401
1 Generally speaking, I was without it, but
2 there -- there -- I think there were a couple
3 of other people who did have accounts that I
4 was able to --
5 Q Who were those people?
6 A I believe Jason Goldberg. I
7 believe he had one. I'm -- I believe he had
8 one that I was able to borrow.
9 Q Where does Jason Goldberg work?
10 A In the Chief of Staff's office.
11 Q Do you know his job title?
12 A No.
13 Q Someone else? You mentioned
14 somebody else, I think, that --
15 A I -- that's the only one I can
16 remember.
17 Q How did that process work? Did
18 they sign on for you or did you ask to use
19 their computer to have them do research for
20 you? Did you give them the project, in other
21 words, or did you actually sit in front of
22 the screen and do --
402
1 A It may have worked both ways. I
2 may have -- I may have at one time just had
3 them call it up. I think it happened both
4 ways. I had them just call something up.
5 Q So today, once you were given your
6 own access to Nexis, as of today, you have a
7 user I.D. that you use that is specific to
8 Nexis? You have to have a particular I.D. to
9 sign onto Nexis? Is that how it works?
10 A I believe that's correct, yes. I
11 mean since I've had it, not today.
12 Q Using your current job as the basis
13 for that.
14 Were you provided training in the
15 use of Nexis?
16 A I think it was offered. It's --
17 you get it through the White House -- through
18 the library. I think they offered it, but I
19 didn't --
20 Q Can you access Nexis using your
21 I.D. number, whatever it's called, from a
22 computer in the White House library?
403
1 A I don't know.
2 Q You have never done that?
3 A I've never done that.
4 Q Can you access Nexis using your
5 official White House user I.D. or whatever is
6 required to get you onto Nexis from any other
7 site, like on the road with a laptop or, you
8 know, from a hotel somewhere, an airport?
9 A I don't -- no, I don't travel and I
10 don't own a laptop.
11 Q You've had some training on Nexis I
12 think you testified. That was provided by
13 White House employees?
14 A I didn't --
15 Q You didn't have training.
16 If you had a question about how to
17 use Nexis or a particular feature of the
18 Nexis package or program that is provided to
19 the White House, who did you turn to?
20 A I don't know. It's never happened.
21 Q You've never had a problem using
22 Nexis where you had to call somebody for
404
1 assistance? You never talked to the White
2 House library about it?
3 A I don't believe so other than I may
4 have called to complain that we couldn't get
5 on for something.
6 Q Do you have a manual that instructs
7 you how to use the Nexis system, as it's
8 described to you by the White House or as
9 it's purchased by the White House?
10 A I believe there is a manual that
11 Nexis puts out that lists what -- what
12 publications they carry.
13 Q What data bases are available on
14 the particular program?
15 A What publications are available.
16 Q You have a copy of that manual?
17 A There's one in the office I'm sure.
18 It might be old, but I'm sure there is one.
19 MR. BOSTION: We'd ask that a copy
20 of that manual be provided. If it's not
21 appropriate, we'll ask for it again.
22 BY MR. BOSTION:
405
1 Q But here's the question I want to
2 ask. Let's suppose you're in Nexis and you
3 wanted to do vetting. Let's assume you look
4 at newspapers. That would be a good thing
5 you would look at, right? You have an ad.
6 You look at some newspapers to check for
7 names. You look at magazines to check for
8 names?
9 MS. GILES: I'm sorry. Is there a
10 question to the first part or --
11 MR. BOSTION: Yes, I'll clarify it.
12 BY MR. BOSTION:
13 Q During the vetting call up a
14 newspaper data base that has a lot of
15 newspapers in it, you can search that data
16 base for names, can you not, a name?
17 A On Nexis?
18 Q Yes.
19 A Can you search for someone's name?
20 Q Yes.
21 A Yes.
22 Q Can you search on the Nexis system
406
1 accessible to you at the White House records
2 other than newspapers or magazines?
3 A I think -- I think that's the bulk
4 of what Nexis carries. I think they may
5 have --
6 Q Have you ever used --
7 A Let me finish the answer -- but I
8 wouldn't rule out that they also -- they may
9 have like newsletters or other -- I mean
10 they've got thousands of publications on
11 Nexis.
12 Q Have you ever used Nexis to search
13 for a public record kept or accessible
14 through Nexis such as, one, a court record?
15 A No, I don't believe I've had that.
16 Q You or your office or have you
17 ever --
18 A No. In answer to that, I'm not
19 aware of anyone in my office.
20 Q Have yourself or anyone in your
21 office ever used Nexis to search for driving
22 records?
407
1 A No. I'm not even aware that that's
2 possible.
3 Q Have you ever used Nexis to search
4 or had anyone in your office used Nexis or
5 aware of anyone in the White House who's used
6 Nexis to search for credit bureau
7 information?
8 A No, absolutely not, and, again, I'm
9 not even aware that that information is
10 available.
11 Q Have you ever used Nexis or has
12 anyone in your office ever used Nexis or
13 anyone in the White House that you know of
14 ever used Nexis to search for a Social
15 Security Number?
16 A Again, I -- now, are you asking me
17 or are you asking --
18 Q You. Let's start with you
19 personally.
20 A And have I -- to do what?
21 Q To look for Social Security
22 Numbers, match names with Social Security
408
1 Numbers.
2 A No, I don't believe I have,
3 although the caveat there is that it's
4 possible that -- I don't think so, but
5 oftentimes vetting will have a Social
6 Security Number and if it's a name -- if it's
7 a common name like John Smith, I wouldn't
8 rule out someone would have attempted as a
9 way to figure out it's the same John Smith,
10 but beyond that I don't -- it's not a common
11 practice and I don't know of anyone who's
12 done it.
13 Q How do you identify the project
14 you're looking for on Nexis? If you're
15 looking for a name, let's say, John Smith and
16 you sign on for a Nexis session, do you
17 identify each project with a project name,
18 each research section with a project name?
19 A Do I?
20 Q Yes.
21 A I don't know. I guess it -- it
22 varies. Whatever thought comes into your
409
1 mind that you think you will remember.
2 MS. GILES: Can we ask the
3 videographer what time you have.
4 VIDEO TECHNICIAN: We have 4:50.
5 MS. GILES: We've gone six hours.
6 MR. BOSTION: I have one more
7 question.
8 BY MR. BOSTION:
9 Q How is the output stored from each
10 session printed out? Do you keep it on
11 disks? Do you store it on the server?
12 A Again, as far as -- there is some
13 things you would just look at and not do
14 either of those things with.
15 Q There are some things --
16 A And are you -- are you asking me
17 about -- I'm sorry. Are we talking about our
18 vetting process?
19 Q I'm talking about any access to
20 Nexis.
21 A Any access to Nexis. I think it
22 varies widely. I mean you certainly would
410
1 look at an article and decide it's not
2 something you want and you wouldn't do either
3 of those things, but, generally speaking, I
4 would think that they're saved and they're
5 not -- I don't think we, generally, print
6 them, but I wouldn't speak for --
7 Q You have had experience in
8 downloading articles and items from Nexis and
9 saving them either in a hard copy, as you
10 call it, hard copy or on a server or
11 something like that? You have done that in
12 your experience or aware that others have
13 done it?
14 A Yes.
15 MR. BOSTION: That's all I have.
16 MS. GILES: We've gone our six
17 hours, so --
18 MR. KLAYMAN: That's fine. I'm
19 just putting this on the record. We're
20 leaving the deposition open given the times
21 that you've objected to several of the
22 document requests and other things that may
411
1 come up.
2 MS. GILES: And we --
3 MR. KLAYMAN: This concludes the
4 session for today.
5 MS. GILES: And we object to
6 leaving it open.
7 MR. KLAYMAN: Not that I agree, but
8 I note your objection.
9 VIDEO TECHNICIAN: We're going off
10 video record at 4:52 Eastern Standard Time.
11 (Whereupon, at 4:52 p.m., the
12 deposition of THOMAS D. JANENDA
13 was adjourned.)
14 * * * * *