301
1 Q Did you give the April calendar for
2 somebody to produce?
3 A I believe I gave April calendar,
4 but I don't know -- you know, I don't know
5 for sure.
6 Q Who is Jim Angle?
7 A He's a reporter.
8 Q Who does he work for?
9 A I believe Fox News.
10 Q Who is Ruth Goldway?
11 A The wife of Ambassador Sheer.
12 Q Karen Tummult?
13 A She's a reporter for Time.
14 Q Jay Brain?
15 A Reporter for Time.
16 Q May Sue Chung?
17 A Former student of Paul's.
18 Q What is the appointment on the
19 April calendar?
20 A Oh, I think with the White House
21 correspondence dinner.
22 MR. KLAYMAN: I'll show you what
302
1 I'll ask the report to mark as Exhibit 8, 7.
2 Are you aware that ambassador Sheer is
3 related to -- his wife is Brook Sheer.
4 (Parker Deposition Exhibit No. 7
5 was marked for identification.)
6 THE WITNESS: Excuse me.
7 BY MR. KLAYMAN:
8 Q The wife of ambassador Sheer is
9 Brook Sheer?
10 A I was on the understanding that
11 Ruth Goldway is his wife.
12 Q Is there a Brook Sheer that is
13 related to the ambassador?
14 A I don't know.
15 Q If I told you that Terry Lenzner is
16 related to, would that refresh your
17 recollection?
18 A No, it would not.
19 Q I'll show you what I marked as
20 exhibit 7.
21 THE WITNESS: Thank you.
22 Q These are the calendars that were
303
1 produced by Mr. Begala at his deposition.
2 Was there anything that but redacted from
3 these calendars prior to production to
4 Judicial Watch? It says redacted at the
5 bottom.
6 A I believe certain things that had
7 to do with his children and his wife were
8 redacted.
9 Q Are you the ones that did the
10 redactions?
11 A Who are you referring to as we.
12 Q You. Were you the one who did the
13 redactions on the calendars produced by
14 Mr. Begala at his deposition?
15 A I didn't personally cover them up
16 and copy them.
17 Q Who did?
18 A I don't know.
19 Q Were you told what to cover up and
20 copy?
21 MS. SHAPIRO: Objection. You
22 mischaracterized her testimony.
304
1 BY MR. KLAYMAN:
2 Q You can respond.
3 A I mean, our counsel redacted them.
4 Q How do you know that?
5 A I mean, I understand it. I was
6 told so.
7 Q Who told you that?
8 A My counsel.
9 Q Was there any criteria that you
10 know of for those redactions, why were they
11 redacted?
12 MS. SHAPIRO: Objection. She can't
13 answer that question.
14 BY MR. KLAYMAN:
15 Q You can respond.
16 A I understand that all things
17 personal regarding his children or his wife
18 also -- I believe another event of a personal
19 nature was redacted.
20 Q Who told you that?
21 A My counsel.
22 Q Did Mr. Begala tell you that?
305
1 A It's in the realm of possible, but
2 I don't think it was him.
3 Q What's the definition of personal
4 versus business?
5 A I make that distinction. Usually
6 for me it means personal, you know, as a
7 lunch, an appointment regarding a doctor, you
8 know, a social engagement.
9 Q So any time Mr. Begala had lunch,
10 it was redacted?
11 A No.
12 Q What's the criteria?
13 A The criteria for something being
14 redacted?
15 Q Yes.
16 MS. SHAPIRO: Objection. She
17 didn't do these redactions. She already
18 testified to that.
19 MR. KLAYMAN: Based on what she was
20 told.
21 MS. SHAPIRO: Well, to extent that
22 counsel told her anything, she's not going to
306
1 reveal it.
2 BY MR. KLAYMAN:
3 Q You can respond?
4 MS. SHAPIRO: Well, if it's
5 something that you heard from counsel, you
6 cannot respond. If it's something you heard
7 from somebody else, then you can.
8 BY MR. KLAYMAN:
9 Q You're responding?
10 A I'm not responding.
11 MR. KLAYMAN: Certify it.
12 I'm going to show you what I'll ask
13 the Court reporter to mark as Exhibit 8 and
14 Exhibit 9. These are two documents that were
15 also produced at Mr. Begala's deposition.
16 (Parker Deposition Exhibit
17 Nos. 8 and 9 were marked for
18 identification.)
19 BY MR. KLAYMAN:
20 Q I'm showing you Exhibit 8, have you
21 ever seen that before?
22 A Yes, I have.
307
1 Q Was that the document that you
2 found in one of the files that you identified
3 before?
4 A Yes, it is.
5 Q What was the name of that file?
6 A It either came from the opposition
7 research file or the Arlington file.
8 Q How did you determine that this was
9 responsive to Judicial Watch's document
10 request to Mr. Begala?
11 MS. SHAPIRO: Objection. Calls for
12 a legal conclusion.
13 Q You can respond.
14 A I believe my last instruction was
15 to find anything that had any kind of mention
16 of FBI files.
17 Q Exhibit 9, which file did that come
18 from?
19 A Either opposition research or
20 Arlington.
21 Q Did you identify it through the
22 same criteria?
308
1 A Yes.
2 Q That was the only criteria?
3 A I remember doing -- having kind of
4 like two sets of searches. The first set of
5 kind of just looking for anything that could
6 anything possibly to do with investigations
7 or I don't remember the subject criteria.
8 But then going back and trying to find
9 anything that actually had the words FBI
10 file.
11 Q Do you know what these documents
12 relate to, 8 and 9?
13 A What do you mean.
14 Q Were there ever used in your office
15 by Mr. Begala or anybody else for any
16 particular purpose?
17 A I don't know what purpose they were
18 used for.
19 Q Had you ever used them before?
20 Have you ever pulled them out before other
21 than produce in this case?
22 A I've never pulled them out again.
309
1 Q Have you ever seen them before?
2 A They're vaguely familiar.
3 Q Had you used them before you
4 produced them in this case, that's the
5 question, for any purpose?
6 A They had been on his desk. I don't
7 know what he used them for. I never used
8 them personally for anything.
9 Q You found these documents on his
10 desk before you produced them at Judicial
11 Watch?
12 A No, they were in my file before I
13 produced them for Judicial Watch.
14 Q You didn't search Mr. Begala's desk
15 produce documents to Judicial Watch did you?
16 A No, I did not.
17 Q And you didn't search his draw you
18 ares, did you?
19 A No, I not.
20 Q Does he have haze own file cabinet?
21 A No, he does not.
22 Q Do you know whether he stores
310
1 anything in safes?
2 A I have no idea.
3 Q Is there a White House safe that
4 you can store important documents into?
5 A I'm not aware.
6 Q Do you have a national security
7 clearance?
8 A Yes, I do.
9 Q Has Mr. Begala?
10 A Yes, he does.
11 Q Do either of you see classified
12 documents?
13 A I've never seen a classified
14 document.
15 Q Have any classified documents ever
16 been delivered from Mr. Begala?
17 A I'm not aware of any such
18 documents.
19 Q Are you aware on any procedures on
20 how to deal with classified documents?
21 A Such as.
22 Q Whether they are to be kept under
311
1 lock and key when you're not looking at them?
2 A I don't have the clearance to look
3 at classified documents so it's something
4 I've never had to deal with.
5 Q I thought you just told me you did
6 have clearance to look at classified
7 documents?
8 A I mean, I have secret clearance,
9 but I've never thought as of any kind of
10 license to look at documents.
11 Q Does Mr. Begala have a top secret
12 clearance?
13 A Yes, he does.
14 Q How do you know that?
15 A I just do.
16 Q How did you find it out?
17 A No, I take that back. I assume
18 that he has one. I don't know for sure.
19 MR. KLAYMAN: I'll show you what
20 I'll ask the Court reporter to mark as
21 exhibit 10.
22 (Parker Deposition Exhibit
312
1 No. 10 was marked for
2 identification.)
3 BY MR. KLAYMAN:
4 Q What's exhibit 10?
5 A Are you asking me?
6 Q Yes.
7 A A redacted copy of Paul's daily
8 schedule from March 9 through March 11.
9 Q Why did you produce these documents
10 today?
11 A Because when I was subpoenaed, I
12 had these in my computer.
13 Q Are these all you had in the
14 computer with regard to Paul's daily
15 schedules?
16 A That's all I'm aware of.
17 Q Are you the one that did the search
18 yourself?
19 A Uh-huh.
20 Q Can you read the first page? It's
21 so small I can't read it.
22 A Sure.
313
1 Q What does it say?
2 A Monday, March 9, 1998 under Paul
3 Begala. 8:30 a.m., Asian Finance COS.
4 Q What is Asian Finance COS?
5 A It means that he had a meeting that
6 they called Asian Finance?
7 Q Do you know what that was about?
8 A No, I don't.
9 Q Do you know who was in the meeting?
10 A No I don't.
11 Q All right. Next?
12 A 11:00 a.m.
13 COS scheduling.
14 Q What does COS mean, chief of staff?
15 A Yes, it does.
16 Q Next?
17 A Also in brackets or one bracket,
18 11:00 a.m., POTUS AMA speech briefing to
19 11:30 a.m.
20 Q What is POTUS?
21 A President of the United States.
22 Q And does AMA mean?
314
1 A American Medication Association.
2 Q Next?
3 A 2:15, POTUS scheduling meeting.
4 Q Next?
5 A 3:30p, meet with political
6 communications students, Roosevelt Room.
7 Q Next?
8 A 4:30p, Pablo Halpern meeting, OEOB
9 147.
10 Q Who is Pablo Halpern?
11 A I don't know.
12 Q Next?
13 A 6:00 o'clock; large Asian markets,
14 COS.
15 Q Let's go to the next page. Go
16 ahead, if you can read down that schedule?
17 A Sure. 8:30 a.m., COS budget.
18 Q Next?
19 A 12:00 o'clock, Ken Walsh, Bombay
20 Club.
21 Q Who's Ken Walsh?
22 A He is a journalist?
315
1 Q With who?
2 A I believe, US News & World Report.
3 Q Your office does a lot of work with
4 journalists, correct?
5 A I guess, yes.
6 Q How would you best describe Paul
7 Begala, as a spinmeister?
8 A I would not describe Paul as a
9 spinmeister.
10 Q How would you describe him?
11 A As a senior advisor to the
12 President doing his job.
13 Q Well, doesn't he communicate with
14 the press to try to get the press to see
15 things in a light favorable to the Clinton
16 administration? Isn't that part of his job?
17 A What Paul does is he -- yes, it is
18 his job to communicate what, what the
19 administration is interested in policy-wise.
20 Q And it's also his job to
21 communicate with the press to get them to
22 view perceived adversaries of the Clinton
316
1 administration negatively, correct?
2 A Paul feels very strongly about not
3 attacking people in an unfair way. He feels
4 that issues stand on their own and that if --
5 I have to say this is my impression of what
6 Paul thinks. I don't know exactly what he
7 thinks, but I think that he feels that we win
8 things on issues, not on slamming people.
9 Q He would never call anybody a name,
10 would he?
11 A In moments of weakness, he may
12 have.
13 Q Next.
14 A Oh, Keith Mason, Jos‚ Fuentes
15 Agostini.
16 Q Who is he?
17 A Keith Mason is a friend of his.
18 Q Jos‚ Fuentes what?
19 A I believe it's Agostini.
20 Q And who is that?
21 A He's the attorney general of Puerto
22 Rico.
317
1 Q Next?
2 A Pre-Residence meeting, John's
3 office.
4 Q What's that?
5 A It's a meeting people have before
6 they have their residence meetings.
7 Q What is a residence meeting?
8 A It's a meeting with lots of senior
9 staff and the President in the residence that
10 you -- that happens every week.
11 Q Do you know what that meeting was
12 about?
13 A No.
14 Q Do you know who attended?
15 A I don't know who attends those
16 meetings.
17 Q Does the First Lady attend those
18 meetings?
19 A Not that I'm aware of.
20 Q The President?
21 A From what I understand.
22 Q And they have those meetings every
318
1 week?
2 A It's a regular happening. It
3 doesn't always happen every week.
4 Q They have those meetings more than
5 once a week?
6 A I'm not aware of that happening.
7 Q Where do they meet in the
8 residence?
9 A I don't know.
10 Q Do you know the room?
11 A No, I don't.
12 Q Type of room?
13 A I've never within to the upstairs
14 part of the residence. I don't know what the
15 layout is.
16 Q Does Paul sometimes take documents
17 with him when he goes to those meetings?
18 A Not that I'm aware of.
19 Q Is that the same room where they
20 discovered those billing records?
21 MS. SHAPIRO: Objection. She's
22 already testified she doesn't know what room
319
1 it is.
2 BY MR. KLAYMAN:
3 Q You can respond.
4 A Not that I'm aware of.
5 Q Next. What else does it say?
6 A Africa, Roosevelt Room.
7 Q Next.
8 A Lateline buffet reception.
9 Q What's that?
10 A Well, all of that together was an
11 event to celebrate the television show
12 Lateline.
13 Q Next?
14 A Screening.
15 Q What's a screening?
16 A The screening of the show Lateline.
17 Q What is Lateline?
18 A It's a situation comedy, I guess it
19 was starring Al Franken that I understand
20 it's supposed to lampoon Nightline. Last
21 night was its first episode.
22 Q And Al Franken was doing a little
320
1 private screening for you-all?
2 A From what I understand -- I don't
3 agree with your characterization of it but
4 there are lots of different kinds of people
5 there, but --
6 Q Were you there?
7 A I was not there.
8 Q Who was there?
9 A I don't know for sure. I've only
10 read press accounts of it. I just know my
11 boss, my boss and his wife went.
12 Q Where did you read the press
13 accounts?
14 A I think in the "Style" section.
15 Q Was the President there?
16 A To the best of my knowledge, no.
17 Q Mrs. Clinton?
18 A I'm not aware.
19 Q Next page, March 11, read to me
20 that schedule.
21 A COS tobacco strategy. Budget
22 supplemental COS, Bill Burton, Mess.
321
1 Q Who is Bill Burton?
2 A I know he used to work in the
3 administration but he is also a friend of
4 Paul's.
5 Q What does he do in the
6 administration?
7 A He used to -- I don't know what he
8 did.
9 Q What did he used to do?
10 A I said I don't know what he did.
11 Q Do you know what he does now?
12 A No, I don't.
13 Q Is Paul close with Bill Burton?
14 A I don't know what the extent of
15 their friendship is.
16 Q Do you know where he lives?
17 A I don't.
18 Q Who is George Stephanopoulos'
19 closest friend?
20 A I am in no position to judge that.
21 Q You know some of his friends, don't
22 you?
322
1 A Yes.
2 Q Name some of his friends?
3 A Paul Begala.
4 Q Who else?
5 A Wendy Smith.
6 Q Who else?
7 A Those are the people that at this
8 time I can verify I know are his friends.
9 Q And where does Wendy Smith live?
10 A New York.
11 Q Do you know where?
12 A No.
13 Q Do you know where she works?
14 A New Yorker.
15 Q Next.
16 A Budget (Hill focus), Gene's office.
17 Q Who is Gene?
18 A Gene Sperling.
19 Q Okay. Next?
20 A POTUS International Women's Day
21 briefing, Map Room.
22 Q Next?
323
1 A Rahm's office.
2 Q Do you know what the meeting in
3 Rahm's office was about?
4 A I don't remember.
5 Q Next. Did you know at one time?
6 A Maybe.
7 Q Next.
8 A POTUS Ruff, Podesta meeting.
9 Q What was that about?
10 A I do not know.
11 Q Have you ever had contact with
12 Mr. Podesta?
13 A I can remember speaking with him
14 once.
15 Q What was that about?
16 A It was at our holiday party. The
17 chief of staff's office had a holiday party.
18 Q Did you talk to him about anything
19 concerning filegate?
20 A To the best of my recollection, no.
21 Q Have you ever had contact with
22 Bruce Lindsey?
324
1 A I may have exchanged pleasantries
2 with him during my time as an intern and
3 volunteer and during my time as an advance
4 person.
5 Q Mack McClarty?
6 A I have exchanged pleasantries with
7 Mr. McClarty during my time as a volunteer,
8 as an intern, during my time as an advance
9 person, and as a staff person.
10 Q Webster Hubble?
11 A I've never spoken with Mr. Hubble.
12 Q Janet Reno?
13 A I don't remember having spoken with
14 Ms. Reno.
15 Q You think you might have?
16 A There is a possibility she may have
17 called for George.
18 Q How did you meet Vernon Jordan?
19 MS. SHAPIRO: I think there's an
20 objection to this, that, if you wanted to
21 pursue the Vernon Jordan inquiry without
22 making a legitimate proffer of relevancy, we
325
1 would call the judge.
2 MR. KLAYMAN: I already did. I
3 just asked you how she met him.
4 MS. SHAPIRO: And you represented
5 that was your last question several hours
6 ago.
7 MR. KLAYMAN: Well, this is a
8 question I just thought of.
9 MS. SHAPIRO: And what's the
10 relevancy?
11 BY MR. KLAYMAN:
12 Q Did you meet him at work?
13 MS. SHAPIRO: Are you refusing to
14 offer a proffer of relevancy?
15 MR. KLAYMAN: I already did.
16 THE WITNESS: I don't remember the
17 first time we met.
18 BY MR. KLAYMAN:
19 Q Did you meet him at work?
20 A I don't remember the first time we
21 met.
22 Q How did you meet him?
326
1 A I don't remember the first time we
2 met.
3 Q How did you meet him?
4 A I don't remember the first time we
5 met.
6 Q Are you talking the Fifth
7 Amendment? That's not my question.
8 MS. SHAPIRO: She's answered the
9 question.
10 MR. KLAYMAN: No, I didn't ask her
11 that question.
12 MS. SHAPIRO: Maybe you can
13 rephrase the question.
14 BY MR. KLAYMAN:
15 Q How did you meet?
16 A I don't remember the first time we
17 met.
18 Q Well, I'm not talking about the
19 time. I'm talking about was it at work or
20 outside the work?
21 A I can't describe something I don't
22 remember.
327
1 Q All right, certify it. Has
2 Mr. Begala ever lied to you?
3 A Not that I'm aware of.
4 Q Has he ever said anything that
5 wasn't true?
6 A Not that I'm aware of.
7 Q Has he ever said anything that
8 turned out not to be true?
9 A Nothing comes to mind.
10 Q Have you ever seen Mr. Begala throw
11 a document away?
12 A I've seen him throw paper away.
13 Q Did he ever tell you why he was
14 throwing paper away?
15 A He's never offered me an
16 explanation for why he's throwing things
17 away.
18 Q You've seen him take some documents
19 home, haven't you?
20 A Yes.
21 Q And you've seen him take some
22 documents home recently, haven't you?
328
1 A The last time I remember seeing him
2 take a folder home, it's been weeks.
3 Q Do you know what was in the folder?
4 A No. I'd like to take a break.
5 Q One last question before the break?
6 MS. SHAPIRO: She wants to take a
7 break.
8 BY MR. KLAYMAN:
9 Q You never saw him bring the folder
10 back, did you?
11 A I don't keep track.
12 THE VIDEO SPECIALIST: We're going
13 off video record at 4:15.
14 (Recess)
15 THE VIDEO SPECIALIST: We're back
16 on video record at 4:28.
17 MS. SHAPIRO: I just like to note
18 that we have been here for about 10 minutes.
19 MR. KLAYMAN: That's correct. I
20 had to take a call.
21 BY MR. KLAYMAN:
22 Q Have you ever been asked by
329
1 Mr. Begala to type up notes for him?
2 A No, I have not.
3 Q He keeps lists of things that he
4 has to do on a daily basis, doesn't he, jots
5 them down?
6 A I've seen him do that.
7 Q And where are those notes stored?
8 A They're not systematically stored
9 any place. Sometimes they're in his desk,
10 just on his desk, in his lapel. Those are
11 the only places I know that they -- that they
12 could be if he's still using them.
13 Q Is there a criterion that you use
14 to send documents to records management?
15 A Yes, there is.
16 Q What's the criterion?
17 A All incoming correspondence that is
18 signed and is an original document we send
19 down. We send down any responses to that
20 incoming correspondence and anything that's
21 generated by our office, any original
22 memoranda, is supposed to do down but it
330
1 doesn't have to immediately go down. We can
2 keep it in our office, but eventually it will
3 have to go down.
4 Q In doing the document search for
5 Mr. Begala's notice of deposition duces
6 tecum, on your own you didn't check with
7 records management, did you?
8 A No, I did not.
9 Q Is there a taping device in your
10 and Mr. Begala's office?
11 A I am not aware of any kind of
12 taping device in our office.
13 Q You've heard him say can I tape
14 this conversation from time to time?
15 A I've never heard that conversation
16 -- I've never heard him say that.
17 Q Do you know whether his
18 conversations have ever been taped?
19 A To the best of my knowledge, no.
20 Q Have you ever taken files or
21 documents home?
22 A Not that I'm aware of.
331
1 Q You have some documents at home
2 now, don't you?
3 A Not that I'm -- I took my
4 deposition home. I took this, my little
5 packet.
6 Q What little packet?
7 A My notice, I took that home last
8 night.
9 Q But you have other documents at
10 your house, too, don't you?
11 A Not that I'm aware of.
12 Q Where is your house?
13 MS. SHAPIRO: Objection. She
14 doesn't have to answer that.
15 MR. KLAYMAN: Do you want to give
16 it to us in confidence? I want you to give
17 it to the court. Are you willing to give it
18 to the court?
19 MS. SHAPIRO: Absolutely not, she
20 doesn't have to tell you where she lives.
21 You can have her work address if you want it.
22 BY MR. KLAYMAN:
332
1 Q Did you search your house for
2 documents? Do you live in a house?
3 A I do not live in a house.
4 Q It is an apartment?
5 A It is an apartment.
6 Q Did you search your apartment for
7 documents in response to Mr. Begala notice of
8 deposition or your own?
9 A No.
10 Q But you do have documents there,
11 don't you?
12 MS. SHAPIRO: Objection. She's
13 answered that three times.
14 BY MR. KLAYMAN:
15 Q You can respond.
16 A Not that I'm aware of.
17 Q But you're not sure?
18 A It is not my practice to bring home
19 documents.
20 Q Do you have a brief case?
21 A No, I don't.
22 Q Have you ever used any kind of
333
1 shopping bag or any other receptacle to take
2 things out of the White House?
3 A Only my personal belongings.
4 Q What do you use for that?
5 A I have a bag that I bring my gym
6 clothes in and my water.
7 Q Do you have a laptop computer?
8 A No, I do not.
9 Q Does Mr. Begala?
10 A I believe there -- a laptop is
11 actually sitting in our office, but I don't
12 think -- he doesn't use -- I've never seen
13 him use it.
14 Q It's his laptop?
15 A I don't remember -- I don't -- I
16 don't know for sure.
17 Q It's not your laptop?
18 A It's not my laptop.
19 Q Are you aware of any documents
20 having been sent to the National Archives
21 from your office?
22 A I am not aware.
334
1 Q Have you ever met Billy Dale?
2 A No, I have not.
3 Q Have you ever heard anyone discuss
4 Billy Dale or the White House travel office?
5 A I think I remember once someone
6 mentioning it.
7 Q Who mentioned it?
8 A I don't remember exactly who
9 mentioned it.
10 Q Where was it mentioned, in what
11 context?
12 A When talking about a staff person,
13 I believe it was mentioned that they had been
14 involved in the problem.
15 Q What staff person was that?
16 A Katherine Cornelius.
17 Q And how did it come up with
18 Katherine Cornelius?
19 A I don't remember.
20 Q Where were you when she said that
21 to you?
22 A I don't know where she was.
335
1 Q Where were you?
2 A I don't remember.
3 Q And what did she tell you
4 specifically?
5 A I don't know it was a she who told
6 me.
7 Q Did she or anyone who mentioned her
8 involvement told you that they had pulled
9 Billy Dale's FBI file at the White House?
10 A No one has ever told me that.
11 Q Are you sure?
12 A I'm sure of that.
13 Q Are you aware that Billy Dale's
14 file was filed from the FBI by the White
15 House?
16 A I'm not aware of that.
17 Q Have you read that?
18 A I don't remember reading that.
19 Q Did you ever hear of Mr. ����?
20 A That name is not familiar.
21 Q From the travel office?
22 A That name is not familiar.
336
1 Q Are you aware that the White House
2 had his file sent over, too?
3 A I'm not aware of that.
4 Q Have you ever discussed with anyone
5 Linda Tripp?
6 A Anyone in the whole wide world?
7 Q Uh-huh.
8 A I think Linda Tripp has come up in
9 conversations that I've had in the last few
10 months.
11 Q Who did it come up with?
12 A My friends.
13 Q Did it come up with anybody at the
14 White House?
15 A I don't remember having any
16 discussions with anybody in the White House
17 regarding Linda Tripp.
18 Q That doesn't mean you didn't --
19 A No, wait, I did have one discussion
20 with somebody.
21 Q Ho did you have it with?
22 A Ruby Shamir.
337
1 Q Who is Ruby Shamir?
2 A Her last is pronounced Sha-mir.
3 And she is an assistant.
4 Q To who?
5 A She primarily -- I think she
6 primarily assists Ann Lewis but she also
7 helps out Sid Blumenthal.
8 Q You have pretty regular contact
9 with Ruby?
10 A Yes, I do.
11 Q And in what context do you have
12 regular context with Ruby?
13 A Personal and professional.
14 Q Well, let's talk about the
15 professional. Why are you in regular contact
16 with her?
17 A Because we have to schedule a lot
18 of meetings. Just in the course of the day
19 we just end up talking a lot.
20 Q What kind of meetings are you
21 scheduling with her?
22 A Whatever -- whatever kind of
338
1 meetings our bosses ask us to schedule.
2 Q So Paul Begala and Blumenthal have
3 a lot of meetings together?
4 A Not necessary.
5 Q But they have some meetings
6 together?
7 A I guess that's fair to say.
8 Q And why do they have meetings
9 together?
10 A To do their job.
11 Q And what do you know their jobs to
12 be that require them to meet?
13 A To discuss policy and communication
14 strategy.
15 Q And what is policy and
16 communication strategy to the best of your
17 knowledge?
18 A Deciding on a policy and coming up
19 with the strategy to, you know -- to persuade
20 a relevant audiences is that your policy's a
21 good idea.
22 Q And to persuade a relevant
339
1 audiences that your adversaries are not good
2 people?
3 A I did not say that.
4 Q To destroy the credibility of
5 anybody who questions the administration?
6 Isn't that part of it?
7 MS. SHAPIRO: Objection. You're
8 badgering the witness. She answered your
9 question.
10 BY MR. KLAYMAN:
11 Q Now, they have had several meetings
12 lately with regard to Kathleen Willey,
13 haven't they?
14 A I'm not aware of that.
15 Q And they have had meetings with
16 regard to Monica Lewinsky, have they not?
17 MS. SHAPIRO: What's the relevance
18 of this? Are you going to give me a proffer
19 of relevance?
20 MR. KLAYMAN: No.
21 BY MR. KLAYMAN:
22 Q They've had meetings about Monica
340
1 Lewinsky, haven't they?
2 A I don't know who the "they" is.
3 MS. SHAPIRO: Okay. I'm
4 instructing her not to answer any further
5 questions.
6 MR. KLAYMAN: Certify it.
7 BY MR. KLAYMAN:
8 Q They have had meetings with regard
9 to the use of FBI files to smear people,
10 haven't they?
11 A I don't know who the "they" is.
12 Q Begala and Blumenthal?
13 MS. SHAPIRO: Objection. You
14 haven't establish any foundation that she
15 knows the substance of any meeting.
16 BY MR. KLAYMAN:
17 Q You can respond.
18 A I'm not aware of any such meetings.
19 Q But you don't know what goes on in
20 those meetings, do you? Are you invited?
21 A I'm usually not invited.
22 Q You don't know whether they're
341
1 discussing these private investigators or not
2 in those meetings, do you?
3 A You're right.
4 Q And you don't know whether they're
5 talking about FBI files, do you?
6 A You're right.
7 Q And you don't know whether they
8 have FBI files in those meetings, do you?
9 A To the best of my knowledge, they
10 certainly do not.
11 Q But you're not there, so you don't
12 know, right?
13 A Correct.
14 Q Have you ever asked?
15 A No, I have not.
16 Q And who attends those meetings?
17 A It depends on the meetings.
18 Q I'm talking about these
19 communications and strategy meetings. Who
20 generally attends?
21 A It matters what the subject matter
22 is. It matters what the issue is, and there
342
1 is a difference between being invited and the
2 person actually attending, and the best I
3 could ever have -- the best knowledge I could
4 ever have would be who was invited to a
5 meeting, if I remembered who was invited.
6 Q Well, who was invited to at least
7 one meeting. Tell me.
8 A Can you be specific regarding to a
9 particular meeting?
10 Q Let's talk in the last month. Have
11 there been such meetings?
12 A Regarding?
13 Q Anything?
14 A There have been meetings in the
15 White House within the last month.
16 Q Those kinds of meetings,
17 communication strategy meetings, there have
18 been meetings, right?
19 A There have been different kinds of
20 meetings to discuss different issues.
21 Q And who went to some of those
22 meetings?
343
1 A Senior staff members.
2 Q Who? Names?
3 A Okay, I will go ahead and list
4 possible people that could attend possible
5 meetings in the White House, okay.
6 Q The types of meetings we're talking
7 about?
8 A Well, that isn't specific enough.
9 Q Well, I'm using your definition,
10 communication strategy meetings. List those
11 people, please.
12 A I mean, no one is having a meeting
13 called a communication strategy meeting.
14 It's usually for a specific event or a
15 specific issue.
16 Q Generally, tell me who in the last
17 month has met with regard to these types of
18 meetings?
19 MS. SHAPIRO: Maybe you can
20 rephrase the question.
21 MR. KLAYMAN: No, I'm not going to
22 rephrase it. I want an answer to the
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1 question.
2 MS. SHAPIRO: She answered your
3 question.
4 MR. KLAYMAN: She did not answer my
5 question.
6 MS. SHAPIRO: Could you read back
7 her response to Mr. Klayman's question?
8 MR. KLAYMAN: I don't need a
9 response. It was not responsive. Please
10 don't waste my time.
11 BY MR. KLAYMAN:
12 Q Who went to these meetings?
13 MS. SHAPIRO: She answered the
14 question and we'll read it back to you.
15 MR. KLAYMAN: Please answer the
16 question. She did not answer. I have no
17 names.
18 MS. SHAPIRO: I'm not going to tell
19 you what she testified to because we can have
20 it read back. She answered the question.
21 BY MR. KLAYMAN:
22 Q Please respond. Please respond. I
345
1 want names of people who you know went to
2 such meetings.
3 MS. SHAPIRO: Do you want me to
4 tell you what her answer was.
5 MR. KLAYMAN: No, I do not. I want
6 you to stop on obstructing my deposition.
7 MS. SHAPIRO: I'm not obstructing
8 your deposition.
9 MR. KLAYMAN: Certify this. I'm
10 asking you to stop.
11 MS. SHAPIRO: If you want a
12 response, you can read back the transcript of
13 what her response was.
14 MR. KLAYMAN: I do not want that
15 response. I want names.
16 MS. SHAPIRO: If he doesn't have a
17 response that you like, that is not a reason
18 to badger her.
19 MR. KLAYMAN: I'm not badgering
20 anyone. You're badgering me, Ms. Shapiro.
21 Certify it. Obstructing a deposition and
22 badgering me.
346
1 BY MR. KLAYMAN:
2 Q Please give me names of people who
3 you know went to such meetings, please.
4 MS. SHAPIRO: You can answer the
5 question one more time if you can, and,
6 otherwise, we won't repeat this all day.
7 BY MR. KLAYMAN:
8 Q That's completely objectionable.
9 You're telling the witness not to answer,
10 Ms. Shapiro?
11 MS. SHAPIRO: I'm telling the
12 witness to answer one more time and I've
13 offered to read it back to you.
14 MR. KLAYMAN: Certify it.
15 BY MR. KLAYMAN:
16 Q Please respond.
17 A From what I understand, you
18 distorted how I described what I thought Paul
19 did in the White House and made it sound like
20 we had meetings, but that's what they do, so
21 therefore I can't speak to a meeting like
22 that. I mean, you'd have to ask me about a
347
1 specific meeting and then maybe I can respond
2 to that.
3 Q I'm asking you with regard to any
4 meetings that Mr. Begala attended with
5 Mr. Blumenthal. Let's try it that way. Who
6 else was present?
7 A Offhand, I can't remember.
8 Q You can't remember?
9 A I can't remember.
10 Q It's your job to know who goes to
11 those meetings, is it not?
12 A Perhaps at that moment it is, but
13 we have several meetings --
14 Q Your mind's gone blank? Is that
15 what you're telling me?
16 A We have several meetings a day.
17 Q Are you telling me your mind's gone
18 blank?
19 MR. KLAYMAN: You're not counsel of
20 record, please stop.
21 MS. PAXTON: I am counsel of
22 record, and please stop badgering the
348
1 witness.
2 MR. KLAYMAN: One counsel at a
3 time.
4 MS. PAXTON: If you continue this,
5 we're going to shut this deposition down. If
6 you have a relevant question to ask, ask it;
7 otherwise, move on. If you have a relevant
8 question, please ask it.
9 MR. KLAYMAN: Do what you want and
10 you do it at your own risk.
11 MS. PAXTON: Do you have any more
12 relative questions to ask this witness,
13 Mr. Klayman.
14 MR. KLAYMAN: One counsel at a
15 time. You're not defending this deposition.
16 BY MR. KLAYMAN:
17 Q Do you now have a memory?
18 A I don't have a specific memory of a
19 specific meeting where I can recount to you
20 who was invited.
21 Q Well, just tell me anybody based on
22 your experience in the office who may have
349
1 gone to a meeting in the last month?
2 MS. PAXTON: This is completely
3 irrelevant to this deposition.
4 MR. KLAYMAN: You can respond.
5 MS. PAXTON: That's it.
6 MS. SHAPIRO: Hold on a minute.
7 We're going to take a short break.
8 (Recess)
9 MS. SHAPIRO: Are we on the record?
10 We'll like to phone the judge at this time
11 because we think you're badgering our witness
12 with irrelevant questions about things that
13 she's testified about and that she's already
14 said she can't remember and you're persisting
15 in badgering her.
16 MR. KLAYMAN: Well, I'll have to
17 bring her back, anyway. So we'll certify it
18 and we'll submit the whole section. Well,
19 there are many things that are going to be at
20 issue in this deposition, Mr. Shapiro, so I
21 don't want to badger the judge and neither do
22 I want to badger you, but I'll tell you
350
1 something. This is one of the worst
2 depositions I've ever seen defended and I'm
3 asking you to alleviate some of the problems
4 that are occurred here by letting her
5 respond.
6 MS. SHAPIRO: You can posture all
7 you want, Mr. Klayman. You're not
8 intimidating me and your threats have no
9 impact.
10 MR. KLAYMAN: Certify it.
11 BY MR. KLAYMAN:
12 Q Have you ever discussed ����
13 Goldberg with anybody?
14 A No, I have not.
15 Q Based on your experience in working
16 with Mr. Begala, how many people --
17 A Wait, I have to add something to my
18 last answer: I think my mother may have said
19 at one point isn't there -- isn't there a
20 book deal involved with ���� Goldberg and I
21 may have acknowledged what she said.
22 Q I'm not asking you about your