401 1 anybody in the White House? 2 A Mr. Klayman, I don't remember 3 having a discussion. I may have. I don't 4 remember the discussion, so I'm not 5 testifying that I never had it. I'm 6 testifying that that was something that 7 happened, probably, two years and what, nine 8 months ago? A year and nine? Whatever it 9 is. 10 I don't remember conversations from 11 that period of time, and if I testified that 12 I remember those conversations, it just 13 wouldn't be -- that would be the case. 14 Q But you are aware that there is a 15 database in the White House, are you not? 16 MS. MARSH: Objection. Asked and 17 answered. 18 THE WITNESS: Again, I'm sure I'm 19 aware, because I do remember reading the 20 story about some sort of a database. 21 BY MR. KLAYMAN: 22 Q If there is a database that deals 402 1 with political matters in the White House 2 paid for by taxpayers, would that not be 3 improper, based on your knowledge of what's 4 proper? 5 A Well, Barry Toiv says -- this is a 6 comment of Barry Toiv from the White House: 7 "There's definitely nothing illegal here." 8 Q I asked you. 9 A Well, I don't know what the White 10 House says. If Mr. Toiv's correct, and 11 again, let me just say this: I'm not a 12 lawyer. So I don't know the answer. 13 But if the White House has a thing 14 that they keep records of people that go to 15 social events, you know, if they want to get 16 people on a certain sort of issue, it seems 17 to me to be legitimate use. 18 Q Based on your experience as a 19 Democratic party and political consultant, is 20 it not your view that it would be illegal to 21 have a database in the White House for 22 political purposes? 403 1 MS. MARSH: Objection. He's not 2 going to -- 3 THE WITNESS: I am a political 4 strategist. I'm not a lawyer. I don't know 5 the criminal statutes of the United States. 6 I'm not going to testify to it. I have 7 testified with a great deal of candor that I 8 am not an expert in the law. 9 BY MR. KLAYMAN: 10 Q You are aware that this issue came 11 up during the campaign finance hearings? 12 A I do not remember it coming up. 13 But if you say it did, I'm sure you know what 14 you're talking about. I don't dispute. 15 Q Are you saying you've never 16 discussed with anybody in the White House or 17 outside the White House the issue of whether 18 or not such a database exists? 19 MS. MARSH: Objection. Asked and 20 answered. 21 THE WITNESS: I've already asked 22 and said I don't have a recollection, but I 404 1 can't say that I didn't. 2 BY MR. KLAYMAN: 3 Q I refer to Exhibit 10. This is the 4 Judicial Watch file. 5 MR. GAFFNEY: Would you provide me 6 of a copy of that, Mr. Klayman? 7 MS. MARSH: Again, I would request 8 that the original of the file we just talked 9 about -- 10 MR. KLAYMAN: You can have it now. 11 I'm going to request that it stays in the 12 custody of the court, all the originals. 13 MS. MARSH: On what basis? 14 MR. KLAYMAN: Because that's 15 generally where original exhibits be 16 retained. 17 MS. MARSH: The rules allow -- we 18 told you at the beginning of the deposition 19 there was such a need. 20 MR. KLAYMAN: Why is there a need? 21 MS. MARSH: They're records of 22 Mr. Carville that he uses. They're records 405 1 in his office. 2 MR. KLAYMAN: We're going to ask 3 that they be kept in the custody of the court 4 reporter until we can ask the judge how to 5 deal with it. 6 MS. MARSH: The rules allow us to 7 substitute copies. There's no reason in this 8 case not to do. So you have had a chance to 9 look at the originals and compare them. In 10 fact, you made the copies. It seems to me -- 11 MR. KLAYMAN: Will you keep these 12 copies in a secured place, Ms. Marsh, in your 13 office? 14 MS. MARSH: The originals? 15 MR. KLAYMAN: Yes. 16 MS. MARSH: I can do that, yes. 17 MR. KLAYMAN: I'll agree. But 18 we'll need to conform the copies before you 19 leave to make sure we have all the pages. 20 MS. MARSH: I would assume that you 21 had done that when you copied them. 22 MR. KLAYMAN: No, because we were 406 1 doing it quickly. 2 BY MR. KLAYMAN: 3 Q Looking at this file entitled 4 "Judicial Watch." 5 A I don't have it. Ms. Marsh has 6 mine. 7 MS. MARSH: No. I just have a 8 copy. You should be looking at the one 9 that's marked, which is the one he has in his 10 hand and is carrying away. 11 THE WITNESS: Okay. 12 BY MR. KLAYMAN: 13 Q When was this file made? 14 A I have no idea. 15 Q Whose handwriting is that on the 16 file tab, "Judicial Watch"? 17 A I don't know. 18 Q Do you have files about other 19 public interest groups in your office? 20 A I don't know. All this is sort of 21 pretty recent. I guess they started it 22 when -- you know, there are a number of 407 1 things in it. 2 Q Did you pull anything out of the 3 Judicial Watch file before you came over here 4 today? 5 A No. 6 Q Did anyone else? 7 A No. There would be nothing to pull 8 out. It's all I got. 9 Q Do you have files on press people 10 in your office? 11 A No. 12 Q Do you have files on individuals or 13 entities who are conceived to be adverse to 14 the Clinton administration in your office? 15 MS. MARSH: By whom? 16 BY MR. KLAYMAN: 17 Q By anyone. 18 A I don't know, you know what I mean? 19 I don't know if somebody is, you know, 20 adverse. I mean, it's just the really broad 21 statements. 22 Some people think that 408 1 Mr. Stephanopoulos is now adverse to the 2 Clinton administration or something. 3 Q Why is that? Because he told the 4 truth? 5 MS. MARSH: Objection. He doesn't 6 know why other people think what they think. 7 BY MR. KLAYMAN: 8 Q He's adverse because he told about 9 the Ellen Rometsch strategy? 10 MS. MARSH: Objection. Same 11 objection. 12 Q Is that why? 13 MS. MARSH: Objection. Same 14 objection. He can't testify as to what other 15 people think. 16 THE WITNESS: I must have read ten 17 stories about it. 18 BY MR. KLAYMAN: 19 Q The reason that George 20 Stephanopoulos is considered adverse is 21 because he's now a snitch, right? 22 MS. MARSH: Objection. Same 409 1 objection. We've gone over ���� for hours 2 today. 3 BY MR. KLAYMAN: 4 Q Is that right, Mr. Carville? 5 A Again, there are any number of 6 stories that -- you said "adverse." My point 7 I was trying to make to you is, that is a 8 broad term that I don't have any meaning -- I 9 don't have a way to sort of put it in 10 context. So if I see -- and by the way, I 11 might add, this so-called file that we 12 discuss is a copy of a press release and two 13 news stories. It's hardly anything that -- 14 sort of innocuous. I don't know, you know. 15 Q Who told you that George 16 Stephanopoulos is now adverse to the Clinton 17 administration? 18 MS. MARSH: Objection. 19 THE WITNESS: Well, I said people 20 can characterize it. There was an article in 21 The New Yorker. There was an article in The 22 Washington Post. There was an article in The 410 1 New York Times. There was an article in 2 about everything. 3 I'll be glad to run a Lexis/Nexis 4 and print you a file of things that thick. I 5 didn't say that he was. I was attempting to 6 make the point that the term "adverse" is a 7 very broad term. 8 BY MR. KLAYMAN: 9 Q Who inside the Clinton 10 administration has used the term that George 11 Stephanopoulos is adverse to it now? 12 MS. MARSH: Objection. Assumes 13 facts not in evidence. 14 THE WITNESS: I don't know. 15 BY MR. KLAYMAN: 16 Q Ron Emanuel? 17 MS. MARSH: Objection. 18 BY MR. KLAYMAN: 19 Q Paul Begala? 20 A I've never heard anybody say he's 21 adverse to the Clinton administration. 22 Q He's now done things that are 411 1 harmful? 2 A I testified earlier, Mr. Klayman, 3 that I heard people vehemently object to his 4 use of the sort of Ellen Rometsch thing. I 5 was very up-front about that. 6 Q Have you ever talked about the 7 Ellen Rometsch thing with Torricelli? 8 A No. 9 Q Congressman John Conyers? 10 A No. 11 Q Have you been in contact with them 12 in the last three months, either one? 13 A No. 14 Q Excuse me? 15 A I've not spoken to either one in 16 the last three months. 17 Q Have you received correspondence or 18 sent correspondence to them? 19 A Not that I can remember. 20 Q Have you sent any documents to 21 them? 22 A No. 412 1 Q They send any documents to you? 2 A No. Let me qualify and say not 3 that I can remember. I'll be awfully 4 surprised if they did. I don't know, to tell 5 you the truth if I've ever talked to 6 Congressman Conyers, but I do know Senator 7 Torricelli. 8 Q Excuse me? 9 A I said that I don't know that I 10 know Congressman Conyers. I do know Senator 11 Torricelli. 12 MR. KLAYMAN: I'll show you what 13 I'll ask the court reporter to mark as 14 Exhibit 20. 15 (Carville Deposition Exhibit 16 No. 20 was marked for 17 identification.) 18 BY MR. KLAYMAN: 19 Q Have you ever seen Exhibit 20 20 before? 21 A I'm sure I have, but I don't recall 22 where. It's a pretty full authorizing paper 413 1 by the DNC. I assume it was for general 2 distribution. 3 Q Have you ever seen a document that 4 looks like Exhibit 20? 5 MS. MARSH: Looks like it in what 6 way? 7 BY MR. KLAYMAN: 8 Q Any way. 9 A I have seen any number of times 10 people talk about the Republicans having 11 subpoena power. I don't know that I've seen 12 a document in this detail with as many 13 different people. But let me add, for the 14 record, at the bottom of it, it says, 15 "Authorized and paid for by the Democratic 16 National Committee," so I don't remember 17 seeing it. 18 I do remember seeing any number of 19 quotes by the Speaker about using the 20 subpoena power. 21 Q Look at number 3, where it refers 22 to McCain, Arizona. 414 1 A Mm-hmm. 2 Q Last sentence: "The House Commerce 3 Committee may look into the same allegations, 4 and a private group, Judicial Watch, has 5 filed lawsuits to investigate the Commerce 6 Department." 7 MS. MARSH: Read the whole 8 paragraph, please. 9 BY MR. KLAYMAN: 10 Q Have you read that? 11 A No. So what's your question? 12 Q Have you seen any documents, other 13 than the ones you showed me in the Judicial 14 Watch file that we just identified, that make 15 reference to Judicial Watch, other than the 16 Judicial Watch file and this? 17 A Mr. Klayman, in all honesty, this 18 is probably something that the Democratic 19 National Committee faxed to my office that I 20 never saw and put it in a file. 21 You requested documents from me. I 22 went and conducted a search of the files to 415 1 the best of my ability. I don't know that 2 anything else does or doesn't seem -- and it 3 is a document that is authorized and paid for 4 by the Democratic National Committee, and, 5 you know, I don't know. I mean, it's -- 6 Q Did you give this document to Paul 7 Begala? 8 A If I don't remember seeing it, I 9 can hardly testify that I gave it to 10 somebody. 11 But depending on when the document 12 was made, I'm sure that it got wide 13 distribution, because it says, "Authorized 14 and paid for by the Democratic National 15 Committee." It wasn't like someone was 16 trying to keep it secret. 17 MR. KLAYMAN: I'll show you what 18 I'll ask the court reporter to mark as 19 Exhibit 21. 20 (Carville Deposition Exhibit 21 No. 21 was marked for 22 identification.) 416 1 BY MR. KLAYMAN: 2 Q I'm showing you Exhibit 21. Have 3 you seen this before? It's titled "Selected 4 Investigations of The Clinton 5 Administration." 6 MS. MARSH: If you'd wait till it 7 goes around this way. 8 THE WITNESS: I am almost sure I've 9 seen this. I have seen things that go into 10 the sort of -- but I haven't seen this. 11 BY MR. KLAYMAN: 12 Q Did you give such a document to 13 Paul Begala? 14 A I don't know. I can't testify to 15 that one way or another. 16 Q Mr. Carville, going back to these 17 objections -- let's take them now -- that 18 your counsel provided them this morning. 19 MS. MARSH: You marked them with an 20 exhibit number, did you not? Will you tell 21 us what number that is, please, Mr. Klayman? 22 MR. KLAYMAN: If you'll hold your 417 1 horses there, it's No. 3. 2 MS. MARSH: I think your assistant 3 took all the original exhibits back. I'd 4 like him to look at the original of it. 5 MR. KLAYMAN: He just did, Ms. 6 Marsh. 7 MS. MARSH: Where is it? 8 MR. KLAYMAN: You want to see the 9 number of it? 10 MS. MARSH: No. I want him to look 11 at the one that's been marked. He's the 12 witness. That's what he should be looking 13 at. 14 BY MR. KLAYMAN: 15 Q Let's compare it up against the 16 subpoena. 17 MR. KLAYMAN: Mr. Bustion, why 18 don't you give him the subpoena and let me 19 have a copy of it? I have a copy of it. 20 BY MR. KLAYMAN: 21 Q Look at the subpoena. What exhibit 22 is that? 418 1 A Exhibit Number 3. 2 MS. MARSH: Exhibit Number 1. 3 BY MR. KLAYMAN: 4 Q You didn't go through each one of 5 these document requests with your counsel 6 before you came here today, did you? 7 MS. MARSH: Objection. He's not 8 going to tell you what he went through with 9 me and what he did not. That's attorney 10 client. 11 BY MR. KLAYMAN: 12 Q I'm not asking what was discussed. 13 MS. MARSH: He's not telling you 14 what was discussed, and it bears on 15 discussions that we may or may not have had. 16 MR. KLAYMAN: This was issued to 17 him, not you, Ms. Marsh. 18 MS. MARSH: I understand that. 19 MR. KLAYMAN: Certify it. 20 BY MR. KLAYMAN: 21 Q Did you go through each one of 22 these document requests before you responded 419 1 to the subpoena? 2 A I did. 3 Q Document request number 1 on the 4 subpoena, did you produce documents pursuant 5 to number 1? 6 A I've never had a grand jury 7 subpoena, a congressional subpoena, in my 8 life. 9 Q Again, you didn't check your house 10 in the Shenandoah Valley? 11 MS. MARSH: He checked his house. 12 He testified to that. You're 13 mischaracterizing totally. 14 BY MR. KLAYMAN: 15 Q Did your lawyer check your house in 16 Shenandoah Valley? 17 MS. MARSH: He's not going to 18 testify to that. 19 MR. KLAYMAN: Certify that. 20 MS. MARSH: Certify that and 21 everything else. You know that's improper. 22 it's privileged information, Mr. Klayman. 420 1 MR. KLAYMAN: I didn't ask about 2 you, but I will. 3 BY MR. KLAYMAN: 4 Q Mr. Carville, did your assistant go 5 out to check your house in the Shenandoah 6 Valley before you told him to do that this 7 morning? 8 A When you said that, I called him 9 and said, "You know, maybe there's something 10 there." I said, "Take that document out, go 11 look through there, and see if you can find 12 anything ����." And then I called him out 13 there. You said there could something be out 14 there, you know. I'm going to go out and 15 search it. 16 Q Where did you tell him to look? 17 A I told him to scour the house. We 18 don't have a place that we keep -- it could 19 be something that somebody faxed out there 20 and he was unable to find it. 21 Q How big is the house? 22 A It's big. 421 1 Q How many rooms? 2 A Five, I guess -- wait a minute. 3 Seven, eight. 4 Q Has your assistant ever worked out 5 there with you before? 6 A Yeah. 7 Q What assistant's that? 8 A Todd. Let me start on number 1 9 here. I have never gotten -- 10 Q I'm asking the questions here. 11 Has he worked with you out there? 12 A Yes. 13 Q And when did you make this request? 14 Was it by phone? 15 A Yeah. 16 Q Where did you do that? 17 A Right out there (indicating). 18 Q Where? In the side library room 19 there? 20 A Yeah. 21 Q And when did you hear back from 22 Todd? 422 1 A I said, "Go out there and take that 2 subpoena and conduct a thorough search, 3 because we searched the entire office, and be 4 sure that" -- "and see if there's anything." 5 Q I said, when did you hear from 6 Todd? 7 A An hour ago, I guess. 8 Q When was that? 9 A An hour ago. I don't know. I'm 10 just giving you -- 11 Q During a bathroom break or what? 12 A Yeah. 13 MS. MARSH: On a break that you 14 were on a break as well. He went in and used 15 the phone in the library. 16 BY MR. KLAYMAN: 17 Q How long did you talk to Todd? A 18 few seconds? 19 A Not very long. Man brought up a 20 point. I want to be sure that we -- I think 21 the word I used was "due diligence," and you 22 said was that -- but I'll search myself, too. 423 1 Q You didn't have time to thoroughly 2 inquire with him as to whether he searched 3 every room and every drawer and every file 4 cabinet? 5 A I know Mr. DeLorenzo, you know. 6 He's going to give it a good look. I doubt 7 if I'd look in the kitchen cabinet for this 8 kind of stuff myself. If you want to go 9 through each one of them -- 10 Q Are there any other documents that 11 you brought to the deposition today that 12 haven't been produced? 13 MS. MARSH: Nonresponsive to the 14 subpoena. 15 MR. KLAYMAN: There are other 16 documents, Ms. Marsh? 17 MS. MARSH: Yes, documents I 18 brought. 19 MR. KLAYMAN: Are they documents 20 that were gathered in searching for documents 21 requested by the subpoena by Mr. Carville? 22 MS. MARSH: No. 424 1 BY MR. KLAYMAN: 2 Q Now, you've written a book, haven't 3 you? 4 A I have. Two of them. Well, half 5 of one and another one. 6 Q In those books, did you ever make 7 reference to Filegate? 8 A I doubt. The other one came out -- 9 they both come out before it came -- that one 10 was published in March of '96. 11 Q Did you ever make reference to 12 doing opposition research in those books? 13 A Could be. Show me "All's Fair." 14 I'll be glad to -- 15 MR. KLAYMAN: Will you let the 16 witness answer, Ms. Marsh, please? 17 MS. MARSH: I'm trying to make a 18 suggestion to make this go faster. If you 19 throw him the book, he can look in the book 20 and let you know quickly. 21 MR. KLAYMAN: I'm referring to the 22 book "All's Fair," Mary Matalin and James 425 1 Carville. It's the photograph section in the 2 middle, and we'll mark it. We'll mark it as 3 Exhibit 22, with the page as Exhibit 22-A. 4 (Carville Deposition Exhibit 5 No. 22 was marked for 6 identification.) 7 BY MR. KLAYMAN: 8 Q And it says here, "In the 'War 9 Room' in Little Rock, speechwriter Michael 10 Waldman; George Stephanopoulos, director of 11 communications; James; and Diane Blair, 12 campaign researcher; (rear) Roger Martin, 13 researcher; and Heidi Chapman, press 14 assistant." 15 So the two researchers, Diane Blair 16 and Roger Martin? 17 A Right. Diane Blair, as I testified 18 earlier, did all of the work on the 19 Governor's Arkansas record. It was her 20 almost sole role in the campaign. She is a 21 teacher. She teaches a class at the 22 University of Arkansas, and I became a very 426 1 close friend of hers. That was her job. 2 But Roger Martin, I remember -- 3 well, we did a variety of sort of things. He 4 was sort of the younger kind of war-room 5 type. 6 Q And they gathered information on 7 opponents and those that spoke out against 8 the administration, correct? 9 A You know, Mr. Klayman, it's your 10 time. It's your nickel. I testified twice 11 that Diane Blair's job was to gather 12 information about the governor's record as 13 Governor of Arkansas, and that was -- her 14 sole was gathering information about the 15 then-Governor Clinton. 16 Q Now, during the course of your 17 professional life, you have taken notes, have 18 you not, Mr. Carville? 19 A No. I never took notes in college. 20 I can't even read my own handwriting. 21 Q Do you use a computer now? 22 A As I testified earlier, there's a 427 1 better chance I could turn on a 747 than a 2 computer. I am not a person that has ever 3 been given to that kind of thing. I've 4 always said that the shortest book ever 5 written would be to select the complete 6 memoranda of one J. Carville. 7 Q Have you ever tape-recorded 8 someone's telephone conversation with their 9 permission? 10 MS. MARSH: About anything or any 11 person? 12 MR. KLAYMAN: About anything. 13 MS. MARSH: I don't think that's 14 relevant. 15 BY MR. KLAYMAN: 16 Q You can respond, with their 17 permission. 18 A I'm sure I have. That's not 19 something that I do as a matter of course. 20 Q And you've kept those tapes? 21 A I doubt if I -- you know, more 22 often than not someone -- when I have a 428 1 conversation, oftentimes, with a reporter, 2 they will, you know, ask if it's okay to sort 3 of tape a conversation. That's not -- I 4 don't have -- this is not something we sort 5 of do. 6 Q But you have kept those tapes? 7 A No, sir. 8 MS. MARSH: He just testified he 9 had not. 10 BY MR. KLAYMAN: 11 Q Have you ever had a discussion with 12 President Clinton about what skeletons he 13 might have had in his closet, ever? 14 MS. MARSH: Objection. Asked and 15 answered. 16 THE WITNESS: I guess in 1992 I 17 did. 18 BY MR. KLAYMAN: 19 Q And what did he tell you? 20 A I don't remember. 21 Q Not important? 22 A I don't remember. If I don't 429 1 remember, I don't know whether it's not 2 important. 3 Q Was it anything to do with women? 4 MS. MARSH: Objection. Asked and 5 answered ad infinitum this morning. 6 THE WITNESS: It's 5 o'clock. 7 BY MR. KLAYMAN: 8 Q Have you ever recommended anyone 9 for a White House job? 10 A I'm sure that there were campaign 11 people that I recommended. There would have 12 to be. I mean, well, many of the people have 13 got White House jobs who didn't really need 14 my recommendation. But some of the people, 15 you know, sort of mid-level people or 16 something, I probably recommended. 17 Q Did you ever meet Bernie Nussbaum? 18 A I have met Bernie. I don't think 19 I've ever had a phone conversation with him, 20 or I haven't talked to Bernie in, I would 21 guarantee, the last four or five years. 22 Q Close friend of the First Lady, 430 1 though, right? 2 A He is. 3 Q Did you ever talk to Bernie about 4 Filegate? 5 A No. I haven't talked to Bernie 6 since June of 1996. 7 Q Have you ever talked to any of Mrs. 8 Clinton's secretaries or chiefs of staff 9 about Filegate? 10 A Not that I can remember. 11 Q Have you ever been advised that any 12 of the documents taken out of Vince Foster's 13 office had anything to do with Filegate? 14 A No, sir. 15 Q Who made the decision to revoke 16 your White House pass other than Mr. Panetta? 17 Do you know of anyone else who played a role? 18 A I do not. 19 Q You are aware that there's an FBI 20 file on you? 21 A I'm not surprised that there is. 22 Q You've asked to see it? 431 1 A No. I don't have that much time to 2 read that much, Mr. Klayman. 3 Q You wouldn't want that released 4 publicly, would you? 5 A I would not. 6 Q Have you ever had any discussions 7 about the firing of the White House travel 8 office with anyone in the White House or 9 anywhere else? 10 A Oh, I mean I -- you know, I'm sure 11 that I had discussions. When I first heard 12 of that, I don't exactly where I was. In 13 ����, Pennsylvania, riding in a car with 14 Governor John Sununu. 15 Q And what did you say? 16 A I said, "What is this?" I didn't 17 know what the travel office was or anything. 18 I was asking him. 19 Q Have you ever had any discussions 20 with the President about the firing of Billy 21 Ray in the travel office? 22 A No. 432 1 Q The First Lady? 2 A No. 3 Q With anyone in the White House? 4 A I'm sure I have. 5 Q Who? 6 A I don't remember but any number of 7 people. 8 Q Have you ever conducted any 9 research on senator Fred Thompson, you or 10 your staff? 11 A I never have. 12 Q Jesse helms? 13 A No. 14 Q Do you know of anyone who has 15 conducted research on Fred Thompson? 16 A No. I'm sure that somebody at the 17 DNC has. I'm sure who ran against him for 18 the senate. 19 Q Judge Sentelle? 20 A Somebody sent me something out of a 21 sort of, you know, directory of American 22 judges or something like that. But that's 433 1 about it. That's not the title of it, but 2 it's one of those kinds of things. 3 Q Who sent that to you? 4 A I don't even remember, but I do 5 remember -- 6 MR. KLAYMAN: Just wait. 7 (Discussion off the record) 8 BY MR. KLAYMAN: 9 Q Who sent you that information about 10 Judge Sentelle? Where did it come from? 11 A I remember seeing something from a 12 thing. There's a book that they put out, 13 like a biography of different judges. 14 Q Jesse Helms? 15 MS. MARSH: You already asked about 16 that. 17 THE WITNESS: I don't have any -- 18 BY MR. KLAYMAN: 19 Q Anybody send you any information 20 about him? 21 A Not that I can remember. You know, 22 it's sort of possible. I haven't been much 434 1 involved in North Carolina politics. 2 Q Dig some information up on him 3 yourself? 4 A No. 5 Q ����? 6 A ����, you mean? 7 Q Yeah. Chris Matthews? 8 A Chris, that talk show Chris 9 Matthews? 10 Q Yes. 11 A No. 12 Q Susan ���� 13 A No. 14 Q Chris Ruddy? 15 A No. 16 Q ���� Goldberg? 17 A No. 18 Q Monica Lewinsky? 19 A No. 20 Q Dan Burton? 21 A Yeah. 22 Q Where did you get information about 435 1 Dan Burton? 2 A Well, I know that I got -- I read 3 an article about shooting up watermelons or 4 cantaloupes or something like that, and -- 5 MR. GAFFNEY: Are we done, Jill? 6 MR. KLAYMAN: We'll attach as 7 Exhibit 22 a letter from David S. Cohen, who 8 walked off with the original Exhibit 11. He 9 says he's sending it back by Federal Express. 10 MS. MARSH: What is Exhibit 11, do 11 you recall? 12 MR. KLAYMAN: I ask this be marked 13 Exhibit 22. 14 (Carville Deposition Exhibit 15 No. 23 was marked for 16 identification.) 17 MS. MARSH: If we have copies of 18 these, we can leave the originals with you, 19 as long as I have copies of all of them. And 20 I think they were all marked, were they not? 21 I'm leaving the originals with you. 22 I just need copies, that's all. 436 1 MR. GAFFNEY: That's 23. 2 MR. KLAYMAN: Twenty-three, excuse 3 me. 4 Before we break, we are going to 5 leave this deposition open. 6 MS. MARSH: And we will object. 7 You gave us a time of six hours. Six hours 8 you got. 9 MR. KLAYMAN: For the reasons set 10 forth on the record, particularly with regard 11 to documents and objections and matters of 12 that nature. 13 MS. MARSH: We will object. 14 (Whereupon, at 5:03 p.m., the 15 deposition of JAMES CARVILLE was 16 continued.) 17 * * * * *
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