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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