301
1 First Lady plays at the White House?
2 A That's a different question. Do I
3 have an interest in the -- I mean I think she
4 does a great job. I don't -- in the course
5 of my workday I don't have any reason to
6 think about it all that much.
7 Q Your job is to do research, right?
8 A Correct.
9 Q Your job is to know what's going
10 on, right?
11 A Correct.
12 Q You work for the communications
13 department, correct?
14 A Correct.
15 Q And communications is meant to
16 convey to the public what's happening at the
17 White House, correct? Isn't that one of the
18 roles?
19 A Yes, certainly.
20 Q And the First Lady plays a role at
21 the White House, correct?
22 A Absolutely.
302
1 Q So you're telling me you've never
2 had any discussions as to what role she plays
3 at the White House?
4 MS. GILES: Objection. Asked and
5 answered.
6 THE WITNESS: I mean have there
7 been discussions that the First Lady is doing
8 such and such an event or hosting a child
9 care conference or something, yes, but beyond
10 that I don't -- I don't know that I've had
11 discussions about her role.
12 BY MR. KLAYMAN:
13 Q Have there ever been discussions
14 that you have been privy to where people have
15 discussed what her role is vis-a-vis the
16 President's role? How they interact?
17 Whether she runs certain operations in the
18 White House? Whether she makes certain
19 decisions about what occurs in the White
20 House? You've never been privy to any of
21 that as head of your office or otherwise?
22 A I just -- I'm sorry. I find
303
1 that I'm trying to answer your question. It
2 seems very broad to me. Like I'm aware of
3 the First Lady and the fact that she's
4 involved with the administration, you know.
5 Her events are occasionally discussed as a
6 part of what's happening communications wise.
7 Beyond that I don't know that I have much
8 more knowledge of her.
9 Q Have you ever attended a meeting
10 where Mrs. Clinton was present?
11 A No, sir, I don't believe I have.
12 Q Do you know whether --
13 A Are you saying ever I was at a --
14 in the campaign -- meeting as in -- like I've
15 been in places where she and the President
16 are there for like a social function or they
17 both came to the campaign headquarters like a
18 week before the election and both said, you
19 know, made remarks, that kind of thing. I
20 have been in those situations, but I don't
21 recall any time where I've been in a meeting
22 where there has been any substance discussed.
304
1 Q Do you know whether Mrs. Clinton
2 has walk-in rights to staff meetings at the
3 White House?
4 A I really don't. I'm sorry.
5 Q Have you ever been in a meeting
6 with the President?
7 A I don't -- no, I have not.
8 Q Have you ever met the President?
9 A Yes, sir.
10 Q And where did you meet him?
11 A I met him once -- once in 1992. In
12 passing somebody introduced him to me and I
13 shook his hand and probably a couple of other
14 social occasions like Christmas parties or
15 something like that. And then on one
16 occasion during the debate preps in 1996 I
17 was introduced to him and shook his hand and
18 had a picture taken.
19 Q Have you or anyone else in the
20 White House ever communicated with Bob
21 Mulholland? Do you know who Bob Mulholland
22 is?
305
1 A I do know who he is.
2 Q When did you meet Mr. Mulholland?
3 A I don't know that I've ever met
4 him, but when I was at the DNC, I think I was
5 aware of him as a California like person, but
6 I have not had any contact --
7 Q And what was his role there?
8 A If I can finish my answer. I don't
9 believe I've had any contact with him
10 since -- certainly since coming to the
11 campaign or since -- basically, I don't think
12 since I left the DNC, I don't believe.
13 Q Has anyone else in your office or
14 the White House had contact with him in the
15 last six months?
16 A At my house or at the White House?
17 Q In your office.
18 A In my office. Not that I'm aware
19 of, no.
20 Q You're aware that in the last few
21 weeks he's threatened to dig up dirt and
22 smear republicans?
306
1 A I read that remark or saw that
2 remark reported on.
3 Q Has that been discussed in your
4 office, that remark?
5 A I believe briefly, yes.
6 Q Who was it discussed with?
7 A I think it might have been with
8 Glen and we both thought it was an incredibly
9 stupid remark.
10 Q Why did you think it was a stupid
11 remark?
12 A I just, you know, in the context
13 that I find myself sitting here, it's not the
14 kind of thing that anyone should be out there
15 trying to, you know, make political points
16 on, speaking off the cuff. There's a lot of
17 scrutiny about such things and it was not
18 appropriate.
19 Q Why in your opinion is it not
20 appropriate?
21 A Sitting here today? Because I
22 think that such remarks, you know, obviously
307
1 should be treated -- I mean talking about
2 doing that to people ought to be a serious
3 matter and I think -- I don't think that -- I
4 thought it was inappropriate given the
5 context of, you know, everything has gotten
6 to it and the scrutiny and the --
7 Q Well, you are aware that he said he
8 was only going to use public information,
9 correct?
10 A I'm not aware of that, no. I don't
11 recall.
12 Q If all he was going to use is
13 public information, there's nothing wrong
14 with that, is there?
15 MS. GILES: Objection as to
16 relevance. This is about Mr. Mulholland?
17 BY MR. KLAYMAN:
18 Q Based on your experience. Based on
19 your experience in doing opposition research,
20 if all he was going to do was use public
21 information, in your opinion there's nothing
22 wrong with that, is there?
308
1 A You know, you're asking my -- I
2 thought you were asking my personal opinion
3 about what I thought of his comments. I gave
4 you those.
5 Do I think that they're -- you
6 know, if he decided he was going to defend
7 the President all on his own out there and
8 speak out about it, I guess as an American
9 that's his right, to defend the President of
10 the United States.
11 Q I'm trying to separate out the fact
12 that you thought it was a stupid comment
13 because it attracted attention from whether
14 his comment was legally improper?
15 A You know, the reason I said I
16 thought it was a stupid comment is because I
17 knew you were going to ask me about it here.
18 I have no knowledge of it. I read it in the
19 newspaper or I saw it on CNN. That's it was
20 stupid to me, I mean, to be honest.
21 Q Why did you know I was going to ask
22 you about it?
309
1 A Because it's the type of thing
2 having, you know, read some depositions and
3 all, that I figured would come up.
4 Q Do you know where Mr. Mulholland
5 works in California?
6 A No, sir.
7 Q Do you know what city he's from?
8 A No, sir.
9 Q And why did Glen Weiner think it
10 was a stupid comment?
11 A I can't really -- I mean I assume
12 it was for the same reason that I did -- that
13 we -- but I cane speak for why he thought it
14 was stupid. I can't even say that -- that he
15 said it was stupid. I think that's what I
16 thought. I don't know that I'm attributing
17 quotes to him.
18 Q Are you aware that George
19 Stephanopoulos went on "This Week" with Sam
20 Donaldson and Cokie Roberts and made a
21 statement that White House allies are
22 whispering about an Ellen Roemech strategy?
310
1 A I am aware of that as I sit here
2 having read depositions, yes.
3 Q Did you know that at the time it
4 occurred on February 8, 1998?
5 A I may have a vague recollection of
6 it, but I don't really remember it all that
7 well. I don't believe I saw it myself, but I
8 know it got some coverage, so --
9 Q It was the topic of discussion in
10 the White House around that time?
11 A Not to my knowledge, no.
12 Q Was it a topic of discussion to
13 anybody else's knowledge that you know of?
14 A I can't really respond as to what
15 other people's knowledge was.
16 Q Have you ever pulled up the
17 transcript of George Stephanopoulos'
18 statement on February 8th?
19 A Yes, sir.
20 Q When did you pull the transcript
21 up?
22 A Sometime in the last four days.
311
1 Q And did someone ask you to do that
2 or did you do it on your own?
3 A I did it in -- as part of my --
4 well, let me be totally clear. I -- it was
5 E-mailed to me, as every transcript -- most
6 transcripts of news programs and Sunday
7 programs are E-mailed to me.
8 Q Go ahead.
9 A No.
10 Q Who E-mailed it to you?
11 A The -- I believe it was the
12 communications -- there's a guy who works in
13 communications who E-mails every -- after
14 every -- every day, you know, transcripts of
15 news programs.
16 Q Who is that?
17 A I believe his name is Dag Vega,
18 something like that, Dag.
19 Q Where does he work?
20 A I believe -- my best guess is that
21 he works in communications -- no, press
22 office or something. I think it's office.
312
1 And as a regular course of business to keep
2 people at the White House aware of what's
3 going on they E-mail out transcripts.
4 Q Who told him to E-mail this
5 transcript to you about George Stephanopoulos
6 and Ellen Roemech?
7 A I assume nobody did. I assume it
8 was not E-mailed to me, it was E-mailed White
9 House -- across the White House, as it is
10 after every Sunday with all the White House
11 transcripts -- I mean all the Sunday show
12 transcripts.
13 Q Correct me if I'm wrong, but I
14 thought you told me that it was just E-mailed
15 to you in the last few days?
16 A No, no, no. What I said was I
17 pulled it up and printed it up in the last
18 few days as a result of my document search
19 and the fact that that was the one of the
20 matters that you were interested in. It was
21 E-mailed to everyone who receives transcripts
22 at the White House at the time.
313
1 Q Had you seen that transcript on or
2 about February 8th or in that period,
3 February, March?
4 A I don't remember it, but as a
5 general practice, I try to read them -- I try
6 to read the transcripts from the Sunday shows
7 if I haven't been able to watch them, so it's
8 possible I read it. It's probably, you know,
9 I don't know, it may be likely that -- that I
10 would have attempted to read them any way.
11 Q When you read it in and about that
12 time period, did you take note of the remark
13 about Ellen Roemech and dragging down
14 adversaries?
15 A I didn't say that I read it at the
16 time. I said it was likely that I would have
17 attempted to read, you know, the six or seven
18 Sunday transcripts that come by. And I
19 don't -- actually don't recall -- I don't --
20 beyond the fact that I think it made some
21 news. I don't remember whether I read it in
22 a transcript or if I read it in a newspaper
314
1 clip.
2 Q At that time?
3 A Right.
4 MR. KLAYMAN: I'll show you what
5 I'll ask the court reporter to mark as
6 Exhibit 6. It's a copy of that transcript,
7 the February 8, 1998, show on "This Week,"
8 where Mr. Stephanopoulos made the referenced
9 comments.
10 (Janenda deposition Exhibit
11 No. 6 was marked for
12 identification.)
13 BY MR. KLAYMAN:
14 Q And I'm referring to page two of
15 that transcript, specifically halfway down,
16 where it says --
17 MS. GILES: Exhibit 6? Is that --
18 MR. KLAYMAN: Excuse me?
19 MS. GILES: Are we up to Exhibit 6?
20 MR. KLAYMAN: Yes.
21 BY MR. KLAYMAN:
22 Q Where it says halfway down, "Sam
315
1 Donaldson: We know what the White House
2 tactics are. I mean they're almost open
3 about it. Attack the press, and perhaps with
4 good reason, attack the independent counsel,
5 perhaps for some good reason, and
6 stonewalling the central issue, which is the
7 President of the United States. And if he
8 has nothing to hide, why is he hiding?" And
9 then George Stephanopoulos responds, "I agree
10 with that and there is a different long-term
11 strategy, which I think would be far more
12 explosive. White House allies are already
13 starting to whisper about what I'll call the
14 Ellen Roemech strategy."
15 Do you know what the reference to
16 Ellen Roemech is about?
17 A I do having read the -- read the
18 depositions for this deposition.
19 Q Did you know who Ellen Roemech was
20 before you read the depositions?
21 A I don't believe I did, no.
22 Q Did you know that or did you have
316
1 any knowledge that J. Edgar Hoover had used
2 FBI files against people back in the Kennedy
3 administration?
4 A I think I had a vague sense, having
5 taken history, that there was some issues
6 along those lines like Martin Luther King
7 or --
8 Q Right. And then Sam Donaldson
9 says, "I remember her." Stephanopoulos
10 responds, "You remember her?
11 "Sam Donaldson: Oh, yes.
12 "George Stephanopoulos: She was a
13 girlfriend of John F. Kennedy who also
14 happened to be an East German spy and Robert
15 Kennedy was in charge of getting her out of
16 the country and also getting J. Edgar Hoover
17 to go to the Congress and say don't you
18 investigate this because if you do, we're
19 going to open hope up everybody's closets.
20 And I think in the long running they have a
21 deterrent strategy on getting a lot of --
22 "George Will: Monica Lewinsky is
317
1 an East German spy?
2 "Sam Donaldson: No, but that's a
3 good point and are you suggesting for a
4 moment that what they're beginning to say is
5 that if you investigate this too much, we'll
6 put all of your dirty linen right on the
7 table. Every member of the senate? Every
8 member of the press corps?
9 "George Stephanopoulos:
10 Absolutely. The President said he would
11 never resign and I think some around him are
12 willing to take everybody down with him."
13 Now, I take it you have heard
14 discussions at the White House about taking
15 people down in the last six months, have you
16 not?
17 A No, sir.
18 Q Never heard anything like that?
19 A I have never heard anyone discuss
20 taking someone down, no.
21 Q And you have heard discussions in
22 the last six months about gathering
318
1 information about republicans, have you not?
2 A I guess I'd ask you to define that,
3 what you mean by that.
4 Q Just what I said.
5 A Again, I make --
6 Q I can't be more plain than that.
7 A As a research director of the White
8 House, I -- you asked me have I ever
9 collected research on republicans. That's
10 difficult because I would say certainly I
11 deal with issues all the time and I probably
12 have done research on where does Newt
13 Gingrich stand on X issue that's going to be,
14 you know, topic A next week. Have I ever
15 done, you know, any other kind of research?
16 No.
17 Q That's not question I asked you.
18 The question I asked you,
19 Mr. Janenda, is whether or not you heard
20 anyone at the White House ever discuss
21 gathering negative information on republicans
22 in the last six months.
319
1 A I don't think that's the question
2 you asked me, but, no, I have not. I can
3 answer that more clearly.
4 Q I changed it slightly.
5 A Okay.
6 Q I put in the word "negative." The
7 first one was just information.
8 A Right.
9 Q That's the first question. Did you
10 ever hear anyone say in the last six months
11 that we need to collect information on the
12 republicans? Yes or no?
13 A I can't give you a yes or no. I
14 don't recall anyone saying that. But where
15 are republicans on tax reform, something like
16 that.
17 Q Well, that's information, isn't it?
18 A Yes.
19 Q My question is very neutral. It
20 doesn't say collect information which is
21 negative to smear people. It says --
22 A Which is why --
320
1 Q Have you ever heard anyone say in
2 the last six months let's get some
3 information on Republicans?
4 A And I was trying to answer that
5 question.
6 Q The answer is yes, you've heard
7 that, haven't you?
8 A No, I've not heard anyone say get
9 some information on republicans, no. Have I
10 had someone ask me -- I'm not trying to split
11 hairs. I'm just trying to -- I mean this is,
12 you know -- I do issues on -- I do research
13 on issues. Occasionally certainly there are
14 republicans who come up in the course of
15 doing that research.
16 Q Let me ask you this: I'm asking
17 you the question calmly, aren't I?
18 A Yes, absolutely.
19 Q And you know when why I'm asking
20 the questions that way, right?
21 A I do. That's why I'm trying to be
22 particularly careful.
321
1 Q You know that I'm searching for
2 information about gathering dirt on
3 republicans. You know that's why I'm here,
4 right?
5 A If you say so.
6 Q Isn't that your understanding?
7 MS. GILES: You're asking him what
8 his understanding of your intent is?
9 MR. KLAYMAN: Yeah.
10 THE WITNESS: I can't --
11 MS. GILES: You can testify as to
12 your personal knowledge.
13 BY MR. KLAYMAN:
14 Q You have formed an opinion as to
15 why I'm here, haven't you?
16 A No, I haven't. I'm here and I'm
17 trying to answer every question you ask me.
18 Q You have discussed Larry Klayman
19 and Judicial Watch with some people, haven't
20 you?
21 A No, I --
22 Q I'm not talking about your counsel
322
1 but with other people.
2 A Have I ever discussed you ever?
3 Q Yeah.
4 A I don't know. I couldn't say it
5 never came up. I mean you've been in the
6 papers.
7 Q Have you ever seen me on
8 television?
9 A Probably have, yeah.
10 Q Have you ever seen democrat
11 consultants or members of the White House say
12 Larry, you're a Clinton hater? You've heard
13 that, haven't you?
14 A It wouldn't surprise me, but I'm
15 saying I don't particularly recall that.
16 Q You have heard people say I'm out
17 to get the President, right?
18 A I don't think that I have, no.
19 Q You haven't heard that.
20 But is it your impression that I'm
21 trying to find out whether you or anyone else
22 in the White House has been digging up
323
1 negative information on republicans and other
2 perceived adversaries?
3 MS. GILES: The questions is about
4 his understanding of your intent. This is
5 clearly irrelevant.
6 MR. KLAYMAN: It is not irrelevant.
7 It gets to his state of mind, it gets to his
8 bias in answering these questions.
9 BY MR. KLAYMAN:
10 Q You're aware of that, aren't you?
11 That is your impression, is it not?
12 A Honestly, you know, I'm attempting
13 to answer every question as honestly and
14 completely as I can, you know, in my first
15 deposition ever. So I'm not doing anything
16 other than, you know --
17 Q I'm trying to be direct with you
18 and I'm trying to be diplomatic and I'm
19 trying to get the answers.
20 A And I'm trying to give you those
21 answers.
22 Q But I find it hard sometimes to
324
1 have the questions answered and the reason
2 I'm probing here, to answer your counsel's
3 question, is because frequently those
4 questions aren't answered and I'm wondering
5 if it's because you think I'm looking for
6 something.
7 A I don't -- what is the -- I don't
8 understand your question.
9 Q The question is whether your belief
10 is I'm looking for something that could prove
11 that the White House is out to get
12 information to smear perceived adversaries.
13 A Are you asking what is my
14 impression --
15 Q Yeah.
16 A -- of what you're doing?
17 Q Yeah. Is that your impression?
18 A You want my impression?
19 Q Yeah, that's all I want.
20 A You know, I think that what
21 happened or allegedly happened with -- with
22 the Filegate matter was a very serious thing
325
1 and I think that, you know, I think wrongly
2 you're trying to find out whether I would
3 ever or have ever done anything improper with
4 either an FBI file or any other kind of
5 government file. I think that's what you
6 want to ask me and I'm glad to have an
7 opportunity to tell you that I have never
8 done such a thing and I don't know anyone who
9 has done such a thing. That's my impression
10 of --
11 Q So you think I'm out to get you?
12 A I didn't say that.
13 MS. GILES: Objection.
14 Mischaracterizes the testimony.
15 THE WITNESS: I give you the answer
16 that I think you were --
17 BY MR. KLAYMAN:
18 Q You think I'm out to prove that
19 information has been misused by the White
20 House about perceived adversaries?
21 A I don't know how my -- I gave you
22 my impression. I'm just not comfortable
326
1 continuing to guess what it is that you're --
2 Q I'm not asking you to guess. I'm
3 asking for your own belief.
4 MS. GILES: As to?
5 BY MR. KLAYMAN:
6 Q Larry Klayman is here to uncover
7 that your office misused Privacy Act
8 information against adversaries of the
9 Clinton administration.
10 A No, I -- I think that, you know,
11 your case deals with the FBI files matter and
12 you're -- you're interested in whether or not
13 anything like that has, you know, happened
14 again or whatever and I'm happy to tell you
15 and have the opportunity to tell you, as I
16 said, that I am not aware of any such thing
17 having happened.
18 Q Now, at the time that
19 Stephanopoulos made this statement, you must
20 have overheard conversations in the White
21 House about Stephanopoulos, correct?
22 A I mean I can't say that I did. I
327
1 think that -- no, I can't say that I did.
2 Q This was a topic of conversation,
3 was it not? George going on T.V. and saying
4 that the White House allies were whispering
5 about a strategy to destroy adversaries?
6 A Was there a conversation about this
7 at the White House? Is that --
8 Q Yeah, that you're aware of.
9 A I don't believe so -- I mean I --
10 not to my knowledge. It wouldn't surprise
11 me. But I don't recall specifically having
12 overheard such a conversation.
13 Q Now, this statement, in your
14 opinion, is a pretty significant statement,
15 is it not? It's an important statement?
16 A Frankly, I tend to -- not trying to
17 be flip, but, again I tend to sort of lump
18 George in with the other 15 people who are on
19 Sunday T.V. every Sunday.
20 Q Which is?
21 A Which is what? What do I think of
22 those people?
328
1 Q The way you lump them in. You lump
2 them in as crackpots or what?
3 A Well, I -- you know, they're
4 pundits. It's their opinion, you know, I
5 don't know where they -- what they --
6 Q Have you ever heard George
7 Stephanopoulos referred to not as a
8 commentator but a common traitor at the White
9 House?
10 A I have never heard that, no.
11 Q Based on your understanding of what
12 opposition researchers are supposed to do,
13 it's not to gather information to destroy
14 adversaries, correct?
15 A No, sir, only because I think your
16 terms are -- they're loaded terms. I mean
17 they're -- no, I would disagree with that.
18 Q How would you disagree?
19 A What do I think an opposition
20 researcher's job is?
21 Q Well, I was trying to say to you
22 that it's not an opposition researcher's job
329
1 to get information to smear and destroy
2 people. You agree with that, right?
3 A That it is not their job?
4 Q Yes.
5 A Correct.
6 Q And based on your experience in
7 working in politics and at the White House,
8 it wouldn't be proper, would it, to try to
9 take everybody down that opposes you with
10 negative information?
11 MS. GILES: Objection. Vague and
12 ambiguous terms, "take them down."
13 BY MR. KLAYMAN:
14 Q Well, let me use George's phrase.
15 Let me use George Stephanopoulos' phrase.
16 "The President said he would never resign and
17 I think some around him are willing to take
18 everybody down with him."
19 Now, based on your experience in
20 working in politics and the White House,
21 based on your ethics and moral values, is
22 that something you would do, you would
330
1 participate in?
2 A No, sir, it's not, but, again, it's
3 something that somebody said on a Sunday
4 show. I don't give it a whole lot of
5 credence one way or another. But, no, it's
6 not something I would think was a good thing
7 or positive thing.
8 Q And based on your knowledge, it
9 wouldn't be a legal thing, correct? I'm not
10 asking you to make a conclusion as a lawyer,
11 but just based on your own belief is that
12 legal?
13 A I would just hesitate to venture
14 into making legal -- I'm sorry. I just -- I
15 don't know what the laws are.
16 Q What's your feeling about that?
17 A About what?
18 Q Whether destroying people, taking
19 everybody down is legal?
20 A I don't know what that means. I
21 don't know -- I honestly have no idea what
22 that means. What does take people down mean?
331
1 I just don't know what it means.
2 MS. GILES: And he's not, in fact,
3 a legal expert, so he can't testify as to
4 what's legal.
5 MR. KLAYMAN: Excuse me?
6 MS. GILES: He is not a legal
7 expert.
8 MR. KLAYMAN: I already qualified
9 that I'm not asking for a legal opinion.
10 MS. GILES: You are asking him
11 whether it's legal.
12 BY MR. KLAYMAN:
13 Q Do you know what the Privacy Act
14 is?
15 A Not particularly, no.
16 Q Have you ever heard of it?
17 A I've heard of it, yeah.
18 Q Are you aware there's certain
19 information that the government collects
20 about people that can't be released publicly?
21 A That -- I mean, I'm just saying I'm
22 not aware of it as a law, but certainly.
332
1 Q What I'm saying is Stephanopoulos'
2 statement, whether he was making it off the
3 cuff or whether he had actual knowledge, if
4 it's true, that's a very significant
5 statement, is it not?
6 MS. GILES: Which statement are we
7 talking about?
8 MR. KLAYMAN: It's a very important
9 statement. The one about taking everybody
10 down that I just read.
11 THE WITNESS: You draw certain
12 conclusions from that statement and I may
13 draw different ones and I don't know what he
14 means by take people down. I just -- I find
15 it hard -- I'm not trying to be evasive. I
16 just find it hard to answer about what he's
17 talking about.
18 BY MR. KLAYMAN:
19 Q Are you aware that Stephanopoulos
20 is in frequent contact with James Carville?
21 You read the deposition?
22 A Beyond having read the deposition,
333
1 it doesn't surprise me. They're good friends
2 to the best of my knowledge.
3 Q And from reading the deposition
4 you're aware that Mr. Stephanopoulos talks to
5 Carville as frequently, seven or so times a
6 day?
7 A Beyond whatever -- I don't know
8 whether that's what it said in the
9 deposition, but beyond whatever it said in
10 the deposition I don't have any knowledge of
11 it. But, again, it doesn't surprise me.
12 Q And you have observed Mr. Weiner
13 frequently talking to Mr. Carville on the
14 telephone, have you not?
15 A No, sir.
16 Q Do you monitor the telephone
17 records of your office? Do you ever review
18 them?
19 A No, sir.
20 Q Do you have access to them?
21 A I have no idea. What do you mean?
22 Like who's called who?
334
1 Q Excuse me?
2 A What do you mean? I don't know
3 what you mean by telephone records.
4 Q I mean, you're aware that the
5 telephone company or an internal computer can
6 list the calls that are made on a telephone?
7 MS. GILES: Maybe the court
8 reporter should read the last question that's
9 pending.
10 (The reporter read the record as
11 requested.)
12 THE WITNESS: No. Certainly at
13 home. I guess I'm not aware of what the
14 system is.
15 BY MR. KLAYMAN:
16 Q So you don't know how many times
17 Mr. Weiner talks to Mr. Carville a day, if at
18 all?
19 A If at all, I am not aware of it.
20 I've never --
21 Q Even though -- I'm sorry.
22 A No, I've never asked for or, you
335
1 know, looked at his phone records, no.
2 Q You don't know one way or the
3 other?
4 A Correct.
5 MS. GILES: I need a two-minute
6 break. Is now a good time?
7 MR. KLAYMAN: Sure.
8 VIDEO TECHNICIAN: We're going off
9 video record at 3:31 Eastern Standard Time.
10 (Recess)
11 VIDEO TECHNICIAN: We're back on
12 video record at 3:38 Eastern Standard Time.
13 BY MR. KLAYMAN:
14 Q Have you or anyone at the White
15 House ever had a communication with Murray
16 Waas?
17 A Communication?
18 Q Or received anything from him or
19 talked to him or anything like that.
20 A Again, I -- answering for myself I
21 can say no. Answering for the White House, I
22 couldn't do that.
336
1 Q Do you know who Murray Waas is?
2 A He's a writer, author.
3 Q Have you ever seen him in the White
4 House?
5 A I wouldn't know him if I bumped
6 into him.
7 Q Have you or anyone else had any
8 contact with anyone from Salon Magazine other
9 than pulling off the Web site?
10 A No. Again, I can't -- I can't
11 answer for the entire White House, put
12 personally not to my knowledge, no.
13 Q Have you or anyone from the White
14 House ever communicated or had any contact
15 with Joe Conason of The New York Observer?
16 A I don't -- I mean I'm familiar with
17 him as a writer, but I -- I don't know of
18 anyone who's had contact with him, no.
19 Q Have you or anyone at the White
20 House ever communicated with or had any
21 contact with Lars Eric Nelson?
22 A Again, I'm familiar with his
337
1 writing, but I'm not -- I don't know -- I
2 have not had any contact with him and I don't
3 know of anyone who has had contact with him.
4 Q Same question with regard to Peter
5 Finn?
6 A Peter?
7 Q Finn. Did you ever hear of Peter
8 Finn?
9 A I'm not familiar with that name,
10 no. No, I haven't, honestly.
11 Q Are you aware of something called
12 the communications stream of conspiracy
13 commerce?
14 A The I'm sorry?
15 Q The communication stream of
16 conspiracy commerce. Did you ever hear
17 anything like that, a research project that
18 was prepared inside the White House about
19 right wing media food chains?
20 A Media food chain. Yeah, I vaguely
21 recall, although I'm not sure. Do you have
22 a -- do you have it? Do you know what --
338
1 MR. KLAYMAN: I can give you
2 something that looks like it. Let's mark it
3 as -- this is a reprint of it -- as Exhibit
4 7.
5 (Janenda Deposition Exhibit
6 No. 7 was marked for
7 identification.)
8 MR. KLAYMAN: I think y'all have
9 seen this thing before.
10 MS. ZIEGLER: Actually, I haven't.
11 MR. KLAYMAN: You haven't. Here's
12 a complimentary copy.
13 BY MR. KLAYMAN:
14 Q Take your time and leaf through
15 that. This is a reprint of it, but it
16 contains the White House version --
17 A Off the top of my head this is
18 not whatever I had in my head. I've never
19 seen this before.
20 Q Inside this thing, this was a
21 reprint by the Western Journalism Center,
22 contains the compilation of the White House.
339
1 I'm just asking whether this refreshes your
2 recollection as to whether you or anyone that
3 you know of worked on a report inside the
4 White House over how alleged right wing media
5 communicates.
6 A This is -- there's something else
7 in here besides the Western Journalism --
8 Q Yeah.
9 A -- because I've not seen this
10 before. I don't -- no, I'm not familiar with
11 this.
12 Q Are you familiar with anyone in the
13 White House having researched how right wing
14 media communicates?
15 A No, sir.
16 Q Never heard of that?
17 A No, I -- I mean I have a vague
18 recollection that there was something written
19 in the paper, something about it, something,
20 but I don't -- I've never seen this before.
21 Q Have you or anyone else at the
22 White House ever had contact with a Larry
340
1 Potts?
2 A That name doesn't ring any bills
3 for me.
4 Q Gloria Sutherland?
5 A Again --
6 MS. GILES: Just to clarify, he can
7 only speak for his own person knowledge.
8 THE WITNESS: Right. I'm sorry.
9 MS. GILES: Not the whole White
10 House.
11 BY MR. KLAYMAN:
12 Q Yeah, everything is within your own
13 personal knowledge.
14 Has your office ever had any
15 contact or communication with Robert Bennett?
16 A Not to my knowledge, no.
17 Q David Kendall?
18 A No. I think you already asked me
19 that. No.
20 Q Have you ever met or had any
21 contact with Marsha Scott?
22 A I wouldn't want to say no. I think
341
1 she may still work at the White House but I
2 don't have any recollection of having met
3 her, no.
4 Q Has she ever had any contact with
5 your office to the best of your knowledge?
6 A I hate to speculate, but if she
7 still works at the White House, it might be a
8 woman who was involved with the Hormel
9 nomination whose name I may have heard on a
10 phone call or something, but I'm not
11 positive.
12 Q Has your office done research on
13 the Hormel nomination?
14 A Yeah, I -- yeah, certainly.
15 Q What issue in particular did you
16 research concerning that nomination?
17 MS. GILES: The details about
18 nominees is very sensitive and other than
19 asking if they used FBI files or
20 inappropriately used government files,
21 anything along those lines, I'm instructing
22 the witness not to get into details.
342
1 BY MR. KLAYMAN:
2 Q Well, let me ask this question:
3 Obviously you're aware of what the
4 controversy is concerning Mr. Hormel, right,
5 without getting into it, just generally
6 speaking?
7 A I know that there are republicans
8 who oppose his nomination, yes.
9 Q And do you know why?
10 A Speaking on their behalf?
11 Q No, based on what you have
12 knowledge of.
13 A Yeah, because he's gay, as far as I
14 know.
15 Q And what I'm going to ask you is
16 whether you have ever looked into or know
17 whether anyone else has looked into that
18 issue with regard to republicans.
19 A Restate the question.
20 MS. GILES: Mr. Hormel or --
21 BY MR. KLAYMAN:
22 Q No, Republicans. Are you aware of
343
1 anyone at the White House commissioning
2 research to find out whether Republicans had
3 similar sexual preferences?
4 A No, sir, absolutely not.
5 Q Is it ever your job or anybody
6 else's that you know of to try to blunt
7 criticism that Republicans or other political
8 adversaries may level by showing that, in
9 fact, they do the same things?
10 A On policy grounds I'm sure, you
11 know, something -- like if we're going to
12 be -- yeah, it's probably happened, sure.
13 Q Did your office play a role in
14 researching whether republicans took foreign
15 money to, for instance, during the last
16 campaign?
17 A No, sir. I'm confused as to what
18 you're asking.
19 Q Well, I'm getting to the --
20 A While I worked at the White House?
21 Q In other words, the old everybody
22 does it defense, which we hear very
344
1 frequently in political circles no matter
2 what your political persuasion.
3 A No.
4 Q You've heard people raise that as a
5 defense everybody does it, right?
6 A I'm aware that, yeah, I've heard it
7 before.
8 Q But who in the White House does
9 that kind of research, the everybody does it
10 research we'll call it?
11 A It's a term I couldn't possibly
12 define. And your specific question, but I'll
13 answer it, is who, if anyone, in the White
14 House does research on campaign finance --
15 Q Or on any issue.
16 A -- whatever, I'm not aware of what
17 -- but just to answer that question.
18 Q I mean, let's say there's an
19 allegation that --
20 A Can I answer that question?
21 Q Sure, sure.
22 A I'm not aware that anyone -- you
345
1 know, people read the newspapers, but I'm not
2 aware of anyone having, you know, in the
3 White House having done that.
4 Q Let me just pose a hypothetical.
5 I'm not trying to be funny or anything, but
6 suppose an allegation is raised that somebody
7 does something in the White House that's
8 raised by a political opponent that that
9 political opponent is saying is
10 inappropriate. Is there anyone at the White
11 House or any office of the White House that
12 would be in charge with researching to show
13 that the person who made that accusation does
14 the same stuff?
15 MS. GILES: Objection.
16 Hypothetical.
17 BY MR. KLAYMAN:
18 Q You can respond.
19 A No, to the best of my knowledge.
20 Q That stuff doe snot go on at the
21 White House, that kind of research?
22 A No, I don't think so in terms of
346
1 tasking somebody to do research, no. I'm not
2 saying that there aren't people who talk to
3 reporters who don't say such things. I'm
4 just saying that I don't -- I'm not aware of
5 any of office that is tasked with -- and to
6 my knowledge there is no such office.
7 Q What does it go on, on a
8 person-by-person basis?
9 A Again, I'm just trying to be clear.
10 I can't -- I'm just saying --
11 Q Well, let me give you an example.
12 A I can answer there's no office and
13 it's not my office.
14 Q During Thompson's campaign finance
15 investigation last fall -- you're aware of
16 that, right?
17 A Uh-huh, yes.
18 Q Were you ever asked to do any
19 research by anyone in the White House about
20 campaign finance issues?
21 MS. GILES: Objection. Campaign
22 finance isn't relevant. Again, if you want
347
1 to get into the types of research he did,
2 whether he looked at FBI files, government
3 files --
4 MR. KLAYMAN: I'm trying to figure
5 out how this thing operates. I mean so far
6 after five hours of deposition I still can't
7 figure out what they.
8 MS. GILES: He's been very clear of
9 what he does. If you want to get --
10 MR. KLAYMAN: And, frankly, I can't
11 figure out what his role is.
12 THE WITNESS: I'm happy --
13 MR. KLAYMAN: So I'm having
14 difficulty.
15 THE WITNESS: Is that a question?
16 I'm h happy to restate what it is my office
17 does, which is to track the administration of
18 accomplishments, to vet people who are coming
19 to Presidential events, to help prepare paper
20 for Presidential events that come out of the
21 communications office and, generally, be
22 aware of what's happening in the world. And
348
1 I'm sure others, you know, as -- as they come
2 up.
3 BY MR. KLAYMAN:
4 Q Well, I'm asking you as well. I
5 know that's what you claim that's what your
6 office does. But are there other offices,
7 based on your experience in the
8 communications department, that do opposition
9 research on what your opponents are doing?
10 A No, I'm not aware of any such
11 office.
12 Q Now, you are aware during the
13 campaign finance hearings last fall that
14 people like Lonnie Davis, out of the White
15 House Counsel's Office, were on T.V.
16 frequently delineating how republicans had
17 done the same types of thing the republicans
18 were accusing democrats of doing.
19 A Sure.
20 Q You are aware of that?
21 A I am aware of that.
22 Q Now, do you have any knowledge as
349
1 to whether Mr. Davis was getting his
2 research?
3 A I really wouldn't want to answer
4 for Mr. Davis.
5 Q I'm not asking you to answer for
6 Mr. Davis. I asked whether you had any
7 knowledge as to where that research emanated
8 upon which he was then able to make the
9 statements he made.
10 A I'm sure that the Democratic
11 National Committee, you know, was doing work
12 that -- for -- for democrats who were trying
13 to support the President and the
14 administration during that period. It
15 wouldn't surprise me he were reading
16 materials distributed by the Democratic
17 National Committee.
18 Q Do they regularly supply the White
19 House with that type of research, they
20 meaning the DNC?
21 A The DNC, you know, as far as I
22 know, routinely puts out press releases and
350
1 other information that's available to anybody
2 as far as I know.
3 Q Do they routinely send over
4 opposition research to the White House?
5 A I never said that they send over
6 opposition research to the White House.
7 Q That's what I just asked you.
8 That's what I just asked you.
9 A You asked me -- all right. Not --
10 not to, you know, not to my knowledge. I
11 mean it's certainly routine for the DNC,
12 whatever they are putting out, you know, for
13 it to also go to the White House, but --
14 Q You were the head of the research
15 office at the DNC?
16 A I was the deputy director.
17 Q Right. And then you were the head
18 of the research office for the campaign?
19 A Correct.
20 Q And that is the type of thing that
21 you did in those two jobs, wasn't it, to show
22 that republicans were doing the same things