1


       1            UNITED STATES DISTRICT COURT
                        DISTRICT OF COLUMBIA
       2
            -----------------------------x
       3    CARA LESLIE ALEXANDER et al.,:
                                         :
       4                Plaintiffs,      :
                                         :
       5                                 :
                       v.                : Civil Action
       6                                 : No. 96-2123 (RCL)
            FEDERAL BUREAU OF            :
       7    INVESTIGATION et al.,        :
                                         :
       8                Defendants.      :
            -----------------------------x
       9
                                              Washington, D.C.
      10
                                     Wednesday, March 18, 1998
      11

      12    Deposition of

      13                ELEANOR STACY PARKER

      14    a witness, called for examination by counsel

      15    for Plaintiffs pursuant to notice and

      16    agreement of counsel, beginning at

      17    approximately 10:16 a.m. at the offices of

      18    Judicial Watch, Inc., 501 School Street S.W.,

      19    Washington, D.C., before Sherry C. Knox,

      20    notary public in and for the District of

      21    Columbia, when were present on behalf of the

      22    respective parties:








                                                              2


       1    APPEARANCES:

       2       On behalf of Plaintiffs:

       3          LARRY KLAYMAN, ESQUIRE
                  Judicial Watch
       4          501 School Street S.W., Suite 725
                  Washington, D.C.  20024
       5          (202) 593-8442

       6       On behalf of Government Defendants:

       7          ELIZABETH J. SHAPIRO, ESQUIRE
                  ANNE L. WEISMAN, ESQUIRE
       8          Federal Programs Branch
                  Civil Division
       9          United States Department of Justice
                  901 E Street N.W.
      10          Washington, D.C.  20530
                  (202) 514-5302
      11
                  JON PIFER, ESQUIRE
      12          Office of the General Counsel
                  Federal Bureau of Investigation
      13          935 Pennsylvania Avenue N.W.
                  Washington, D.C.  20535
      14          (202) 324-4522

      15          SALLY PATRICIA PAXTON, ESQUIRE
                  Special Associate Counsel to the President
      16          The White House
                  Washington, D.C.
      17          (202) 456-5079

      18       On behalf of Defendant Hillary Rodham Clinton:

      19          MARCIE.R ZIEGLER, ESQUIRE
                  Williams & Connolly
      20          725 12th Street N.W.
                  Washington, D.C.  20005
      21          (202) 434-5803

      22                    *  *  *  *  *








                                                              3


       1                   C O N T E N T S

       2    EXAMINATION BY:                            PAGE

       3       Counsel for Plaintiffs                     5

       4    PARKER DEPOSITION EXHIBITS:

       5    No.  1 - Judicial Watch Press Release       138

       6    No.  2 - Broadcast Transcript               153

       7    No.  3 - Begala Declaration                 257

       8    No.  4 - Notice of Begala Deposition        268
                      Duces Tecum, Attachments
       9
            No.  5 - Notice of Parker Deposition        289
      10              Duces Tecum, Attachments

      11    No.  6 - March 1998 Calendar                299

      12    No.  7 - October 1997-April 1998            302
                      Calendar
      13
            No.  8 - Selected Investigations List       306
      14
            No.  9 - "Gingrich Keeps His Promise"       306
      15              Report

      16    No. 10 - Appointments Schedule              312

      17    No. 11 - Federal Bureau of                  354
                      Investigation (FBI) Press
      18              Release

      19    No. 12 - FBI General Counsel Report         355

      20    No. 13 - Response to Notice of
                      Deposition Duces Tecum
      21

      22                    *  *  *  *  *








                                                              4


       1                P R O C E E D I N G S

       2              THE VIDEO SPECIALIST:  Good

       3    morning.  This is the video deposition of

       4    Eleanor Stacy Parker taken by the counsel for

       5    the plaintiff in the matter of Cara Leslie 

       6    Alexander et al. v. Federal Bureau of 

       7    Investigation et al. in the U.S. District

       8    Court for the District of Columbia, Case

       9    Number 96-2123 (RCL) held in the offices of

      10    Judicial Watch, 501 School Street Southwest,

      11    Washington, D.C., on this date, March 18,

      12    1998 and at the time indicated on the video

      13    screen, which is 10:16 a.m.

      14              My name is Sylvanus Holley.  I'm

      15    the videographer.  The court reporter today

      16    is Sherry Knox from the firm of Beta

      17    Reporting.

      18              Will counsel now introduce

      19    themselves?

      20              MR. KLAYMAN:  Larry Klayman on

      21    behalf of Judicial Watch, general counsel.

      22              MR. FITTON:  Tom Fitton, legal








                                                              5


       1    assistant, Judicial Watch.

       2              MS. SHAPIRO:  Elizabeth Shapiro

       3    representing the witness, Executive Office of

       4    the President, and the FBI.

       5              MS. PAXTON:  Sally Paxton with the

       6    White House.

       7              MS. WEISMANN:  Anne Weismann

       8    representing the witness.

       9              MS. ZIEGLER:  Marcie Ziegler

      10    representing Hillary Clinton.

      11              THE VIDEO SPECIALIST:  Will the

      12    court reporter please swear in the witness?

      13    Whereupon,

      14                ELEANOR STACY PARKER

      15    was called as a witness and, having been

      16    first duly sworn, was examined and testified

      17    as follows:

      18              EXAMINATION BY COUNSEL FOR PLAINTIFFS

      19              BY MR. KLAYMAN:

      20         Q    Will you please state your name?

      21         A    Eleanor Stacy Parker.

      22              MR. KLAYMAN:  As a preliminary








                                                              6


       1    matter, I just put on the record my

       2    continuing objection should Ms. Paxton, on

       3    behalf of White House counsel's office,

       4    confer with the witness.  I understand from

       5    previous depositions that she will not agree

       6    not to confer with the witness and the reason

       7    for that is she is a material witness in this

       8    case.

       9              MS. SHAPIRO:  We understand your

      10    objection.

      11              MR. KLAYMAN:  Throughout the

      12    deposition.  Throughout the deposition.

      13              MS. SHAPIRO:  We understand your

      14    objection, and we will not abide by it.  We

      15    don't agree.

      16              MR. KLAYMAN:  Certify this.

      17              MS. SHAPIRO:  Could I also for the

      18    record serve you with Ms. Parker's response

      19    to your document request?  I'm handing a copy

      20    to legal assistant.

      21              MR. KLAYMAN:  Do you have extra

      22    copies of this or will we need to make extra








                                                              7


       1    copies if we mark it as an exhibit?

       2              MS. SHAPIRO:  I think I have one

       3    extra copy.

       4              MR. KLAYMAN:  Do you want a copy,

       5    Ms. Ziegler, right now or would you wait

       6    until the end?

       7              MS. ZIEGLER:  I can wait until the

       8    end.

       9              MR. KLAYMAN:  All right.  Thank

      10    you.

      11              BY MR. KLAYMAN:

      12         Q    Ms. Parker, how old are you?

      13         A    Twenty-three.

      14         Q    Where were you born?

      15         A    Detroit, Michigan.

      16         Q    Where did you go to high school?

      17         A    Troy High School in Troy, Michigan.

      18         Q    And when did you graduate?

      19         A    In 1992.

      20         Q    And what happened in 1992?  Did you

      21    go on to higher education or did you get a

      22    job professionally?








                                                              8


       1         A    Are you referring to the summer or

       2    the fall?

       3         Q    Let's say the summer.

       4         A    I volunteered in two different

       5    places.  I volunteered for Sandy Levin for

       6    Congress, and I also volunteered for the

       7    Oakland County Democratic party.

       8         Q    And what specifically did you do?

       9         A    I did menial intern duties for the

      10    Sandy Levin campaign.  I -- I assembled

      11    clips.  I did occasional odd tasks.  It's --

      12    I don't remember very well exactly what I

      13    did.

      14         Q    How did you get the job?  Did you

      15    know somebody?

      16         A    No.  I saw their office that was

      17    open and I went in and said that I wanted to

      18    help.

      19         Q    And what happened after the summer,

      20    if anything?  Did you go to a university or

      21    did you get another job?

      22         A    In the fall, I began at the George








                                                              9


       1    Washington University.

       2         Q    Here in Washington, D.C.?

       3         A    Correct.

       4         Q    And what year was that again?

       5         A    That was 1992.

       6         Q    And what did you major in at George

       7    Washington?

       8         A    I began by majoring in

       9    international affairs or relations, I don't

      10    remember how they distinguish it there.  And

      11    in -- and then the next year, I changed my

      12    major to political communication.

      13         Q    What year did you graduate, if at

      14    all?

      15         A    I finished in 1996.

      16         Q    And what, if anything, did you do

      17    in 1996 professionally speaking?

      18         A    When I graduated, I temped until I

      19    could begin campaign work, and in August --

      20         Q    Who did you temp for?

      21         A    Help, Unlimited.

      22         Q    And how long did you stay there?








                                                              10


       1         A    I believe it was through the end of

       2    August.  I was waiting to get my first

       3    campaign assignment.

       4         Q    What type of jobs did you do for

       5    Help, Unlimited?

       6         A    Clerical and data entry jobs.

       7         Q    Who was your immediate supervisor

       8    at Help, Unlimited?

       9         A    I don't remember their names.

      10         Q    Do you remember their first names?

      11         A    Not at this time.

      12         Q    Do you remember the names of some

      13    of the companies or individuals you worked

      14    for when you worked for Help, Unlimited?

      15         A    Environmental Defense Fund.

      16         Q    Was there a person there that you

      17    worked for?

      18         A    I don't remember specifically their

      19    names.  I worked primarily as a receptionist,

      20    and I don't remember their names.

      21         Q    You're aware you're under oath, are

      22    you not?








                                                              11


       1         A    Oh, yes.

       2         Q    And being under oath means that you

       3    have to tell everything you remember?

       4         A    Correct.

       5              MS. SHAPIRO:  Objection.  She

       6    doesn't need to be reminded she's under oath.

       7    She took an oath when she began the

       8    deposition.

       9              MR. KLAYMAN:  Well, the oath is a

      10    very formalistic recitation of law.  I just

      11    wanted to make sure she understood as a

      12    general sense.

      13              BY MR. KLAYMAN:

      14         Q    You are aware that you can't forget

      15    and say you forgot if in fact you remember?

      16    You're aware of that?

      17         A    I'm aware.

      18         Q    Did you work for any other entities

      19    or individuals other than the Environmental

      20    Defense Fund?

      21         A    Yes, I did.

      22         Q    Which ones?








                                                              12


       1         A    Off the top of my head, I can't

       2    remember.

       3         Q    Before your deposition today, did

       4    you talk to anybody about it other than the

       5    attorneys sitting at this table?

       6         A    Yes.

       7         Q    Who?

       8         A    I told my mother.

       9         Q    Who is your mother?

      10         A    Must I give you the name of my

      11    mother?

      12         Q    Yes.

      13              MS. SHAPIRO:  I object to the

      14    relevancy of her giving her mother's name.

      15              BY MR. KLAYMAN:

      16         Q    You can respond.

      17              What's her first name?

      18         A    Her first name is Carol.

      19         Q    Carol Parker?

      20         A    No.

      21         Q    And what's her name?  What's her

      22    last name?








                                                              13


       1              MS. SHAPIRO:  What's the need for

       2    this?  Could you just explain for the record

       3    what the relevance is?

       4              MR. KLAYMAN:  It's obvious what the

       5    need is.  She may have talked to her mother

       6    and given her information.

       7              MS. SHAPIRO:  That's not a proper

       8    inquiry.

       9              MR. KLAYMAN:  If you want to give

      10    it to the court under a protective order,

      11    that's fine.  I have no problem with that.

      12    You can put it under the protective order.

      13              MS. SHAPIRO:  Do you want to seal

      14    this deposition?

      15              MR. KLAYMAN:  No, I'm willing to

      16    have the name put under protective order.

      17              MS. SHAPIRO:  That protective order

      18    is under dispute right now.

      19              MR. KLAYMAN:  All right, you don't

      20    want to provide the names, certify it.

      21              MS. SHAPIRO:  Fine.

      22              MR. KLAYMAN:  Is that the








                                                              14


       1    instruction, not to provide the name?

       2              MS. SHAPIRO:  Yes.

       3              BY MR. KLAYMAN:

       4         Q    Who else did you talk to about the

       5    deposition?

       6         A    My father.

       7              MR. KLAYMAN:  Same instruction?

       8              MS. SHAPIRO:  Yes, unless she wants

       9    to give his first name.

      10              BY MR. KLAYMAN:

      11         Q    Do you want to give his first name?

      12         A    No.

      13         Q    All right, certify it.

      14              Did you talk to anybody else?

      15         A    Yes.

      16         Q    Who else?

      17         A    My boyfriend.

      18         Q    And what's his name?

      19         A    Jonathan.

      20         Q    And what's his last name?

      21              MS. SHAPIRO:  Let's take a quick

      22    break.








                                                              15


       1              THE VIDEO SPECIALIST:  We're going

       2    off video record at 10:24.

       3                   (Recess)

       4              THE VIDEO SPECIALIST:  We're back

       5    on video record at 10:25.

       6              MS. SHAPIRO:  This line of

       7    questioning is improper in that you haven't

       8    established what she might have talked about

       9    to these people.  She's willing to tell you

      10    the substance of her conversations and

      11    generally who they were, her mother, her

      12    boyfriend, her father, but there's absolutely

      13    no purpose, other than an improper purpose,

      14    for her to be naming people when you haven't

      15    established any relevancy or if you want to

      16    put the video and the transcript under seal.

      17              MR. KLAYMAN:  I'm not going to put

      18    the entire video and transcript under seal,

      19    but as a courtesy to her, if she didn't want

      20    to give us the names of her mother and

      21    father, I was willing to let her do that

      22    under seal.








                                                              16


       1              I had asked a very simple question,

       2    whether she talked to them about this

       3    deposition.  That is highly relevant.

       4              MS. SHAPIRO:  And she said yes.

       5              MR. KLAYMAN:  And I asked them for

       6    the names.

       7              MS. SHAPIRO:  That's right.  And I

       8    think until you establish that there's

       9    anything relevant that she discussed with

      10    them, that their names are absolutely

      11    irrelevant and improper.

      12              MR. KLAYMAN:  Well, I may never

      13    know that if she's not being completely

      14    candid here today, and that's why you need to

      15    get the names of these people.

      16              MS. SHAPIRO:  Well, I view --

      17              MR. KLAYMAN:  That's a catch-22.

      18              MS. SHAPIRO:  I view asking for

      19    these names as harassment unless you've

      20    established that there is some kind of

      21    substance.

      22              MR. KLAYMAN:  It's not harassment,








                                                              17


       1    and I'll certify this whole line of inquiry,

       2    and we'll go to the court on it.

       3              MS. SHAPIRO:  That's fine.

       4              MR. KLAYMAN:  This is a standard

       5    type of deposition question in all civil

       6    proceedings.

       7              MS. SHAPIRO:  That's fine.

       8              MR. KLAYMAN:  Who did you talk to

       9    about your deposition.

      10              MS. SHAPIRO:  That's right, and she

      11    told you and I think she's answered that

      12    question.  And she's willing to tell you any

      13    information you want to know about the

      14    substance of those conversations.

      15              MR. KLAYMAN:  I --

      16              MS. SHAPIRO:  She's not going to

      17    name names when there's no relevancy that's

      18    been established.

      19              MR. KLAYMAN:  The relevance

      20    established, if she talked to them about this

      21    deposition, that is the most relevant

      22    question that I could have asked her.








                                                              18


       1              MS. SHAPIRO:  Well, you haven't

       2    asked her what she said to them.  How do you

       3    know it's relevant?

       4              MR. KLAYMAN:  I will ask her that,

       5    certainly, but whatever she said to them may

       6    or may not be the case because then I have

       7    the right to see whether from these other

       8    witnesses other types of information were

       9    provided.  I do not take the witness on face

      10    value.  If that was the case, I'm sure we

      11    wouldn't be here today, Ms. Shapiro.

      12              MS. SHAPIRO:  Well, we are --

      13              MR. KLAYMAN:  Because it's been

      14    your position that nothing's ever happened

      15    here that is in any way subject to

      16    litigation.  That's been your position.

      17              MS. SHAPIRO:  This witness has

      18    taken an oath.  I don't think there's any

      19    point in getting into a discussion here about

      20    the legality of your line of questioning.  We

      21    stated our objection.  We view it as

      22    improper, we view it as harassment.  If you








                                                              19


       1    want to take that to the judge, that's fine,

       2    but why don't we move along?

       3              MR. KLAYMAN:  I view your

       4    inappropriate objections as harassment.

       5              BY MR. KLAYMAN:

       6         Q    Ms. Parker, who else did you talk

       7    to about your deposition?

       8         A    I've told friends about my

       9    depositions -- deposition, sorry.

      10         Q    Which friends?

      11              MR. KLAYMAN:  Same instruction?

      12              MS. SHAPIRO:  Yes.

      13              MR. KLAYMAN:  Certify it.

      14              BY MR. KLAYMAN:

      15         Q    Anyone else?

      16         A    My grandmother.

      17              MR. KLAYMAN:  Same instruction?

      18              MS. SHAPIRO:  Yes.

      19              BY MR. KLAYMAN:

      20         Q    Anyone else?

      21         A    No.

      22         Q    Mr. Paul Begala?








                                                              20


       1         A    I didn't tell him about my

       2    deposition.

       3         Q    Did you talk to him about your

       4    deposition?

       5         A    Yes.

       6         Q    Why didn't you tell me that when I

       7    asked you?

       8         A    You asked me who I told about my

       9    deposition.

      10         Q    How did Mr. Begala find out that

      11    you were being deposed, to the best of your

      12    knowledge?

      13         A    My -- Ms. Paxton came in and --

      14              MS. SHAPIRO:  I'm just going to

      15    caution the witness not to reveal the

      16    substance of any conversations between her

      17    and Ms. Paxton.

      18              THE WITNESS:  Okay.

      19              BY MR. KLAYMAN:

      20         Q    You can reveal that Ms. Paxton came

      21    in.

      22         A    Ms. Paxton came in.








                                                              21


       1         Q    Came in where?

       2         A    Came in to our office.

       3         Q    When?

       4         A    Last week.

       5         Q    And at that time, did you have a

       6    meeting with Mr. Begala over this deposition?

       7         A    No.

       8         Q    Did you have a meeting with

       9    Ms. Paxton over this deposition?

      10         A    Not at that time.

      11         Q    What meetings did you have with

      12    either Ms. Paxton or Mr. Begala about this

      13    deposition?

      14         A    Could you repeat that question,

      15    please?

      16         Q    What meetings did you have with

      17    Ms. Paxton or Mr. Begala about your

      18    deposition, meetings or conversations?

      19         A    I had meetings with Ms. Paxton and

      20    my counsel.  I had no meetings with

      21    Mr. Begala regarding this.

      22         Q    Who is your counsel?








                                                              22


       1         A    Ms. Shapiro.

       2         Q    And when did those meetings take

       3    place?

       4         A    On occasion over the last week.

       5         Q    How many?

       6         A    I'm not sure.

       7         Q    Roughly speaking?

       8         A    Three to six.

       9         Q    How many?

      10         A    Three to six, varying length.

      11         Q    And how long was each meeting?

      12         A    They were varying length.

      13         Q    Let's take the first meeting.  How

      14    long was that?

      15         A    I don't remember.

      16         Q    Roughly speaking.

      17         A    I don't remember.  They all blur

      18    together.

      19         Q    Well, how long were the meetings if

      20    you added all of the three to six together,

      21    roughly speaking?

      22         A    Under four hours.








                                                              23


       1         Q    And who was present at those

       2    meetings besides Ms. Shapiro and Ms. Paxton?

       3         A    No one.

       4         Q    Did you ever discuss your

       5    deposition with Mr. Begala?

       6         A    Yes.

       7         Q    When was that?

       8         A    On occasion over the last week.

       9         Q    When was the first such meeting?

      10              MS. SHAPIRO:  Objection.  She

      11    testified that there wasn't a meeting.

      12              BY MR. KLAYMAN:

      13         Q    You discussed it by phone?  How did

      14    you discuss it with him?  What was the mode?

      15    What was the, the way that you made the

      16    discussion with him?

      17         A    We were in -- we were in the

      18    office, and -- and we occasionally spoke

      19    about it.

      20              MR. KLAYMAN:  I'm going to object,

      21    and please certify this.  That kind of a

      22    remark, giving the witness testimony, is








                                                              24


       1    wholly inappropriate and sanctionable.

       2              Certify it.

       3              MS. SHAPIRO:  I didn't give her

       4    testimony.  She testified, and you can read

       5    it back.

       6              MR. KLAYMAN:  It's clear you were

       7    trying to lead her in a direction which

       8    wasn't even true, Ms. Shapiro.

       9              MS. SHAPIRO:  The record will speak

      10    for itself.  I only ÄÄÄÄ her testimony.

      11              MR. KLAYMAN:  It will and please

      12    mark this for sanctionable conduct.

      13              BY MR. KLAYMAN:

      14         Q    How long were these discussions in

      15    the office over the last week?

      16         A    Never longer than a minute.

      17         Q    And how many such discussions were

      18    there?

      19         A    I don't know.

      20         Q    Roughly speaking?

      21         A    Less than five.

      22         Q    What was discussed during the first








                                                              25


       1    discussion?

       2         A    I can't accurately answer that

       3    because things that he have said to me, they

       4    blur together, and I can give you a general

       5    idea of what he said to me, but I can't speak

       6    to each individual --

       7         Q    Please provide a general idea of

       8    what he said to you and what you said to him,

       9    if anything.

      10         A    He told me not to worry, he told me

      11    to tell the truth.

      12         Q    And that required six different

      13    conversations?

      14         A    He was trying --

      15              MS. SHAPIRO:  Objection.  That's

      16    not a question.

      17              BY MR. KLAYMAN:

      18         Q    I'm asking you.  That requires six

      19    different conversations?

      20         A    He was trying to reassure me.

      21         Q    The answer calls for a yes or no.

      22              MS. SHAPIRO:  Objection.  She








                                                              26


       1    answered the question.

       2              BY MR. KLAYMAN:

       3         Q    Please respond.

       4         A    He was trying to reassure me.

       5         Q    Are you saying that's all that was

       6    discussed, six different times?

       7         A    He also said that we shouldn't talk

       8    about this.

       9         Q    Talk about what?

      10         A    Talk about the deposition.

      11         Q    Did he say anything else?

      12         A    Not to the best of my recollection.

      13         Q    And what did you say?

      14         A    I said okay.

      15         Q    You said okay six different times?

      16         A    Yes.

      17         Q    So it was the same conversation six

      18    different times?

      19         A    To the best of my recollection.

      20         Q    Did you ask him any questions

      21    during these conversations?

      22         A    No, he made it very clear that we








                                                              27


       1    weren't to talk about the deposition.

       2         Q    He made it clear that you were to

       3    talk about it only with Ms. Paxton and

       4    Ms. Shapiro?

       5         A    He reminded me that those

       6    conversations were privileged.

       7         Q    He told you that the conversations

       8    with Ms. Paxton and Ms. Shapiro were

       9    privileged?

      10         A    Yes.

      11         Q    How did that come up?

      12         A    I don't remember.

      13         Q    So now you're adding something

      14    different than what you previously told me.

      15    It wasn't just tell the truth and it will be

      16    okay.  It was the conversations you have with

      17    Ms. Shapiro and Ms. Paxton are privileged?

      18         A    It was also part of we should not

      19    talk about this deposition.

      20         Q    And Mr. Begala told you I'll give

      21    my information to Ms. Paxton and Ms. Shapiro

      22    and they'll tell you what I have to say?








                                                              28


       1         A    He did not say that.

       2              MS. SHAPIRO:  Objection.

       3              BY MR. KLAYMAN:

       4         Q    Did you understand that to be the

       5    case?

       6         A    Could you repeat that?

       7         Q    Did understand that to be the case?

       8         A    Understand what to be the case?

       9         Q    That that's the way it was going to

      10    work, that Mr. Begala would relay what he

      11    wanted to say to you through Ms. Paxton and

      12    Ms. Shapiro?

      13         A    There was -- he did not insinuate

      14    that, he did not say that, I did not

      15    understand that.

      16         Q    Have you had an opportunity to

      17    review Mr. Begala's deposition transcript?

      18         A    Yes, I have.

      19         Q    How many times?

      20         A    Once.

      21         Q    Did you go over it carefully with

      22    Ms. Shapiro and Ms. Paxton?








                                                              29


       1              MS. SHAPIRO:  Objection.

       2              BY MR. KLAYMAN:

       3         Q    You can respond.

       4              MS. SHAPIRO:  No, she can't

       5    respond.

       6              MR. KLAYMAN:  Whether she went over

       7    the deposition with you?

       8              MS. SHAPIRO:  If she went over it

       9    with us, she cannot respond.

      10              MR. KLAYMAN:  I'm not asking her

      11    about any communications between you, just

      12    whether she went over a document with you,

      13    which is a public document.

      14              MS. SHAPIRO:  She can't respond

      15    about what we did during privileged

      16    conversations.

      17              MR. KLAYMAN:  Certify it.

      18              You're on notice.  Every time you

      19    take this kind of a stance, we will include

      20    this for a motion for sanctions.

      21              MS. SHAPIRO:  I object to your

      22    constant threatening of me.








                                                              30


       1              MR. KLAYMAN:  I'm just putting you

       2    on notice so the next time you do it you'll

       3    do it with an intent.

       4              MS. SHAPIRO:  I'm just asserting

       5    privileges and objections pursuant to the

       6    rules.

       7              And let me say, once again, as I've

       8    said every time we have been in deposition

       9    together, that you persistently talk over me.

      10    Would you please give me the courtesy of

      11    finishing what I have to say and then you can

      12    speak?

      13              MR. KLAYMAN:  I don't need those

      14    kinds of lectures, Ms. Shapiro.  It's not my

      15    intention to talk over you.  The fact is you

      16    keep making the objection beyond that which I

      17    think is a conclusion, so I'm happy to have

      18    you speak on the record, but I don't need

      19    lectures.  And I am telling you that we will

      20    move for sanctions, and I want you to have

      21    this in your knowledge when you do it again.

      22              MS. SHAPIRO:  And I would keep the








                                                              31


       1    same in mind for yourself, Mr. Klayman.

       2              MR. KLAYMAN:

       3         Q    Ms. Parker, what did you talk about

       4    with your mother about this deposition?

       5         A    I told her I had been subpoenaed,

       6    that I was called for a deposition today.  I

       7    explained to her that Mr. Begala had also

       8    been subpoenaed and called to deposition.  I

       9    asked her if she remembered the FBI file

      10    problems in order to contextualize what was

      11    -- this whole situation.

      12         Q    Did she tell you anything?

      13         A    She expressed shock, surprise,

      14    anger, and told me to tell the truth --

      15         Q    Why was she angry?  Did she express

      16    that?

      17         A    She was angry because her daughter

      18    was being subpoenaed.

      19         Q    What did you tell her about the

      20    subject of your testimony today that got her

      21    angry?

      22              MS. SHAPIRO:  Objection.








                                                              32


       1              BY MR. KLAYMAN:

       2         Q    If anything?

       3              MS. SHAPIRO:  Mischaracterizes her

       4    testimony.

       5              BY MR. KLAYMAN:

       6         Q    If anything, if anything?

       7         A    She was angry about the process,

       8    and she did not understand why I was being

       9    subpoenaed.

      10         Q    Did you tell her because you work

      11    for Mr. Begala and helped in document

      12    collection?

      13         A    Yes, I did.

      14         Q    And she still expressed anger?

      15         A    Yes, she did.

      16         Q    Now, you understand why you've been

      17    asked to testify, don't you?

      18         A    In a cursory way.

      19         Q    You are aware that Mr. Begala

      20    testified that you helped him produce the

      21    documents that Judicial Watch requested?

      22         A    I'm aware.








                                                              33


       1         Q    And you understand that's a

       2    legitimate line of questioning, is it not?

       3              MS. SHAPIRO:  Objection.  That

       4    calls for a legal conclusion.

       5              BY MR. KLAYMAN:

       6         Q    Do you take it as legitimate?

       7         A    I don't want to judge a legitimacy.

       8         Q    Do you resent being called here

       9    today?

      10         A    Not yet.

      11         Q    Did you resent it before?

      12              MS. SHAPIRO:  Objection as to

      13    relevancy.

      14              BY MR. KLAYMAN:

      15         Q    Before you actually came into this

      16    room?

      17         A    No.

      18         Q    Did you say anything else to your

      19    mother or did she say anything else to you?

      20         A    Not that I can remember.

      21         Q    What was discussed with your

      22    boyfriend about this deposition?








                                                              34


       1         A    I told him that I had been

       2    subpoenaed and called to deposition.

       3         Q    Did you tell him why you thought

       4    you were being called to deposition?

       5         A    Yes.

       6         Q    And what did you tell him in that

       7    regard?

       8         A    I told -- I tried to explain to him

       9    what little I know about the FBI files

      10    matter.  I told him that my boss had been

      11    subpoenaed and called to deposition, and I

      12    told him that they probably wanted me to come

      13    in because of questions regarding the office.

      14         Q    The little that you knew about the

      15    FBI file matter, where did you obtain that

      16    information?

      17         A    News clippings.

      18         Q    Who gave you the news clippings?

      19         A    I barely remember reading them in

      20    the summer of '96.

      21         Q    Was that information that your

      22    mother provided to you?  Did you talk to her








                                                              35


       1    before your boyfriend.

       2         A    There was two parts to that

       3    question.  Which do you want me to answer?

       4         Q    Did you talk to your mother before

       5    you talked to your boyfriend?

       6         A    Yes, I did.

       7         Q    And was the information relayed to

       8    your boyfriend about filegate, was your

       9    mother told you about it or did you get it

      10    from another source?

      11         A    You have to repeat the last part of

      12    that question.

      13         Q    What you related to your --

      14              MS. SHAPIRO:  Objection.  That's a

      15    completely vague question.

      16              BY MR. KLAYMAN:

      17         Q    What you said to your boyfriend

      18    about filegate, did you get that information

      19    from your mother or did you also get it from

      20    other sources?

      21         A    First of all, I don't appreciate

      22    the characterization of this problem as








                                                              36


       1    filegate.  Second of all, my mother did not

       2    give me any information.

       3         Q    Why don't you appreciate the

       4    characterization as filegate?

       5         A    I don't understand what it means.

       6         Q    I don't understand what you mean.

       7    What do you mean, you don't appreciate the

       8    characterization?  You sounded quite

       9    indignant there.  Is it your position that

      10    the Clinton administration is being unfairly

      11    questioned about this matter?

      12         A    I don't have a position on this.

      13         Q    Have you been told that this case

      14    is frivolous and has no merit by anybody in

      15    the Clinton administration in the White

      16    House?

      17         A    No, I have not.

      18         Q    Has Mr. Begala told you that?

      19         A    He's not said that.

      20         Q    I'm going to call it filegate

      21    because that's what everybody calls it, so

      22    that's the definition for this case,








                                                              37


       1    filegate.

       2         A    Okay.

       3         Q    And has Mr. Begala ever talked to

       4    you about filegate?

       5         A    You must define "filegate."

       6         Q    The transfer of FBI files from the

       7    FBI to the White House about Republican

       8    employees of the White House during this

       9    administration.

      10         A    Mr. Begala has never mentioned

      11    anything regarding what you just said -- what

      12    you just said.

      13         Q    So tell me what you said to your

      14    boyfriend about filegate.

      15         A    I didn't mention anything about

      16    filegate.  I said that there had been some

      17    problems -- or there allegedly had been some

      18    problems with -- with people's FBI files

      19    being read, and, therefore, there was -- I

      20    understood that this organization Judicial

      21    Watch had a suit against the federal

      22    government regarding it and Paul had made a








                                                              38


       1    joke regarding it and therefore he had been

       2    subpoenaed.

       3         Q    Where had you learned that

       4    information, that Paul had been, I take it,

       5    Paul Begala, had been subpoenaed because he

       6    made a joke?

       7         A    We received a press release.

       8         Q    Did you get that from any place

       9    else?

      10         A    Did I get what from any place else?

      11         Q    That information?

      12         A    I was first made aware when someone

      13    made me aware of the press release.

      14         Q    Who made you aware of the press

      15    release?

      16         A    Someone in our research office.

      17         Q    Who is that?

      18         A    I don't remember.

      19         Q    A man or a woman?

      20         A    A man.

      21         Q    Who was in your research office?

      22    Who works there?








                                                              39


       1         A    I don't know all the employees at

       2    the research office.

       3         Q    Well, tell me the ones you know.

       4         A    Tom Janenda and Glen Wiener.

       5         Q    Do you know what his job title is?

       6         A    No, I do not.

       7         Q    And what's the other fellow's name?

       8         A    Glen Wiener.  I believe it's W-e-i

       9    or -- I don't know the spelling.

      10         Q    W-e-i-n-e-r?

      11         A    I believe so, but I'm not sure.

      12         Q    Who else works in that press

      13    office, in that research office?

      14         A    Those are the only two people I'm

      15    aware of who work at the office.

      16         Q    And the research office, is that

      17    part of a bigger part of the communications

      18    department?

      19         A    I don't know where it's -- where it

      20    fits in the organization.

      21         Q    But it works with Mr. Begala,

      22    correct?








                                                              40


       1         A    How would you define "working

       2    with"?

       3         Q    Works under his direction?

       4         A    No.

       5         Q    Whose direction does it work under?

       6         A    I don't know.  I don't know where

       7    it fits in the organization.

       8         Q    Where is it located?

       9         A    It's in the Old Executive Office

      10    Building.

      11         Q    Is it close to your office?

      12         A    How do you define "close"?

      13         Q    Near.

      14         A    I mean, it's all relative.  You

      15    have to better define "near."

      16         Q    Well, let's go with yards, how many

      17    yards away --

      18         A    I don't know how many yards.

      19         Q    Roughly speaking?  Is it on the

      20    same hallway?

      21         A    No.

      22         Q    Where is it located?








                                                              41


       1         A    It's on the first floor of the Old

       2    Executive Office Building.

       3         Q    What's the room number?

       4         A    I don't know.

       5         Q    What's your room number?

       6         A    147.

       7         Q    Do you have to take a stairwell to

       8    get down to the research office?

       9         A    No.

      10         Q    So you're on the first floor, too?

      11         A    Correct.

      12         Q    So how far away is it, roughly

      13    speaking?

      14         A    I don't know how many yards, but if

      15    I were walking it would take me about a

      16    minute.

      17         Q    And how many people are there in

      18    the research office?

      19         A    I don't know.

      20         Q    Roughly speaking?

      21         A    I don't know.

      22         Q    I'm not trying in any way to be








                                                              42


       1    critical here, but we can make this

       2    deposition, we can move it along faster if

       3    you try to answer my questions as best you

       4    can.  I'm not going to hold you to exact

       5    precision?

       6              MS. SHAPIRO:  Objection.  She's

       7    answered the best she can.

       8              BY MR. KLAYMAN:

       9         Q    Otherwise, I'll ask the questions

      10    sometimes three or four different ways.

      11    Sometimes doing that I've gotten an answer.

      12    Now, that can make this a very long process?

      13         A    I understand.

      14         Q    And it will be my position,

      15    Ms. Parker, that if it becomes a long process

      16    that we will ask the Court for permission to

      17    bring you back again.  So I ask you if you

      18    will move this along as quickly as possible?

      19              MS. SHAPIRO:  Objection to trying

      20    to intimidate the witness.  She's answering

      21    fully.

      22              MR. KLAYMAN:  I'm not trying to








                                                              43


       1    intimidate her.  I'm trying to get this thing

       2    to move along.

       3              MS. SHAPIRO:  If you can ask more

       4    precise questions, maybe it will move along

       5    faster or maybe relevant questions.

       6              MR. KLAYMAN:  Certify this,

       7    improper remark.

       8              BY MR. KLAYMAN:

       9         Q    Ms. Parker, how many people

      10    approximately have you met from that office?

      11         A    I've only met two people and they

      12    are the people that I have already stated.

      13         Q    I'm sorry, I didn't understand.

      14              MS. SHAPIRO:  Could you read the

      15    record back then, please?

      16              MR. KLAYMAN:  No, please answer the

      17    question.

      18              MS. SHAPIRO:  She answered the

      19    question.  Please ask her another question.

      20              MR. KLAYMAN:  Do you want to read

      21    the record back, that's fine.  I'm going to

      22    take my time, Ms. Shapiro.








                                                              44


       1              MS. SHAPIRO:  That's fine.

       2                   (The reporter read the record as

       3                   requested.)

       4              BY MR. KLAYMAN:

       5         Q    Have you talked to anybody in the

       6    White House or elsewhere about this research

       7    office?

       8         A    Could you please be more specific?

       9         Q    I don't want to be more specific.

      10    I'm just asking you a general question.

      11         A    I've never spoken in general terms

      12    about the office before.

      13         Q    How did you find out there was even

      14    a research office?

      15         A    I know that Paul works with Tom and

      16    Glen, and sometimes when we need things I can

      17    turn to them for help, so if I need a

      18    particular clipping or if -- I understand

      19    them as a place that, if I'm looking for

      20    something in the public record, they can help

      21    me find.

      22         Q    Who told you that, that that's a








                                                              45


       1    place where, if you need something in the

       2    public record, you can look to them?

       3         A    It's something that I figured out.

       4         Q    How did you figure that out?

       5         A    I don't know the exact way that I

       6    figured it out.  I know that Tom and Glen

       7    would bring things to Paul and so I figured

       8    out that if they would bring things to Paul

       9    that I could ask them when I needed things.

      10    I don't remember the exact thought process,

      11    but I just -- I figured out that they could

      12    help out.

      13         Q    You've had a conversation with

      14    Mr. Begala, have you not, about what Tom and

      15    Glen do?

      16         A    No.

      17         Q    You've had a conversation with

      18    others about what Tom and Glen do?

      19         A    No.

      20         Q    You've been to their office, Tom

      21    and Glen's, haven't you?  That's how you know

      22    it only takes only a minute to walk there?








                                                              46


       1         A    Yes, I have.

       2         Q    Because you have taken things to

       3    them from Paul Begala and others?

       4         A    No, I've borrowed books.

       5         Q    What books have you borrowed?

       6         A    I remember borrowing a

       7    Congressional directory and I believe I

       8    borrowed -- I believe I borrowed some sort of

       9    dictionary at one time.

      10         Q    Have you seen the layout of that

      11    office?  I take it you have when you've

      12    walked in?

      13         A    Yes, I have.

      14         Q    How many offices are there?

      15         A    I'm happy to try -- well, see, it

      16    would be guessing and the problem is walking

      17    in there I don't know that in that whole

      18    suite it's all research.  I just know where

      19    Glen and Tom visibly sit.

      20         Q    Well, you allowed to guess?

      21         A    Well, I don't want to guess.

      22         Q    Well, I want a general idea.  This








                                                              47


       1    is subject to discovery and discovery allows

       2    me to get some information that may lead me

       3    to other information; so, roughly speaking,

       4    how many offices are there?

       5              MS. SHAPIRO:  I object to the

       6    extent that you are asking her about things

       7    that she has no knowledge of.  She's not

       8    required to guess.

       9              MR. KLAYMAN:  Certify this.  It's

      10    inappropriate to tell witness they have no

      11    knowledge of things when clearly they're

      12    testifying about it.  Certify, improper

      13    conduct.

      14              THE WITNESS:  I only know about Tom

      15    and Glen.  I know that they have two offices.

      16    I don't know who else sits in the offices

      17    next to theirs.  I don't know if they are in

      18    the research department.  I don't know who

      19    they are, what they do, so I can't speak to

      20    it.

      21              BY MR. KLAYMAN:

      22         Q    My question was what offices are in








                                                              48


       1    and around Tom and Glen's offices?

       2         A    I don't know.

       3              MS. SHAPIRO:  Asked and answered.

       4              BY MR. KLAYMAN:

       5         Q    Roughly, there are offices in

       6    addition to theirs, aren't there, down there?

       7         A    I'm sorry.

       8         Q    There are offices in addition to

       9    Tom and Glen's down in that area of the EOB,

      10    correct?

      11         A    Yes, there are.

      12         Q    And there's more than one office,

      13    correct?

      14         A    Yes, there are.

      15         Q    There's more than two offices,

      16    correct?

      17         A    I'm not sure.

      18         Q    There are secretaries or assistants

      19    sitting in that office, are there not, in

      20    that suite of offices?

      21         A    Not necessarily.

      22         Q    There are computers in that office,








                                                              49


       1    correct?

       2         A    Yes.

       3         Q    You previously testified that you

       4    know that Paul uses them, Paul meaning

       5    Begala, for public record stuff, right?

       6         A    Correct.

       7         Q    What did you mean by "public

       8    record"?

       9         A    Records that are publicly

      10    available.

      11         Q    How do you define whether records

      12    are publicly available?

      13         A    I don't have an exhaustive

      14    definition for that.  I know what I'm usually

      15    looking for.  Usually it's news clippings or

      16    votes or trying to find when -- if someone

      17    said something in an interview, you know,

      18    anything that we can find in the paper or

      19    find in the Congressional Record.

      20         Q    Before your deposition today in the

      21    context of preparing for this deposition, you

      22    did discuss the phrase "public record" with








                                                              50


       1    someone, didn't you?

       2         A    I don't believe I've ever discussed

       3    public record with anyone.

       4         Q    Did you discuss what's meant by

       5    public document?

       6         A    I understand what a public document

       7    is.

       8         Q    How did you learn that?

       9         A    Well, over my years of studying

      10    political science, I somehow have come up

      11    with the answer.

      12         Q    Was there a course on what's a

      13    public record?

      14         A    If there was, I didn't take it.

      15         Q    Have you ever read government

      16    manuals to define what's a public record as

      17    opposed to what's a private record?

      18         A    No, I have not.

      19         Q    Or confidential record?

      20         A    No, I have not.

      21         Q    Has anyone ever given you

      22    instructions in the context of your job at

 

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