301


       1    First Lady plays at the White House?

       2         A    That's a different question.  Do I

       3    have an interest in the -- I mean I think she

       4    does a great job.  I don't -- in the course

       5    of my workday I don't have any reason to

       6    think about it all that much.

       7         Q    Your job is to do research, right?

       8         A    Correct.

       9         Q    Your job is to know what's going

      10    on, right?

      11         A    Correct.

      12         Q    You work for the communications

      13    department, correct?

      14         A    Correct.

      15         Q    And communications is meant to

      16    convey to the public what's happening at the

      17    White House, correct?  Isn't that one of the

      18    roles?

      19         A    Yes, certainly.

      20         Q    And the First Lady plays a role at

      21    the White House, correct?

      22         A    Absolutely.








                                                              302


       1         Q    So you're telling me you've never

       2    had any discussions as to what role she plays

       3    at the White House?

       4              MS. GILES:  Objection.  Asked and

       5    answered.

       6              THE WITNESS:  I mean have there

       7    been discussions that the First Lady is doing

       8    such and such an event or hosting a child

       9    care conference or something, yes, but beyond

      10    that I don't -- I don't know that I've had

      11    discussions about her role.

      12              BY MR. KLAYMAN:

      13         Q    Have there ever been discussions

      14    that you have been privy to where people have

      15    discussed what her role is vis-a-vis the

      16    President's role?  How they interact?

      17    Whether she runs certain operations in the

      18    White House?  Whether she makes certain

      19    decisions about what occurs in the White

      20    House?  You've never been privy to any of

      21    that as head of your office or otherwise?

      22         A    I just -- I'm sorry.  I find








                                                              303


       1    that I'm trying to answer your question.  It

       2    seems very broad to me.  Like I'm aware of

       3    the First Lady and the fact that she's

       4    involved with the administration, you know.

       5    Her events are occasionally discussed as a

       6    part of what's happening communications wise.

       7    Beyond that I don't know that I have much

       8    more knowledge of her.

       9         Q    Have you ever attended a meeting

      10    where Mrs. Clinton was present?

      11         A    No, sir, I don't believe I have.

      12         Q    Do you know whether --

      13         A    Are you saying ever I was at a --

      14    in the campaign -- meeting as in -- like I've

      15    been in places where she and the President

      16    are there for like a social function or they

      17    both came to the campaign headquarters like a

      18    week before the election and both said, you

      19    know, made remarks, that kind of thing.  I

      20    have been in those situations, but I don't

      21    recall any time where I've been in a meeting

      22    where there has been any substance discussed.








                                                              304


       1         Q    Do you know whether Mrs. Clinton

       2    has walk-in rights to staff meetings at the

       3    White House?

       4         A    I really don't.  I'm sorry.

       5         Q    Have you ever been in a meeting

       6    with the President?

       7         A    I don't -- no, I have not.

       8         Q    Have you ever met the President?

       9         A    Yes, sir.

      10         Q    And where did you meet him?

      11         A    I met him once -- once in 1992.  In

      12    passing somebody introduced him to me and I

      13    shook his hand and probably a couple of other

      14    social occasions like Christmas parties or

      15    something like that.  And then on one

      16    occasion during the debate preps in 1996 I

      17    was introduced to him and shook his hand and

      18    had a picture taken.

      19         Q    Have you or anyone else in the

      20    White House ever communicated with Bob

      21    Mulholland?  Do you know who Bob Mulholland

      22    is?








                                                              305


       1         A    I do know who he is.

       2         Q    When did you meet Mr. Mulholland?

       3         A    I don't know that I've ever met

       4    him, but when I was at the DNC, I think I was

       5    aware of him as a California like person, but

       6    I have not had any contact --

       7         Q    And what was his role there?

       8         A    If I can finish my answer.  I don't

       9    believe I've had any contact with him

      10    since -- certainly since coming to the

      11    campaign or since -- basically, I don't think

      12    since I left the DNC, I don't believe.

      13         Q    Has anyone else in your office or

      14    the White House had contact with him in the

      15    last six months?

      16         A    At my house or at the White House?

      17         Q    In your office.

      18         A    In my office.  Not that I'm aware

      19    of, no.

      20         Q    You're aware that in the last few

      21    weeks he's threatened to dig up dirt and

      22    smear republicans?








                                                              306


       1         A    I read that remark or saw that

       2    remark reported on.

       3         Q    Has that been discussed in your

       4    office, that remark?

       5         A    I believe briefly, yes.

       6         Q    Who was it discussed with?

       7         A    I think it might have been with

       8    Glen and we both thought it was an incredibly

       9    stupid remark.

      10         Q    Why did you think it was a stupid

      11    remark?

      12         A    I just, you know, in the context

      13    that I find myself sitting here, it's not the

      14    kind of thing that anyone should be out there

      15    trying to, you know, make political points

      16    on, speaking off the cuff.  There's a lot of

      17    scrutiny about such things and it was not

      18    appropriate.

      19         Q    Why in your opinion is it not

      20    appropriate?

      21         A    Sitting here today?  Because I

      22    think that such remarks, you know, obviously








                                                              307


       1    should be treated -- I mean talking about

       2    doing that to people ought to be a serious

       3    matter and I think -- I don't think that -- I

       4    thought it was inappropriate given the

       5    context of, you know, everything has gotten

       6    to it and the scrutiny and the --

       7         Q    Well, you are aware that he said he

       8    was only going to use public information,

       9    correct?

      10         A    I'm not aware of that, no.  I don't

      11    recall.

      12         Q    If all he was going to use is

      13    public information, there's nothing wrong

      14    with that, is there?

      15              MS. GILES:  Objection as to

      16    relevance.  This is about Mr. Mulholland?

      17              BY MR. KLAYMAN:

      18         Q    Based on your experience.  Based on

      19    your experience in doing opposition research,

      20    if all he was going to do was use public

      21    information, in your opinion there's nothing

      22    wrong with that, is there?








                                                              308


       1         A    You know, you're asking my -- I

       2    thought you were asking my personal opinion

       3    about what I thought of his comments.  I gave

       4    you those.

       5              Do I think that they're -- you

       6    know, if he decided he was going to defend

       7    the President all on his own out there and

       8    speak out about it, I guess as an American

       9    that's his right, to defend the President of

      10    the United States.

      11         Q    I'm trying to separate out the fact

      12    that you thought it was a stupid comment

      13    because it attracted attention from whether

      14    his comment was legally improper?

      15         A    You know, the reason I said I

      16    thought it was a stupid comment is because I

      17    knew you were going to ask me about it here.

      18    I have no knowledge of it.  I read it in the

      19    newspaper or I saw it on CNN.  That's it was

      20    stupid to me, I mean, to be honest.

      21         Q    Why did you know I was going to ask

      22    you about it?








                                                              309


       1         A    Because it's the type of thing

       2    having, you know, read some depositions and

       3    all, that I figured would come up.

       4         Q    Do you know where Mr. Mulholland

       5    works in California?

       6         A    No, sir.

       7         Q    Do you know what city he's from?

       8         A    No, sir.

       9         Q    And why did Glen Weiner think it

      10    was a stupid comment?

      11         A    I can't really -- I mean I assume

      12    it was for the same reason that I did -- that

      13    we -- but I cane speak for why he thought it

      14    was stupid.  I can't even say that -- that he

      15    said it was stupid.  I think that's what I

      16    thought.  I don't know that I'm attributing

      17    quotes to him.

      18         Q    Are you aware that George

      19    Stephanopoulos went on "This Week" with Sam

      20    Donaldson and Cokie Roberts and made a

      21    statement that White House allies are

      22    whispering about an Ellen Roemech strategy?








                                                              310


       1         A    I am aware of that as I sit here

       2    having read depositions, yes.

       3         Q    Did you know that at the time it

       4    occurred on February 8, 1998?

       5         A    I may have a vague recollection of

       6    it, but I don't really remember it all that

       7    well.  I don't believe I saw it myself, but I

       8    know it got some coverage, so --

       9         Q    It was the topic of discussion in

      10    the White House around that time?

      11         A    Not to my knowledge, no.

      12         Q    Was it a topic of discussion to

      13    anybody else's knowledge that you know of?

      14         A    I can't really respond as to what

      15    other people's knowledge was.

      16         Q    Have you ever pulled up the

      17    transcript of George Stephanopoulos'

      18    statement on February 8th?

      19         A    Yes, sir.

      20         Q    When did you pull the transcript

      21    up?

      22         A    Sometime in the last four days.








                                                              311


       1         Q    And did someone ask you to do that

       2    or did you do it on your own?

       3         A    I did it in -- as part of my --

       4    well, let me be totally clear.  I -- it was

       5    E-mailed to me, as every transcript -- most

       6    transcripts of news programs and Sunday

       7    programs are E-mailed to me.

       8         Q    Go ahead.

       9         A    No.

      10         Q    Who E-mailed it to you?

      11         A    The -- I believe it was the

      12    communications -- there's a guy who works in

      13    communications who E-mails every -- after

      14    every -- every day, you know, transcripts of

      15    news programs.

      16         Q    Who is that?

      17         A    I believe his name is Dag Vega,

      18    something like that, Dag.

      19         Q    Where does he work?

      20         A    I believe -- my best guess is that

      21    he works in communications -- no, press

      22    office or something.  I think it's office.








                                                              312


       1    And as a regular course of business to keep

       2    people at the White House aware of what's

       3    going on they E-mail out transcripts.

       4         Q    Who told him to E-mail this

       5    transcript to you about George Stephanopoulos

       6    and Ellen Roemech?

       7         A    I assume nobody did.  I assume it

       8    was not E-mailed to me, it was E-mailed White

       9    House -- across the White House, as it is

      10    after every Sunday with all the White House

      11    transcripts -- I mean all the Sunday show

      12    transcripts.

      13         Q    Correct me if I'm wrong, but I

      14    thought you told me that it was just E-mailed

      15    to you in the last few days?

      16         A    No, no, no.  What I said was I

      17    pulled it up and printed it up in the last

      18    few days as a result of my document search

      19    and the fact that that was the one of the

      20    matters that you were interested in.  It was

      21    E-mailed to everyone who receives transcripts

      22    at the White House at the time.








                                                              313


       1         Q    Had you seen that transcript on or

       2    about February 8th or in that period,

       3    February, March?

       4         A    I don't remember it, but as a

       5    general practice, I try to read them -- I try

       6    to read the transcripts from the Sunday shows

       7    if I haven't been able to watch them, so it's

       8    possible I read it.  It's probably, you know,

       9    I don't know, it may be likely that -- that I

      10    would have attempted to read them any way.

      11         Q    When you read it in and about that

      12    time period, did you take note of the remark

      13    about Ellen Roemech and dragging down

      14    adversaries?

      15         A    I didn't say that I read it at the

      16    time.  I said it was likely that I would have

      17    attempted to read, you know, the six or seven

      18    Sunday transcripts that come by.  And I

      19    don't -- actually don't recall -- I don't --

      20    beyond the fact that I think it made some

      21    news.  I don't remember whether I read it in

      22    a transcript or if I read it in a newspaper








                                                              314


       1    clip.

       2         Q    At that time?

       3         A    Right.

       4              MR. KLAYMAN:  I'll show you what

       5    I'll ask the court reporter to mark as

       6    Exhibit 6.  It's a copy of that transcript,

       7    the February 8, 1998, show on "This Week,"

       8    where Mr. Stephanopoulos made the referenced

       9    comments.

      10                   (Janenda deposition Exhibit

      11                   No. 6 was marked for

      12                   identification.)

      13              BY MR. KLAYMAN:

      14         Q    And I'm referring to page two of

      15    that transcript, specifically halfway down,

      16    where it says --

      17              MS. GILES:  Exhibit 6?  Is that --

      18              MR. KLAYMAN:  Excuse me?

      19              MS. GILES:  Are we up to Exhibit 6?

      20              MR. KLAYMAN:  Yes.

      21              BY MR. KLAYMAN:

      22         Q    Where it says halfway down, "Sam








                                                              315


       1    Donaldson:  We know what the White House

       2    tactics are.  I mean they're almost open

       3    about it.  Attack the press, and perhaps with

       4    good reason, attack the independent counsel,

       5    perhaps for some good reason, and

       6    stonewalling the central issue, which is the

       7    President of the United States.  And if he

       8    has nothing to hide, why is he hiding?"  And

       9    then George Stephanopoulos responds, "I agree

      10    with that and there is a different long-term

      11    strategy, which I think would be far more

      12    explosive.  White House allies are already

      13    starting to whisper about what I'll call the

      14    Ellen Roemech strategy."

      15              Do you know what the reference to

      16    Ellen Roemech is about?

      17         A    I do having read the -- read the

      18    depositions for this deposition.

      19         Q    Did you know who Ellen Roemech was

      20    before you read the depositions?

      21         A    I don't believe I did, no.

      22         Q    Did you know that or did you have








                                                              316


       1    any knowledge that J. Edgar Hoover had used

       2    FBI files against people back in the Kennedy

       3    administration?

       4         A    I think I had a vague sense, having

       5    taken history, that there was some issues

       6    along those lines like Martin Luther King

       7    or --

       8         Q    Right.  And then Sam Donaldson

       9    says, "I remember her."  Stephanopoulos

      10    responds, "You remember her?

      11              "Sam Donaldson:  Oh, yes.

      12              "George Stephanopoulos:  She was a

      13    girlfriend of John F. Kennedy who also

      14    happened to be an East German spy and Robert

      15    Kennedy was in charge of getting her out of

      16    the country and also getting J. Edgar Hoover

      17    to go to the Congress and say don't you

      18    investigate this because if you do, we're

      19    going to open hope up everybody's closets.

      20    And I think in the long running they have a

      21    deterrent strategy on getting a lot of --

      22              "George Will:  Monica Lewinsky is








                                                              317


       1    an East German spy?

       2              "Sam Donaldson:  No, but that's a

       3    good point and are you suggesting for a

       4    moment that what they're beginning to say is

       5    that if you investigate this too much, we'll

       6    put all of your dirty linen right on the

       7    table.  Every member of the senate?  Every

       8    member of the press corps?

       9              "George Stephanopoulos:

      10    Absolutely.  The President said he would

      11    never resign and I think some around him are

      12    willing to take everybody down with him."

      13              Now, I take it you have heard

      14    discussions at the White House about taking

      15    people down in the last six months, have you

      16    not?

      17         A    No, sir.

      18         Q    Never heard anything like that?

      19         A    I have never heard anyone discuss

      20    taking someone down, no.

      21         Q    And you have heard discussions in

      22    the last six months about gathering








                                                              318


       1    information about republicans, have you not?

       2         A    I guess I'd ask you to define that,

       3    what you mean by that.

       4         Q    Just what I said.

       5         A    Again, I make --

       6         Q    I can't be more plain than that.

       7         A    As a research director of the White

       8    House, I -- you asked me have I ever

       9    collected research on republicans.  That's

      10    difficult because I would say certainly I

      11    deal with issues all the time and I probably

      12    have done research on where does Newt

      13    Gingrich stand on X issue that's going to be,

      14    you know, topic A next week.  Have I ever

      15    done, you know, any other kind of research?

      16    No.

      17         Q    That's not question I asked you.

      18              The question I asked you,

      19    Mr. Janenda, is whether or not you heard

      20    anyone at the White House ever discuss

      21    gathering negative information on republicans

      22    in the last six months.








                                                              319


       1         A    I don't think that's the question

       2    you asked me, but, no, I have not.  I can

       3    answer that more clearly.

       4         Q    I changed it slightly.

       5         A    Okay.

       6         Q    I put in the word "negative."  The

       7    first one was just information.

       8         A    Right.

       9         Q    That's the first question.  Did you

      10    ever hear anyone say in the last six months

      11    that we need to collect information on the

      12    republicans?  Yes or no?

      13         A    I can't give you a yes or no.  I

      14    don't recall anyone saying that.  But where

      15    are republicans on tax reform, something like

      16    that.

      17         Q    Well, that's information, isn't it?

      18         A    Yes.

      19         Q    My question is very neutral.  It

      20    doesn't say collect information which is

      21    negative to smear people.  It says --

      22         A    Which is why --








                                                              320


       1         Q    Have you ever heard anyone say in

       2    the last six months let's get some

       3    information on Republicans?

       4         A    And I was trying to answer that

       5    question.

       6         Q    The answer is yes, you've heard

       7    that, haven't you?

       8         A    No, I've not heard anyone say get

       9    some information on republicans, no.  Have I

      10    had someone ask me -- I'm not trying to split

      11    hairs.  I'm just trying to -- I mean this is,

      12    you know -- I do issues on -- I do research

      13    on issues.  Occasionally certainly there are

      14    republicans who come up in the course of

      15    doing that research.

      16         Q    Let me ask you this:  I'm asking

      17    you the question calmly, aren't I?

      18         A    Yes, absolutely.

      19         Q    And you know when why I'm asking

      20    the questions that way, right?

      21         A    I do.  That's why I'm trying to be

      22    particularly careful.








                                                              321


       1         Q    You know that I'm searching for

       2    information about gathering dirt on

       3    republicans.  You know that's why I'm here,

       4    right?

       5         A    If you say so.

       6         Q    Isn't that your understanding?

       7              MS. GILES:  You're asking him what

       8    his understanding of your intent is?

       9              MR. KLAYMAN:  Yeah.

      10              THE WITNESS:  I can't --

      11              MS. GILES:  You can testify as to

      12    your personal knowledge.

      13              BY MR. KLAYMAN:

      14         Q    You have formed an opinion as to

      15    why I'm here, haven't you?

      16         A    No, I haven't.  I'm here and I'm

      17    trying to answer every question you ask me.

      18         Q    You have discussed Larry Klayman

      19    and Judicial Watch with some people, haven't

      20    you?

      21         A    No, I --

      22         Q    I'm not talking about your counsel








                                                              322


       1    but with other people.

       2         A    Have I ever discussed you ever?

       3         Q    Yeah.

       4         A    I don't know.  I couldn't say it

       5    never came up.  I mean you've been in the

       6    papers.

       7         Q    Have you ever seen me on

       8    television?

       9         A    Probably have, yeah.

      10         Q    Have you ever seen democrat

      11    consultants or members of the White House say

      12    Larry, you're a Clinton hater?  You've heard

      13    that, haven't you?

      14         A    It wouldn't surprise me, but I'm

      15    saying I don't particularly recall that.

      16         Q    You have heard people say I'm out

      17    to get the President, right?

      18         A    I don't think that I have, no.

      19         Q    You haven't heard that.

      20              But is it your impression that I'm

      21    trying to find out whether you or anyone else

      22    in the White House has been digging up








                                                              323


       1    negative information on republicans and other

       2    perceived adversaries?

       3              MS. GILES:  The questions is about

       4    his understanding of your intent.  This is

       5    clearly irrelevant.

       6              MR. KLAYMAN:  It is not irrelevant.

       7    It gets to his state of mind, it gets to his

       8    bias in answering these questions.

       9              BY MR. KLAYMAN:

      10         Q    You're aware of that, aren't you?

      11    That is your impression, is it not?

      12         A    Honestly, you know, I'm attempting

      13    to answer every question as honestly and

      14    completely as I can, you know, in my first

      15    deposition ever.  So I'm not doing anything

      16    other than, you know --

      17         Q    I'm trying to be direct with you

      18    and I'm trying to be diplomatic and I'm

      19    trying to get the answers.

      20         A    And I'm trying to give you those

      21    answers.

      22         Q    But I find it hard sometimes to








                                                              324


       1    have the questions answered and the reason

       2    I'm probing here, to answer your counsel's

       3    question, is because frequently those

       4    questions aren't answered and I'm wondering

       5    if it's because you think I'm looking for

       6    something.

       7         A    I don't -- what is the -- I don't

       8    understand your question.

       9         Q    The question is whether your belief

      10    is I'm looking for something that could prove

      11    that the White House is out to get

      12    information to smear perceived adversaries.

      13         A    Are you asking what is my

      14    impression --

      15         Q    Yeah.

      16         A    -- of what you're doing?

      17         Q    Yeah.  Is that your impression?

      18         A    You want my impression?

      19         Q    Yeah, that's all I want.

      20         A    You know, I think that what

      21    happened or allegedly happened with -- with

      22    the Filegate matter was a very serious thing








                                                              325


       1    and I think that, you know, I think wrongly

       2    you're trying to find out whether I would

       3    ever or have ever done anything improper with

       4    either an FBI file or any other kind of

       5    government file.  I think that's what you

       6    want to ask me and I'm glad to have an

       7    opportunity to tell you that I have never

       8    done such a thing and I don't know anyone who

       9    has done such a thing.  That's my impression

      10    of --

      11         Q    So you think I'm out to get you?

      12         A    I didn't say that.

      13              MS. GILES:  Objection.

      14    Mischaracterizes the testimony.

      15              THE WITNESS:  I give you the answer

      16    that I think you were --

      17              BY MR. KLAYMAN:

      18         Q    You think I'm out to prove that

      19    information has been misused by the White

      20    House about perceived adversaries?

      21         A    I don't know how my -- I gave you

      22    my impression.  I'm just not comfortable








                                                              326


       1    continuing to guess what it is that you're --

       2         Q    I'm not asking you to guess.  I'm

       3    asking for your own belief.

       4              MS. GILES:  As to?

       5              BY MR. KLAYMAN:

       6         Q    Larry Klayman is here to uncover

       7    that your office misused Privacy Act

       8    information against adversaries of the

       9    Clinton administration.

      10         A    No, I -- I think that, you know,

      11    your case deals with the FBI files matter and

      12    you're -- you're interested in whether or not

      13    anything like that has, you know, happened

      14    again or whatever and I'm happy to tell you

      15    and have the opportunity to tell you, as I

      16    said, that I am not aware of any such thing

      17    having happened.

      18         Q    Now, at the time that

      19    Stephanopoulos made this statement, you must

      20    have overheard conversations in the White

      21    House about Stephanopoulos, correct?

      22         A    I mean I can't say that I did.  I








                                                              327


       1    think that -- no, I can't say that I did.

       2         Q    This was a topic of conversation,

       3    was it not?  George going on T.V. and saying

       4    that the White House allies were whispering

       5    about a strategy to destroy adversaries?

       6         A    Was there a conversation about this

       7    at the White House?  Is that --

       8         Q    Yeah, that you're aware of.

       9         A    I don't believe so -- I mean I --

      10    not to my knowledge.  It wouldn't surprise

      11    me.  But I don't recall specifically having

      12    overheard such a conversation.

      13         Q    Now, this statement, in your

      14    opinion, is a pretty significant statement,

      15    is it not?  It's an important statement?

      16         A    Frankly, I tend to -- not trying to

      17    be flip, but, again I tend to sort of lump

      18    George in with the other 15 people who are on

      19    Sunday T.V. every Sunday.

      20         Q    Which is?

      21         A    Which is what?  What do I think of

      22    those people?








                                                              328


       1         Q    The way you lump them in.  You lump

       2    them in as crackpots or what?

       3         A    Well, I -- you know, they're

       4    pundits.  It's their opinion, you know, I

       5    don't know where they -- what they --

       6         Q    Have you ever heard George

       7    Stephanopoulos referred to not as a

       8    commentator but a common traitor at the White

       9    House?

      10         A    I have never heard that, no.

      11         Q    Based on your understanding of what

      12    opposition researchers are supposed to do,

      13    it's not to gather information to destroy

      14    adversaries, correct?

      15         A    No, sir, only because I think your

      16    terms are -- they're loaded terms.  I mean

      17    they're -- no, I would disagree with that.

      18         Q    How would you disagree?

      19         A    What do I think an opposition

      20    researcher's job is?

      21         Q    Well, I was trying to say to you

      22    that it's not an opposition researcher's job








                                                              329


       1    to get information to smear and destroy

       2    people.  You agree with that, right?

       3         A    That it is not their job?

       4         Q    Yes.

       5         A    Correct.

       6         Q    And based on your experience in

       7    working in politics and at the White House,

       8    it wouldn't be proper, would it, to try to

       9    take everybody down that opposes you with

      10    negative information?

      11              MS. GILES:  Objection.  Vague and

      12    ambiguous terms, "take them down."

      13              BY MR. KLAYMAN:

      14         Q    Well, let me use George's phrase.

      15    Let me use George Stephanopoulos' phrase.

      16    "The President said he would never resign and

      17    I think some around him are willing to take

      18    everybody down with him."

      19              Now, based on your experience in

      20    working in politics and the White House,

      21    based on your ethics and moral values, is

      22    that something you would do, you would








                                                              330


       1    participate in?

       2         A    No, sir, it's not, but, again, it's

       3    something that somebody said on a Sunday

       4    show.  I don't give it a whole lot of

       5    credence one way or another.  But, no, it's

       6    not something I would think was a good thing

       7    or positive thing.

       8         Q    And based on your knowledge, it

       9    wouldn't be a legal thing, correct?  I'm not

      10    asking you to make a conclusion as a lawyer,

      11    but just based on your own belief is that

      12    legal?

      13         A    I would just hesitate to venture

      14    into making legal -- I'm sorry.  I just -- I

      15    don't know what the laws are.

      16         Q    What's your feeling about that?

      17         A    About what?

      18         Q    Whether destroying people, taking

      19    everybody down is legal?

      20         A    I don't know what that means.  I

      21    don't know -- I honestly have no idea what

      22    that means.  What does take people down mean?








                                                              331


       1    I just don't know what it means.

       2              MS. GILES:  And he's not, in fact,

       3    a legal expert, so he can't testify as to

       4    what's legal.

       5              MR. KLAYMAN:  Excuse me?

       6              MS. GILES:  He is not a legal

       7    expert.

       8              MR. KLAYMAN:  I already qualified

       9    that I'm not asking for a legal opinion.

      10              MS. GILES:  You are asking him

      11    whether it's legal.

      12              BY MR. KLAYMAN:

      13         Q    Do you know what the Privacy Act

      14    is?

      15         A    Not particularly, no.

      16         Q    Have you ever heard of it?

      17         A    I've heard of it, yeah.

      18         Q    Are you aware there's certain

      19    information that the government collects

      20    about people that can't be released publicly?

      21         A    That -- I mean, I'm just saying I'm

      22    not aware of it as a law, but certainly.








                                                              332


       1         Q    What I'm saying is Stephanopoulos'

       2    statement, whether he was making it off the

       3    cuff or whether he had actual knowledge, if

       4    it's true, that's a very significant

       5    statement, is it not?

       6              MS. GILES:  Which statement are we

       7    talking about?

       8              MR. KLAYMAN:  It's a very important

       9    statement.  The one about taking everybody

      10    down that I just read.

      11              THE WITNESS:  You draw certain

      12    conclusions from that statement and I may

      13    draw different ones and I don't know what he

      14    means by take people down.  I  just -- I find

      15    it hard -- I'm not trying to be evasive.  I

      16    just find it hard to answer about what he's

      17    talking about.

      18              BY MR. KLAYMAN:

      19         Q    Are you aware that Stephanopoulos

      20    is in frequent contact with James Carville?

      21    You read the deposition?

      22         A    Beyond having read the deposition,








                                                              333


       1    it doesn't surprise me.  They're good friends

       2    to the best of my knowledge.

       3         Q    And from reading the deposition

       4    you're aware that Mr. Stephanopoulos talks to

       5    Carville as frequently, seven or so times a

       6    day?

       7         A    Beyond whatever -- I don't know

       8    whether that's what it said in the

       9    deposition, but beyond whatever it said in

      10    the deposition I don't have any knowledge of

      11    it.  But, again, it doesn't surprise me.

      12         Q    And you have observed Mr. Weiner

      13    frequently talking to Mr. Carville on the

      14    telephone, have you not?

      15         A    No, sir.

      16         Q    Do you monitor the telephone

      17    records of your office?  Do you ever review

      18    them?

      19         A    No, sir.

      20         Q    Do you have access to them?

      21         A    I have no idea.  What do you mean?

      22    Like who's called who?








                                                              334


       1         Q    Excuse me?

       2         A    What do you mean?  I don't know

       3    what you mean by telephone records.

       4         Q    I mean, you're aware that the

       5    telephone company or an internal computer can

       6    list the calls that are made on a telephone?

       7              MS. GILES:  Maybe the court

       8    reporter should read the last question that's

       9    pending.

      10                   (The reporter read the record as

      11                   requested.)

      12              THE WITNESS:  No.  Certainly at

      13    home.  I guess I'm not aware of what the

      14    system is.

      15              BY MR. KLAYMAN:

      16         Q    So you don't know how many times

      17    Mr. Weiner talks to Mr. Carville a day, if at

      18    all?

      19         A    If at all, I am not aware of it.

      20    I've never --

      21         Q    Even though -- I'm sorry.

      22         A    No, I've never asked for or, you








                                                              335


       1    know, looked at his phone records, no.

       2         Q    You don't know one way or the

       3    other?

       4         A    Correct.

       5              MS. GILES:  I need a two-minute

       6    break.  Is now a good time?

       7              MR. KLAYMAN:  Sure.

       8              VIDEO TECHNICIAN:  We're going off

       9    video record at 3:31 Eastern Standard Time.

      10                   (Recess)

      11              VIDEO TECHNICIAN:  We're back on

      12    video record at 3:38 Eastern Standard Time.

      13              BY MR. KLAYMAN:

      14         Q    Have you or anyone at the White

      15    House ever had a communication with Murray

      16    Waas?

      17         A    Communication?

      18         Q    Or received anything from him or

      19    talked to him or anything like that.

      20         A    Again, I -- answering for myself I

      21    can say no.  Answering for the White House, I

      22    couldn't do that.








                                                              336


       1         Q    Do you know who Murray Waas is?

       2         A    He's a writer, author.

       3         Q    Have you ever seen him in the White

       4    House?

       5         A    I wouldn't know him if I bumped

       6    into him.

       7         Q    Have you or anyone else had any

       8    contact with anyone from Salon Magazine other

       9    than pulling off the Web site?

      10         A    No.  Again, I can't -- I can't

      11    answer for the entire White House, put

      12    personally not to my knowledge, no.

      13         Q    Have you or anyone from the White

      14    House ever communicated or had any contact

      15    with Joe Conason of The New York Observer?

      16         A    I don't -- I mean I'm familiar with

      17    him as a writer, but I -- I don't know of

      18    anyone who's had contact with him, no.

      19         Q    Have you or anyone at the White

      20    House ever communicated with or had any

      21    contact with Lars Eric Nelson?

      22         A    Again, I'm familiar with his








                                                              337


       1    writing, but I'm not -- I don't know -- I

       2    have not had any contact with him and I don't

       3    know of anyone who has had contact with him.

       4         Q    Same question with regard to Peter

       5    Finn?

       6         A    Peter?

       7         Q    Finn.  Did you ever hear of Peter

       8    Finn?

       9         A    I'm not familiar with that name,

      10    no.  No, I haven't, honestly.

      11         Q    Are you aware of something called

      12    the communications stream of conspiracy

      13    commerce?

      14         A    The I'm sorry?

      15         Q    The communication stream of

      16    conspiracy commerce.  Did you ever hear

      17    anything like that, a research project that

      18    was prepared inside the White House about

      19    right wing media food chains?

      20         A    Media food chain.  Yeah, I vaguely

      21    recall, although I'm not sure.  Do you have

      22    a -- do you have it?  Do you know what --








                                                              338


       1              MR. KLAYMAN:  I can give you

       2    something that looks like it.  Let's mark it

       3    as -- this is a reprint of it -- as Exhibit

       4    7.

       5                   (Janenda Deposition Exhibit

       6                   No. 7 was marked for

       7                   identification.)

       8              MR. KLAYMAN:  I think y'all have

       9    seen this thing before.

      10              MS. ZIEGLER:  Actually, I haven't.

      11              MR. KLAYMAN:  You haven't.  Here's

      12    a complimentary copy.

      13              BY MR. KLAYMAN:

      14         Q    Take your time and leaf through

      15    that.  This is a reprint of it, but it

      16    contains the White House version --

      17         A    Off the top of my head this is

      18    not whatever I had in my head.  I've never

      19    seen this before.

      20         Q    Inside this thing, this was a

      21    reprint by the Western Journalism Center,

      22    contains the compilation of the White House.








                                                              339


       1    I'm just asking whether this refreshes your

       2    recollection as to whether you or anyone that

       3    you know of worked on a report inside the

       4    White House over how alleged right wing media

       5    communicates.

       6         A    This is -- there's something else

       7    in here besides the Western Journalism --

       8         Q    Yeah.

       9         A    -- because I've not seen this

      10    before.  I don't -- no, I'm not familiar with

      11    this.

      12         Q    Are you familiar with anyone in the

      13    White House having researched how right wing

      14    media communicates?

      15         A    No, sir.

      16         Q    Never heard of that?

      17         A    No, I -- I mean I have a vague

      18    recollection that there was something written

      19    in the paper, something about it, something,

      20    but I don't -- I've never seen this before.

      21         Q    Have you or anyone else at the

      22    White House ever had contact with a Larry








                                                              340


       1    Potts?

       2         A    That name doesn't ring any bills

       3    for me.

       4         Q    Gloria Sutherland?

       5         A    Again --

       6              MS. GILES:  Just to clarify, he can

       7    only speak for his own person knowledge.

       8              THE WITNESS:  Right.  I'm sorry.

       9              MS. GILES:  Not the whole White

      10    House.

      11              BY MR. KLAYMAN:

      12         Q    Yeah, everything is within your own

      13    personal knowledge.

      14              Has your office ever had any

      15    contact or communication with Robert Bennett?

      16         A    Not to my knowledge, no.

      17         Q    David Kendall?

      18         A    No.  I think you already asked me

      19    that.  No.

      20         Q    Have you ever met or had any

      21    contact with Marsha Scott?

      22         A    I wouldn't want to say no.  I think








                                                              341


       1    she may still work at the White House but I

       2    don't have any recollection of having met

       3    her, no.

       4         Q    Has she ever had any contact with

       5    your office to the best of your knowledge?

       6         A    I hate to speculate, but if she

       7    still works at the White House, it might be a

       8    woman who was involved with the Hormel

       9    nomination whose name I may have heard on a

      10    phone call or something, but I'm not

      11    positive.

      12         Q    Has your office done research on

      13    the Hormel nomination?

      14         A    Yeah, I -- yeah, certainly.

      15         Q    What issue in particular did you

      16    research concerning that nomination?

      17              MS. GILES:  The details about

      18    nominees is very sensitive and other than

      19    asking if they used FBI files or

      20    inappropriately used government files,

      21    anything along those lines, I'm instructing

      22    the witness not to get into details.








                                                              342


       1              BY MR. KLAYMAN:

       2         Q    Well, let me ask this question:

       3    Obviously you're aware of what the

       4    controversy is concerning Mr. Hormel, right,

       5    without getting into it, just generally

       6    speaking?

       7         A    I know that there are republicans

       8    who oppose his nomination, yes.

       9         Q    And do you know why?

      10         A    Speaking on their behalf?

      11         Q    No, based on what you have

      12    knowledge of.

      13         A    Yeah, because he's gay, as far as I

      14    know.

      15         Q    And what I'm going to ask you is

      16    whether you have ever looked into or know

      17    whether anyone else has looked into that

      18    issue with regard to republicans.

      19         A    Restate the question.

      20              MS. GILES:  Mr. Hormel or --

      21              BY MR. KLAYMAN:

      22         Q    No, Republicans.  Are you aware of








                                                              343


       1    anyone at the White House commissioning

       2    research to find out whether Republicans had

       3    similar sexual preferences?

       4         A    No, sir, absolutely not.

       5         Q    Is it ever your job or anybody

       6    else's that you know of to try to blunt

       7    criticism that Republicans or other political

       8    adversaries may level by showing that, in

       9    fact, they do the same things?

      10         A    On policy grounds I'm sure, you

      11    know, something -- like if we're going to

      12    be -- yeah, it's probably happened, sure.

      13         Q    Did your office play a role in

      14    researching whether republicans took foreign

      15    money to, for instance, during the last

      16    campaign?

      17         A    No, sir.  I'm confused as to what

      18    you're asking.

      19         Q    Well, I'm getting to the --

      20         A    While I worked at the White House?

      21         Q    In other words, the old everybody

      22    does it defense, which we hear very








                                                              344


       1    frequently in political circles no matter

       2    what your political persuasion.

       3         A    No.

       4         Q    You've heard people raise that as a

       5    defense everybody does it, right?

       6         A    I'm aware that, yeah, I've heard it

       7    before.

       8         Q    But who in the White House does

       9    that kind of research, the everybody does it

      10    research we'll call it?

      11         A    It's a term I couldn't possibly

      12    define.  And your specific question, but I'll

      13    answer it, is who, if anyone, in the White

      14    House does research on campaign finance --

      15         Q    Or on any issue.

      16         A    -- whatever, I'm not aware of what

      17    -- but just to answer that question.

      18         Q    I mean, let's say there's an

      19    allegation that --

      20         A    Can I answer that question?

      21         Q    Sure, sure.

      22         A    I'm not aware that anyone -- you








                                                              345


       1    know, people read the newspapers, but I'm not

       2    aware of anyone having, you know, in the

       3    White House having done that.

       4         Q    Let me just pose a hypothetical.

       5    I'm not trying to be funny or anything, but

       6    suppose an allegation is raised that somebody

       7    does something in the White House that's

       8    raised by a political opponent that that

       9    political opponent is saying is

      10    inappropriate.  Is there anyone at the White

      11    House or any office of the White House that

      12    would be in charge with researching to show

      13    that the person who made that accusation does

      14    the same stuff?

      15              MS. GILES:  Objection.

      16    Hypothetical.

      17              BY MR. KLAYMAN:

      18         Q    You can respond.

      19         A    No, to the best of my knowledge.

      20         Q    That stuff doe snot go on at the

      21    White House, that kind of research?

      22         A    No, I don't think so in terms of








                                                              346


       1    tasking somebody to do research, no.  I'm not

       2    saying that there aren't people who talk to

       3    reporters who don't say such things.  I'm

       4    just saying that I don't -- I'm not aware of

       5    any of office that is tasked with -- and to

       6    my knowledge there is no such office.

       7         Q    What does it go on, on a

       8    person-by-person basis?

       9         A    Again, I'm just trying to be clear.

      10    I can't -- I'm just saying --

      11         Q    Well, let me give you an example.

      12         A    I can answer there's no office and

      13    it's not my office.

      14         Q    During Thompson's campaign finance

      15    investigation last fall -- you're aware of

      16    that, right?

      17         A    Uh-huh, yes.

      18         Q    Were you ever asked to do any

      19    research by anyone in the White House about

      20    campaign finance issues?

      21              MS. GILES:  Objection.  Campaign

      22    finance isn't relevant.  Again, if you want








                                                              347


       1    to get into the types of research he did,

       2    whether he looked at FBI files, government

       3    files --

       4              MR. KLAYMAN:  I'm trying to figure

       5    out how this thing operates.  I mean so far

       6    after five hours of deposition I still can't

       7    figure out what they.

       8              MS. GILES:  He's been very clear of

       9    what he does.  If you want to get --

      10              MR. KLAYMAN:  And, frankly, I can't

      11    figure out what his role is.

      12              THE WITNESS:  I'm happy --

      13              MR. KLAYMAN:  So I'm having

      14    difficulty.

      15              THE WITNESS:  Is that a question?

      16    I'm h happy to restate what it is my office

      17    does, which is to track the administration of

      18    accomplishments, to vet people who are coming

      19    to Presidential events, to help prepare paper

      20    for Presidential events that come out of the

      21    communications office and, generally, be

      22    aware of what's happening in the world.  And








                                                              348


       1    I'm sure others, you know, as -- as they come

       2    up.

       3              BY MR. KLAYMAN:

       4         Q    Well, I'm asking you as well.  I

       5    know that's what you claim that's what your

       6    office does.  But are there other offices,

       7    based on your experience in the

       8    communications department, that do opposition

       9    research on what your opponents are doing?

      10         A    No, I'm not aware of any such

      11    office.

      12         Q    Now, you are aware during the

      13    campaign finance hearings last fall that

      14    people like Lonnie Davis, out of the White

      15    House Counsel's Office, were on T.V.

      16    frequently delineating how republicans had

      17    done the same types of thing the republicans

      18    were accusing democrats of doing.

      19         A    Sure.

      20         Q    You are aware of that?

      21         A    I am aware of that.

      22         Q    Now, do you have any knowledge as








                                                              349


       1    to whether Mr. Davis was getting his

       2    research?

       3         A    I really wouldn't want to answer

       4    for Mr. Davis.

       5         Q    I'm not asking you to answer for

       6    Mr. Davis.  I asked whether you had any

       7    knowledge as to where that research emanated

       8    upon which he was then able to make the

       9    statements he made.

      10         A    I'm sure that the Democratic

      11    National Committee, you know, was doing work

      12    that -- for -- for democrats who were trying

      13    to support the President and the

      14    administration during that period.  It

      15    wouldn't surprise me he were reading

      16    materials distributed by the Democratic

      17    National Committee.

      18         Q    Do they regularly supply the White

      19    House with that type of research, they

      20    meaning the DNC?

      21         A    The DNC, you know, as far as I

      22    know, routinely puts out press releases and








                                                              350


       1    other information that's available to anybody

       2    as far as I know.

       3         Q    Do they routinely send over

       4    opposition research to the White House?

       5         A    I never said that they send over

       6    opposition research to the White House.

       7         Q    That's what I just asked you.

       8    That's what I just asked you.

       9         A    You asked me -- all right.  Not --

      10    not to, you know, not to my knowledge.  I

      11    mean it's certainly routine for the DNC,

      12    whatever they are putting out, you know, for

      13    it to also go to the White House, but --

      14         Q    You were the head of the research

      15    office at the DNC?

      16         A    I was the deputy director.

      17         Q    Right.  And then you were the head

      18    of the research office for the campaign?

      19         A    Correct.

      20         Q    And that is the type of thing that

      21    you did in those two jobs, wasn't it, to show

      22    that republicans were doing the same things

 

 

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