401 1 was a mistake. I wish I hadn't done it. 2 Q Did it concern you at the time that 3 you were using the FBI for a political 4 purpose? 5 A That's not what I thought I was 6 doing. I thought I was trying to be accurate 7 and that's exactly what I thought I did. 8 Q Now, there was a discussion at the 9 White House at the time that issuing a 10 statement that the FBI was investigating this 11 criminally would take some of the pressure 12 off of the White House for firing the White 13 House Travel Office? 14 A No. Actually my only concern was 15 that I didn't want to put out a statement 16 that would be contradicted by the FBI. I 17 wanted to make sure that whatever I said was 18 accurate and true, which is why I asked the 19 FBI, you know. 20 In the -- in the atmosphere we live 21 in today that turns out to be suspect and 22 that's why I wish I hadn't done it. But I 402 1 was doing it in an attempt to make sure 2 everything I said was right. 3 Q During the time that this press 4 release was being prepared and the statement 5 was issued did anyone inside the White House 6 caution you or anyone else about using the 7 FBI's name in the context of the Travel 8 Office? 9 A Had -- had the White House 10 Counsel's Office cautioned me on it I would 11 haven't done it. In fact, I believe -- 12 MS. SHAPIRO: Nor would he testify 13 to it. 14 MR. KLAYMAN: I don't find that 15 humorous to interrupt his testimony, 16 Ms. Shapiro. 17 MS. SHAPIRO: Well, I need to 18 caution the witness not to disclose any 19 privileged information -- 20 MR. KLAYMAN: I don't think you 21 need to do anything. 22 MS. SHAPIRO: -- and you're talking 403 1 over me again. 2 MR. KLAYMAN: I'm afraid you talked 3 over his testimony and that's inappropriate. 4 MR. BRAND: He was about to utter a 5 privileged statement she thought. 6 MR. GAFFNEY: I'd ask the counsel 7 for the plaintiff to show a little more 8 respect to counsel around the table. 9 MR. KLAYMAN: I think the record 10 will speak for itself in terms of respect, 11 Mr. Gaffney. You're not the -- with respect 12 to counselor here, we do have a videotaped 13 deposition. I think it will show the 14 demeanor adequately. 15 THE WITNESS: Too bad we don't have 16 two cameras. 17 MR. KLAYMAN: Certify it. You want 18 to take a break and move the cars? Off the 19 record. 20 VIDEOGRAPHER: This is the video 21 operator. We're going off the record. The 22 time now is approximately 5:57 p.m. 404 1 (Discussion off the record) 2 VIDEOGRAPHER: This is the video 3 operator. This is tape two of the George 4 Stephanopoulos deposition. The time now is 5 approximately 6:15 p.m. Mr. Klayman? 6 BY MR. KLAYMAN: 7 Q Have you ever discussed the FBI 8 files matter with Dick Morris? 9 A No. 10 Q Are you aware that Mr. Morris' 11 girlfriend, Sherry Rowlands, kept a diary 12 whereby she's reported to have stated that 13 based upon conversations with Dick Morris, 14 that Hillary Clinton is the mastermind of 15 Filegate? 16 A I don't know what she wrote. I 17 know there may have been reports of what she 18 may have written at the time, but I don't 19 know what it was. 20 Q At the time of the Dick Morris 21 incident, were you still working at the White 22 House? 405 1 A Uh-huh. 2 Q It was in and around that time 3 period that the reports of Hillary Clinton's 4 alleged involvement in Filegate surfaced? 5 A I don't know that. I just answered 6 that question. 7 Q But you did read about the Rowlands 8 diary, at that time? 9 A Sure. I don't remember what it 10 said. 11 Q Have you ever read the Rowlands 12 diary? 13 A No. I think the report is in the 14 Starr tabloid. 15 Q Was there any discussion at the 16 White House about that statement, as reported 17 by Star Magazine, at the time? 18 A No. 19 Q None that you know of? 20 A Not that specific statement. I 21 mean speaking only for myself, I was just 22 happy that he was gone. 406 1 Q He's not one of your favorites? 2 A No. 3 Q Would if be fair to say that 4 there's a hate relationship between the two 5 of you? 6 A No, it's more complicated than 7 that. 8 Q How so? 9 A Just is. It has nothing to do with 10 the FBI files. I never talked to him about 11 the FBI files. 12 Q You dislike Mr. Morris? 13 A Right now I don't think about him 14 too much. 15 Q Well, when you thought about him, 16 you disliked him strongly? 17 A Yeah, that's fair. 18 Q What's the basis of your dislike 19 with him? 20 A It's an aesthetic thing. 21 Q Do you think he's ugly? 22 A I didn't say that. 407 1 Q Then what do you mean by it's an 2 aesthetic thing? 3 A Just a sensibility, a feeling, not 4 my kind of guy. 5 Q Why is that? 6 A It's hard to -- you know, facts 7 aren't feelings. Feelings aren't facts. 8 It's just a feeling I have. 9 Q Did he ever do anything to you that 10 you disagreed with? 11 A Nothing that has anything to do 12 with the FBI files. 13 Q But anything with you generally? 14 I'm going to ask you some questions about 15 him. 16 A Great. 17 Q I want to know what your opinion of 18 him is. 19 A I told you my opinion of him. 20 Q What is it based on? 21 A Working with him. 22 Q Do you consider him to be a 408 1 dishonest person? 2 A You know, depends on the day. 3 Q You have considered him to be a 4 dishonest person? 5 A I have no idea how this can 6 possibly be relevant to -- to the FBI files. 7 Q His reputation with you is one of 8 dishonesty? 9 A Sometimes yes, sometimes no. 10 Q Do you have any opinion of him 11 based upon his reported sexual activities, 12 that's the reason you don't like him? 13 A No, but it's -- I think it was an 14 incredibly stupid thing to do. 15 Q What? Have an affair with Sherry 16 Rowlands? 17 A While he was in the employ of the 18 President when it could be used against him 19 and it could threaten the campaign, yes. 20 Q It's stupid to do it or stupid to 21 get caught? 22 A I already answered that question. 409 1 I said it was a stupid thing to do. 2 Q Is it also stupid to get caught in 3 your opinion? 4 A I said it was stupid to do. I 5 think it is stupid to do. 6 Q During the period that Dick 7 Morris was a consultant for President 8 Clinton? 9 A For the Clinton for President 10 campaign, yes. 11 Q For 1996. 12 A DNC. I don't really know how he 13 was paid. 14 Q Did he ever you who he was employed 15 by? 16 A It's not the kind of thing he would 17 sit down and talk about. He worked -- he 18 worked, generally, on the campaign. I don't 19 know who paid him. 20 Q I take it you've had discussions 21 with him during the course of his employment 22 on behalf of the President's campaign? 410 1 A Never about the FBI files. 2 Q Have you heard of discussions just 3 generally? 4 A Sure. 5 Q About campaign strategy? 6 A Absolutely. 7 Q You meet with him on a frequent 8 basis leading up to the 1996 elections? 9 A Depending on the day. 10 Q During the time that you met with 11 him did he ever tell you that he had had 12 conversations with Hillary Rodham Clinton? 13 A May have, sure. Never about the 14 FBI files. 15 Q Well, what conversations did he 16 tell that he had? 17 A I don't remember. We talked a lot. 18 Q He was in constant contact with 19 Mrs. Clinton, was he not, leading up to 20 the 1996 campaign? 21 A I don't know that. He may. I'm 22 sure he talked to her occasionally. I don't 411 1 know what constant contact means. I don't 2 know how much contact he had. 3 Q Do you know what kind of access he 4 had to Mrs. Clinton? 5 A I just answered that. Contact and 6 access aren't that different a thing. 7 MR. KLAYMAN: I'll show you what 8 will I ask the court reporter to mark as 9 Exhibit 18. 10 (Stephanopoulos Deposition 11 Exhibit No. 18 was marked for 12 identification.) 13 BY MR. KLAYMAN: 14 Q Exhibit 18 consists of a cover 15 letter from Jerry McDewitt, of Kirkpatrick & 16 Lockhart, LLP, to Ms. Barbara Olson, Chief 17 Investigate Counsel, Committee on Government 18 Reform and Oversight, and attached to it is a 19 two-page affidavit of Dick Morris. 20 It states at the top of page one of 21 that affidavit, "Statement to Government 22 Oversight Committee by Dick Morris." You can 412 1 have an opportunity and review that 2 affidavit. 3 A I did. 4 Q Have you ever seen it before? 5 A I don't think so. 6 Q Excuse me? 7 A I don't think so. 8 Q Were you aware that Mr. Morris had 9 prepared and submitted an affidavit to the 10 Government Reform and Oversight Committee? 11 A I may have been. I'm not surprised 12 by it. I don't know if I had contemporaneous 13 knowledge. 14 Q Where did you get any knowledge at 15 all? 16 A I probably saw a press report that 17 he had been called there, but I couldn't 18 swear to it. 19 Q Did you discuss his affidavit with 20 him? 21 A If I never discussed FBI files with 22 him, then I didn't discuss this with him. 413 1 Otherwise I would have answered that. 2 Q Did you ever discuss Mr. Morris' 3 affidavit with anyone at Kirkpatrick & 4 Lockhart? 5 A No. 6 Q It states, paragraph one, "The 7 account printed in the Star of my 8 conversation with Ms. Rowlands on June 24th, 9 1996, is, to the best of my knowledge, 10 inaccurate." 11 Paragraph two, "It's my 12 recollection that I had a conversation with 13 her on or about June 24th in which we 14 discussed who the public believed was 15 responsible for the search of FBI files by 16 the White House." 17 Do you have any knowledge of the 18 conversation Mr. Morris had with Mrs. Clinton 19 on or about June 24th? 20 A No. 21 Q "My recollection is that I said in 22 words or substance, everyone thinks it's 414 1 Hillary who is responsible. I base that 2 comment on polling data I had recently 3 analyzed. The poll was conducted on 4 June 18th and 19th. 5 In that polling respondents were 6 first asked if they believed the 7 investigation showed the Clintons are 8 responsible for a lot of wrongdoing. 9 39 percent said that they felt the 10 Clintons were responsible and 35 percent said 11 they were not. In the survey those 12 respondents who said the Clintons were 13 responsible were then asked if they believed 14 that the President or the First Lady were 15 responsible for the examination of FBI files 16 by the White House. 17 This question was answered with 18 74 percent saying the First Lady was 19 responsible and 6 percent saying the 20 President was responsible. 21 "This poll data was the basis of 22 any such remarks by me. I do not recall 415 1 sharing the actual poll data with Rowlands." 2 Are you aware of any such polling 3 that occurred in and around this time period? 4 A It's possible. I don't remember it 5 specifically. 6 Q Do you remember anything about it? 7 A Not really. I mean this is just a 8 perfect example of what Dick would do. I 9 mean he would poll on a question that was, 10 basically, a factual matter. 11 To me what was important was 12 whether it happened. Based on my testimony 13 to date I didn't know anything about what 14 happened. The polling was irrelevant. 15 Q But you don't know specifically of 16 any actual poll that he took on these 17 matters? 18 A I don't remember it, no. 19 Q Paragraph three, "I have no 20 personal knowledge or information from any 21 source whatsoever as to who was responsible 22 for ordering the FBI files or the use to 416 1 which such files were put on receipt by White 2 House personnel." 3 Did Dick ever discuss that with 4 you? 5 A I already answered that question. 6 Q Now, during the course of your 7 dealings with Dick Morris did he ever tell 8 anyone anything that was untrue about George 9 Stephanopoulos? 10 A Sure. 11 Q What did he tell others that were 12 untrue about you? 13 A Again, I don't know what relevance 14 it has, but he once told the President that I 15 leaked polling information to the Bob Dole 16 Presidential Campaign, which Dick Morris had, 17 in fact, leaked to the Bob Dole Presidential 18 Campaign. 19 Q Anything else? 20 A That's the one that sticks out in 21 my mind. 22 Q But that's an example of how 417 1 Mr. Morris would sometimes fabricate facts? 2 A Your conclusion. It just wasn't 3 true. 4 Q Based on your experience? 5 A Wasn't true. 6 Q That wasn't the only time that 7 you've ever known Dick Morris not to tell the 8 truth, was it? 9 A That's the one that sticks out in 10 my mind. 11 Q But there were other occasions, 12 correct? 13 A Probably, but I couldn't swear to 14 it now. 15 Q You have a very low regard for 16 Mr. Morris' honesty, don't you? 17 A I already answer had question. 18 Q What is the reputation of Dick 19 Morris around the White House for honesty? 20 Bad? 21 A Depended on who you asked. 22 Q What was the general reputation 418 1 when you were there? 2 A I don't know if there was a general 3 reputation. It depended on who you asked. 4 Q Did the President have any opinion 5 that he ever expressed to you about Dick 6 Morris' honesty and veracity? 7 MS. SHAPIRO: Objection. He's not 8 going to testify about any conversations he 9 had with the President. 10 MR. KLAYMAN: Certify it. 11 BY MR. KLAYMAN: 12 Q Did anyone else ever express to you 13 their views that Dick Morris was not an 14 honest person during the time you were at the 15 White House? 16 A Probably. I don't have any 17 specific conversation. 18 Q Do you remember names of persons 19 who hold that belief? 20 A Could have been anybody. 21 Q Has Mr. Paul Begala ever expressed 22 to you what his opinion is of Dick Morris' 419 1 honesty? 2 A I don't know about his honesty. I 3 don't think Paul likes Dick Morris very much, 4 but I don't know. 5 Q Did Mr. Blumenthal ever tell you 6 what his opinion is of Dick Morris' honesty? 7 A No. 8 Q Mr. Emanuel? 9 A Again, I don't know about honesty. 10 I'm sure we talked about Dick at times. 11 Q Did he ever express to you his view 12 that Dick wasn't an honest person? 13 A Couldn't swear to that. I don't 14 think he likes Dick that much, but you'd have 15 to ask him. 16 Q Did Mr. Panetta ever express his 17 views on whether Mr. Morris was honest? 18 A Again, I don't remember honest 19 particularly. I don't know what exactly he 20 thought about Dick. I don't think he had a 21 very high regard for him. 22 Q Discussions of honesty really don't 420 1 occur much at the White House, do they? 2 A That's actually not true at all. 3 Q Whether somebody is honest? 4 A In fact, about 20 minutes ago we 5 spent a lot of time explaining about one of 6 the reasons I -- in the statement I put out 7 about the Travel Office, I was trying to make 8 sure it was honest. That was my job. 9 Q Do you know a Gary Aldrich? 10 A No. I know of him. 11 Q You never met him? 12 A Oh, I met him. 13 Q When did you first meet him? 14 A I guess he interviewed me during 15 the FBI background checks early in '93. 16 Q What was his job title at the time? 17 A Got me. 18 Q Were you aware that he was an FBI 19 agent at the time? 20 A To the extent that I thought about 21 him, sure. 22 Q He was in charge of doing 421 1 background checks? 2 A I assume that's the first time I 3 met him. 4 Q Did you ever have an opportunity to 5 review a manuscript or a published version of 6 his book "Unlimited Access"? 7 A Those are two very different 8 things. When I heard about it, I asked my 9 assistant to go to Crown Books and buy it, 10 which she did, and brought it back for me and 11 then I read it. 12 Q Who was your assistant at the time? 13 A Laura Capps. 14 MR. KLAYMAN: I will show you what 15 I will ask the court reporter to mark as 16 Exhibit 19. 17 (Stephanopoulos Deposition 18 Exhibit No. 19 was marked for 19 identification.) 20 MR. BRAND: The xerox company loves 21 you, Larry. 22 MR. KLAYMAN: Excuse me? 422 1 MR. BRAND: The Xerox company loves 2 you. 3 MR. KLAYMAN: I think they do. 4 THE WITNESS: Good old days. 5 BY MR. KLAYMAN: 6 Q Could you take an opportunity and 7 take a look at Exhibit 19? Is this a copy of 8 the book Unlimited Access which you asked 9 Ms. Capps to buy for you? 10 A It looks like -- well, it looks 11 like a photocopy of it, yes. 12 Q Did you provide this to the 13 Government Reform and Oversight Committee? 14 A I don't know. 15 MR. BRAND: Maybe the White House 16 did. We did. 17 THE WITNESS: Yeah, I don't 18 remember. 19 BY MR. KLAYMAN: 20 Q Let's turn to Bates number 056345. 21 A One of my favorite pages. 22 Q Is that your handwriting next to 423 1 the underlined portions? 2 A Sure. 3 Q You wrote "lie"? 4 A Yes, because it is. 5 Q How did you determine that the 6 markings here off these paragraphs 7 constituted lies? 8 A I was there at the time. 9 Q Why did you annotate this copy of 10 the book? Why did you take the time to do 11 it? 12 A Because Mr. Aldrich was getting a 13 lot of publicity to what I believe was a 14 total fabrication, which has later been borne 15 out by subsequent events. 16 MR. BRAND: Does this have 17 something to do with the files? 18 MR. KLAYMAN: Well, I'm going to 19 get to that. I'm just trying to identify his 20 handwriting right now. 21 THE WITNESS: I already answered 22 that. 424 1 BY MR. KLAYMAN: 2 Q Turn to page 056347. 3 A Well, it's -- but I mean since you 4 asked me, I'm going to explain why I thought 5 these were lies. 6 "One of the reasons the Clintons 7 were late was because Vice President Gore had 8 just found out that the West Wing office 9 usually reserved for the vice-president was 10 instead going to be occupied by the First 11 Lady." 12 That, in fact, is not true. The 13 one underlying contention that -- that she 14 was going to get his office wasn't true; and, 15 two, the reason they were late was -- because 16 they were late at the White House was that 17 with President and Mrs. Bush. 18 Number two, second, it said that, 19 "Network news cameras, trained on Blair 20 House, the morning of the inauguration, 21 recorded a glimpse of the President and First 22 Lady screaming at each other. Hillary 425 1 shouted at him that as far as she was 2 concerned they had a deal, a deal that dated 3 back to the campaign when Lloyd Cutler had 4 convinced her to stand by Clinton despite the 5 allegations that he'd had an affair with 6 Gennifer Flowers." 7 Number one, there's no way that 8 that network news cameras could pick up the 9 sound and. 10 Number two, I was with them for all 11 of that morning except for the time they were 12 at the White House when I went to the 13 Capitol. I never observed it. 14 Number three, Lloyd Cutler -- I was 15 with them when the Gennifer Flowers story 16 broke in the campaign and Lloyd Cutler was 17 nowhere to be seen. That's not true. 18 Q Are you saying that you never saw 19 the President and Mrs. Clinton screaming, 20 either one or the other? 21 A At this time -- 22 Q Have you ever seen either of them 426 1 scream at each other? 2 A I'm not going to answer that 3 question. 4 Q You have to answer that question. 5 You just offered testimony. Have you ever 6 seen them scream at each other? 7 A I have never saw them scream at 8 each other about the FBI files. 9 Q You saw them scream at each other 10 about other things, correct? 11 A I never saw them scream at each 12 other about this. 13 Q But you did see them scream at each 14 other, correct? 15 A I -- I have seen a lot of things in 16 my time. That is no relevance to the FBI 17 files and, finally, at the bottom of the 18 page -- 19 Q Is the answer no? Is the answer 20 no, that you never saw them scream at each 21 other? 22 A I didn't say that. I would finally 427 1 say -- 2 Q Did the President ever -- 3 A Wait. Let me finish. 4 Q During the time that you worked 5 there. I'm entitled to ask questions. You 6 can go on. 7 MS. SHAPIRO: He's entitled to 8 finish his answer. 9 THE WITNESS: I'm entitled to 10 finish my answer -- 11 MR. KLAYMAN: Well, finish your 12 answer. 13 THE WITNESS: -- which is the last 14 lie which I documented on this page was that 15 in the holding room Hillary was screaming at 16 her because -- and that's why he was late to 17 go out and give his speech. 18 The reason he was late to go out 19 and give his speech is because I was up in 20 the speakers office with a draft of the 21 speech and I was late getting there. They 22 were -- when he got there, he was fine. 428 1 There was no screaming. 2 BY MR. KLAYMAN: 3 Q Did the President during the time 4 that you worked at the White House ever 5 scream at you? 6 MR. GAFFNEY: I'm going to object, 7 Mr. Klayman, to this question. It has 8 utterly no relevance whatsoever in any claim 9 asserted in either complaint in these 10 consolidated or nor is it conceivably related 11 to this. 12 I consider this an abuse of the 13 subpoena process and unless you withdrew the 14 question, I'm putting you on notice that we 15 may seek sanctions in the discovery code 16 under the court's inherent authority to this 17 line of questioning. 18 MR. KLAYMAN: Thank you, 19 Mr. Gaffney. Want to say anything else? 20 MR. GAFFNEY: I believe the record 21 is clear on my views. 22 MR. KLAYMAN: The witness raised 429 1 these issues. He wanted to explain, so I'm 2 entitled to ask. 3 MR. BRAND: The witness did not 4 raise these issues and if you think that the 5 subpoena power that counsel gets pursuant to 6 a civil case entitles you to conduct a broad 7 fishing expedition into any issue that -- to 8 pose any question you feel like posing, that 9 is a position that is untenable in the law 10 and if you want to proceed on that, you do so 11 at your own peril. 12 MR. KLAYMAN: Let me lay a 13 foundation so you can, then, make your speech 14 again. 15 BY MR. KLAYMAN: 16 Q During the time you were at the 17 White House, did the President ever criticize 18 you on anything? 19 A I'm not going to answer that. 20 MR. KLAYMAN: Certify it. 21 BY MR. KLAYMAN: 22 Q Did he ever yell at you about 430 1 anything that you did? 2 A I'm not going to answer that. 3 Q Were you yelled at with regard to 4 the Travel Office and the press release 5 identified earlier by anyone at the White 6 House? 7 A No. 8 Q Yelled at by the President? 9 A I'm not going to answer it. 10 MR. KLAYMAN: Certify it. 11 BY MR. KLAYMAN: 12 Q That's Exhibit 17 I'm referring to. 13 To the best of your knowledge, did 14 the President ever scream at anyone 15 concerning the FBI file matter? 16 MR. BRAND: Larry, the clock on the 17 wall now says 6:30. We've been at this since 18 roughly 10 after 10:00 with the lunch break. 19 I don't want to go beyond the six hours 20 allotted at this point. 21 MR. KLAYMAN: Well, I've been 22 keeping track of the time and if you deduct 431 1 out lunch and the break, the six hours will 2 come to a close around 7:30. 3 THE WITNESS: No way. 4 MR. KLAYMAN: Yes. 5 THE WITNESS: No way. 6 MR. KLAYMAN: Yes. 7 THE WITNESS: I was here at 10:10. 8 MR. BRAND: That can't be right. 9 MR. KLAYMAN: Are you setting the 10 ground rules, Mr. Stephanopoulos? 11 MR. BRAND: No, what I'm saying -- 12 MS. SHAPIRO: The court has set the 13 ground rules, I'm afraid. 14 MR. KLAYMAN: That's correct. 15 MR. BRAND: What I'm saying is, 16 Larry, is at six hours after being here we're 17 going to end for today. That's all we're 18 saying, which is my understanding of what the 19 order of the court has provided. 20 MR. KLAYMAN: When does that six 21 hours conclude in your opinion, Mr. Brand? 22 MR. BRAND: I think we're there 432 1 already. I've actually let it slide as an 2 act of grace to let you finish up what you 3 need to finish up on this issue, not all of 4 these other irrelevant matters. 5 MR. KLAYMAN: Should I be calling 6 you Willie Maze in the future? What do you 7 mean by letting it slide? 8 MR. BRAND: By my calculation we're 9 past the six hours. 10 MR. KLAYMAN: We're not past it and 11 if you deduct all the time that was taken for 12 breaks and lunch, a very long lunch break, I 13 might add, by Mr. Stephanopoulos, the six 14 hours will not be concluded until 15 aren't 7:30. 16 MR. BRAND: We're not staying 17 until 7:30. 18 MR. KLAYMAN: Well, when are you 19 going to take it upon yourself to leave, 20 Mr. Brand? 21 MR. BRAND: I think we were done 22 at 6:30. I think that was the six hours by 433 1 the calculation I've kept in my notes. 2 MR. KLAYMAN: Well, notwithstanding 3 the calculations which are on the record, can 4 I ask questions up to 7:00 as of tonight? 5 THE WITNESS: How about a quarter 6 of? 7 MR. KLAYMAN: You're setting the 8 ground rules, Mr. Stephanopoulos? 9 MR. BRAND: No, we're saying when 10 we think we -- I'm telling you when we think 11 it's over. 12 MR. KLAYMAN: I'm telling you it 13 will not come to a close as of 7:30. I will 14 submit to the court for the record how long 15 the testimony was and, in fact, because we 16 didn't get responses to a lot of things, we 17 will be moving to bring Mr. Stephanopoulos 18 back. But right now I want to complete the 19 six hours that I have. 20 MR. BRAND: We'll go to a quarter 21 of 7:00 and then we're leaving. 22 MR. KLAYMAN: Okay. Well, you do 434 1 so at your own risk. There have been other 2 instances in other cases involving this court 3 where people have gotten up and left and we 4 will be moving for appropriate remedies if 5 you get up and leave at your own volition. 6 BY MR. KLAYMAN: 7 Q Turn to page 056360. 8 A 360. 9 Q Is that your handwriting on that 10 page? 11 A Yeah. 12 Q What does it say at the top? 13 A Innuendo. 14 Q Innuendo. When you put questions 15 marks as opposed to stars, is there any 16 reason for that? 17 A I don't know exactly. Let me read 18 it. 19 Q If you have question marks, does 20 that mean you have questions about it? It 21 might be right, but you have questions? 22 A No. What it meant was that I 435 1 thought it was too ludicrous even to check, 2 but that it would be one of the easier things 3 to disprove. 4 Q Stars, what do stars mean? It 5 means it's right, correct, important point? 6 A No, it means that it was even a 7 better example of how he was fabricating 8 things. 9 Q But you didn't write fabricated, 10 did you? 11 A I know my own code. I know my own 12 handwriting. I know when I wrote three stars 13 and two parallel lines that meant that I was 14 going to come back to that as an example of 15 how Gary Aldrich was making stuff up in his 16 book. That's when I meant. 17 Q In fact, you've referred to Gary 18 Aldrich before as a pathological liar, have 19 you not? 20 A Oh, and I'll take this opportunity 21 to do so again for pay. 22 Q What was your code for question 436 1 marks? 2 A Too silly to check -- well, I 3 already answered that. 4 Q To silly to check is question 5 marks? 6 A But easy to disprove. 7 Q But easy to disprove. Page 056397. 8 Is that your handwriting there? 9 A Yeah. 10 Q What did your code mean when you 11 had three questions marks and the word 12 "ridiculous" and a line? 13 A It meant it was ridiculous. 14 MR. BRAND: It would be easy to 15 disprove. 16 THE WITNESS: It would be easy to 17 disprove, right. 18 BY MR. KLAYMAN: 19 Q Turning to the next page. 20 A Lots of stars. 21 Q Well, let's go back to 056397. 22 What information did you have with regard to 437 1 this incident with Vince Foster that could 2 lead you to believe that it was ridiculous 3 what Mr. Aldrich had written? 4 A What is he talking to here? Let me 5 see. It's hard to follow. He's not a 6 greater writer either. 7 Well, basically you're 79 pages in 8 and I think he had already demonstrated I 9 didn't believe much of anything, but this was 10 a specific claim which I thought sounded 11 ridiculous. 12 Again the question marks did mean 13 it was something that we could check pretty 14 easily. The rest speaks for itself. 15 Q But, in fact, you didn't have any 16 information yourself to prove it was 17 ridiculous? 18 A Well, I had -- certainly had enough 19 information to write in my own copy of my own 20 book that it was ridiculous. 21 Q But you didn't have any information 22 yourself to prove it was ridiculous? 438 1 A I was reading the book at home. I 2 came upon page 79 -- 3 Q Well, the bottom line is you 4 actually did know whether this was true or 5 false because, in fact, you had talked to 6 Foster about these matters, hadn't you, 7 security clearances? 8 A Absolutely not. 9 Q Let's turn to the next 10 page, 056938. Look down in the middle of the 11 page where it says, "Craig didn't answer. He 12 just stared straight ahead and in his 13 nonanswer I believe he was telling me that he 14 knew that the rumors were true. We sat there 15 in silence while I thought of what to say 16 next. I was very uncomfortable. I tried to 17 change the subject." 18 Now, according to your previous 19 coding system, if you put a line and three 20 stars, that means it's untrue, correct? 21 A I think it means it's something 22 that I could use to call everything else he 439 1 was saying into question. I think that this 2 is pretty clearly a fabricated conversation 3 based on what he believed, suppositions he 4 believed about the members, it was a leap -- 5 leap into the unknown by Mr. Aldrich trying 6 to get things into the record that otherwise 7 couldn't be gotten into the record. 8 I thought if a reasonable 9 journalist read this, they would agree with 10 my judgment that this was a fabrication. 11 Q But, in fact, you didn't have any 12 information as to the conversation between 13 Mr. Aldrich and Mr. Livingstone, did you? 14 A Mr. Aldrich might not have had it 15 either. He might have just written it. 16 Q But you didn't have any information 17 to disprove what he said was true, did you? 18 A I certainly had enough that I 19 believe if I could show it to reporters, they 20 would be able to back me up on it. 21 Q Were you familiar with the 22 conversations that Mr. Aldrich had with 440 1 Mr. Livingstone? 2 A No, but I don't think -- and I 3 don't know that he even had one. 4 Q Turn to the next page. 5 A I notice that there's no 6 documentation by him here. I notice he's put 7 things in quotes without footnotes, not 8 standard historical practice. 9 Q Next page, 056399. You have false 10 written next to several entries, correct? 11 Let's look at the bottom entry on that page 12 where it says, "Look, Gary, I'm the security 13 guy around here. Whatever happens recording 14 security I'm in it even if I don't decide, 15 even if I'm just told what to do. I'm still 16 in the meetings. 17 They know that I deal with the FBI 18 all the time, so they would naturally want me 19 to know what is going on. I've been in most 20 of the meetings about security and the FBI. 21 Your director calls me all the time. He 22 knows me by my first name." 441 1 In fact, you do have knowledge that 2 FBI Director Lewis Freeh had called Craig 3 Livingstone, correct? 4 A I didn't have that, no, otherwise I 5 wouldn't have written false. 6 Q Did you have any knowledge as to 7 whether Williams Sessions had called Craig 8 Livingstone? 9 A I didn't believe he had. I didn't 10 know. 11 Q But you didn't have enough 12 information yourself? 13 A I had enough information and enough 14 judgment to believe in my personal copy of my 15 own -- of my own book that I could write 16 false there. 17 Q But you didn't have any information 18 to disprove what Mr. Aldrich had written, did 19 you, firsthand information? 20 A It just didn't sound right to me. 21 Q If it doesn't sound right, it's all 22 of a sudden false and Gary Aldrich is a 442 1 pathological liar; is that it? 2 A No, there's a million things in 3 here that are wrong. Again, I've expressed 4 to you this is my personal copy of the book. 5 I can write whatever I want in my 6 personal copy of the book and it's my 7 judgment that Mr. Aldrich is a pathological 8 liar, which I think is borne out by the 9 amount of untruths and falsehoods in this 10 book. 11 But, you know, I don't see how -- 12 what I wrote in my -- in my copy of Gary 13 Aldrich's book is relevant to that at all. 14 Q In fact, you did have information 15 about what Mr. Aldrich wrote about in the 16 last paragraph on page 056399, didn't you? 17 A I already answered that question. 18 Q No? 19 A No. 20 Q Page 056400, last paragraph, you 21 just have a line. "Craig looked at me like I 22 didn't have a brain. Nussbaum? It's not 443 1 Nussbaum we've got to talk to. We'll be 2 talking to Hillary. What? You're kidding? 3 No? Look, Craig. I said I'd help you, but 4 an FBI agent meeting was with the First 5 Lady." Did you have any information with 6 regard to this last paragraph to put a line 7 next to it, to question it? 8 A I don't know why I put a line next 9 to it. 10 Q In fact, you previously testified, 11 when you put a line next to something, that 12 meant that it was false? 13 A That's not what I said. 14 Q Do you consider this to be false, 15 what was written here? 16 A Probably, yeah. I think most -- I 17 think the book, as I've said in public many, 18 many times, is basically a fabrication. 19 Q Turn to the next page. 056401. 20 First paragraph, "Hillary is the one to talk 21 to, trust me. I'll be talking to her 22 tonight. I've got to join them on a trip on 444 1 Air Force One. 2 She'll understand the risk you're 3 taking. You don't have to worry about her 4 hurting your career. I know her well enough. 5 She'll be interested to hear what you have to 6 say and she's the only one who can change 7 things." 8 A This was a butte for me. I thought 9 this was, you know, rock solid evidence of 10 disproving things because, if I remember the 11 chronology correctly, this came out sometime 12 in June. This came out after the FBI files, 13 I think, had happened. Yeah, it was after 14 the FBI files. Right? 15 I mean why I think I wrote that, if 16 my memory is correct, that this book came out 17 after all of the testimony had come out in 18 the FBI files. That by this time I would 19 have known, based on public records, that 20 Hillary denied getting Craig Livingstone the 21 job, that Hillary said, in fact, she may have 22 only met him once or twice, did not have a 445 1 close personal relationship and deep 2 relationship with him where she would be 3 talking to him, that he wouldn't have been on 4 that trip in Air Force One most likely, that 5 this would have been one of the easiest 6 things to disprove in the whole book. 7 Q Did you ever sat about to gather 8 information to disprove this particular 9 paragraph in Aldrich's book? 10 A I don't know if I needed to on that 11 one because there was enough on the public 12 record already. 13 Q You would believe anything on the 14 public record; is that your position? 15 A No, no, I didn't say that. I 16 believe the First Lady, when she says 17 something on the public record. 18 Q You were not privy to this alleged 19 conversation with Hillary, were you, as 20 reflected on 056401? 21 A I was privy to the public 22 statements where Hillary said that she didn't 446 1 have that kind of relationship with him. 2 Q You would believe anything that 3 Hillary Rodham Clinton tells you? 4 A I certainly would believe what 5 Hillary Rodham Clinton says on the public 6 record about her relationship with Craig 7 Livingstone and certainly I'll believe what 8 she says more than what Gary Aldrich writes 9 in his stupid book. 10 Q Why is that? 11 A Because Gary Aldrich is a 12 pathological liar and Mrs. Clinton isn't? 13 Q Has Mrs. Clinton ever been analyzed 14 as to whether she is or is not? 15 MR. BRAND: Larry, if you don't 16 mind, I would ask you to withdraw the 17 question so we don't go down the same route. 18 BY MR. KLAYMAN: 19 Q Well, what was the basis for your 20 statement that Gary Aldrich is a pathological 21 liar and Mrs. Clinton is not? Is there any 22 medical evident to support either position? 447 1 A I don't know about medical 2 evidence. I think this book is all the 3 evidence I need to show that Gary Aldrich is 4 a pathological liar and I think my six-year 5 relationship with Mrs. Clinton is all the 6 evidence I need to know that she isn't. 7 Q But you never researched anything 8 in particular with regard to Gary Aldrich's 9 book? 10 A I researched the whole book, as you 11 can tell by my markings. 12 Q Is there a file that contains your 13 research as to whether passages in this book 14 are untrue? 15 A Right here? 16 Q That's it? Did you ever ask 17 anybody to research what Gary Aldrich had 18 written? 19 A I think there were some affidavits 20 collected of people who were mentioned in the 21 book where they were disputing what he said. 22 Q Who collected those affidavits? 448 1 A Counsel's office. I talked to 2 people about them. 3 Q Who in the counsel's office? 4 A I don't remember. 5 Q It's pretty important, isn't it, 6 what was written in Gary Aldrich's book? 7 A Not really actually in retrospect. 8 Q Didn't you go on a TV show, I think 9 it was this week as a matter of fact and call 10 Gary Aldrich a pathological liar? 11 A I did. 12 Q Did you research whether what he 13 had written was true before you made that 14 statement on TV? 15 A I read the book. 16 Q That's all you did? 17 A I read the book. I talked to 18 people who were charged with things in the 19 book. Basically, you know, David Brock and 20 George Will did as much damage, if not more 21 damage, to Gary Aldrich's reputation on that 22 show as I did. 449 1 Q Who did you talk about Aldrich's 2 claimed false statements? 3 A Depended on the statement. 4 Q Who in particular? Name anybody. 5 A Oh, probably Doris Matsui. I 6 remember one about Doris Matsui. 7 Q Did you talk to Doris Matsui? 8 A Either to her or her office and she 9 filed some affidavit. 10 Q You can't remember? 11 A Not exactly. 12 Q Did you ever talk to Hillary Rodham 13 Clinton about Gary Aldrich? 14 A No. 15 Q Would you look at me when you 16 answer that question. Did you ever talk to 17 Hillary Rodham Clinton? 18 A Do I have to? 19 Q Yes. 20 A No. 21 MR. BRAND: It's almost 10 of 6. 22 MR. KLAYMAN: Are you ordering the 450 1 deposition closed, Mr. Brand? 2 MR. BRAND: I'm not ordering 3 anything. I told you we stayed for six 4 hours. That's all we can do today. 5 MR. KLAYMAN: Is this all you're 6 doing today? 7 MR. BRAND: Yes. 8 MR. KLAYMAN: Well, let the record 9 reflect that your leaving this deposition on 10 your own volition, that I want to continue 11 and I'm going to leave this deposition open. 12 MS. SHAPIRO: We object to leaving 13 the deposition open and the court's order 14 reflects that only six hours is authorized 15 for this deposition. 16 MR. KLAYMAN: We have not done six 17 hours of testimony. 18 MR. GAFFNEY: I concur with the 19 statements of Ms. Shapiro. I would add also 20 that six hours was far more than enough to 21 get this examination done and we will object 22 to any effort by you to take any further 451 1 testimony. 2 MR. KLAYMAN: Are you taking issue 3 with the court's order, Mr. Gaffney? 4 MR. GAFFNEY: The court's order 5 speaks for itself, Mr. Klayman. 6 MR. KLAYMAN: You think two six 7 hours was too much? 8 MR. GAFFNEY: Mr. Klayman, I'm not 9 here to have a discussion with you on the 10 record. I'm here, to the extent I speak, 11 make objections. 12 MR. KLAYMAN: We have not done six 13 hours testimony and that's our position and 14 our position is the deposition is open. 15 VIDEOGRAPHER: This conclude this 16 video deposition. The time now is 17 approximately 6:51 p.m. 18 (Whereupon, at 6:51 p.m., the 19 deposition of GEORGE STEPHANOPOULOS 20 was adjourned.) 21 * * * * * 22
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