after having left James, that there may
3 have been -- he may have had a conversation
4 or two with people back there saying I have
5 left, but if you're looking for such and
6 such, it used to be here. I mean that kind
7 of conversation, but --
8 Q Faxes have come into your office
9 from Carville, have they not, or EIP?
10 A Not that I'm aware of.
11 Q Have faxes come in from
12 Stephanopoulos?
13 A Faxes from Stephanopoulos?
14 Q Yes.
15 A No, not that I'm aware of.
16 Q Your office communicates from time
17 to time with the Democratic National
18 Committee, does it not?
19 A Certainly.
20 Q And it provides information to the
21 Democratic National Committee, does it not?
22 A Certainly.
221
1 Q Provides information about people
2 who have challenged or criticized the Clinton
3 administration?
4 A No, sir.
5 Q It never has done that?
6 A I cannot think of any occasion --
7 and maybe you would have to be more clear
8 about who you're talking about.
9 Q Well, a person or a group that's
10 been critical of Clinton. Haven't you sent
11 information to the DNC about such persons or
12 groups?
13 A I don't recall having done that,
14 although I wouldn't rule out that -- you
15 know, if I saw an article that I thought -- a
16 printed article that was of interest to me,
17 that I might, you know, say did you guys see
18 that in the course of a conversation.
19 Q When did that happen?
20 A I'm sure that it's probably
21 happened, but I don't -- I'm trying to think
22 of the specific example. I don't have one.
222
1 I'm sorry.
2 Q Did you ever see the movie "The War
3 Room"?
4 A I did.
5 Q Do you remember the scene where
6 George Stephanopoulos is on the phone, he's
7 talking to somebody who's a democrat and
8 they're talking about a s certain piece of
9 information and Stephanopoulos says something
10 to the effect, well, you know, you better
11 never do that because, if so, you'll never
12 work in the democrat party again? Do you
13 remember that?
14 A I remember that, yes.
15 MS. GILES: Objection to the
16 question on the grounds of relevance.
17 MR. KLAYMAN: I'm laying a
18 foundation.
19 BY MR. KLAYMAN:
20 Q What was your understanding of what
21 was being discussed in that --
22 A I have absolutely no understanding
223
1 and I was at the preview of the movie and
2 when that was said everyone laughed, so --
3 Q Now, you're very much aware, are
4 you not, that if you say the wrong thing at
5 this deposition, you may never work with the
6 democrats again?
7 A No, sir, I'm concentrating on
8 giving you full and honest answers.
9 Q But obviously that segment of the
10 movie caught your attention?
11 A No. As I said, I -- what I can
12 recall is that people laughed and thought it
13 was sort of funny, like what was he talking
14 about.
15 Q What's funny about it?
16 MS. GILES: Objection. His
17 reactions to a movie? I mean can we move on
18 to more relevant topics?
19 BY MR. KLAYMAN:
20 Q Did you laugh?
21 A No, I didn't laugh. I just
22 remember it seemed to be something that
224
1 people thought was funny.
2 Q Has your office had contact with
3 Terry Linzner's office? Do you know who
4 Terry Linzner is?
5 A I do know he is from
6 publicly-reported stories.
7 Q Has your office ever had contact
8 with him?
9 A None whatsoever that I'm aware of
10 at all.
11 Q His firm is called IGI
12 International, did you ever hear that?
13 A I've heard of him and I'm that he
14 has a firm, but I can't say the name of the
15 firm means anything to me.
16 Q Did you ever have contact with IGI?
17 A No, sir, not to best of my
18 knowledge.
19 Q Has your office ever had contact
20 with Williams & Connolly or David Kendall or
21 anybody from Williams & Connolly?
22 A Not that I'm aware of, no.
225
1 Q Same question with regard to Bob
2 Bennett from Skadden & Arps?
3 A Not that I'm aware of.
4 Q Do you know what Skadden & Arps is?
5 It's a law firm.
6 A It's a law firm.
7 Q Have you ever had contact with a
8 private detective by the name of Pellicano?
9 A No, sir.
10 Q Palladino?
11 A Not to the best of my -- I mean if
12 he walked in the door, I wouldn't know who he
13 was, but to the best of my knowledge I
14 don't -- I don't believe so.
15 Q Who are the people that you
16 interact with most at the White House, that
17 you see most on a routine basis?
18 A My own --
19 Q Not the people in your office,
20 obviously those people, but outside of your
21 office, your suite of offices.
22 A The -- certainly my -- the rest of
226
1 the communications staff, Ann Lewis, speech
2 writer, Michael Waldman and his staff,
3 people -- a lot of people who put together --
4 I don't even know where they all work, but in
5 relation to the vetting work there are a
6 number of people who are constantly putting
7 together lists of who is going to be invited
8 to particular events that we work with quite
9 a bit. The -- it's not uncommon for us to
10 work with the press office and its staff in
11 terms of they might be looking for a --
12 Q Is this Mike McCurry's office when
13 you say "press office"?
14 A He's the press secretary, correct.
15 Q And who works just underneath him?
16 A Who works just underneath him?
17 Q Who's in that office that you can
18 remember?
19 A Who's in the press office?
20 Q Uh-huh?
21 A Amy Weiss Toby, Joe Lockhart, Barry
22 Toiv, Steve Silverman. I'm trying to think.
227
1 That's the best of my recollection. There
2 are more --
3 Q And you interact --
4 A There are more people.
5 Q You interact regularly with these
6 people?
7 A Not regularly in the sense that
8 there's a scheduled meeting of any kind, but
9 it's not uncommon that, you know, there might
10 be something that would come up that we would
11 help, you know, help them find.
12 Q And you do interact with Sidney
13 Blumenthal?
14 A I do occasionally, yeah. I bump
15 into him at staff meetings a couple times a
16 week.
17 Q He's in the communications office,
18 too, isn't he?
19 A I believe he is, yes, is my
20 understanding. I could be wrong, but I
21 believe he's under Ann Lewis, communications.
22 Q Why didn't you mention him when I
228
1 was asked you?
2 A I was continuing to list people and
3 you interrupted me.
4 Q Well, we were outside the
5 communications office at that point.
6 A I probably would have said so.
7 I -- I was naming people.
8 Q Name some more.
9 MS. GILES: What's the question?
10 People he's ever had contact with or --
11 MR. KLAYMAN: Who does he interact
12 with most on a regular basis.
13 THE WITNESS: Well, and he wouldn't
14 fit into that category, which is probably why
15 I didn't name him. Ruby Shamir, who is Ann
16 Lewis' assistant, Stacey Spector is deputy
17 communications director.
18 BY MR. KLAYMAN:
19 Q And how is that name spelled?
20 A First or last?
21 Q Last.
22 A I believe it's S-P-E-C-T-O-R.
229
1 Q Is she related to Arnold Spector,
2 the senator?
3 A Not to the best of my knowledge.
4 Q Anyone else?
5 A I mean --
6 Q What does Sidney Blumenthal do?
7 What is his job?
8 A He's a -- I don't know his title or
9 anything, but he's a senior communications
10 person, to the best of my knowledge, under or
11 within communications working with Ann Lewis.
12 Q Now, his job is to dig up dirt,
13 isn't it?
14 A No, sir, not to my best of my
15 knowledge.
16 Q Who does he work with primarily?
17 A As far as I can tell, he spends a
18 lot of time -- well, I don't want to flip. I
19 don't know.
20 Q No, tell me what you mean. You're
21 not going to be flip.
22 A Spends a lot of time in his office
230
1 on the phone. I don't know who he works
2 with. I'm sure he's -- I mean he's part of
3 the senior communications staff. I don't
4 know who he works with.
5 Q He works under Ann Lewis, does he
6 not?
7 A Again, I -- I believe that's true,
8 but I -- I haven't seen it on a chart.
9 Q Did you ever ask Ms. Lewis what he
10 does?
11 A No, sir.
12 Q Have you ever asked anybody what he
13 does?
14 A No, sir.
15 Q Do you know who he's in contact
16 with on a regular basis?
17 A No, sir.
18 Q You think you have sen --
19 MS. GILES: If I get some
20 relevance to --
21 BY MR. KLAYMAN:
22 Q You have seen --
231
1 MS. GILES: If I can just get -- if
2 I can --
3 MR. KLAYMAN: This is discovery.
4 MS. GILES: -- state my objection
5 for the record. This witness' knowledge
6 about other people's duties seems very far
7 afield.
8 MR. KLAYMAN: No, this is --
9 MS. GILES: Can you tie this back
10 to the subject matter of the case?
11 MR. KLAYMAN: This is relevant.
12 I'm trying to find out how the communications
13 office operates.
14 BY MR. KLAYMAN:
15 Q You have received from
16 Mr. Blumenthal and/or his office from time to
17 time materials from Salon Magazine, have you
18 not?
19 A I believe probably I have, yes.
20 Q You know there's a Salon Magazine.
21 A I don't specifically recall. I'm
22 sure, you know, he'll often send an envelope
232
1 with a number of press clips in it of some
2 kind or another that will arrive, you know,
3 from his office.
4 Q Do those envelopes have
5 instructions in them?
6 A No, sir.
7 Q And what do you do with those press
8 clips?
9 A Occasionally I read them.
10 Occasionally I don't read them.
11 Q Does it have a routing slip to who
12 it's sent?
13 A No, sir.
14 Q Do you know whether other people
15 are receiving them as well?
16 A I couldn't say.
17 Q Is there any indication as to who
18 received the same materials that you
19 received?
20 A No, sir, there's not. There's no
21 indication.
22 Q Now, what was the subject matter of
233
1 some of the materials you received from
2 Mr. Blumenthal?
3 A They, generally, have to do with
4 Ken Starr's investigation and, you know, I
5 would say they -- that's to my recollection,
6 that they're, generally, along those topics.
7 Q Now, is there anything with regard
8 to Filegate that you've received from him?
9 A Not to the best of my recollection,
10 but, again, I haven't -- a lot of times I
11 don't -- I don't read the -- I don't read
12 everything he sends us, so --
13 Q Is that stuff sent to you, you Tom
14 Janenda?
15 A Me personally, yes.
16 Q And I take it you called him and
17 said Mr. Blumenthal, why are you sending me
18 this stuff?
19 A No, I haven't.
20 Q You have no curiosity?
21 A No, he's -- no, I haven't done
22 that.
234
1 Q Do you take what he sends you and
2 just throw it out immediately?
3 A No, I don't throw it out
4 immediately. Sometimes I read it. Sometimes
5 I don't read it. Sometimes it sits on my
6 desk for, you know, a couple of days.
7 Q What do you do with it?
8 A Generally, I throw it out at the
9 end of the week or at the end of the day. I
10 get rid of it. I get -- people forward a lot
11 of articles, you know, across the board to
12 me.
13 Q I take it that you have filed some
14 of the materials that Mr. Blumenthal has sent
15 you?
16 A No, sir, and I specifically looked.
17 Q You or your office?
18 A No, not that I'm aware of. Again,
19 those are press clips. I mean that's,
20 generally, all -- I can't -- just press clips
21 of things that -- things that are interesting
22 as far as I know.
235
1 Q You said that you attend staff
2 meetings, correct?
3 A I think I said I attend
4 communications staff meetings, yes.
5 Q How frequent do those meetings
6 occur?
7 A It varies, but they are scheduled
8 to occur Monday, Wednesdays and Fridays.
9 Q And at what time do they occur?
10 A Usually somewhere in the vicinity
11 of 9:15.
12 Q 9:15 a.m.
13 A Yes, sir.
14 Q And how long did do, generally,
15 last?
16 A It varies. They're brief. Fifteen
17 minutes.
18 Q Does the communications department
19 ever have meetings longer than 15 minutes?
20 A I'm sure they probably do.
21 Q You had meetings longer than 15
22 minutes when the Monica Lewinsky story broke,
236
1 did you not?
2 MS. GILES: Objection. We're not
3 going to get into the Monica Lewinsky matter.
4 BY MR. KLAYMAN:
5 Q He can respond.
6 A I'm happy to respond. I've never
7 been in any meeting about Monica Lewinsky.
8 Q Did you have a meeting longer than
9 15 minutes when the peace accord was reached
10 with Northern Ireland?
11 A Again, am I answering for myself or
12 am I answering for the communications
13 department?
14 Q Communications department.
15 A I can't answer for the
16 communications -- I was not in a meeting -- I
17 don't know. The communications department
18 could have had a four-hour meeting about the
19 peace in Northern Ireland.
20 Q Are you not invited to general
21 communications department meetings?
22 A That are a lot of meetings. I am
237
1 not invited to every meeting, no.
2 Q How is it decided what meeting you
3 attend and what meeting you don't then?
4 A I would be, you know, notified by
5 someone or my -- I would be requested to
6 attend.
7 Q How are you, generally, notified?
8 A Either a phone call or an E-mail.
9 Q And where does the phone call or
10 E-mail come from?
11 A I just find it very difficult to
12 answer these questions because it's -- I mean
13 you're asking a communications meeting.
14 There are communications meetings probably
15 two or three at a time in the White House and
16 they're on what's happening this week, next
17 week. I -- I get invited to some. I don't
18 get invited to some.
19 Q Well, tell me where you can
20 remember having gotten notification to attend
21 a communications meetings, all the different
22 sources.
238
1 A E-mail and phone calls.
2 Q From who?
3 A Often Ruby Shamir, Stacey Spector,
4 rarely -- occasionally Michael Waldman,
5 speech writer. Beyond that I'm -- I'm
6 guessing.
7 Q Did you ever get notification from
8 Paul Begala's office to attend a meeting?
9 A I remember -- it hasn't happened
10 often, but it may have happened -- I believe
11 there was a -- he was attempting -- Paul was
12 attempting to host a meeting that was like a
13 week ahead, yes, I believe I was --
14 Q You got notification from Sidney
15 Blumenthal's office to attend a meeting?
16 A No, sir, I don't believe so.
17 Q Mike McCurry's office?
18 A It may very well -- it may be. It
19 wouldn't be uncommon, but -- I mean -- I
20 shouldn't say it wouldn't be uncommon. I'm
21 just saying it wouldn't surprise me if I have
22 been invited to a meeting when someone in the
239
1 press office had asked for one, but I don't
2 specifically recall one.
3 Q Ann Lewis?
4 A Yes, absolutely.
5 Q Who is, generally, in attendance at
6 these meetings Monday, Wednesday and Friday
7 from 9:15 that take about 15 minutes? Who,
8 generally, attends?
9 A The communications staff.
10 Q I'm talking about people, names.
11 A Ann Lewis, Stacey Spector, Ruby
12 Shamir, myself, my staff. I don't know if I
13 said Michael Waldman, his speech writing
14 staff, Sidney Blumenthal sometimes yes,
15 sometimes no, Ann Walker sometimes yes, I
16 mean, you know, again, and there are a couple
17 of people that do communications or speech
18 writing for like foreign policy and that's --
19 to the best of my ability to recall those are
20 the people that are at that meeting.
21 Q I take it you discussed the fact
22 that you were being deposed in Judicial
240
1 Watch's lawsuit in one of these staff
2 meetings, didn't you?
3 A No, sir, I did not.
4 Q Did anyone raise that issue?
5 A I don't believe so, but, frankly, I
6 haven't been at a couple of them this week
7 and I couldn't answer. I would be surprised
8 because I don't believe that anyone knows
9 that I'm being deposed, so --
10 Q Have you ever heard Judicial Watch,
11 Larry Klayman or Judge Lamberth mentioned in
12 any of these staff meetings?
13 A Not to the -- I have no
14 recollection of that, no.
15 Q So you don't remember? Might have
16 been discussed, but you just don't remember?
17 A I have no recollection of having --
18 ever had it come up, but you're right, I
19 couldn't say that it never came up.
20 Q At any of the meetings that you've
21 ever attended in the White House did you ever
22 discuss the Hillary Clinton health care task
241
1 force case that Judge Lamberth had?
2 MS. GILES: Objection. Relevance.
3 BY MR. KLAYMAN:
4 Q You can respond.
5 A I don't know.
6 Q Known as APS, A-P-S.
7 A I'm not familiar with that term.
8 I'm. generally, familiar with the case and I
9 don't believe I've ever had a meeting or been
10 at a meeting when that was discussed.
11 Q What was the last staff meeting you
12 attended? When was that?
13 A Probably Friday because I don't
14 believe there was one --
15 Q And who was at that meeting? Last
16 Friday you mean?
17 A Yes.
18 Q Who was at that meeting?
19 A I believe, generally, the people I
20 listed. I -- I don't believe Ann Walker was
21 there. I don't believe Sidney Blumenthal was
22 there, but beyond that, I believe that,
242
1 generally, the people I -- I outlined, the
2 communications staff, the speech writers.
3 Q Tell me specifically what was
4 discussed last Friday at that meeting.
5 MS. GILES: Can you wait for a
6 second?
7 I don't want the witness to answer
8 about the topics that were discussed, but if
9 you're going to get into more detail than
10 that, the topics will have to be --
11 BY MR. KLAYMAN:
12 Q Well, let's hear the topics. Tell
13 us all the topics that were discussed.
14 A It was a pretty quick meeting, to
15 my recollection, that Ms. Lewis had somewhere
16 else to be, and it was, basically, just
17 laying out the -- a quick overview of what
18 the schedule was going to be for the
19 president and what events were going to be
20 happening in the next seven or eight days.
21 Q So what were the general topics at
22 the events?
243
1 A As I said, the President's
2 schedule, the, you know, disaster relief
3 trip, the trip to Chili, those were,
4 basically, you know, what was happening on
5 the calendar of events.
6 Q Any discussion of Paula Corbin
7 Jones?
8 A No, sir.
9 Q When was the last meeting before
10 that meeting that you remember attending?
11 A Kind of blurs together here.
12 Probably the Monday of that week I believe.
13 Q And what were the general topics
14 discussed at that meeting? Well, let me ask
15 you who was at that meeting Monday?
16 A It's really hard for me to say, to
17 be honest with you. I mean it was the same
18 general crowd, but I -- I could not recall
19 exactly, you know, among those people who was
20 there, who wasn't there.
21 Q Same general crowd plus Blumenthal?
22 A I couldn't say that for sure. I
244
1 don't -- I don't recall.
2 Q And what were the general topics
3 discussed?
4 A Just laying the same -- same kind
5 of thing. I mean that's what the gist of the
6 meeting is, where is the President going on
7 Monday, Wednesday, Tuesday, you know, Monday,
8 Tuesday, Wednesday, and then check in with
9 the speech writers on who's working on those
10 remarks, some logistics about, you know,
11 events. That's, basically, my recollection.
12 I can't tell you specifically, but that's the
13 gist of it.
14 MS. GILES: I mean if you want to
15 ask him whether the topics were, you know,
16 FBI files or misuse of government files,
17 obviously you're entitled, but other than
18 that, the inner workings of the
19 communications office has no relevance to
20 this lawsuit.
21 MR. KLAYMAN: There have been
22 several times during this lawsuit that you've
245
1 questioned the relevance. The court has
2 issued orders which have tried to explain the
3 relevance of certain issues and certainly
4 it's relevant for me to find out how the
5 office functions, what they generally deal
6 with, and there are matters that go beyond
7 the FBI files that are relevant to this
8 lawsuit.
9 MS. GILES: Sure, other potential
10 misuse of government files I would agree is
11 relevant.
12 MR. KLAYMAN: For instance, Linda
13 Tripp. I mean we have an order recently on
14 the relevance of Linda Tripp.
15 MS. GILES: The potential misuse of
16 government files, I agree. If you want to
17 ask him about that, I welcome those
18 questions.
19 BY MR. KLAYMAN:
20 Q Well, let's talk about Linda Tripp.
21 Clearly there must be an entity
22 inside the White House that collected public
246
1 information about Linda Tripp when the story
2 broke. Who did that?
3 A No one to -- I disagree with the
4 assumption that there is someone and I don't
5 know of anyone.
6 Q Let's talk about Kathleen Willey.
7 Who in the White House gathered public
8 information about Kathleen Willey?
9 MS. GILES: Why is Kathleen Willey
10 relevant?
11 BY MR. KLAYMAN:
12 Q You can respond.
13 MS. GILES: Are you asking about
14 the release of her letter?
15 BY MR. KLAYMAN:
16 Q this is inappropriate. Certify it.
17 MS. GILES: Because, if you're
18 going to ask about misuse of government
19 files, again I --
20 MR. KLAYMAN: I don't want to spew
21 on the record. We spent two hours in court a
22 few weeks ago going over what was relevant
247
1 about Kathleen Willey.
2 MS. GILES: Absolutely, and we have
3 a court order.
4 MR. KLAYMAN: Okay? I'll indulge
5 you in this instance, but I don't want to get
6 into it each step of the way, but Kathleen
7 Willey's letter were obviously taken out of
8 her personnel files obviously.
9 MS. GILES: We now have a written
10 court opinion April 13th talking about what's
11 relevant in this lawsuit. FBI files matters
12 is your claim. Other potential misuse of
13 government files, then certainly those
14 topics --
15 MR. KLAYMAN: And the order also
16 talks about the fact that discovery is that
17 which is relevant or may lead to relevant
18 evidence.
19 MS. GILES: And the judge defined
20 what was relevant.
21 MR. KLAYMAN: I'm entitled to ask
22 the question. If you want to continue to try
248
1 to interrupt my questioning, I'll continue to
2 certify.
3 MS. GILES: What is the pending
4 question?
5 BY MR. KLAYMAN:
6 Q Who in the White House gathered
7 information on Kathleen Willey?
8 A Again, no one to my knowledge was
9 collecting information on Ms. Willey.
10 Q You had an opportunity to read the
11 testimony of Stacey Parker, did you not?
12 A Yes.
13 Q And you are aware that she keeps a
14 file for Mr. Begala called opposition
15 research from reading that deposition?
16 A Having -- having read her
17 deposition, I'm aware of that, yes.
18 Q And that in that file was
19 information about Newt Gingrich, Bob Barr,
20 Fred Thompson and perhaps others?
21 A I'm not familiar with the contents
22 of the -- of the file.
249
1 Q I'm talking about from reading her
2 deposition.
3 MS. GILES: The deposition speaks
4 for itself.
5 BY MR. KLAYMAN:
6 Q You can respond.
7 Then why did you give it to him?
8 Please respond.
9 A I'm trying to answer you. I'm,
10 generally, aware that she had such a file.
11 I'm not particularly aware of what it was
12 that was -- what was in it and what wasn't in
13 it.
14 Q Have you ever talked to Stacey
15 Parker?
16 A Certainly, yeah.
17 Q When did you first meet Stacey
18 Parker?
19 A That is a gray area for me.
20 Q What do you mean by gray area?
21 A I mean I know that I know her from
22 before she started working for Paul, but I
250
1 can't exactly be clear as to when it was I
2 met her. I don't know. I can't say when I
3 met her.
4 Q Did you meet her in a professional
5 capacity or a social capacity?
6 A This is why I'm saying it's a gray
7 area, but I vaguely think that I knew who she
8 was, but I don't know where it was that I met
9 her.
10 Q Now, she's testified that she's
11 come down to your office. You saw that in
12 her deposition, did you not?
13 A Yes.
14 Q And you can confirm that she
15 visited your office?
16 A Yeah, I'm sure -- I'm sure that she
17 has. I think one occasion when she first
18 began I was in the office while she was there
19 and I -- yeah.
20 Q When she visited the office, did
21 she see you or did she come to see somebody
22 else?