351


       1    mother.

       2         A    Well, I just wanted to give you an

       3    accurate answer.

       4         Q    What reporter is Mr. Begala the

       5    closest with?

       6         A    I'm not in position to judge

       7    closeness.

       8         Q    Who do you know that he sees

       9    frequently or talks to frequently?

      10         A    He talks to Mark Halperin, he talks

      11    to Wolf Blitzer, he talks to John King.

      12         Q    John who?

      13         A    King.

      14         Q    Who is he with?

      15         A    CNN.  Talks to Karen ÄÄÄÄ.

      16         Q    Who is she with?

      17         A    Time.  John Harris calls.

      18         Q    From the Post?

      19         A    Correct.

      20         Q    Who else?

      21         A    Peter Baker.

      22         Q    Who else?








                                                              352


       1         A    I mean, other people call.  Those

       2    are the people who stand out as people who

       3    call, who call more.

       4         Q    Have you ever heard any discussions

       5    about a report prepared inside the White

       6    House called the communications stream of

       7    commerce?

       8         A    It's not familiar.

       9         Q    Are you aware of anyone inside the

      10    White House ever having gathered information

      11    about journalists who are considered to be

      12    adverse to the administration?

      13         A    I think I read press accounts of

      14    it.

      15         Q    Are you aware of it ever having

      16    occurred?

      17         A    No, I'm not.

      18         Q    Have you ever had any

      19    communications in your office from the

      20    Internal Revenue Service?

      21         A    Not that I'm aware of.

      22         Q    Has Mr. Begala ever called the








                                                              353


       1    Internal Revenue Service?

       2         A    Not that I'm aware of.

       3         Q    Do you know of anyone who has?

       4         A    I'm sorry?

       5         Q    Do you know of anyone who has?

       6         A    In what capacity?

       7         Q    In any capacity.

       8         A    I mean, it's highly conceivable

       9    that anyone could have called the IRS for any

      10    number of reasons since everyone must file

      11    their taxes.

      12         Q    I'm going to show you what was

      13    marked as exhibit 11 to Mr. Carville's

      14    deposition and ask whether you've ever seen

      15    any of these documents before?

      16         A    Okay.

      17              MS. PAXTON:  What exhibit is this?

      18              MS. SHAPIRO:  Here.  I got passed

      19    over.

      20              BY MR. KLAYMAN:

      21         Q    Have you ever seen any of these

      22    documents before?








                                                              354


       1         A    No, I have not.

       2              BY MR. KLAYMAN:

       3         Q    Have you ever seen a New Republican

       4    article about Larry Klayman?

       5         A    Not to the best of my knowledge.

       6         Q    Do you know what the New Republic

       7    is?

       8         A    Yes, I do.

       9              MR. KLAYMAN:  I'll just show you

      10    what has been marked as Exhibit 5 to

      11    Mr. Stephanopoulos' deposition which is a

      12    press release of June 14, 1996.  In fact,

      13    I'll ask that it be marked in this

      14    deposition.  What's the next one, exhibit

      15    what, 11?

      16                   (Parker Deposition Exhibit

      17                   No. 11 was marked for

      18                   identification.)

      19              BY MR. KLAYMAN:

      20         Q    Have you ever seen this document

      21    before?

      22              You can take the time and review it








                                                              355


       1    if you'd like.

       2         A    I've never seen this document

       3    before.

       4              MR. KLAYMAN:  I'll show you what

       5    I'll ask the Court reporter to mark as

       6    Exhibit 12 and ask whether you've ever seen

       7    this document before.

       8                   (Parker Deposition Exhibit

       9                   No. 12 was marked for

      10                   identification.)

      11              THE WITNESS:  I've never seen this

      12    document before.  And I'd like to add that I

      13    was not in the White House during the time it

      14    was -- June 14.

      15              BY MR. KLAYMAN:

      16         Q    I just asked you whether you've

      17    ever seen the document before.

      18              Did you meet Mr. Livingstone before

      19    the inaugural in 1993?

      20         A    To the best of my memory, no.

      21         Q    Did you meet Livingstone more than

      22    once?








                                                              356


       1         A    I've had contact with him more than

       2    once.

       3         Q    You identified two occasions.  What

       4    in addition to the two that you previously

       5    testified to?

       6         A    There was one time he was taking

       7    someone on a tour in the White House and he

       8    stopped by our office he introduced us to the

       9    person he was taking on tour.  I also

      10    remember him calling the office and offering

      11    concert tickets.

      12         Q    Who was he taking on a tour?

      13         A    David Bowie.

      14         Q    The rock singer?

      15         A    Yes.

      16         Q    Did he stop by the office with

      17    David Bowie?

      18         A    Yes, he did.

      19         Q    Who was in the office at the time?

      20         A    I don't remember who was the

      21    assistant at the time.

      22         Q    Was it when you were working for








                                                              357


       1    Stephanopoulos or Begala?

       2         A    Stephanopoulos.

       3         Q    And did he meet George

       4    Stephanopoulos, Livingstone, at the time?

       5         A    I don't remember if George was

       6    there.

       7         Q    You think he was there, don't you?

       8         A    No, I don't remember.

       9              MS. SHAPIRO:  Objection.

      10              BY MR. KLAYMAN:

      11         Q    He met several people in the

      12    office, didn't he?

      13         A    Who are you referring to?

      14         Q    Livingstone?

      15         A    Excuse me.

      16         Q    When Livingstone brought Bowie to

      17    the office, he met several people in the

      18    office?

      19         A    I don't remember who else was

      20    there.  I remember -- I remember a comment

      21    that Livingstone made and I remember meeting

      22    David Bowie.








                                                              358


       1         Q    He met the President, didn't he?

       2         A    Excuse me?

       3         Q    Livingstone and Bowie met the

       4    President when they came by George's office.

       5         A    I'm not aware of that.

       6         Q    George's office is right next to

       7    the Oval Office, isn't it?

       8         A    That's true.

       9         Q    And they walked into the Oval

      10    Office?

      11         A    I'm not aware of that.

      12         Q    With Livingstone?

      13         A    I have no idea.

      14         Q    But it may have happened?

      15         A    A lot of things may have happened.

      16         Q    I'm asking do you know whether it

      17    happened definitively or not?

      18         A    No, I'm not aware.

      19         Q    And what was the other time with

      20    these tickets, concert tickets?  Who did he

      21    call for those, George?

      22         A    The way I remember it is that he








                                                              359


       1    called twice, the first time to speak to

       2    whoever the assistant was at the time and the

       3    second time -- I don't remember if he -- I

       4    don't remember if he talked to me or not.  I

       5    just -- I -- I -- I kind of remember it as he

       6    had tickets.  I don't remember if he told the

       7    assistant that he had tickets.  I don't have

       8    a firm memory of how the whole thing

       9    happened.

      10         Q    And the tickets were intended for

      11    George Stephanopoulos?

      12         A    I don't remember who he was first

      13    offering them to.

      14         Q    He didn't offer them to you, did

      15    he?

      16         A    I don't remember if he personally

      17    offered them to me.  In the end I was able to

      18    go.

      19         Q    In the end you were?

      20         A    Yes.

      21         Q    You went?

      22         A    Uh-huh.








                                                              360


       1         Q    You had more than one set of

       2    tickets?

       3         A    From what I understand, there was a

       4    block of tickets.  They weren't for free.  We

       5    had to pay for them.

       6         Q    What concert was it?

       7         A    Pearl Jam.

       8         Q    And did he offer those ticks to

       9    George Stephanopoulos?

      10              MS. SHAPIRO:  Asked and answered.

      11              BY MR. KLAYMAN:

      12         Q    You can respond.

      13         A    I don't know.

      14         Q    Did he ask to speak to George

      15    Stephanopoulos?

      16         A    I don't remember.

      17         Q    You've seen Livingstone and

      18    Stephanopoulos together, haven't you?

      19         A    I don't have any image in my head

      20    of the two of them standing together.

      21         Q    But do you think that you've seen

      22    them together?








                                                              361


       1         A    I mean, I don't remember seeing

       2    them together.

       3         Q    In fact, the two of them were

       4    somewhat friendly, weren't they?

       5         A    May ask I how you define

       6    "friendly."

       7         Q    Knew each other quite well?

       8         A    I'm not aware of that.

       9         Q    Did you ever know of Livingstone

      10    visiting you or Stephanopoulos or Begala

      11    other than the times you've identified today?

      12         A    No, I do not.

      13         Q    Have you ever seen Livingstone and

      14    Hillary Clinton together?

      15         A    I have no recollection of that.

      16         Q    You don't know one way or the

      17    other?

      18         A    I have no memory of seeing them

      19    together.

      20         Q    Livingstone and the President?

      21         A    I have no memory of seeing them

      22    together.








                                                              362


       1              MS. SHAPIRO:  We're over the 6-hour

       2    time right now.  We're willing to go to 5:15,

       3    but that's over and above.

       4              MR. KLAYMAN:  Are you saying we

       5    have gone six hours at this point?

       6              MS. SHAPIRO:  Yes.

       7              MR. KLAYMAN:  And our records show

       8    that we haven't, and Mr. Fitton has been

       9    sitting here with a time clock.

      10              MS. SHAPIRO:  So have we.

      11              BY MR. KLAYMAN:

      12         Q    Have you ever seen the President

      13    and Livingstone together?

      14              MS. SHAPIRO:  Asked and answered.

      15              THE WITNESS:  I don't remember.

      16              BY MR. KLAYMAN:

      17         Q    Please answer.  You have no memory?

      18         A    I have in memory of them being

      19    together.

      20         Q    Have you ever seen an FBI file

      21    laying on anybody's desk?

      22         A    No, and that's to the best of my








                                                              363


       1    knowledge.

       2         Q    Have you ever seen an FBI file?

       3         A    I don't know.

       4         Q    When you met with Gary Aldridge,

       5    how many times did you meet with him?

       6         A    Once.

       7         Q    Do you think he was a pretty nice

       8    guy?

       9         A    He was pleasant with me.

      10         Q    And did he have FBI files with him?

      11    Did he have your file with him as he was

      12    sitting there?

      13         A    He did not verify to me that what

      14    was in front of him was my FBI file.  He

      15    didn't insinuate it.  He didn't say anything.

      16         Q    During the time that you worked in

      17    the White House, have you ever seen any

      18    memoranda circulated that talked about how,

      19    if you get inquiries from the press, you

      20    should response?

      21         A    Excuse me?

      22         Q    During the time that you have








                                                              364


       1    worked at the White House, have you ever seen

       2    any memoranda written on White House

       3    stationery or otherwise which give

       4    instructions on how to respond if you get

       5    inquiries from the press?

       6         A    What kind of instructions?

       7         Q    I don't know.  I haven't seen them.

       8    I'm asking you.  Like, if you get an inquiry

       9    about filegate contact this person.  If you

      10    get an inquire about Monica Lewinski, contact

      11    this person?

      12         A    I have never seen a directive like

      13    that.

      14         Q    Have you seen any other directives

      15    of any sort?

      16         A    I've seen talking points.  I've

      17    seen press guidances.

      18         Q    Have seen talking points on

      19    anything dealing with FBI files?

      20         A    No I have.

      21         Q    Talking points on anything dealing

      22    private investigators?








                                                              365


       1         A    No.

       2         Q    Talking points on anything dealing

       3    with opposition research?

       4         A    No, I have not.

       5         Q    Talking points on anything dealing

       6    with the current controversies over Monica

       7    Lewinski and Linda Tripp and Kathleen Willey

       8    and others?

       9         A    No, I have not.

      10         Q    Did Stephanopoulos ever talk to you

      11    about Gary Aldridge?

      12         A    No, he has not.

      13         Q    Did he ever remark to you about any

      14    portions about Gary Aldridge's book?

      15         A    He never remarked about any

      16    portions of the book.

      17         Q    I'm coming to a close in terms of

      18    these questions subject, of course, to our

      19    need to recall the witness once we get all

      20    the documents and get a court ruling on the

      21    questions that weren't answered, but just to

      22    refresh my recollection on the first dates








                                                              366


       1    that you were in the White House I want to

       2    make sure I have them exactly.  During your

       3    first period there as a volunteer then an

       4    intern, what were the exact dates?

       5         A    I started some time in March of '93

       6    to the best of my memory and I stayed on as a

       7    volunteer until the fall semester of '95, and

       8    then I was an intern for that semester and

       9    then when that semester was over --

      10         Q    You were an intern after the fall

      11    semester of '95?

      12         A    No, fall '95, I was an intern.

      13    Then, after that, I was back to being a

      14    volunteer.

      15         Q    And what period were you a

      16    volunteer again?

      17         A    After that semester was finished

      18    through May '96.

      19         Q    And then you left again?

      20         A    Correct.

      21         Q    And when did you come back?

      22         A    I came back as a staff person in








                                                              367


       1    September of '97.

       2         Q    And you have been there ever since?

       3         A    Correct.

       4         Q    Do you have any other jobs?

       5         A    Right now?

       6         Q    Yes.

       7         A    No.

       8         Q    Did you ever know any interns that

       9    worked at Starbucks on Wisconsin Avenue?

      10         A    No.

      11         Q    Is that funny?

      12         A    I think it's awful.

      13         Q    Do you know somebody died there?

      14         A    I'm very aware that somebody died

      15    there.

      16         Q    Do you know whether it was a White

      17    House intern, a former White House intern?

      18         A    No, by I'm aware there is a

      19    conspiracy out there that suggests that.

      20         Q    Where did you hear that?

      21         A    I've heard it.

      22         Q    Where did you hear it?








                                                              368


       1         A    I don't remember.

       2         Q    Who told you that in the White

       3    House?

       4         A    I don't know.

       5              MS. SHAPIRO:  Objection.

       6              BY MR. KLAYMAN:

       7         Q    On the Drudge Report?  Is that

       8    where you heard it?

       9         A    I don't know.

      10         Q    You ever hear of ÄÄÄÄ?

      11         A    Excuse me.

      12         Q    ÄÄÄÄ?

      13         A    The name is not familiar.

      14         Q    Salon magazine, Salon web site?

      15         A    I'm familiar with Salon.

      16         Q    How did you become familiar with

      17    it?

      18         A    There have been articles that have

      19    been circulated from Salon so I started

      20    checking them out myself.

      21         Q    Who circulated them?

      22         A    I think Mr. Blumenthal has








                                                              369


       1    circulated them.

       2         Q    What articles are they?

       3         A    I don't keep track.

       4         Q    And this is fairly recent?

       5         A    Over the last couple of months.

       6         Q    And what were the articles about?

       7         A    I don't keep track.

       8         Q    Do you remember one article?

       9         A    I think there's a recent piece on

      10    ÄÄÄÄ.

      11         Q    Judge ÄÄÄÄ?

      12         A    Actually, I don't know very much

      13    about ÄÄÄÄ.  I don't know if he's a judge.

      14         Q    You mean ÄÄÄÄa person rather than

      15    hail that falls from the sky?

      16         A    A person named ÄÄÄÄ.

      17         Q    And has ÄÄÄÄ ever contacted the

      18    office?

      19         A    Not that I'm aware of.

      20         Q    Has Mr. Begala ever talked to ÄÄÄÄ?

      21         A    Not that I'm aware of.

      22         Q    Has Mr. Blumenthal?








                                                              370


       1         A    I can't speak to that.

       2         Q    Has anybody that you know of?

       3         A    I have no knowledge of anyone

       4    speaking to him.

       5         Q    What's your understanding of what

       6    Salon is.

       7         A    It's a magazine on the net.  It's a

       8    -- I mean, I see it as a magazine.

       9         Q    The White House is feeding Salon

      10    information, is it not?

      11         A    I can't speak to that.

      12         Q    You don't know?

      13         A    I can't speak to that.  I don't

      14    know.

      15         Q    The information that you've seen

      16    that Mr. Blumenthal circulate, how did it

      17    come to your attention?

      18         A    Interoffice mail.

      19         Q    And does he attach the entire copy

      20    of the web site or what was included?

      21         A    A printout of the article.

      22         Q    What was the article about?








                                                              371


       1         A    I don't keep track of the articles

       2    that have come through.

       3         Q    It's understood in the White House

       4    that this is a publication that's meant to

       5    smear conservatives, isn't it?

       6         A    I don't know it -- I've never

       7    spoken to anyone else about their

       8    understanding of Salon.

       9         Q    What's your understanding?

      10              MS. SHAPIRO:  Asked and answered.

      11              BY MR. KLAYMAN:

      12         Q    You can respond.

      13         A    I see it as a magazine.

      14         Q    What's the reputation in the White

      15    House as to the nature of the Salon magazine.

      16    Is it viewed like a tabloid?

      17         A    I answered that.

      18         Q    Do you have any knowledge as to who

      19    pays for Salon?

      20         A    Who do -- what do you mean?

      21         Q    Do you know of anyone who supports

      22    Salon magazine?








                                                              372


       1         A    I've never noticed any advertisers,

       2    if they have advertisers.

       3         Q    Have you ever talked to

       4    Mr. Carville about Salon magazine?

       5         A    No, I have not.  The.

       6         Q    Is it your understanding that Salon

       7    magazine is the liberal version of the Drudge

       8    Report?

       9         A    I have never thought of it in that

      10    way.

      11         Q    Does that make sense to you?

      12         A    I wouldn't agree with that

      13    characterization.

      14         Q    Why?

      15         A    It's not something I would come up

      16    with.

      17         Q    Have you ever become aware of an

      18    organization called the Education and

      19    Information Project?

      20         A    I have never heard of that.

      21         Q    Do you know whether that's

      22    connected with Mr. James Carville?








                                                              373


       1         A    I have never heard of it.

       2         Q    How did you find out about Linda

       3    Tripp's arrest record?

       4              MS. SHAPIRO:  Objection.

       5              BY MR. KLAYMAN:

       6         Q    Have you found out about Linda

       7    Tripp's arrest record through White House

       8    sources?

       9         A    No.

      10         Q    Having gone through this entire

      11    deposition, is there anything that you

      12    haven't told me with regard to any

      13    information that you've ever seen or heard at

      14    the White House concerning the Federal Bureau

      15    of Investigation?

      16         A    Excuse me?  Could you please --

      17         Q    Having now gone through this

      18    investigation, is there anything that you

      19    haven't testified to thus far about

      20    information that you've heard or seen or

      21    obtained at the White House about FBI files?

      22         A    No.








                                                              374


       1              MR. KLAYMAN:  I have no further

       2    questions at this time and we will leave the

       3    deposition open for the reasons stated about

       4    10 minutes ago.

       5              MS. SHAPIRO:  We'll object as

       6    usual.  The deposition is closed.

       7              THE VIDEO SPECIALIST:  We're going

       8    off video record at 5:15.

       9                   (Whereupon, at 5:15 p.m., the

      10                   deposition of ELEANOR STACY

      11                   PARKER was adjourned.)

      12                   *  *  *  *  *

 

 

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