351
1 Mr. Begala and Mr. Emanuel, I remember
2 talking to them. I said in terms of
3 Mr. Blumenthal that I -- it's reasonable to
4 assume that I did, but I don't have a
5 specific recollection of the conversation.
6 BY MR. KLAYMAN:
7 Q Did you talk to anybody outside of
8 The White House about this statement of
9 Mr. Stephanopoulos' involving --
10 A I'm sure that I did.
11 Q Who did you talk to? Ickes?
12 A No, I did not talk to Ickes. I'm
13 sure reporters called me about it. You know
14 what I mean? I don't have a recollection
15 about who I specifically talked to, but --
16 Q Which reporters?
17 A I don't know.
18 Q Let me show you your calendars.
19 Maybe that will refresh your recollection.
20 MS. MARSH: Can we have the
21 original one back, please?
22 MR. KLAYMAN: You will at the end.
352
1 MS. MARSH: Is there a reason we
2 can't have it now?
3 MR. KLAYMAN: Because we want to
4 refer to it.
5 MR. GAFFNEY: This is an exhibit?
6 MR. KLAYMAN: Yes.
7 MR. GAFFNEY: Can I have my copy of
8 the exhibit?
9 MR. KLAYMAN: You can have your
10 copy, Mr. Gaffney.
11 MS. GILES: Can I get a copy, too,
12 as well as Exhibits 8 through 11?
13 MR. KLAYMAN: We'll give them to
14 you at the end. Thank you. It's not our
15 fault these things weren't produced timely.
16 MS. MARSH: They are produced
17 timely. Mr. Klayman, the subpoena says
18 today. That's when they were produced. That
19 is timely.
20 THE WITNESS: I thought we did a
21 good job of --
22 MS. MARSH: We did what we were
353
1 required to do, James.
2 MS. GILES: What number exhibit are
3 the calendars?
4 MR. KLAYMAN: All they're asking
5 for is how it was marked on the original.
6 That's all. Don, all they're asking for is
7 what number's on the original.
8 MR. BUSTION: They have the
9 original and a copy.
10 MR. KLAYMAN: It was in a folder.
11 MS. MARSH: For the record, there's
12 writing on it now saying "Carville
13 Exhibit 18," because I thought it was my
14 copy.
15 MR. KLAYMAN: What number is the
16 original?
17 MR. BUSTION: It's never been
18 marked as an exhibit.
19 MR. KLAYMAN: Okay. It's marked as
20 an exhibit now, Exhibit 18.
21 (Carville Deposition Exhibit
22 No. 18 was marked for
354
1 identification.)
2 BY MR. KLAYMAN:
3 Q Tell me what Exhibit 18 is,
4 Mr. Carville. It starts January 1996.
5 A The calendar that I produced in
6 response to requests for documents that you
7 made.
8 I might add, I think that three
9 months of 1997 -- I think they told me
10 January, February, and March of '97 -- are
11 missing.
12 Q Three months when? In 1997?
13 A Yes.
14 Q Where was this calendar taken from?
15 A Well, they had the office keep a
16 thing, like, on a desk for me, and they tore
17 them off and put them in something, and they
18 couldn't find three of them. I was surprised
19 I was able to produce this many for you.
20 Q They're kept loose, page by page?
21 A They kind of tear it off after a
22 month, and there's a box they put it on under
355
1 there. For all I know, I thought they threw
2 them away. I thought I was going to come in
3 here and tell you all I had was a calendar
4 for the last month. I was actually kind of
5 pleased I was able to put this together.
6 Q So you're missing three months in
7 1997?
8 A Right.
9 Q Which ones? January, February,
10 March?
11 A Right, that looks like what it is.
12 Q Have an opportunity to look at this
13 calendar and tell me whether it refreshes
14 your recollection as to who you spoke with
15 about George Stephanopoulos' statement about
16 Ellen Rometsch?
17 A No, it doesn't. Given the fact
18 that I was in Washington, I probably, you
19 know, talked to -- you know, I talked to
20 people.
21 Q Let's look at the calendar for
22 December 1997.
356
1 A December of 1997?
2 Q Right. Do you see the entry on the
3 10th of December?
4 A Right.
5 Q Fabiana Jorge?
6 A Mm-hmm.
7 Q Who's that?
8 A She's a woman who does a lot of
9 work in Latin America.
10 Q Is that for your private business?
11 A It is.
12 Q It's nothing to do with Clinton
13 administration?
14 A Not at all.
15 Q Molly Dickinson?
16 A She is a reporter who has written
17 extensively about the S&L crisis, and she
18 was -- it's not something that I'm sort of
19 into, but she's a woman, and that's her sort
20 of thing.
21 Q She have anything to do with Henry
22 Hyde?
357
1 A Not that I know of. I would not
2 think so.
3 Q Look down on 31 December 1997:
4 Sally Quinn, Ben Bradlee, 1:30 p.m.
5 They're people you talk to
6 frequently, aren't they?
7 A No. I haven't talked to them in I
8 don't know how long.
9 Q Let's turn to the next calendar,
10 January '98. The entry for the 31st, you
11 have it again: Sally Quinn and Ben Bradlee,
12 right?
13 A I don't know what that is. It's
14 the same date. See, it's the 31st, and --
15 it's December 31st on that calendar. It was
16 a New Year's Eve party they have.
17 Q Jules Whitcover?
18 A You know, the gentleman from ����
19 Report, and he's writing a book on kind of
20 demise of the old style of politics or
21 something, and he wanted to come by my office
22 and talk to me about that.
358
1 Q Did you ever hear of somebody by
2 the name of ����?
3 A I have.
4 Q Who is he?
5 A He's a guy that used to work for --
6 I think he worked for different papers, and
7 now he writes for -- he's got some articles
8 in ���� Magazine.
9 Q Are you in contact with ���� these
10 days?
11 A No I haven't talked with ���� since
12 three months ago.
13 Q Have you talked with anyone from
14 ���� Magazine in the last three months?
15 A Oh, I may have talked to somebody
16 that's a reporter by the name of Jonathan
17 ����. I may have spoken to him.
18 Q When's the last time you talked to
19 him?
20 A I just don't know.
21 Q And recently in the last few weeks?
22 A Probably not, but, you know, I
359
1 could have. I don't know. He's someone I
2 speak to periodically, but I'm not --
3 Q Did you talk to him about George's
4 statements concerning Ellen Rometsch?
5 A No. No.
6 Q In fact, they've been publishing a
7 lot about perceived Clinton adversaries
8 lately, haven't they?
9 A They have.
10 Q You've been in contact with them to
11 give them information about adversaries,
12 right?
13 A I haven't spoken to -- I might have
14 had one at the most two conversations in
15 response to a question to Jonathan and that's
16 it. And I would testify with absolute
17 certainty I had more than five minutes of
18 conversation with him.
19 Q What did you talk to him about?
20 What was the subject matter?
21 A I don't know. Give me a chance to
22 look up and see if they quote it in there. I
360
1 would know. It was a colorful story.
2 Q You talked to him about Ken Starr
3 and Paula Jones?
4 A I don't know. I don't remember.
5 But I can do some kind of a search and tell
6 you. But I don't remember whatever it was,
7 but it was very limited, and he is not a
8 reporter that I speak to very often.
9 Q How long as ���� magazine been
10 publishing?
11 A I have no idea.
12 Q It's a recent publication, isn't
13 it?
14 A I don't know. It's one of these
15 computer things.
16 Q It's kind of like the liberal side
17 of ����?
18 MS. MARSH: Objection.
19 THE WITNESS: I guess. You can
20 characterize it how you want. I'm not an
21 expert on ���� Magazine.
22 BY MR. KLAYMAN:
361
1 Q ����'s strange brother?
2 MS. MARSH: Objection. What kind
3 of relevance does that have to this?
4 Q Do you know who owns that magazine?
5 A I do not.
6 Q But you work closely with it?
7 MS. MARSH: Objection.
8 THE WITNESS: I just want to say
9 this for the record. I have sat here and
10 tried to answer every question that you had
11 regardless as honestly and truthfully as I
12 can. And when I say that I haven't talked to
13 somebody more than five minutes in the last
14 three months and I've said it two or three
15 times, and you come back and you say "you
16 work closely with them," you know, I just got
17 to tell you that that's -- in addition to
18 being ill-mannered, it's just an affront.
19 I don't talk to them. I haven't
20 talked -- I might have talked to Jonathan
21 ���� twice. He's somebody I've spoken to on
22 the phone. My conversations with him have
362
1 been very limited and not great detailed.
2 BY MR. KLAYMAN:
3 Q Has it dawned on you, Mr. Carville,
4 after the experience in scheduling your
5 deposition, I don't believe you?
6 MS. MARSH: Come on, Mr. Klayman.
7 THE WITNESS: We've done all right
8 here for five hours or so. Let's just see if
9 we can get through this last hour. Okay?
10 BY MR. KLAYMAN:
11 Q Charlie Peters, who is he?
12 A He's the publisher of the
13 Washington Monthly, and is a friend of mine,
14 and is a man that I really like.
15 Q You had a meeting with Bob Barnett
16 at 12:30 on the 19th of January?
17 A He's my lawyer, and you know as
18 well as I do, this lawyer would slap me right
19 in the face if I answered that question.
20 Q I didn't ask you a question.
21 A I know, but you were getting ready
22 to.
363
1 MS. MARSH: I wouldn't slap you,
2 but I would assert the privilege.
3 MR. KLAYMAN: I don't know about
4 that, Ms. Marsh.
5 MS. MARSH: I do, and so does
6 Mr. Carville, Mr. Klayman. And I don't
7 appreciate comments of that kind on the
8 record.
9 BY MR. KLAYMAN:
10 Q You know Larry King Live very well?
11 MS. MARSH: The show or the person?
12 THE WITNESS: The person? Yeah,
13 I've been on the show.
14 BY MR. KLAYMAN:
15 Q These calendars contain your
16 appointments and meetings for the period that
17 you produced them for, correct?
18 A That's correct.
19 Q And they're accurate to the best of
20 your knowledge?
21 A They are. They've been redacted
22 for personal business and things like that,
364
1 but they have.
2 Q You didn't redact them for things
3 that deal with your professional activities,
4 just for your personal activities?
5 A That's correct.
6 What they did is, it's like, if
7 there was a speech I gave, they just gave the
8 location, not the group. And if it's foreign
9 consulting, foreign consulting is on there.
10 Q Did you just consult with your
11 lawyer before you made that remark?
12 A I did. She reminded me of exactly
13 what I told you.
14 Q So she provided you information and
15 then you testified, correct?
16 MS. MARSH: No, Mr. Klayman, I did
17 not. I reminded him of a conversation he had
18 this morning with his staff.
19 THE WITNESS: She sure did, and I'm
20 grateful that she did, because it helps me
21 provide you with a better answer.
22 BY MR. KLAYMAN:
365
1 Q I'm sure you are grateful.
2 Now, Mr. Carville, do you know
3 whether there's any kind of internal
4 investigation at the White House to determine
5 who was responsible for requesting the FBI
6 files that are the subject of this case?
7 A I do not.
8 Q Have you ever heard anyone talk
9 about such an investigation?
10 A No, I don't think I have. Maybe
11 there was some talk about it in '96, but I
12 suppose that once the independent counsel got
13 ahold to it, that he probably would have
14 taken a dim view on a parallel internal
15 investigation. But I don't know that. I'm
16 not an expert in this kind of thing.
17 Q Around the time that the FBI file
18 scandal broke in June of '96, did you ever
19 have any contact with the White House's
20 counsel?
21 A I doubt if I had contact. I
22 really, really doubt it.
366
1 Q Are you aware that Ms. Sally Paxton
2 is sitting here and played a role in
3 disseminating information throughout the
4 White House after that scandal broke?
5 MS. GILES: Objection. That's
6 outrageous.
7 THE WITNESS: I'm getting ready to
8 testify to something I don't know, Ms.
9 Paxton. And I would be as stunned as any
10 human being would be that if anybody in the
11 White House's counsel's disseminated --
12 BY MR. KLAYMAN:
13 Q I'm talking about, just relayed the
14 fact a scandal had broken in the White House?
15 A I don't know. Till today, she
16 seems like a nice enough person. I don't
17 know Ms. Paxton.
18 Q You ever talk to her before?
19 A To the best of my knowledge, I
20 haven't spoken to Ms. Paxton.
21 Q You know Jack Quinn?
22 A I know Jack Quinn.
367
1 Q He also was president's counsel?
2 A I think he was the vice president's
3 chief of staff.
4 Q You talked to Jack Quinn about the
5 Filegate matter?
6 A I doubt if I spoke to him about it,
7 but I can't testify to an absolute certainty.
8 Q Who in the White House have you
9 talked to about the Filegate matter?
10 A I've certainly talked to
11 Mr. Begala. I've talked to Ron Emanuel about
12 it. I'm sure I talked to Mr. ���� about it.
13 Q Who else?
14 A I don't know. June of '96 -- my
15 memory just not that good.
16 Q In what context did you talk to
17 Begala about it?
18 A I think if I'm not mistaken, he was
19 in Boston at the time, and I probably called
20 and said something. I don't know the
21 context, you know: "What is this?"
22 Q And what did he tell you?
368
1 A I don't remember, Mr. Klayman. The
2 definite recollection, I don't remember his
3 words, but he was also upset about it.
4 Q And when did you talk to Emanuel
5 about it?
6 A I don't remember. Again, if you're
7 asking if this thing was in June of '96, it
8 was some time ago.
9 Q And who is ����, Doug ����?
10 A Mm-hmm.
11 Q Who was Doug ���� at the time?
12 A Political director at the White
13 House.
14 Q What did you speak to him about?
15 A Again, I said very likely he's
16 someone that I speak to periodically, and
17 likely that I did. But I don't have a
18 specific recollection of a conversation that
19 I had in June of 1996. I mean, if you asked
20 me who did I talk to in June of 1996, I
21 couldn't answer with any degree of certainty.
22 Q I'm going to show you what has been
369
1 marked as Exhibit 9 to your deposition. It's
2 called "Filegate."
3 MS. MARSH: May we have the
4 original as well as a copy?
5 MR. KLAYMAN: I'm going to work off
6 the original.
7 MS. MARSH: I'd like to compare the
8 original and a copy, if you don't mind.
9 MR. KLAYMAN: That's fine.
10 BY MR. KLAYMAN:
11 Q You might want to review it while
12 your counsel's leafing through.
13 A I pretty much went through this.
14 Q The top page of the copy is
15 entitled "Filegate, Miscellaneous, Gary
16 Aldrich Book."
17 You had a file on this controversy,
18 did you not?
19 A Yeah.
20 Q And when was this file made?
21 A It probably was -- Todd redid the
22 stuff, the filing things. I'd have to ask
370
1 him. But it was -- the file was made before
2 that. I don't know if they moved the files
3 from one room to the other. I could find out
4 for you.
5 Q The file was created on or about
6 June of 1996?
7 A I don't know when it was. I can't
8 tell you, because what happened is, I guess
9 they just had "File, FBI," and I noticed that
10 they had that, and the Gary Aldrich book
11 because it was an FBI thing. The file system
12 that we have is not a sophisticated,
13 computerized thing.
14 Q But you put it together?
15 A I have never put a file together.
16 They get stuff that comes in, they pick it
17 up, they'll file it.
18 Today, you know, this past week and
19 this morning, all morning, the first time
20 I've gone rummaging through looking for
21 everything to make sure that I could tell you
22 that --
371
1 Q But you started collecting stuff
2 around the time the scandal broke, right?
3 A Well, there are things that go
4 back -- some of the things that sort of go
5 back. I don't know how these things
6 happened. I'm sure that -- I don't know.
7 But obviously, this is an article on 6/26/96,
8 6/26/96. These are newspaper clips. Maybe
9 there was a pile of newspaper clips, you
10 know; he took them all and just -- you know
11 what I mean? Broke them down.
12 Q At the time that the scandal broke,
13 you were providing consultancy for the
14 Democratic national committee?
15 A No, I was not. Remember that in
16 1994, it was really -- the contract with the
17 Democratic national committee was terminated.
18 And I didn't -- I was not talking, to my
19 knowledge, in 1996. I had minimum contact
20 with the DNC.
21 Q You were providing informal advice
22 to them?
372
1 A If I was, it was sure limited.
2 MS. MARSH: Objection.
3 Mischaracterizes his earlier testimony.
4 THE WITNESS: Yeah. It was
5 extremely limited, and I don't recall doing
6 any.
7 BY MR. KLAYMAN:
8 Q But you started collecting
9 materials about the scandal because you knew
10 it was important?
11 A You know, Mr. Klayman, I've
12 testified consistently today that I thought
13 that when I first saw this, I thought this
14 was serious. I was curious as to an
15 explanation. It's not the only sort of file,
16 you know, things that I was sort of
17 collecting. You know, it wasn't collecting
18 information. Most of this stuff is just
19 newspaper articles, and by the way, much of
20 it is not very favorable. A lot of it's
21 Washington Times, which is not really
22 particularly disposed to the President.
373
1 Q Now, you are aware that there is an
2 FBI memorandum that says that Hillary Clinton
3 strongly recommended Craig Livingstone for
4 the job of director?
5 MR. GAFFNEY: Objection to the form
6 of the question. Assumes facts not in
7 evidence.
8 THE WITNESS: I have not seen --
9 BY MR. KLAYMAN:
10 Q Have you ever heard that said?
11 A I remember that there were press
12 stories concerning "How did this man get a
13 job?" But I have no idea, and I'm not the
14 person to ask. No way that I would know.
15 Q Did you read press stories that
16 Dick Morris told Sherry Rollins, his
17 then-girlfriend, as recorded in her diary,
18 that Hillary was the mastermind of Filegate?
19 Do you remember that?
20 A You read so much stuff. Excuse me
21 if I don't believe the source on that one,
22 Mr. Klayman. That would be something that
374
1 would be of no -- I can't say that I do
2 remember that, no.
3 Q You don't have a high regard for
4 Mr. Morris?
5 A I think he is a clever man, but no.
6 I'm under oath, and I would be required to
7 say that in terms of his veracity, I probably
8 don't have the highest regard for him. I
9 think he's a man of some intellect.
10 MR. KLAYMAN: I'll show you what
11 I'll ask the court reporter to mark as
12 Exhibit 19. It's a memorandum written by
13 special agent Dennis Scullabrene, then on
14 White House detail.
15 (Carville Deposition Exhibit
16 No. 19 was marked for
17 identification.)
18 MR. GAFFNEY: What exhibit is this,
19 Mr. Klayman?
20 MR. KLAYMAN: Exhibit 19.
21 BY MR. KLAYMAN:
22 Q Do you see the center of the page:
375
1 "Bernard Nussbaum, Counsel to the President,
2 advised he has known the appointee for the
3 period of time he's been employed in the new
4 administration. He had come highly
5 recommended to him by Hillary Clinton, who
6 has known his mother for a longer period of
7 time. He was confident that the appointee
8 lives a circumspect life and was not aware of
9 any illegal drug or alcohol problems. He
10 said that the appointee will work at the
11 White House on security matters. He said
12 that in the short period of time that the
13 appointee has worked for him he has been
14 completely satisfied with his performance,
15 conduct, and productivity. He recommended
16 the appointee for continued access in his
17 current capacity."
18 Have you ever seen this document
19 before?
20 A I have not.
21 MS. MARSH: I object to the extent
22 we have only one page.
376
1 THE WITNESS: One of the reasons
2 that I thought that the FBI file story was --
3 that I was concerned about it is these kinds
4 of things, when people don't have a chance to
5 rebut them, or we get one page, or we get one
6 story, very often we don't know.
7 I don't have any -- and I'm not an
8 expert. This is the first time I've seen
9 this. I have absolutely no competency
10 whatsoever, by training or anything else, to
11 render an opinion on very much about it.
12 BY MR. KLAYMAN:
13 Q I didn't ask you. I asked if you
14 ever seen it before, this page?
15 A I said I haven't seen it.
16 Q Were you aware of the information
17 contained in it that Agent Scullabrene had
18 written that Bernard Nussbaum told him --
19 A That's the first time I ever heard
20 of Agent Scullabrene, and the first time I've
21 seen this document.
22 Q Had you had ever that Hillary
377
1 Clinton had strongly recommended Livingstone
2 for his job?
3 A I had heard people say that, and I
4 had heard any number of people deny it.
5 Q Who did you hear say it?
6 A I don't remember. I'm sure it was
7 on radio or something like that. But at one
8 time it was a -- you know, who hired Craig
9 Livingstone?
10 Q Now, you have talked to the
11 President about the FBI files?
12 A To my knowledge, I never have.
13 Q You talked to the First Lady about
14 it, haven't you?
15 A No, I have not. To my knowledge, I
16 have not. No doubt in my mind, the First
17 Lady wouldn't have anything to do with any
18 such thing.
19 Q Now, as far as your contact with
20 The White House, you care about the longevity
21 of this White House, don't you? You care
22 about its continued existence?
378
1 A Well, I'm sure I do.
2 Q And that's one of the reason why
3 you provide advice, because you care about
4 them?
5 A You know, Mr. Klayman, I have
6 friends over there. I periodically talk to
7 people. I would not -- I don't provide -- I
8 think I like to think of myself more as
9 providing friendship and support more than
10 actual advice. I got my own sort of life I
11 gotta lead.
12 Q I'm sorry. I mean, I'd like to sit
13 down, maybe sometime after everything's all
14 over, and you can tell me the whole story.
15 A I'll tell you now.
16 Q I don't want you to tell me now,
17 because we've got limited time for this
18 round. But my point is, you care whether
19 they continue to exist as the Clinton
20 presidency, correct?
21 A I am a friend and supporter of the
22 President and the First Lady, and I am a
379
1 friend of many people that work there, and I
2 wish them well in all of their endeavors.
3 Q And you have taken a role in terms
4 of starting the foundation to air information
5 about Ken Starr and his investigation,
6 correct?
7 A "Air information"? I just sort of
8 say it.
9 Q What's the name of your foundation?
10 A The Education and Information
11 Project.
12 Q And it's actually incorporated,
13 isn't it?
14 A It is.
15 Q Did Mr. Barnett help you
16 incorporate it?
17 A He did not.
18 Q Who did?
19 MS. MARSH: Objection.
20 Attorney-client privilege.
21 THE WITNESS: Attorney-client
22 privilege, and I'm not getting into that.
380
1 BY MR. KLAYMAN:
2 Q Incorporations are a matter of
3 public record.
4 MS. MARSH: Get it and look at it.
5 THE WITNESS: I'll invoke the
6 attorney-client privilege.
7 MR. KLAYMAN: Certify this.
8 MS. MARSH: Whatever that means.
9 BY MR. KLAYMAN:
10 Q You get money to run that
11 operation, don't you?
12 A Not very much.
13 Q Where do you get the money to run
14 it?
15 MS. MARSH: I object to the line of
16 questioning. It has nothing to do with
17 Filegate.
18 BY MR. KLAYMAN:
19 Q Do you get it from Craig
20 Livingstone? Anthony Marcesa?
21 A Mr. Klayman, I'll let you ask
22 anything you want and let me answer. If I
381
1 testified five times at least today that I
2 don't know Craig Livingstone, that I met him
3 for the first time a week ago, and that I
4 asked Craig Livingstone if he knew me, and he
5 said the only thing that he can ever recall
6 is one conversation, then what would lead you
7 to believe that Mr. Livingstone would give me
8 money? I mean --
9 Q Has any benefactor of
10 Mr. Livingstone given you money?
11 A If I don't know Mr. Livingstone,
12 how would I know?
13 Q Are you aware that he's working out
14 in Laguna Beach, California, for a large
15 Democratic donor?
16 A I am not.
17 Q Have Democratic donors given you
18 money to that institute?
19 MS. MARSH: Objection as to the
20 relevance of this line of questioning.
21 THE WITNESS: Who is the large
22 Democratic donor he's working for?
382
1 BY MR. KLAYMAN:
2 Q Maybe before this is over I'll ask.
3 MS. MARSH: He said he didn't know.
4 THE WITNESS: I'm sitting at the
5 bar of the Palm Restaurant --
6 BY MR. KLAYMAN:
7 Q I don't want to hear it again.
8 A I don't know the man. I don't know
9 who he works for. I don't know anything. I
10 don't know who are his benefactors.
11 Q I asked you who your benefactors
12 were?
13 A Me, mostly.
14 Q You're not going to tell me who
15 they were?
16 A No.
17 MR. KLAYMAN: Certify it.
18 BY MR. KLAYMAN:
19 Q Now, given the fact that you do
20 care about the White House, you do provide
21 advice to it, you did start this foundation
22 to disseminate information about Ken Starr
383
1 and his investigation, isn't it then logical
2 that you talked to the President and First
3 Lady about a matter which you admit is
4 serious such as Filegate?
5 MS. MARSH: Objection. Asked and
6 answered. It also mischaracterizes his
7 testimony. It puts together things that he
8 did not testify.
9 BY MR. KLAYMAN:
10 Q Please respond.
11 A I don't have any -- I have
12 absolutely no doubt. I know the President
13 and First Lady. I don't have to ask them. I
14 know that they had absolutely nothing to do
15 with this.
16 And it appears to me now, after a
17 period of time, that in all likelihood, my
18 belief is the original explanation, is the
19 explanation that seems to me to be most
20 likely. And that is it was some kind of an
21 administrative glitch.
22 But what I will not do is say --
384
1 nor did I, and you can send people out to
2 look: When this thing broke, I would not say
3 that it was not something that was worthy of
4 people asking questions. I thought that it
5 was. But I don't know anything to help you
6 in your lawsuit.
7 Q And in fact, the verdict has yet to
8 come in as to how this happened, correct?
9 MS. MARSH: Objection.
10 Mischaracterization.
11 BY MR. KLAYMAN:
12 Q Based upon what I'm doing, correct?
13 MS. MARSH: Objection.
14 THE WITNESS: I would say that,
15 legally, you know, we would wait to see what
16 the independent counsel says. But I guess
17 it's an ongoing thing of -- I don't know if
18 he ever finishes anything. But maybe he
19 will.
20 BY MR. KLAYMAN:
21 Q Have you ever discussed the
22 Filegate matter with anyone at Williams &
385
1 Connolly?
2 A There's no way that I -- I don't
3 know.
4 Q Mr. Kendall?
5 A I don't know.
6 Q Mr. Barnett, ����?
7 A I don't know.
8 Q This is, in your view, one of the
9 most important controversies still unsettled
10 in the Clinton administration, correct?
11 A Well, I don't know, Mr. Klayman.
12 This is my belief: That the explanation that
13 was proffered originally is the correct one.
14 Because I think if it wasn't, that we would
15 have heard about it from Mr. Starr or
16 something. I really don't know anything
17 about it, but what I have said consistently
18 is that I don't view it as a sort of trivial
19 thing.
20 Q Now, you have the top page of this
21 Jerry Aldrich manuscript. Did you review his
22 manuscript?
386
1 A No.
2 MS. MARSH: Objection.
3 BY MR. KLAYMAN:
4 Q Did you get a copy of Gary
5 Aldrich's manuscript from the White House?
6 A I don't know. I don't know where
7 it came from.
8 Q Anybody ever give it to you?
9 MS. MARSH: The manuscript or this
10 page?
11 BY MR. KLAYMAN:
12 Q Gary Aldrich's manuscript.
13 A To tell you the truth, my wife had
14 him on her show any number of times.
15 Q Have you ever seen a copy of Gary
16 Aldrich's book notated by George
17 Stephanopoulos in his handwriting?
18 A I have not. I don't remember.
19 Q Let's look at the second page,
20 "Acknowledgements."
21 "Southeastern Legal Foundation,"
22 did you circle that?
387
1 MS. MARSH: Which is actually page
2 209, the third page of this exhibit.
3 THE WITNESS: I don't know.
4 BY MR. KLAYMAN:
5 Q Is that your circling?
6 A I don't know what my circling looks
7 like.
8 Q You had a special interest in
9 Southeastern Legal Foundation, did you not?
10 A I probably did.
11 Q Why is that?
12 A Because if memory serves me
13 correctly, they're not particularly strong
14 supporters of the President. But I forgot.
15 My interest in them has probably waned. And
16 I don't know much, but somebody circled it,
17 and I don't know if it was me or not. And I
18 don't know what none of my circles look like.
19 Q Then you have a page beginning,
20 "Gingrich pushes the FBI file story." Where
21 did you get that?
22 A I don't know. It looks like
388
1 something came from the DNC. I don't know.
2 First time I ever saw it. Something came in.
3 Now, I'm sure the same thing -- you get
4 people faxing things all the time, and
5 somebody does it, and I see 3 percent of the
6 stuff that comes over the fax.
7 Q The third thing is "FBI Files:
8 Look What I Found in Mine." Did you clip
9 this article?
10 A I have no idea where it came from.
11 Q Next article is "Three Hundred More
12 Files," Washington Times.
13 Did you obtain that?
14 A If I have it, I must have obtained
15 it somewhere. But I don't -- I generally
16 don't clip Washington Times editorials.
17 Q What do you do with them?
18 MS. MARSH: If anything.
19 THE WITNESS: You know, to tell you
20 the truth, I read the paper when I'm in town.
21 And by and large, I've found that most of the
22 reporters there, when they call me, quote me
389
1 accurately.
2 And I find that it is particularly
3 beneficial, if you want to know what's going
4 on in right-wing politics, that they have a
5 lot of sort of information. And I find them
6 kind of -- if you will, in some instances,
7 that political coverage particularly of the
8 Republicans to be informative. And I don't
9 read it to the same extent I read the Post,
10 but I do read the Times periodically. I also
11 read the Weekly Standard.
12 BY MR. KLAYMAN:
13 Q Based on your experience in
14 Washington, if you want to learn what's
15 happening in right-wing politics, read the
16 Times, correct?
17 A I think they got better coverage.
18 Q And if you want to learn what's
19 happening with the left, read The Washington
20 Post, correct?
21 A I doubt that that would be, but
22 that's your opinion. That's not mine.
390
1 Q Then it says, "White House Agrees
2 to Hand Over Papers," 6/26/96. Is that your
3 handwriting on the top?
4 A No.
5 Q Whose is it?
6 A I have no idea.
7 Q Turn to the next news clip of
8 Donald Lambro, "Clinton's Liberal Backers are
9 Testy." It says 6/29 --
10 A I like him. He's like a friend. I
11 talk to him periodically on the phone, also.
12 MS. MARSH: Actually, it says 6/26.
13 BY MR. KLAYMAN:
14 Q 6/26/96. Is that your handwriting?
15 A That does not look like my
16 handwriting, no, sir.
17 Q "In the Loop: Undercover
18 Operator" --
19 MS. MARSH: What's the number at
20 the bottom? 9 what?
21 BY MR. KLAYMAN:
22 Q By Al Kamen. Where did you get
391
1 this?
2 A I have no idea. None.
3 Q Do you see where it says "Even
4 Livingstone is Fleeing Him," at the bottom?
5 MS. MARSH: Where?
6 BY MR. KLAYMAN:
7 Q Lower left-hand corner: "Even
8 Livingstone is Fleeing Him."
9 Do you see that, Mr. Carville?
10 A Mm-hmm.
11 Q "Meanwhile, seems like all the
12 veteran Clintonites are engaged in strenuous
13 finger-pointing over who was responsible for
14 hiring personnel security chief
15 Mr. Livingstone, I presume."
16 MS. MARSH: Former.
17 BY MR. KLAYMAN:
18 Q "Ever since Craig Livingstone was
19 tagged with having all those FBI files,
20 people have been running from him like he had
21 the plague. Livingstone himself vaguely
22 recalled to investigators that he talked with
392
1 former Cabinet secretary Christine Varney and
2 others about working in The White House."
3 Do you know Christine Varney?
4 A I do.
5 Q Have you ever talked to her about
6 anything involving Livingstone or Filegate?
7 A No.
8 Q George Stephanopoulos' Rometsch
9 statement?
10 A No, I have not.
11 Q "The scandals (old and new),
12 contretemps, seances, and assorted
13 sillinesses are not causing much of a ripple
14 in the polls, although Hillary Rodham Clinton
15 is now taking a lot of heat. Even so, the
16 embarrassments are helping to keep the
17 Clintonites off-balance and are causing some
18 internal churlishness among The White House
19 crew. The normally unflappable and
20 mild-mannered White House spokesman, Michael
21 McCurry, is said to be getting snappy of late
22 throwing some little tantrums with colleagues
393
1 and staff."
2 You read this, didn't you, at the
3 time?
4 A How would I know if I -- I mean, I
5 can't testify that I did or didn't. There's
6 no possible way that I could sit here under
7 oath and tell you I read it. I didn't read
8 it, and I have --
9 Q You brought this to the attention
10 of the First Lady at the time, did you not?
11 MS. MARSH: This article?
12 MR. KLAYMAN: Yeah.
13 THE WITNESS: Of course not. I
14 mean, stop and think. Very little I can be
15 certain of. But that I'd call the First Lady
16 of the United States and say, "Oh, boy, did
17 you see The Washington Post this morning?"
18 BY MR. KLAYMAN:
19 Q You brought this to the attention
20 of the President, did you not?
21 A No, Mr. Klayman, I didn't.
22 Q That Hillary Rodham Clinton was
394
1 taking the heat for the Filegate scandal?
2 A I didn't. I don't know how many
3 times --
4 MR. GAFFNEY: I object to the
5 harassing nature of the questions.
6 THE WITNESS: I second the
7 objection.
8 MR. GAFFNEY: As you know,
9 Mr. Klayman, harassing questions are not
10 permitted under rule 30.
11 THE WITNESS: What is this rule 30?
12 MR. KLAYMAN: It's one that Mr. --
13 I'm sorry, I forgot your name -- Gaffney
14 likes a lot.
15 BY MR. KLAYMAN:
16 Q The statement of William H.
17 Kennedy, where did you get this?
18 A I don't know. Somebody at the
19 White House faxed it to me. Communications.
20 Q Who faxed it to you?
21 A I have no idea.
22 Q Did you discuss this with somebody
395
1 at the White House? You did, didn't you?
2 A I'll sure that I did, because I
3 also went on a TV show with Tony Coelho -- we
4 were on with John Fonda and somebody else,
5 and I suspect that I called someone and said,
6 "Fax this stuff, because I'm getting ready to
7 go on TV," which would be what I think
8 happened. But I can't testify to an absolute
9 certainty.
10 Q And you went on TV to talk about
11 the Filegate scandal?
12 A I did. It's not the Filegate
13 scandal. This is just the Aldrich book, I'm
14 sorry.
15 The statement by Tony Coelho has to
16 do with the Aldrich book, not the Filegate
17 scandal. See? The statement of William
18 Kennedy -- what happened is, it's FBI. So it
19 just was one file in the office. You asked
20 for the file that says Filegate, so we
21 brought this. This is about the Aldrich
22 book.
396
1 Q Look at the first page. "Gary
2 Aldrich's account of a conversation with me
3 about Craig Livingstone" --
4 A Maybe that was cross-referenced.
5 But with Tony Coelho, I think it was about
6 him using Quaaludes or something.
7 Q I didn't ask you about Coelho and
8 Quaaludes.
9 A I think what happened, Mr. Klayman,
10 is they sent me the next seven pages, and my
11 guess is that it was something I had called
12 and ask them to send me, because I was
13 getting ready to go on television. And
14 usually -- I don't know how I sort of saved
15 it. I usually leave this stuff --
16 Q Reading the first page: "Gary
17 Aldrich's account of a conversation with me
18 about Craig Livingstone's suitability for the
19 job of Director of Personnel Security is pure
20 fiction. I never told Aldrich that Mrs.
21 Clinton wanted Mr. Livingstone in that post;
22 I have never had any discussion with Mrs.
397
1 Clinton about Mr. Livingstone. No one else
2 ever told me that Mrs. Clinton had any
3 interest whatsoever in Mr. Livingstone or his
4 position. June 29, 1996."
5 Do you know who wrote his statement
6 of William H. Kennedy?
7 A I assume that it's William H.
8 Kennedy, but I don't know.
9 Q Did you discuss this on TV?
10 A No. You would have to get a tape
11 of the show, but you could find it.
12 MS. MARSH: Can we get some more
13 water, please?
14 MR. GAFFNEY: What time are we
15 shutting down?
16 MS. MARSH: 5 o'clock.
17 BY MR. KLAYMAN:
18 Q Then there's a document here:
19 "White House Improperly Obtained the FBI
20 Files of More Than 600 People, New Documents
21 Show."
22 A The document that you referred to
398
1 is a clip from the Wall Street Journal.
2 MS. MARSH: Wait till he asks you a
3 question.
4 THE WITNESS: Okay. I just wanted
5 to --
6 BY MR. KLAYMAN:
7 Q Whose handwriting is on the top?
8 A I have no idea.
9 Q Next document: "Secret System
10 Computerizes Personal Data."
11 A Right.
12 Q I take it you read this article at
13 the time, correct?
14 A I don't know if I -- I couldn't --
15 no way that I could testify I did or didn't
16 read it.
17 Q Take an opportunity and read it.
18 MS. MARSH: The whole thing?
19 MR. KLAYMAN: Well, he can read it
20 quickly.
21 MS. MARSH: Well, it's three pages
22 long.
399
1 BY MR. KLAYMAN:
2 Q Well, read it.
3 MS. MARSH: Read it all, James.
4 THE WITNESS: I tell you what I can
5 do: I can save you some time. If you don't
6 mind, can I take it to the bathroom and go
7 take a whiz, and I can read it in and out?
8 BY MR. KLAYMAN:
9 Q How long would a whiz take, James?
10 A I go pretty fast. My age, you just
11 can't hold it like you used to be able to.
12 Go early, go often.
13 (Recess)
14 BY MR. KLAYMAN:
15 Q Did you have an opportunity to
16 review this?
17 A I did.
18 Q Mr. Carville, there is a personal
19 computer database in the White House, is
20 there not?
21 A I've never seen it.
22 Q You've heard of it, haven't you?
400
1 A I heard of it now, if this article
2 is right.
3 Q You had heard of it before you saw
4 this article, did you not?
5 A I do remember hearing or reading
6 about it or something like that.
7 Q And you heard about it from inside
8 the White House, have you not?
9 A No. No, not that I remember.
10 Q Who did you talk to about it in the
11 White House?
12 A I don't remember having any
13 conversation about this issue with anybody in
14 the White House.
15 No. Wait a minute. When was this
16 story?
17 Q 6/26/96.
18 A I couldn't -- that's highly
19 unlikely I remember a conversation from
20 6/26/96.
21 Q Yet this article, which was found
22 in your files, you never discussed this with