401
1 was a mistake. I wish I hadn't done it.
2 Q Did it concern you at the time that
3 you were using the FBI for a political
4 purpose?
5 A That's not what I thought I was
6 doing. I thought I was trying to be accurate
7 and that's exactly what I thought I did.
8 Q Now, there was a discussion at the
9 White House at the time that issuing a
10 statement that the FBI was investigating this
11 criminally would take some of the pressure
12 off of the White House for firing the White
13 House Travel Office?
14 A No. Actually my only concern was
15 that I didn't want to put out a statement
16 that would be contradicted by the FBI. I
17 wanted to make sure that whatever I said was
18 accurate and true, which is why I asked the
19 FBI, you know.
20 In the -- in the atmosphere we live
21 in today that turns out to be suspect and
22 that's why I wish I hadn't done it. But I
402
1 was doing it in an attempt to make sure
2 everything I said was right.
3 Q During the time that this press
4 release was being prepared and the statement
5 was issued did anyone inside the White House
6 caution you or anyone else about using the
7 FBI's name in the context of the Travel
8 Office?
9 A Had -- had the White House
10 Counsel's Office cautioned me on it I would
11 haven't done it. In fact, I believe --
12 MS. SHAPIRO: Nor would he testify
13 to it.
14 MR. KLAYMAN: I don't find that
15 humorous to interrupt his testimony,
16 Ms. Shapiro.
17 MS. SHAPIRO: Well, I need to
18 caution the witness not to disclose any
19 privileged information --
20 MR. KLAYMAN: I don't think you
21 need to do anything.
22 MS. SHAPIRO: -- and you're talking
403
1 over me again.
2 MR. KLAYMAN: I'm afraid you talked
3 over his testimony and that's inappropriate.
4 MR. BRAND: He was about to utter a
5 privileged statement she thought.
6 MR. GAFFNEY: I'd ask the counsel
7 for the plaintiff to show a little more
8 respect to counsel around the table.
9 MR. KLAYMAN: I think the record
10 will speak for itself in terms of respect,
11 Mr. Gaffney. You're not the -- with respect
12 to counselor here, we do have a videotaped
13 deposition. I think it will show the
14 demeanor adequately.
15 THE WITNESS: Too bad we don't have
16 two cameras.
17 MR. KLAYMAN: Certify it. You want
18 to take a break and move the cars? Off the
19 record.
20 VIDEOGRAPHER: This is the video
21 operator. We're going off the record. The
22 time now is approximately 5:57 p.m.
404
1 (Discussion off the record)
2 VIDEOGRAPHER: This is the video
3 operator. This is tape two of the George
4 Stephanopoulos deposition. The time now is
5 approximately 6:15 p.m. Mr. Klayman?
6 BY MR. KLAYMAN:
7 Q Have you ever discussed the FBI
8 files matter with Dick Morris?
9 A No.
10 Q Are you aware that Mr. Morris'
11 girlfriend, Sherry Rowlands, kept a diary
12 whereby she's reported to have stated that
13 based upon conversations with Dick Morris,
14 that Hillary Clinton is the mastermind of
15 Filegate?
16 A I don't know what she wrote. I
17 know there may have been reports of what she
18 may have written at the time, but I don't
19 know what it was.
20 Q At the time of the Dick Morris
21 incident, were you still working at the White
22 House?
405
1 A Uh-huh.
2 Q It was in and around that time
3 period that the reports of Hillary Clinton's
4 alleged involvement in Filegate surfaced?
5 A I don't know that. I just answered
6 that question.
7 Q But you did read about the Rowlands
8 diary, at that time?
9 A Sure. I don't remember what it
10 said.
11 Q Have you ever read the Rowlands
12 diary?
13 A No. I think the report is in the
14 Starr tabloid.
15 Q Was there any discussion at the
16 White House about that statement, as reported
17 by Star Magazine, at the time?
18 A No.
19 Q None that you know of?
20 A Not that specific statement. I
21 mean speaking only for myself, I was just
22 happy that he was gone.
406
1 Q He's not one of your favorites?
2 A No.
3 Q Would if be fair to say that
4 there's a hate relationship between the two
5 of you?
6 A No, it's more complicated than
7 that.
8 Q How so?
9 A Just is. It has nothing to do with
10 the FBI files. I never talked to him about
11 the FBI files.
12 Q You dislike Mr. Morris?
13 A Right now I don't think about him
14 too much.
15 Q Well, when you thought about him,
16 you disliked him strongly?
17 A Yeah, that's fair.
18 Q What's the basis of your dislike
19 with him?
20 A It's an aesthetic thing.
21 Q Do you think he's ugly?
22 A I didn't say that.
407
1 Q Then what do you mean by it's an
2 aesthetic thing?
3 A Just a sensibility, a feeling, not
4 my kind of guy.
5 Q Why is that?
6 A It's hard to -- you know, facts
7 aren't feelings. Feelings aren't facts.
8 It's just a feeling I have.
9 Q Did he ever do anything to you that
10 you disagreed with?
11 A Nothing that has anything to do
12 with the FBI files.
13 Q But anything with you generally?
14 I'm going to ask you some questions about
15 him.
16 A Great.
17 Q I want to know what your opinion of
18 him is.
19 A I told you my opinion of him.
20 Q What is it based on?
21 A Working with him.
22 Q Do you consider him to be a
408
1 dishonest person?
2 A You know, depends on the day.
3 Q You have considered him to be a
4 dishonest person?
5 A I have no idea how this can
6 possibly be relevant to -- to the FBI files.
7 Q His reputation with you is one of
8 dishonesty?
9 A Sometimes yes, sometimes no.
10 Q Do you have any opinion of him
11 based upon his reported sexual activities,
12 that's the reason you don't like him?
13 A No, but it's -- I think it was an
14 incredibly stupid thing to do.
15 Q What? Have an affair with Sherry
16 Rowlands?
17 A While he was in the employ of the
18 President when it could be used against him
19 and it could threaten the campaign, yes.
20 Q It's stupid to do it or stupid to
21 get caught?
22 A I already answered that question.
409
1 I said it was a stupid thing to do.
2 Q Is it also stupid to get caught in
3 your opinion?
4 A I said it was stupid to do. I
5 think it is stupid to do.
6 Q During the period that Dick
7 Morris was a consultant for President
8 Clinton?
9 A For the Clinton for President
10 campaign, yes.
11 Q For 1996.
12 A DNC. I don't really know how he
13 was paid.
14 Q Did he ever you who he was employed
15 by?
16 A It's not the kind of thing he would
17 sit down and talk about. He worked -- he
18 worked, generally, on the campaign. I don't
19 know who paid him.
20 Q I take it you've had discussions
21 with him during the course of his employment
22 on behalf of the President's campaign?
410
1 A Never about the FBI files.
2 Q Have you heard of discussions just
3 generally?
4 A Sure.
5 Q About campaign strategy?
6 A Absolutely.
7 Q You meet with him on a frequent
8 basis leading up to the 1996 elections?
9 A Depending on the day.
10 Q During the time that you met with
11 him did he ever tell you that he had had
12 conversations with Hillary Rodham Clinton?
13 A May have, sure. Never about the
14 FBI files.
15 Q Well, what conversations did he
16 tell that he had?
17 A I don't remember. We talked a lot.
18 Q He was in constant contact with
19 Mrs. Clinton, was he not, leading up to
20 the 1996 campaign?
21 A I don't know that. He may. I'm
22 sure he talked to her occasionally. I don't
411
1 know what constant contact means. I don't
2 know how much contact he had.
3 Q Do you know what kind of access he
4 had to Mrs. Clinton?
5 A I just answered that. Contact and
6 access aren't that different a thing.
7 MR. KLAYMAN: I'll show you what
8 will I ask the court reporter to mark as
9 Exhibit 18.
10 (Stephanopoulos Deposition
11 Exhibit No. 18 was marked for
12 identification.)
13 BY MR. KLAYMAN:
14 Q Exhibit 18 consists of a cover
15 letter from Jerry McDewitt, of Kirkpatrick &
16 Lockhart, LLP, to Ms. Barbara Olson, Chief
17 Investigate Counsel, Committee on Government
18 Reform and Oversight, and attached to it is a
19 two-page affidavit of Dick Morris.
20 It states at the top of page one of
21 that affidavit, "Statement to Government
22 Oversight Committee by Dick Morris." You can
412
1 have an opportunity and review that
2 affidavit.
3 A I did.
4 Q Have you ever seen it before?
5 A I don't think so.
6 Q Excuse me?
7 A I don't think so.
8 Q Were you aware that Mr. Morris had
9 prepared and submitted an affidavit to the
10 Government Reform and Oversight Committee?
11 A I may have been. I'm not surprised
12 by it. I don't know if I had contemporaneous
13 knowledge.
14 Q Where did you get any knowledge at
15 all?
16 A I probably saw a press report that
17 he had been called there, but I couldn't
18 swear to it.
19 Q Did you discuss his affidavit with
20 him?
21 A If I never discussed FBI files with
22 him, then I didn't discuss this with him.
413
1 Otherwise I would have answered that.
2 Q Did you ever discuss Mr. Morris'
3 affidavit with anyone at Kirkpatrick &
4 Lockhart?
5 A No.
6 Q It states, paragraph one, "The
7 account printed in the Star of my
8 conversation with Ms. Rowlands on June 24th,
9 1996, is, to the best of my knowledge,
10 inaccurate."
11 Paragraph two, "It's my
12 recollection that I had a conversation with
13 her on or about June 24th in which we
14 discussed who the public believed was
15 responsible for the search of FBI files by
16 the White House."
17 Do you have any knowledge of the
18 conversation Mr. Morris had with Mrs. Clinton
19 on or about June 24th?
20 A No.
21 Q "My recollection is that I said in
22 words or substance, everyone thinks it's
414
1 Hillary who is responsible. I base that
2 comment on polling data I had recently
3 analyzed. The poll was conducted on
4 June 18th and 19th.
5 In that polling respondents were
6 first asked if they believed the
7 investigation showed the Clintons are
8 responsible for a lot of wrongdoing.
9 39 percent said that they felt the
10 Clintons were responsible and 35 percent said
11 they were not. In the survey those
12 respondents who said the Clintons were
13 responsible were then asked if they believed
14 that the President or the First Lady were
15 responsible for the examination of FBI files
16 by the White House.
17 This question was answered with
18 74 percent saying the First Lady was
19 responsible and 6 percent saying the
20 President was responsible.
21 "This poll data was the basis of
22 any such remarks by me. I do not recall
415
1 sharing the actual poll data with Rowlands."
2 Are you aware of any such polling
3 that occurred in and around this time period?
4 A It's possible. I don't remember it
5 specifically.
6 Q Do you remember anything about it?
7 A Not really. I mean this is just a
8 perfect example of what Dick would do. I
9 mean he would poll on a question that was,
10 basically, a factual matter.
11 To me what was important was
12 whether it happened. Based on my testimony
13 to date I didn't know anything about what
14 happened. The polling was irrelevant.
15 Q But you don't know specifically of
16 any actual poll that he took on these
17 matters?
18 A I don't remember it, no.
19 Q Paragraph three, "I have no
20 personal knowledge or information from any
21 source whatsoever as to who was responsible
22 for ordering the FBI files or the use to
416
1 which such files were put on receipt by White
2 House personnel."
3 Did Dick ever discuss that with
4 you?
5 A I already answered that question.
6 Q Now, during the course of your
7 dealings with Dick Morris did he ever tell
8 anyone anything that was untrue about George
9 Stephanopoulos?
10 A Sure.
11 Q What did he tell others that were
12 untrue about you?
13 A Again, I don't know what relevance
14 it has, but he once told the President that I
15 leaked polling information to the Bob Dole
16 Presidential Campaign, which Dick Morris had,
17 in fact, leaked to the Bob Dole Presidential
18 Campaign.
19 Q Anything else?
20 A That's the one that sticks out in
21 my mind.
22 Q But that's an example of how
417
1 Mr. Morris would sometimes fabricate facts?
2 A Your conclusion. It just wasn't
3 true.
4 Q Based on your experience?
5 A Wasn't true.
6 Q That wasn't the only time that
7 you've ever known Dick Morris not to tell the
8 truth, was it?
9 A That's the one that sticks out in
10 my mind.
11 Q But there were other occasions,
12 correct?
13 A Probably, but I couldn't swear to
14 it now.
15 Q You have a very low regard for
16 Mr. Morris' honesty, don't you?
17 A I already answer had question.
18 Q What is the reputation of Dick
19 Morris around the White House for honesty?
20 Bad?
21 A Depended on who you asked.
22 Q What was the general reputation
418
1 when you were there?
2 A I don't know if there was a general
3 reputation. It depended on who you asked.
4 Q Did the President have any opinion
5 that he ever expressed to you about Dick
6 Morris' honesty and veracity?
7 MS. SHAPIRO: Objection. He's not
8 going to testify about any conversations he
9 had with the President.
10 MR. KLAYMAN: Certify it.
11 BY MR. KLAYMAN:
12 Q Did anyone else ever express to you
13 their views that Dick Morris was not an
14 honest person during the time you were at the
15 White House?
16 A Probably. I don't have any
17 specific conversation.
18 Q Do you remember names of persons
19 who hold that belief?
20 A Could have been anybody.
21 Q Has Mr. Paul Begala ever expressed
22 to you what his opinion is of Dick Morris'
419
1 honesty?
2 A I don't know about his honesty. I
3 don't think Paul likes Dick Morris very much,
4 but I don't know.
5 Q Did Mr. Blumenthal ever tell you
6 what his opinion is of Dick Morris' honesty?
7 A No.
8 Q Mr. Emanuel?
9 A Again, I don't know about honesty.
10 I'm sure we talked about Dick at times.
11 Q Did he ever express to you his view
12 that Dick wasn't an honest person?
13 A Couldn't swear to that. I don't
14 think he likes Dick that much, but you'd have
15 to ask him.
16 Q Did Mr. Panetta ever express his
17 views on whether Mr. Morris was honest?
18 A Again, I don't remember honest
19 particularly. I don't know what exactly he
20 thought about Dick. I don't think he had a
21 very high regard for him.
22 Q Discussions of honesty really don't
420
1 occur much at the White House, do they?
2 A That's actually not true at all.
3 Q Whether somebody is honest?
4 A In fact, about 20 minutes ago we
5 spent a lot of time explaining about one of
6 the reasons I -- in the statement I put out
7 about the Travel Office, I was trying to make
8 sure it was honest. That was my job.
9 Q Do you know a Gary Aldrich?
10 A No. I know of him.
11 Q You never met him?
12 A Oh, I met him.
13 Q When did you first meet him?
14 A I guess he interviewed me during
15 the FBI background checks early in '93.
16 Q What was his job title at the time?
17 A Got me.
18 Q Were you aware that he was an FBI
19 agent at the time?
20 A To the extent that I thought about
21 him, sure.
22 Q He was in charge of doing
421
1 background checks?
2 A I assume that's the first time I
3 met him.
4 Q Did you ever have an opportunity to
5 review a manuscript or a published version of
6 his book "Unlimited Access"?
7 A Those are two very different
8 things. When I heard about it, I asked my
9 assistant to go to Crown Books and buy it,
10 which she did, and brought it back for me and
11 then I read it.
12 Q Who was your assistant at the time?
13 A Laura Capps.
14 MR. KLAYMAN: I will show you what
15 I will ask the court reporter to mark as
16 Exhibit 19.
17 (Stephanopoulos Deposition
18 Exhibit No. 19 was marked for
19 identification.)
20 MR. BRAND: The xerox company loves
21 you, Larry.
22 MR. KLAYMAN: Excuse me?
422
1 MR. BRAND: The Xerox company loves
2 you.
3 MR. KLAYMAN: I think they do.
4 THE WITNESS: Good old days.
5 BY MR. KLAYMAN:
6 Q Could you take an opportunity and
7 take a look at Exhibit 19? Is this a copy of
8 the book Unlimited Access which you asked
9 Ms. Capps to buy for you?
10 A It looks like -- well, it looks
11 like a photocopy of it, yes.
12 Q Did you provide this to the
13 Government Reform and Oversight Committee?
14 A I don't know.
15 MR. BRAND: Maybe the White House
16 did. We did.
17 THE WITNESS: Yeah, I don't
18 remember.
19 BY MR. KLAYMAN:
20 Q Let's turn to Bates number 056345.
21 A One of my favorite pages.
22 Q Is that your handwriting next to
423
1 the underlined portions?
2 A Sure.
3 Q You wrote "lie"?
4 A Yes, because it is.
5 Q How did you determine that the
6 markings here off these paragraphs
7 constituted lies?
8 A I was there at the time.
9 Q Why did you annotate this copy of
10 the book? Why did you take the time to do
11 it?
12 A Because Mr. Aldrich was getting a
13 lot of publicity to what I believe was a
14 total fabrication, which has later been borne
15 out by subsequent events.
16 MR. BRAND: Does this have
17 something to do with the files?
18 MR. KLAYMAN: Well, I'm going to
19 get to that. I'm just trying to identify his
20 handwriting right now.
21 THE WITNESS: I already answered
22 that.
424
1 BY MR. KLAYMAN:
2 Q Turn to page 056347.
3 A Well, it's -- but I mean since you
4 asked me, I'm going to explain why I thought
5 these were lies.
6 "One of the reasons the Clintons
7 were late was because Vice President Gore had
8 just found out that the West Wing office
9 usually reserved for the vice-president was
10 instead going to be occupied by the First
11 Lady."
12 That, in fact, is not true. The
13 one underlying contention that -- that she
14 was going to get his office wasn't true; and,
15 two, the reason they were late was -- because
16 they were late at the White House was that
17 with President and Mrs. Bush.
18 Number two, second, it said that,
19 "Network news cameras, trained on Blair
20 House, the morning of the inauguration,
21 recorded a glimpse of the President and First
22 Lady screaming at each other. Hillary
425
1 shouted at him that as far as she was
2 concerned they had a deal, a deal that dated
3 back to the campaign when Lloyd Cutler had
4 convinced her to stand by Clinton despite the
5 allegations that he'd had an affair with
6 Gennifer Flowers."
7 Number one, there's no way that
8 that network news cameras could pick up the
9 sound and.
10 Number two, I was with them for all
11 of that morning except for the time they were
12 at the White House when I went to the
13 Capitol. I never observed it.
14 Number three, Lloyd Cutler -- I was
15 with them when the Gennifer Flowers story
16 broke in the campaign and Lloyd Cutler was
17 nowhere to be seen. That's not true.
18 Q Are you saying that you never saw
19 the President and Mrs. Clinton screaming,
20 either one or the other?
21 A At this time --
22 Q Have you ever seen either of them
426
1 scream at each other?
2 A I'm not going to answer that
3 question.
4 Q You have to answer that question.
5 You just offered testimony. Have you ever
6 seen them scream at each other?
7 A I have never saw them scream at
8 each other about the FBI files.
9 Q You saw them scream at each other
10 about other things, correct?
11 A I never saw them scream at each
12 other about this.
13 Q But you did see them scream at each
14 other, correct?
15 A I -- I have seen a lot of things in
16 my time. That is no relevance to the FBI
17 files and, finally, at the bottom of the
18 page --
19 Q Is the answer no? Is the answer
20 no, that you never saw them scream at each
21 other?
22 A I didn't say that. I would finally
427
1 say --
2 Q Did the President ever --
3 A Wait. Let me finish.
4 Q During the time that you worked
5 there. I'm entitled to ask questions. You
6 can go on.
7 MS. SHAPIRO: He's entitled to
8 finish his answer.
9 THE WITNESS: I'm entitled to
10 finish my answer --
11 MR. KLAYMAN: Well, finish your
12 answer.
13 THE WITNESS: -- which is the last
14 lie which I documented on this page was that
15 in the holding room Hillary was screaming at
16 her because -- and that's why he was late to
17 go out and give his speech.
18 The reason he was late to go out
19 and give his speech is because I was up in
20 the speakers office with a draft of the
21 speech and I was late getting there. They
22 were -- when he got there, he was fine.
428
1 There was no screaming.
2 BY MR. KLAYMAN:
3 Q Did the President during the time
4 that you worked at the White House ever
5 scream at you?
6 MR. GAFFNEY: I'm going to object,
7 Mr. Klayman, to this question. It has
8 utterly no relevance whatsoever in any claim
9 asserted in either complaint in these
10 consolidated or nor is it conceivably related
11 to this.
12 I consider this an abuse of the
13 subpoena process and unless you withdrew the
14 question, I'm putting you on notice that we
15 may seek sanctions in the discovery code
16 under the court's inherent authority to this
17 line of questioning.
18 MR. KLAYMAN: Thank you,
19 Mr. Gaffney. Want to say anything else?
20 MR. GAFFNEY: I believe the record
21 is clear on my views.
22 MR. KLAYMAN: The witness raised
429
1 these issues. He wanted to explain, so I'm
2 entitled to ask.
3 MR. BRAND: The witness did not
4 raise these issues and if you think that the
5 subpoena power that counsel gets pursuant to
6 a civil case entitles you to conduct a broad
7 fishing expedition into any issue that -- to
8 pose any question you feel like posing, that
9 is a position that is untenable in the law
10 and if you want to proceed on that, you do so
11 at your own peril.
12 MR. KLAYMAN: Let me lay a
13 foundation so you can, then, make your speech
14 again.
15 BY MR. KLAYMAN:
16 Q During the time you were at the
17 White House, did the President ever criticize
18 you on anything?
19 A I'm not going to answer that.
20 MR. KLAYMAN: Certify it.
21 BY MR. KLAYMAN:
22 Q Did he ever yell at you about
430
1 anything that you did?
2 A I'm not going to answer that.
3 Q Were you yelled at with regard to
4 the Travel Office and the press release
5 identified earlier by anyone at the White
6 House?
7 A No.
8 Q Yelled at by the President?
9 A I'm not going to answer it.
10 MR. KLAYMAN: Certify it.
11 BY MR. KLAYMAN:
12 Q That's Exhibit 17 I'm referring to.
13 To the best of your knowledge, did
14 the President ever scream at anyone
15 concerning the FBI file matter?
16 MR. BRAND: Larry, the clock on the
17 wall now says 6:30. We've been at this since
18 roughly 10 after 10:00 with the lunch break.
19 I don't want to go beyond the six hours
20 allotted at this point.
21 MR. KLAYMAN: Well, I've been
22 keeping track of the time and if you deduct
431
1 out lunch and the break, the six hours will
2 come to a close around 7:30.
3 THE WITNESS: No way.
4 MR. KLAYMAN: Yes.
5 THE WITNESS: No way.
6 MR. KLAYMAN: Yes.
7 THE WITNESS: I was here at 10:10.
8 MR. BRAND: That can't be right.
9 MR. KLAYMAN: Are you setting the
10 ground rules, Mr. Stephanopoulos?
11 MR. BRAND: No, what I'm saying --
12 MS. SHAPIRO: The court has set the
13 ground rules, I'm afraid.
14 MR. KLAYMAN: That's correct.
15 MR. BRAND: What I'm saying is,
16 Larry, is at six hours after being here we're
17 going to end for today. That's all we're
18 saying, which is my understanding of what the
19 order of the court has provided.
20 MR. KLAYMAN: When does that six
21 hours conclude in your opinion, Mr. Brand?
22 MR. BRAND: I think we're there
432
1 already. I've actually let it slide as an
2 act of grace to let you finish up what you
3 need to finish up on this issue, not all of
4 these other irrelevant matters.
5 MR. KLAYMAN: Should I be calling
6 you Willie Maze in the future? What do you
7 mean by letting it slide?
8 MR. BRAND: By my calculation we're
9 past the six hours.
10 MR. KLAYMAN: We're not past it and
11 if you deduct all the time that was taken for
12 breaks and lunch, a very long lunch break, I
13 might add, by Mr. Stephanopoulos, the six
14 hours will not be concluded until
15 aren't 7:30.
16 MR. BRAND: We're not staying
17 until 7:30.
18 MR. KLAYMAN: Well, when are you
19 going to take it upon yourself to leave,
20 Mr. Brand?
21 MR. BRAND: I think we were done
22 at 6:30. I think that was the six hours by
433
1 the calculation I've kept in my notes.
2 MR. KLAYMAN: Well, notwithstanding
3 the calculations which are on the record, can
4 I ask questions up to 7:00 as of tonight?
5 THE WITNESS: How about a quarter
6 of?
7 MR. KLAYMAN: You're setting the
8 ground rules, Mr. Stephanopoulos?
9 MR. BRAND: No, we're saying when
10 we think we -- I'm telling you when we think
11 it's over.
12 MR. KLAYMAN: I'm telling you it
13 will not come to a close as of 7:30. I will
14 submit to the court for the record how long
15 the testimony was and, in fact, because we
16 didn't get responses to a lot of things, we
17 will be moving to bring Mr. Stephanopoulos
18 back. But right now I want to complete the
19 six hours that I have.
20 MR. BRAND: We'll go to a quarter
21 of 7:00 and then we're leaving.
22 MR. KLAYMAN: Okay. Well, you do
434
1 so at your own risk. There have been other
2 instances in other cases involving this court
3 where people have gotten up and left and we
4 will be moving for appropriate remedies if
5 you get up and leave at your own volition.
6 BY MR. KLAYMAN:
7 Q Turn to page 056360.
8 A 360.
9 Q Is that your handwriting on that
10 page?
11 A Yeah.
12 Q What does it say at the top?
13 A Innuendo.
14 Q Innuendo. When you put questions
15 marks as opposed to stars, is there any
16 reason for that?
17 A I don't know exactly. Let me read
18 it.
19 Q If you have question marks, does
20 that mean you have questions about it? It
21 might be right, but you have questions?
22 A No. What it meant was that I
435
1 thought it was too ludicrous even to check,
2 but that it would be one of the easier things
3 to disprove.
4 Q Stars, what do stars mean? It
5 means it's right, correct, important point?
6 A No, it means that it was even a
7 better example of how he was fabricating
8 things.
9 Q But you didn't write fabricated,
10 did you?
11 A I know my own code. I know my own
12 handwriting. I know when I wrote three stars
13 and two parallel lines that meant that I was
14 going to come back to that as an example of
15 how Gary Aldrich was making stuff up in his
16 book. That's when I meant.
17 Q In fact, you've referred to Gary
18 Aldrich before as a pathological liar, have
19 you not?
20 A Oh, and I'll take this opportunity
21 to do so again for pay.
22 Q What was your code for question
436
1 marks?
2 A Too silly to check -- well, I
3 already answered that.
4 Q To silly to check is question
5 marks?
6 A But easy to disprove.
7 Q But easy to disprove. Page 056397.
8 Is that your handwriting there?
9 A Yeah.
10 Q What did your code mean when you
11 had three questions marks and the word
12 "ridiculous" and a line?
13 A It meant it was ridiculous.
14 MR. BRAND: It would be easy to
15 disprove.
16 THE WITNESS: It would be easy to
17 disprove, right.
18 BY MR. KLAYMAN:
19 Q Turning to the next page.
20 A Lots of stars.
21 Q Well, let's go back to 056397.
22 What information did you have with regard to
437
1 this incident with Vince Foster that could
2 lead you to believe that it was ridiculous
3 what Mr. Aldrich had written?
4 A What is he talking to here? Let me
5 see. It's hard to follow. He's not a
6 greater writer either.
7 Well, basically you're 79 pages in
8 and I think he had already demonstrated I
9 didn't believe much of anything, but this was
10 a specific claim which I thought sounded
11 ridiculous.
12 Again the question marks did mean
13 it was something that we could check pretty
14 easily. The rest speaks for itself.
15 Q But, in fact, you didn't have any
16 information yourself to prove it was
17 ridiculous?
18 A Well, I had -- certainly had enough
19 information to write in my own copy of my own
20 book that it was ridiculous.
21 Q But you didn't have any information
22 yourself to prove it was ridiculous?
438
1 A I was reading the book at home. I
2 came upon page 79 --
3 Q Well, the bottom line is you
4 actually did know whether this was true or
5 false because, in fact, you had talked to
6 Foster about these matters, hadn't you,
7 security clearances?
8 A Absolutely not.
9 Q Let's turn to the next
10 page, 056938. Look down in the middle of the
11 page where it says, "Craig didn't answer. He
12 just stared straight ahead and in his
13 nonanswer I believe he was telling me that he
14 knew that the rumors were true. We sat there
15 in silence while I thought of what to say
16 next. I was very uncomfortable. I tried to
17 change the subject."
18 Now, according to your previous
19 coding system, if you put a line and three
20 stars, that means it's untrue, correct?
21 A I think it means it's something
22 that I could use to call everything else he
439
1 was saying into question. I think that this
2 is pretty clearly a fabricated conversation
3 based on what he believed, suppositions he
4 believed about the members, it was a leap --
5 leap into the unknown by Mr. Aldrich trying
6 to get things into the record that otherwise
7 couldn't be gotten into the record.
8 I thought if a reasonable
9 journalist read this, they would agree with
10 my judgment that this was a fabrication.
11 Q But, in fact, you didn't have any
12 information as to the conversation between
13 Mr. Aldrich and Mr. Livingstone, did you?
14 A Mr. Aldrich might not have had it
15 either. He might have just written it.
16 Q But you didn't have any information
17 to disprove what he said was true, did you?
18 A I certainly had enough that I
19 believe if I could show it to reporters, they
20 would be able to back me up on it.
21 Q Were you familiar with the
22 conversations that Mr. Aldrich had with
440
1 Mr. Livingstone?
2 A No, but I don't think -- and I
3 don't know that he even had one.
4 Q Turn to the next page.
5 A I notice that there's no
6 documentation by him here. I notice he's put
7 things in quotes without footnotes, not
8 standard historical practice.
9 Q Next page, 056399. You have false
10 written next to several entries, correct?
11 Let's look at the bottom entry on that page
12 where it says, "Look, Gary, I'm the security
13 guy around here. Whatever happens recording
14 security I'm in it even if I don't decide,
15 even if I'm just told what to do. I'm still
16 in the meetings.
17 They know that I deal with the FBI
18 all the time, so they would naturally want me
19 to know what is going on. I've been in most
20 of the meetings about security and the FBI.
21 Your director calls me all the time. He
22 knows me by my first name."
441
1 In fact, you do have knowledge that
2 FBI Director Lewis Freeh had called Craig
3 Livingstone, correct?
4 A I didn't have that, no, otherwise I
5 wouldn't have written false.
6 Q Did you have any knowledge as to
7 whether Williams Sessions had called Craig
8 Livingstone?
9 A I didn't believe he had. I didn't
10 know.
11 Q But you didn't have enough
12 information yourself?
13 A I had enough information and enough
14 judgment to believe in my personal copy of my
15 own -- of my own book that I could write
16 false there.
17 Q But you didn't have any information
18 to disprove what Mr. Aldrich had written, did
19 you, firsthand information?
20 A It just didn't sound right to me.
21 Q If it doesn't sound right, it's all
22 of a sudden false and Gary Aldrich is a
442
1 pathological liar; is that it?
2 A No, there's a million things in
3 here that are wrong. Again, I've expressed
4 to you this is my personal copy of the book.
5 I can write whatever I want in my
6 personal copy of the book and it's my
7 judgment that Mr. Aldrich is a pathological
8 liar, which I think is borne out by the
9 amount of untruths and falsehoods in this
10 book.
11 But, you know, I don't see how --
12 what I wrote in my -- in my copy of Gary
13 Aldrich's book is relevant to that at all.
14 Q In fact, you did have information
15 about what Mr. Aldrich wrote about in the
16 last paragraph on page 056399, didn't you?
17 A I already answered that question.
18 Q No?
19 A No.
20 Q Page 056400, last paragraph, you
21 just have a line. "Craig looked at me like I
22 didn't have a brain. Nussbaum? It's not
443
1 Nussbaum we've got to talk to. We'll be
2 talking to Hillary. What? You're kidding?
3 No? Look, Craig. I said I'd help you, but
4 an FBI agent meeting was with the First
5 Lady." Did you have any information with
6 regard to this last paragraph to put a line
7 next to it, to question it?
8 A I don't know why I put a line next
9 to it.
10 Q In fact, you previously testified,
11 when you put a line next to something, that
12 meant that it was false?
13 A That's not what I said.
14 Q Do you consider this to be false,
15 what was written here?
16 A Probably, yeah. I think most -- I
17 think the book, as I've said in public many,
18 many times, is basically a fabrication.
19 Q Turn to the next page. 056401.
20 First paragraph, "Hillary is the one to talk
21 to, trust me. I'll be talking to her
22 tonight. I've got to join them on a trip on
444
1 Air Force One.
2 She'll understand the risk you're
3 taking. You don't have to worry about her
4 hurting your career. I know her well enough.
5 She'll be interested to hear what you have to
6 say and she's the only one who can change
7 things."
8 A This was a butte for me. I thought
9 this was, you know, rock solid evidence of
10 disproving things because, if I remember the
11 chronology correctly, this came out sometime
12 in June. This came out after the FBI files,
13 I think, had happened. Yeah, it was after
14 the FBI files. Right?
15 I mean why I think I wrote that, if
16 my memory is correct, that this book came out
17 after all of the testimony had come out in
18 the FBI files. That by this time I would
19 have known, based on public records, that
20 Hillary denied getting Craig Livingstone the
21 job, that Hillary said, in fact, she may have
22 only met him once or twice, did not have a
445
1 close personal relationship and deep
2 relationship with him where she would be
3 talking to him, that he wouldn't have been on
4 that trip in Air Force One most likely, that
5 this would have been one of the easiest
6 things to disprove in the whole book.
7 Q Did you ever sat about to gather
8 information to disprove this particular
9 paragraph in Aldrich's book?
10 A I don't know if I needed to on that
11 one because there was enough on the public
12 record already.
13 Q You would believe anything on the
14 public record; is that your position?
15 A No, no, I didn't say that. I
16 believe the First Lady, when she says
17 something on the public record.
18 Q You were not privy to this alleged
19 conversation with Hillary, were you, as
20 reflected on 056401?
21 A I was privy to the public
22 statements where Hillary said that she didn't
446
1 have that kind of relationship with him.
2 Q You would believe anything that
3 Hillary Rodham Clinton tells you?
4 A I certainly would believe what
5 Hillary Rodham Clinton says on the public
6 record about her relationship with Craig
7 Livingstone and certainly I'll believe what
8 she says more than what Gary Aldrich writes
9 in his stupid book.
10 Q Why is that?
11 A Because Gary Aldrich is a
12 pathological liar and Mrs. Clinton isn't?
13 Q Has Mrs. Clinton ever been analyzed
14 as to whether she is or is not?
15 MR. BRAND: Larry, if you don't
16 mind, I would ask you to withdraw the
17 question so we don't go down the same route.
18 BY MR. KLAYMAN:
19 Q Well, what was the basis for your
20 statement that Gary Aldrich is a pathological
21 liar and Mrs. Clinton is not? Is there any
22 medical evident to support either position?
447
1 A I don't know about medical
2 evidence. I think this book is all the
3 evidence I need to show that Gary Aldrich is
4 a pathological liar and I think my six-year
5 relationship with Mrs. Clinton is all the
6 evidence I need to know that she isn't.
7 Q But you never researched anything
8 in particular with regard to Gary Aldrich's
9 book?
10 A I researched the whole book, as you
11 can tell by my markings.
12 Q Is there a file that contains your
13 research as to whether passages in this book
14 are untrue?
15 A Right here?
16 Q That's it? Did you ever ask
17 anybody to research what Gary Aldrich had
18 written?
19 A I think there were some affidavits
20 collected of people who were mentioned in the
21 book where they were disputing what he said.
22 Q Who collected those affidavits?
448
1 A Counsel's office. I talked to
2 people about them.
3 Q Who in the counsel's office?
4 A I don't remember.
5 Q It's pretty important, isn't it,
6 what was written in Gary Aldrich's book?
7 A Not really actually in retrospect.
8 Q Didn't you go on a TV show, I think
9 it was this week as a matter of fact and call
10 Gary Aldrich a pathological liar?
11 A I did.
12 Q Did you research whether what he
13 had written was true before you made that
14 statement on TV?
15 A I read the book.
16 Q That's all you did?
17 A I read the book. I talked to
18 people who were charged with things in the
19 book. Basically, you know, David Brock and
20 George Will did as much damage, if not more
21 damage, to Gary Aldrich's reputation on that
22 show as I did.
449
1 Q Who did you talk about Aldrich's
2 claimed false statements?
3 A Depended on the statement.
4 Q Who in particular? Name anybody.
5 A Oh, probably Doris Matsui. I
6 remember one about Doris Matsui.
7 Q Did you talk to Doris Matsui?
8 A Either to her or her office and she
9 filed some affidavit.
10 Q You can't remember?
11 A Not exactly.
12 Q Did you ever talk to Hillary Rodham
13 Clinton about Gary Aldrich?
14 A No.
15 Q Would you look at me when you
16 answer that question. Did you ever talk to
17 Hillary Rodham Clinton?
18 A Do I have to?
19 Q Yes.
20 A No.
21 MR. BRAND: It's almost 10 of 6.
22 MR. KLAYMAN: Are you ordering the
450
1 deposition closed, Mr. Brand?
2 MR. BRAND: I'm not ordering
3 anything. I told you we stayed for six
4 hours. That's all we can do today.
5 MR. KLAYMAN: Is this all you're
6 doing today?
7 MR. BRAND: Yes.
8 MR. KLAYMAN: Well, let the record
9 reflect that your leaving this deposition on
10 your own volition, that I want to continue
11 and I'm going to leave this deposition open.
12 MS. SHAPIRO: We object to leaving
13 the deposition open and the court's order
14 reflects that only six hours is authorized
15 for this deposition.
16 MR. KLAYMAN: We have not done six
17 hours of testimony.
18 MR. GAFFNEY: I concur with the
19 statements of Ms. Shapiro. I would add also
20 that six hours was far more than enough to
21 get this examination done and we will object
22 to any effort by you to take any further
451
1 testimony.
2 MR. KLAYMAN: Are you taking issue
3 with the court's order, Mr. Gaffney?
4 MR. GAFFNEY: The court's order
5 speaks for itself, Mr. Klayman.
6 MR. KLAYMAN: You think two six
7 hours was too much?
8 MR. GAFFNEY: Mr. Klayman, I'm not
9 here to have a discussion with you on the
10 record. I'm here, to the extent I speak,
11 make objections.
12 MR. KLAYMAN: We have not done six
13 hours testimony and that's our position and
14 our position is the deposition is open.
15 VIDEOGRAPHER: This conclude this
16 video deposition. The time now is
17 approximately 6:51 p.m.
18 (Whereupon, at 6:51 p.m., the
19 deposition of GEORGE STEPHANOPOULOS
20 was adjourned.)
21 * * * * *
22