301
1 BY MR. KLAYMAN:
2 Q And you were worried that when
3 Stephanopoulos used the word "White House
4 allies," people would think you were
5 involved?
6 A I don't think anyone -- I never
7 thought anybody would think I was involved in
8 anything like that, particularly anybody that
9 knows me or talks to me.
10 Q But you didn't want anybody to even
11 have the suggestion, didn't you?
12 You can respond.
13 A Mr. Klayman, I wouldn't want
14 anybody -- if I thought that somebody was
15 using information on the FBI files, okay, I
16 would bolt so fast it would be like
17 lightning. Okay?
18 Q And why is that?
19 A Because it's -- those things are --
20 that is not their sort of intended use. God
21 knows what, you know, might be in there, what
22 might be checked or unchecked. And I said on
302
1 TV when this story broke that I thought it
2 was a serious thing that needed to be looked
3 at.
4 Q The Filegate story?
5 A I sure did. Yes, sir.
6 Q Back in 1996?
7 A Yes, sir. I'd be glad -- if you
8 have your people, you can look, and I
9 distinctly remember saying that.
10 Q Because you recognized that the use
11 of FBI files is a serious crime, correct?
12 A Well, I probably knew it was a
13 crime, but it's just not something that I
14 would take sort of lightly.
15 Q Not something that's done in a
16 civilized democratic society, correct?
17 MS. MARSH: Objection. Ask him a
18 real question.
19 THE WITNESS: No.
20 BY MR. KLAYMAN:
21 Q Your opinion.
22 A No. Look, I've made my opinion
303
1 known. I've made it publicly known that I
2 thought this was serious. And if it is, then
3 I guess it is. They've been investigating
4 it. And if it was an administrative glitch,
5 and one of the things that's always impressed
6 me -- one of the reasons I believe it very
7 likely was an administrative glitch is, no
8 one was leaking information about it or
9 something.
10 But I have no idea. I don't know
11 what happened.
12 Q I wasn't talking about Filegate per
13 se. I was talking about the use of FBI
14 files.
15 If there was the use of FBI files
16 in any administration, Republican or
17 Democrat, that would be a serious thing?
18 A Wait a minute. Hold on. Hold on.
19 If, like, people get a security
20 clearance. Okay? They probably have. I'm
21 not an expert on this. But there probably is
22 a legitimate use of a file like this in a
304
1 democracy like ours. But it sure is not a
2 political use of a file like this to go after
3 your political opponents. But I would
4 concede that there's some -- I don't know
5 what it is, but I'm sure that there's some
6 use to it.
7 Q You'll concede that would be a
8 serious crime?
9 A Yeah. I don't know what the law
10 is. You could tell me what the law is. But
11 it ought to -- if it's not a big law felony
12 against it, then they ought to make one.
13 Q And you'd never do anything like
14 that?
15 A I would not.
16 Q And you wouldn't be associated with
17 anything like that?
18 A I would not, period.
19 Q That's why you were mad when you
20 called Stephanopoulos?
21 A Well, I wouldn't want to --
22 MS. MARSH: Asked and answered 20
305
1 times. Objection.
2 THE WITNESS: I didn't like the
3 metaphor -- the example that George used.
4 And, you know, I was not pleased with him.
5 But I can assure you if someone
6 came to me and showed me an FBI file, I would
7 turn their ass in right away. Excuse me.
8 I'm sorry. Strike that. I would turn them
9 in right away.
10 BY MR. KLAYMAN:
11 Q Are you aware that George
12 Stephanopoulos has testified that he stands
13 by the accuracy of his statement?
14 A I'm not, but he'd have to stand by
15 it himself. I know one thing. He sure
16 didn't say I was the one that told him.
17 Q Are you going to turn George
18 Stephanopoulos in?
19 MS. MARSH: Objection. For what?
20 THE WITNESS: No. I'm going to
21 turn him in for what? He said it on
22 television.
306
1 BY MR. KLAYMAN:
2 Q For having knowledge about the
3 commission of a felony?
4 MS. MARSH: Objection. That
5 mischaracterizes his statements.
6 MR. GAFFNEY: Objection. I would
7 add for the record, Mr. Klayman, that is a
8 serious, serious accusation you made, and I
9 would ask you to withdraw it.
10 MR. KLAYMAN: It's based on his
11 testimony.
12 MR. GAFFNEY: It is not.
13 MR. KLAYMAN: I laid the
14 foundation.
15 MR. GAFFNEY: It is not based on
16 his testimony.
17 BY MR. KLAYMAN:
18 Q If you knew that Mr. Stephanopoulos
19 had knowledge of the commission of a felony
20 involving the use of FBI files, would you
21 turn him in?
22 A You would have to ask
307
1 Mr. Stephanopoulos. I don't think that he
2 does, you know. And I don't know, you know,
3 I don't know what he said. I haven't seen
4 his deposition.
5 But I could tell you that from day
6 one when this thing happened, I thought it
7 was serious.
8 Q Now, when you talked to
9 Mr. Stephanopoulos that day that you called
10 him up, did you say, "George, who are these
11 White House allies?"
12 A I said, "I don't know who" -- I
13 don't remember what I said, but it was
14 something like, "I don't know who was telling
15 you this, if they are, but they're out of
16 their minds."
17 Q You asked him who they were, didn't
18 you?
19 A I knew he wasn't going to tell me.
20 Q But you did ask him?
21 A I probably did.
22 Q And what did he tell you?
308
1 A He wouldn't tell me, as much as I
2 can remember. I don't know who would be so
3 idiotic to say something like that. But,
4 again, you have to ask him.
5 Q Did you say to Mr. Stephanopoulos,
6 "If you know who these people are, you better
7 turn them in"?
8 A I don't remember, but I probably
9 said "You ought to." But I don't know. I
10 was just mad about the statement being used.
11 And I don't know. You'd have to ask -- the
12 best person to ask about this is
13 Mr. Stephanopoulos, really.
14 Q Did you report this to any law
15 enforcement agency?
16 A What am I going to report? He said
17 it to six million people.
18 Q But did you take any action to
19 bring it to the attention of --
20 A No. No. Like I said, he said it
21 in front of six million people. Again, I
22 don't know what he said, Mr. Klayman, and I
309
1 didn't -- no. I did not.
2 He said it to -- I don't know how
3 many people watched "This Week with Sam and
4 Cokie," now. And, you know, if you have
5 information or whatever, you have
6 Mr. Stephanopoulos under oath, you can get
7 him to testify to whatever he testifies to.
8 Q Did you bring this to the attention
9 of Ken Starr?
10 A No. Bring it to the attention of
11 Ken Starr?
12 MR. GAFFNEY: Mr. Klayman, I object
13 to this entire line of questioning, because
14 of the fact that it assumes that there's some
15 sort of crime here. I think accusing someone
16 in the course of a deposition of committing a
17 felony is a serious thing, and I urge you
18 to --
19 THE WITNESS: Yeah.
20 MR. KLAYMAN: I'll let the record
21 speak for itself. I'll let the record speak
22 for itself. I don't need you to --
310
1 MR. GAFFNEY: I urge you to
2 withdraw the line of questioning.
3 MR. KLAYMAN: I don't need your
4 pious indignation, Mr. Gaffney.
5 MS. MARSH: We don't need your
6 comments, Mr. Klayman. Ask him a question.
7 MR. KLAYMAN: The record will speak
8 for itself.
9 BY MR. KLAYMAN:
10 Q Did you have any other
11 conversations with Mr. Stephanopoulos about
12 this Ellen Rometsch remark?
13 A I'm sure I did. I probably brought
14 it up two or three times after that.
15 Q When else did you bring it up?
16 A I don't remember. And I said "I
17 probably did." If I don't remember exactly
18 the conversation, I certainly don't remember
19 the times. But it is --
20 Q In what context did it come up?
21 A I don't know. Mr. Klayman, I
22 testified that I probably did. I didn't
311
1 know. So I wouldn't know what context it
2 was. But it was something that I was
3 sufficiently peeved about that I would be
4 likely to bring up repeatedly.
5 Q You brought it up again because
6 you're very worried about its ramifications,
7 correct?
8 MS. MARSH: Objection.
9 THE WITNESS: I didn't like the
10 statement. I never heard anybody even
11 remotely suggest such a thing.
12 BY MR. KLAYMAN:
13 Q When did you talk to
14 Mr. Stephanopoulos about it?
15 A Mr. Klayman, I don't know if -- I
16 keep saying it over and over. I talked to
17 him the first time the Sunday night that the
18 thing ran on the television, and I don't
19 remember the date. And I probably brought it
20 up with him, you know, a couple or three
21 times after that.
22 Q Within the same week?
312
1 A I don't know, Mr. Klayman. I can't
2 under oath tell you definitively yes or no if
3 it was the same week.
4 Q Did you bring it up in person or by
5 phone?
6 A I'm sure it was by phone. I hadn't
7 seen him in person in a while.
8 Q And things kept bothering you and
9 called him back?
10 MS. MARSH: Objection.
11 THE WITNESS: Yeah. I'm not --
12 look. I've answered all of my answer. I
13 told you to the best of my ability what it
14 is.
15 BY MR. KLAYMAN:
16 Q You told Mr. Stephanopoulos
17 something to the effect that "If they're
18 going to blame anyone for this, it's going to
19 be me. Why the heck did you say that?"
20 A No, I did not say that. I don't
21 think I did. And I don't think anybody that
22 knows me would blame me. It would take
313
1 someone that didn't know me at all to blame
2 me for something like this.
3 Q Well, that was running through your
4 mind, wasn't it?
5 MS. MARSH: Objection. Asked and
6 answered.
7 THE WITNESS: I gave you an answer.
8 I don't think that anybody, particularly
9 anybody that knows me, would blame me for
10 something like this.
11 BY MR. KLAYMAN:
12 Q Well, not all the federal
13 prosecutors in this country know you?
14 A No.
15 MS. MARSH: Come on, Mr. Klayman,
16 ask him a real question.
17 BY MR. KLAYMAN:
18 Q That bothered you, didn't it?
19 A No, it --
20 MS. MARSH: Mr. Klayman --
21 MR. KLAYMAN: Please don't
22 interrupt my testimony, Ms. Marsh.
314
1 MS. MARSH: Then ask him a real
2 question, not --
3 THE WITNESS: You're right. You
4 characterized it right. It's testimony, as
5 opposed to a question. I will agree with
6 that.
7 BY MR. KLAYMAN:
8 Q But you were concerned that there
9 were people in this country who didn't know
10 you who would blame you, right, as a White
11 House ally?
12 MS. MARSH: Objection.
13 THE WITNESS: I was concerned that
14 I think that he said something that I never
15 heard, okay? And I never heard anybody
16 saying this, and I don't know where in the
17 world -- who the world told him that.
18 But if there was somebody and they
19 told him that, it certainly is nothing that
20 I've ever heard, or ever heard anybody in the
21 remotest sense even discuss.
22 And I don't think that anybody who
315
1 knows anything about me would for one second
2 believe that I would do such a thing.
3 BY MR. KLAYMAN:
4 Q My question was, those who don't
5 know about you, they could believe such a
6 thing?
7 MS. MARSH: How does he know,
8 Mr. Klayman?
9 THE WITNESS: Well, look, this is
10 America. I guess I can't stop anybody from
11 doing anything.
12 But I certainly have never been
13 contacted about this by anybody other than
14 you.
15 BY MR. KLAYMAN:
16 Q But you're out there in front of
17 this whole war against James Carville?
18 A I'm out there in front criticizing
19 Ken Starr.
20 Q Against Ken Starr? You're in the
21 forefront of this war against Ken Starr?
22 A Wait a minute. The stuff I
316
1 criticized Ken Starr for is stuff on the
2 public record.
3 No. I don't think anybody -- I
4 never -- not one person -- this is the first
5 time -- not one person said, "Gee, you think
6 you're part of this or anything?" Not a one.
7 Q You have made declarations of war
8 against Ken Starr publicly, have you not?
9 A Yeah. I'll say I did.
10 MS. GILES: Objection. Vague and
11 ambiguous.
12 THE WITNESS: Yeah. I'll beat
13 the -- perhaps. I sure didn't do it in
14 secret.
15 BY MR. KLAYMAN:
16 Q Once you even said you were going
17 to break his kneecaps, right?
18 A No, I did not. You know, it's
19 always good when -- when you know what the
20 facts are, it's always better if you tell me
21 the facts, because we can have a better
22 thing.
317
1 I think what I said, to be exact,
2 is he's one mistake away from walking around
3 without any kneecaps. To paraphrase that,
4 there's an old saying called "He doesn't have
5 a leg to stand on."
6 Q Is it "you don't have a leg to
7 stand on" or "you don't have kneecaps to hold
8 your legs"?
9 MS. MARSH: Objection. Asked and
10 answered.
11 THE WITNESS: You've asked me a
12 question. First of all, you've --
13 MR. KLAYMAN: I'll show you what
14 I've asked the court reporter to mark as
15 Exhibit 16.
16 (Carville Deposition Exhibit
17 No. 16 was marked for
18 identification.)
19 BY MR. KLAYMAN:
20 Q I'm showing you Exhibit 16. This
21 is a report, "Carville: I Zapped Starr's
22 Charges," by Thomas M. DeFrank of the Daily
318
1 News, Washington bureau chief.
2 Take an opportunity --
3 A Go ahead.
4 Q Take an opportunity to look at
5 page 2, where those arrows are?
6 A I'm impressed with my memory.
7 Q And you said, 'He's one more
8 mistake away from not having any kneecaps,'
9 Carville chortled."
10 You said that, didn't you?
11 A I did.
12 Q That was a threat against
13 Mr. Starr, wasn't it?
14 A Of course it was not. Of course it
15 was not.
16 MR. KLAYMAN: You find that funny,
17 Ms. Paxton?
18 MS. PAXTON: You got me under oath?
19 MS. MARSH: Ms. Paxton is not under
20 oath.
21 MR. KLAYMAN: Just let it be noted
22 that White House counsel finds that funny.
319
1 MS. GILES: Objection to the
2 characterization of Ms. Paxton's reaction.
3 THE WITNESS: No. This is
4 ludicrous. I'm 53 years old. I am a
5 passionate man. I am in no way, shape, or
6 form a violent man. And again, it was to
7 say, one more mistake, he's not, in
8 argumentative sense, "he's not going to have
9 a leg to stand on"; that his credibility was
10 falling from beneath him, and I might add if
11 you look at the recent state of polls, it
12 would reflect that --
13 BY MR. KLAYMAN:
14 Q You say you're not a violent man?
15 A No. I don't think not think so,
16 no, sir.
17 Q Is that why you were arrested in
18 Mexico?
19 MS. MARSH: Objection.
20 MR. GAFFNEY: Oh, please,
21 Mr. Klayman.
22 MS. MARSH: Objection.
320
1 THE WITNESS: I'm not even going
2 to --
3 MR. KLAYMAN: I'll show you what
4 I'll ask the court reporter to mark as
5 Exhibit 17.
6 (Carville Deposition Exhibit
7 No. 17 was marked for
8 identification.)
9 BY MR. KLAYMAN:
10 Q This is a rendition of what was
11 said on "Meet the Press" January 25, 1998,
12 Sunday, at 10:41 a.m., when you were on that
13 show with Mr. Tim Russert.
14 I turn your attention to page 16,
15 under "Mr. Carville" at the top. And I'm
16 going to read two-thirds of the way down into
17 that paragraph.
18 "Let them go. Let them throw their
19 best punches. And you know what? In the
20 end, people are going to have to have an open
21 mind about this" --
22 MS. MARSH: Read the whole
321
1 paragraph. Read the whole paragraph.
2 MR. KLAYMAN: I don't want to read
3 it.
4 BY MR. KLAYMAN:
5 Q "In the end, when the whole story
6 comes out, they're going to see that this
7 so-called independent counsel who was put in
8 there by a political hack to do the jobs of a
9 political hack is nothing more than on a
10 vendetta against the President of the United
11 States."
12 When you referred to "put in there
13 by a political hack" are you referring to
14 Judge Sentell?
15 A I am.
16 MS. MARSH: I want to object that
17 it was not the entire statement made by
18 Mr. Carville, but a portion of it.
19 MR. KLAYMAN: I'm reading it.
20 MR. GAFFNEY: What page are we on,
21 Mr. Klayman?
22 MR. KLAYMAN: 16.
322
1 MR. GAFFNEY: Sorry.
2 BY MR. KLAYMAN:
3 Q "And there absolutely is not going
4 to be any resignations or any such things as
5 that, but I tell you what there's going to
6 be. There's going to be a war. With the
7 friends of the President are disgusted by
8 these kinds of tactics. And we're going to
9 fight, and we're going to fight very hard to
10 defend this President."
11 That's an accurate statement that
12 you made, is it not?
13 A Yes.
14 MS. MARSH: Same objection.
15 BY MR. KLAYMAN:
16 Q And in fact, those friends of the
17 President are the same allies that George
18 Stephanopoulos was referring to on
19 February 8, 1998 on "This Week" when he
20 talked about Ellen Rometsch and the strategy?
21 THE WITNESS: This is crazy.
22 MS. MARSH: Objection. I don't
323
1 know Mr. Stephanopoulos, but we deposed Mr.
2 Stephanopoulos.
3 BY MR. KLAYMAN:
4 Q Isn't that true?
5 A No. You talked to
6 Mr. Stephanopoulos. I have told you -- you
7 know, it's not like -- when I talk about Ken
8 Starr, it's not like I do it behind anybody's
9 back. I have been opposed to Mr. Starr since
10 his appointment.
11 Q Now, when you talked to George
12 Stephanopoulos, when you called him after he
13 made that remark, I take it there was at
14 least three or four conversations, correct?
15 MS. MARSH: Objection.
16 Mischaracterizing his testimony.
17 THE WITNESS: You know, you're
18 characterizing it -- I don't know.
19 BY MR. KLAYMAN:
20 Q Did you tell Mr. Stephanopoulos,
21 "That statement is just not true"?
22 MS. MARSH: What statement?
324
1 BY MR. KLAYMAN:
2 Q That he made about the Ellen
3 Rometsch strategy?
4 A What I told Mr. Stephanopoulos is
5 that that's crazy. No one that I ever talked
6 to, no one I've ever known -- I've never
7 heard of such a thing as that.
8 Q And did Mr. Stephanopoulos say in
9 response, "Gee, I knew it wasn't true. I was
10 just kidding." Something to that effect?
11 A No, he did not say that.
12 Q In fact, he didn't deny its
13 accuracy, did he?
14 A Well, he sure denied that I had
15 anything to do with it.
16 Q But he didn't deny its accuracy,
17 did he?
18 A I don't recall what he said. You
19 had a chance to depose him. Whatever he said
20 under oath, I'm sure that
21 Mr. Stephanopoulos --
22 Q I'm asking you what you recall him
325
1 saying?
2 A I don't recall. I recall him
3 saying, "Well, you certainly would never, you
4 know, say such a thing."
5 But I don't recall him denying its
6 accuracy.
7 Q You discussed Mr. Stephanopoulos'
8 statements with others after it was made, did
9 you not?
10 A I'm sorry. Come again?
11 Q You discussed Mr. Stephanopoulos'
12 statement about the Ellen Rometsch strategy
13 with other people?
14 A Yeah, I sure did.
15 Q Well, who did you discuss it with?
16 A I know with Mr. Begala and
17 Mr. Emanuel, for starters.
18 Q Who else?
19 A You know, probably anybody asked me
20 about it. I don't know. I just don't know,
21 Larry -- I mean, Mr. Klayman. But my
22 reaction was, "What is he talking about?"
326
1 Q Did you discuss it with Erskine
2 Bowles?
3 A No, sir.
4 Q You discussed it with the
5 President, didn't you?
6 A No, sir.
7 Q You discussed it with the first
8 lady?
9 A No, sir.
10 Q Discussed it with Mr. Kendall,
11 didn't you?
12 A I doubt it.
13 Q Mr. Bennett, Bob Bennett?
14 A No, sir.
15 Q Did you discuss it with any members
16 of the press or the media?
17 A I may have, but I don't know.
18 Q Who in the press or media?
19 A I don't know.
20 Q Who do you talk with most in the
21 media?
22 A Oh, just different people.
327
1 Q Who are the people that you talk to
2 most?
3 A Well, if Mr. Stephanopoulos is the
4 media, I talk to him a lot. I talk to -- you
5 know, it depends on who calls. Different
6 reporters will call me for different things.
7 Q You talked about that statement
8 with Mr. Blumenthal of the White House,
9 didn't you?
10 A I probably did. I don't know if I
11 recall it specifically happening. But I
12 certainly am not in a position to say that I
13 did not.
14 Q You talked about with Ms. Anne
15 Lewis, didn't you?
16 A No.
17 Q You don't really talk to her that
18 much?
19 A No.
20 Excuse me. Can I take two minutes?
21 Q Did you talk to her brother Barney
22 at all?
328
1 A I haven't talked to Barney in -- I
2 mean, I know him. I've seen him. I haven't
3 talked to Barney probably since the first of
4 the year.
5 Q Let me just ask, you have to go to
6 the bathroom?
7 A Yeah.
8 Q Let me just ask a few questions.
9 Can you make it?
10 A I'll try.
11 MS. MARSH: Why don't you just let
12 him take a break? It will take one minute.
13 MR. KLAYMAN: I just have a few in
14 this area.
15 BY MR. KLAYMAN:
16 Q Who are you closest with in the
17 media? Who do you talk with most frequently?
18 MS. MARSH: Objection. Asked and
19 answered.
20 THE WITNESS: I can't characterize
21 that, because it depends on what's going on.
22 It depends on the story. Sometimes, if
329
1 there's a certain kind of story that a
2 certain reporter is working on, they'll call
3 a little more often, and other times they
4 won't.
5 BY MR. KLAYMAN:
6 Q If I was to subpoena your telephone
7 records, who would it show you called most
8 often?
9 A I have no idea.
10 Q Give me a couple names.
11 A I don't -- I'd really rather not
12 characterize it --
13 Q Who have you talked to in the media
14 in the last week?
15 A Susan Page, Tony Blakely, Steve
16 Roberts.
17 MS. MARSH: You're talking about
18 other than the people he mentioned already
19 today, the woman from the Washington Post?
20 MR. KLAYMAN: Let him respond.
21 THE WITNESS: Yeah. Rich Carlton,
22 his girl. I don't know. I'd have to go back
330
1 and look at my cost slips. I can't just --
2 BY MR. KLAYMAN:
3 Q Peter Baker of The Washington Post?
4 A I talked to Peter some, but I don't
5 think I've spoken to him in the last week.
6 Q John Harris?
7 A I talked to John some, but -- I may
8 have spoken to him in the last week, but I
9 just don't recall.
10 Q Charles Babcock?
11 A No.
12 Q Not too much? So Peter Baker's the
13 one you talk to the most?
14 A I'll talk to him. If he calls, you
15 know, he calls with a story or something --
16 Excuse me. I'm going to get up and
17 go take a leak. I just can't hold it no
18 longer. Excuse me.
19 MR. KLAYMAN: Certify it.
20 (Recess)
21 THE WITNESS: I dispatched
22 Mr. DeLorenzo out to the phone to conduct as
331
1 thorough a search as he possibly could. I
2 called him. He said he was unable to find
3 any.
4 BY MR. KLAYMAN:
5 Q When did you ask him?
6 A When you asked me if I checked the
7 form, "I want you to go out and see if
8 there's something out there and take a good
9 look."
10 And as I assured you in the earlier
11 thing, either -- I will look myself, and if I
12 find anything, I'll hand it over to you
13 forthwith.
14 Q We'll get back to the documents a
15 bit later.
16 Mr. Carville, you testified that
17 you did talk to other people about
18 Mr. Stephanopoulos' statement. Tell me what
19 you discussed with Mr. Begala and
20 approximately when you discussed it with him?
21 A It was probably somewhere along "Is
22 George losing his mind?" or something to the
332
1 effect of "What's he talking about?" But I
2 don't -- I can't remember.
3 Q When did you call Mr. Begala?
4 A Probably that night or the very
5 next morning. Probably something I was
6 not --
7 Q Did you talk to him more than once
8 about this?
9 A I'm sure that I did. I just
10 don't -- I'm sure that I did.
11 Q Clearly, having talked to him more
12 than once, you must have said more than just
13 he was losing his mind?
14 A I'm sure that I did, but I don't
15 know. In a period of time, I have any number
16 of conversations, Mr. Klayman, and rather
17 than characterize a conversation that I do
18 not know what it is or what I said -- I'm
19 sure that I did. But I don't remember
20 exactly the language or anything else, and I
21 think that Mr. Begala talked to
22 Mr. Stephanopoulos also, but you have his
333
1 deposition, and I'm sure that you asked him.
2 Q Now, this conversation didn't take
3 place very long ago, did it?
4 MS. MARSH: Which conversation are
5 we talking about?
6 BY MR. KLAYMAN:
7 Q With Mr. Begala, these series of
8 conversations?
9 A I don't know. What was the date
10 that George was on TV? We've got the thing
11 right here. February 8. Yeah, I'm sure it
12 took place --
13 Q You asked Mr. Begala "Who are these
14 White House allies?" didn't you?
15 A No, I didn't have to ask him,
16 because he said the same thing I did. I
17 never heard of such a thing, so how would he
18 know? I mean, his was the same as I. You
19 know, "What is George talking about? Who
20 could he possibly talk to?" Neither one of
21 us had ever heard.
22 Not much to ask him, because he had
334
1 never heard of it either. And I would
2 describe Mr. Begala as, if anything, as upset
3 as I was about the whole so-called Filegate
4 thing.
5 Q That's because Filegate is no
6 laughing matter, is it?
7 MS. MARSH: Objection. Ask him a
8 real question.
9 THE WITNESS: Yeah. I did not
10 find -- I did not find Mr. Begala's joke
11 offensive. In fact, it was a joke that
12 started out with the passport file story and
13 just sort of went on to something else.
14 BY MR. KLAYMAN:
15 Q In fact, Mr. Begala said that he'd
16 been using that joke for six years, right?
17 A Well, he couldn't have been -- as I
18 say, I don't remember the date that this
19 became -- but I think it was less than six
20 years ago that the joke origin came from kind
21 of a standup line that somebody, I think,
22 gave to Dee Dee Myers, to say something looks
335
1 better than your picture in the passport
2 file.
3 MS. GILES: Mr. Begala's deposition
4 speaks for itself.
5 MR. KLAYMAN: I don't want you to
6 be tipping witnesses off.
7 MS. GILES: You're
8 mischaracterizing Mr. Begala's deposition
9 testimony. As I recall, the joke started out
10 where -- I think Dee Dee was -- I don't know.
11 You know what I mean?
12 A good joke is like a fruitcake at
13 the holidays. Everybody just passes it
14 around. It started out from that, and I
15 guess I got ���� into a joke about that.
16 BY MR. KLAYMAN:
17 Q Because, in fact, the FBI files
18 matter isn't six years old, is it?
19 A I don't think it is. To tell you
20 the truth, you would know. I got the
21 stuff --
22 Q It came in June of 1996, correct?
336
1 A Yeah. I know it wasn't six years
2 old.
3 Q So the joke about the FBI files can
4 be six years old?
5 A Sure. The joke started out as the
6 passport files, all right? And you would say
7 something like, "You know, Mary Matalin told
8 James Carville when she first saw him,
9 'You're better-looking than you are in your
10 passport file.'" Ha-ha. Okay.
11 Then when the FBI file, Filegate or
12 whatever you call it, broke, the joke ���� in
13 or became -- it became a more current thing.
14 I don't know if you use humor very much, but
15 people that do look for something that is
16 current. And I'm sure that you did, but I
17 actually -- you know, Mr. Begala told me that
18 when he said it, he even said it was a joke
19 in there. And I think somebody -- one of the
20 TV commentators said, "No good joke goes
21 unpunished." And there's a picture of
22 Mr. Begala coming to his deposition. That's
337
1 the origin of the joke.
2 Q My question was simple. It's that
3 if indeed someone looked at FBI files in the
4 Clinton administration, that wouldn't be a
5 funny matter, would it?
6 MS. MARSH: Objection.
7 Argumentative.
8 THE WITNESS: You know,
9 Mr. Klayman, if someone did, it would not be
10 funny. But I did not take offense at
11 Mr. Begala's joke. I knew it was a joke. I
12 knew the origin of the joke. I knew where it
13 came from. Just as though it wouldn't have
14 been funny if somebody looked at someone's
15 passport file to make a joke.
16 BY MR. KLAYMAN:
17 Q But you never found George Bush
18 funny, did you?
19 A Yeah, sometimes. Yeah.
20 Q By word or by deed?
21 A He could -- don't cry -- he could
22 pop off. But George Bush's endearing value
338
1 is he was good for the imitators. The people
2 that would do him could be sort of, you know,
3 funny. I thought that -- you know, I thought
4 that President Reagan could fire off a good
5 line or two, and President Carter isn't
6 exactly a barrel of laughs.
7 President Clinton's got -- he tends
8 to -- his stories tend to get long sometimes,
9 like his speeches.
10 Q Who's that?
11 A President Clinton.
12 Q He's probably our least funny
13 president, isn't he?
14 A No, I wouldn't think so. I think
15 President Reagan probably had more of a knack
16 for one-liners, but I think President Clinton
17 has some pretty good lines.
18 Q When this Filegate scandal broke,
19 you were part of setting strategy to respond
20 to that on behalf of the White House, weren't
21 you?
22 A Not too much. In June of 1996, I
339
1 was --
2 Q Tell me how you learned of the
3 scandal.
4 A Boy, I don't remember. I either
5 read about it in the paper or somebody called
6 me and said -- I don't remember if someone
7 gave me a heads-up or I saw it in the paper
8 or saw it on television.
9 Q And who called you?
10 A If I testify that I don't remember
11 that if someone called me or saw it on
12 television or read about it in the paper, how
13 could I possibly remember who called me?
14 Q You always reminded me of Carnac
15 the Magnificent.
16 A Okay. Well, I liked him.
17 Q What, if anything, did you do when
18 you learned about the scandal when it broke?
19 A I mean, you know, you could go back
20 and find out. I told him, "Don't look for me
21 to defend this. Somebody better" -- you
22 know, there better be a good explanation for
340
1 it, because if someone was actually doing
2 this, you can butter me. I'm toast. I'm out
3 of here.
4 Q And what, if anything, did you do
5 to find out whether someone actually did it?
6 A Well, people assured me that, look,
7 it was whatever they called it: An
8 administrative glitch, et cetera. It's been
9 investigated now. Independent counsel's had
10 it for I don't know how long, and probably
11 now he's waiting for the reporting, but ����
12 and hopeful that there was not any malicious
13 intent here. And one of the things --
14 Q Excuse me. Backing up. Where does
15 that come from, there was no malicious
16 intent?
17 A I said I'm hopeful -- I'll wait and
18 see what the report is. It was not malicious
19 intent.
20 Q What report?
21 A Independent counsel writes the
22 report.
341
1 Q Your favorite independent counsel,
2 Ken Starr?
3 A My favorite.
4 Q And you're going to wait for what
5 happens in this case?
6 A Well, I'm curious to see what he
7 says in this, yes. Again, I'm not going to
8 sit here and say that I think that this was
9 a -- to me, of everything that happened here,
10 I thought this is something that -- I said if
11 this is true, it's really indefensible. I
12 was assured it was not.
13 I think that -- I'm confident and
14 hopeful that history bears the people that
15 assured me. I certainly don't blame people
16 for looking into it. I don't think this is
17 like some kind of sex investigation.
18 Q Is this much more serious than
19 Monica Lewinsky and Kathleen Willey?
20 A To me it is, yes.
21 Q And you're going to accept Ken
22 Starr's finding as the gospel?
342
1 A No. But I'll tell you what: But
2 if he gets 12 people to go along with him, I
3 would be mighty upset.
4 Q And you're aware that this lawsuit
5 will, if it goes to trial, and we believe it
6 will, ultimately reach a jury verdict over
7 whether, in a civil context, these violations
8 of privacy occurred?
9 MS. GILES: Objection.
10 BY MR. KLAYMAN:
11 Q Are you aware of that?
12 A I have not read the pleadings in
13 the case. I don't know where the case is. I
14 don't know what's alleged. So I just sort of
15 stay away from it.
16 Q Are you aware that this is a civil
17 suit with regard to allegations that the
18 provision of the files from the FBI to the
19 Clinton White House constituted violations of
20 privacy?
21 A I am aware that it's a civil suit.
22 I am, Mr. Klayman. But I'm not aware of much
343
1 more than that.
2 Q Have you had a chance to review the
3 complaint in this case?
4 A I did not read the complaint. I'm
5 not a lawyer anymore. I'm someone who
6 graduated from law school.
7 Q You did practice, though, didn't
8 you?
9 A Oh, that would be a loose
10 definition of it. I would not claim any
11 expertise in the law.
12 Q In fact, you're reported to have
13 done some litigation, correct? You did do
14 some litigation, did you. Yes or no?
15 A I did some, but I was not -- I
16 would not hold myself out as anything
17 remotely -- again, I haven't picked up a law
18 book in I don't know how long.
19 Q And you did some litigation in
20 Louisiana, right?
21 A I did some.
22 Q Who did you work for when you did
344
1 the litigation?
2 A It was one of these kinds of
3 things. It was a firm that had about four or
4 five different names while I was there.
5 Literally, I was sitting at my desk one day,
6 and said, "If I had to hire a lawyer, I
7 wouldn't hire me, so I wouldn't ask anybody
8 else to," and left.
9 Q You played a lawyer in movies,
10 haven't you?
11 A I did.
12 Q When was that?
13 A Filmed in February of 1996.
14 Q What was the name of that movie?
15 A "The People versus Larry Flynt."
16 Q Who did you play? Larry Flynt?
17 A No. I played a man by the name of
18 Simon Lees.
19 Q And what did he do?
20 A He was then the district attorney
21 at Hamilton County, Ohio. He is now the
22 sheriff of Hamilton County, Ohio. He is
345
1 still in public office. He is the person who
2 prosecuted Flynt.
3 Q And that case dealt with
4 litigation, didn't it?
5 MS. MARSH: The actual case or the
6 movie?
7 BY MR. KLAYMAN:
8 Q The movie.
9 A Look, again, the fact that I played
10 a ten-minute role in a movie doesn't make me
11 an expert on civil litigation. I'm sitting
12 here telling you I am most decidedly not an
13 expert on civil litigation. I am telling you
14 that I got out of the practice of law because
15 I wasn't very good at it and didn't enjoy it,
16 and I'm sitting here telling you --
17 Q And instead you became a movie
18 star?
19 MS. MARSH: Objection.
20 MR. GAFFNEY: I'd like to make an
21 objection here. For someone who filed
22 pleadings with the court describing the
346
1 urgency of this deposition, such that you had
2 to interfere with Mr. Carville's travel
3 plans, I hardly think questions about his
4 movie career bear out the assertions you make
5 in your pleadings.
6 MR. KLAYMAN: Your objection
7 already took longer than my question, which I
8 think lasted two seconds.
9 MS. MARSH: More than one question
10 about the movie.
11 THE WITNESS: We can talk about the
12 movie all --
13 BY MR. KLAYMAN:
14 Q Mr. Carville, let's get back to
15 your discussions after George Stephanopoulos.
16 You had discussions with Sidney
17 Blumenthal about Stephanopoulos' comment,
18 didn't you?
19 A I don't know that I could say -- I
20 would not be surprised if I did. But I don't
21 have a specific recollection, and I think
22 that's what I testified to earlier. But if I
347
1 didn't testify to that earlier, that is
2 that --
3 Q Was that person to person, or did
4 you have telephone conversations?
5 A I'm sure it was telephone
6 conversation. I don't see Mr. Blumenthal all
7 that often.
8 Q When was that conversation?
9 A If I don't remember the
10 conversation, how can I tell you when the
11 conversation is? I don't mean to pull a
12 Carnac. I said that I did, but I don't
13 remember having the specific conversation.
14 If I don't remember having the specific
15 conversation, it is logical to follow that I
16 don't remember the time of the conversation.
17 Q You did testify --
18 MS. MARSH: He said he might have.
19 THE WITNESS: What I testified to,
20 Mr. Klayman, was that it was certainly highly
21 likely that it came up in a conversation, but
22 I don't have a specific recollection of it.
348
1 BY MR. KLAYMAN:
2 Q And you had a conversation with
3 others in the White House, didn't you?
4 A I know that I had conversations
5 with Mr. Begala and Mr. Emanuel.
6 Q And Mr. Emanuel?
7 A That's what I said.
8 Q Did we already discuss what you
9 said to Emanuel?
10 A No. But I'm sure it's the same
11 thing.
12 Q What did you guys discuss?
13 A The same thing that I told
14 Mr. Begala, and he told me the same thing.
15 He didn't know what in the name of God's
16 green earth George was talking about.
17 Q You asked all these people for the
18 names of White House allies George was
19 referring to?
20 MS. MARSH: All which people?
21 BY MR. KLAYMAN:
22 Q Begala, Ron Emanuel, and
349
1 Blumenthal?
2 A Mr. Blumenthal didn't.
3 Q Let me just finish my question.
4 You asked all these people, "Who
5 are these allies George is talking about?"
6 Didn't you? You asked that, didn't you?
7 Didn't you ask that, Mr. Carville?
8 A Hold on. Now, if they said that
9 they don't know what in the hell George is
10 talking about, that they never heard of any
11 such thing in their life, it is logical to
12 follow that they would have no idea of who
13 George was talking to or who would say such a
14 thing.
15 The person to ask that to, and I'm
16 sure that you did, is Mr. Stephanopoulos,
17 because I don't have the foggiest idea.
18 Q Did you ask these people who George
19 was talking to?
20 A I probably said if they told me --
21 again, let me back up and say, I don't know
22 what the hell he's talking about. I never
350
1 have heard that. Then they sure would not
2 know who he was talking to.
3 But you had Mr. Stephanopoulos
4 here, and you can ask him, or you did, I'm
5 sure.
6 Q Did you ask these people those
7 questions, yes or no?
8 MS. MARSH: Objection. Asked and
9 answered.
10 MR. KLAYMAN: It has never been
11 asked.
12 MS. MARSH: It has been.
13 THE WITNESS: There was no need for
14 me to ask the question, because they
15 immediately said that they had never heard or
16 talked to anybody that said such a thing.
17 How would they know who he talked to?
18 BY MR. KLAYMAN:
19 Q So now you remember what they said?
20 MS. MARSH: Objection.
21 Mr. Klayman, he said he's told you this.
22 THE WITNESS: I said in terms of