351
         1          A    I've read.

         2          Q    Have you seen it?

         3          A    I've seen --

         4          Q    You said you didn't read it, but

         5     have you seen it?

         6          A    I've seen newspaper reports of it.

         7          Q    Well, what was it about Sue Schmitt

         8     that caused you to undertake a meeting about

         9     her?

        10          A    She was a reporter writing about

        11     the White House every day.

        12          Q    Was there a concern that she was

        13     writing articles that were negative to the

        14     White House?

        15          A    People are going to write articles

        16     negative to the White House.  You can't have

        17     a meeting about everyone that writes

        18     something negative about the White House.

        19               I remember one story in particular

        20     that was just absolutely wrong and I had

        21     discussions with people at The Washington

        22     Post about that.









                                                             352
         1          Q    Williams & Connolly represent The

         2     Washington Post, right?

         3          A    Asked and answered.

         4          Q    Has anyone at the White House ever

         5     used Mr. Kendall to make a point to The

         6     Washington Post with regard to a story?

         7          A    I'm sure David Kendall has talked

         8     to The Washington Post, but you'd have to ask

         9     him.

        10          Q    I'm asking whether the White House

        11     ever asked him to intercede with The

        12     Washington Post to get stories written more

        13     favorable.

        14          A    The White House isn't a person.

        15          Q    Based on your knowledge.

        16          A    What's the question?

        17          Q    Did anyone at the White House ever

        18     ask Mr. Kendall or anyone at Williams &

        19     Connolly to intercede with The Washington

        20     Post to have more favorable stories written

        21     about it?

        22          A    Not that I know of.









                                                             353
         1          Q    Was any request made to intercede

         2     through Mr. Kendall or anybody else at

         3     Williams & Connolly with regard to Sue

         4     Schmitt?

         5          A    No not that I know of.

         6          Q    Have there been any requests

         7     through Williams & Connolly for retaliation

         8     against The Washington Post for unfavorable

         9     stories?

        10          A    Not that I know of and I'm sure if

        11     that request were made, they would -- they

        12     would refuse to do it.

        13          Q    Was Williams & Connolly aware that

        14     the White House was gathering information on

        15     Sue Schmitt?

        16          A    You have to ask them.

        17          Q    Was there ever any discussion that

        18     this might put David Kendall and Williams &

        19     Connolly in a conflict of interest situation

        20     if you started investigating Sue Schmitt?

        21          A    Not that I know of.

        22          Q    Have you ever had any conversations









                                                             354
         1     with Peter Baker of The Washington Post?

         2          A    Sure.

         3          Q    While you were at the White House?

         4          A    Yes.

         5          Q    Did anyone ever set out to

         6     investigate him?

         7          A    Not that I know of.

         8          Q    In fact, he's quite favorably

         9     disposed to the White House, is he not?

        10          A    I don't really know.  He's a

        11     reporter.  He follows the facts as he sees

        12     them.

        13          Q    Has anyone had a bone to pick with

        14     Peter Baker when you were at the White House?

        15          A    What do you mean?

        16          Q    Anyone complain about his

        17     reporting?

        18          A    Not that I know of.  I always had

        19     good relations with him.  I don't think he

        20     was there when the FBI files story broke I

        21     should say for the record one more time.

        22               I question the relevance to the FBI









                                                             355
         1     files and I would say for the record that

         2     every single time a direct question about my

         3     direct knowledge about FBI files has been

         4     asked I have answered it fully and

         5     completely.

         6          Q    Thank you for that judgment,

         7     Mr. Stephanopoulos.

         8          A    You're welcome.

         9          Q    During the time that you were at

        10     the White House did anyone ever ask that a

        11     Washington Post reporter be removed from his

        12     or her beat?

        13          A    No, and were it asked, that would

        14     guarantee that that person would have

        15     lifetime tenure on that beat.

        16          Q    When you worked at the White House,

        17     were there reporters that were considered to

        18     be enemies of the Clinton White House?

        19          A    Not by me.

        20          Q    By others?

        21          A    Not that I know of.

        22          Q    Do you know whether that's true









                                                             356
         1     today based on your contacts with the White

         2     House?

         3          A    No.  As far as I know, there's no

         4     enemies list.

         5          Q    Chris Ruddy wouldn't qualify?

         6          A    As I said, he would qualify in my

         7     mind as a dishonest, disreputable, disgusting

         8     journalist, but not an enemy, no.

         9               MR. KLAYMAN:  I will show you what

        10     I will ask the court reporter to mark as

        11     Exhibit 12.

        12                    (Stephanopoulos Deposition

        13                    Exhibit No. 12 was marked for

        14                    identification.)

        15               BY MR. KLAYMAN:

        16          Q    I'm showing you what I have asked

        17     the court reporter to mark as Exhibit 12.

        18     Have you ever seen this document before,

        19     Mr. Stephanopoulos?

        20          A    I may have, but I couldn't swear to

        21     it.

        22          Q    Where do you think you saw it?









                                                             357
         1          A    I don't know.  It seems accurate.

         2          Q    Did you see it during the time you

         3     worked at the White House?

         4          A    I'm not sure.

         5          Q    Was it provided to you by

         6     Mr. Begala?

         7          A    Actually probably not because, for

         8     instance, the John Huang situation really

         9     came up after I left the White House.  It was

        10     up a little bit towards the end.  But I don't

        11     really know.

        12          Q    Was this document provided to you

        13     by Mr. Begala?

        14          A    I don't know.

        15          Q    Has he provided documents to you

        16     since you left the White House from time to

        17     time?

        18          A    He sometimes sent me speeches that

        19     he's read, public record documents.  Nothing

        20     that wasn't on the public record.

        21               MR. KLAYMAN:  I show you what will

        22     ask the court reporter to mark as Exhibit 13.









                                                             358
         1                    (Stephanopoulos Deposition

         2                    Exhibit No. 13 was marked for

         3                    identification.)

         4               BY MR. KLAYMAN:

         5          Q    Showing you Exhibit 13, this is a

         6     document that says, "Gingrich Keeps His

         7     Promise."  Have you ever seen this document

         8     before?

         9          A    No.

        10          Q    Have you ever heard reference to

        11     this document before?

        12          A    I wouldn't know how it would be

        13     referred to.

        14          Q    When did you first learn of a Craig

        15     Livingstone?

        16          A    I don't know.  My guess is it was

        17     probably in the -- during the inaugural or

        18     the transition, but if it wasn't then, it was

        19     sometime close after that.

        20          Q    How did you learn of him?

        21          A    He was an advance guy.

        22          Q    Do you know who hired him as an









                                                             359
         1     advance guy?

         2          A    No.

         3          Q    What's the definition of an advance

         4     guy?

         5          A    Someone who works on advance.

         6          Q    What is advance?

         7          A    It means you go to a place where

         8     the President or candidate is supposed to be

         9     in advance of his or her arrival to prepare

        10     the site.

        11          Q    In the course of your duties and

        12     responsibilities in the '92 campaign you came

        13     in contact with Mr. Livingstone from time to

        14     time, correct?

        15          A    I don't know.  I may have.  I mean

        16     I came in contact with thousands of advance

        17     people because sometimes I would travel with

        18     the President, but I don't remember it.

        19               I do -- I think -- I have a more

        20     distinct memory that it happened either

        21     during the transition or the inaugural.

        22          Q    During the 1992 campaign, did the









                                                             360
         1     campaign conduct research on opposition

         2     candidates?

         3          A    Certainly.

         4          Q    How did it do that?

         5          A    We had a team of researchers, went

         6     through the public record.

         7          Q    Who were those researchers?

         8          A    Lots of them.

         9          Q    Such as?

        10          A    Eric Berman headed them.  He had a

        11     team.

        12          Q    Did the campaign employ private

        13     investigators?

        14          A    If they did, I had nothing to do

        15     with it.

        16          Q    Well, I'm asking whether you have

        17     knowledge of that.

        18          A    I've read some reports that maybe

        19     the campaign did.  I don't know if it's true

        20     or not.

        21          Q    Do you have any knowledge yourself

        22     that they did?









                                                             361
         1          A    No.

         2          Q    Did you ever discuss during the

         3     campaign opposition research with Paul

         4     Begala?

         5          A    Sure.

         6          Q    Did you ever discuss opposition

         7     research with regard to adversaries of

         8     Governor Clinton?

         9          A    Mostly it was about President Bush

        10     and his record.

        11          Q    Did you ever discuss opposition

        12     research with regard to democratic candidates

        13     in the primary?

        14          A    May have.  We didn't really do --

        15     we didn't really -- there were a couple of

        16     times in votes, things like pay raises, we

        17     might bring that up, but nothing that wasn't

        18     on the public record.

        19          Q    Did you ever discuss opposition

        20     research with anyone concerning Governor

        21     Jerry Brown?

        22          A    It's conceivable that I did, but I









                                                             362
         1     don't know that I did.

         2          Q    Are you aware of an incident

         3     involving alleged drug usage in his house in

         4     California?

         5          A    I know that John McQwithy of ABC

         6     News reported that.

         7          Q    Was that information fed to him by

         8     the Clinton campaign?

         9          A    I don't think so.

        10          Q    But you're not sure?

        11          A    I'm not sure.

        12          Q    You're not sure?

        13          A    What do you mean by I'm not sure?

        14     I gave you my answer.

        15          Q    What's your answer?

        16          A    I don't think so.  I certainly

        17     didn't do it.

        18          Q    Do you know of anyone hiring a

        19     private investigator to look into drug usage

        20     by Governor Brown?

        21          A    If I didn't know about anyone

        22     hiring a private investigator, I couldn't,









                                                             363
         1     therefore, know about anybody being hired as

         2     a private investigator to look into Jerry

         3     Brown.

         4          Q    Did James Carville get himself

         5     involved in opposition research during the

         6     campaign in any way?

         7          A    Yeah, maybe -- maybe reading the

         8     research on the public record, sure.

         9          Q    What research did he read on the

        10     public record?

        11          A    The fact that George Bush had the

        12     largest tax increase in American history.

        13     That's one example.

        14          Q    What was Hillary Clinton's role

        15     during the campaign?

        16          A    She was helping her husband run for

        17     president.

        18          Q    Did she get involved in opposition

        19     research in any way?

        20          A    Not really, no.

        21          Q    But she did it in part, did she

        22     not?









                                                             364
         1          A    I don't have any direct knowledge

         2     of that.

         3          Q    Who would have direct knowledge of

         4     that?

         5          A    Ask her.

         6          Q    Who worked with her during the

         7     campaign?  Who was her contingent?

         8          A    Sorry.

         9          Q    Who was her contingent?

        10          A    She had a lot of people work for

        11     her.  I wasn't on her staff.

        12          Q    Who worked for her during the

        13     campaign?

        14          A    A lot of people worked for her.  I

        15     have no idea what happened --

        16          Q    Who was the primary person?

        17          A    What happened in 1992, what

        18     conceivable relevance could that have with

        19     what happened to the FBI files in the White

        20     House in 1996?

        21          Q    Who was the person who worked with

        22     her most closely during the 1992 campaign?









                                                             365
         1          A    I don't have an answer to that.  A

         2     lot of people worked with her.  Magee

         3     Williams I guess.

         4          Q    Anyone else?

         5          A    A lot of people worked with her.

         6     She had a press secretary.

         7          Q    Who was the press secretary?

         8          A    It was Richard Mintz for a while

         9     and Jody Franklin worked with her.  She had a

        10     whole staff.

        11          Q    Did Micky Kantor work with her?

        12          A    I'm sure he talked to her.

        13          Q    Do you know whether she worked with

        14     any private investigators?

        15          A    No.

        16          Q    Tell me what, if anything, you know

        17     about what Craig Livingstone did during the

        18     inaugural.

        19          A    I don't really know.  I know he did

        20     something having to do with advance and

        21     security, but I don't know what it was

        22     largely.  Rahm Emanuel ran the inaugural.  I









                                                             366
         1     was mostly in Little Rock dealing with the

         2     transition.

         3          Q    Rahm Emanuel would know that?

         4          A    I don't know that he would know it.

         5          Q    But he'd be the person you would

         6     think of that would know that?

         7          A    Not necessarily.  Craig Livingstone

         8     wasn't that high level an employee.

         9          Q    Did he have a reputation by the

        10     time of the inaugural for any aspect of his

        11     work characteristics?

        12          A    Not that I know of.

        13          Q    Did there come a point in time when

        14     Craig Livingstone's reputation was discussed

        15     at the White House when you were there?

        16          A    After the -- the story broke.

        17          Q    Who did you discuss his reputation

        18     with?

        19          A    I don't know if I discussed his

        20     reputation in particular, but we discussed

        21     this case and it seemed like a terrible

        22     mistake.









                                                             367
         1          Q    Was Craig Livingstone's reputation

         2     discussed?

         3          A    What does that mean?

         4          Q    Did anyone check the guy out to

         5     find out where he came from, how he got into

         6     the position of White House Director of

         7     Security et cetera?

         8          A    Well, I answered that in David

         9     Brinkley's transcript of what my knowledge

        10     was of how he got hired.

        11          Q    To the best of your knowledge,

        12     after the FBI files controversy broke did

        13     anyone confront Craig Livingstone with what

        14     had happened?

        15          A    I assume so, yeah.  He was

        16     disciplined.

        17          Q    Who confronted him?

        18          A    I don't know if it was Jack Quinn

        19     or Leon Panetta, but it was someone in

        20     management.

        21          Q    In fact, he was put on

        22     administrative leave with pay, correct?









                                                             368
         1          A    If you say so.

         2          Q    You're aware of that, correct?

         3          A    I know that something happened.  I

         4     don't know what exactly it was.

         5          Q    How is administrative leave with

         6     pay discipline?

         7          A    Sounds like discipline to me.

         8          Q    Not having to work and getting paid

         9     for it, that's discipline?

        10          A    I think Craig Livingstone has

        11     paid -- has paid the price for his mistake.

        12          Q    How so?

        13          A    He's got to be dragged through all

        14     this.  He made a mistake.  He's been, you

        15     know, written about, talked about, been

        16     dragged through innumerable hearings and

        17     investigations.

        18               And I believe that, you know, for a

        19     mistake which was severe was, to my mind,

        20     based on everything I know, an innocent, but

        21     egregious screw-up.

        22          Q    During the time you worked in the









                                                             369
         1     White House did you become aware that Craig

         2     Livingstone had threatened to smash in the

         3     face of his next door neighbor?

         4          A    I read press reports after the FBI

         5     story broke about that.  I have no

         6     independent knowledge of it.

         7          Q    In fact, a criminal complaint had

         8     been filed against him by the next door

         9     neighbor?

        10          A    I read press reports.  I had no

        11     independent knowledge.

        12          Q    Was that a subject of discussion at

        13     the White House when that story broke?

        14          A    I assume so.  I don't remember the

        15     specific discussion.

        16          Q    Was there any investigation

        17     undertaken to find out the circumstances of

        18     him threatening to smash in the face of his

        19     next door neighbor?

        20          A    Not that I know of.

        21          Q    No one really cared, did they?

        22          A    I didn't say that.  As far as I









                                                             370
         1     know, he was disciplined.

         2          Q    By who?

         3          A    I already answered that question.

         4          Q    During the time that you worked in

         5     the White House did you ever encounter Chris

         6     Livingstone?

         7          A    Sure.

         8          Q    Where did you encounter him?

         9          A    The hallway.  He might have come to

        10     my office one or twice.

        11          Q    What were the circumstances of him

        12     coming to your office?

        13          A    He once came to ask if I would make

        14     a phone call to his hometown newspaper, which

        15     I agreed to do.  People ask me to do that

        16     kind of thing all the time.  That's the only

        17     one I really remember.  That's the smoking

        18     gun.

        19          Q    Did you make a comment to your

        20     hometown newspaper?

        21          A    To my hometown --

        22          Q    To his hometown newspaper?









                                                             371
         1          A    Yes.

         2          Q    What was that comment?

         3          A    I don't remember.  If you have a

         4     copy of it, I'd be happy to read it back.

         5               MR. KLAYMAN:  I'll show you what I

         6     will ask the court reporter to mark as

         7     Exhibit 14.

         8                    (Stephanopoulos Deposition

         9                    Exhibit No. 14 was marked for

        10                    identification.)

        11               BY MR. KLAYMAN:

        12          Q    Showing you Exhibit 14.  Can you

        13     turn to page two?

        14          A    Okay.

        15          Q    Do you see where it says,

        16     "Stephanopoulos has worked with Livingstone

        17     since Clinton's Presidential campaign.  Gives

        18     him high marks.  He does a terrific job.

        19               All I know is that anything that he

        20     has to do with security or logistics, Craig

        21     is going to take care of it.

        22               You don't have to tell him how to









                                                             372
         1     do it, when to do it, just that it needs to

         2     be done and he does it and he knows how to

         3     cut through the bureaucracy and get thing

         4     done."  That's your quote, is it not?

         5          A    Uh-huh.

         6          Q    Where did you get the information

         7     to be able to make that statement about

         8     Mr. Livingstone.

         9          A    It's my impression.  That's why --

        10     that's why I said all I know.

        11          Q    Based on your experience, did you

        12     draw that impression from working with him?

        13          A    Not particularly closely, but, you

        14     know, he seemed to do a good job from what I

        15     could tell.

        16          Q    Let's go back over this.  "He does

        17     a terrific job."  How did you get the

        18     information that he does a terrific job?  Did

        19     you work with him before?

        20          A    I encountered him sometimes in the

        21     White House.  He ran some events.  He seemed

        22     to do a good job.









                                                             373
         1          Q    What events did he run?

         2          A    I don't know.

         3          Q    How do you make a statement about

         4     somebody if you can't remember what he did?

         5          A    Well, then I may have been able to

         6     remember something.  Five years later I can't

         7     remember it.  I just don't know exactly what

         8     he did.

         9               I know he's an advance person doing

        10     events.  This -- I was trying to do a nice

        11     thing for him for his hometown newspaper.

        12     That's not a criminal act.

        13          Q    You were lying to the hometown

        14     newspaper?

        15          A    I didn't say that.  I don't know

        16     why you put that in the record.  I think it

        17     shows one more time that all you're doing

        18     here is -- is trying to harass me rather than

        19     get answers to the questions.

        20          Q    But do you frequently provide

        21     information to the press if you don't have a

        22     foundation, factual foundation to do it?









                                                             374
         1          A    I didn't say I didn't have a

         2     factual foundation to do it.  That was my

         3     impression.  This was a profile in a local

         4     newspaper about a young guy who has, he

         5     described, a second-tier job at the White

         6     House.  It was a nice thing to do.  It took

         7     me 30 seconds.  I didn't think about it

         8     again.

         9          Q    The second statement, "All I know

        10     is that anything that has anything to do with

        11     security or logistics Craig is going to take

        12     care of it."

        13               How did you get the factual

        14     foundation to be able to make that statement

        15     to Mr. Livingstone's hometown newspaper?

        16          A    Because that was his job and I

        17     didn't have any evidence to the contrary.

        18     That's why I also said "all I know."

        19          Q    You had a deep factual knowledge as

        20     to what he was doing in the security area,

        21     did you not?

        22          A    I didn't say that.  If you want to









                                                             375
         1     read back my answer, I'm happy to do that.

         2          Q    What is it that Craig had done with

         3     security up to that point in time that

         4     allowed you to make the statement to the

         5     hometown newspaper?

         6          A    He had been the director of

         7     security.  I had never heard any real

         8     complaints.  I didn't know much about it.  He

         9     asked me to do a favor for him.  I did.  You

        10     know, sue me.

        11          Q    Who is going to sue you?

        12          A    It's a figure of speech.

        13          Q    Next statement, "You don't have to

        14     tell him how to do it, when to do it, just

        15     that it needs to be done and he does it and

        16     he knows how to cut through the bureaucracy

        17     and get things done."

        18               What information did have at the

        19     time you made this statement that Craig

        20     Livingstone was an efficient individual that

        21     could cut through the bureaucracy and get

        22     things done?









                                                             376
         1          A    I had no evidence to the contrary.

         2     Again, it was a nice thing to say.  It's

         3     basic boiler plate language.

         4          Q    Basic BS to the press?

         5          A    I didn't say that.

         6          Q    Do you know where Craig Livingstone

         7     is today?

         8          A    No.

         9          Q    Have you ever discussed Craig

        10     Livingstone's hiring with Hillary Rodham

        11     Clinton?

        12          A    No.

        13          Q    Have you ever met Anthony Marceca?

        14          A    Not that I know of, no.

        15          Q    Do you know what he did at the

        16     White House?

        17          A    Not really, no.  I've read

        18     public -- public reports about what he may

        19     have done.  I have no independent knowledge.

        20          Q    Have you ever discussed politics

        21     with Craig Livingstone?

        22          A    I don't think so, no.









                                                             377
         1          Q    Did you ever discuss personnel

         2     matters with Craig Livingstone?

         3          A    I don't think so, no.  I think once

         4     he called my office asking me to recommend

         5     him to run the White House Military Office

         6     and I didn't know enough -- enough about his

         7     background to do that so I didn't do it.

         8     Just let it go.

         9          Q    Did you ever visit the Office of

        10     Personnel Security?

        11          A    No.

        12          Q    Did you ever go into the vault in

        13     the Office of Personnel Security?

        14          A    If I didn't visit the office, I

        15     didn't go in the vault.

        16          Q    Did anyone in the immediate entree

        17     of people that worked with you ever go to the

        18     Office of Personnel Security?

        19          A    No.

        20               MR. KLAYMAN:  I will show you what

        21     I will ask the court reporter to mark as

        22     Exhibit 15.









                                                             378
         1                    (Stephanopoulos Deposition

         2                    Exhibit No. 15 was marked for

         3                    identification.)

         4               BY MR. KLAYMAN:

         5          Q    I'm showing you Exhibit 15, which

         6     is an excerpt from Security of Background

         7     Files, July 17th, 1996, "Hearing Before the

         8     Committee on Government Reform and Oversight,

         9     House of Representatives," July 17th 1996.

        10               Turning to the third page, which is

        11     on White House stationery, a letter dated

        12     5/27/94.  "Dear George."  It goes on to the

        13     next page, bears Bates numbers 046222 to

        14     046223.  Have you ever seen this document

        15     before?

        16          A    Yes.

        17          Q    When did you first see it?

        18          A    When I was asked -- well, I assume

        19     when I was in the White House and then when I

        20     went and testified on it before the House

        21     Government Affairs Committee.

        22          Q    This is a letter that you got from









                                                             379
         1     Craig Livingstone?

         2          A    That's what it looks like.

         3          Q    Let me read it to you.

         4               Did you get it on or about May

         5     27th, 1994?

         6          A    That's the date on it.

         7               MR. BRAND:  You don't have to read

         8     it to us, Larry.  We can read it.  Just tell

         9     us what you want --

        10               MR. KLAYMAN:  I want it in the

        11     record.  "Dear George."

        12               MR. BRAND:  It's in the record when

        13     you marked it as an exhibit.  Why do we have

        14     to waste time with this?

        15               MR. KLAYMAN:  We're not wasting

        16     time.

        17               MR. BRAND:  Your reading of

        18     documents is a waste of time.

        19               MR. KLAYMAN:  I'll conduct it the

        20     way I want to conduct it.

        21               MR. BRAND:  If you have a question

        22     about it, ask it.









                                                             380
         1               MR. KLAYMAN:  Mr. Brand, you've

         2     already taken up more time it takes me to

         3     read it.

         4               BY MR. KLAYMAN:

         5          Q    "Dear George:  Thank you for

         6     offering to be of assistance in my efforts to

         7     further serve the President as Director of

         8     the White House Military Office.  Points to

         9     consider:  If asked, Colonel Reins."  Can you

        10     read the next word?

        11               MR. BRAND:  It's not his letter.

        12               THE WITNESS:  You're the one

        13     reading it.

        14               MR. BRAND:  He didn't write it.

        15               BY MR. KLAYMAN:

        16          Q    Can you read the next word?

        17          A    You're the one who wants to read

        18     the letter.  It looks like an "and" to me.

        19          Q    "Colonel Reins and other."  What's

        20     the next word?

        21          A    I'm not going to -- if you want to

        22     read the letter, you read it.  If you can't









                                                             381
         1     read his handwriting, then tough.

         2          Q    I'm asking you for your assistance,

         3     here.  You got the letter.  Did you

         4     understand it when you read it?

         5          A    I understood the basic gist of it,

         6     sure.

         7          Q    Can you read the third paragraph

         8     for me?

         9          A    "If asked, Colonel Reins and

        10     others" -- that looks likes WHMO, which is an

        11     acronym for White House Military Office --

        12     military commanders advised that they would

        13     be happy to work with me."

        14          Q    "I have all the appropriate

        15     clearances.  I have worked with the military

        16     for 14 months.  The job by nature should have

        17     someone with sound political skills,

        18     particularly as we approach NH, New

        19     Hampshire.  I appreciate your counsel and

        20     consideration.  I would be honored to serve

        21     my President in this new position.  I won't

        22     let him down.  Best Wishes.  Craig









                                                             382
         1     Livingstone."

         2               Had you ever received a letter from

         3     Craig Livingstone before this one?

         4          A    Not that I know of.

         5          Q    Did you take any action with regard

         6     to this letter that Mr. Livingstone sent you?

         7          A    You can read the previous page and

         8     if you read it, my --

         9          Q    I'm not asking for the previous

        10     page.

        11          A    Well, I'm going to tell you the

        12     previous page.  I got a note from my

        13     assistant, who read the letter, saying what

        14     should we do with this and I wrote nothing.

        15          Q    Who was your assistant?

        16          A    Which is exactly what we did.

        17     Ms. Heather Beckel.

        18          Q    Why did you do nothing?

        19          A    Because I didn't want to do

        20     anything.  I didn't know enough about him or

        21     his background or the White House Military

        22     Office.  It had nothing to do with my









                                                             383
         1     responsibilities.

         2          Q    Do you know what the military

         3     office meant, what that reference meant?

         4          A    In general terms.

         5          Q    What is it?

         6          A    White House Military Office.

         7          Q    Is there such a thing?

         8          A    Yeah.

         9          Q    Did you ever have contact with the

        10     White House Military Office, while you were

        11     there?

        12          A    The President has a military aide.

        13     I would see the military aide occasionally on

        14     trips.

        15          Q    What was meant by New Hampshire in

        16     that letter to the best of your knowledge?

        17          A    You have to ask Craig.

        18          Q    Why was the military office

        19     important for New Hampshire?

        20          A    I have no idea.

        21          Q    Was he talking about the primary

        22     in 1996?









                                                             384
         1          A    You have to ask him.  I got the

         2     letter, read it, did nothing, instructed my

         3     assistant to do nothing.

         4          Q    During the time that you were at

         5     the White House did you ever speak with

         6     William Sessions?

         7          A    Maybe on the day he left there was

         8     some ceremony, or the day he was reappointed.

         9     I don't know.  I might have shook his hand.

        10     That's about it.

        11          Q    You ever discuss the FBI files

        12     matter with him?

        13          A    No.

        14          Q    Did you ever have a discussion with

        15     Director Lewis Freeh when you were at the

        16     White House?

        17          A    I sat next to him at a dinner party

        18     once.

        19          Q    Did you ever discuss the FBI files

        20     matter?

        21          A    No.

        22          Q    Have you had a conversation with









                                                             385
         1     Director Lewis Freeh since you left the White

         2     House?

         3          A    No.

         4          Q    Howard Shapiro, have you ever had a

         5     conversation with him while you were at the

         6     White House?

         7          A    I already answered that.

         8          Q    Did you ever talk to him about Gary

         9     Aldrich's book when you were at the White

        10     House?

        11          A    No.

        12          Q    Have you talked to him about Gary

        13     Aldrich's book since you left the White

        14     House?

        15          A    No.

        16          Q    Any other matter?

        17          A    No.

        18          Q    When did you first learn that there

        19     was an investigation into the Travel Office?

        20          A    I don't remember.

        21          Q    Excuse me?

        22          A    It depends what you consider an









                                                             386
         1     investigation.

         2               MR. BRAND:  What does that have to

         3     do with this case?

         4               MR. KLAYMAN:  Listen, Mr. Brand.

         5               BY MR. KLAYMAN:

         6          Q    When did you first learn of the

         7     Travel Office controversy?

         8          A    I said I don't remember.  Sometime

         9     in May 1993, I assume.

        10          Q    How did it come to your attention?

        11          A    I don't remember exactly, you

        12     know -- actually.  Wait.  No, no, I do.  I

        13     was in -- I was receiving an award from my

        14     university, Columbia University, and I got a

        15     beep from Andrea Mitchell, of NBC News, said

        16     something about the Travel Office was

        17     breaking.

        18               I had had some brief conversations

        19     before that, I think, with Jeff Eller once in

        20     a parking lot, but I didn't know that it was

        21     really about to break.

        22          Q    What did Andrea Mitchell tell you









                                                             387
         1     specifically?

         2          A    It was a beep.  It wasn't a

         3     conversation.

         4          Q    Did you call her back?

         5          A    When I got back to the White House.

         6          Q    What did she say to you?

         7          A    Well, by the time I got back to the

         8     White House, it was kind of irrelevant.

         9     There was a big story, they had done the

        10     firing, they had done a press briefing.

        11               Again, I have no idea that was

        12     something that happened in May of 1993 has to

        13     do with the FBI files in June of 1996.

        14          Q    Up to that point in May of 1993 had

        15     you met Harry Thomasson?

        16          A    Thomasson.

        17          Q    Have you ever met him?

        18          A    I have met him.

        19          Q    How is that pronounced?

        20          A    Thomasson.

        21          Q    Thomasson.  Yes?

        22          A    Uh-huh.









                                                             388
         1          Q    Were you aware of any desire on his

         2     part to take over the Travel Office?

         3          A    Not until after the fact.

         4          Q    Had you ever met his wife?

         5          A    Sure.

         6          Q    What was her name?

         7          A    Linda Bloodworth Thomasson?

         8          Q    Were you aware from her of any

         9     desire to take over the Travel Office?

        10          A    No, I don't know that they had any

        11     desire to take over the Travel Office.

        12          Q    Had you ever met Katherine

        13     Cornelius up to that point in time?

        14          A    Sure.

        15          Q    In what capacity had you met her?

        16          A    I met her when I moved to Arkansas

        17     in the campaign.  I saw her occasionally

        18     during the course of campaign.

        19          Q    Were you aware of any desire on

        20     Katherine Cornelius' part to have someone

        21     else take over the Travel Office?

        22          A    After the fact, but I've learned a









                                                             389
         1     lot since that happened.

         2               MR. KLAYMAN:  I'll show you what I

         3     will ask the court reporter to mark as

         4     Exhibit 16.

         5                    (Stephanopoulos Deposition

         6                    Exhibit No. 16 was marked for

         7                    identification.)

         8               BY MR. KLAYMAN:

         9          Q    Showing you Exhibit 16.

        10               MS. SHAPIRO:  Do you have a copy

        11     for us?

        12               BY MR. KLAYMAN:

        13          Q    This is an excerpt from your

        14     deposition before the Government Reform and

        15     Oversight Committee, is it not,

        16     Mr. Stephanopoulos?

        17          A    It looks like it.

        18          Q    Turn to page three, where it says,

        19     "Question:  The First Lady is CC'd on that

        20     memo.  Was there any procedure that you had

        21     or those who worked for you had concerning

        22     CC'ing the First Lady on the memorandum in









                                                             390
         1     the White House?"

         2          A    I stand by the answer.

         3          Q    Do you know what's being referred

         4     to there?

         5          A    I stand by the answer I gave there.

         6          Q    Was there a type of information

         7     that would be CC'd did to the First Lady?

         8          A    I stand by the answer I gave there.

         9          Q    Since you've given that deposition

        10     do you have any information as to how the

        11     First Lady was CC'd on matters involving the

        12     Travel Office affair?

        13          A    No.

        14          Q    Was it the First Lady who

        15     encouraged the firing of the Travel Office

        16     staff?

        17          A    Not that I know of.

        18               MS. SHAPIRO:  Objection to the

        19     relevancy of this for the record.

        20               BY MR. KLAYMAN:

        21          Q    Are you saying that she did or she

        22     didn't?









                                                             391
         1               MS. SHAPIRO:  Will you let me state

         2     my objection, please?

         3               MR. KLAYMAN:  I thought you just

         4     did.

         5               MS. SHAPIRO:  You talked over me

         6     and I want to make sure it's picked up by the

         7     reporter.  I object on relevancy grounds.

         8     Now you can proceed.

         9               MR. KLAYMAN:  I'm sorry.  I didn't

        10     interrupt your relevancy grounds.

        11               MS. SHAPIRO:  You talked over it.

        12     We need to make a record.

        13               MR. KLAYMAN:  All right.  Good.

        14               BY MR. KLAYMAN:

        15          Q    Are you stating unequivocally that

        16     Hillary Clinton did not instigate the firing

        17     of the Travel Office staff.

        18          A    I have read a lot of public reports

        19     since this that suggest that.  I had no

        20     knowledge of it at the time.

        21          Q    Are you aware that in the course of

        22     the Travel Office controversy the file of









                                                             392
         1     Billy Dale, the FBI file, was pulled by the

         2     White House?

         3          A    No.

         4          Q    Have you ever heard that before?

         5          A    I don't think so.

         6          Q    Are you aware that in the course of

         7     the Travel Office controversy that the White

         8     House went directly to the FBI and asked the

         9     FBI to do an investigation of Billy Dale and

        10     other members of the White House Travel

        11     Office?

        12          A    No.

        13          Q    You never heard that mention?

        14          A    No, I certainly didn't do it.

        15          Q    Do you know of anyone who is

        16     involved?

        17          A    I already answered that question.

        18          Q    Are you aware of a complaint by

        19     Janet Reno about bypassing her office to

        20     request an investigation by the FBI into

        21     Billy Dale and the Travel Office staff?

        22          A    I didn't know about the









                                                             393
         1     investigation.  I couldn't know about the

         2     objection.  No, I did not.

         3          Q    Have you ever discussed the Travel

         4     Office firings with Attorney General Janet

         5     Reno?

         6          A    No.

         7          Q    Have you ever meet with Janet Reno?

         8          A    I have been in meetings with Janet

         9     Reno.

        10          Q    Have you been in meetings that

        11     concern Filegate?

        12          A    No.

        13          Q    Have you been in meetings that

        14     concern Travelgate?

        15          A    No.

        16          Q    Did you participate in meetings

        17     dealing with her re-appointment as Attorney

        18     General in 1996?

        19          A    No.

        20          Q    What was the nature of the meetings

        21     that you were in with her?

        22          A    Meetings on the crime bill,









                                                             394
         1     meetings on the Oklahoma City bombing,

         2     various cabinet meetings.

         3          Q    Did you ever discuss the Travel

         4     Office firings with John Collingswood of the

         5     FBI?

         6          A    Might have discussed the statement

         7     that he put out, yeah.

         8          Q    What statement did he put out?

         9          A    It was a statement about what

        10     nature of the investigation -- what was the

        11     nature of the investigation and you know very

        12     well because this is all in the public

        13     record.

        14               And I can't believe we're wasting

        15     more time, it's nearly 6:00, eight hours into

        16     this deposition about something that happened

        17     in 1993, when the FBI files were taken

        18     in 1996.

        19          Q    Who was John Collingswood?

        20          A    I'm assuming he's the direct -- I

        21     don't know his exact title.  He was director

        22     of public information for the FBI.









                                                             395
         1          Q    What statement did he put out to

         2     the best of your knowledge?

         3          A    It was about whether the Travel

         4     Office was being investigated.

         5          Q    Did you put out a statement with

         6     that regard?

         7          A    I had to give a briefing on it,

         8     sure.

         9               MR. KLAYMAN:  I will show you what

        10     I will ask the court reporter to mark as

        11     Exhibit 17.

        12                    (Stephanopoulos Deposition

        13                    Exhibit No. 17 was marked for

        14                    identification.)

        15               BY MR. KLAYMAN:

        16          Q    Have you seen Exhibit 17 before?

        17     This is, "White House Press Release,

        18     Statement of White House Travel Office" dated

        19     May 21st, 1993?

        20          A    Yes.

        21          Q    Did you prepare that?

        22          A    In part, sure.  I reviewed it.  I









                                                             396
         1     approved it, I probably read it.

         2          Q    Did you write it?

         3          A    I'm sure I wrote -- I wrote pieces

         4     of it and edited it.  I'm sure I didn't do

         5     the first draft.

         6          Q    Who did the first draft?

         7          A    I don't know.

         8          Q    Was it done by the White House

         9     Counsel's Office?

        10          A    Probably was reviewed by them.  I

        11     don't know who actually did the drafting.

        12          Q    Was it your responsibility to send

        13     out press releases at this time?

        14          A    They went out over my name, yes.

        15          Q    That was part of your duties and

        16     responsibilities?

        17          A    Yes.

        18          Q    In this press release did you state

        19     that Mr. Billy Dale was under criminal

        20     investigation by the FBI?

        21          A    I don't think the word "Billy Dale"

        22     appears here.









                                                             397
         1          Q    That the White House Travel Office

         2     employees were under criminal investigation?

         3          A    No, that's different.  Where --

         4     there is a sentence that says, "The FBI has

         5     determined from the information it's already

         6     obtained that additional criminal

         7     investigation is warranted."  That's what it

         8     says.

         9          Q    Where did you get that information?

        10          A    From the FBI.

        11          Q    Who gave it to you at the FBI?

        12          A    I assume it was John Collingswood.

        13          Q    You had that information before you

        14     wrote this press release?

        15          A    Certainly before I read it.

        16          Q    Did you ask who was under criminal

        17     investigation by the FBI?

        18          A    I wanted to make sure that what we

        19     were saying was right and it was what the FBI

        20     was saying.

        21          Q    Now, this statement was made with

        22     regard to the White House Travel Office,









                                                             398
         1     correct?

         2          A    Sure.

         3          Q    Therefore, anybody that worked in

         4     the White House Travel Office, one could

         5     infer from this statement, would be under

         6     criminal investigation, correct?  That's what

         7     you meant?

         8          A    No.  I meant exactly what I said

         9     and it's a very carefully written statement.

        10     "The White House has received a final report

        11     by the accounting firm of Peat Marwick

        12     regarding its study of the White House Travel

        13     Office.  We are making the report available

        14     to the FBI and the public this afternoon.

        15               "The FBI has determined from the

        16     information that's already obtained that

        17     additional criminal investigation is

        18     warranted."

        19               The date is May 21st, 1993, a full

        20     three years before any story on the White

        21     House files -- FBI files in the White House

        22     broke.









                                                             399
         1          Q    Did you have any information in

         2     writing at the time from the FBI that they

         3     had embarked upon a criminal investigation at

         4     the time you made this press release on May

         5     21st, 1993?

         6          A    I wouldn't have said this if I

         7     didn't believe it were true.

         8          Q    Did you have any hard evidence that

         9     it was true?

        10          A    They told me that.

        11          Q    Collingswood?

        12          A    I assume so, yes.

        13          Q    Did it come from any other source?

        14          A    No.

        15          Q    At the time that you made this

        16     statement did you double check whether it was

        17     true with someone other than Collingswood?

        18          A    No, I didn't feel that was

        19     appropriate or necessary.

        20          Q    That's a pretty serious statement,

        21     is it not?

        22          A    Sure.  That's why I wanted to make









                                                             400
         1     sure it was not contradicted by the FBI.

         2     That's why I asked the FBI representative

         3     whether it was true.

         4          Q    Are you aware that at the time

         5     Former Associate Attorney General Web Hubbell

         6     blamed you for a mistake in issuing this

         7     press release to any of the White House

         8     Travel Office Director Billy Dale was under

         9     criminal investigation by the FBI?

        10          A    Again, that's not what the

        11     statement said.  It was -- I actually think

        12     it was a mistake as well in retrospect simply

        13     because it was -- because it created a

        14     controversy.

        15               I think I did everything right to

        16     the best of my ability.  There were members

        17     of the White House Counsel's Office in my

        18     office when this statement was prepared.  I

        19     believed I was acting in accordance with the

        20     rules.  If I wasn't or if there were an

        21     appearance that I wasn't, that is something I

        22     have acknowledged and still acknowledge.  It

 

 

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