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

 

 

Goto
Previous Section
of this deposition