1     says, "The associated press reported last

         2     week that Secret Service entry logs showed

         3     Lenzner himself visiting the White House a

         4     half dozen times in recent years, including a

         5     1996 meeting with ex-deputy chief of staff

         6     Harold Ickes to discuss potential

         7     investigative work."

         8               You are aware that Mr. Lenzner

         9     visited Ickes to discuss investigative work?

        10          A    No.

        11          Q    You never heard that before?

        12          A    No.

        13          Q    Have you ever seen him in the White

        14     House other than times that he came in to see

        15     his daughter?

        16          A    No.

        17          Q    In the last three months what's

        18     been the frequency of your conversations with

        19     James Carville?

        20          A    Same as always.

        21          Q    What's that?

        22          A    Several times a day, as I answered


         1     several hours ago.

         2          Q    Why is it that you speak with

         3     Mr. Carville several times a day?

         4          A    Asked and answered.

         5          Q    Are you calling him to get

         6     information for use in your commentary on ABC

         7     and other things that you're doing?

         8          A    I talk to him all the time about a

         9     lot of things.

        10          Q    What are you doing for Newsweek

        11     Magazine?

        12          A    Writing occasional articles.

        13          Q    Do you have a contract with

        14     Newsweek?

        15          A    Yeah.

        16          Q    Negotiated by Mr. Barnett?

        17          A    Yeah.

        18          Q    Just, roughly speaking, are you on

        19     some kind of retainer agreement with

        20     Newsweek?

        21          A    It's none of your business.

        22          Q    If you're asserting a reporter's


         1     privilege, it's my business?

         2          A    I have a contract to write articles

         3     with them.

         4          Q    Are you consulting with

         5     Mr. Carville to gather information for the

         6     Newsweek articles?

         7          A    No.

         8          Q    Are you consulting with

         9     Mr. Carville to gather information for your

        10     ABC commentary?

        11          A    No.  I talk to him because we're

        12     friends.

        13          Q    Now, you've heard Mr. Carville make

        14     a statement that Clinton allies were going to

        15     declare war on Ken Starr, did you not?

        16          A    I have seen the report of that.  I

        17     have never actually heard him say it.

        18          Q    Did he tell you that he was going

        19     to declare war or anybody was going to

        20     declare war?

        21          A    No, which I answered a question

        22     ago.


         1          Q    Have you asked Mr. Carville what he

         2     meant by declaring war?

         3          A    No.

         4          Q    Have you asked anyone what was

         5     meant by that?

         6          A    No.

         7          Q    Have you ever discussed with Paul

         8     Begala a speech that he gave in Miami at the

         9     Democrat Business Council?

        10          A    No.

        11          Q    Are you aware that he gave a speech

        12     there?

        13          A    I have seen reports of it, sure.

        14          Q    Are you aware that he made

        15     reference to looking at FBI files?

        16          A    I am aware that he made a joke and

        17     the fact that a joke could occasion a

        18     subpoena from you shows once again that

        19     you're looking to harass people at the White

        20     House or harass friends at the White House

        21     and that you're engaging in frivolous

        22     activity, not a legitimate investigation.  I


         1     mean dozens of other people have made FBI

         2     file jokes in the last five, ten years,

         3     including republicans.

         4          Q    Have you made FBI file jokes?

         5          A    You know, it's possible that I

         6     have, yes.

         7          Q    Do you find it funny?

         8          A    If the joke is good, sure.

         9          Q    Are you aware that Mr. Begala

        10     challenged our subpoena before the court,

        11     tried to quash our subpoena?

        12          A    I'm not, but I would support him in

        13     that.

        14          Q    Are you aware that the court

        15     sustained our right to take Mr. Begala's

        16     deposition?

        17          A    I guess they must have because Paul

        18     was here.

        19          Q    Are you saying that the court acted

        20     in a frivolous fashion by allowing the

        21     deposition?

        22          A    No, I'm saying you acted -- I'm


         1     saying you have acted in a frivolous fashion.

         2     I can't speak to the court and I won't speak

         3     to the court.  I think your questions today

         4     demonstrate you're acting.

         5          Q    You're saying the court should

         6     never have ordered Mr. Begala's deposition?

         7     Is that what you're saying?

         8          A    That's not what I said.  That is

         9     precisely the opposite.

        10          Q    Well, if the court ordered Begala's

        11     deposition and he had an opportunity to

        12     challenge it, then how is it frivolous for me

        13     to take it?

        14          A    That's my conclusion, but you don't

        15     care how I reach my conclusions though.

        16          Q    Effectively, you're telling the

        17     judge that he acted in a frivolous fashion?

        18          A    No.

        19               MS. SHAPIRO:  Objection.  You're

        20     just arguing with the witness now.  This is

        21     pointless.

        22               BY MR. KLAYMAN:


         1          Q    Is that what you're telling the

         2     judge?

         3          A    No.  I'm saying that you are

         4     frivolous and you are harassing witnesses.

         5     As far as I know, the judge is an honorable

         6     person.

         7          Q    Are you aware that you had an

         8     opportunity to challenge your subpoena?

         9          A    I'm doing my duty pursuant to the

        10     court. That doesn't change my judgment of

        11     you.

        12          Q    Well, you never challenged your

        13     subpoena, did you, in front of the court?

        14          A    I guess not, no.

        15          Q    Now, did you ever discuss the FBI

        16     files matter with Mr. Carville?

        17          A    I may have, but I don't remember

        18     it.

        19          Q    You don't remember anything?

        20          A    (Nodding)

        21          Q    No?

        22          A    I don't think I -- I mean it's very


         1     possible that the matter was a matter of same

         2     public controversy, we discussed it -- and we

         3     discussed the newspapers every day as part of

         4     our normal chat.  But I don't have a specific

         5     recollection of discussing this matter.

         6          Q    Have you discussed the fact that

         7     Mr. Carville has been subpoenaed to testify

         8     in this Judicial Watch case?

         9          A    Answered already.

        10          Q    I didn't ask you what specifically

        11     you discussed.

        12          A    No, I answered that specific

        13     question about six hours ago.

        14          Q    You're not going to give me any

        15     more?

        16          A    I already answered.

        17               MR. KLAYMAN:  All right.  Certify

        18     it.

        19               BY MR. KLAYMAN:

        20          Q    What is your understanding that

        21     this civil case that you're here on today is

        22     all about, the legal basis for it?


         1          A    I haven't thought about it that

         2     much.  You tell me.

         3          Q    Do you know what the causes of

         4     action that my clients have pled are?

         5          A    No.  Tell me.

         6          Q    Have you looked at the complaint?

         7          A    No.

         8          Q    Has anyone told you what these

         9     causes of action are?

        10          A    No.

        11          Q    Has anyone told you what the

        12     alleged liability is?

        13          A    No.

        14          Q    Has anyone told you what the

        15     alleged damage is?

        16          A    No.

        17          Q    Yet you formed an opinion that it's

        18     completely frivolous?

        19          A    I formed the opinion that you are

        20     frivolous and I know the fact that you're

        21     calling me and asking me questions about my

        22     life in high school and college rather than


         1     simply asking me questions about the FBI

         2     files is demonstration -- demonstrates that

         3     you're acting in a frivolous way.

         4               If you ask me questions about the

         5     FBI files, I will answer them just as I have

         6     for the past several hours.

         7          Q    It is your contention that I have

         8     asked you no questions about FBI files in

         9     this deposition?

        10          A    No.  To the extent that you have

        11     asked me questions about FBI files, I have

        12     answered them to the best of my ability.  I

        13     just wish we would spend more time on the FBI

        14     files and less time on frivolous matters.

        15          Q    Mr. Stephanopoulos, have you ever

        16     read the book The Dark Side of Camelot?

        17          A    No.

        18          Q    Have you ever seen it?

        19          A    I've seen a picture of it.

        20          Q    Have you read excerpts of it?

        21          A    No.

        22          Q    Have you ever read any history


         1     books that referred to the Kennedy

         2     administration?

         3          A    Sure.

         4          Q    When did you read those books?

         5          A    Oh, I've read books on the Kennedy

         6     administration probably ever -- well, if you

         7     take away we used to have a picture book in

         8     my house -- photo book put out by Life

         9     Magazine about the Kennedy assassination.

        10               I read that when I was quite young,

        11     you know, probably 6, 7 or 8 years old.  But

        12     I would guess that from the age of 10 or 12 I

        13     consistently read books on the Kennedys.

        14          Q    Are you an avid reader?

        15          A    Uh-huh.

        16          Q    You enjoy reading about politics

        17     and history?

        18          A    I enjoy reading about a lot of

        19     different things, including politics and

        20     history.

        21          Q    Politics is your profession, is it

        22     not?


         1          A    It has been.

         2          Q    How old are you?

         3          A    I'm 37.

         4          Q    When were you born?

         5               MR. BRAND:  Do the math.

         6               BY MR. KLAYMAN:

         7          Q    Date?

         8          A    February 10th, 1961.  So I wasn't

         9     involved --

        10          Q    Now, in the course of your reading

        11     and your courses on history did you learn

        12     about the role of J. Edgar Hoover during the

        13     Kennedy administration?

        14          A    I read a lot of different things

        15     about the role of J. Edgar Hoover during the

        16     Kennedy administration.

        17          Q    What did you read about and what

        18     did you learn?

        19          A    A lot of things.

        20          Q    Tell us.

        21          A    Now, you -- what -- when did J.

        22     Edgar Hoover die?  1971?  1972?  So J. Edgar


         1     Hoover died when I was 10 or 11 years old.

         2               Again, I would submit that my

         3     judgment or my -- what I've read about J.

         4     Edgar Hoover could have precious little to do

         5     with what might have happened in the White

         6     House in June of 1996 when J. Edgar Hoover

         7     had been dead probably for 15 years?

         8          Q    My question was, what do you

         9     remember about what J. Edgar Hoover's

        10     activities were during the Clinton

        11     administration, based upon your reading of

        12     history and books?

        13          A    Well, you're just proving my point.

        14     There is absolutely no involvement by J.

        15     Edgar Hoover in anything having to do with

        16     the Clinton administration because he was

        17     dead long before Clinton --

        18          Q    I didn't ask that question.

        19          A    Precisely.  Could you please read

        20     his question?

        21          Q    You can waste me time and you can

        22     waste yours, but I will be moving the court


         1     accordingly?

         2               MS. SHAPIRO:  You did say the

         3     Clinton administration.

         4               THE WITNESS:  Could you please read

         5     his question?

         6               THE REPORTER:   Do you want me to

         7     read the question?

         8               BY MR. KLAYMAN:

         9          Q    No, I will ask the question again

        10     because this is completely nonresponsive and

        11     makes no difference.  I will repeat it again.

        12          A    I answered your question.

        13               Wait a second.  You now said that

        14     my answer is nonresponsive.  I would please

        15     ask the court reporter to read his question

        16     and read my answer.

        17          Q    I'm going to rephrase it because I

        18     want to move along.

        19          A    Well, before -- and I want to

        20     establish for the court that my answer was

        21     actually perfectly responsive to the

        22     question.


         1          Q    I did not certify the question and

         2     it's not your prerogative to stop my

         3     deposition.

         4               Mr. Stephanopoulos, what is it that

         5     you learned about in the course of your

         6     reading that J. Edgar Hoover did during the

         7     Kennedy administration?

         8          A    Note for the record that for the

         9     second time you asked what happened in the

        10     Clinton administration, which J. Edgar Hoover

        11     did nothing and then --

        12          Q    I just said the Kennedy.

        13          A    Then he did amend that and say the

        14     Kennedy administration.

        15          Q    Kennedy administration.

        16          A    Right.  During the course -- J.

        17     Edgar Hoover was the FBI director during the

        18     entire John F. Kennedy presidency.  He was

        19     also the FBI director when Lyndon B. Johnson

        20     was President and I believe for most of

        21     Richard Nixon, if not all of Richard Nixon's

        22     presidency as well.


         1               He was obviously the FBI director

         2     before those presidents as well.  I think he

         3     went back as far as the last time was

         4     Roosevelt, but I couldn't swear to that.

         5               I know he was the FBI director for

         6     about 50 years, the longest serving FBI

         7     director in history.  I also believe that he

         8     abused his power at times.

         9          Q    How so?  What did you learn about

        10     that led you to form that opinion?

        11          A    I think he -- he interpreted his

        12     mandate quite broadly and I believe too

        13     broadly and I think he at times collected

        14     files on private citizens like Martin Luther

        15     King, perhaps like the Kennedys, in a way

        16     that was inappropriate.

        17          Q    Collected FBI files?

        18          A    He wouldn't collect them.  He would

        19     make them.

        20          Q    What about collecting those FBI

        21     files in your opinion was an abuse of power?

        22          A    What was abusive -- what was --


         1     what was abusive about it was creating them

         2     in order to blackmail people.  I'm glad you

         3     asked, because I -- I think what's

         4     interesting about this, and what is relevant

         5     about this is that what J. Edgar Hoover did

         6     is nothing like what happened in the White

         7     House to my knowledge in 1996.

         8               J. Edgar Hoover created files on

         9     people, blackmailed them with the

        10     information, my reading of history.  What

        11     happened in the White House in 1996 is that

        12     FBI files were mistakenly gathered by

        13     low-level employees.

        14               When this mistake was discovered,

        15     it was immediately denounced by the President

        16     and all other officials with responsibility.

        17     The information in the files was never used

        18     or disseminated in any way, shape or form.

        19               I never directed anybody to read

        20     them nor to my knowledge did any other White

        21     House official, the President or First Lady,

        22     and that when the mistake was discovered, it


         1     was rectified.

         2               The difference between J. Edgar

         3     Hoover's activities and the activities in the

         4     Clinton White House are the difference

         5     between night and day.

         6          Q    Who, to the best of your knowledge,

         7     did J. Edgar Hoover gather files on besides

         8     Martin Luther King?

         9          A    Well, as I said, I think he had

        10     some files on the Kennedys.  I don't remember

        11     what else.  As I said, I was only four years

        12     old.

        13          Q    To the best of your knowledge, J.

        14     Edgar Hoover gathered a file on Ellen

        15     Rometsch, did he not?

        16          A    Uh-huh.

        17          Q    Learned about that through reading

        18     history and science books?

        19          A    Yes.

        20          Q    Who is Ellen Rometsch?

        21          A    She was an East German spy who was

        22     alleged to have had an affair with John F.


         1     Kennedy, among others.

         2          Q    What was the type of information

         3     that you learned in your history studies that

         4     was gathered on Ellen Rometsch by J. Edgar

         5     Hoover?

         6          A    Well, he -- he determined through

         7     his investigation that President Kennedy was

         8     having an affair with Ellen Rometsch and it

         9     seemed like he was blackmailing the President

        10     with that information.

        11          Q    In fact, he also found out that

        12     Ellen Rometsch was having affairs with half

        13     of congress as well; is that correct?

        14          A    I think that's right.

        15          Q    He used those files to blackmail a

        16     congressman?

        17          A    Basically, yeah, there was a Bobby

        18     Baker investigation at the time and I think

        19     that there was a conspiracy of silence, I

        20     think that's correct, that both sides decided

        21     to keep a lid on all of this is my reading of

        22     the history.


         1          Q    Sometimes Hoover was reported to

         2     even have cooperated with Kennedy to use the

         3     Rometsch files against the congressman so the

         4     congressman wouldn't dredge up the affair the

         5     Kennedys were having?

         6          A    Sure, he would play both sides.

         7          Q    You learned all of this in your

         8     history studies and reading the books in high

         9     school and college, et cetera?

        10          A    Since then.

        11          Q    Since then?

        12          A    In fact, I mean I should say that

        13     since -- let's just get to the point since

        14     this is something that --

        15          Q    Well, I will ask you questions.

        16          A    Well, I was going to answer the

        17     question.

        18          Q    Well, you will answer my questions.

        19          A    No, whoa, whoa, whoa.  I'm

        20     answering your question.  I'm answering your

        21     last question.

        22               In fact, the last time I read about


         1     this was a few weeks ago when I was reading

         2     "Pillar of Fire" by Tyler Branch, who

         3     includes a page on this, and that's what's

         4     refreshed my memory on this incident.

         5          Q    But you had read about it before,

         6     correct?

         7          A    Probably.

         8          Q    It's pretty common knowledge in

         9     Washington about J. Edgar Hoover's activities

        10     with FBI files, it's not a unique revelation,

        11     is it?

        12          A    I don't know if it's common

        13     knowledge.  I know it's written about in

        14     history books.

        15          Q    Also his affairs with men in his

        16     department, things like that, that's been

        17     pretty well documented, correct?

        18          A    I don't know why you're asking

        19     that.

        20          Q    Well, I'm just asking your

        21     knowledge of J. Edgar Hoover?

        22          A    As I said, I was about 10 years old


         1     when J. Edgar Hoover died.  I read a fair

         2     amount of him. Frankly, you know, I've never

         3     read anything that would suggest affairs with

         4     men in his department.

         5               There was a discussion that he had

         6     a long-term relationship with his assistant,

         7     Clyde Tollson, but there's never been any

         8     discussion that he had affairs beyond that

         9     that I know about of.  I don't know that

        10     that's relevant either.

        11          Q    I'm just trying to find out what

        12     you know about J. Edgar Hoover.

        13          A    Which, of course, is quite relevant

        14     to what happened to the FBI files in 1996

        15     after J. Edgar Hoover was long dead.

        16          Q    You're aware that sometimes he had

        17     some of his employees go out and tend to his

        18     garden and do private matters, that kind of

        19     thing?  You read about that, right?

        20          A    I probably did.  Again, I would

        21     submit for the record that I find it hard to

        22     imagine how J. Edgar Hoover's assistant in


         1     the 1940s, '50s and '60s, who may or may not

         2     have attended his garden, has anything to do

         3     with the mistaken collection of FBI files in

         4     the Clinton White House in 1996 for the

         5     record.

         6          Q    I'm trying to gather the totality

         7     of your knowledge about J. Edgar Hoover.  Is

         8     it your opinion based on everything you've

         9     read that he was an extremely ruthless

        10     individual?

        11          A    I'm sure he was a complicated

        12     individual, that he had a ruthless side among

        13     many other sides.  I never met the man.

        14          Q    Recently you gave an appearance on

        15     "This Week" with Sam Donaldson and Cokie

        16     Roberts where you made reference to an Ellen

        17     Rometsch strategy, correct?

        18          A    I said what I would call an Ellen

        19     Rometsch strategy.

        20          Q    Before giving that interview in ABC

        21     had you ever referred to Ellen Rometsch in

        22     any speech you had given publicly or any


         1     television, radio appearance or writing?

         2          A    No.  I read Pillar of Fire the

         3     night before.

         4          Q    You never made any public reference

         5     before?

         6          A    No.

         7          Q    That was the first time.  Before

         8     going on that show on February 8th on "This

         9     Week" had you discussed Ellen Rometsch with

        10     anyone else in the last two weeks before

        11     that?

        12          A    No.

        13          Q    Or, say, the last three months

        14     before that?

        15          A    No.  As I said, I had just read

        16     "Pillar of Fire" the night before.

        17          Q    Had you discussed J. Edgar Hoover

        18     with anyone in the three months prior to your

        19     appearance on ABC on February 8th, 1998?

        20          A    No.

        21               MR. KLAYMAN:  I will show you what

        22     I will ask the court reporter to mark as


         1     Exhibit 7.

         2                    (Stephanopoulos Deposition

         3                    Exhibit No. 7 was marked

         4                    identification.)

         5               VIDEOGRAPHER:  This is the video

         6     operator.  This concludes tape two of the

         7     George Stephanopoulos deposition.  We will be

         8     continued on tape three.

         9                    (Pause)

        10               VIDEOGRAPHER:  This is the video

        11     operator.  We're going back on the record.

        12     The time now is approximately 4:02 p.m.

        13     Mr. Klayman?

        14               BY MR. KLAYMAN:

        15          Q    Mr. Stephanopoulos, what I've

        16     handed you as Exhibit 7 is the transcript of

        17     your appearance on "This Week" with Sam

        18     Donaldson and Cokie Roberts on February 8th,

        19     1998.  I would like to give you an

        20     opportunity to review it.

        21          A    I did.

        22          Q    I turn your attention to page two,


         1     middle of the page, "Sam Donaldson:  We know

         2     what the White House tactics are.  I mean

         3     they have been almost open about it.

         4               Attack the press, and perhaps with

         5     good reason, attack the independent counsel,

         6     perhaps for some good reason, and stonewall

         7     on the central issue, which is the President

         8     of the United States.  If he has nothing to

         9     hide, why is he hiding?

        10               "George Stephanopoulos:  I agree

        11     with that.  There's a different, long-term

        12     strategy, which I think would be far more

        13     explosive.  White House allies are already

        14     starting to whisper about what I'll call the

        15     Ellen Rometsch strategy."

        16               You made that statement, did you

        17     not, Mr. Stephanopoulos on February 8th,

        18     1998, on "This Week" with Sam Donaldson and

        19     Cokie Roberts on ABC Television?

        20          A    Yes.

        21          Q    Now, before you made this statement

        22     on ABC did you think about what you were


         1     going to say when you were on ABC that day?

         2          A    Sure.

         3          Q    In fact, you had thought that you

         4     were going to make reference to this Ellen

         5     Rometsch strategy at best?

         6          A    I wasn't sure I would, no.  I -- I

         7     had been reading about it.  It was something

         8     I thought about.

         9          Q    It's not your practice to make

        10     things up out of whole cloth, is it?

        11          A    No.

        12          Q    You wouldn't say something on ABC

        13     unless it was true, would you?

        14          A    Well, it's my opinion.  There's a

        15     lot of -- I mean that's what analysis and

        16     opinion and judgment are all about, as you've

        17     tried to establish here today.  I mean this

        18     is my opinion.  These are my words, this is

        19     my characterization, this is my metaphor.

        20     But I believe it to be true.

        21          Q    "George Stephanopoulos:  I agree

        22     with that," what Donaldson was saying.  What


         1     is it about what he said in the previous

         2     sentence that I read to you that you agree

         3     with?

         4          A    All of it.

         5          Q    That the strategy of the White

         6     House was to attack the press?

         7          A    Part of the strategy, and I think

         8     rightfully sometimes.

         9          Q    You learned of that strategy by

        10     talking with people at the White House prior

        11     to your appearance on February 8th, correct?

        12          A    Well, I'm not going to tell you who

        13     I talked to or who I didn't talk to.  What I

        14     am going to tell you is that is my judgment.

        15          Q    Who did you talk to?

        16          A    I'm not going to tell you.

        17          Q    Why aren't you going to tell me?

        18          A    I have a privilege.

        19          Q    What's that privilege?

        20          A    Journalistic privilege.

        21          Q    Do you have any journalistic

        22     credentials?


         1          A    What is a journalistic credential?

         2     I don't have a journalism degree, if that's

         3     what you're asking.  I don't know if that's a

         4     requirement to write or speak as a

         5     journalist.

         6               I have done reporting for the

         7     Christian Science Monitor, I have written for

         8     Newsweek Magazine, I have appeared as a

         9     political analyst since 1997 on ABC

        10     Television and when I was in graduate school,

        11     I also did a documentary for CBS television.

        12          Q    At the time you made this

        13     statement, did you hold a press pass to the

        14     White House?

        15          A    No.  I don't know what relevance

        16     that is though.

        17          Q    Have you ever held a press pass for

        18     the White House?

        19          A    No.

        20          Q    Have you ever held any kind of

        21     credentials that you can show demonstrate

        22     you're a member of the press?


         1          A    My contract with ABC News.

         2          Q    That's it?

         3          A    That's pretty -- that's pretty

         4     good.

         5               MR. KLAYMAN:  Mr. Brand, we're

         6     going to require production of that contract

         7     if you continue to hold it as privilege --

         8               THE WITNESS:  To hell you are.

         9               MR. KLAYMAN:  -- claim a privilege.

        10               MR. BRAND:  I don't know what the

        11     contract has to do with it.  If he had no

        12     contract, he would be entitled to the first

        13     amendment, as anybody is.

        14               MR. KLAYMAN:  Well, we are asking

        15     you to produce it.

        16               MR. BRAND:  I'm not going to

        17     produce it.

        18               BY MR. KLAYMAN:

        19          Q    Do you have any badge that says

        20     you're a member of the press?

        21               MR. BRAND:  Do you have a badge

        22     that says you're a lawyer?


         1               MR. KLAYMAN:  As I matter of fact,

         2     I do.  You probably do, too. It's called a

         3     bar card.

         4               MR. BRAND:  What is the

         5     significance of badge to be a reporter?

         6               BY MR. KLAYMAN:

         7          Q    Do you have any kind of badge that

         8     says you're a member of the press?

         9          A    I have an ABC beeper.  I have --

        10     no, you know, I don't carry a badge.  I carry

        11     a driver's license and a passport.  That's my

        12     identification.

        13          Q    Is that, the latter, so you can get

        14     out of the country in a moment's notice?

        15          A    Yes, as a matter of fact.

        16          Q    What caused you to make that

        17     statement on "This Week, I agree with that

        18     and there's a different long-term strategy

        19     which I think would be far more explosive"?

        20          A    The words speak for themselves.

        21          Q    Notwithstanding the fact that you

        22     have asserted a claimed privilege, that


         1     information wasn't made out of whole cloth,

         2     was it, that White House allies are already

         3     starting to whisper about what I will call

         4     the Ellen Rometsch strategy?  You obtained

         5     this information from alleged sources,

         6     correct?

         7          A    Sure, the -- the -- tying to it

         8     Ellen Rometsch -- the Ellen Rometsch metaphor

         9     is mine.  As I said, I read "Pillar of Fire."

        10     That's why I said what I will call the Ellen

        11     Rometsch strategy.

        12          Q    But you obtained information that

        13     the use of FBI files was being whispered

        14     about by White House allies.

        15          A    No, that is not the information I

        16     obtained.

        17          Q    What was the nature of the

        18     information you obtained?

        19          A    It's none of your business.

        20               MR. KLAYMAN:  Certify it.

        21               BY MR. KLAYMAN:

        22          Q    When you referred to the Ellen


         1     Rometsch strategy, what are you referring to

         2     in this statement?

         3          A    The words speak for themselves.

         4          Q    What are you referring to?

         5          A    Well, I'll read it.  "She was a

         6     girlfriend of John F. Kennedy, who also

         7     happened to be an East German spy.

         8               Robert Kennedy was charged with

         9     getting her out of the country and also

        10     getting John Edgar Hoover to go to the

        11     congress and say don't you investigate this

        12     because if you do, we're going to open up

        13     everybody's closets."  That's the description

        14     of the John F. Kennedy, J. Edgar Hoover --

        15          Q    Finish the phrase.

        16          A    "I think that in the long run they

        17     have a deterrent strategy," then I was

        18     interrupted.

        19          Q    "On getting a lot of?"

        20          A    "Getting a lot of."  Had I not been

        21     interrupted, I suppose I would have said

        22     something, a lot of information on their


         1     adversaries, but that has nothing to do with

         2     FBI files.  I never mentioned FBI files.

         3          Q    In fact, as you previously

         4     discussed, when Robert Kennedy was in charge

         5     of getting her out of the country and getting

         6     J. Edgar Hoover to go to congress, he went to

         7     congress, as you testified about earlier,

         8     with the knowledge that there were FBI files

         9     on some congressmen, correct?

        10          A    Right, that's what happened to John

        11     F. Kennedy and J. Edgar Hoover.  I was making

        12     a broader metaphor about background

        13     information.  I was not referring to FBI

        14     files.

        15          Q    How can we verify that you weren't

        16     referring to FBI files just background

        17     information?

        18          A    I just told you.

        19          Q    Now, is it not true that J. Edgar

        20     Hoover used FBI files against the

        21     congressman?

        22          A    It may have been true.  I wasn't


         1     there.

         2          Q    In fact, J. Edgar Hoover had FBI

         3     files on some of the affairs the congressman

         4     had with the woman, correct, based on your

         5     knowledge of the history?

         6          A    I don't know.  I wasn't there.

         7          Q    But you've read that, correct?

         8          A    I read about the FBI files.  I

         9     don't know whether the FBI file is used in

        10     this context, but I read that.

        11          Q    You read it before you made this

        12     statement?

        13          A    Yes.

        14          Q    In this statement you did not

        15     differentiate between getting information

        16     from FBI files or some other source, correct?

        17          A    Well, as you see, I was interrupted

        18     and I was trying to go on, but I was

        19     interrupted.

        20          Q    In fact, you said before you were

        21     interrupted, on page 3 of 12, "I think that

        22     in the long run they have a deterrent


         1     strategy on getting a lot of."  You meant FBI

         2     files, correct?

         3          A    No, I already answered that.

         4     That's not what I meant.

         5               MR. KLAYMAN:  I'll show you what

         6     I'll ask the court reporter to mark as

         7     Exhibit 8.

         8                    (Stephanopoulos Deposition

         9                    Exhibit No. 8 was marked

        10                    identification.)

        11               MS. SHAPIRO:  Are you marking this

        12     or referring to the past exhibit?

        13               MR. KLAYMAN:  It's been marked as

        14     Exhibit 8.

        15               BY MR. KLAYMAN:

        16          Q    Referring to Exhibit 8, this is a

        17     passage from "The Dark Side of Camelot" by

        18     Seymour M. Hersh, page 405.  Take an

        19     opportunity to review this,

        20     Mr. Stephanopoulos, 405 and 406 up to the end

        21     of the second paragraph, middle of the page.

        22          A    Yeah.


         1          Q    Have you read it?

         2          A    Uh-huh.

         3          Q    Now, this passage is consistent

         4     with what you read the night before with

         5     regard to this other book, correct?

         6          A    It's far more detailed.

         7          Q    How is it more detailed?

         8          A    It's two pages, not one paragraph.

         9          Q    But both of them refer to the use

        10     of FBI files against political adversaries of

        11     J. Edgar Hoover, correct?

        12          A    Well, or, more generally, they

        13     refer to the background of these people.

        14     That's what I was referring to.

        15          Q    But both of the passages that you

        16     read.  What was the name of the other book

        17     again?

        18          A    Pillar of Fire.

        19          Q    Pillar of Fire.  That refers to the

        20     FBI files as well?

        21          A    I don't know if it used the word

        22     "FBI files," but it refers to it by name.


         1          Q    The answer is yes?

         2          A    That's not what I said.

         3          Q    Pillar of Fire referred to FBI

         4     files?

         5          A    I didn't say that.  I said I don't

         6     remember whether it referred to FBI files.  I

         7     said it referred to the general matter, you

         8     said that, and I don't know why you keep

         9     insisting on putting words in my mouth.

        10          Q    Does this refresh your recollection

        11     as to what you meant by Ellen Rometsch

        12     strategy when you made that on ABC's "This

        13     Week" on February 8th?

        14               MR. BRAND:  First of all, you keep

        15     characterizing his recollection as needed to

        16     be refreshed.  He's testified fully about

        17     what he meant by Ellen Rometsch and where he

        18     got the information, so you could you stop

        19     characterizing his memory as needing

        20     refreshing.

        21               MR. KLAYMAN:  I'm allowed to

        22     refresh his recollection.


         1               MR. BRAND:  You've got to show he

         2     doesn't have a present memory before you do

         3     that, Larry, and like Doug Harvard, the

         4     umpire, says, you can go look that up if you

         5     want to.  That's the way it's done.

         6               Please, stop characterizing his

         7     memory as failing when, in fact, he's

         8     testified fully and exhausted his memory.  If

         9     you want to ask him about this, pending

        10     whatever relevance it has, then ask him about

        11     it.

        12               MR. KLAYMAN:  Thank you for your

        13     speech, Mr. Brand.  Now, let's get back to

        14     the questioning.

        15               BY MR. KLAYMAN:

        16          Q    Let's take it line by line.  That's

        17     funny?

        18          A    It is.  It really is.

        19          Q    Good.  I'm glad that you find it

        20     funny.

        21               "George Stephanopoulos:  I agree

        22     with that and there's a different, long-term


         1     strategy."

         2               Where did you learn there was a

         3     different, long term strategy?

         4          A    In the course of my work.

         5          Q    What work?

         6          A    My work for ABC.

         7          Q    What type of work did you do that

         8     caused you to come into that information?

         9          A    It's none of your business.

        10               MR. KLAYMAN:  Certify it.

        11               BY MR. KLAYMAN:

        12          Q    Did you talk with people inside the

        13     White House to get that information?

        14          A    I'm not going to answer that

        15     question.

        16               MR. KLAYMAN:  Certify it.

        17               BY MR. KLAYMAN:

        18          Q    Did you talk to people outside of

        19     the White House?

        20          A    I'm not going to answer that

        21     question.

        22               MR. KLAYMAN:  Certify it.


         1               BY MR. KLAYMAN:

         2          Q    You then state, "which I think

         3     would be far more explosive."  Where did you

         4     obtain the information that this long-term

         5     strategy would be far more explosive?

         6          A    That's my judgment, that the

         7     strategy, if embarked on, would be more

         8     explosive.  That's my conclusion based on my

         9     years of experience.

        10          Q    What did you mean by explosive?

        11          A    It would be a matter of some

        12     controversy.

        13          Q    What is a matter of some

        14     controversy?

        15          A    You're the one who used the word

        16     "controversy."  I don't have to define it for

        17     you.

        18          Q    Well, you just used it yourself, so

        19     what do you mean by it?

        20          A    It means exactly what it says.

        21          Q    Would it raise legal ramifications?

        22          A    Not necessarily.


         1          Q    Were you thinking of that when you

         2     made that statement?

         3          A    Actually no.  I was referring to

         4     political implications.

         5          Q    What political implications

         6     specifically were you thinking about when you

         7     made that statement?

         8          A    That it would be a matter of

         9     political controversy.

        10          Q    I'm not asking you for a source

        11     here.  I'm asking you how would it raise

        12     political implications.

        13          A    I know it.  I'm just -- and I'm

        14     answering your question.  If you don't

        15     understanding English, go back to school.

        16     That's my answer.

        17               MR. KLAYMAN:  Certify this.

        18               BY MR. KLAYMAN:

        19          Q    How would it raise political

        20     implications?

        21          A    I think if there were a -- well, in

        22     fact, it already has, hasn't it?  There's


         1     been discussion about whether people, you

         2     know, for instance Bill Bennett, Bob

         3     Bennett's brother, has said that all

         4     republican candidates for President in the

         5     year 2,000 are now going to have to undergo

         6     an adultery check.

         7               They're going to have to be squeaky

         8     clean.  That's precisely the kind of thing I

         9     was referring to when I talked about this,

        10     that this would become a matter of political

        11     of controversy if every -- if this were

        12     pursued.

        13               And everybody agreed to believe it

        14     was fair game to look into the backgrounds of

        15     political adversaries or anybody in politics.

        16     I think -- in fact, my -- my analysis has

        17     been borne out in part by events.

        18          Q    You were also referring to the

        19     method of looking into that background in

        20     terms of the explosiveness?

        21          A    No, actually I wasn't.

        22          Q    You stated that, "White House


         1     allies are already starting to whisper about

         2     what I'll call the Ellen Rometsch strategy."

         3     How did you define White House allies?

         4          A    Speaks for itself.

         5          Q    I'm not asking you right now to

         6     name the sources of that information, but how

         7     did you define the term "White House allies."

         8          A    People sympathetic to the White

         9     House.

        10          Q    Was there a smaller subset of

        11     people than you were referring to when you

        12     made this statement?

        13          A    No.

        14          Q    How do you define people

        15     sympathetic to the White House?

        16          A    Boy.  I mean people who agree with

        17     the President's policies, people who like the

        18     President, people who are democrats, people

        19     when don't like the kind of harassment that

        20     this lawsuit -- or that at least the way

        21     you're conducting this lawsuit demonstrates.

        22               People who are fed up with the


         1     tactics of Ken Starr; people who believe that

         2     this case should have never gone to trial;

         3     people who like the Family and Medical Leave

         4     Act; people who want a minimum wage increase;

         5     people who think that doing away with the IRS

         6     would -- would harm the country; people who

         7     think that a national health care plan is a

         8     good idea; people who want to invest more in

         9     education; people who believe that we should

        10     do more to protect the environment; people

        11     who want more police on the street; people

        12     who think it's a good thing that the deficit

        13     has been eliminated under President Clinton's

        14     watch and 15 million jobs have been created;

        15     people who are happy with low interest rates;

        16     people who are happy with low unemployment;

        17     people who have been able to get a

        18     scholarship to go to college under the

        19     America National Service program; people who

        20     are happy that the killing has stopped in

        21     Bosnia; people who are hoping for Middle East

        22     peace; people who are glad that we were able


         1     to threaten Sadam Hussain's military force so

         2     that we could get the inspectors back in.

         3               All those people could conceivably

         4     be considered sympathetic to the President,

         5     allies to the President.

         6          Q    People who would believe that it's

         7     okay for the Chief Executive Officer to

         8     commit adultery?

         9          A    I don't think I said that.  Would

        10     you please read my answer --

        11          Q    Would they be in that subset?

        12          A    Would you please read my answer

        13     back?

        14          Q    No, but would they be included as a

        15     White House ally?

        16          A    I gave my answer.

        17               MR. BRAND:  You're just arguing

        18     with the witness.

        19               BY MR. KLAYMAN:

        20          Q    People who believe that it's okay

        21     to permit perjury in a civil deposition?

        22          A    You asked me to --


         1          Q    Are they included in there?

         2          A    You asked me to define what I meant

         3     by White House allies.  If you would like to

         4     hear the answer read back again, I'm happy to

         5     hear it.

         6          Q    Are those people in your

         7     definition, people who say it's okay to

         8     commit perjury in a civil deposition?

         9          A    I answered the question.

        10          Q    Yes or no?

        11          A    I answered your question.  The

        12     answer to that subsequent question was no,

        13     that it wasn't included in my original

        14     answer.

        15          Q    People who believe that it's all

        16     right to commit adultery in the White House

        17     while you're a Chief Executive Officer, are

        18     they included in that subset?

        19               MS. SHAPIRO:  Objection to the

        20     relevancy.

        21               BY MR. KLAYMAN:

        22          Q    You can respond.


         1          A    I gave my answer.

         2          Q    Yes or no?

         3          A    I gave my answer.

         4          Q    You have to answer.

         5          A    I gave my answer.

         6          Q    Are you refusing to answer?

         7          A    No, I'm referring back to my old

         8     answer.

         9          Q    Are those people in that group of

        10     people that we just discussed?

        11          A    If they were in that group of

        12     people, I would have said that in the group

        13     of people.  I gave my answer.  You can define

        14     it -- as any way you want.  I gave the answer

        15     to your question.

        16          Q    Is James Carville in this category

        17     of White House allies?

        18          A    What category?

        19          Q    That you just defined.

        20          A    He's in the category I defined

        21     there.  I'm not going to answer the question

        22     as regards to what I said on ABC Television.


         1          Q    Is he in the category of what you

         2     said on ABC Television?

         3          A    I'm not going to answer that.

         4          Q    On what ground?

         5          A    I'm not going to tell you who I

         6     talked to.

         7          Q    I didn't ask you whether you got

         8     the information from Carville, I just want to

         9     know whether he's within the definition of

        10     White House allies in ABC Television.

        11          A    He's within the definition of White

        12     House allies I gave in this deposition.  I am

        13     not going to answer the question as to what I

        14     said on ABC Television.

        15          Q    On what basis?

        16          A    On the basis that I'm not going to

        17     divulge who I did or did not talk to.

        18               MR. KLAYMAN:  Mr. Brand, are you

        19     instructing him not to answer --

        20               MR. BRAND:  Yes.

        21               MR. KLAYMAN:  -- with regard to

        22     that classification?


         1               MR. BRAND:  On the same grounds

         2     that we discussed before.

         3               MR. KLAYMAN:  I'm not asking

         4     whether Mr. Carville gave the information

         5     which Mr. Stephanopoulos then used to make

         6     his statement on ABC about the Ellen Rometsch

         7     strategy.

         8               I'm asking whether when he referred

         9     to White House allies on ABC whether

        10     Mr. Carville would be included in that

        11     definition as he used it on ABC.

        12               THE WITNESS:  I'm not answering

        13     that question.

        14               MR. KLAYMAN:  Are you instructing

        15     him not to answer that?

        16               MR. BRAND:  To the extent it's

        17     within the asserted privilege, yes.

        18               MR. KLAYMAN:  Well, that's not an

        19     answer.  Are you saying he can respond or

        20     not?

        21               MR. BRAND:  He's fully responded to

        22     these ridiculous questions, Larry.



Previous Section / Next Section
of this deposition