251
1 A My recollection is that she came to
2 see me, that she didn't really know anyone
3 else. That's my recollection.
4 Q What did she come to see you for?
5 A It was in -- it was within -- my
6 recollection is it was within, you know, a
7 week or so of the time that she began at the
8 White House and I don't recall what brought
9 her there. It might have been like a trans
10 -- I believe it was something like Paul
11 wanted to know if I -- if you guys could find
12 a transcript or something like that. And
13 then I also just sort of talked her in and
14 said welcome, you know, are you getting along
15 okay, how are you doing, that kind of thing.
16 Q So to ask those kind of questions
17 you must have known her from before?
18 A No, I don't -- I disagree with
19 that.
20 Q Do you ask people you've never met
21 before how are you doing?
22 A Certainly. Someone who is new on
252
1 their job I would certainly -- I would hope
2 anyway -- attempt to say hello and find out
3 how -- if they were okay, if they --
4 Q Has she been in your office in the
5 last few months?
6 A I couldn't answer for sure. I
7 personally don't remember the last time she
8 was in the office, but I'm -- it's very, very
9 possible that she would come in to the
10 office.
11 Q In fact, she's in there quite
12 frequently, is she not?
13 A That's your characterization. I
14 just said I can't recall seeing her in the
15 office recently.
16 Q How many times is she in the office
17 per week, roughly speaking?
18 A Again, I disagree with the premise.
19 I think there may be, you know, may be weeks
20 that go by that she's not in there at all or
21 she may come in more than that or she may
22 come in, frankly, like I said when I'm not
253
1 there. I'm out at a meeting. I guess I
2 can't answer for that. I can't answer for
3 how often Stacey Parker comes into Suite 197.
4 Q Is she friendly with anyone in the
5 office besides you at this point? Does she
6 come in to see Glen Weiner or come in to see
7 Robin or Ann Walker or Brenda Costello?
8 A I can't answer for all of those
9 people actually. I -- I don't know.
10 Q You are aware that --
11 A I think that she, generally, knows
12 people other than me in my office after
13 having been there, but I can't speak to --
14 Q You are aware that Paul Begala was
15 previously the political consulting partner
16 of James Carville, correct?
17 A Certainly.
18 Q You are aware that Paul Begala
19 knows Glen Weiner, correct?
20 A I'm sure he does, yes.
21 Q And so, therefore, Stacey Parker
22 has come into the office to see Glen Weiner
254
1 from time to time, correct?
2 A I -- I just don't want to get
3 confused between what I've read and what I
4 know myself independently. It wouldn't
5 surprise me in the least if -- of Stacey knew
6 Glen after having been here for a little
7 while and would be just as willing to ask him
8 for a transcript as she would be to ask me
9 for a transcript because I'm less -- I'm in
10 the office less.
11 Q In fact, Stacey has gone into your
12 office from time to time to get information
13 which James Carville has sent to Glen Weiner,
14 which is then taken back to Paul Begala?
15 Isn't that the case?
16 A I certainly don't think that that's
17 accurate. The only example, which,
18 obviously, again, I've read here and I
19 vaguely recall is the press release. That's
20 the only occasion in which I can think of
21 something that came in, I now understand that
22 came from Carville.
255
1 Beyond that, I think, as I earlier
2 testified, I have no recollection of anything
3 coming from Carville's office to my office.
4 Q Have you ever seen that press
5 release?
6 A I did glance at it, yes.
7 Q When did you see it?
8 A I couldn't give you the date.
9 Whenever date it was that you all issued it.
10 I -- my -- I saw it on that day.
11 Q Who brought it to your attention on
12 that day?
13 A Glen.
14 Q Where did Glen say he got it?
15 A I honestly don't recall. I can't
16 say. He didn't tell me where he got it.
17 Q You know it came from Mary
18 Matalin's radio show, don't you?
19 A Again, I have no knowledge of that.
20 I think I read that somewhere in here, but --
21 Q Where did you read that?
22 A In one of the depositions.
256
1 MR. KLAYMAN: I'll show you what
2 I'll ask the court reporter to mark as
3 Exhibit 4. It is the press release.
4 (Janenda Deposition Exhibit
5 No. 4 was marked for
6 identification.)
7 BY MR. KLAYMAN:
8 Q This is the press release which
9 Glen Weiner showed you, is it not?
10 A I'll take your word for it. I
11 believe it is, yes.
12 MS. GILES: Why don't you read
13 through it and make sure.
14 THE WITNESS: I mean I believe the
15 headline is the same, which is about all I
16 looked at, and I believe the date is about
17 right. I can't say that it's the same copy
18 or that it had the same fax markings, but it
19 appears to be the same -- in content the same
20 press release.
21 BY MR. KLAYMAN:
22 Q It's not the first time that Glen
257
1 Weiner showed you something that Carville had
2 sent to him, is it, this press release?
3 A Is the -- at the time I don't
4 believe I was aware of it, but since the
5 time -- I would say it is the only time I can
6 recall that he showed me something that came
7 from James' office.
8 Q You are aware, however, that he
9 received materials from James' office from
10 time to time?
11 A No, I think I already testified
12 that I'm not aware of that.
13 Q Have you talked to Stacey Parker in
14 the last two months?
15 A I probably have. I mean I probably
16 have gone into his -- you know, gone into
17 Paul's office on some time in the past two
18 months and --
19 Q What caused you to go into Paul's
20 office?
21 A I -- I don't know that I can recall
22 a specific time or reason. I'm just saying
258
1 that I'm -- in the normal course of a week it
2 wouldn't be out of the ordinary for me to pop
3 into his office and run into Stacey.
4 Q Why did you go to his office?
5 A I think I've already answered the
6 question.
7 Q I didn't hear. Why specifically?
8 A I said I didn't have a specific
9 recollection, but that I'm sure it wouldn't
10 be uncommon for me to pass by, you know, to
11 go into Paul's office on an occasion during
12 the week to, you know, drop off something or
13 whatever. It wouldn't be out of the ordinary
14 that I would run into Stacey.
15 Q In the whole course of your working
16 in the White House can you ever remember one
17 reason why you went to Paul's office?
18 A I can't. I'm sorry. I mean --
19 Q Have you ever visited the office of
20 Charles Ruff?
21 A I've been in his office before,
22 yes.
259
1 Q On what occasion?
2 A I think it was -- I think the only
3 time I've ever been in his office was -- was
4 around the time of the videotapes of the
5 White House, WACA tapes or something like
6 that.
7 Q Why were you there?
8 A Because I had --
9 Q You can respond.
10 MS. GILES: Actually can you wait a
11 minute? I want to make sure there's no
12 privileged information. Can we go off the
13 record for a minute?
14 MR. KLAYMAN: Do you want to take a
15 break? Let's take a five-minute break.
16 VIDEO TECHNICIAN: We're going off
17 video record at 2:15 Eastern Standard Time.
18 (Recess)
19 VIDEO TECHNICIAN: We're back on
20 video record at 2:25 p.m. Eastern Standard
21 Time.
22 BY MR. KLAYMAN:
260
1 Q The question that was pending dealt
2 with whether you visited Mr. Ruff's office.
3 A Yes, sir.
4 Q And why? Why did you visit his
5 office?
6 A As I said, I believe I was in his
7 office on one occasion for 15 or 20 minutes
8 in a -- in a meeting discussing as to how it
9 was that the -- that the -- I don't know if
10 I'm referring to it correctly, but the
11 videotapes that had been discovered, as to
12 how they were going to be logistically turned
13 over the next day to the press and to the --
14 to the committee -- to the relevant
15 committee.
16 Q Was that something that your office
17 was involved in?
18 A No, sir.
19 Q Then why were you there?
20 A I was asked at the last minute
21 because it was something that came up so
22 quickly and there was so much material to go
261
1 through in a short period of time and what
2 the priority was, the best of my
3 recollection, my recall, was we want to go
4 through this stuff and get -- get it out and
5 what's -- how do we do that. And I was
6 called as an extra set of eyes to watch some
7 of the -- some of the actual tapes.
8 MS. GILES: Beyond that I'm going
9 to object on relevancy to the subject matter.
10 I wanted him to say enough so you knew what
11 the subject matter was and you can ask if FBI
12 files or government files were discussed, but
13 other than that, the topic is not relevant to
14 this deposition.
15 BY MR. KLAYMAN:
16 Q Did you hire Glen Weiner for a
17 position in your office?
18 A Technically I don't know whether I
19 hired him or someone else hired him, but the
20 intent of the question, yes, I'm the one who
21 wanted him to be hired in my office.
22 Q And at the time you knew he had
262
1 been working with James Carville?
2 A Yes, sir.
3 Q And the reason you wanted him hired
4 is because he had been doing opposition
5 research for James Carville, had some
6 experience?
7 A No, sir.
8 Q You are aware that Mr. Carville
9 wanted him hired and placed in your office?
10 A No. In fact, I don't believe
11 that's true or accurate.
12 Q Then what is true and accurate?
13 Why did you want Mr. Weiner in that office?
14 A Why did I want him?
15 Q Why did anybody want him in that
16 office?
17 MS. GILES: He can only testify to
18 as his own personal knowledge.
19 BY MR. KLAYMAN:
20 Q All right. Well, let's start with
21 you. Obviously everything is based on your
22 own personal knowledge.
263
1 A I wanted him because I worked with
2 him previously and I thought very -- and
3 continue to, to this day, to this minute,
4 think very highly of him and his intellect
5 and his ability, and his writing ability and
6 I just -- I enjoy him as a person and think
7 he's good at his, you know, at research.
8 Q Now, you are aware that James
9 Carville has threatened and, in fact, stated
10 that he's waging war against Ken Starr,
11 correct?
12 A Am I aware of that? Yeah, I -- I
13 believe I remember when he said that on some
14 T.V. show and it got a lot of attention.
15 Q And you're aware that James
16 Carville has threatened to break Starr's
17 kneecaps, correct?
18 MS. GILES: Objection.
19 THE WITNESS: No, I'm not actually.
20 BY MR. KLAYMAN:
21 Q You never heard that?
22 A No, I didn't.
264
1 Q I'll show you what I'll ask the
2 court reporter to mark as Exhibit 5. It's a
3 "Meet the Press" interview of James Carville
4 on January 25, 1998?
5 Strike Exhibit 5. We're going to
6 substitute something.
7 Remark this as Exhibit 5. It's,
8 "Carville: I Zapped Starr's Charges." I
9 provide you and your counsel and counsel for
10 Mrs. Clinton a copy of this.
11 (Janenda Deposition Exhibit
12 No. 5 was marked for
13 identification.)
14 BY MR. KLAYMAN:
15 Q Take a look at this, Mr. Janenda.
16 Take your time, read it. I turn your
17 attention to the second page, third and
18 fourth paragraphs, where it states, and this
19 is quoting Carville, "He's one more mistake
20 away from not having any kneecaps, Carville
21 chortled. Carville was particularly incensed
22 over weekend charges by Starr's defenders
265
1 that Carville's activity may verge on
2 obstruction of justice." Do you see that?
3 A Yes, I do.
4 Q Now, this refreshes your
5 recollection that Mr. Carville threatened to
6 break the kneecaps of Ken Starr, correct?
7 A No, sir, it's, I believe, the first
8 time I've seen this comment, so it doesn't
9 refresh my recollection.
10 Q You've never heard of this comment
11 before?
12 A I don't remember it, no.
13 Q Now, you had heard the comment
14 about waging war on Starr before you hired
15 Glen Weiner, correct?
16 A I don't know whether that's
17 accurate or not. I hired Glen or Glen
18 started working in August of 1997. I have no
19 idea whether L that was prior to or before.
20 Q You were aware, however, before you
21 hired Mr. Weiner of Mr. Carville's reputation
22 for threatening perceived adversaries of the
266
1 Clintons?
2 A I would disagree with your
3 characterization. He's an outspoken
4 supporter of the President certainly.
5 Q You were aware that he had made
6 threats before, though, were you not?
7 A Again, I don't -- no, I mean to be
8 totally accurate, I'm not aware of threats.
9 I'm aware that he's a vocal defender and
10 supporter of the President.
11 Q Did it cause you any concern to
12 hire Mr. Weiner and put him in your office
13 given his prior association with
14 Mr. Carville?
15 A Not in the least, no.
16 Q Why not in the least?
17 A Because he was being hired, you
18 know, as a quality individual, as a good
19 researcher, someone whose integrity I held
20 very highly and had nothing to do with his
21 previous job.
22 Q Have you ever instructed Mr. Weiner
267
1 not to provide White House information to
2 Mr. Carville or others?
3 A I can't say that I recall that, no.
4 Q To the best of your knowledge,
5 Mr. Carville does not work for the White
6 House, does he?
7 A No, sir.
8 Q So you placed no restriction on
9 Mr. Weiner sending materials to Mr. Carville?
10 A I don't know that I -- it ever was
11 an issue. I don't -- I don't recall.
12 Q Did you or did you not instruct
13 Mr. Weiner do not send materials to
14 Mr. Carville?
15 A I don't recall. I may have when he
16 started. I don't recall it. That's my
17 testimony. I don't recall having done so.
18 Q I take it you received
19 recommendations from Mr. Weiner when he was
20 being considered for a job in your office?
21 A I'm sorry?
22 Q I take you received recommendations
268
1 from Mr. Weiner, references.
2 A References?
3 Q Yes. Before you hired him?
4 A No, I don't believe so, no. I knew
5 him personally very well. That's why -- as I
6 stated.
7 Q One of the things you found
8 attractive about Mr. Weiner was his
9 association with Mr. Carville, was it not?
10 A No, sir.
11 Q How long do you intend to stay in
12 your present position?
13 A I couldn't give you an answer to
14 that. I don't know.
15 Q Do you have plans to have a career
16 in politics?
17 A I don't -- I don't know what my
18 future plans are. I really haven't had a lot
19 of time to think about it, so, no, I have no
20 intention of having a career in politics, no.
21 Q Have you expressed to Mr. Weiner
22 what you would like to do after you finish
269
1 this job, or anybody in your office? Have
2 you ever told them gee, I'd like to run for
3 congress or some day be a senator or anything
4 like that?
5 A I'm sure we've had many -- I mean
6 I'm friends with them and it certainly could
7 have come up where we had a similar
8 discussion, but I cannot recall having said
9 any of those specific things.
10 Q Well, what did you tell them about
11 what you think you would like to do in the
12 future?
13 A I'm not saying that I did have that
14 conversation. I'm saying --
15 Q Have you ever expressed to anyone
16 what you think you'd like to do in the
17 future?
18 A I've expressed probably to tons of
19 people, you know, a lot of people over the
20 last whatever years ideas I had about the
21 future, sure.
22 Q And what have you expressed about
270
1 what you think you'd like to be doing after
2 you finish with this job?
3 A I just want to be clear. Is
4 this -- you really want to know what I want
5 to do with my life? Is that --
6 Q Yeah.
7 A I don't know. I'm trying to decide
8 whether I want to move back to New England,
9 whether I want to stay in Washington, if I
10 might want to work on the Hill or if I'm
11 really sick of politics and all of the crap
12 that is often associated with it and if I'm
13 ready to get out. That's the generic
14 conversation I've probably had.
15 Q Is the reason you're thinking about
16 moving back to New England so you can
17 establish a base to maybe run for office some
18 day?
19 A No. Have I considered it? Has it
20 ever popped into my mind or have I ever said
21 it to anyone? Is that your question?
22 Q Yeah.
271
1 A Sure I may have said that.
2 Q Specifically what office would you
3 like to run for?
4 A I have no idea whether I will ever
5 run for anything. I may have mentioned to
6 someone it was one of six or eight options or
7 things I had occasionally passed through my
8 head, but I have no plans to run for any
9 office.
10 Q Well, I'm just asking what
11 particular office did you mention to somebody
12 else that you would like to seek?
13 A I have no specific recollection,
14 you know, of such a conversation.
15 Q How about a general conversation?
16 A No, I don't. Run for office
17 generically.
18 Q As a democrat?
19 A I certainly would, yes, if I were
20 going to run.
21 Q Have you ever gone to lunch or had
22 any conversation with Mr. Carville about what
272
1 you do in the communications research office?
2 A No, sir.
3 Q Have you ever gone to lunch or had
4 any meeting with Mr. Weiner and Mr. Carville?
5 A No, sir.
6 Q Within the last six months have you
7 had any telephone conversations with
8 Mr. Carville?
9 A None that I have any memory of. I
10 don't believe I have, no.
11 Q Have you seen him in the office
12 during that period?
13 A In my office?
14 Q Yes.
15 A No.
16 Q Have you seen him in the White
17 House during that period?
18 A As I said, let's think about six
19 months here. As I -- I think I said earlier,
20 the last time I can remember seeing him other
21 than on T.V. maybe was I think I saw -- yeah,
22 I saw him at a White House Christmas party.
273
1 Q Have you or anyone else in your
2 office had any contact with the defense
3 department in the last year?
4 A Would you define contact?
5 Q Written, oral, whatever.
6 A Again, it's so broad. I mean I was
7 certain we may have like gone on to their Web
8 site or something or if the President were
9 doing an event that were somehow related, we
10 may have maybe. But I have no recollection
11 of -- I personally don't recall having
12 directly spoken with anyone, no.
13 Q Have you or anyone in your office
14 ever gone on Judicial's Watch's Web site?
15 A I don't believe I have. I think
16 Glen did on the day that you put out your
17 press release.
18 Q How do you think that?
19 A Because my recollection is that --
20 that he showed this to me and it wasn't much
21 of a -- better of a copy than the one that
22 you've handed me here and he was confused as
274
1 to whether it was actually a -- like a real
2 press release or -- I think -- my
3 recollection is that the gist of our
4 conversation was what do -- what do -- again,
5 nothing flip intended here, but what do
6 Begala and Carville have to do with Filegate.
7 This must be wrong. And I think I said to
8 him or he said in my presence I'll check on
9 the Web site and see if this is actually
10 something that they put out today.
11 Q Well, what would lead you to
12 believe that they don't have something to do
13 with Filegate?
14 A Just by nature of the fact that
15 neither of them were working at the White
16 House during the time that it occurred was my
17 reaction -- my gut reaction when I saw it.
18 Q Well, what is your understanding of
19 Filegate? Why would that be limited to
20 people who worked at the White House based on
21 your understanding at the time?
22 A I mean based on what I've read in
275
1 the paper, it was something that happened or
2 whenever -- allegedly happened within the
3 White House years ago. I mean I --
4 Q Have you ever heard of a Clifford
5 Bernanth, B-E-R-N-A-N-T-H?
6 A The name does not ring a bell, no.
7 Q Have you ever gone up on the Web
8 site of Matt Drudge.
9 A Probably, yeah. Yes.
10 Q Who asked you to go up on his Web
11 site?
12 A I don't think anyone would ever
13 tell me to do that, no.
14 Q Why did you go up on the Web site?
15 A It would be in the nature of -- a
16 typical morning of my workday would be to
17 attempt to read everything and to know and to
18 anticipate what was going to be in the news
19 that day. And at various points if I think
20 to check his Web site, he's certainly been
21 one of the source of some things that have
22 been prominent in the news, so --
276
1 Q Why is it important for you to know
2 what the news is on any particular day?
3 A Because I consider it to be part of
4 my job as research director within the
5 communications office to do my best and to
6 have my staff to their best to anticipate
7 things that may come up as questions during,
8 you know, the course of a day.
9 Q And that would be --
10 A And -- and, generally, to know
11 what's going on in the world.
12 Q And that would be on any issue,
13 correct?
14 A Sure.
15 Q Your job is to be informed so you
16 can react and get information relevant to
17 what's in the news that day?
18 A Depending on the issues.
19 Q In fact, your communications
20 office, communications research office is the
21 modern day equivalent of the war room,
22 correct?
277
1 A No, sir, that's your
2 characterization.
3 Q Is there something that serves in a
4 function similar to the war room in the White
5 House or elsewhere currently?
6 A Or elsewhere? Not currently to my
7 knowledge, no.
8 Q But your office is to be able to
9 obtain information quickly upon request; is
10 that not the case?
11 A Generically speaking, sure, that's
12 one of the roles, but I think I already
13 described to you that the -- the bulk of the
14 work of my office is to track the
15 administrations record, to take care of
16 vetting of people who are coming to the White
17 House, to help prepare paper for Presidential
18 events and to, generally, be aware of, you
19 know, what's in the news or something that
20 people might get asked about.
21 Q What are the various sources that
22 your office would consult with to gather
278
1 information quickly in a news event? What do
2 you typically use besides Nexis? I know you
3 identified that. What would you use besides
4 Nexis?
5 A The press clips that I described to
6 you that are delivered every morning. We
7 usually attempt to read those, you know,
8 relatively early because most people don't
9 have time to do that. So if there were
10 something in there that, you know, we thought
11 people might not have caught, we would raise
12 that.
13 I mean it could be something about
14 education that was happening on the Hill that
15 we think people might -- we would make sure
16 that the person dealing with education would
17 be aware of it.
18 Certainly there are Web sites, as
19 I've described them, that we would -- I don't
20 know that there's a list per se, but, you
21 know, CNN's Web site you would just check to
22 make sure there wasn't something new or
279
1 breaking that people should be aware of.
2 Q What other Web sites would you tap
3 into in the ordinary course of what your
4 office does?
5 A I don't know that it's fair to say
6 that there's an ordinary -- that there's sort
7 of an established like these 10 sites or
8 something like that.
9 Q Well, name some that you know that
10 your office has consulted with.
11 A Definitely CNN Web site, the
12 other -- some of the other networks have Web
13 sites, you know, MSNBC. What else? I don't
14 know. A news -- news outlets. I mean those
15 are the ones I can think of that we would
16 sort of keep an eye on or attempt to check.
17 Q EIP, Carville's group, has a Web
18 site?
19 A I'm sorry. And I -- before I go
20 on, I already mentioned that the Drudge
21 report is something that you might
22 occasionally check.
280
1 Q And Salon Magazine?
2 A Possibly, yeah.
3 Q How did you learn that Salon had a
4 Web site?
5 A How did I learn that they had a Web
6 site?
7 Q Yeah. You or anyone else in your
8 office to the best of your knowledge.
9 A I didn't think it was a big secret.
10 I'm not trying to be flip, but I -- I don't
11 know. I mean it's just another news source.
12 Q Is that something that Sidney
13 Blumenthal bought to your office's attention?
14 A No, sir.
15 Q You sometimes go into EIP, James
16 Carville's Web site, do you not?
17 A I'm actually not aware that he has
18 one or if he has one and I have never
19 attempted to log on to it, if he does have
20 one.
21 Q Has your office ever been asked to
22 do any research on Mike Emmick, a deputy to
281
1 Ken Starr?
2 A No, sir.
3 Q Bruce Udolfe, another Starr deputy?
4 A No, sir.
5 Q Any member of Starr's staff?
6 A I don't believe so, no.
7 Q But requests can come in that don't
8 go to you; is that not the case? I mean
9 requests can be made to Weiner or to --
10 A No, I -- I mean that is possible.
11 I mean I am generally aware of requests.
12 Now, if someone -- again, if someone just
13 were looking for a news clip or a transcript
14 and I weren't around, certainly could -- they
15 might just ask someone else in my staff.
16 In terms of anyone taking on a
17 project that they were going to do work on, I
18 don't believe that happens without my
19 knowledge.
20 Q Is there a procedure how things
21 that come into the office are routed to you
22 first?
282
1 A I don't think there's a procedure.
2 I think people in the White House generally
3 attempt to call me before they would call
4 someone on my staff.
5 Q But you wouldn't know, for
6 instance, if James Carville was calling in to
7 Glen Weiner and asking him to do research?
8 There's no procedure that would say that
9 Carville would have to talk to you before
10 Weiner talked to him, correct?
11 A I'm not aware of any research that
12 Glen has ever done for James Carville.
13 Q You didn't answer my question.
14 A What is your question?
15 Q My question is you don't have any
16 procedure that would prevent Weiner from
17 talking to Carville without informing you, do
18 you?
19 A No, he's free to speak with, you
20 know, anyone in America.
21 Q And you don't know whether he's
22 actually doing research for Carville, do you?
283
1 A I am Glen's boss and during the
2 course of the day I give him work to do. At
3 the end of the day, you know, he shows me a
4 draft of something. You know, I'm aware of
5 what is going on in my office generally, so
6 --
7 Q You're not aware of what Brenda
8 Costello does, are you?
9 A I don't consider her to be in my
10 office.
11 Q You're not aware what Ann Walker
12 does, correct?
13 A Correct, I do not also consider her
14 to be in my office.
15 Q Do you require a report from each
16 of the employees in your office each day?
17 A I wouldn't say it's anything that
18 formal, no.
19 Q What is it?
20 A But, generally speaking, we would
21 check in with each other in the morning and
22 probably check in with each other at end of
284
1 the day.
2 Q Is there a procedure for doing
3 that?
4 A No, I just -- I think I just said
5 there's not any formal procedure, no.
6 Q Have you ever given any instruction
7 I want you to come by my office before you
8 leave each night and tell me what you've
9 accomplished and what you haven't
10 accomplished?
11 A No, sir.
12 Q Is there any formal written
13 procedure that you get on a periodic basis, a
14 written report from each employee as to what
15 they've done?
16 A No, sir. I think I would be --
17 Q Is there any procedure in your
18 office for sending memoranda to each other
19 giving you an update as to what the employees
20 are doing?
21 A No, sir.
22 Q Do you send each other E-mails with
285
1 reports as to what each are of you are
2 working on?
3 A No. As I described to you, it is
4 verbal. I, generally, speak with both of
5 them in the morning and -- or three of them
6 now and three of them at the end of each day
7 and there's enough work going on that, you
8 know, I'm presented with drafts of something.
9 People don't have a lot of time on their
10 hands beyond the work that I'm assigning to
11 them.
12 Q But you can't tell me categorically
13 that Weiner doesn't take instructions from
14 Carville and do research for him; is that
15 correct? You can't tell me that?
16 MR. KLAYMAN: Objection. Asked and
17 answered plus you're going to have Mr. Weiner
18 here for a deposition at some point.
19 BY MR. KLAYMAN:
20 Q You can respond. You can respond.
21 A Restate your question, please.
22 Q You can't tell me uncategorically
286
1 that Weiner doesn't do research requests for
2 Carville from time to time? You don't know
3 that?
4 A Again, I believe that I am familiar
5 with the bulk of how Glen spends his day. Do
6 I -- can I say that he's never received a
7 phone call from James, no, I can't answer
8 that.
9 Q That's not what I asked you.
10 Have you ever asked Glen Weiner
11 specifically have you ever done any research
12 requests for James Carville?
13 A No, I don't believe I have.
14 Q Do you have any way of monitoring
15 as to whether Weiner is taking research
16 requests from Carville?
17 A Beyond the way that I just
18 described to you?
19 Q You didn't describe anything to me.
20 That's why I'm asking the question.
21 A Well, I'll describe it again.
22 I'm -- he is my employee and I know what he
287
1 does with his day because I give him a lot of
2 work. And at the beginning of the day I talk
3 to him about what work he has to do. At the
4 end of the day, generally speaking, I look at
5 what he's done and I believe myself to be
6 largely aware of what he's doing while he's
7 at work at the White House.
8 Q I ask you the question whether you
9 have any procedure that you can know for sure
10 that Weiner is not working for Carville at
11 taxpayer expense?
12 A Yes.
13 Q And where is that?
14 A All right.
15 Q Where is that?
16 A He works for the --
17 Q What's the procedure?
18 A -- White House. That's what I can
19 tell you. If you're asking --
20 Q What's the procedure?
21 A -- does he work for James Carville,
22 the salary is a White House salary. He works
288
1 for me at the White House.
2 Q Right, but I'm asking you whether
3 there's some way that you have monitored him
4 in a formal way to make sure that he's not
5 doing research requests or other requests for
6 Carville other than your general knowledge
7 that he's occupied?
8 MS. GILES: This has been asked and
9 answered. The questions are better directed
10 at Mr. Weiner.
11 MR. KLAYMAN: I want a definitive
12 response. Definitive response.
13 THE WITNESS: Ask the question
14 again, please. Sorry.
15 BY MR. KLAYMAN:
16 Q Do you have any formal mechanism
17 for ensuring that Weiner has never carried
18 out a request of Carville's?
19 A No, I can't -- I cannot say that
20 he's never taken a phone call and provided a
21 transcript or a Presidential accomplishments
22 page or something like that.
289
1 Q Has your office ever billed
2 Carville for photocopies or for services
3 rendered or anything like that?
4 A Absolutely not, no, because, as I
5 said earlier, I don't believe that any work
6 in my office has been done to support
7 Mr. Carville in any way.
8 Q Has anyone in your office ever had
9 communications from the U.S. attorney in
10 Arkansas, P.K. Holmes?
11 A I'm sorry.
12 Q From the U.S. Attorney in Arkansas,
13 P.K. Holmes. That's his name.
14 A I certainly don't believe so. I've
15 never heard the name.
16 Q Have you ever had any
17 communications from Senator David Pryor?
18 A I would hate to rule it out seeing
19 how he's a United States Senator and it
20 wouldn't surprise me if there had been
21 something along the way.
22 Q Has anyone in your office ever had
290
1 any communications with Susan McDougal or her
2 lawyer?
3 A Absolutely not. To the best of my
4 knowledge, no.
5 Q Have you or anyone else in your
6 office ever communicated with anyone with the
7 FBI?
8 A Yes, sir.
9 Q When was that?
10 A I'm sure we all in order to become,
11 you know, blue pass, full-time employees at
12 the White House we all went through a process
13 which included an FBI background interview.
14 Q Other than going through background
15 checks, have you or anyone else in your
16 office had contact with the FBI over doing
17 research or any other function in your
18 office?
19 A Not to be -- again, just so I'm. I
20 have had conversations with FBI agents
21 regarding other people's background
22 interviews who were also seeking or beginning
291
1 employment. Beyond that I can think of no
2 other contact.
3 Q For you and others in your office?
4 A What's the question? I'm sorry.
5 Q For you or others in your office?
6 A Have I what?
7 Q Other contact with the FBI, does
8 that refer to you or you and others in your
9 office as well, that you don't have any
10 knowledge of any contact?
11 A I have no knowledge of any contact
12 --
13 Q Doing background checks?
14 A -- of anyone -- between anyone in
15 my office and the FBI.
16 Q Do you know if Carville was ever
17 interviewed by the FBI for your background
18 check?
19 A I have no idea who the FBI spoke
20 with.
21 Q Have you or anyone else in your
22 office ever had communication with a Caryn
292
1 Mann?
2 A The name does not ring any bells.
3 I don't believe so, no, sir.
4 Q Mr. Dozhier, D-O-Z-H-I-E-R?
5 A No, sir, I don't believe so.
6 Q Caryn Mann's son, Joshua Rand?
7 A Again, no, I don't believe so.
8 Q Have you or anyone else in your
9 office ever had any communication with J.
10 Kendall Few, F-E-W?
11 A I don't know the name.
12 Q He's the person who lodged a
13 complaint against Ken Starr from South
14 Carolina.
15 A No, sir.
16 Q Have you or anyone in your office
17 ever done any research concerning Dick Army?
18 A I want to be careful. I -- I know
19 there's been no what I would call campaign or
20 opposition research because that doesn't
21 happen, but would his name have come up in a
22 document on a particular issue seeing as how
293
1 he's the whatever in the leadership of the
2 republican party, I'm sure his name has come
3 up.
4 Q Has anyone in your office ever
5 researched his past history with regards to
6 social relations?
7 A Restate the question.
8 Q You're aware that there were
9 reports in the last few weeks that he had
10 flirted with a woman when he was at a
11 university?
12 A No, I read that, but I have no --
13 no knowledge of that or don't believe --
14 Q Who in the White House researched
15 that issue?
16 A I reject the premise. I don't
17 believe that anyone in the White House would
18 have researched that or did research it.
19 Q Did Carville research that issue?
20 A Again, I have no knowledge
21 whatsoever of how that would have come into
22 the press.
294
1 Q Have you ever communicated, or
2 anyone in your office, with Craig
3 Livingstone?
4 A No, sir, I don't believe so.
5 Q Have you ever discussed Craig
6 Livingstone with anyone at the White House?
7 A I honestly don't believe so. That
8 was all something that happened before I got
9 there.
10 Q Have you ever communicated with
11 Anthony Marceca?
12 A No, sir, not to my knowledge.
13 Q Has anyone in your office?
14 A No, sir, not to my knowledge.
15 Q Have you or anyone in your office
16 ever communicated with Nathan Marceca,
17 Anthony Marceca's son?
18 A No, sir, I don't believe so.
19 There's someone by that name who works at the
20 White House, but I don't have no -- I have no
21 idea if it's a relation or not.
22 Q Who is that?
295
1 A I don't know. I'm just --
2 Q Well --
3 A I've seen in the directory -- in
4 the personnel directory or the phone
5 directory.
6 Q That there's a Nathan Marceca?
7 A No, that there's a Marceca, so I'm
8 just saying.
9 Q Do you know where that person
10 works? Can you remember or do you have any
11 knowledge?
12 A I don't even -- no, it's just a
13 name that I -- I have seen either on an
14 E-mail or something as someone who is at the
15 White House. I'm not even sure it's the same
16 person or any relation, frankly.
17 Q Have you or anyone in office your
18 had a communication with Bernard Nussbaum?
19 A No, sir, not that I'm aware of.
20 Q Have you ever discussed
21 Mr. Nussbaum with anyone at the White House?
22 A I don't believe so.
296
1 Q Have you ever seen an FBI
2 background file or summary report?
3 A I don't believe so, no. I --
4 seeing how that is sort of central here, I
5 don't have any knowledge of any -- never seen
6 any FBI file to the best of my knowledge.
7 Q Have you or anyone at the White
8 House ever discussed how Craig Livingstone
9 was hired?
10 A Has anyone at the White House ever
11 discussed it?
12 Q That you have knowledge of.
13 A No, sir.
14 Q I take it, you know, in your time
15 at the White House you have had an
16 opportunity to discuss what role Mrs. Clinton
17 performs as First Lady.
18 A I -- I don't understand the
19 question.
20 Q The question is very simple. I
21 take it that during your time at the White
22 House and your involvement in democratic
297
1 matters that you've had an opportunity to
2 discuss what Mrs. Clinton's role is at the
3 White House?
4 A Again, I'm -- not to be flip, but
5 she's the First Lady. She's, you know, a
6 prominent person. I don't recall ever having
7 discussed that with anyone.
8 Q Do you sometimes eat lunch down in
9 the cafeteria?
10 A Rarely. Maybe twice.
11 Q Do you sometimes go out to lunch
12 with people from the White House?
13 A Usually eat lunch at my desk.
14 Q I didn't ask you that.
15 A Well, you asked me if I go out to
16 lunch and I'm saying no.
17 Q Yeah, do you sometimes go out. I
18 mean why if I ask you a question like that
19 would you answer another one?
20 MS. GILES: The question about
21 where he has lunch. There's no need to
22 badger the witness.
298
1 MR. KLAYMAN: I'm not badgering.
2 I'm just trying to figure out why I can't get
3 a straight response to the question.
4 THE WITNESS: No, you are.
5 BY MR. KLAYMAN:
6 Q Why is it?
7 A I don't go out to lunch very often.
8 Occasionally maybe.
9 Q I said on occasion do you go out to
10 lunch with people from the White House?
11 A Yes.
12 Q Let me back up.
13 On occasion do you sometimes go out
14 to dinner with people that work at the White
15 House?
16 A Sure.
17 Q Are you telling me that there's
18 never been any discussion as to what role
19 Hillary Clinton plays at the White House
20 during all of those occasions?
21 A I don't think I said that. I said
22 beyond the fact that she's the First Lady and
299
1 I don't recall -- I don't -- maybe I don't
2 understand your question. What is it
3 you're --
4 Q My question is, whether you've ever
5 had a discussion with anyone where you've
6 discussed what role Hillary Clinton plays at
7 the White House.
8 A And I guess my answer to that is I
9 don't recall having done that, no.
10 Q You really have no interest in
11 that?
12 A No, I -- she's the First Lady, you
13 know.
14 Q That's all you care to know, she's
15 the First Lady?
16 A Again, maybe you rephrase your
17 question. Maybe I'm missing what it is
18 you're asking me.
19 Q No, my question is very clear.
20 It's clear you don't want to answer my
21 question so we'll move on.
22 MS. GILES: Objection. Harassing.
300
1 MR. KLAYMAN: It's not harassing.
2 MS. GILES: He's giving
3 straightforward answers. If you don't like
4 them --
5 MR. KLAYMAN: And I'm telling the
6 witness I'm asking you to answer my
7 questions.
8 MS. GILES: He has --
9 THE WITNESS: I'm trying to do
10 that, sir.
11 MR. KLAYMAN: I'm not here to ask
12 questions and have you answer another
13 question. That's the way we'll move this
14 thing along.
15 MS. GILES: The witness is
16 answering your questions. The record will
17 speak for itself.
18 MR. KLAYMAN: The record will speak
19 for itself.
20 BY MR. KLAYMAN:
21 Q I'll ask the question again. You
22 have no interest in the function that the