351
1 A I've read.
2 Q Have you seen it?
3 A I've seen --
4 Q You said you didn't read it, but
5 have you seen it?
6 A I've seen newspaper reports of it.
7 Q Well, what was it about Sue Schmitt
8 that caused you to undertake a meeting about
9 her?
10 A She was a reporter writing about
11 the White House every day.
12 Q Was there a concern that she was
13 writing articles that were negative to the
14 White House?
15 A People are going to write articles
16 negative to the White House. You can't have
17 a meeting about everyone that writes
18 something negative about the White House.
19 I remember one story in particular
20 that was just absolutely wrong and I had
21 discussions with people at The Washington
22 Post about that.
352
1 Q Williams & Connolly represent The
2 Washington Post, right?
3 A Asked and answered.
4 Q Has anyone at the White House ever
5 used Mr. Kendall to make a point to The
6 Washington Post with regard to a story?
7 A I'm sure David Kendall has talked
8 to The Washington Post, but you'd have to ask
9 him.
10 Q I'm asking whether the White House
11 ever asked him to intercede with The
12 Washington Post to get stories written more
13 favorable.
14 A The White House isn't a person.
15 Q Based on your knowledge.
16 A What's the question?
17 Q Did anyone at the White House ever
18 ask Mr. Kendall or anyone at Williams &
19 Connolly to intercede with The Washington
20 Post to have more favorable stories written
21 about it?
22 A Not that I know of.
353
1 Q Was any request made to intercede
2 through Mr. Kendall or anybody else at
3 Williams & Connolly with regard to Sue
4 Schmitt?
5 A No not that I know of.
6 Q Have there been any requests
7 through Williams & Connolly for retaliation
8 against The Washington Post for unfavorable
9 stories?
10 A Not that I know of and I'm sure if
11 that request were made, they would -- they
12 would refuse to do it.
13 Q Was Williams & Connolly aware that
14 the White House was gathering information on
15 Sue Schmitt?
16 A You have to ask them.
17 Q Was there ever any discussion that
18 this might put David Kendall and Williams &
19 Connolly in a conflict of interest situation
20 if you started investigating Sue Schmitt?
21 A Not that I know of.
22 Q Have you ever had any conversations
354
1 with Peter Baker of The Washington Post?
2 A Sure.
3 Q While you were at the White House?
4 A Yes.
5 Q Did anyone ever set out to
6 investigate him?
7 A Not that I know of.
8 Q In fact, he's quite favorably
9 disposed to the White House, is he not?
10 A I don't really know. He's a
11 reporter. He follows the facts as he sees
12 them.
13 Q Has anyone had a bone to pick with
14 Peter Baker when you were at the White House?
15 A What do you mean?
16 Q Anyone complain about his
17 reporting?
18 A Not that I know of. I always had
19 good relations with him. I don't think he
20 was there when the FBI files story broke I
21 should say for the record one more time.
22 I question the relevance to the FBI
355
1 files and I would say for the record that
2 every single time a direct question about my
3 direct knowledge about FBI files has been
4 asked I have answered it fully and
5 completely.
6 Q Thank you for that judgment,
7 Mr. Stephanopoulos.
8 A You're welcome.
9 Q During the time that you were at
10 the White House did anyone ever ask that a
11 Washington Post reporter be removed from his
12 or her beat?
13 A No, and were it asked, that would
14 guarantee that that person would have
15 lifetime tenure on that beat.
16 Q When you worked at the White House,
17 were there reporters that were considered to
18 be enemies of the Clinton White House?
19 A Not by me.
20 Q By others?
21 A Not that I know of.
22 Q Do you know whether that's true
356
1 today based on your contacts with the White
2 House?
3 A No. As far as I know, there's no
4 enemies list.
5 Q Chris Ruddy wouldn't qualify?
6 A As I said, he would qualify in my
7 mind as a dishonest, disreputable, disgusting
8 journalist, but not an enemy, no.
9 MR. KLAYMAN: I will show you what
10 I will ask the court reporter to mark as
11 Exhibit 12.
12 (Stephanopoulos Deposition
13 Exhibit No. 12 was marked for
14 identification.)
15 BY MR. KLAYMAN:
16 Q I'm showing you what I have asked
17 the court reporter to mark as Exhibit 12.
18 Have you ever seen this document before,
19 Mr. Stephanopoulos?
20 A I may have, but I couldn't swear to
21 it.
22 Q Where do you think you saw it?
357
1 A I don't know. It seems accurate.
2 Q Did you see it during the time you
3 worked at the White House?
4 A I'm not sure.
5 Q Was it provided to you by
6 Mr. Begala?
7 A Actually probably not because, for
8 instance, the John Huang situation really
9 came up after I left the White House. It was
10 up a little bit towards the end. But I don't
11 really know.
12 Q Was this document provided to you
13 by Mr. Begala?
14 A I don't know.
15 Q Has he provided documents to you
16 since you left the White House from time to
17 time?
18 A He sometimes sent me speeches that
19 he's read, public record documents. Nothing
20 that wasn't on the public record.
21 MR. KLAYMAN: I show you what will
22 ask the court reporter to mark as Exhibit 13.
358
1 (Stephanopoulos Deposition
2 Exhibit No. 13 was marked for
3 identification.)
4 BY MR. KLAYMAN:
5 Q Showing you Exhibit 13, this is a
6 document that says, "Gingrich Keeps His
7 Promise." Have you ever seen this document
8 before?
9 A No.
10 Q Have you ever heard reference to
11 this document before?
12 A I wouldn't know how it would be
13 referred to.
14 Q When did you first learn of a Craig
15 Livingstone?
16 A I don't know. My guess is it was
17 probably in the -- during the inaugural or
18 the transition, but if it wasn't then, it was
19 sometime close after that.
20 Q How did you learn of him?
21 A He was an advance guy.
22 Q Do you know who hired him as an
359
1 advance guy?
2 A No.
3 Q What's the definition of an advance
4 guy?
5 A Someone who works on advance.
6 Q What is advance?
7 A It means you go to a place where
8 the President or candidate is supposed to be
9 in advance of his or her arrival to prepare
10 the site.
11 Q In the course of your duties and
12 responsibilities in the '92 campaign you came
13 in contact with Mr. Livingstone from time to
14 time, correct?
15 A I don't know. I may have. I mean
16 I came in contact with thousands of advance
17 people because sometimes I would travel with
18 the President, but I don't remember it.
19 I do -- I think -- I have a more
20 distinct memory that it happened either
21 during the transition or the inaugural.
22 Q During the 1992 campaign, did the
360
1 campaign conduct research on opposition
2 candidates?
3 A Certainly.
4 Q How did it do that?
5 A We had a team of researchers, went
6 through the public record.
7 Q Who were those researchers?
8 A Lots of them.
9 Q Such as?
10 A Eric Berman headed them. He had a
11 team.
12 Q Did the campaign employ private
13 investigators?
14 A If they did, I had nothing to do
15 with it.
16 Q Well, I'm asking whether you have
17 knowledge of that.
18 A I've read some reports that maybe
19 the campaign did. I don't know if it's true
20 or not.
21 Q Do you have any knowledge yourself
22 that they did?
361
1 A No.
2 Q Did you ever discuss during the
3 campaign opposition research with Paul
4 Begala?
5 A Sure.
6 Q Did you ever discuss opposition
7 research with regard to adversaries of
8 Governor Clinton?
9 A Mostly it was about President Bush
10 and his record.
11 Q Did you ever discuss opposition
12 research with regard to democratic candidates
13 in the primary?
14 A May have. We didn't really do --
15 we didn't really -- there were a couple of
16 times in votes, things like pay raises, we
17 might bring that up, but nothing that wasn't
18 on the public record.
19 Q Did you ever discuss opposition
20 research with anyone concerning Governor
21 Jerry Brown?
22 A It's conceivable that I did, but I
362
1 don't know that I did.
2 Q Are you aware of an incident
3 involving alleged drug usage in his house in
4 California?
5 A I know that John McQwithy of ABC
6 News reported that.
7 Q Was that information fed to him by
8 the Clinton campaign?
9 A I don't think so.
10 Q But you're not sure?
11 A I'm not sure.
12 Q You're not sure?
13 A What do you mean by I'm not sure?
14 I gave you my answer.
15 Q What's your answer?
16 A I don't think so. I certainly
17 didn't do it.
18 Q Do you know of anyone hiring a
19 private investigator to look into drug usage
20 by Governor Brown?
21 A If I didn't know about anyone
22 hiring a private investigator, I couldn't,
363
1 therefore, know about anybody being hired as
2 a private investigator to look into Jerry
3 Brown.
4 Q Did James Carville get himself
5 involved in opposition research during the
6 campaign in any way?
7 A Yeah, maybe -- maybe reading the
8 research on the public record, sure.
9 Q What research did he read on the
10 public record?
11 A The fact that George Bush had the
12 largest tax increase in American history.
13 That's one example.
14 Q What was Hillary Clinton's role
15 during the campaign?
16 A She was helping her husband run for
17 president.
18 Q Did she get involved in opposition
19 research in any way?
20 A Not really, no.
21 Q But she did it in part, did she
22 not?
364
1 A I don't have any direct knowledge
2 of that.
3 Q Who would have direct knowledge of
4 that?
5 A Ask her.
6 Q Who worked with her during the
7 campaign? Who was her contingent?
8 A Sorry.
9 Q Who was her contingent?
10 A She had a lot of people work for
11 her. I wasn't on her staff.
12 Q Who worked for her during the
13 campaign?
14 A A lot of people worked for her. I
15 have no idea what happened --
16 Q Who was the primary person?
17 A What happened in 1992, what
18 conceivable relevance could that have with
19 what happened to the FBI files in the White
20 House in 1996?
21 Q Who was the person who worked with
22 her most closely during the 1992 campaign?
365
1 A I don't have an answer to that. A
2 lot of people worked with her. Magee
3 Williams I guess.
4 Q Anyone else?
5 A A lot of people worked with her.
6 She had a press secretary.
7 Q Who was the press secretary?
8 A It was Richard Mintz for a while
9 and Jody Franklin worked with her. She had a
10 whole staff.
11 Q Did Micky Kantor work with her?
12 A I'm sure he talked to her.
13 Q Do you know whether she worked with
14 any private investigators?
15 A No.
16 Q Tell me what, if anything, you know
17 about what Craig Livingstone did during the
18 inaugural.
19 A I don't really know. I know he did
20 something having to do with advance and
21 security, but I don't know what it was
22 largely. Rahm Emanuel ran the inaugural. I
366
1 was mostly in Little Rock dealing with the
2 transition.
3 Q Rahm Emanuel would know that?
4 A I don't know that he would know it.
5 Q But he'd be the person you would
6 think of that would know that?
7 A Not necessarily. Craig Livingstone
8 wasn't that high level an employee.
9 Q Did he have a reputation by the
10 time of the inaugural for any aspect of his
11 work characteristics?
12 A Not that I know of.
13 Q Did there come a point in time when
14 Craig Livingstone's reputation was discussed
15 at the White House when you were there?
16 A After the -- the story broke.
17 Q Who did you discuss his reputation
18 with?
19 A I don't know if I discussed his
20 reputation in particular, but we discussed
21 this case and it seemed like a terrible
22 mistake.
367
1 Q Was Craig Livingstone's reputation
2 discussed?
3 A What does that mean?
4 Q Did anyone check the guy out to
5 find out where he came from, how he got into
6 the position of White House Director of
7 Security et cetera?
8 A Well, I answered that in David
9 Brinkley's transcript of what my knowledge
10 was of how he got hired.
11 Q To the best of your knowledge,
12 after the FBI files controversy broke did
13 anyone confront Craig Livingstone with what
14 had happened?
15 A I assume so, yeah. He was
16 disciplined.
17 Q Who confronted him?
18 A I don't know if it was Jack Quinn
19 or Leon Panetta, but it was someone in
20 management.
21 Q In fact, he was put on
22 administrative leave with pay, correct?
368
1 A If you say so.
2 Q You're aware of that, correct?
3 A I know that something happened. I
4 don't know what exactly it was.
5 Q How is administrative leave with
6 pay discipline?
7 A Sounds like discipline to me.
8 Q Not having to work and getting paid
9 for it, that's discipline?
10 A I think Craig Livingstone has
11 paid -- has paid the price for his mistake.
12 Q How so?
13 A He's got to be dragged through all
14 this. He made a mistake. He's been, you
15 know, written about, talked about, been
16 dragged through innumerable hearings and
17 investigations.
18 And I believe that, you know, for a
19 mistake which was severe was, to my mind,
20 based on everything I know, an innocent, but
21 egregious screw-up.
22 Q During the time you worked in the
369
1 White House did you become aware that Craig
2 Livingstone had threatened to smash in the
3 face of his next door neighbor?
4 A I read press reports after the FBI
5 story broke about that. I have no
6 independent knowledge of it.
7 Q In fact, a criminal complaint had
8 been filed against him by the next door
9 neighbor?
10 A I read press reports. I had no
11 independent knowledge.
12 Q Was that a subject of discussion at
13 the White House when that story broke?
14 A I assume so. I don't remember the
15 specific discussion.
16 Q Was there any investigation
17 undertaken to find out the circumstances of
18 him threatening to smash in the face of his
19 next door neighbor?
20 A Not that I know of.
21 Q No one really cared, did they?
22 A I didn't say that. As far as I
370
1 know, he was disciplined.
2 Q By who?
3 A I already answered that question.
4 Q During the time that you worked in
5 the White House did you ever encounter Chris
6 Livingstone?
7 A Sure.
8 Q Where did you encounter him?
9 A The hallway. He might have come to
10 my office one or twice.
11 Q What were the circumstances of him
12 coming to your office?
13 A He once came to ask if I would make
14 a phone call to his hometown newspaper, which
15 I agreed to do. People ask me to do that
16 kind of thing all the time. That's the only
17 one I really remember. That's the smoking
18 gun.
19 Q Did you make a comment to your
20 hometown newspaper?
21 A To my hometown --
22 Q To his hometown newspaper?
371
1 A Yes.
2 Q What was that comment?
3 A I don't remember. If you have a
4 copy of it, I'd be happy to read it back.
5 MR. KLAYMAN: I'll show you what I
6 will ask the court reporter to mark as
7 Exhibit 14.
8 (Stephanopoulos Deposition
9 Exhibit No. 14 was marked for
10 identification.)
11 BY MR. KLAYMAN:
12 Q Showing you Exhibit 14. Can you
13 turn to page two?
14 A Okay.
15 Q Do you see where it says,
16 "Stephanopoulos has worked with Livingstone
17 since Clinton's Presidential campaign. Gives
18 him high marks. He does a terrific job.
19 All I know is that anything that he
20 has to do with security or logistics, Craig
21 is going to take care of it.
22 You don't have to tell him how to
372
1 do it, when to do it, just that it needs to
2 be done and he does it and he knows how to
3 cut through the bureaucracy and get thing
4 done." That's your quote, is it not?
5 A Uh-huh.
6 Q Where did you get the information
7 to be able to make that statement about
8 Mr. Livingstone.
9 A It's my impression. That's why --
10 that's why I said all I know.
11 Q Based on your experience, did you
12 draw that impression from working with him?
13 A Not particularly closely, but, you
14 know, he seemed to do a good job from what I
15 could tell.
16 Q Let's go back over this. "He does
17 a terrific job." How did you get the
18 information that he does a terrific job? Did
19 you work with him before?
20 A I encountered him sometimes in the
21 White House. He ran some events. He seemed
22 to do a good job.
373
1 Q What events did he run?
2 A I don't know.
3 Q How do you make a statement about
4 somebody if you can't remember what he did?
5 A Well, then I may have been able to
6 remember something. Five years later I can't
7 remember it. I just don't know exactly what
8 he did.
9 I know he's an advance person doing
10 events. This -- I was trying to do a nice
11 thing for him for his hometown newspaper.
12 That's not a criminal act.
13 Q You were lying to the hometown
14 newspaper?
15 A I didn't say that. I don't know
16 why you put that in the record. I think it
17 shows one more time that all you're doing
18 here is -- is trying to harass me rather than
19 get answers to the questions.
20 Q But do you frequently provide
21 information to the press if you don't have a
22 foundation, factual foundation to do it?
374
1 A I didn't say I didn't have a
2 factual foundation to do it. That was my
3 impression. This was a profile in a local
4 newspaper about a young guy who has, he
5 described, a second-tier job at the White
6 House. It was a nice thing to do. It took
7 me 30 seconds. I didn't think about it
8 again.
9 Q The second statement, "All I know
10 is that anything that has anything to do with
11 security or logistics Craig is going to take
12 care of it."
13 How did you get the factual
14 foundation to be able to make that statement
15 to Mr. Livingstone's hometown newspaper?
16 A Because that was his job and I
17 didn't have any evidence to the contrary.
18 That's why I also said "all I know."
19 Q You had a deep factual knowledge as
20 to what he was doing in the security area,
21 did you not?
22 A I didn't say that. If you want to
375
1 read back my answer, I'm happy to do that.
2 Q What is it that Craig had done with
3 security up to that point in time that
4 allowed you to make the statement to the
5 hometown newspaper?
6 A He had been the director of
7 security. I had never heard any real
8 complaints. I didn't know much about it. He
9 asked me to do a favor for him. I did. You
10 know, sue me.
11 Q Who is going to sue you?
12 A It's a figure of speech.
13 Q Next statement, "You don't have to
14 tell him how to do it, when to do it, just
15 that it needs to be done and he does it and
16 he knows how to cut through the bureaucracy
17 and get things done."
18 What information did have at the
19 time you made this statement that Craig
20 Livingstone was an efficient individual that
21 could cut through the bureaucracy and get
22 things done?
376
1 A I had no evidence to the contrary.
2 Again, it was a nice thing to say. It's
3 basic boiler plate language.
4 Q Basic BS to the press?
5 A I didn't say that.
6 Q Do you know where Craig Livingstone
7 is today?
8 A No.
9 Q Have you ever discussed Craig
10 Livingstone's hiring with Hillary Rodham
11 Clinton?
12 A No.
13 Q Have you ever met Anthony Marceca?
14 A Not that I know of, no.
15 Q Do you know what he did at the
16 White House?
17 A Not really, no. I've read
18 public -- public reports about what he may
19 have done. I have no independent knowledge.
20 Q Have you ever discussed politics
21 with Craig Livingstone?
22 A I don't think so, no.
377
1 Q Did you ever discuss personnel
2 matters with Craig Livingstone?
3 A I don't think so, no. I think once
4 he called my office asking me to recommend
5 him to run the White House Military Office
6 and I didn't know enough -- enough about his
7 background to do that so I didn't do it.
8 Just let it go.
9 Q Did you ever visit the Office of
10 Personnel Security?
11 A No.
12 Q Did you ever go into the vault in
13 the Office of Personnel Security?
14 A If I didn't visit the office, I
15 didn't go in the vault.
16 Q Did anyone in the immediate entree
17 of people that worked with you ever go to the
18 Office of Personnel Security?
19 A No.
20 MR. KLAYMAN: I will show you what
21 I will ask the court reporter to mark as
22 Exhibit 15.
378
1 (Stephanopoulos Deposition
2 Exhibit No. 15 was marked for
3 identification.)
4 BY MR. KLAYMAN:
5 Q I'm showing you Exhibit 15, which
6 is an excerpt from Security of Background
7 Files, July 17th, 1996, "Hearing Before the
8 Committee on Government Reform and Oversight,
9 House of Representatives," July 17th 1996.
10 Turning to the third page, which is
11 on White House stationery, a letter dated
12 5/27/94. "Dear George." It goes on to the
13 next page, bears Bates numbers 046222 to
14 046223. Have you ever seen this document
15 before?
16 A Yes.
17 Q When did you first see it?
18 A When I was asked -- well, I assume
19 when I was in the White House and then when I
20 went and testified on it before the House
21 Government Affairs Committee.
22 Q This is a letter that you got from
379
1 Craig Livingstone?
2 A That's what it looks like.
3 Q Let me read it to you.
4 Did you get it on or about May
5 27th, 1994?
6 A That's the date on it.
7 MR. BRAND: You don't have to read
8 it to us, Larry. We can read it. Just tell
9 us what you want --
10 MR. KLAYMAN: I want it in the
11 record. "Dear George."
12 MR. BRAND: It's in the record when
13 you marked it as an exhibit. Why do we have
14 to waste time with this?
15 MR. KLAYMAN: We're not wasting
16 time.
17 MR. BRAND: Your reading of
18 documents is a waste of time.
19 MR. KLAYMAN: I'll conduct it the
20 way I want to conduct it.
21 MR. BRAND: If you have a question
22 about it, ask it.
380
1 MR. KLAYMAN: Mr. Brand, you've
2 already taken up more time it takes me to
3 read it.
4 BY MR. KLAYMAN:
5 Q "Dear George: Thank you for
6 offering to be of assistance in my efforts to
7 further serve the President as Director of
8 the White House Military Office. Points to
9 consider: If asked, Colonel Reins." Can you
10 read the next word?
11 MR. BRAND: It's not his letter.
12 THE WITNESS: You're the one
13 reading it.
14 MR. BRAND: He didn't write it.
15 BY MR. KLAYMAN:
16 Q Can you read the next word?
17 A You're the one who wants to read
18 the letter. It looks like an "and" to me.
19 Q "Colonel Reins and other." What's
20 the next word?
21 A I'm not going to -- if you want to
22 read the letter, you read it. If you can't
381
1 read his handwriting, then tough.
2 Q I'm asking you for your assistance,
3 here. You got the letter. Did you
4 understand it when you read it?
5 A I understood the basic gist of it,
6 sure.
7 Q Can you read the third paragraph
8 for me?
9 A "If asked, Colonel Reins and
10 others" -- that looks likes WHMO, which is an
11 acronym for White House Military Office --
12 military commanders advised that they would
13 be happy to work with me."
14 Q "I have all the appropriate
15 clearances. I have worked with the military
16 for 14 months. The job by nature should have
17 someone with sound political skills,
18 particularly as we approach NH, New
19 Hampshire. I appreciate your counsel and
20 consideration. I would be honored to serve
21 my President in this new position. I won't
22 let him down. Best Wishes. Craig
382
1 Livingstone."
2 Had you ever received a letter from
3 Craig Livingstone before this one?
4 A Not that I know of.
5 Q Did you take any action with regard
6 to this letter that Mr. Livingstone sent you?
7 A You can read the previous page and
8 if you read it, my --
9 Q I'm not asking for the previous
10 page.
11 A Well, I'm going to tell you the
12 previous page. I got a note from my
13 assistant, who read the letter, saying what
14 should we do with this and I wrote nothing.
15 Q Who was your assistant?
16 A Which is exactly what we did.
17 Ms. Heather Beckel.
18 Q Why did you do nothing?
19 A Because I didn't want to do
20 anything. I didn't know enough about him or
21 his background or the White House Military
22 Office. It had nothing to do with my
383
1 responsibilities.
2 Q Do you know what the military
3 office meant, what that reference meant?
4 A In general terms.
5 Q What is it?
6 A White House Military Office.
7 Q Is there such a thing?
8 A Yeah.
9 Q Did you ever have contact with the
10 White House Military Office, while you were
11 there?
12 A The President has a military aide.
13 I would see the military aide occasionally on
14 trips.
15 Q What was meant by New Hampshire in
16 that letter to the best of your knowledge?
17 A You have to ask Craig.
18 Q Why was the military office
19 important for New Hampshire?
20 A I have no idea.
21 Q Was he talking about the primary
22 in 1996?
384
1 A You have to ask him. I got the
2 letter, read it, did nothing, instructed my
3 assistant to do nothing.
4 Q During the time that you were at
5 the White House did you ever speak with
6 William Sessions?
7 A Maybe on the day he left there was
8 some ceremony, or the day he was reappointed.
9 I don't know. I might have shook his hand.
10 That's about it.
11 Q You ever discuss the FBI files
12 matter with him?
13 A No.
14 Q Did you ever have a discussion with
15 Director Lewis Freeh when you were at the
16 White House?
17 A I sat next to him at a dinner party
18 once.
19 Q Did you ever discuss the FBI files
20 matter?
21 A No.
22 Q Have you had a conversation with
385
1 Director Lewis Freeh since you left the White
2 House?
3 A No.
4 Q Howard Shapiro, have you ever had a
5 conversation with him while you were at the
6 White House?
7 A I already answered that.
8 Q Did you ever talk to him about Gary
9 Aldrich's book when you were at the White
10 House?
11 A No.
12 Q Have you talked to him about Gary
13 Aldrich's book since you left the White
14 House?
15 A No.
16 Q Any other matter?
17 A No.
18 Q When did you first learn that there
19 was an investigation into the Travel Office?
20 A I don't remember.
21 Q Excuse me?
22 A It depends what you consider an
386
1 investigation.
2 MR. BRAND: What does that have to
3 do with this case?
4 MR. KLAYMAN: Listen, Mr. Brand.
5 BY MR. KLAYMAN:
6 Q When did you first learn of the
7 Travel Office controversy?
8 A I said I don't remember. Sometime
9 in May 1993, I assume.
10 Q How did it come to your attention?
11 A I don't remember exactly, you
12 know -- actually. Wait. No, no, I do. I
13 was in -- I was receiving an award from my
14 university, Columbia University, and I got a
15 beep from Andrea Mitchell, of NBC News, said
16 something about the Travel Office was
17 breaking.
18 I had had some brief conversations
19 before that, I think, with Jeff Eller once in
20 a parking lot, but I didn't know that it was
21 really about to break.
22 Q What did Andrea Mitchell tell you
387
1 specifically?
2 A It was a beep. It wasn't a
3 conversation.
4 Q Did you call her back?
5 A When I got back to the White House.
6 Q What did she say to you?
7 A Well, by the time I got back to the
8 White House, it was kind of irrelevant.
9 There was a big story, they had done the
10 firing, they had done a press briefing.
11 Again, I have no idea that was
12 something that happened in May of 1993 has to
13 do with the FBI files in June of 1996.
14 Q Up to that point in May of 1993 had
15 you met Harry Thomasson?
16 A Thomasson.
17 Q Have you ever met him?
18 A I have met him.
19 Q How is that pronounced?
20 A Thomasson.
21 Q Thomasson. Yes?
22 A Uh-huh.
388
1 Q Were you aware of any desire on his
2 part to take over the Travel Office?
3 A Not until after the fact.
4 Q Had you ever met his wife?
5 A Sure.
6 Q What was her name?
7 A Linda Bloodworth Thomasson?
8 Q Were you aware from her of any
9 desire to take over the Travel Office?
10 A No, I don't know that they had any
11 desire to take over the Travel Office.
12 Q Had you ever met Katherine
13 Cornelius up to that point in time?
14 A Sure.
15 Q In what capacity had you met her?
16 A I met her when I moved to Arkansas
17 in the campaign. I saw her occasionally
18 during the course of campaign.
19 Q Were you aware of any desire on
20 Katherine Cornelius' part to have someone
21 else take over the Travel Office?
22 A After the fact, but I've learned a
389
1 lot since that happened.
2 MR. KLAYMAN: I'll show you what I
3 will ask the court reporter to mark as
4 Exhibit 16.
5 (Stephanopoulos Deposition
6 Exhibit No. 16 was marked for
7 identification.)
8 BY MR. KLAYMAN:
9 Q Showing you Exhibit 16.
10 MS. SHAPIRO: Do you have a copy
11 for us?
12 BY MR. KLAYMAN:
13 Q This is an excerpt from your
14 deposition before the Government Reform and
15 Oversight Committee, is it not,
16 Mr. Stephanopoulos?
17 A It looks like it.
18 Q Turn to page three, where it says,
19 "Question: The First Lady is CC'd on that
20 memo. Was there any procedure that you had
21 or those who worked for you had concerning
22 CC'ing the First Lady on the memorandum in
390
1 the White House?"
2 A I stand by the answer.
3 Q Do you know what's being referred
4 to there?
5 A I stand by the answer I gave there.
6 Q Was there a type of information
7 that would be CC'd did to the First Lady?
8 A I stand by the answer I gave there.
9 Q Since you've given that deposition
10 do you have any information as to how the
11 First Lady was CC'd on matters involving the
12 Travel Office affair?
13 A No.
14 Q Was it the First Lady who
15 encouraged the firing of the Travel Office
16 staff?
17 A Not that I know of.
18 MS. SHAPIRO: Objection to the
19 relevancy of this for the record.
20 BY MR. KLAYMAN:
21 Q Are you saying that she did or she
22 didn't?
391
1 MS. SHAPIRO: Will you let me state
2 my objection, please?
3 MR. KLAYMAN: I thought you just
4 did.
5 MS. SHAPIRO: You talked over me
6 and I want to make sure it's picked up by the
7 reporter. I object on relevancy grounds.
8 Now you can proceed.
9 MR. KLAYMAN: I'm sorry. I didn't
10 interrupt your relevancy grounds.
11 MS. SHAPIRO: You talked over it.
12 We need to make a record.
13 MR. KLAYMAN: All right. Good.
14 BY MR. KLAYMAN:
15 Q Are you stating unequivocally that
16 Hillary Clinton did not instigate the firing
17 of the Travel Office staff.
18 A I have read a lot of public reports
19 since this that suggest that. I had no
20 knowledge of it at the time.
21 Q Are you aware that in the course of
22 the Travel Office controversy the file of
392
1 Billy Dale, the FBI file, was pulled by the
2 White House?
3 A No.
4 Q Have you ever heard that before?
5 A I don't think so.
6 Q Are you aware that in the course of
7 the Travel Office controversy that the White
8 House went directly to the FBI and asked the
9 FBI to do an investigation of Billy Dale and
10 other members of the White House Travel
11 Office?
12 A No.
13 Q You never heard that mention?
14 A No, I certainly didn't do it.
15 Q Do you know of anyone who is
16 involved?
17 A I already answered that question.
18 Q Are you aware of a complaint by
19 Janet Reno about bypassing her office to
20 request an investigation by the FBI into
21 Billy Dale and the Travel Office staff?
22 A I didn't know about the
393
1 investigation. I couldn't know about the
2 objection. No, I did not.
3 Q Have you ever discussed the Travel
4 Office firings with Attorney General Janet
5 Reno?
6 A No.
7 Q Have you ever meet with Janet Reno?
8 A I have been in meetings with Janet
9 Reno.
10 Q Have you been in meetings that
11 concern Filegate?
12 A No.
13 Q Have you been in meetings that
14 concern Travelgate?
15 A No.
16 Q Did you participate in meetings
17 dealing with her re-appointment as Attorney
18 General in 1996?
19 A No.
20 Q What was the nature of the meetings
21 that you were in with her?
22 A Meetings on the crime bill,
394
1 meetings on the Oklahoma City bombing,
2 various cabinet meetings.
3 Q Did you ever discuss the Travel
4 Office firings with John Collingswood of the
5 FBI?
6 A Might have discussed the statement
7 that he put out, yeah.
8 Q What statement did he put out?
9 A It was a statement about what
10 nature of the investigation -- what was the
11 nature of the investigation and you know very
12 well because this is all in the public
13 record.
14 And I can't believe we're wasting
15 more time, it's nearly 6:00, eight hours into
16 this deposition about something that happened
17 in 1993, when the FBI files were taken
18 in 1996.
19 Q Who was John Collingswood?
20 A I'm assuming he's the direct -- I
21 don't know his exact title. He was director
22 of public information for the FBI.
395
1 Q What statement did he put out to
2 the best of your knowledge?
3 A It was about whether the Travel
4 Office was being investigated.
5 Q Did you put out a statement with
6 that regard?
7 A I had to give a briefing on it,
8 sure.
9 MR. KLAYMAN: I will show you what
10 I will ask the court reporter to mark as
11 Exhibit 17.
12 (Stephanopoulos Deposition
13 Exhibit No. 17 was marked for
14 identification.)
15 BY MR. KLAYMAN:
16 Q Have you seen Exhibit 17 before?
17 This is, "White House Press Release,
18 Statement of White House Travel Office" dated
19 May 21st, 1993?
20 A Yes.
21 Q Did you prepare that?
22 A In part, sure. I reviewed it. I
396
1 approved it, I probably read it.
2 Q Did you write it?
3 A I'm sure I wrote -- I wrote pieces
4 of it and edited it. I'm sure I didn't do
5 the first draft.
6 Q Who did the first draft?
7 A I don't know.
8 Q Was it done by the White House
9 Counsel's Office?
10 A Probably was reviewed by them. I
11 don't know who actually did the drafting.
12 Q Was it your responsibility to send
13 out press releases at this time?
14 A They went out over my name, yes.
15 Q That was part of your duties and
16 responsibilities?
17 A Yes.
18 Q In this press release did you state
19 that Mr. Billy Dale was under criminal
20 investigation by the FBI?
21 A I don't think the word "Billy Dale"
22 appears here.
397
1 Q That the White House Travel Office
2 employees were under criminal investigation?
3 A No, that's different. Where --
4 there is a sentence that says, "The FBI has
5 determined from the information it's already
6 obtained that additional criminal
7 investigation is warranted." That's what it
8 says.
9 Q Where did you get that information?
10 A From the FBI.
11 Q Who gave it to you at the FBI?
12 A I assume it was John Collingswood.
13 Q You had that information before you
14 wrote this press release?
15 A Certainly before I read it.
16 Q Did you ask who was under criminal
17 investigation by the FBI?
18 A I wanted to make sure that what we
19 were saying was right and it was what the FBI
20 was saying.
21 Q Now, this statement was made with
22 regard to the White House Travel Office,
398
1 correct?
2 A Sure.
3 Q Therefore, anybody that worked in
4 the White House Travel Office, one could
5 infer from this statement, would be under
6 criminal investigation, correct? That's what
7 you meant?
8 A No. I meant exactly what I said
9 and it's a very carefully written statement.
10 "The White House has received a final report
11 by the accounting firm of Peat Marwick
12 regarding its study of the White House Travel
13 Office. We are making the report available
14 to the FBI and the public this afternoon.
15 "The FBI has determined from the
16 information that's already obtained that
17 additional criminal investigation is
18 warranted."
19 The date is May 21st, 1993, a full
20 three years before any story on the White
21 House files -- FBI files in the White House
22 broke.
399
1 Q Did you have any information in
2 writing at the time from the FBI that they
3 had embarked upon a criminal investigation at
4 the time you made this press release on May
5 21st, 1993?
6 A I wouldn't have said this if I
7 didn't believe it were true.
8 Q Did you have any hard evidence that
9 it was true?
10 A They told me that.
11 Q Collingswood?
12 A I assume so, yes.
13 Q Did it come from any other source?
14 A No.
15 Q At the time that you made this
16 statement did you double check whether it was
17 true with someone other than Collingswood?
18 A No, I didn't feel that was
19 appropriate or necessary.
20 Q That's a pretty serious statement,
21 is it not?
22 A Sure. That's why I wanted to make
400
1 sure it was not contradicted by the FBI.
2 That's why I asked the FBI representative
3 whether it was true.
4 Q Are you aware that at the time
5 Former Associate Attorney General Web Hubbell
6 blamed you for a mistake in issuing this
7 press release to any of the White House
8 Travel Office Director Billy Dale was under
9 criminal investigation by the FBI?
10 A Again, that's not what the
11 statement said. It was -- I actually think
12 it was a mistake as well in retrospect simply
13 because it was -- because it created a
14 controversy.
15 I think I did everything right to
16 the best of my ability. There were members
17 of the White House Counsel's Office in my
18 office when this statement was prepared. I
19 believed I was acting in accordance with the
20 rules. If I wasn't or if there were an
21 appearance that I wasn't, that is something I
22 have acknowledged and still acknowledge. It