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 ���� 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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