101
1 the conversation with Mr. Kendall. What else
2 was discussed?
3 A I don't know. I just called him to
4 ask him about this.
5 Q Let the record reflect Mr. Gaffney
6 just passed a note to Ms. Marsh.
7 MS. MARSH: Yes, he did, and
8 Ms. Marsh took it. You have to put that on
9 the record, too.
10 THE WITNESS: I think the other
11 thing is that --
12 MS. MARSH: Wait till he asks you a
13 question.
14 MR. GAFFNEY: Would you like me to
15 reenact it for the video?
16 MR. KLAYMAN: No, you can reenact
17 it for the court.
18 MS. MARSH: Subject to the
19 objection that we filed regarding a request
20 for calendars that's extremely broad, request
21 number 3. We filed an objection or served on
22 an objection on you in regard to that.
102
1 Subject to that objection, however,
2 Mr. Carville has brought to you today what he
3 has of his calendars and the dates included
4 in the subpoena that have been redacted to
5 take out personal information, and he can
6 produce those as well.
7 MR. KLAYMAN: Is there anything
8 else you're producing today?
9 MS. MARSH: No, that's all.
10 MR. KLAYMAN: I take it there are
11 other documents responsive to our subpoena
12 which are not being produced pursuant to your
13 so-called objection?
14 MS. MARSH: I don't think so. To
15 the subpoena? I don't think so. The
16 objections were made just in case there were
17 supplemental documents that come up later
18 that fall within some of these broad
19 categories, but I don't believe there's
20 anything else. You can ask him through the
21 schedule of documents, if you want to, to
22 see.
103
1 MR. KLAYMAN: Well, we will go
2 through that and come back to this. I'll
3 show you what I'll ask the court reporter to
4 mark as Exhibit 12.
5 (Carville Deposition Exhibit
6 No. 12 was marked for
7 identification.)
8 MS. MARSH: Did you not want him to
9 go through his calendars and sign those at
10 the bottom?
11 MR. KLAYMAN: We will do that at
12 the perfect time.
13 BY MR. KLAYMAN:
14 Q I'll show you what I've asked the
15 court reporter to mark as Exhibit 12. This
16 is a press release of Judicial Watch,
17 "Stephanopolous, Begala and Carville
18 subpoenaed in Filegate." Have you seen that
19 before, Mr. Carville?
20 A I have.
21 Q Where did you get this document?
22 A It was faxed to me by probably -- I
104
1 don't know -- somebody with Mary's show,
2 maybe Ann Clank or Amanda Butler, but I don't
3 know.
4 Q Did you call over there and ask for
5 a copy of this?
6 A No. I think what happened was I
7 didn't think the press release beat the
8 subpoena, or, wait, no, the subpoena --
9 MS. MARSH: Don't guess if you
10 don't know.
11 THE WITNESS: Yeah at 2/23 -- I
12 don't know. You'd have to look and see when
13 the dates were, but you faxed it to them and
14 they faxed it to me.
15 Q My question was did you call over
16 there and ask them did you get any press
17 releases from Judicial Watch?
18 A No.
19 Q They faxed it to you on their own?
20 A Right.
21 Q That's Mary's show?
22 A Right.
105
1 Q Mary told her worker to send it to
2 you?
3 MS. MARSH: Objection.
4 THE WITNESS: I have no idea.
5 Q You sent a copy of this to Begala?
6 A I did.
7 Q Did you call Begala before you sent
8 it?
9 A I don't know. I don't know if I --
10 maybe I was out of town. If you give me my
11 calendar I'll see where I was on 2/23. Maybe
12 someone at the office did. Why don't you
13 hand me my calendars and I can tell you where
14 I was and if I was in town it's likely I did.
15 If I'm not it's likely somebody in the office
16 did. I don't have a memory as to when it
17 came over.
18 Q And you faxed it the same day to
19 Begala?
20 A It looks like it came in at 9:57
21 and then there's a fax at 11 -- I can't read
22 it. The two dates on the fax seem to be the
106
1 23rd of February.
2 Q And after it was sent to Begala he
3 called you?
4 A I don't know. I got to find out
5 where -- if you let me see my calendar and
6 see where I was. I don't know if I sent it.
7 I don't know if I did or somebody else did.
8 Q Mr. Bustion, stand there with him
9 while he looks through that, if you would.
10 A I was at the Sperling -- no, wait.
11 the 23rd. That was a Monday. In all
12 likelihood I did fax it because I was in
13 Washington on that day.
14 Q You faxed it to Begala?
15 A I don't know.
16 MS. MARSH: Don't guess.
17 MR. GAFFNEY: Mr. Klayman, again, I
18 object to you questioning the witness about
19 something you haven't provided to the rest of
20 counsel.
21 THE WITNESS: Let me just say this,
22 Mr. Klayman, I didn't put it in -- I don't
107
1 even know how to work the fax machine but it
2 may have come over and somebody said look at
3 this and I said okay well fax it to Paul. It
4 would seem to me -- I can't tell you to a
5 certainty that would happen but that would be
6 logical, or somebody came and said look at
7 this, do you want me to fax it to Paul.
8 Q And you talked to Paul about this
9 press release after you faxed it to him,
10 didn't you?
11 A I'm sure I did. I don't have a
12 memory of the conversation.
13 Q And you told him you'd faxed it to
14 him, correct?
15 A I tell you I don't even remember
16 what -- either somebody handed it to me. I
17 don't -- I don't know the sequence of events
18 is the truth, but my office faxed it to him,
19 probably at my direction, and I'm sure that I
20 spoke to him about it. It would be highly
21 unusually irregular if I did not.
22 Q And he expressed to you his
108
1 knowledge that he got the fax from you,
2 correct?
3 MS. MARSH: Do you remember?
4 THE WITNESS: I don't remember.
5 I'm sure he did. It just would be hard for
6 me to imagine a situation where somebody got
7 a fax that you were going to be subpoenaed
8 and you didn't fax it to the guy.
9 BY MR. KLAYMAN:
10 Q Mr. Carville --
11 MR. KLAYMAN: Mr. Bustion, would
12 you gather up the exhibits we've marked so
13 far?
14 MS. MARSH: You're not going to ask
15 him anything else about these exhibits?
16 MR. KLAYMAN: I may.
17 MS. MARSH: I'd like them left in
18 front of him if you're going to refer to
19 them.
20 MR. KLAYMAN: No, I'm not referring
21 to those right now.
22 BY MR. KLAYMAN:
109
1 Q Where did you go to college?
2 A Louisiana State.
3 Q And what year did you graduate?
4 A '70 from undergraduate and '73 from
5 law school.
6 Q Did you go to any kind of
7 postgraduate education after that?
8 MS. MARSH: After law school?
9 THE WITNESS: No, just law school.
10 BY MR. KLAYMAN:
11 Q Did you just state where you went
12 to undergraduate?
13 A Louisiana State, got my
14 undergraduate degree in '70 and my law degree
15 in '73.
16 Q Did you take any time off in
17 between?
18 A Well, I can explain to you what
19 happened is I got invited to leave in May of
20 1966. I joined the Marine Corps, spent two
21 years in the Marines, and then came back in
22 '68 and started school and started back in
110
1 June, summer school of '68, and sort of
2 worked and I taught school the year '69 and
3 then graduated in undergraduate school in May
4 of '70, and started law school must have been
5 in September of 1970 or August or whenever
6 they started. I don't remember.
7 Q Were you ever convicted of a crime
8 up to today?
9 MS. MARSH: Objection as to
10 relevance.
11 THE WITNESS: A crime? You know,
12 traffic ticket.
13 BY MR. KLAYMAN:
14 Q Anything other than that?
15 MS. MARSH: Objection.
16 THE WITNESS: No.
17 BY MR. KLAYMAN:
18 Q Have you ever gone by the name
19 Chester?
20 A Sure.
21 Q Are there any police files with the
22 name Chester on it where you're referred to?
111
1 A I don't know.
2 Q Are there any police files where
3 your name has been excised from it?
4 MS. MARSH: Objection as to
5 relevance.
6 BY MR. KLAYMAN:
7 Q That you know of?
8 A None that I know of.
9 Q Down in Louisiana?
10 MS. MARSH: Objection.
11 THE WITNESS: I don't know but
12 there may be. I can't tell you that there's
13 not. Yeah, that I know. I'm 53 years old.
14 Q Have you ever served in the
15 military?
16 A Two years in the Marines.
17 Q Did you serve your complete tour?
18 A Mm-hmm.
19 Q You didn't leave early?
20 A You know what? I was arrested one
21 time. Let me back up. I was arrested in
22 Tijuana when I was in the Marines.
112
1 Q What were you arrested for?
2 A Fighting, but what happened was
3 there were three of us in a bar and we didn't
4 have $20 and we gave the bartender $20 and he
5 didn't give us change and he said he didn't
6 speak English and one of the guys reached
7 over to give him an English lesson and by
8 that time the thing broke out and the Tijuana
9 police came and locked us up.
10 Q Were you convicted of a crime?
11 A I can tell you what happened is
12 they notified the base. Somebody goes and
13 they notify the base and some friends of ours
14 came down to Tijuana with the bail money and
15 then we had to go back -- you know, they sent
16 us back to Camp Pendleton and the commanding
17 officer said that we'd had good records and
18 we didn't even get an Article 15, which is
19 commanding office nonjudicial punishment, but
20 I was arrested in Tijuana. That's the only
21 time to my knowledge I've been arrested.
22 Q Have you been barred from Mexico
113
1 from ever coming back?
2 A No.
3 MS. MARSH: Objection as to
4 relevance.
5 THE WITNESS: I doubt if the record
6 keeping there was -- 1967 or '68 in Tijuana
7 was -- in terms of the name Chester, I was
8 born Chester James Carville Junior, and my
9 father died in 1978 and it was like -- my
10 mother always wanted me to be called James
11 and it was kind of like C. James Carville
12 Junior, and I'm just not an initial and a
13 name kind of guy and just became James
14 Carville. I'm very proud of my name.
15 Q You had to leave the military
16 early, did you not?
17 A No.
18 Q Involuntarily, did you not?
19 A No. No, of course not.
20 MS. MARSH: Objection as to
21 relevance.
22 THE WITNESS: I had an honorable
114
1 discharge. Went back to Camp Pendleton and
2 went to boot camp graduation during the
3 Republican National Convention.
4 BY MR. KLAYMAN:
5 Q When did you first have anything to
6 do with politics?
7 A My grandfather was on the police
8 jury in Louisiana, so I guess when I was a
9 little bitty boy I, you know, probably sort
10 of go around with him and door knock and
11 everything and the first campaign I ever
12 worked on was a man named D. Price LeBlanc.
13 They called him the trading country boy. And
14 he ran for the legislature against a man
15 named Boise ����, and I guess I was 15.
16 Maybe I was a little bit -- somewhere around
17 there. It was 1959. I was born in '44,
18 probably just turned 15. And I would go
19 around and tear signs down for him or
20 something, put signs up, take signs up, that
21 kind of foolishness.
22 Q Louisiana in terms of politics
115
1 based on your considerable experience, which
2 we'll get into, is a pretty corrupt state,
3 isn't it?
4 MS. MARSH: Objection as to
5 relevance and also whether he's an expert on
6 Louisiana politics.
7 BY MR. KLAYMAN:
8 Q Based on your experience?
9 A I love my home state. I would
10 prefer to use the word "colorful" as opposed
11 to corrupt.
12 Q Why can't we use the word
13 "corrupt"?
14 MS. MARSH: Objection.
15 THE WITNESS: I'll say the politics
16 in Louisiana are colorful. I would rather
17 not compare it to other places that I hadn't
18 been.
19 BY MR. KLAYMAN:
20 Q Tell me what was the first campaign
21 you ever worked on as an adult.
22 A Probably for a man named ���� Brown
116
1 when I was in law school. You mean worked
2 on, like, ran for district attorney in Baton
3 Rouge, and, I mean, you know, like, when I
4 was in law school I was -- you know, we'd
5 have, like -- when I was in college I was in
6 the Young Democrats, and I guess we worked on
7 the '64. That would probably be the more --
8 '64 Presidential race. I wasn't paid
9 anything, but, you know, it was sort of a --
10 we'd pass out stuff.
11 Q And what did you do?
12 A Not much. Free Speech Alley at LSU
13 and we'd go out and argue with the
14 Republicans and that kind of stuff. I doubt
15 if we affected a vote.
16 Q What was the next campaign you
17 worked on?
18 A Well, I'm trying to catalog my life
19 here to '64. I went in the marines on '66, I
20 didn't work on any campaigns then. I got out
21 in '68. I didn't do anything in the '72
22 presidential -- probably '73 East Baton Rouge
117
1 parish district attorney. I worked for a man
2 named ���� Brown.
3 Q And in the course of that campaign
4 was there an opponent to Mr. ���� Brown?
5 A Mm-hmm, good friend of mine.
6 Q What's his name?
7 A His name is Frank Foile. He is a
8 judge. I think he is still is a judge in
9 East Baton Rouge parish. I know he was.
10 Q And during that campaign the guy
11 you worked for, ���� Brown did some research
12 on his opponent. That's pretty normal, isn't
13 it, in a campaign?
14 A I'm sure he did. I was a law
15 student. I doubt if I was -- you know, for
16 sure.
17 Q Now, what was the next campaign you
18 worked on?
19 A '73, worked for a man named Jerry
20 ����. When I got out of law school I went to
21 a firm called ���� ���� ���� & ����. And the
22 ���� of the law firm ran for the Public
118
1 Service Commission in Louisiana, which I
2 think there are only like three or five. It
3 was a pretty powerful job in Louisiana.
4 Q And you did some opposition
5 research on that campaign?
6 A I doubt if we did very much because
7 we got our clocks cleaned. Whatever it was,
8 it was woefully inadequate.
9 Q Tell me in those days how
10 opposition research was done based on your
11 experience.
12 A I was more of a put up the signs,
13 drive the candidate around kind of guy. We
14 didn't do very much then. The whole research
15 apparatus was not anything like it is today
16 on the Clinton campaign.
17 Q What was the next campaign you
18 worked on?
19 A 1974. Probably Billy ����, who ran
20 for an open congressional seat in the Third
21 District of Louisiana in 1979.
22 Q What was your role in that
119
1 campaign?
2 A I worked for the media firm that
3 was doing the spots.
4 Q And who was that?
5 A It was a firm in Baton Rouge called
6 ���� & ����.
7 Q And what did you do for them?
8 A Help put together spots, go down
9 and do the meetings and, you know, was kind
10 of -- you know, it had kind of moved up from
11 just sort of being a Gopher to helping the
12 campaign help produce spots, that kind of
13 stuff. We did the -- you ever see those old
14 weather vane spots we used to get in the
15 studio, had a gushing wind. We run against a
16 guy named Jim Diamond, and I'd sit under the
17 table and we had this kind of weather vane
18 thing. One day he says this the next day he
19 says this. I've done a thousand of those.
20 Q Did you do some opposition research
21 in that campaign?
22 A Oh, yeah.
120
1 Q How did you collect it?
2 A I don't remember. He was in the
3 legislature. I'm sure we went and looked at
4 his votes and said that he was whatever. The
5 biggest negative he had was he was from the
6 New Orleans area and our guy was not, and it
7 was, you know, back then the people from New
8 Orleans vote for people in the New Orleans
9 area and the people out in the country --
10 it's not quite like that any more.
11 Q In those days --
12 MS. MARSH: If we're going to talk
13 about opposition research can we get a
14 definition that we all agree on?
15 BY MR. KLAYMAN:
16 Q Get information about the opponent?
17 That's opposition research, right?
18 A Yeah.
19 Q And to get information you get it
20 wherever you can get it, right?
21 A No. I mean, I never have gone
22 through anybody's trash or followed anybody
121
1 around or anything like that -- no, I did. I
2 followed a guy around one time. Pete Dawkins
3 because he did a thing and we heard that he
4 was going to go to Winston-Salem for a
5 fund-raiser and I told the guys, I said I
6 betcha he's going on an RJR jet. And so I
7 sent somebody out to the Trenton airport and
8 sure enough he got on an RJR jet.
9 Q You have hired people to follow
10 people, haven't you, in the course of
11 campaigns?
12 A No, sir.
13 Q And you have hired people or worked
14 with people to dig up information wherever
15 you could, correct?
16 A No, sir. I have hired people --
17 I've certainly hired people to "dig up
18 information." I have not "hired people to
19 dig up information wherever they could."
20 Q You told people specifically where
21 to go look for information or you just said
22 get me some information about this?
122
1 A No, it depends on the level of
2 sophistication of the people that you have.
3 Sometimes starting out in campaigns you'd
4 have to say, you know, he was on the City
5 Council. Go see what his attendance record
6 was, you know what I mean, get the sort of
7 campaign contributions things, look at the
8 votes, depending on what the background of
9 the candidate was.
10 Q Get information from people that
11 knew the candidate?
12 MS. MARSH: What are you asking
13 him? Did he ever do that?
14 BY MR. KLAYMAN:
15 Q I'll ask you if you've ever done
16 that. Surely you have, haven't you? Or
17 people that have worked with you? You'd be
18 crazy not to?
19 MS. MARSH: One question at a time.
20 THE WITNESS: I can't tell you that
21 I never did it but we generally don't -- to
22 my knowledge, this is just not sort of a
123
1 technique that we use as go and kind of
2 interview neighbors or something like that.
3 I can't tell you it didn't happen on a
4 campaign that I worked on. Sometimes
5 campaigns are big things and things happen
6 that you don't know about.
7 BY MR. KLAYMAN:
8 Q Sometimes on the campaigns you've
9 worked on you've hired people to look into
10 court records or hire peopled to talk to
11 people?
12 A I've hired people to look at court
13 records, I'm sure.
14 Q But you hired people to get
15 information about a particular subject,
16 right?
17 A Sure.
18 Q I was watching one of your film
19 debuts yesterday, War Room. Did you see that
20 one?
21 A Oh, yeah.
22 Q Almost won an academy award for
124
1 that one, right?
2 A Good movie.
3 Q There's a scene in there where
4 you're talking about allegations that George
5 Bush's campaign had purchased printing
6 presses from Brazil, right?
7 A Right.
8 Q Now, you hired somebody to look
9 around and try to find that, didn't you?
10 A No. That's not true. Somebody
11 called us -- I forgot but it was somebody
12 down in Brazil said they saw it or somebody
13 said you're not going to believe this, and,
14 you know, then I called the press and said
15 whatever and they sort of went back and forth
16 but, no, I didn't hire anybody to do that.
17 Q You have been involved in campaigns
18 where the other campaign has spread what
19 you've considered to be false information?
20 A I'm sure. Everybody in every
21 campaign I've ever worked in always thinks
22 the other side spreads false information.
125
1 Q In fact, during that movie you made
2 several statements that in your view Roger
3 Ailes was spreading false information about
4 the Clinton campaign didn't you?
5 MS. MARSH: Objection as to
6 relevance.
7 THE WITNESS: I don't remember what
8 it is -- Roger wasn't even doing the TV in
9 1992, was he? I don't think he was working
10 for Bush.
11 BY MR. KLAYMAN:
12 Q You tell me.
13 A That's the best I can remember. He
14 didn't work the '92 campaign.
15 Q In fact, you made several
16 statements in that movie, didn't you?
17 MS. MARSH: Objection to relevance.
18 THE WITNESS: Tell me what the
19 statement is. I don't remember every
20 statement I made in the movie -- you know
21 what it was? You're talking about the thing
22 where they said they're going to come and
126
1 they're going to say this, the deal in New
2 Hampshire and I said something about George
3 F. ����, who happened to show up at my
4 wedding, which was kind of embarrassing.
5 Q And you basically said that Ailes
6 was going to come up there and spread false
7 information?
8 A Right.
9 Q That sometimes happens in
10 campaigns, doesn't it, in your view?
11 A Yeah.
12 Q And in fact to be prepared you got
13 to be prepared to fight back, don't you?
14 That's why you had the war room?
15 MS. MARSH: Objection as to
16 relevance, also as to vagueness.
17 BY MR. KLAYMAN:
18 Q Right?
19 A Yeah.
20 Q And the way you fight back is by
21 spreading false information about your
22 opponent, correct?
127
1 A I'd like to think that we spread
2 accurate information but, you know --
3 Q Sometimes it happens?
4 MS. MARSH: You mean generally on
5 any campaign or on what he's been on.
6 MR. KLAYMAN: He can respond.
7 MS. MARSH: You've got to clarify.
8 Any campaign?
9 THE WITNESS: As I understand the
10 question, sometimes in campaigns false
11 information gets spread. Is that the
12 question? Yeah.
13 BY MR. KLAYMAN:
14 Q And sometimes you've been
15 associated with campaigns that have spread
16 false information?
17 A You have to give me an example what
18 you're talking about and I could respond to
19 it, but people have said the information that
20 we've spread is false but we didn't think it
21 was -- I don't know of a time where I spread
22 information that I knew it was false, but,
128
1 no, there's not a -- you know,
2 interpretations of different things. Okay?
3 Somebody would say that you voted against --
4 I mean, there are a lot of these things. You
5 vote against nutrition programs. It might be
6 part of a larger budget or budget
7 reconciliation act, et cetera. A lot of this
8 stuff is just not -- you know, is not clear.
9 It's not just totally clear. I don't know of
10 any situation that it was -- you know, that
11 I've spread anything that I knew was false.
12 Q Sometimes things happen so fast you
13 don't worry whether it's true or correct?
14 A No. I'll tell you what I've found,
15 Mr. Klayman, and we have said this for a long
16 time is we actually like the more aggressive
17 coverage of campaigns and the truth boxes, et
18 cetera, et cetera because we think it forces
19 the discipline in campaigns that tend to have
20 better research do better, but, I mean,
21 that's not to say we haven't been -- you
22 know, you don't get criticized. A political
129
1 campaign, people make charges, charges go
2 back and forth, et cetera, et cetera. That's
3 the nature of what happens in political
4 campaigns.
5 Q And sometimes false information
6 gets out, correct?
7 A Again --
8 MS. MARSH: Objection as to
9 relevance.
10 BY MR. KLAYMAN:
11 Q Let me give you an example.
12 A All right, go ahead.
13 Q Jennifer Flowers, that's an
14 example, isn't it?
15 MS. MARSH: Of what.
16 BY MR. KLAYMAN:
17 Q False information that your
18 campaign disseminated that the governor
19 didn't have an affair with her?
20 A I don't think he did.
21 Q Your idea of an affair is only if
22 you have sex more than once?
130
1 MS. MARSH: Objection as to
2 relevance. What's the relevance of this of
3 what his idea of a love affair is? What's
4 the relevance of that to the case about the
5 FBI.
6 MR. KLAYMAN: I'm getting the way
7 he functions.
8 MS. MARSH: Regarding sex? What
9 does that have to do with FBI filegate?
10 MR. KLAYMAN: His truthfulness and
11 veracity.
12 THE WITNESS: I understand from an
13 article in Time magazine is that he said that
14 they groped one time in 1977. Groping does
15 not fit my definition of sex but maybe it
16 fits somebody else's.
17 BY MR. KLAYMAN:
18 Q You've seen his deposition
19 recently, haven't you?
20 A I have not seen his deposition but
21 I saw an account of it on the web site at
22 Time magazine where they said for purposes of
131
1 sex it shall be defined -- and I'll give you
2 the exact thing, the touching of such and
3 such area and such and such area. You know,
4 in the buttocks and they said did you have
5 ever have sex with Jennifer Flowers and from
6 what I'm told the President said yes, I was
7 in a nightclub in Little Rock in 1977 that
8 they were groping. I don't call that sex but
9 I'll defer if somebody else has a different
10 opinion what it is but that's what I was told
11 was in there.
12 Q You did make statements, did you
13 not, during the presidential campaign in 1992
14 that Governor Clinton did not have an affair
15 or sex with Jennifer Flowers, correct?
16 MS. MARSH: Objection as to
17 relevance.
18 THE WITNESS: I did. I still
19 believe that. But I think I put it in my
20 book that I didn't think.
21 Q Now, if you were to see
22 Mr. Clinton's deposition and it now says that
132
1 he had sex one time, would you want to make a
2 public statement saying I didn't mean to
3 mislead lead the people at that time?
4 MS. MARSH: Objection. I want to
5 object to the question as no relevance to the
6 matters that are at issue in this case. It's
7 extremely hypothetical and suppositional.
8 It's asking if he sees a deposition and it
9 says certain things. No one knows what's in
10 that deposition. I haven't seen it.
11 BY MR. KLAYMAN:
12 Q What did you do to check out that
13 that was true, that there was never an affair
14 and there was never sex during 1992?
15 MS. MARSH: Objection as for
16 relevance.
17 MR. KLAYMAN: You can respond.
18 THE WITNESS: Just used my common
19 sense. If somebody edits -- you know, if
20 I've got newspaper reports that he didn't
21 even recognize the voice on the telephone and
22 there's something like supposedly 12 edits in
133
1 this so-called tape and that's what he said,
2 I don't think that he did. That's all I can
3 tell you. I didn't do any -- how would I
4 know?
5 BY MR. KLAYMAN:
6 Q Now, during the campaign, you call
7 kept a file on Jennifer Flowers, didn't you?
8 MS. MARSH: Objection as to
9 relevance and who's "y'all"?
10 Q The campaign. I figured
11 Mr. Carville would understand that. You know
12 what y'all means?
13 MS. MARSH: It could mean the
14 campaign. It could mean Mr. Carville.
15 BY MR. KLAYMAN:
16 Q The campaign.
17 A I'm sure that we had -- I'm sure
18 that there must have been. I don't have -- I
19 don't know if I saw the file.
20 MS. MARSH: Don't guess.
21 THE WITNESS: I don't know, but I'm
22 sure I would expect that we did.
134
1 BY MR. KLAYMAN:
2 Q And you had people out there doing
3 research about Jennifer Flowers, didn't you?
4 MS. MARSH: Objection as to
5 relevance.
6 THE WITNESS: Not me. I'm not
7 telling you there wasn't but I'm telling you
8 I didn't --
9 BY MR. KLAYMAN:
10 Q Did Betsy Wright play a role in
11 doing research on Jennifer Flowers?
12 MS. MARSH: Objection as to
13 relevance.
14 THE WITNESS: I knew about that
15 when I read it in the paper, and if the
16 article in the paper's accurate then they
17 did.
18 BY MR. KLAYMAN:
19 Q You didn't know about that?
20 A No, sir.
21 Q Now, you were director of that
22 campaign?
135
1 A No.
2 Q What was your title?
3 A Hold on just a second. I did not
4 become -- what I did is, whatever you call
5 it, I ran the war room. I did not assume
6 that position until late June of --
7 Q What position?
8 A The war room or whatever you wanted
9 to call it. I did the communications
10 research, that thing. Okay? Between the
11 time I went to work for Governor Clinton
12 December 1 and then I was on the road
13 doing -- you know, doing shows and stuff like
14 that. I never -- I could tell you that I
15 don't know -- I didn't know anybody. I don't
16 even know if I actually know a private
17 investigator, to tell you the truth, but at
18 any rate I didn't know anything about this
19 till I read it in the paper and I can't
20 remember when I did.
21 Q What was your official title at
22 various stages of the 1992 Clinton campaign?
136
1 A Consultant to the Clinton campaign?
2 BY MR. KLAYMAN:
3 Q You were widely regarded as the
4 number one guy for campaign strategy, right?
5 MS. MARSH: Objection.
6 THE WITNESS: No, I wouldn't
7 characterize it that way. I certainly was
8 one of the senior people in the campaign,
9 particularly after late June of 1992.
10 BY MR. KLAYMAN:
11 Q And it would have been your job to
12 know if there are private investigators out
13 there on Jennifer Flowers, correct?
14 MS. MARSH: Objection as to
15 relevance.
16 THE WITNESS: No. I mean, by the
17 time I took over Jennifer Flowers was so far
18 gone -- let me explain to you. When I
19 assumed the more senior position in the
20 campaign it was June and nobody was talking
21 about Jennifer Flowers any more. We had
22 whole other fish to fry here.
137
1 Q They were talking about bimbos
2 generally, weren't they?
3 MS. MARSH: Objection as to
4 relevance.
5 THE WITNESS: You'd have to ask
6 Miss Wright.
7 BY MR. KLAYMAN:
8 Q There was more than one woman who
9 was of concern to the campaign, was there
10 not?
11 MS. MARSH: Objection as to
12 relevance.
13 THE WITNESS: You'd have to ask
14 Ms. Wright?
15 BY MR. KLAYMAN:
16 Q You knew it was a concern that
17 there were women potentially out there and
18 could embarrass Governor Clinton during the
19 '92 campaign, correct?
20 MS. MARSH: Objection as to
21 relevance. Don't guess.
22 THE WITNESS: I certainly knew
138
1 about Jennifer Flowers. When she came out it
2 was hardly a secret. I did not -- I was
3 not -- this is not something that I dealt
4 with in terms of -- I didn't know anything
5 about these so-called private investigators
6 until -- I guess I read about it in the
7 newspaper.
8 BY MR. KLAYMAN:
9 Q Mr. Carville, are they giving you
10 too much credit for being in control of the
11 campaign?
12 MS. MARSH: Objection.
13 Argumentative.
14 BY MR. KLAYMAN:
15 Q The media?
16 MS. MARSH: Objection.
17 THE WITNESS: I don't know. I
18 certainly wasn't in control of what Betsy
19 Wright did in terms of that. I think I had
20 other responsibilities.
21 MS. GILES: I object to this whole
22 line of inquiry as having no conceivable
139
1 relevance to the FBI files that are subject
2 matter of this litigation.
3 BY MR. KLAYMAN:
4 Q You ever heard of Little Rock
5 lawyer by the name of Samuel Jones?
6 A No.
7 Q Wright Lindsey & Jennings?
8 A No.
9 Q That law firm?
10 A If it's Bruce Lindsey's law firm, I
11 guess I would --
12 Q Do you meet Sam Jones from that law
13 firm?
14 A Not to my knowledge, no.
15 MR. KLAYMAN: Let's take a little
16 break, resume in a few minutes.
17 VIDEOGRAPHER: Going off video
18 record at 12:12.
19 (Recess)
20 VIDEOGRAPHER: We're back on video
21 record at 12:19.
22 BY MR. KLAYMAN:
140
1 Q Just let the record reflect we've
2 gone two hours at this point because we broke
3 at 12:15.
4 Mr. Carville, it isn't your
5 practice, is it not, to keep files on
6 individuals who may be a threat to a
7 candidate?
8 A Illuminate me a little bit.
9 Q Well, like Jennifer Flowers.
10 A You know, Mr. Klayman, again, if
11 you're -- I don't ever recall seeing a "file"
12 on Jennifer Flowers.
13 Q I understand what your testimony
14 was but I'm asking you, and it's different
15 than what I just asked --
16 MS. MARSH: Mr. Klayman, we don't
17 need those remarks.
18 BY MR. KLAYMAN:
19 Q Now that I've highlighted the issue
20 but I'm asking whether it has happened in the
21 course of campaigns that you've kept files on
22 individuals that have had unkind things to
141
1 say about your candidate. Surely that must
2 have happened?
3 A I mean, we keep a wealth of
4 material. If we're running -- I mean, give
5 me an example. Look, if I'm running a race
6 and it's against an incumbent --
7 Q Let's take the '92 campaign. You
8 had a file on governor Jerry Brown, didn't
9 you?
10 MS. MARSH: Objection as to
11 relevance.
12 THE WITNESS: Yeah, I doubt it. I
13 mean, I'm sure that we had -- somebody did --
14 you know, he was for the flat tax. You know,
15 what was the impact of the flat tax, et
16 cetera, et cetera, but there was no -- you
17 keep using this world, you know, file or
18 something. We certainly have research.
19 Q And you put it in one place,
20 generally don't you?
21 A Yeah, hopefully.
22 Q And you put that in a file, right?
142
1 Isn't that normal?
2 A Well, it's usually in a -- you
3 know, probably like a looseleaf binder but
4 sometimes -- now they put them in manila --
5 most of these kids use computers. Most of
6 it's in a computer, to tell you the truth.
7 Probably wasn't like that when I first
8 started but now they just sit there and --
9 Q People you work with now use
10 computers?
11 A Yeah.
12 Q What they have is computer files
13 where they have the information on candidate
14 one area or an opponent or somebody has
15 something to say?
16 A I expect they do. Like I say, I
17 can't operate a computer, so I couldn't tell
18 you what's in one.
19 Q During the 1929 campaign you had
20 those kinds of organized files or looseleaf
21 binders, whatever you want to call them?
22 A I think it was all in computer and
143
1 if I was -- you know, most of the time they
2 just -- you know, I didn't see the files like
3 that. It was mostly all sort of computer
4 stuff. I'm sure we had clip files and that
5 kind of thing. I know they had clips but
6 again with Lexis, Nexis, you don't have the
7 same -- when I started, you don't have the
8 same kind of clips and sort of
9 cross-references, et cetera, et cetera, today
10 that you did even in 19 -- you know, in the
11 mid-80s because -- I don't know how they do
12 it but they punch in the stuff and it sort of
13 punches out.
14 Q Is there somebody in your office
15 now who knows how to punch stuff in and punch
16 it out on a computer?
17 A Kevin, and I think Todd knows.
18 Q So he keeps computer files?
19 A Yeah. We look through them.
20 Q Who's "we"?
21 A Kevin and I. I sat right there and
22 said let's look through the file, everything
144
1 in the subpoena. I sure did.
2 Q During 1992 the campaign had a file
3 on ���� Browning, didn't they?
4 MS. MARSH: Objection as to
5 relevance.
6 THE WITNESS: I have no idea who
7 she is.
8 BY MR. KLAYMAN:
9 Q Would it refresh your recollection
10 if it's been reported she's one of the people
11 that the President has had a sexual
12 relationship with?
13 A May be, but it don't refresh my
14 recollection. First time I've heard of it?
15 BY MR. KLAYMAN:
16 Q Mary Jo Jenkins?
17 MS. MARSH: Objection.
18 THE WITNESS: (Shaking head)
19 BY MR. KLAYMAN:
20 Q You all had a file for her?
21 A If I never heard of her how can I
22 tell you we had a file on her or not?
145
1 Q Beth Colson?
2 MS. MARSH: Objection.
3 THE WITNESS: Never heard of her.
4 I heard of -- no. Give me the names again.
5 BY MR. KLAYMAN:
6 Q Beth Colson?
7 A No.
8 Q Mary Joe Jenkins?
9 A No.
10 Q Dolly Kyle Browning?
11 A No.
12 Q Just so we're clear and then we'll
13 move on, are you telling me that the
14 statements being made by various media
15 organizations and others that then governor
16 Clinton had had affairs or had sexual
17 relations with a number of women weren't of
18 concern to you, James Carville, in terms of
19 your duties and responsibilities as head of
20 the war room in the Clinton campaign in 1992?
21 MS. MARSH: Objection as to
22 relevance.
146
1 THE WITNESS: I wouldn't say it
2 wasn't a concern. It just wasn't -- Betsy
3 did that part of the campaign. That was the
4 thing that she dealt with, and that kind of
5 information, I mean, is just something that I
6 would not -- that I was sort of involved in.
7 We were doing other things and it wasn't --
8 by the time that the war room probably got up
9 and running right after the Democratic
10 national convention and by that time it was
11 not that big of a concern, frankly. It was
12 earlier in the campaign.
13 BY MR. KLAYMAN:
14 Q I take it you and Begala took jobs
15 as consultants with the campaign?
16 A Right.
17 Q When was that?
18 A December 1, 1991.
19 Q And what were your duties and
20 responsibilities from that point forward up
21 to the point that you became head of the war
22 room?
147
1 A It varied. Certainly in New
2 Hampshire we were all up there and traveled
3 with the candidate and after New Hampshire I
4 went to Georgia to help with the Georgia
5 primary, and I can't remember --
6 sequentially, I think South Carolina came a
7 little before that and Georgia was a part of
8 Super Tuesday, but I remember after the New
9 Hampshire primary I went down to Georgia.
10 And then from there ended up in
11 Illinois, I think, and ���� was running
12 the -- we had people from different states.
13 ���� was sort of running the Illinois
14 primary. We were up there helping. And then
15 from there, I think we moved on to New York,
16 and then --
17 Q I'm not asking where you moved on.
18 But what were your duties --
19 A I was trying to help get a state
20 organized and working with the people seeing
21 about getting a media buy. You know what I
22 mean? Who was going to be for us? Who was
148
1 going to be against us? Scheduling. I
2 remember trying to get what ed boards you go
3 to, that kind of thing and by that time -- by
4 the time that we had -- by the time of the
5 New York primary was over, what happened was
6 is that we went to -- if you read my book and
7 I'm just trying to be as accurate as I can on
8 the dates -- sometime in early May, remember,
9 Jerry Brown was still running, and Stan
10 Greenburg and I and maybe it was Manny
11 Grunwald, I'm not sure, went to see -- talked
12 to Mickey Cantor, said, look, in all
13 likelihood we're going to win this nomination
14 but we want to work on something and we
15 called it the Manhattan Project, which
16 related to how to improve voter attitudes
17 toward the President. And we did a lot of
18 research, focus policies, et cetera, et
19 cetera and because of the primary process at
20 that time, we were not doing that well in the
21 general election, but, if you read my book, I
22 would trust my memory more to the exactitude
149
1 of that in All's Fair when it was a lot fresh
2 in my memory.
3 Q The name of the book is All's Fair?
4 A Right.
5 Q Now, but up to the point, like,
6 from New Hampshire onward, your job was to be
7 among other things one of the spinners that
8 would be able to communicate with the media
9 about the governor, right?
10 MS. MARSH: Objection as to
11 relevance and as to the term "spinners."
12 BY MR. KLAYMAN:
13 Q Your job was to be in charge of
14 what was being disseminated?
15 A You know, we went from sort of
16 primary to primary and some primaries I was
17 more involved than other primaries. I was
18 more involved in the Georgia primary than I
19 was in the Florida primary. I was more
20 involved in the New York primary than I was
21 in the Connecticut primary. It's just a hard
22 thing to characterize it as sort of one thing
150
1 because it changed as the campaign went on.
2 Q You certainly had to know, in terms
3 of your communications with the media, about
4 the problems that the governor was claimed to
5 have had with women, correct?
6 MS. MARSH: Objection as to
7 relevance.
8 THE WITNESS: Well, I certainly
9 knew about Jennifer Flowers.
10 BY MR. KLAYMAN:
11 Q Who did Betsy Wright report to in
12 the campaign?
13 A The governor.
14 Q She also reported to you, did she
15 not?
16 A On the Arkansas record stuff. She
17 did not report to me on anything to do with
18 women, but, yes, on what was the unemployment
19 rate, what was the such and, you know what I
20 mean? If they say what happened -- remember,
21 the great 124 tax increase brouhaha, yes.
22 Yes, she definitely did report to me on that,