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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of this deposition