[House Hearing, 105 Congress]
[From the U.S. Government Publishing Office]
JOHNNY CHUNG: HIS UNUSUAL ACCESS TO THE WHITE HOUSE, HIS POLITICAL
DONATIONS, AND RELATED MATTERS
=======================================================================
HEARINGS
before the
COMMITTEE ON
GOVERNMENT REFORM
AND OVERSIGHT
HOUSE OF REPRESENTATIVES
ONE HUNDRED FIFTH CONGRESS
FIRST SESSION
__________
NOVEMBER 13 AND 14, 1997
__________
Serial No. 105-69
__________
Printed for the use of the Committee on Government Reform and Oversight
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WASHINGTON : 2003
____________________________________________________________________________
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COMMITTEE ON GOVERNMENT REFORM AND OVERSIGHT
DAN BURTON, Indiana, Chairman
BENJAMIN A. GILMAN, New York HENRY A. WAXMAN, California
J. DENNIS HASTERT, Illinois TOM LANTOS, California
CONSTANCE A. MORELLA, Maryland ROBERT E. WISE, Jr., West Virginia
CHRISTOPHER SHAYS, Connecticut MAJOR R. OWENS, New York
STEVEN SCHIFF, New Mexico EDOLPHUS TOWNS, New York
CHRISTOPHER COX, California PAUL E. KANJORSKI, Pennsylvania
ILEANA ROS-LEHTINEN, Florida GARY A. CONDIT, California
JOHN M. McHUGH, New York CAROLYN B. MALONEY, New York
STEPHEN HORN, California THOMAS M. BARRETT, Wisconsin
JOHN L. MICA, Florida ELEANOR HOLMES NORTON, Washington,
THOMAS M. DAVIS, Virginia DC
DAVID M. McINTOSH, Indiana CHAKA FATTAH, Pennsylvania
MARK E. SOUDER, Indiana ELIJAH E. CUMMINGS, Maryland
JOE SCARBOROUGH, Florida DENNIS J. KUCINICH, Ohio
JOHN B. SHADEGG, Arizona ROD R. BLAGOJEVICH, Illinois
STEVEN C. LaTOURETTE, Ohio DANNY K. DAVIS, Illinois
MARSHALL ``MARK'' SANFORD, South JOHN F. TIERNEY, Massachusetts
Carolina JIM TURNER, Texas
JOHN E. SUNUNU, New Hampshire THOMAS H. ALLEN, Maine
PETE SESSIONS, Texas HAROLD E. FORD, Jr., Tennessee
MICHAEL PAPPAS, New Jersey ------
VINCE SNOWBARGER, Kansas BERNARD SANDERS, Vermont
BOB BARR, Georgia (Independent)
ROB PORTMAN, Ohio \1\
DAN MILLER, Florida \2\
Kevin Binger, Staff Director
Richard D. Bennett, Chief Counsel
William Moschella, Deputy Counsel and Parliamentarian
Judith McCoy, Chief Clerk
Phil Schiliro, Minority Staff Director
----------
\1\ Left the committee on November 13, 1997.
\2\ Joined the committee on November 13, 1997.
C O N T E N T S
----------
Page
Hearing held on:
November 13, 1997............................................ 1
November 14, 1997............................................ 877
Statement of:
Darby, Brooke, former executive assistant to Nancy Soderberg
at the National Security Council; and Robert Suettinger,
former director of Asian Affairs for the National Security
Council, accompanied by Lt. Colonel John Sparks, deputy
legal adviser, National Security Council................... 878
Hernreich, Nancy, Deputy Assistant to the President for
Appointments and Scheduling, accompanied by Bob Cearly;
Kelly Crawford, former staff assistant to Ms. Hernrich,
accompanied by David Wilson; Carol Khare, former assistant
to the chairman, Democratic National Committee, accompanied
by Evan Werbel............................................. 705
Williams, Margaret A., accompanied by Ed Dennis, Esq......... 11
Letters, statements, etc., submitted for the record by:
Barr, Hon. Bob, a Representative in Congress from the State
of Georgia, exhibit 195.................................... 751
Bennett, Richard, chief counsel, Committee on Government
Reform and Oversight:
Exhibit 232.............................................. 18
Exhibit 227.............................................. 21
Exhibit 171.............................................. 31
Exhibit 172.............................................. 39
Exhibit 255.............................................. 43
Exhibit 174.............................................. 49
Exhibit 259.............................................. 53
Exhibit 201.............................................. 55
Exhibit 196.............................................. 715
Exhibit 198.............................................. 717
Exhibit 215.............................................. 721
Burton, Hon. Dan, a Representative in Congress from the State
of Indiana:
Exhibit C-82............................................. 83
Exhibit 191.............................................. 748
Crawford, Kelly, former staff assistant to Ms. Hernrich,
deposition of.............................................. 760
Cox, Hon. Christopher, a Representative in Congress from the
State of California:
Exhibit 187.............................................. 85
Exhibit 153.............................................. 91
Davis, Hon. Danny K., a Representative in Congress from the
State of Illinois, prepared statement of................... 2
Dennis, Ed, Esq., letter dated March 6, 1997................. 116
Fattah, Hon. Chaka, a Representative in Congress from the
State of Pennsylvania:
Newspaper articles....................................... 911
Wall Street Journal article.............................. 102
Horn, Hon. Stephen, a Representative in Congress from the
State of California:
Exhibit 240.............................................. 741
Exhibits 204, 205, 206, 207, 208, and 215................ 929
Khare, Carol, former assistant to the chairman, Democratic
National Committee, deposition of.......................... 812
Kucinich, Hon. Dennis, a Representative in Congress from the
State of Ohio, memo dated April 25, 1997................... 119
Lantos, Hon. Tom, a Representative in Congress from the State
of California:
Letter dated April 6, 1994............................... 75
Photographs.............................................. 67
Morris, Richard, deposition of............................... 1048
Ratliffe, Gina D., deposition of............................. 547
Rohrbaugh, Robert, senior investigative counsel, Committee on
Government Reform and Oversight:
Exhibit 196.............................................. 881
Exhibit 198.............................................. 884
Exhibit C-79............................................. 886
Exhibit 250.............................................. 889
Exhibit 175.............................................. 894
Exhibit 251.............................................. 897
Exhibit 252.............................................. 899
Ryan, Evan, deposition of.................................... 420
Sildon, Eric, deposition of.................................. 1141
Swiller, Ari, deposition of.................................. 948
Waxman, Hon. Henry A., a Representative in Congress from the
State of California:
Final rule, political activities of Federal employees.... 135
Photographs.............................................. 63
Williams, Margaret A.:
Deposition of............................................ 155
Prepared statement of.................................... 14
JOHNNY CHUNG: HIS UNUSUAL ACCESS TO THE WHITE HOUSE, HIS POLITICAL
DONATIONS, AND RELATED MATTERS
----------
THURSDAY, NOVEMBER 13, 1997
House of Representatives,
Committee on Government Reform and Oversight,
Washington, DC.
The committee met, pursuant to notice, at 10:15 a.m., in
room 2154, Rayburn House Office Building, Hon. Dan Burton
(chairman of the committee) presiding.
Present: Representatives Burton, Morella, Cox, Ros-
Lehtinen, McHugh, Horn, Mica, Davis of Virginia, McIntosh,
Souder, Shadegg, Sununu, Pappas, Snowbarger, Barr, Portman,
Waxman, Lantos, Kanjorski, Sanders, Maloney, Barrett, Norton,
Fattah, Cummings, Kucinich, Davis of Illinois, Tierney, Allen,
and Ford.
Staff present: Kevin Binger, staff director; Richard
Bennett, chief counsel; Dudly Hodgson, chief investigator;
Barbara Comstock, chief investigative counsel; Judith McCoy,
chief clerk; William Moschella, deputy counsel and
parliamentarian; Teresa Austin, assistant clerk/calendar clerk;
Will Dwyer, director of communications; Ashley Williams, deputy
director of communications; Dave Bossie, oversight coordinator;
Robert Rohrbaugh, James C. Wilson, and Uttam Dhillon, senior
investigative counsels; Charli Coon, Kristi Remington, Bill
Hanka, and Jennifer Safavian, investigative counsels; Phil
Larsen, investigative consultant; Jim Schumann, investigator;
Robin Butler, office manager; Carolyn Pritts, David Jones, and
John Mastranadi, investigative staff assistants; Phil Schiliro,
minority staff director; Phil Barnett, minority chief counsel;
Kenneth Ballen, minority chief investigative counsel; Agnieszka
Fryszman, Kristin Amerling, Christopher Lu, Andrew McLaughlin,
Michael Raphael, Michael Yang, and Michael Yeager, minority
counsels; Harry Gossett, minority professional staff member;
Ellen Rayner, minority chief clerk; Jean Gosa and Andrew Su,
minority staff assistants; and Sheridan Pauker, minority
research assistant.
Mr. Burton. Good morning, a quorum being present, the
Committee on Government Reform and Oversight will come to
order.
Before Mr. Waxman and I begin our opening statements, we
will dispose of some procedural matters. First of all, I ask
unanimous consent that all Members' statements be included in
the record.
And without objection, so ordered.
[The prepared statement of Hon. Danny K. Davis follows:]
[GRAPHIC] [TIFF OMITTED] T5667.001
[GRAPHIC] [TIFF OMITTED] T5667.002
Mr. Burton. I ask unanimous consent that all exhibits,
articles, and extraneous or tabular material referred to during
this hearing be included in the record.
Without objection, so ordered.
I ask unanimous consent that the depositions of Maggie
Williams, Evan Ryan, and Gina Ratliffe be made a part of the
record.
Without objection, so ordered.
I ask unanimous consent that Members be able to use the
depositions of Carol Khare and Kelly Crawford in open session.
Without objection----
Mr. Waxman. Reserving the right to object, and I will not
object, but I do want to indicate that it is our desire that
those three depositions be made public.
We are withholding a unanimous consent request while our
lawyers look at those depositions to see if there is any reason
that they ought not to be made public. I just want to point
that out. We will hopefully come back to this issue later. I
withdraw my reservation to the unanimous consent request.
Mr. Burton. Without objection, so ordered.
In concurrence with the minority, I ask unanimous consent
that the Members be able to use the depositions of Ari Swiller,
Dick Morris and Eric Sildon in open session.
Without objection, so ordered.
I ask unanimous consent that the depositions of Carol Khare
and Kelly Crawford be made a part of the record once they have
had the opportunity to review their deposition pursuant to
committee rule No. 20.
Without objection, so ordered.
Questioning in the matter under consideration shall proceed
under clause 2(j)(2) of House rule 11, and committee rule 14,
in which the chairman and ranking minority member allocate time
to committee counsel as they deem appropriate for extended
questioning, not to exceed 60 minutes per panel, equally
divided between the majority and minority.
Today, we are going to begin 2 days of hearings regarding
Johnny Chung, his political donations, and his unusual access
to the President of the United States.
Today's hearing will focus on his controversial $50,000
contribution to the Democratic National Committee in March
1995, the role of the First Lady's office, his success in
gaining access to the President for Chinese associates, and his
involvement in the Harry Wu affair.
Mr. Chung has been subpoenaed to appear before this
committee. As everyone knows, he has invoked his fifth
amendment right against self-incrimination. We are continuing
to have discussions with his attorney, who has asked that Mr.
Chung testify in executive session. At this point, it is our
plan to conduct a deposition with Mr. Chung tomorrow morning
before making a final determination on that matter.
These are our first hearings on Johnny Chung. They will not
be our last. We will not try to answer all of the questions
that have been raised about him in just 2 days. This is an area
that we will return to in the coming months.
Johnny Chung contributed $366,000 to the Democratic
National Committee. All of that money has been returned because
of suspicions about its legality.
While all the answers are not in yet, these suspicions
appear to be well-founded. In addition to his donations to the
DNC, this committee has obtained clear-cut evidence that
employees of Johnny Chung arranged conduit contributions to the
Clinton/Gore campaign. Committee staff has interviewed three
individuals in California, who contributed $1,000 each to the
Clinton/Gore campaign and were reimbursed in cash by an
employee of Johnny Chung.
This hearing is not, however, just about Johnny Chung. This
hearing is about a White House that attracted him like a
magnet. This is a story about a President who was starved for
cash and did not mind going all out to get it.
Johnny Chung wanted to use the White House, and this is a
White House that was willing to be used.
In a Los Angeles Times article this summer, Johnny Chung
said, quote, ``I see the White House is like a subway, you have
to put in coins to open the gates.''
Where did he get this impression? It is not hard to figure
out. This is the same White House where hundreds and hundreds
of major donors, complete strangers, were invited to sleep over
in the Lincoln bedroom at the President's directive. This was
the same White House where over 100 fund-raising coffees were
held by the President. This was the same White House where
convicted stock swindlers and drug traffickers found their way
into intimate gatherings with the President. This was the same
White House where John Huang and Charlie Trie were roaming the
hallways with controversial figures like James Riady of
Indonesia and Ng Lap Seng of Macau.
Time after time, we are seeing that the President and his
people were more than happy to be used, as long as the money
kept flowing in.
Johnny Chung was described by one National Security Council
aide as a, quote, ``hustler.'' More and more this description
appears to fit. To Johnny Chung, the White House and the
President were promotional tools for his business ventures.
His promotional booklet for his fax business features no
less than 12 photos of the President and the First Lady. There
are another dozen photos of Mr. Chung in various rooms at the
White House. He was aggressively using this booklet to recruit
new investors for his company. One California investor was so
impressed with Mr. Chung and his connections with the President
that he and his family invested over $900,000 in Johnny Chung's
company. Within months, he realized he had made a mistake and
sued to get his money back.
Johnny Chung was also working very hard to develop business
ties in China. When the Los Angeles Times asked him about his
efforts to get Chinese officials in to see the President of the
United States, he said, ``I am trying to build a new business
in China, so I am happy to do my best to help.''
In March 1995, Johnny Chung wanted to get six well-placed
Chinese nationals into the White House to see the President. He
went to see Richard Sullivan at the DNC. He offered to make a
substantial contribution if he could get them in and arrange
this meeting.
Mr. Sullivan would not set up the meeting. In his Senate
deposition, Mr. Sullivan said, ``Johnny Chung had made me
nervous. Him showing up with these five people from China . . .
I had a sense that he might be taking money from them and then
giving it to us, you know. That was my concern.''
Mr. Chung was not deterred. He went to the First Lady's
office at the White House. Mr. Chung has said in news
interviews that the First Lady's Chief of Staff was willing to
help him, but that she solicited a large contribution from him
to help pay off the DNC's debts to the White House. Mr. Chung
said that he readily agreed to donate $50,000. This charge is
denied by Mrs. Clinton's Chief of Staff, Margaret Williams. We
will hear testimony from her today.
Mr. Chung has also stated that he was told that the First
Lady was aware of his contribution. I will ask the staff at
this point to play that portion of his interview that Mr. Tom
Brokaw had with him.
Would you put that on right now, please? I hope the sound
system is working.
[Video tape presentation was shown.]
Mr. Burton. One by one, Mr. Chung's requests were quickly
agreed to. It apparently took a flurry of phone calls between
the White House and the DNC before the final and most important
request was filled: admission to the President's Saturday
morning radio address. After interviewing and deposing several
people over the last 2 weeks, we still do not know who gave the
final approval for this request. We will ask several of our
witnesses today who gave the final approval. We need to know
that. However, it appears that this may remain an even greater
mystery than who hired Craig Livingstone.
There are three important questions that we would like to
try to answer on this issue: First, did the White House staff
solicit campaign contributions in exchange for official favors?
Second, why wasn't anyone asked to screen foreign nationals
being brought into the President, as was done in previous
administrations? Third, was Mr. Chung's donation itself legal?
We have 2 days to try to resolve these three questions. We
will see how far we get.
I think that it is interesting to note that Richard
Sullivan, the finance director of the Democrat National
Committee, would not set up a meeting with the President,
because he was concerned that Mr. Chung's contributions may
have come from a foreign source. I will repeat his words once
again: ``I had a sense that he might be taking money from them,
(his Chinese associates), and giving it to us.''
However, when Mr. Chung's $50,000 check came in, it was
readily accepted, no questions asked. In fact, Mr. Chung
contributed a total of $190,000 after that date.
Were Mr. Sullivan's concerns justified? The facts aren't
all in yet. Mr. Chung's finances are difficult to unravel.
However, here is what we do know about the $50,000 donation.
On March 6, Johnny Chung received a $150,000 wire transfer.
The money came from the Haomen Tangshan Beer Co. in Beijing.
Mr. Chung escorted the chairman of this company to see
President Clinton in December 1994. At the time, there was less
than $20,000 in Mr. Chung's account.
On March 9, the day of his meeting with Mrs. Clinton, Mr.
Chung wrote a check to the DNC for $50,000.
What do these transactions mean? We honestly don't know.
Was this a conduit contribution? Was this $150,000 legitimate
income earned by Mr. Chung's business? We don't have the
answers yet. We hope to ask Mr. Chung these questions tomorrow.
If nothing else about the way the White House dealt with
Johnny Chung generates any outrage, the case of Harry Wu
should. On June 19, 1995, human rights activist Harry Wu was
arrested in China. He was trying to expose slave labor
conditions there. This set off a lengthy and very delicate area
of negotiations to win his release.
When Johnny Chung met the President in a receiving line at
a fund-raiser, he informed the President that he was going to
go to China and try to get Harry Wu released. According to
Johnny Chung's account, the President urged him to go on.
Mr. Chung sent a fax to both the White House and the DNC
stating that he needed a letter of credentials so that the
Chinese Government would know that he was there on the
President's behalf. He told the DNC that he was going to meet
with the President of China.
This should have set off alarm bells. He should have
immediately received a call from the White House. He should
have been told that this was an extremely sensitive situation
and that it had to be handled by professional diplomats.
Instead, he apparently got no response from the White House.
What he did get was a letter of credentials and
encouragement from the head of the Democrat National Committee,
Mr. Fowler. The chairman of the DNC was perfectly prepared to
allow one of his major contributors to go blundering into a
very delicate situation with God knows what consequences.
At the same time Mr. Fowler's letter was being prepared,
another DNC official, Bobby Watson, was calling the White House
to warn them that Mr. Chung was on his way to China, and that
he intended to represent to the Chinese Government that he was
speaking for the President of the United States. In other
words, they knew that they shouldn't have been doing what they
were doing, but they did it anyway, and then they tried to
contain the damage.
By the time the National Security Council found out about
this, Mr. Chung was already on his way to China. It was too
late.
Far East expert Robert Suettinger stated in a memo to
Anthony Lake: ``All we can do is hope the Chinese recognize
Chung's credentials are thin, and that his message should be
treated with caution. No one in the administration has any idea
of what he plans to say on the subject of Harry Wu.
``In the Harry Wu case, however, he could conceivably do
damage, depending on what he says and how much credibility he
carries with Beijing.''
Mr. Suettinger's comments pretty much say it all. He will
be testifying tomorrow.
Was the Clinton White House that desperate to humor Johnny
Chung and keep the money flowing? A man's life and freedom were
hanging in the balance. Would no one call Johnny Chung and stop
him from forging ahead into this explosive situation?
We have two panels of witnesses over the next 2 days. We
have serious issues to deal with. We have a lot of ground to
cover. As I said earlier, we are not going to try to answer all
of the questions about Johnny Chung and the White House over
the next 2 days. However, I hope that we will make a dent.
I look forward to hearing the testimony of Ms. Williams and
other witnesses today, and I now recognize Mr. Waxman for this
opening statement.
Mr. Waxman. Thank you, Mr. Chairman.
This is not a hearing about economic espionage or foreign
agents or conspiracies to infiltrate our political system or
any of the more sensational charges that we heard about earlier
this year. This is a hearing about campaign contributions and
access, and that is an important topic, especially if we have
any genuine interest in reforming our campaign finance system.
I think Robert Suettinger will testify tomorrow, providing
the best description of Johnny Chung in a 1995 memo. That memo
appeared in the New York Times on February 15th, warned that
Mr. Chung should be treated with a pinch of suspicion. Mr.
Suettinger wrote, ``My impression is is that he's a hustler and
appears to be involved in setting up some kind of consulting
operation.''
I think that is right. Nothing in the materials that the
committee has received indicates anything else. Johnny Chung
was acting in his self-interest to make money. And in doing so,
he did what thousands of other people do in Washington every
year. He set out to gain access.
Now, one of the reasons the public ridicules politicians is
that in these instances we invariably have selective outrage.
When Republicans buy or sell access, Democrats howl. When
Democrats buy or sell access, we have Republican outrage.
We specialize in self-righteousness and ignore the
overwhelming reality, and that reality is that money buys
access. To pretend otherwise is ridiculous.
I have a page from the Senate Republican Campaign
committee's 1996 manual. It provides advice on fund-raising to
Republican candidates, and has a section entitled: ``Why do
people give money?'' It lists three reasons. One, they know you
and like you; two, they believe in similar issues, (usually
small donors); three, to gain access to power.
So there is no misunderstanding, I am not suggesting that
only Republicans think this way. There is probably nearly
identical advice given to the Democrats in our campaign finance
manuals. Johnny Chung and thousands others fall into category
No. 3. They are in the business of politics and money brings
enhanced access.
I am amazed that anyone would be surprised by this. If Jane
Smith, just a regular constituent, called any member of this
committee and asked for a meeting, the answer would probably be
no. That is a reality of politics. We have too many requests
and we can't meet with everyone. But if Jane Smith and her
husband had given $2,000 each and then called our staffs, the
chances are pretty good that there would be a meeting. And that
is a cold reality of politics today.
It may, and I hope it does, bother us. We should find it
repugnant and we should come clean to the American people and
admit what they already know is true. In the scheme of things,
Johnny Chung was not a big player by Washington standards. He
is dwarfed by the money and access that tobacco companies and
others like Archer Daniels Midland or Amway enjoy. Nonetheless,
the record shows Mr. Chung gave hundreds of thousands of
dollars and then visited the White House over 50 times. He ate
in the Mess, attended a radio address, sat in the movie
theater, attended parties, and schmoozed. The only thing it
seems he didn't do is ask for any policy favors.
It could be that the White House extends these privileges
to every American that asks. I am skeptical and find it
impossible to believe that Mr. Chung would have had the same
opportunities had he not given campaign contributions.
Another reality of politics is that this didn't start with
Johnny Chung. I have an article from May 1, 1992, by Lars-Erik
Nelson, and that should be of great interest to this committee.
It was given to me by my Uncle Ben, who was looking through
some of his papers, and I want to read parts of this article.
The headline says:
President Bush and his campaign team recognize dollars,
ignore donors. Who is that distinguished gentleman sitting at
the head table with Michael Kojima? Why, yes, it's President
Bush. And there's Barbara, too. Aren't they lucky to be rubbing
shoulders with Michael Kojima at this gala President's dinner?
A better question, of course, is who is Michael Kojima to
be seated with the President? And the answer to that is, nobody
has a clue. Kojima simply donated $400,000 to a Republican
fund-raiser and was made an honored guest.
He is described as a Los Angeles businessman, but his
office address is a front, rented space in a law firm where he
never shows up. His voting address is also a fake; it's his
wife's business address.
He shows up in no newspaper clippings. The California
secretary of state has no listing for his business. California
politicians, both Democrat and Republican, have never heard of
him.
The organizers of the President's dinner, which raised $9
million for Republican congressional candidates, admit they are
mystified about Kojima. This is the first time he has appeared
as a heavy-hitting contributor, and, as GOP spokesman Rich
Galen explained, you don't cross-examine a guy who writes
checks with so many zeros after the dollar sign.
Lots of things stink in your Nation's capital, but this
President's dinner absolutely reeks.
One of the cochairmen, James Elliot, is a convicted felon,
in connection with an S&L racket, who was lobbying for a
Presidential pardon. He figured selling tickets to the
President's dinner might help his cause. Surely, it would. If
he could sell $92,000 worth of tickets, he gets to be
photographed with the President.
There is worse, however. According to a suit filed in
Illinois, Elliot leaned on employees of his company, Cherry
Payment Systems, to buy $1,500-per-plate tickets to the
President's dinner if they knew what was good for them. William
Neiss, an employee who refused, said he was fired as a result.
President Bush, of course, is horrified that anyone would
lean on people to support the Republican Party. Bush has been
in politics for 28 years, but he is like unto a newborn babe
when it comes to the subject of campaign contributions.
Also, he has nothing, in principle, against selling access
to himself. Spokesman Marlin Fitzwater explained: ``It's buying
access in the system, yes,'' he said. ``That's what the
political parties and the political operation is all about.''
Now, you and I were not born yesterday. Certainly it is a
long-established practice that the extremely wealthy can buy
their way into the system, buy invitations to state dinners in
the White House, buy photo opportunities with the President,
buy a lunch with Vice President Quayle, ($20,000), or even buy
Ambassadorships, ($100,000).
Generally, however, the politicians who peddle this access
know who is buying it. In the case of Kojima, they have no
idea. They don't know who he is or what he does or where his
money comes from. He called himself an international business
consultant, but what could that mean? The Bank of Credit and
Commerce International was an international business. Manuel
Noriega was in international business.
The Secret Service checked only to make sure he posed no
physical threat to the President. As for embarrassing Bush, the
Secret Service couldn't care less. ``We don't veto his guest
list,'' a spokesman said. Oddly, the Republicans don't care who
Kojima is, either. They just look at the check, cash it, and
ask him where he wants to sit.
After 2 days of searching all available records for Michael
Kojima, all I can tell you about him is this: Whoever he is,
whatever he does, and whatever he wants out of life, he has
more access to President Bush than you ever will.
Well, there it is. Before we had a Clinton administration,
or any of us had ever heard of Johnny Chung, we had money,
access, international consultants, coercion to contribute, and
a willingness to accept money with no questions asked. As Yogi
Berra once said, it is deja vu all over again.
Was it wrong that Michael Kojima could work the system so
that he could sit by President Bush's side? Absolutely. Should
we be disgusted? Absolutely. Was it wrong that Johnny Chung
could work the system so that he could be at President
Clinton's side? Absolutely. Should we be disgusted? Absolutely.
Mr. Chairman, I know that on many occasions you have said
that it is not the system that is broken. I think you are dead
wrong. The system is a farce. Johnny Chung is an equal
opportunity opportunist. And I want, if we could, to show a
couple of photos of him.
We know about him with President Clinton. But he was also
able to get photographs and access to the Speaker of the House,
Newt Gingrich. The majority leader, Senator Bob Dole.
Mr. Chairman, I know you oppose reforms that fundamentally
change how we finance campaigns and I think you are wrong
again. The only legitimate purpose our hearings can serve is to
change the system. If we had public financing, I believe we
would have a whole lot less of Michael Kojimas and Johnny
Chungs to worry about.
One last point. Our first witness today is Maggie Williams
and she is here voluntarily. She has already been deposed in
the Senate for 8 hours, and in the House for over 10 hours.
She now lives in Paris and made a special trip to be here
today. She worked for the Clinton administration for 4 years.
No one has produced any evidence that she ever acted illegally
or unethically, notwithstanding that she has already incurred
over a quarter of a million dollars in legal fees. I think in
most cases people don't go into public service for the money.
But this is ridiculous.
Ms. Williams, having reviewed your depositions, I think the
Senate made the right choice by not calling you as a witness. I
am not sure why you are here, but I want to thank you for
coming here today and tell you that I look forward to your
testimony.
Mr. Chairman, I yield back the balance of my time.
Mr. Burton. Thank you, Mr. Waxman.
Ms. Williams, would you rise so that you can be sworn,
please?
[Witness sworn.]
Mr. Burton. Be seated.
Ms. Williams, on behalf of this committee, we welcome you
here today. You are recognized for 5 minutes, if you wish to
make an opening statement. If it is longer than that, we will
include your entire statement in the record.
STATEMENT OF MARGARET A. WILLIAMS, ACCOMPANIED BY ED DENNIS,
ESQ.
Ms. Williams. Thank you. Good morning, Mr. Chairman, Mr.
Waxman, members of the committee. You have asked me to come
here today to address you concerning Johnny Chung.
I will tell you what I know of this matter. There are many
things that I do not know and will be unable to assist you
with, but those things that I know about, I am more than happy
to answer your questions this morning.
I do not remember the exact circumstances of my first
introduction to Johnny Chung. I know I met him early in the
first term of the Clinton administration. I do remember the
story he told me at our first meeting. He told me that Mrs.
Clinton's encouragement was important to the success of his
business. He credited her with his professional achievements
and told me she remained a significant inspiration in his life.
His enthusiasm for Mrs. Clinton, I will tell you, bordered
on the worshipful. Mr. Chung would not and seemingly could not
stop saying how much he admired her. He was highly emotional
about his support for her, and I did not doubt his sincerity.
This initial interaction with Mr. Chung became the context for
my association with him. At some point, I also learned that he
was a contributor to the Democratic National Committee.
As has been reported in the media and recorded in the
visitor entry records, Johnny Chung came to the buildings in
the White House complex a number of times. Many of those
entries were arranged by my assistant, Evan Ryan. Long before
Mr. Chung requested that he be cleared through my office for
entry into the White House complex, he routinely would be in
the Old Executive Office Building and stop by my office which
housed the First Lady's staff. Our staff office, unlike most of
the offices in the Old Executive Office Building, kept the
reception door open. The open door, a rotating picture gallery
featuring the First Lady busy with her many activities, stacks
of reprinted speeches available for the taking, and a huge
cardboard cutout of the First Lady, a favorite site for visitor
photos, encouraged unscheduled drop-bys from interns, visitors
with other business in the Old Executive Office Building,
family members, and friends. The reception area was a welcoming
place and we made it that way on purpose.
Mr. Chung visited the First Lady's office in the Old
Executive Office Building more often than most. Like other
visitors to our reception area, he typically would spend time
viewing the pictures, using the phone reserved for guests,
chatting with anyone and everyone working or passing through
the front of our office. His many visits and then his constant
requests later to be cleared into the complex did provoke
complaints from both my volunteers and my staff. They found his
visits to be a nuisance. They found his personal manner
irritating. Indeed, there were times when I walked through
other offices to avoid running into Mr. Chung when I was
especially busy.
Nevertheless, the standard of treatment I demanded for
Johnny Chung was the same standard of treatment I demanded for
all of our visitors and supporters who came into the Old
Executive Office Building. I continued to require that the
First Lady's staff, whether they wanted to or not, extend every
courtesy to him. And I instructed my staff to be tolerant of
both his visits as well as his requests.
Now, to be honest, any special treatment given to Mr. Chung
represented my efforts to compensate to some degree for the
snickers that sometimes occurred during his inartful and
sometimes confounding use of the English language. He could be
embarrassingly aggressive. He was like a bull in a China shop
is, but he was never unkind. He was never rude. He was
different, it was clear. It was clear to me; it was clear to my
staff that he was different. He was different socially and
culturally, and it showed. Sometimes painfully so. And as an
African American, I can tell you, I know what it means to be
different in politics in America, and be on the outside of
things and struggle mightily for insider status and
recognition. And so I, perhaps, had an especially high
tolerance for Mr. Chung.
A prime example of his aggressive and I believe sometimes
simply misguided behavior was his persistent requests to give
money directly to Mrs. Clinton. He wanted to demonstrate his
financial support for her. On more than one occasion I told Mr.
Chung this was not possible, although his offer was much
appreciated.
In response to his requests, I told him he could support
Mrs. Clinton by supporting the DNC. So when he asked me how can
I give, how can I show support, I told him support the DNC or
perhaps give to the Clinton/Gore campaign. Write Mrs. Clinton a
note and tell her how much you appreciate the work she is doing
for our country. Help the President and Mrs. Clinton's legal
defense fund. These were my standard responses to anyone asking
me how they could help or show their support for the Clintons.
I do not remember if I ever responded to Mr. Chung's
requests to give money to Mrs. Clinton by directing him to the
President and First Lady's legal defense fund, although it is
likely that I did. I do know that when Lynn Cutler, one of the
founders of the Back-to-Business Committee, asked if I knew
Clinton supporters who would be spokespersons or contributors
to the group, Mr. Chung's name was one of the four or five
people I recommended that she talk to.
One day Mr. Chung came to the Old Executive Office
Building. I believe that either in the reception area of my
office in the Old Executive Office Building or in the hallway
leading into the reception area, Mr. Chung pressed me to take a
check for the DNC. He was both excited and insistent, saying
words to the effect, ``I give to the DNC through you; I give
through the First Lady's office.''
Now, I did not encourage Mr. Chung to believe that
presenting me or someone in my office with a campaign
contribution or a DNC contribution would result in any credit
with me or my office, nor did I encourage him to believe that
our office was a conduit for campaign contributions of any
kind.
And now, in retrospect, after having had depositions of
nearly 15 hours about this matter, after coming here and
leaving my new husband in Paris, France, in retrospect, I could
have been equally insistent, I suppose, that I could have been
rude and refused to take the check from him. But it made no
sense to me at that time to do anything than take the check,
quiet him, shorten our encounter, remain gracious, and get on
with what I had to do.
I believe I put the check in my outbox leaving an assistant
or volunteer to direct it to its appropriate destination, as I
had done with other checks that my office had received through
the mail.
Entry records to the White House complex suggest that Mr.
Chung had a picture taken with Mrs. Clinton on the same day he
gave me that check to pass along to the DNC. I did arrange for
Mr. Chung to use my personal account at the White House
lunchroom. Possibly more than one time--my personal account,
the account that I pay for with my own money.
Both arrangements were the type I had made for others,
including Members of Congress, members and friends of the
administration, staff, visitors, and family, on numerous
occasions. I needed no special motivation to do for Mr. Chung
what I had done for others.
[The prepared statement of Ms. Williams follows:]
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Mr. Burton. Thank you, Ms. Williams. I will now start our
questioning with Mr. Bennett.
Mr. Waxman. Mr. Chairman, yes, before you do, I want to
apologize that I have to go to another committee where they are
holding a hearing on tobacco. I will return in time to ask some
questions of you, Ms. Williams.
Mr. Bennett. Good morning, Ms. Williams.
Ms. Williams. I'm sorry, I didn't hear your name.
Mr. Bennett. My name is Dick Bennett. I have been the chief
counsel for the last 2 months. I don't believe--you did not
testify before the U.S. Senate.
Ms. Williams. No, I didn't.
Mr. Bennett. We felt it was important to have you testify
here publicly. I thank you for coming and----
Mr. Burton. Excuse me; could you pull the mic closer to you
to be sure to hear you.
Ms. Williams. Certainly.
Mr. Bennett. For the record, I note that you are
represented by an old friend of mine, Mr. Ed Dennis from
Philadelphia. Mr. Dennis, it is nice to see you.
Ms. Williams, if at any time you need to refer to Mr.
Dennis, indicate that and I will give you the time. Also, Mr.
Lanny Breuer from the White House is back. Mr. Breuer, nice to
see you, and we will not call you forward to testify.
Mr. Breuer. I appreciate that.
Ms. Williams. I have one more thing. Could you explain the
lights?
Mr. Bennett. The lights. The light is green while I am
speaking, then it comes to yellow as I begin to--I think it is
3 minutes left and it will turn yellow. When it hits red, I am
to stop.
Ms. Williams. OK.
Mr. Bennett. And if you see it go red and I am still
talking, tell me to shut up. You can tell me that if you want.
Ms. Williams, you served as Chief of Staff to Mrs. Clinton
from the very first days of the Clinton administration until
May of this year; is that correct?
Ms. Williams. Yes, sir, that is correct.
Mr. Bennett. Were you always the Chief of Staff for Mrs.
Clinton?
Ms. Williams. I always felt I was the Chief of Staff.
Mr. Bennett. And that was your title the entire time you
were at the White House?
Ms. Williams. My entire title was Assistant to the
President and Chief of Staff to Mrs. Clinton.
Mr. Bennett. I think you indicated in your opening
statement that Mr. Chung's enthusiasm for Mrs. Clinton bordered
on the worshipful. I believe that was your word.
Ms. Williams. Yes, sir, that was my word.
Mr. Bennett. In fact, Mrs. Clinton had showed some kindness
to Mr. Chung previously; had she not? I will put on the screen,
if I can, exhibit 232, a letter of April 26, 1993, and the
exhibits are
there for you, Ms. Williams, or you can look on the TV screen
in front of you. It might assist you.
The letter of April 26, 1993, is a letter to Mr. Chung from
Mrs. Clinton, and as you can see, that is not just a form
letter; it is a sincere letter noting personal things in Mr.
Chung's life, correct?
[Exhibit 232 follows:]
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Ms. Williams. I do not know if it's not a form letter.
Mr. Bennett. It certainly directs attention to personal
items in his life; does it not? To your knowledge, she was
supportive to Mr. Chung and kind to him; wasn't she?
Ms. Williams. Yes, she was.
Mr. Bennett. And, indeed, in terms of your opening
statement where you noted that he visited the office----
Mr. Lantos. Do you have copies of that letter?
Mr. Bennett. I believe you do as an exhibit, Congressman
Waxman. It is exhibit 232 in the exhibit book before you.
Exhibit 232 in the exhibit book right before you, sir. Letter
of April 26, 1993.
Mr. Lantos. May I make an inquiry of counsel?
Mr. Bennett. You certainly may, sir, yes.
Mr. Lantos. You are referring to this as a letter
indicating a personal relationship?
Mr. Bennett. No, sir, I'm just indicating the kindness that
Mrs. Clinton showed to Mr. Chung. I am not indicating a deep
personal relationship between Mrs. Clinton and Mr. Chung, no,
sir.
Mr. Lantos. Let me read this letter, to be sure we read the
same letter:
Dear Mr. Chung: Thank you for your letter and my apologies
for not getting back to you sooner.
It appears from the correspondence you have had with
federal and state officials, and with the private sector, that
you are already on the right track. Nevertheless, I wish you
good look with your innovative systems. Sincerely yours,
Hillary Rodham Clinton.
This is about as nonpersonal a letter as I have ever seen.
Mr. Burton. The counsel has the time.
Mr. Lantos. I am not trying to impose on his time. But if
he misrepresents a letter, that needs to be pointed out, Mr.
Chairman.
Mr. Burton. Mr. Lantos, you will have time and you can
point it out when you have the time. Mr. Bennett.
Mr. Lantos. I think it is relevant to point it out when it
is raised.
Mr. Bennett. Ms. Williams, with all due respect to
Congressman Lantos, you understand my question. I am not asking
you with respect to that letter that Mr. Chung was a close
personal friend of Mrs. Clinton. With respect to her reference,
you're on the right track, I wish you good luck with your
innovative system, trying to cast that in as neutral a form as
possible, clearly she was wishing him good luck in some
venture; isn't that correct from the way you interpret this
letter?
Ms. Williams. Yes, she says I wish you good luck.
Mr. Bennett. And you don't have any particular knowledge of
how well she knew Mr. Chung in April 1993?
Ms. Williams. No.
Mr. Bennett. Do you know whether she knew him in April
1993?
Ms. Williams. In April 1993?
Mr. Bennett. Yes.
Ms. Williams. I do not know dates. I can't tell you if she
knew him in April 1993.
Mr. Bennett. When was the first time--I believe you
previously indicated to us, and correct me if I am wrong, Ms.
Williams, that you believe you may have first met Mr. Johnny
Chung during the campaign of 1992.
Ms. Williams. No, I first met him early in the Clinton
administration. So that would have been early 1993.
Mr. Bennett. And April 1993 being early when you first met
him, do you know whether or not Mrs. Clinton knew him at that
time?
Ms. Williams. The reason why I'm hesitant to respond
exactly is because I do not know, one, whether or not this is a
form letter or if I had talked to her in April 1993 about
knowing Johnny Chung. And, in fact, I actually don't remember
seeing this letter until sometime in 1997, I believe.
Mr. Bennett. Well, you indicated that Johnny Chung visited
the office more than most. In fact, the WAVES records, if we
can put up exhibit 227, and the chart, page 8 of that exhibit,
reflects 22 visits to the First Lady's office in just an 11-
month period from March 1995 until February 1996. I think it's
on the TV screen in front of you, Ms. Williams. Clearly, Mr.
Chung visited the First Lady's office far more than that. He
was a constant visitor essentially; wasn't he?
[Exhibit 227 follows:]
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Ms. Williams. Yes. Yes, as I said in my statement.
Mr. Bennett. And do you recall a woman named Gina Ratliffe
who worked in the First Lady's office with you?
Ms. Williams. Yes, she was an intern.
Mr. Bennett. Do you recall introducing Mr. Chung to Ms.
Ratliffe, and I believe she says at pages 34 and 35 of her
deposition, and the depositions are in front of you, I don't
think you really need to stop, I will just represent a
statement she made and I want to know if you concur with that.
She indicated that you took Mr. Chung to see her and said
something to the effect, this guy is coming in, he is a big DNC
donor, his name is Johnny Chung. Do you recall anything to that
effect?
Ms. Williams. No, I can't recall why I would introduce
Johnny Chung to an intern or I wasn't in the habit of making
introductions for Johnny Chung.
Mr. Bennett. So you have no recollection of that event?
Ms. Williams. No, I do not.
Mr. Bennett. Directing your attention with respect to
contributions by Mr. Chung, do you have any knowledge of
contributions by Mr. Chung which would have been made to the
Democratic National Committee, President Clinton's legal
defense fund, or his election campaign prior to November 1994?
Ms. Williams. Prior to November 1994?
Mr. Bennett. Of 1994.
Ms. Williams. I wouldn't know that.
Mr. Bennett. He was, in fact, to your knowledge, a trustee
of the Democratic National Committee.
Ms. Williams. I believe that he was a trustee.
Mr. Bennett. Do you have any personal knowledge of any
solicitation of Mr. Chung either by the President or the First
Lady at any time?
Ms. Williams. No, I do not.
Mr. Bennett. Do you have any knowledge--prior to February
1995, do you have any knowledge of any requests made by Mr.
Chung upon either the President or the First Lady or the
Democratic National Committee?
Ms. Williams. Prior to February----
Mr. Bennett. Prior to February 1995.
Ms. Williams. No, do I have any knowledge? No.
Mr. Bennett. Directing your attention to February 1995, you
did become aware at that time, did you not, that there were
certain requests that Mr. Chung was making? And to assist you I
would ask that we put up exhibit 171. And, again, these are in
the exhibit books for the Members on the table. Exhibit 171 was
a list Mr. Chung gave to Richard Sullivan of the Democratic
National Committee indicating that a delegation from China will
be coming in March and seeking assistance in arranging certain
benefits.
Have you seen this document before, Ms. Williams?
[Exhibit 171 follows:]
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Ms. Williams. Only at the time of my depositions.
Mr. Bennett. In fact, with respect to this request of the
Democratic National Committee on February 27th, it was followed
the next day by a request of the White House, and I'd ask to be
put up exhibit 172. And this was a request to the Visitors
Office of the White House.
Can you see that, Ms. Williams?
[Exhibit 172 follows:]
[GRAPHIC] [TIFF OMITTED] T5667.022
Ms. Williams. Yes.
Mr. Bennett. Wherein Mr. Chung references the same trip by
important and powerful business leaders of China, have you
previously seen that document?
Ms. Williams. Only at the time of my deposition.
Mr. Bennett. Did you have knowledge of essentially what we
would define as I guess a wish list of Mr. Chung reflected by
exhibit 171 in terms of certain things he was hoping--certain
benefits he might receive? Did you have knowledge of his
request in that regard?
Ms. Williams. Only knowledge in terms of having seen both
these letters at my deposition that there existed a wish list.
Mr. Bennett. At the time, did you have any knowledge in
February or March 1995, that he wanted to meet the President
and meet the Vice President and have lunch at the White House
Mess?
Ms. Williams. In February, I had no knowledge of what he
wanted.
Mr. Bennett. Ultimately by March, then, you did obtain some
knowledge of some of these requests by Mr. Chung, then; didn't
you?
Ms. Williams. Well, not obtain some knowledge. I mean,
although I have never been certain of the dates or the time,
but at some point in time, Mr. Chung made a direct request to
my office for a picture with Mrs. Clinton. I don't know if it
was the first time or the second time, but I know he'd had many
pictures with Mrs. Clinton prior to that, and also he made a
request to use my White House Mess account. So that's when I
had knowledge of his requests.
Mr. Bennett. And I'm not asking you to specify a particular
date, but at some point in time you knew there were certain
courtesies he wanted to have extended to him, correct?
Ms. Williams. Well, I believe that in my mind when you talk
about certain courtesies, he made requests like hundreds of
other people make requests to have a picture taken with Mrs.
Clinton. As I said in my deposition, there came a time when he
made that request to my office and we handled it pretty much in
the same way that we would handle any other picture request
coming from anyone, quite frankly.
Mr. Bennett. Well, actually picking up on the comments made
by Congressman Waxman--it might set a precedent for majority
counsel quoting from the minority side--Congressman Waxman made
an important point I think that clearly there are many, many
people across the country who would want to come to the White
House and have their picture taken with the First Lady, and
clearly Mr. Chung with his access that he had procured in one
form or another, unlike many, many other people across the
country, Mr. Chung, in fact, was able to get his picture taken
with the First Lady; isn't that correct?
Ms. Williams. That's correct. But if I may take just a
moment, counsel, to explain a little bit about the White House,
the First Lady's office's particular process for handling
picture requests. I think that might shed some light on why we
did not treat Mr. Chung's request as a particular request.
Mr. Bennett. If I might, I don't really want to go into
this point. It's not that I am wanting to cut you off but I
have a limited amount of time. I am not suggesting any
impropriety on your part.
Ms. Williams. But I actually believe that it will shed some
clarity and I think it is important. I am really hopeful that
the chairman will give you more time.
Mr. Bennett. That's fine, go ahead, Ms. Williams, we want
to hear what you have to say. Go ahead on that one.
Ms. Williams. Very early on we discovered that the number
of requests that came for pictures with Mrs. Clinton were huge.
And these were not just requests from donors, although there
would be requests from donors, but there would be requests from
interns, from people who would be visiting the White House on
that day, and I mean really visiting the White House on that
day, groups of people who were coming into the White House, and
we decided that we needed a way to be able to accommodate
quickly a huge number of pictures and be able to turn around on
a dime. And so we developed a system within our office by which
if Mrs. Clinton had an occasion to be leaving the White House
as she did, to be going somewhere, walking out the door, we
were sure of two things: she would have a photographer with her
and she would also have her makeup on. These would be two
clearly essential things to have in order to have any kind of a
picture.
And so because we wanted to accommodate huge numbers of
pictures, what we could simply do in the morning was to check
her schedule, see if she was on her way anywhere, and anyone
who would ask for a picture that day or the previous day could
get a picture by seeing her on her way out. She would not have
to spend a long period of time with them, she would take the
picture, and that way we could accommodate huge numbers of
people. And so that was the process by which Johnny Chung came
to get this particular picture.
Mr. Bennett. And Johnny Chung was clearly at her office
with such frequency that it wasn't difficult to find a time to
allow her to see him, I gather.
Ms. Williams. Quite frankly, it had nothing to do with the
frequency of Johnny Chung being in her office. If you had
called me and I knew you and you called me Monday morning and
you say, listen, Maggie, my mom and dad are in town. What they
really want is a picture with Mrs. Clinton today. Is that
possible? I would say, 1 second, Mr. Counselor, let me check
her schedule today. I see that she's on her way to give a
speech at the AFL-CIO. I think it's possible. And I would have
someone clear in your mom and dad and have the picture taken.
Mr. Bennett. Well, I think under the present circumstances
I'm not sure I could have my picture taken with Mrs. Clinton,
but I will certainly ask Mr. Breuer if the occasion arises.
Directing your attention to March 1995, there were, in
fact, a series of unpaid bills for collection issued in
connection with some political activity which had been held at
the White House; isn't that correct?
Ms. Williams. Well----
Mr. Bennett. To assist you, if we could put up exhibit 255,
and looking at exhibit 255, this is a memorandum which I
believe you received, Ms. Williams, in March 1995 from the
Usher's Office in connection with many unpaid bills for
collection. Included among those bills were receptions in
connection with the Democratic National Committee.
And clearly as to those political bills they could not be
paid out of the normal White House budget so they were bills
that needed to be paid and needed to be paid by the Democratic
National Committee; isn't that correct?
[Exhibit 255 follows:]
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Ms. Williams. Yes, sir----
Mr. Bennett. I think at the bottom of that document----
Ms. Williams. I'm not quite finished. I'm sorry; I wasn't
quite finished with my response.
Mr. Bennett. Go ahead.
Ms. Williams. I said yes, but one of the things that I
wanted to make sure was noted was that in addition to the DNC
bills on here that are unpaid, that there are other
organizations on this same memo whose bills are not paid, for
instance, the U.S. Olympic Committee. Here there's a mother's
day health care event with a different sponsor. I will agree
that the majority of the bills listed here have to do with the
DNC.
You'll also notice that there are a number of bills--a
number of items or entries on this list where no bill has been
submitted at all to the DNC. And so what we have is not just a
list of DNC bills unpaid, but a list of bills that were unpaid
from a number of different organizations, including the DNC.
Mr. Bennett. And so we are clear, in fairness to you, Ms.
Williams, I'm not suggesting that all the items on that
exhibit--those two pages are bills that cannot be paid out of
the White House budget, but clearly there are some that could
not be paid and had to be paid by the Democratic National
Committee, that was my point.
Ms. Williams. Actually, there is a big confusion on that
point because----
Mr. Bennett. If I could at least reference the document--I
am not trying to cut you off, but I am looking at the time on
this and I'm looking at the bottom of the document before you
on the screen which indicates particularly there is certainly
over $135,000, which is to be paid by the DNC. Do you see that
entry there?
Ms. Williams. I do, but once again, I'm going to have to
interrupt you because I want there to be some clarity about
what this document actually represents.
Mr. Bennett. Absolutely. Go right ahead.
Ms. Williams. These bills are not bills that would have
been paid out of any White House budget whatsoever. I believe
what you said in your earlier statement that, of course, these
bills would not be paid out of the White House budget. No. No
bill listed here would have been paid.
The point I was simply trying to make is that this is not a
document that says the DNC has unpaid bills. It does say that,
but in addition what it says is that the U.S. Olympic Committee
has unpaid bills. It says that another organization has unpaid
bills. That there are people who come and use the White House,
the Kennedy Center, all kinds--in fact, there are very few
events that are actually paid for by the official White House
budget. In fact, most of them are paid for by the DNC or a
sponsoring organization. Only the congressional Christmas party
is paid for out of the official White House budget, in fact. So
I just wanted to be clear that this represents a number of
organizations who owed money.
Mr. Bennett. I understand.
Ms. Williams. OK.
Mr. Bennett. With respect to this indebtedness, you were
here and saw the tape of the interview with Mr. Chung by Tom
Brokaw played by the chairman; did you not? You saw the tape we
played today of the Tom Brokaw interview?
Ms. Williams. Yes.
Mr. Bennett. Had you seen that interview before?
Ms. Williams. No, I had not.
Mr. Bennett. With respect to the contention of Mr. Chung
that essentially someone urged him to make a $50,000
contribution to deal with this kind of debt, did you, Ms.
Williams, ever specifically solicit $50,000 of Mr. Chung to
assist in the repayment of some of this money to the Democratic
National Committee to pay some of these debts?
Ms. Williams. No, I did not. As I said in response to Mr.
Chung asking how can I help Mrs. Clinton, or I would like to
give money directly to Mrs. Clinton, I did say, support the
DNC, support these other organizations, so I had said that to
him, yes.
Mr. Bennett. Do you have any knowledge--I believe Evan Ryan
was your assistant?
Ms. Williams. That's correct.
Mr. Bennett. And for the record, Mr. Chairman, Mrs. Ryan is
presently out of the country and traveling with the First Lady
and was unable to be here today and perhaps can appear at a
later date.
Do you have any knowledge of Ms. Evan Ryan ever mentioning
to Mr. Chung that he could make a $50,000 contribution in order
to cover some of this debt?
Ms. Williams. No, I have no knowledge of that.
Mr. Bennett. And then showing you exhibit 174, that, in
fact, is the $50,000 check to the DNC. Did you, in fact, look
at that check when you received it in your office, Ms.
Williams?
[Exhibit 174 follows:]
[GRAPHIC] [TIFF OMITTED] T5667.030
Ms. Williams. No, my----
Mr. Bennett. Do you know how much the check was for?
Ms. Williams. No, I did not.
Mr. Bennett. And exactly how was the check handed to you?
Ms. Williams. As I--let me just refer to my statement.
Mr. Bennett. Certainly.
Ms. Williams. As I--again, Mr. Chung came to the Old
Executive Office Building. I'm not certain where, but either in
the reception area of my office or it could have been in the
hallway in front of my office he handed the check to me. I was
either coming or going some place is what I recall.
Mr. Bennett. Ms. Williams, I'm going to play you a tape, if
I can, Mr. Chairman, of the testimony of Richard Sullivan
before the Senate. Do you know Richard Sullivan?
Ms. Williams. I've met Richard Sullivan. I don't know him
well.
Mr. Bennett. He's an official with the Democratic National
Committee. Did you have a chance to hear his Senate testimony?
Ms. Williams. No.
Mr. Bennett. Ms. Williams, I will just play a brief portion
of this, Mr. Chairman.
[Video tape presentation was shown.]
Mr. Bennett. Did Mr. Sullivan ever indicate such concerns
to you?
Ms. Williams. No, he did not.
Mr. Bennett. Let me ask you this: How would Johnny Chung in
the statement he made to Tom Brokaw, in the discussion about
holiday bills, bills that were owed, helping out paying bills,
how would Johnny Chung know that there was money owed, that
there were debts that someone needed help paying bills unless
someone from your staff told him?
Ms. Williams. Well, I believe you'd have the opportunity to
ask him that tomorrow.
Mr. Bennett. And hopefully he will answer, but I'm asking
you. Do you have any explanation as to how he would know of
these debts and these problems and trying to pay bills?
Ms. Williams. No.
Mr. Bennett. And how he would come up with the figure of
$50,000 and have any knowledge of this? Do you personally have
any knowledge of how he would know?
Ms. Williams. No, I do not. No.
Mr. Bennett. And you yourself didn't speak with him about
these bills?
Ms. Williams. No, I cannot recall a time that I did.
Mr. Bennett. And you don't have any personal knowledge
yourself of any member of your staff speaking with him; is that
correct?
Ms. Williams. I have no personal knowledge of that.
Mr. Bennett. That is to say you don't deny that he may or
may not, you just don't have any personal knowledge of that?
Ms. Williams. I have no personal knowledge of that. I don't
quite----
Mr. Bennett. Looking at exhibit 171 just very quickly
again, if we can.
[Note.--Exhibit 171 may be found on pp. 31 to 37.]
Ms. Williams. I'm sorry.
Mr. Bennett. Go ahead.
Ms. Williams. I think I maybe missed something in that
question.
Mr. Bennett. What I'm trying to clarify is, I understand
that you have testified that you did not speak with Mr. Chung
about these debts, that you did not solicit $50,000 from him.
My question to you was how he would know----
Ms. Williams. Right.
Mr. Bennett [continuing]. Of these debts, and my question
was as to members of your staff, you have testified that you
have no personal knowledge one way or the other whether or not
they solicited him. You just don't know essentially.
Ms. Williams. Right. I thought that's what I said. I didn't
understand the question.
Mr. Bennett. With respect to exhibit 171, the wish list,
ultimately, many of the items on this wish list were satisfied;
weren't they? In fact, I think essentially all of them, other
than meeting with the Vice President, were ultimately
satisfied; weren't they? He did get to meet with President
Clinton? He did have lunch in the White House Mess, going down
that list, to your knowledge; isn't that correct?
Ms. Williams. Oh, yes, I know he had lunch in the White
House Mess.
Mr. Bennett. Let me go into again in terms of certain
matters in terms of followup and cover a couple of points
within the time allowed here.
Mrs. Ryan is presently out of the country, as I said, Ms.
Williams, but her deposition transcript is before you, and
referencing pages 110 to 112, if you will take a minute to look
at that.
Ms. Williams. OK.
Mr. Bennett. And it is also available for Members of the
minority. Mrs. Ryan has testified that when she told you that
Mr. Chung was in the office, and he had some businessmen from
China and wanted these various perks, she has testified that
she also told you that he was going to be donating money to the
DNC, and Mrs. Ryan describes your response as follows, and it's
page 110 of her deposition: ``Her response was we could see,
you know, we'd see if we could set those things up for him and
that was helpful to know about his donation because then maybe
that would enable the DNC to pay off some of their debts.''
Do you see that testimony of Mrs. Ryan in her deposition,
Ms. Williams?
Ms. Williams. Yes, I do.
Mr. Bennett. Do you ever recall saying that to Evan Ryan,
specific reference to paying off the debts and seeking money
from Mr. Chung?
Ms. Williams. No, I did not. Mrs. Ryan knew, as did other
people in my office, that the DNC along with other
organizations had outstanding debts. That wasn't a secret. But
I don't recall discussing it with Ms. Ryan in relationship to
Mr. Chung specifically.
Mr. Bennett. Mr. Chairman, I know that the red light has
lit but I believe that the witness indicated at one point in
time that I gave her some more time and she asked if you would
give me some time.
Mr. Burton. Yes, Mr. Lantos--there were interruptions, so
we will allow a little more time.
Mr. Bennett. Thank you. If I could have 5 more minutes, Mr.
Chairman.
One other thing, Ms. Williams, I meant to ask you, the
interview with Tom Brokaw, Mr. Chung stated that he was told by
Mrs. Ryan that Mrs. Clinton knew of this $50,000 donation.
That's what he says on the tape. Do you know whether Mrs.
Clinton knew of this donation?
Ms. Williams. I didn't tell her. I don't know why she would
know.
Mr. Bennett. To your knowledge--you have no knowledge one
way or another. You did not speak with Mrs. Clinton about the
donation?
Ms. Williams. No, I did not.
Mr. Bennett. With respect to followup by Mr. Chung
ultimately, exhibit 259, if I can, exhibit 259 before you is, I
think, Mr. Chung contacting you concerning procuring these
photographs, do you see that, Ms. Williams?
[Exhibit 259 follows:]
[GRAPHIC] [TIFF OMITTED] T5667.031
Ms. Williams. I can't see it but I'm familiar with the----
Mr. Bennett. Mr. Dennis is putting it before you with the
exhibit book as well as the TV screen. Ultimately, these
photographs were sent to Mr. Chung, and just quickly, exhibit
201 is not your direct response to that, but it's the response
of Ms. Carol Khare of the Democratic National Committee, who is
going to testify before this committee later this afternoon,
indicating that photographs were, in fact, forwarded.
Ultimately, Mr. Chung got his pictures with the First Lady to
your knowledge, correct?
[Exhibit 201 follows:]
[GRAPHIC] [TIFF OMITTED] T5667.032
Ms. Williams. Yes, the pictures with the First Lady, I
didn't send them directly, but I'm sure that our office process
worked and he got pictures with the First Lady.
Mr. Bennett. But ultimately there were questions and
problems with respect to the matter of Mr. Chung's photograph
with the President and the individuals he'd taken into the Oval
Office; weren't there?
Ms. Williams. There seems to have been, yes.
Mr. Bennett. What involvement did you have with respect to
those problems as to the picture of Mr. Chung with the
President and his six guests to the Oval Office?
Ms. Williams. I saw his letter at my--one of my
depositions. So I don't remember seeing this letter but I may
have been called by Johnny Chung or Evan Ryan may have told me
there were problems with Mr. Chung receiving his pictures from
the President and was there anything that I could do to help
get his pictures.
Mr. Bennett. Do you know Ms. Nancy Hernreich?
Ms. Williams. Yes, I do.
Mr. Bennett. And who is she?
Ms. Williams. She is the President's Assistant.
Mr. Bennett. And she, in fact, will testify this afternoon,
and also Ms. Kelly Crawford--who is Ms. Crawford? Do you know
Kelly Crawford?
Ms. Williams. Hillary Crawford?
Mr. Bennett. Kelly Crawford.
Ms. Williams. Yes.
Mr. Bennett. And she at one time worked at the White House?
Ms. Williams. Yes, she did.
Mr. Bennett. Did you have any discussions with either of
them about the comments they had with the President concerning
his concern about the photographs?
Ms. Williams. No, not that I recall.
Mr. Bennett. With respect to Ms. Gina Ratliffe, she at one
point in time ultimately worked for Mr. Chung; didn't she?
Ms. Williams. That's correct.
Mr. Bennett. And at the same time she was working for Mr.
Chung she was still volunteering at the White House?
Ms. Williams. No, I don't believe so.
Mr. Bennett. At any point in time did Ms. Ratliffe work
both for Mr. Chung and at the White House, to your knowledge?
Ms. Williams. No, not to my knowledge, no.
Mr. Bennett. Did you arrange for her to get a position with
Mr. Chung?
Ms. Williams. No.
Mr. Bennett. Ultimately she was employed by him?
Ms. Williams. Yes, I understand she had taken a job with
him.
Mr. Bennett. Was that after she was employed by the First
Lady?
Ms. Williams. Well, I don't believe she was ever employed
by the First Lady. She was an intern and then a volunteer.
Mr. Bennett. And did she go from being an intern and a
volunteer, to your knowledge, to an employee of Mr. Chung?
Ms. Williams. Go from being an intern?
Mr. Bennett. Chronologically in terms of what she was
doing.
Ms. Williams. Oh, I do not know if there was a period in
between when she left our office and went to work for Mr. Chung
or if there was no period in between, I just don't know.
Mr. Bennett. But your testimony is that she was never
volunteering at the White House at the same time she was
working and being paid by Mr. Chung?
Ms. Williams. Not to my knowledge, no.
Mr. Bennett. Ms. Williams--and I will wind up with this,
Mr. Chairman--do you have any personal knowledge either
directly speaking with the President or in speaking with other
members of the staff at the White House, of President Clinton's
concerns when he learned of the release of the photographs of
him with Mr. Chung and the delegation from China?
Ms. Williams. I have no personal knowledge.
Mr. Bennett. Did you hear of those concerns at the White
House?
Ms. Williams. I knew that there was some concern about the
pictures, but I don't know where that concern emanated from,
whether it was from the President or someone else.
Mr. Bennett. Mr. Chairman, it is probably appropriate for
me to stop and I will conclude my examination. Thank you very
much.
Just one followup question. Ms. Williams, did Mrs. Clinton
have knowledge--did Mrs. Clinton have knowledge of Ms. Ryan
ultimately going to work for Mr. Chung?
Ms. Williams. Ms. Ryan? I think you mean Ms. Ratliffe.
Mr. Bennett. Excuse me, I misspoke. Did you ever speak with
Mrs. Clinton about Gina Ratliffe going from being an intern on
her staff to going to work with Mr. Chung?
Ms. Williams. No, there would be no reason. She was an
intern, a volunteer.
Mr. Bennett. Do you have any knowledge whether or not Mrs.
Clinton knew that Ms. Ratliffe went from the staff of the First
Lady to go to work for Mr. Chung?
Ms. Williams. No, I have no knowledge if she did.
Mr. Bennett. I have no further questions, Mr. Chairman, and
thank you, Mr. Chairman, for allowing me to exceed my time.
Thank you, Ms. Williams.
Mr. Burton. The gentleman's time has expired. Would the
minority like to have us go vote and come back?
Mr. Waxman. Mr. Chairman, yes, I think it would be
appropriate for us to vote and come back, but I do want to
point out that the issue on the House floor, as soon as the
vote is completed, will be a matter that affects this
committee: the Republican leadership has requested a rules
change to allow this committee to have eight subcommittees,
which is quite unheard of and in our view a real waste of
taxpayers' money. So if the chairman would permit, we ought to
give some of us time to make a statement on the floor before we
reconvene.
Mr. Burton. That would be fine with me. The problem is I
don't want to impose on Ms. Williams' time unduly. Could we
have some of the Members come back and go ahead?
Mr. Waxman. I think it wouldn't last more than 5 or 10
minutes for some of us to make our statements.
Mr. Burton. Why don't we do this. Ms. Williams, would you
like to get a sandwich or something while we are down there
debating another issue?
Ms. Williams. No, but I will be OK.
Mr. Burton. Why don't we plan to return as quickly as
possible. The committee will stand in recess until the fall of
the gavel.
[Recess.]
Mr. Burton. The committee will come to order.
Did you have a chance to get something to eat, Ms.
Williams, or can I call you Maggie?
Ms. Williams. You can call me Maggie.
Mr. Burton. You haven't had lunch?
Ms. Williams. I am waiting until after this to have dinner.
Mr. Burton. You might be very hungry.
Ms. Williams. I'm sure.
Mr. Burton. Mr. Waxman, you are recognized for 30 minutes.
Mr. Waxman. Ms. Williams, I want to thank you for being
here. I think it has been an extraordinary measure of
cooperation for you to come. And as you can tell from my
opening remarks, I think Johnny Chung's experience is a classic
example of why we need campaign finance reform. He gave a lot
of money to the DNC, about $400,000, and he got a lot of access
to the White House, over 50 visits. His story paints a pretty
depressing picture, in my view. It is hard to see how any
member of the public could pay attention to the Johnny Chung
story and not be discouraged about the health of our political
system. To put it simply, his story presents the appearance
that campaign contributions could result in remarkable access
to the White House.
Now, I understand you may have a different interpretation
than I do, and I want to ask you about this. Johnny Chung
visited the White House 50 times. He was allowed to bring his
business associates into the White House on more than one
occasion. He went to several White House Christmas parties. He
had numerous photos taken with the President and the First
Lady. He attended a radio address. He got to eat at the White
House Mess on several occasions. He even got appointed to the
U.S. delegation to a Commerce Department trade forum.
Ms. Williams, how do you explain how someone like Johnny
Chung got this extraordinary access?
Ms. Williams. Congressman, as I said at the beginning of
this hearing, I would talk to you about what it is that I know.
I certainly know how he got a picture with Mrs. Clinton, which
I talked to you about. I certainly know how he got to go into
the White House lunchroom, that he ate on my account. I am
clear about that. I did not know about the trade commission. I
did not know about several other instances.
Mr. Waxman. But about those issues that you do know about.
Ms. Williams. Right.
Mr. Waxman. How is it that this fellow got such good
treatment?
Ms. Williams. Well, I'm going to say two things to you. I
am not naive in terms of treatment of donors, but I will say
another thing to you which I don't think gives the American
people a lot of hope, because one of the things that makes me
exceedingly sad is that people watch these hearings, and they
think that as between the U.S. Congress and the White House
there is not one good soul among us.
And one of the things that I want to say is that there were
a lot of people working at the White House, not only to ensure
that people like Johnny Chung, who was a donor and a supporter
of the Clintons, was able to come in, but that millions of
Americans were able to come in.
And I happen to be in an office in a situation working for
a woman who's graciousness, I think, is probably typified by
the fact that when she was called a horrible name on national
television by the mother of the Speaker of the House, what she
decided to do was to invite her to tea. Now that sounds a
little crazy, a little offbeat, but that was a model of
graciousness that we had in the White House. And what I am
telling you today, although I do know that certain people in
the White House, outside of the White House, pay special
attention to people who give the money, there are also people
in the White House who pay special attention to people just
because they are people. And if we could give more access to
the public to the White House, we would do it.
There are security concerns, for one. But quite frankly, in
the time that I have been at the White House, nearly a million
and a half people go through the doors of the White House. In
addition to the regular tour, there is also a special tour for
people who need something more. Even the Congress has a right
to have constituents that they choose who might be donors, who
might just be friends and families, to have a special tour of
the White House. So we have tried very hard to give access to a
lot of people.
Mr. Waxman. I guess the only point I am making and I don't
dispute what you are saying because I know the First Lady is a
very gracious person and this White House has tried to be as
open as possible. But it's hard for me to believe that ordinary
people would get the kind of treatment that a Johnny Chung got.
We have a campaign finance system where good people in public
office try to think about how much an individual may contribute
or how much they have already contributed when they think about
giving scarce resources--like their time and access--to those
contributors.
I'd like to focus for a moment on Mr. Chung's visits. Was
there a typical visit? What did Mr. Chung do on a typical
visit, if there was one?
Ms. Williams. Well, I wasn't always present when he would
make a typical visit to the White House. And I really don't
know--according to the records, I'm told that he came to the
First Lady's office, was cleared in by the First Lady's office,
which is to say he was outside of the doors and we made
arrangements for him to come in about 20 or 21 times. Somewhere
around that number.
And that the other times that he was cleared into the White
House, he was cleared in by another office, none of which at
the time I knew about, but I did know from the people who
worked at our reception office that he would drop by our
office. And typically what he would do would be to use the
phone, tell people his story of meeting with Mrs. Clinton, and
what it has done for his life, and he would mostly sit and chat
and wait to see if I would come out of the office so he could
talk to me or talk to anyone else. That was his typical visit.
Mr. Waxman. Did he meet with Mrs. Clinton often?
Ms. Williams. Meet with Mrs. Clinton? No, actually I think
he only saw her in receiving lines at these large events. As I
said, the one picture that I know that I arranged for was a
picture. He never in any of his visits asked for a meeting with
Mrs. Clinton, a substantive meeting with Mrs. Clinton. He never
talked to me about policy. He never talked to me about his
business concerns, so I did not have a sense that what he was
doing in our office was business. And, in fact, there were only
two occasions that I can remember him ever being with other
people when I saw him.
One, he had a group of people and he introduced them to me.
They did not speak English, and they all bowed to me, and I
bowed back to them. And so that particular group of people
stands out in my mind.
On another occasion, I believe that he brought two or three
people who worked for him. Other than that, I have no knowledge
of who else he brought into the White House.
Mr. Waxman. To your knowledge, did he ever comment,
advocating any official business, advocating a position, policy
position or asking for any official business with the White
House?
Ms. Williams. Never--not to my knowledge, no.
Mr. Waxman. Now, in March 1995, Mr. Chung met with you and
in the First Lady's office and gave you a $50,000 check for the
DNC. The key question here is whether you solicited this
contribution. Did you?
Ms. Williams. No, I did not, as I said in my testimony, on
many occasions he had asked to give money to Mrs. Clinton
personally. He wanted to help her personally, he would say. I
want to give to her personally, and I said you should give to
the DNC or give to the campaign or any of the other entities
that were available.
Mr. Waxman. Did you or anyone in your office ever solicit
any contribution from him, ask him to give a dollar amount?
Ms. Williams. No, not to my knowledge, not at all.
Mr. Waxman. What happened when Mr. Chung tried to give you
this check?
Ms. Williams. Well, it was only, as I recall, the whole
incident--incident, a few minutes, if not a few seconds. I
remember him being much more excited than normal and that, in
fact, he had in his hand something and kept saying, ``You take;
you take.'' And I was saying, Johnny, you can't give, once
again as I recall, you can't give anything to Mrs. Clinton
because he said, ``You take, you take, it's DNC. I give to the
DNC through you. I give.'' And he was--once again, not unkind
and not rude, but certainly in my face a little bit.
Mr. Waxman. So he insisted on giving it. Was it an envelope
or a check?
Ms. Williams. I really don't recall. I mean----
Mr. Waxman. Did you know how much money the check was for?
Ms. Williams. No, I didn't even--I mean, the thing that is
most memorable about that event for me is not even the check
itself, it's kind of his behavior at that time.
Mr. Waxman. After he gave you the check what did you do
with it?
Ms. Williams. I believe I threw it in my outbox.
Mr. Waxman. And then what happened?
Ms. Williams. Well, other checks come through the mail to
the First Lady's office. And generally, if I get them, I put
them in my outbox where a volunteer or my assistant will direct
them to the appropriate entity.
Mr. Waxman. So it was then put in your outbox to mail to
the DNC.
Ms. Williams. Yeah, to send it wherever it belongs.
Mr. Waxman. Mr. Bennett has already mentioned a February
27, 1995, letter that Mr. Chung wrote to Richard Sullivan of
the DNC. The document is Bates Stamped DNC 3233326. I think you
have that letter.
Mr. Dennis. What is the exhibit number, Congressman Waxman?
Mr. Waxman. Exhibit 171.
Ms. Williams. The letter to Richard Sullivan?
Mr. Waxman. Yes, this letter describes Mr. Chung's plans
for bringing a Chinese delegation to Washington. Did Mr. Chung
also write to you about this visit?
Ms. Williams. No, he did not.
Mr. Waxman. Did you have any knowledge about his agenda,
which included meetings with the President, tours of the White
House, before he met with him in March?
Ms. Williams. No.
Mr. Waxman. I want to turn to another issue that has
received a lot of attention. Mr. Chung and his delegation
attended one of the President's radio addresses during the
March visit. Are the invitations for these broadcasts
coordinated by one person in the President's office?
Ms. Williams. I really couldn't tell you if they were
coordinated by one person.
Mr. Waxman. OK. Did you assist Mr. Chung in any way in
obtaining an invitation to that March 11, 1995, radio address
and did you instruct anyone on your staff to do so?
Ms. Williams. No, it's not my recollection I helped him
with the picture and----
Mr. Waxman. The picture is afterwards?
Ms. Williams. No, I helped him with a picture for Mrs.
Clinton, and----
Mr. Waxman. But not on the radio?
Ms. Williams. No not on the radio.
Mr. Waxman. In this context, did you mention to anyone in
the President's office or the DNC that Mr. Chung had made a
contribution to the DNC?
Ms. Williams. No, I did not.
Mr. Waxman. Did you do anything, no matter how
insignificant, to help with this matter?
Ms. Williams. No, not that I recall, nothing.
Mr. Waxman. Let me ask you a more general question. Did you
ever help anyone else obtain an invitation to the President's
radio address?
Ms. Williams. One, person, yes.
Mr. Waxman. And who was that?
Ms. Williams. A person by the name of Ceandra Scott who was
an assistant to the chairman of the DNC. Her parents--I don't
remember if it was her parents or her grandparents were in town
and she really wanted them to go to the radio address.
Mr. Waxman. I want to make sure I understand your testimony
on two key points. First, you never solicited a contribution
from Mr. Chung, and two, you had no role in assisting with his
attendance at the President's radio address; is that correct?
Ms. Williams. That's correct.
Mr. Waxman. Mr. Chairman, what confuses me about today's
hearing is that Ms. Williams had to travel all the way from
Europe to be here today. She was already deposed by us for over
10 hours; by the Senate for 8 hours. By the end of the day
today it will be a long full day, and on the key points she has
testified repeatedly under oath that she didn't solicit Mr.
Chung's contribution.
If she didn't solicit the contribution, there is no
illegality. Then the question becomes, I suppose, whether Mr.
Chung's access creates an appearance of impropriety. That is a
much larger issue that really goes to the heart of our campaign
finance system, and it seems to me that if we were going to
focus on that, we should be at least willing to look at some of
the big fish.
Ms. Williams, are you familiar with a man by the name of
Duane Andreas of the Archer Daniels Midland Co.?
Ms. Williams. I've certainly heard his name.
Mr. Waxman. I ask because I find it odd that we are holding
a hearing on money and access without any mention of Mr.
Andreas and his company. Here is an individual whose generosity
to both parties, Republicans and Democrats, is legendary. As
you may know, he was a supporter of President Clinton, but he
was also a contributor to Senator Dole.
In fact, I have a series of photos starting with Mr.
Andreas and President Truman. Then we have Mr. Andreas with
President Kennedy and we also have Mr. Andreas with President
Reagan and that photo is now being shown.
Mr. Andreas and his company gave over $450,000 to Senator
Dole; $70,000 to Speaker Gingrich and his PAC and $100,000 to
the DNC at one fund-raiser alone. He's given to almost every
major Presidential candidate since Richard Nixon. At the same
time, his company has received billions of dollars in Federal
subsidies through the Ethanol Subsidy Program, and tens of
millions of dollars in government contracts.
Now, in the case of Mr. Chung, it doesn't seem that he was
interested in any Federal subsidies or policies; is that right
as far as you know, Ms. Williams?
[The photographs referred to follow:]
[GRAPHIC] [TIFF OMITTED] T5667.033
[GRAPHIC] [TIFF OMITTED] T5667.034
Ms. Williams. To my knowledge, he never discussed it with
me.
Mr. Waxman. And as far as we know he was never awarded a
Government contract; is that right?
Ms. Williams. To my knowledge.
Mr. Waxman. Mr. Chairman, since we are going to spend our
time looking at access and contributions, I believe ADM
deserves at least as much attention as we are giving to Johnny
Chung. And there are a lot of others, too. And if we are going
to get into this issue, let's get into this issue, because it
goes to the very heart of our campaign finance system: the
access that people get to Democrats and Republicans,
Presidential candidates and congressional candidates; the kinds
of quid pro quos that they get, if not in the precise term of a
bribe, nevertheless one that the American people look at as
corrupting. I think that's what our campaign finance system
does. It corrupts. It makes people think about the money. And
then think about what they can do to those who can give the
money.
We still have time left, and I want to yield at this time
10 minutes to my colleague from California, Mr. Lantos.
Mr. Lantos. I thank the gentleman for yielding. I want to
welcome Ms. Williams. You have been a very distinguished public
servant. You have a record in the private sector of devoting
your life to children's issues and I want to welcome you to our
committee.
I want to apologize to you for having been dragged back
here from Paris and I want to ask you if you have any idea what
your legal costs have been thus far? Give us just a ballpark
figure.
Ms. Williams. Not including today, $350,000.
Mr. Lantos. Well, I suspect that's a pretty awesome amount
to most of us in this room, and this all in this game which I
have labeled ``Trivial Pursuit,'' so today we are engaged in, I
don't know what chapter of this drama.
I want to spend a few minutes on Mr. Chung as a political
hustler of a very bipartisan character. A great deal of
attention was paid early on to a picture he had with the First
Lady. I would like to draw attention to various other pictures
that feature Mr. Chung.
Let's first look at the one with Mr. Chung and the Speaker
of the House, Newt Gingrich. They seem to be engaged in a
rather serious and substantive dialog. I cannot tell the topic
by just looking at the picture, but I don't think they are
sharing jokes or engaging in trivial discussions. Both of them
look very serious.
Now, when we move over to Mr. Chung and the former
Republican Presidential candidate--well, we are now looking at
Mr. Chung and Mr. Gingrich. If we could take now Mr. Chung and
Senator Dole. Mr. Chung and Senator Dole have a more sort of
cordial appearance. They may have been discussing athletic
events or perhaps the meal that they may or may not have
shared.
In any event there is a degree of physical proximity
between the two of them which indicates a modicum of intimacy.
Now, if we may move on to a lady who recently was in the
news again because she, again, won the gubernatorial contest in
New Jersey, Governor Christine Whitman. She seems delighted to
be meeting Johnny Chung, and Johnny Chung is equally pleased in
meeting her.
She, of course, is not the only distinguished Republican
Governor that Johnny Chung seems to be cordial with. If we look
at the State of Virginia, we find Governor George Allen
literally beaming at the chance of spending a few leisurely,
relaxed and I suspect warm moments with Mr. Chung.
Mr. Chung, it seems, was not partial to the East Coast, so
let me take you to the heart of the country with Governor Jim
Edgar of Illinois who is smiling and pleased. In this case it's
Mr. Chung who seems to be overly elated at the opportunity of
getting together.
And since I think, in all fairness, the Pacific Coast
should not be discriminated against. Let me take you to the
State I have the privilege of representing, the State of
California, where former Republican Presidential candidate and
our current Governor, Pete Wilson, is serious, but very
positive in his exchange with Mr. Chung.
These pictures, of course, could be concocted, this series
of pictures, ad nauseam and ad infinitum because if you are a
resourceful and aggressive political hustler, as obviously this
gentleman is, then sooner or later you get a picture with
somebody.
[The photographs referred to follow:]
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Mr. Lantos. I would like to read a letter which in terms of
warmth and intimacy dramatically exceeds the letter Mrs.
Clinton wrote Mr. Chung. This was written by the Governor of
the State of California, Pete Wilson, and this is what it says:
``Dear Mr. Chung: It is my understanding that you have been
nominated as Entrepreneur of the Year,'' a title surely
deserved. ``Congratulations! It is a well-deserved recognition.
``My Communications and Press officers inform me that you
and your team have performed in an outstanding manner. Your
good work, in turn, has enabled my office to serve the people
of California effectively and efficiently.''
Now, I don't quite understand this, so let me read it
again, because I have difficulty seeing how Mr. Chung's
entrepreneurial excellence had an impact on the gubernatorial
office in California, but there may be things here I don't know
about. So let me read Governor Pete Wilson's sentence again.
He's talking to Mr. Chung and says: ``Your good work in turn
has enabled my office to serve the people of California
effectively and efficiently, especially during California's
recent disasters.''
[The letter referred to follows:]
[GRAPHIC] [TIFF OMITTED] T5667.042
Mr. Lantos. If you read this carefully, it seems that all
this tremendous Statewide effort in California during the
various tragedies that befell the State a few years ago, and
were handled so effectively, may have been the result of the
entrepreneurial brilliance of Johnny Chung. To conclude Pete
Wilson's letter, ``Again, you have my appreciation for a job
well done!''
Now, I suspect that what we are dealing with, as the
distinguished ranking member pointed out, is the seamy side and
the occasionally hilarious side of the political fund-raising
system that we on this side of the aisle are anxious and eager
to reform and correct. But since we need to look at more than
episodic evidence, let me indicate, still sticking to the
question of photo opportunities, the kinds of photo
opportunities that the Republican National Committee has
offered its generous contributors.
Photo opportunities: The 1997 Republican National Committee
annual gala offered those who raised $250,000 a photo
opportunity with Senate Majority Leader Trent Lott and Speaker
of the House Newt Gingrich on May 13, 1997. In 1995, the
Republican Senate/House dinner invitation offered those who
donated or raised $100,000, a quote, ``a photo opportunity with
Senate Majority Leader Bob Dole, House Majority Leader Dick
Armey and Speaker of the House Newt Gingrich.'' A 1992
President's dinner, this involved President Bush, promised
those who raised $92,000, you get the cute connection. It's
1992, oh, you have to give $92,000, $92,000 you get a photo
opportunity with President Bush.
Season ticket holders, now if you thought that season
ticket holders is a sports expression, it isn't. Season ticket
holders are people in the Republican National Committee's
lexicon. They are contributors who gave $250,000 a year. They
were invited to attend private receptions with Presidential
candidates, private meetings with congressional committee
chairmen, lunch with Newt Gingrich and Bob Dole, breakfast with
the Republican Presidential nominee at the Republican National
Convention. Season ticket holders also are promised a GOP staff
person on call to answer questions and provide assistance.
If you are not a season ticket holder, but a lower level
contributor, $175,000 over a 4-year period, you're invited to
attend a retreat with Presidential candidates, participate in
international business missions, and national and regional
meetings with key Republican leaders.
Now, if you are just an Eagle, an Eagle is a person who
gives $15,000 a year, you are invited to attend a White House
dinner, meeting in Washington with party leaders and an
international business mission and so on.
Now, I find Johnny Chung's activities nauseating and
revolting and very likely illegal. And I hope that the full
weight of the law will be brought to bear on any activities on
his part or on anybody else's part where we are dealing with
violations of law.
But the fact that in the process of his hustling, during
the course of which he got hold of the Speaker of the House of
Representatives in an intimate setting, the Republican
Presidential candidate, former Senator Dole, a man for whom I
have very high regard, in a close setting, these fine
Republican Governors covering the national landscape from
California to New Jersey, from Virginia to Illinois, do not
make it so unique that in his reckless and mindless pursuit of
political leaders, he also was interested in meeting with some
people in the White House.
I find the performance unattractive, unacceptable,
nauseating, but totally bipartisan. And the hypocritical
attempt on the part of some on the other side to portray Mr.
Johnny Chung as perpetrating these photo outrages with
Democrats only, the facts simply will not bear out. I yield
back the time to the ranking member.
Mr. Waxman. Thank you for yielding back to me, Mr.
Kanjorski. Do you want to ask questions of Ms. Williams?
Mr. Kanjorski. Thank you very much, Mr. Chairman.
Mr. Waxman. Mr. Kanjorski, it looks like I'm not yielding
you any time. Why don't we wait until the next round. We yield
back the balance of our time.
Let me ask a question. You said that Mr. Chung would tell
you how his meeting with Mrs. Clinton had changed his life. Did
he ever tell you about his meetings with these Republican
Governors and whether that changed his life as well?
Ms. Williams. No, he did not.
Mr. Waxman. I yield back the balance of my time.
Mr. Burton. The gentleman yields back. Mrs. Morella.
Mrs. Morella. Thank you, Mr. Chairman. Ms. Williams, you
didn't see this as any part of your job description, did you? I
just wanted to indicate my appreciation for your being here and
your willingness to answer questions. I've always valued
working with you in small ways in the past.
Ms. Williams. Thank you.
Mrs. Morella. There are a couple of questions I have
because they mystify me and perhaps you can shed some light on
this. I have been looking at the papers I have here before me,
and there is one here that is exhibit 255--155? 155, maybe we
could put it on the screen. At any rate, it is a memorandum to
you, Ms. Williams, from Gary Walters, and it's bills for
collection. In that memorandum which you received from Gary
Walters, at the bottom it indicates, remaining to be paid by
the DNC for fiscal year 1994, $135,345.25.
[Note.--Exhibit 255 can be found on pp. 43 to 46.]
Mrs. Morella. Now, in the Tom Brokaw tape, Mr. Chung
specifically said that he was solicited by Evan Ryan to make a
contribution to cover that particular debt. Do you know
anything about that?
Ms. Williams. No, I do not.
Mrs. Morella. The thing that puzzles me is that how do you
fathom that he knew about this debt for holiday events if
somebody didn't tell him? And who do you think might have told
him? Where do you think the information might have come from?
Ms. Williams. Congresswoman, as I have been asked that
question earlier, and my first reaction would be not to
speculate where Mr. Chung had heard that. I will say to you
that this document, or the fact that the DNC, along with other
organizations, had not paid debts to the White House for events
held there was really not a state secret. People at the DNC
knew this, people in my office knew this. I could simply say to
you that this was not a well kept or hidden state of issues.
But I do not know from whom, if in fact he got the information,
whom he got it from.
Mrs. Morella. You can understand why it would be puzzling
because it says specific in terms of the breakdown with regard
to the events that had been held. So somebody got the word out.
You don't know who did? And you say it may have been very well-
known.
Ms. Williams. I think that it was--I think that it was
generally known, because at the DNC and also at the White
House, that there were bills that organizations had not paid,
including the DNC, yes.
Mrs. Morella. Incidentally, that is exhibit 255; right.
I had another question in looking over some of the
photographs and the letters and this has to do with the fact
that evidently Mr. Chung must have been using these photographs
and letters for his own business benefits. One witness that was
interviewed by the committee said that Mr. Chung convinced him
to invest over $900,000 in his company, AISI, and he said he
was finally forced to sue Mr. Chung when he discovered that
AISI was not capable of even providing the services that Mr.
Chung said that it could.
And I just wondered, were you aware that Mr. Chung was
utilizing these letters, photographs, for his personal
aggrandizement for his business, it was fraud?
Ms. Williams. No, I had no idea.
Mrs. Morella. It seems as though at some point there was a
cease and desist that was sent from the White House, and so
evidently somebody caught on to the fact that this was
inappropriately used. Are you aware of that?
Ms. Williams. No, I'm not--no, I'm not specifically aware
of that.
Mrs. Morella. I have another kind of question, and that has
to do with the young intern, Gina Ratliffe.
Ms. Williams. Uh-huh.
Mrs. Morella. And trying to follow the line of her
involvement as an intern in the First Lady's office. In her
deposition, Ms. Ratliffe said that she started to work as a
volunteer in the First Lady's office after she returned from
her trip to China with Johnny Chung. And I just wondered, did
you know that when she was volunteering in the First Lady's
office that she was employed by Mr. Chung?
Ms. Williams. No, I have to tell you, I really didn't focus
very much on the comings and goings of the interns and the
volunteers.
Mrs. Morella. If you had known, what kind of advice would
you have given her?
Ms. Williams. With respect to?
Mrs. Morella. Whether she should sever her internship or
sever her work with Mr. Chung. I mean----
Ms. Williams. I guess, Congresswoman, I'm not quite clear.
She was working----
Mrs. Morella. She was employed by Mr. Chung while she was
working at the White House as an intern. I just wondered, had
you known that this was going on, would you have said to her, I
really don't think you should be here or you shouldn't be
working for Mr. Chung? I mean, I probably would have said
something to a young woman who was an intern had I found out?
Ms. Williams. Well, it's very hard for me to speculate or
give advice in retrospect. I prefer not to do that because
there are quite a few things that I have recently learned with
respect to Mr. Chung through news media accounts and since we
haven't heard from him, I'm reticent to simply receive those as
given until we do. We have--so, I mean, I don't know what
specific advice I would give to her about not volunteering in
the First Lady's office because she was working with Mr. Chung.
I just don't quite know what advice that would be.
Mrs. Morella. OK.
Mr. Burton. The gentlewoman's time has expired.
Mrs. Morella. Yes, I thank you, Mr. Chairman. I thank you,
Ms. Williams. These are just riddles within enigmas that were
cryptic. Thank you.
Mr. Burton. Mr. Kanjorski.
Mr. Kanjorski. Thank you very much, Mr. Chairman. Ms.
Williams, what was the policy of the Clinton administration in
regard to increasing access to the White House?
Ms. Williams. Well, I certainly know that both the
President and the First Lady were always looking for
opportunities to increase the number of people who got to come
to the White House. In fact it was--it is during the term of
Mrs. Clinton's time as First Lady that she started talking
about the White House as the people's house and asked that
several things be worked on and done, including having special
days like the veterans of foreign affairs days where veterans
could come into the White House, special day for scouts and
girl guides. The idea was to get as many people into the White
House as possible.
Mr. Kanjorski. Isn't it true that you had a policy there to
encourage average Americans to come down and volunteer: opening
up Christmas cards to the President, answering letters to the
President and the First Lady?
Ms. Williams. Oh, the White House could not survive without
the help of its volunteers and we certainly encouraged people
to do that. Young people and quite a few older people.
Mr. Kanjorski. I remember particularly being down in the
Executive Office Building myself when two busloads of senior
citizens from Carbon County, PA, were just tickled pink to have
an opportunity to be invited into the White House to volunteer
their time to open up Christmas cards and letters to the
President. And that wasn't particular to Carbon County, PA, was
it?
Ms. Williams. No, in fact a number of things we have done.
We have tried to, at Christmas to go out and get people from
the States to come in and participate at Christmas, whether it
be their choirs or in-house decorating. Yes, there has been a
real special effort made that, you know, I'm extremely proud of
in trying to get people into the White House to see it, because
it's incredible to be there.
Mr. Kanjorski. Ms. Williams, I go home to my district every
weekend and I talk to constituents. When they describe their
opportunity to visit the White House, they light up and just
the essence of being close to the President and the First Lady,
even if they never see them. And isn't it true, 95 percent of
the people that pass through the White House or come there
never really get an opportunity to see the President, but just
the association that the President is there and their
particular President is there gives them great enthusiasm?
Ms. Williams. Oh, certainly. And I would say that while
you're probably right that 95 percent of them never see the
President or First Lady, Mrs. Clinton has made it a habit from
time to time to actually walk through the visitors' lines and
to see people who would not ordinarily have a chance to see
her. So, yes, access has been important to us.
Mr. Kanjorski. And although a million and a half people a
year do come to the White House, even if you calculated that
over the 5 years of this Presidency, that's about 7.5 million.
That would leave about 262.5 million people in the United
States that in the last 5 years didn't get an opportunity to go
to the White House, isn't that right?
Ms. Williams. That is true, but soon the White House will
be available on CD-ROM.
Mr. Kanjorski. But what I wanted to point out when we say
the White House, it is really the White House compound we are
talking about.
Ms. Williams. Oh, yes.
Mr. Kanjorski. And most people don't realize that what they
see as the White House is a very small portion of the
President's office and residence of the White House. But
alongside and off on the West side of the White House is the
Old Executive Office Building that sort of looks like a French
architecture--well, I've never been too fond of it myself. It
lacks air conditioning, seems to be inefficient and was
probably planned by some frustrated architect. But anyway, that
is where most of the operations of the White House occur, in
that Old Executive Office Building; isn't that correct?
Ms. Williams. Yes, in fact that's where the First Lady's
staff is situated in the Old Executive Office Building.
Mr. Kanjorski. That's where your office was. Isn't it true
that the First Lady was also occupying a working office in or
near the West Wing?
Ms. Williams. That's true. In the West Wing in fact.
Mr. Kanjorski. So if I dropped by your office, if I were
informed at all, I would have to know that the likelihood is
that the First Lady would be there on very, very few occasions,
but that was a working office.
Ms. Williams. That's correct.
Mr. Kanjorski. So Johnny Chung taking this opportunity to
come by your office would have to be either naive or he wasn't
coming there with the anticipation of seeing the First Lady
because she is hardly ever there; is that correct?
Ms. Williams. Rarely is she there, and he never asked to
see her.
Mr. Kanjorski. The only other thing I would to straighten
out, I have heard a lot of postulation on the other side here
about dastardly campaign contributions. Now I'm going to be a
bit of a confessor, I don't think there is a member on this
committee, in the House of Representatives, or in the U.S.
Senate who hasn't been discombobulated or embarrassed when a
supporter, friend, or associate of theirs either walks into
their official office or sees them at a function and wants to
press their hand and hand them an envelope, and usually with a
political contribution involved. And so often in my career,
because of the FEC regulations, the contribution is in cash and
you have to end up going to your lawyer, sending letters and
trying to straighten out the whole problem, but it is always
the case that you mentioned in your testimony. How do you treat
these people? Do you turn on them and suggest that they are
being criminal? Do you ratchet the envelope back in their hands
and say don't ever come here again? But it is really a sort of
sensitivity that you address this and you try and handle it in
a modulated way, not to offend them, and in the other way
comport with the regulations and the laws regarding campaign
contributions.
Is that what you describe in your testimony today when you
were faced with this suddenness and the rush of Mr. Chung
wanting to personally pass that envelope to you and knowing
full well that it would take an awful lot of time to explain to
him the convoluted rules and regulations of campaign financing
and conduits and everything else, but instead you just took it,
passed it on unopened, unseen and really had little
significance, but it did embarrass you; is that correct?
Ms. Williams. Slightly, Congressman. Embarrassed myself and
embarrassed for him.
Mr. Burton. The gentleman's time has expired.
I'd like to, before I yield to my colleague, Mr. Cox, I'd
like to take a couple of minutes. I have not yet had 5 minutes,
so I think it's important to maybe explain a little bit of why
we are here.
Mr. Lantos pointed out a number of public officials who
have appeared with Mr. Chung. And we agree that that took
place. But one of the major functions and focuses of our
investigation is the illegal foreign contributions that came
into the United States.
Mr. Lantos. The light is not on.
Mr. Burton. Would you turn the light on for me, please,
thank you.
One of the main focuses of the investigation is to find out
if illegal foreign contributions were coming into the United
States through conduits into the American political process,
whether it's Republican or Democrat. Now, we know that on March
6, 1995--and Ms. Williams, according to her testimony, has no
knowledge of this, so we are not making any kind of allegation
about that. But there was $150,000 that came from the Bank of
China in Beijing, China, on March 6th, to Johnny Chung at the
CalFed Bank. $150,000 came from the Bank of China in Beijing on
March 6th. Now, we know that 3 days later on March 9th, he gave
a check to Ms. Williams for $50,000.
Now, at the time he got the $150,000 from the Bank of China
in Beijing, he had a negative bank account. He didn't have any
money. So it's logical to assume that the $150,000 he got from
the Bank of Beijing--Bank of China in Beijing, China was money
that he gave to Ms. Williams which ultimately found its way to
the DNC. That doesn't mean that Ms. Williams did anything
wrong. But the fact is she was a recipient, probably, of
illegal foreign contributions.
Now, the reason I bring that up, and then there were
$70,000 that was subsequently deposited to the Johnny Chung
general bank account on March 4th. But the fact of the matter
is there is a very strong possibility, and you can see the
chart on the monitor, that foreign money was laundered and was
given to the DNC.
[Exhibit C-82 follows:]
[GRAPHIC] [TIFF OMITTED] T5667.043
Mr. Burton. That's what we are all about. We are trying to
find out about illegal foreign contributions that found its way
into the Democrat National Committee and, if it occurred, into
the Republican National Committee. That's what this is all
about.
These pictures of the people that Johnny Chung met, he may
have met me for all I know. These pictures don't really mean a
lot, other than they show that he was a person who had the
ability to have access to a number of people. But what we are
really all about here, at least what I would like us to be
about, is the laundering of foreign money into the election
process in this country, and whether or not Mr. Chung or
anybody else tried to get some concessions in the area of
foreign policy or business concessions or anything else in
exchange for that money and whether or not foreign governments
or foreign entities were getting the benefits of these
contributions in the form of concessions to a country or to a
foreign business. That's what we are all about, and that's why
I wanted to take my time to respond.
With that, I apologize, I will yield the remainder of my
time he would like, to Mr. Cox, and then he can have his own
time in the next go-round.
Mr. Cox. I thank the chairman. I will just use the balance
of the chairman's time and take my own time later to pursue the
chairman's line of questioning.
The thank you note that was sent from the DNC to Johnny
Chung on July 24, 1995, that came from Don Fowler said to
Johnny Chung, I enjoyed meeting with your friend, who is the
wife of the Chief of Staff of the Chinese People's Liberation
Army. The people that came into the White House with Johnny
Chung were all, for the most part, communist Chinese officials.
The China Petrochemical Corp., COSCO, CITIC, the firm headed by
the arms dealer Wang Jun, who himself was at a White House
coffee. CITIC, of course is directly controlled by the State
Council, the People's Republic of China. Did you talk to the
National Security Council about this group's visit into the
White House at any time before the visit took place?
Ms. Williams. No, I actually--if Mr. Chung--once Mr.
Chung--once it was agreed that Mr. Chung, could, one, have a
photo with Mrs. Clinton or go to the Mess, it was simply a
matter of clearing in whoever he was bringing with him. I was--
--
Mr. Cox. Was this your decision?
Ms. Williams. Pardon?
Mr. Cox. Was this your decision?
Ms. Williams. No, it was pretty much----
Mr. Cox. Who made the decision to let the people come in?
Ms. Williams. The White House security people. What
typically happens is if Mr. Chung was going to come and take a
picture--and I'm not even sure at that point in time that I
knew that Mr. Chung was bringing in a group of people to have a
picture taken with Mrs. Clinton. I was OKing a picture----
Mr. Cox. But I have a document here, exhibit 187, which is
a name list of the delegation which was in your possession
prior to the radio address.
[Exhibit 187 follows:]
[GRAPHIC] [TIFF OMITTED] T5667.044
Ms. Williams. It was in my possession----
Mr. Cox. Had you ever seen exhibit 187 prior to the radio
visit? Because this is a document that was prepared by the
White House and it lists the names and titles of the PRC people
who were coming in.
Ms. Williams. No, this was not, never in my possession.
Mr. Cox. When did you first see this document?
Ms. Williams. During the deposition.
Mr. Cox. Can you tell from this document who prepared it?
Ms. Williams. No.
Mr. Cox. I wonder if I could inquire of counsel, do we know
who prepared this document, exhibit 187, which says Name List
of Delegation? It is my understanding this is a White House
document.
Mr. Bennett. Congressman, I believe the testimony this
afternoon will indicate the document was initially prepared by
Mr. Chung, and there is handwriting of witnesses who will be
called this afternoon who made notations on this document,
White House personnel.
Mr. Cox. Is it committee staff's understanding that this
document was circulated inside the White House prior to the----
Mr. Bennett. It is our understanding that that is the
handwriting of Ms. Nancy Hernreich of the White House.
Mr. Burton. Mr. Cox, my time has expired.
Mr. Cox. I appreciate the gentleman, I will return to this
later. Thank you.
Mr. Burton. Mr. Barrett.
Mr. Barrett. Thank you, Mr. Chairman. I am curious, first
of all, as to whether we will be holding hearings, as I sit
here next to the Republican wall of shame, into how he got
access to these individuals. Do you plan on holding any
hearings on that?
Mr. Burton. If there's any indication that illegal foreign
money came into the RNC, of course we'll look into that.
Mr. Barrett. Have you attempted at all to discern that?
Mr. Burton. Well, there has to be some indication that
there was wrongdoing before we start an investigation. If you
have some evidence, I most certainly will do that. We have
evidence in this case. We have $50,000 that we are sure, or
almost certain, came from the Bank of China in Beijing.
Mr. Barrett. Reclaiming my time, Mr. Chairman.
Mr. Burton. I will give you more time.
Mr. Barrett. Mr. Chairman, it is my time. If you want to
take my time away from me, but it is my time.
Mr. Burton. We will investigate.
Mr. Barrett. It is wonderful to put the innuendo on the
table that the fact is that the money came from the Bank of
China, but that doesn't mean that it is necessarily Chinese
Government money. But that is what these hearings are. They are
innuendo after innuendo, and it is a travesty that we are
looking at this, but we are not spending a second on the Triad
Management Group. We're not going to look on that and there are
allegations on that, Mr. Chairman. There are real allegations
on that, and this committee would not for a second dare spend
any time examining allegations against Republicans. And that's
why this is such a total travesty. There is no attempt here for
fairness. There is no attempt here to balance these hearings.
This is nothing more than going after the President of the
United States. That is clearly what this is, and I think that
everybody should recognize that.
Ms. Williams, I thank you for being here. I'm sorry that
you had to come back. You obviously have spent a lot of time
and a lot of money to defend yourself. I frankly don't think
that this committee cares about that at all. I think they would
be more than happy to have you go into bankruptcy because you
committed a mortal sin, Ms. Williams. You worked in a
Democratic White House. That was your sin, and if this is going
to ruin your life, it's going to ruin your life. And that's the
way this committee works and we should all be well aware of
that.
I'd like to ask you a couple of questions if I could,
please, about your role with Mr. Chung. Before the March 1995
events, Mr. Chung had told you on other visits that he wanted
to give to the First Lady, hadn't he?
Ms. Williams. Yes, that's correct.
Mr. Barrett. And what did you tell him?
Ms. Williams. I told him that he could not give personally
to Mrs. Clinton. He could do not that.
Mr. Barrett. And you always told him that, didn't you?
Ms. Williams. Yes, I told him that would be inappropriate,
that we could not do that.
Mr. Barrett. And you told him that if he wanted to
contribute money, he could give to entities such as the DNC and
the campaign; is that correct?
Ms. Williams. That's correct.
Mr. Barrett. Did you ever suggest to him that if he gave
money to the DNC, he would help pay off DNC debts to the First
Lady relating to White House Christmas parties?
Ms. Williams. No, I did not.
Mr. Barrett. Did you ever say to Ms. Ryan that if Mr. Chung
asks her how he could help the First Lady, Ms. Ryan should
suggest helping the DNC pay off its debts concerning the
Christmas parties?
Ms. Williams. No, I have no recollection of that.
Mr. Barrett. You simply passed the check on to DNC when you
received it?
Ms. Williams. Right. That's correct.
Mr. Barrett. And that was your normal practice? That had
happened in other incidences?
Ms. Williams. With checks, yes.
Mr. Barrett. Was the incident in which Chung handed you a
check the first time anyone had handed you a political
contribution check in the White House?
Ms. Williams. Yes, it is.
Mr. Barrett. Since this incident, no one came to the office
of First Lady to give you a political contribution check?
Ms. Williams. No.
Mr. Barrett. Let me ask you this, then. This fellow, again,
from these pictures right here, I would put in the category of
a political groupie. Would you say that is an accurate
description of him?
Ms. Williams. I don't like to call names.
Mr. Barrett. I'm not saying that that is a derogatory name.
He obviously likes to be around politicians.
Ms. Williams. Well, he likes to be around politicians.
Mr. Barrett. Maybe that is the negative. I don't
necessarily mean groupie as a negative word. Was he involved in
high level policy discussions?
Ms. Williams. Not to my knowledge.
Mr. Barrett. He was just someone who liked to be around the
First Lady.
Ms. Williams. He liked to be around the office, yes.
Mr. Barrett. Just like he apparently liked to be around
Governor George Allen, a Republican from Virginia; he liked to
be around Governor Christine Whitman, a Republican from New
Jersey; he liked to be around majority leader, Senator Bob
Dole, a Republican from Kansas; he liked to be around Speaker
Newt Gingrich, a Republican from Georgia; he liked to be around
Governor Jim Edgar, a Republican of Illinois; Governor Pete
Wilson, a Republican of California, and apparently the entire
Governor's office is something he liked to be around. So he is
a man who liked to be around power. Would you say that is
pretty accurate?
Ms. Williams. I would say that would be correct.
Mr. Barrett. And how did you treat him differently from
other people?
Ms. Williams. No differently. I tried to accommodate his
requests. If I could do something for him, I would. If I could
do something for you, I would.
Mr. Barrett. And so you treated him and his political
contribution just like any other one; is that correct?
Ms. Williams. Just like anybody else, not necessarily even
a contributor, but, yeah, I thought I treated him fairly, and I
treated him well, and I was gracious to him, and I went out of
my way to accommodate his requests, and I felt that that was a
job that we were supposed to be doing in our office for
everybody.
Mr. Barrett. OK, thank you. Again, I thank you for your
comments. And I think that Mr. Waxman did a wonderful job in
his opening statement, because the problem here is, yes, there
was too much access to the Democratic White House. There is too
much access to Democratic Members of Congress and there is too
much access to Republican Members of Congress. People who have
money in this society have more influence on Government than
people who don't have money. That's what the problem is, and
that's why this hearing is a sham because it doesn't really
care about that. All it cares about is trying to make the
President look as bad as it possibly can, and I yield back the
balance of my time.
Mr. Burton. The gentleman's time has expired. The gentleman
from California, Mr. Cox.
Mr. Cox. I thank the chairman.
Mr. Burton. Would you yield to me for 30 seconds?
Mr. Cox. Pleased to yield to the chairman.
Mr. Burton. Let me just correct one thing that my colleague
has just said. First of all, we are investigating allegations
of illegal foreign contributions coming in to the Republican
party and the National Policy Forum. We've had two people in
California, detailees and others, talking about Mr. Ted Sioeng,
who gave money to the National Policy Forum as well as the
Democrat National Committee. We have subpoenaed and are
receiving information on the Young brothers, who had a shell
corporation in Miami that gave money to the Republican National
Committee. We are looking at both sides.
I understand the reason to try to make it look like we are
being totally biased. The fact of the matter is we are not. We
are looking at foreign contributions, illegal foreign
contributions that may have bought influence in this country in
the political process. That's what it's all about.
Mr. Barrett. Would the gentleman yield?
Mr. Burton. I do not have the time.
Mr. Barrett. What about the Triad Management? Are we
looking at that, Mr. Chairman?
Mr. Burton. If the gentleman would yield another 10
seconds, I am going to send a subpoena to Triad. Does that
satisfy you?
Mr. Barrett. I think that that's a positive statement.
Mr. Burton. Thank you very much. Mr. Cox.
Mr. Cox. Reclaiming my time, thank you, Mr. Chairman.
Ms. Williams, do you understand the concern, and I think it
is a legitimate one, on both sides of the aisle about illegal
foreign payments?
Ms. Williams. Do I understand the concern?
Mr. Cox. About illegal foreign payments?
Ms. Williams. Yes, I understand the concern.
Mr. Cox. And even if you were not aware of it at the time,
do you think it's appropriate for this committee to be
investigating the apparent connection between a March 6th wire
transfer to Johnny Chung for $150,000 from the PRC to the
$50,000 check that you received in the White House----
Ms. Williams. I really don't think it is in my----
Mr. Cox [continuing]. A few days later?
Ms. Williams. I don't think it's really in my purview to
say whether or not I think it's the right thing to do.
Mr. Cox. Well, I ask this because, as the Chief of Staff to
the First Lady of the United States, you have a great deal of
experience and judgment. And if questions are being raised
about the propriety of the investigation, I just want to know
whether or not you can see a prima facie reason for us to
investigate when there's a $150,000 wire transfer using the
bank of China in Beijing that goes into Johnny Chung's account,
and 3 days later, he hands you a $50,000 check inside the White
House. Is that something, even though you didn't know at the
time, is that something----
Ms. Williams. Mr. Cox, I did not know that at the time. And
with all due respect, and I want you to know this, with all due
respect, if you were interested in my opinion about this, you
would have asked me before I was here.
Mr. Cox. Well, I'm asking you now.
Ms. Williams. Well, I do not want to make comments now. I
am a fact witness here, and I don't necessarily have to give my
opinion.
Mr. Cox. Fair enough. With the ranking member, you covered
the ground of whether or not you solicited this contribution.
And it's your opinion as well as your fact testimony that you
did not solicit; is that correct?
Ms. Williams. Well, that is not an opinion. It is fact
testimony.
Mr. Cox. To the extent it's a legal opinion as well as a
fact question, but it's your testimony that you did not solicit
for legal purposes; is that right.
Ms. Williams. That's my testimony.
Mr. Cox. You did precisely what? You accepted an envelope,
but did not open it?
Ms. Williams. I don't recall if there was an envelope. I
recall that I accepted something that I believed to be a check.
Mr. Cox. Why did you believe it to be a check?
Ms. Williams. Because he said, here I give to you, I give
to you. It looked like a check.
Mr. Cox. Did you contact the White House Counsel's Office
about that check?
Ms. Williams. No, I did not.
Mr. Cox. Were you aware of the guidance from the White
House Counsel's Office that it's inappropriate for you to
accept that check?
Ms. Williams. The guidance I believe I had from the White
House Counsel was that you could take a check. That did not
necessarily constitute acceptance, and since other checks had
come through the mail, as long as you passed it on to the
appropriate entity.
Mr. Cox. Well, to refresh your recollection, the Counsel to
the President sent a memo around to all the heads of White
House offices that states that Federal law prohibits the
receipt of campaign contributions in Federal buildings. It says
that Federal employees----
Mr. Dennis. Is there a document? Excuse me, Congressman. Is
there a document number?
Mr. Cox. Document--excuse me, exhibit No. 153. And while
you're looking for that, I will just read from 18 United
States----
Mr. Dennis. I have it here.
Mr. Cox [continuing]. Code, Section 607, which says that it
is unlawful for any person to receive, receive, not solicit,
but receive any contribution in any room or building occupied
in the discharge of official duties. Any person who violates
this section shall be fined under this title or imprisoned not
more than 3 years or both.
Has your lawyer told you about this criminal code provision
prior to your appearing here today?
[Exhibit 153 follows:]
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Ms. Williams. If I understand it, my lawyer wrote a letter
about it.
Mr. Dennis. Mr. Cox, if I might address that particular
issue----
Mr. Cox. I'm just----
Mr. Dennis [continuing]. Since you asked what her lawyer
had to say.
Mr. Cox. I'm curious whether the witness at this time is
aware of this criminal statute.
Mr. Dennis. I'm aware of it. She's aware of it.
Mr. Cox. I thank counsel. The advice memorandum from the
White House Counsel's Office.
Mr. Lantos. Regular order, Mr. Chairman.
Mr. Burton. Mr. Cox, you may conclude this question, and
then we'll go on to the next Member.
Mr. Cox. Now that we've identified the exhibit, is that
something that you recognize that was received in your office?
Ms. Williams. I'm sorry. Yes. I believe it was.
Mr. Cox. I thank the witness, and I yield back.
Mr. Burton. The gentleman's time has expired. Mr. Fattah.
Mr. Fattah. Thank you, Mr. Chairman. And I, for one, am
pleased to hear the chairman's announcement that he has issued
a number of subpoenas and looking into various matters that
have been raised. So as one who, at times, raised questions in
that regard, I want to commend you in your announcement. And I
hope that, as we go forward, we can continue to find
opportunities in which we will be able to agree.
Let me mention a couple things for the record quickly. One
is that it is the law that you can't receive these
contributions. What that means in the U.S. Congress is, if you
receive a check here, you have 7 days to transfer it out to
your political office. And that is the rule both here in the
House and in the Senate and the rule in the White House as by--
pursuant to advice of counsel which we have, if one would read
the complete document, is that you must move the check along.
And that's what you did. You received a check. And you sent it
on to the DNC?
Ms. Williams. That's correct.
Mr. Fattah. So there should be no confusion that here,
under the rules of the U.S. Congress, these are Federal
buildings under which work takes place. It is a perfectly legal
practice that people receive checks. And they have, under the
rules of the Congress, 7 days, an entire week, to move those
checks on to their various campaign committees and in the
Senate. And the White House has a rule to do it, and they, in
fact, do it much more expeditiously than our rules call for.
Mr. Cox. Would the gentleman yield, because that's not the
law at all.
Mr. Fattah. Excuse me. I would be glad to yield at my
completion. I want to talk about this issue of access because
this is a fascinating subject to me. We're talking here as co-
equal branches of the Government, the executive and the
legislature. We're talking about someone who is writing checks
having access to come and visit. We have more than 1,000 people
here in the Capitol every day who have written checks to tens
and dozens of Members of Congress who access various offices
every day as paid lobbyists. They're here to talk to Members of
Congress about matters of importance to them.
Now, we have this gentleman, Mr. Chung, and I take issue
with people who have used his name in derogatory terms on both
sides of the committee, because I'm not sure at all that that's
appropriate. I think that we know something about the culture
of Asian Americans who in their conduct of business place a
great deal of reliance on pictures and relationships and
business cards and things that here in America one might see a
little bit different. But it's part of their custom. And as we
can see, he was quite aggressive. And as a businessman in his
initial enterprises, was also quite successful.
So until at such time that there's something clearly on the
record that this American has violated the law, I'm not sure
that we as a committee should be speaking of him in derogatory
terms. But, nonetheless, if our concern is that someone is
writing checks and showing up more than 50 times in the White
House over a span of 3, 4, or 5 years, we have people who write
checks and show up here every day, every single day.
And so we even have, and I want to enter into the record a
story from the Wall Street Journal, ``Gingrich Backer Had
Unusual Access As a Volunteer in the Speaker's Office,'' a
Donald Jones. He was a CEO helping to deal with a very
important piece of legislation that he had some interest in.
I also have another account from the Washington Post, which
showed that the majority party here invited a group of
lobbyists representing the largest polluters in our country
into the room to draft the laws that would, in fact, govern who
would be liable for the pollution and the deterioration of
property that they had caused.
So this issue of access, to the degree that this committee
is interested in it, is something that I think we could have a
broad scope on. And I--this other thing that was mentioned in
the chairman's opening remarks and has been referred to again
is Don Fowler's letter to Johnny Chung so that he could either
visit China or use it in some way.
Haley Barbour not only wrote a letter, but Haley Barbour
went to China with the principal of the Young Brothers in order
to help facilitate. In fact, his quote in the story that I also
would like to put in the record, Mr. Chairman, Mr. Young said,
well, Mr. Barbour----
Mr. Burton. Without objection.
[The information referred to follows:]
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Mr. Fattah [continuing]. Traveling with him, it helped put
powder on his face. That was the suggestion that it made him
look like someone who knew important people in the United
States and therefore could help facilitate business
transactions here.
So this is not a letter that was written. This was a party
chairman, someone who, on a weekly basis, met with the majority
leaders and Speaker here and Senator Lott and the majority
leader in the Senate as to the conduct of legislative business.
This party chairman got up and went to China in order to
facilitate this gentleman's business transactions. This is the
same gentleman who they borrowed the $2 million from and then
decided not to repay it in order to finance the Republican
contest in the 1996 elections.
I just want to ask you, Ms. Williams, since you've said
that you have done nothing wrong, and no one here has accused
you of doing anything wrong, and you've been brought here from
Paris, this committee is investigating Mr. Chung's access to
the White House. You were not at any time involved in any
discussions with him about official actions or policies in the
White House?
Ms. Williams. No. Not at any time.
Mr. Fattah. And you don't have any knowledge of him ever
seeking policy changes in terms of the White House in any
regard.
Ms. Williams. No, not to my knowledge.
Mr. Fattah. So if the committee was investigating
contributions for improper influences on policy, you would have
some difficulty helping us in that regard.
Ms. Williams. Yes.
Mr. Fattah. I want to thank you for your appearance here
today.
Ms. Williams. OK.
Mr. Burton. The gentleman's time is expired. Ms. Ros-
Lehtinen. Excuse me, Mr. Horn.
Mr. Horn. I'll pass.
Mr. Burton. You'll pass right now. Mr. Barr.
Mr. Barr. Thank you, Mr. Chairman. In the time period that
we've been talking about here, Ms. Williams, that is March and
April 1995, what was your official title?
Ms. Williams. Assistant to the President, Chief of Staff to
the First Lady.
Mr. Barr. OK. How were you paid?
Ms. Williams. How was I paid?
Mr. Barr. Yes, ma'am.
Ms. Williams. By the U.S. Government.
Mr. Barr. OK. You received a Government paycheck?
Ms. Williams. Yes, sir.
Mr. Barr. Drawn on funds from the Treasury Department?
Ms. Williams. Yes.
Mr. Barr. OK. One of the locations that we've been talking
about here was your office. Where, again, was your office
located again during this time period that we're talking about
here?
Ms. Williams. The office that I worked out of was in the
Old Executive Office Building. I also had an office in the
White House building.
Mr. Barr. OK. And in both of those were locations that were
used for the discharge of official duties; is that correct?
Ms. Williams. Yes. That is correct.
Mr. Barr. OK. Thank you. If we can have exhibit 174
replaced on the screen, please, I would appreciate it.
We have talked about this. But I just wanted to redirect
your attention to it. This is a check dated March 9, 1995, from
Mr. Chung to DNC for $50,000. And you've testified that you
knew that this was a check. I think your words were it looked
like a check. And it does give every appearance of that; is
that correct?
[Note.--Exhibit 174 may be found on p. 49.]
Ms. Williams. Yes.
Mr. Barr. OK. Is it a political check?
Ms. Williams. It's a check made out to the DNC.
Mr. Barr. What is the DNC?
Ms. Williams. The Democratic National Committee.
Mr. Barr. Is that a political organization?
Ms. Williams. Yes, it is.
Mr. Barr. OK. In your written statement, on page 2, and I
don't recall whether or not you read this in its entirety, but
on page 2 of your written statement, dated today, the second
paragraph, I'm going to quote this here, and if you would, just
read along just to make sure that I do quote it properly: ``So
when he asked how he could give and show his support, I told
him he could support the DNC or give to the Clinton/Gore
campaign.''
Have I read that accurately?
Ms. Williams. Yes.
Mr. Barr. And that is your testimony?
Ms. Williams. Yes.
Mr. Barr. OK. Now, if we could have exhibit 153 replaced,
please. This is the memo that I think Mr. Cox drew your
attention to just a short while ago, dated April 1995. I would
like to quote, just to make sure that we're accurately stating
what the Counsel to the President stated. In the first
paragraph on page 1, it states that this is a review, in other
words, not annunciation of new policies or new-found statutes;
this is a review.
We then look also at page 2. It says that there are a
number of criminal statutes which prohibit the use of Federal
programs, property, or employment for political purposes. And
these are punishable by imprisonment and substantial fine.
On page 3, at item 3, up toward the top of the page there,
it says that Federal employees, including White House
employees, may not knowingly receive a political contribution
from any person.
Then down toward the--let's go over to page 4. And in
paragraph (A)(2), campaign fund-raising activities of any kind
are prohibited in or from government buildings. In addition,
Federal employees are prohibited from soliciting or accepting
campaign contributions.
Down at the bottom of page 4, paragraph C, Federal law
prohibits the receipt of campaign contributions in Federal
buildings.
And here it comes to something that I think there's been a
little confusion about. And I think it's deliberate. There is a
reference to mail. The check that we're talking about here from
Mr. Chung was not mailed, was it?
Ms. Williams. No, it was not.
Mr. Barr. I didn't think so. It was received in person by
you. Now, if we could, then, turn our attention--and I know
your counsel is a man very learned in the criminal law, having
been a U.S. attorney--to Title 18 of the United States Code,
which is the criminal code, section 607.
I would respectfully suggest that you speak with him,
because in your testimony today, you have laid out each and
every element of section 607(A), which is a Federal criminal
statute, which says it shall be unlawful for any person, and
any person is defined in section 603 to include yourself,
pursuant to your sworn testimony, to solicit or receive any
contribution--you have received a contribution, this check--
within the meaning of section 301(A) to the Federal Election
Campaign Act in 1971 in any room or building occupied in the
discharge of official duties. And we have established that the
office in which you operate in and which you received this
check fits that category.
I would suggest that you have a very serious discussion
with your attorney because I think you have violated section
607(A) of the U.S. Criminal Code.
Mr. Dennis. Mr. Barr, may I speak to that issue or Mr.
Chairman, if I might?
Mr. Burton. Yes. You'll be allowed to answer.
Mr. Dennis. My client is not being a lawyer. I would like
to make a part of the record a letter that I sent to Joseph
diGenova, dated March 6, 1997, in response to an----
Mr. Barr. Mr. Chairman, if I could?
Mr. Fattah. Can we let the counsel speak, please?
Mr. Barr. Hold on just a moment.
Mr. Fattah. Mr. Chairman.
Mr. Barrett. Regular order, Mr. Chairman.
Mr. Barr. Mr. Chairman, I have a parliamentary inquiry.
Mr. Burton. State your parliamentary inquiry.
Mr. Barr. When we refer to documents, and folks on the
other side are very quick to jump on us if the document is not
on the screen and if the document is not in the hands of the
witness, to make sure that they have copies of documents----
Mr. Barrett. Regular order, Mr. Chairman. If he can state
it in the form of an inquiry rather than a soliloquy.
Mr. Burton. I will listen to the inquiry and then make a
decision. Just 1 second.
Mr. Barr. Thank you, Mr. Chairman. In this case, it is not
the witness, but her counsel that is seeking to read into the
record and discuss the document that we don't even have, and I
would, therefore, object to that.
Mr. Burton. Well, I would appreciate that. But I think the
Chair will allow a little latitude here to hear what the
counsel has to say.
Mr. Barr. If I might just pose one further question, Mr.
Chairman, and that is could counsel extend us the same courtesy
that we extend to him and furnish those copies of the document
to which he's referring?
Mr. Burton. Does the counsel have copies of this document?
Mr. Dennis. I have no additional copies. I can have copies
made. But I can certainly refer to this and read from it and
provide copies of the letter after my statement. I would be
happy to do that.
Mr. Burton. OK. Well, we'll allow you to go ahead, and we
would like to have copies for Mr. Barr and other Members.
Mr. Dennis. Thank you----
Mr. Burton. Proceed.
Mr. Dennis [continuing]. Mr. Chairman. This is not a very
long letter, but let me read it into the record. It says:
``Dear Joe''--Mr. diGenova by the way was former U.S. attorney
of the District of Columbia.
``Your off-the-cuff opinion on the Hatch Act given to the
national media is 101 years out of date. You are quoted as
taking issue with my client's handling of a political
contribution to the Democratic National Committee calling it,''
quote, ``totally improper,'' end quote, ``because in your
words,'' quote, ``it is illegal to receive Federal campaign
funds on the property of the White House or the Executive
Office Building,'' end quote. ``New York Times, March 6th,
1997.
``In 1896, President Grover Cleveland's administration
issued an opinion on the meaning of the word `receive' under
the predecessor to the modern statutes limiting political
activities by the Federal employees and the interpretation that
has been followed consistently through reenactments and
codifications of these statutes over the past 100 years.
Attorney General Judson Harman wrote in 1896 in a published
opinion at 21 Opinions of Attorney General 298,'' quote, ``The
place where he, bracket, the Federal employee, end bracket,
received the contribution is immaterial'' because, quote,
``possession which simply constitutes the taker a mere
custodian without right on his own behalf or of that of others
does not violate the act.
``The vitality of Harman's opinion has not diminished over
the years. The word `receive' and the phrase `receive a
political contribution' in 5 U.S.C. Section 7323(a)(2) and the
phrase `receive any contribution' in 18 U.S.C. Section 607(a)
is defined today by Federal regulations as follows: `Receive
means to come into possession of something from a person
officially on behalf of a candidate, a campaign, a political
party, or a partisan political group.' 5 CFR section 734.101,
1996. To further drive the point home, the Office of Personnel
Management, the agency that promulgates these regulations, has
recently addressed this very issue in both its comments to
interim regulations on the subject in 1994 and its adoption of
final regulations a mere 8 months ago stating,'' quote,
``Ministerial activities which precede or follow the official
acceptance and receipt, such as handling, disbursing, or
accounting for contributions are not covered under the
definition of `accept' and `receive.' As Attorney General
Harman stated over a century ago, where an employee's relation
to the transaction is `purely mechanical,' '' and that's in
quotes, ``the employee has not acted improperly or illegally
regardless of whether he or she is in a Federal building.''
There are several additional paragraphs. That's my opinion
with regard--and analysis with regard to this particular issue.
And I just wanted the committee to be aware that there is
substantial authority for the fact that these circumstances
would not give rise to a criminal violation or a civil
violation of any statute or regulation on the part of my
client.
[The letter referred to follows:]
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Mr. Burton. The gentleman's statement and the
correspondence you alluded to you will be made a part of the
record.
Mr. Kucinich.
Mr. Kucinich. Thank you very much, Mr. Chairman.
First I would like to submit something for the record. This
is a memo for all Members' offices and the employees of the
House of Representatives, dated April 25, 1997, and the subject
is Rules Governing Solicitation by Members, Officers and
Employees in General.
[The memo referred to follows:]
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Mr. Kucinich. In this--and I cite from this for the purpose
of bringing some clarity to this moment. Under the topic of
receiving political contributions, and I quote: ``However, if
someone unexpectedly offers a contribution during a visit to a
House office, or someone unexpectedly mails or delivers a
contribution to the office, the contribution can be accepted,
provided that it is forwarded to the political committee within
7 days of receipt. The criminal statute, 18 U.S.C. 607 includes
a provision which specifically permits acceptance and
forwarding of a contribution received in a Congressional
office, provided that the contribution was not solicited in any
manner which directs a contributor to mail or deliver a
contribution in a Federal office.'' Then it goes on to talk
about the implications of the frank.
I would like to submit this into the record. I would also
like to submit a copy of 18 U.S.C. 607, which spells out the
circumstances under which someone in effect can be a custodian,
but passing it along, they're not lawfully--they're not
unlawfully receiving it. And also, an addendum which is the
Hatch Act which, in effect, would qualify the conditions under
which someone would have temporary custodianship of a
contribution.
Mr. Cox. Would the gentleman yield? Is the gentleman aware
that that's not the law that applies to the White House?
Mr. Kucinich. I am aware furthermore that in exhibit 153-4,
the White House in receipt of campaign contributions in the
White House, spells out a policy of passing along such
contributions. I'm going to continue if I may.
I furthermore want to point out and caution members of the
committee about implying that Ms. Williams broke any laws in
regard to this, since it's very clear that there are policy
statements and ethics statements which suggest that there is
one standard that has already been applied to the legislative
branch and a policy through an exhibit that implies that there
is an equivalent in the administrative branch.
Furthermore, on another issue, the chairman of this
committee said on record that the check from Mr. Chung came
from the Chinese Government and was therefore illegal. But I
would submit respectfully that the Chair is not correct.
On March 6, 1995, Mr. Chung received a $150,000 wire
transfer into his account which had only about $9,000 in it. On
March 19, 1995, he wrote a $50,000 DNC check that he handed to
Maggie Williams.
There is nothing illegal with this transaction as the money
he received by wire was his own earned money. In fact, the wire
transfer record itself states that it was a payment for goods
from the Haomen Group. The Haomen Group is a Chinese beer and
soda company. And Mr. Chung escorted an executive to that
company through the White House in December 1994, and was
reportedly trying to market the company's beer in the United
States.
The wire transfer came from the Chase Manhattan Bank in New
York City. Now the Senate released the underlying documents
about the wire transfer to the press which then reported the
facts. For instance, the July 18 articles in both the L.A.
Times and in Newsday fully report the facts about the March 6
wire transfer. Quoting from the L.A. Times, ``a partial review
of Chung's personal financial records shows that contrary to
GOP assertions, Chung had in excess of $300,000 in various bank
accounts at the time, indicating that he could have covered his
$50,000 contributions without Chinese funds.''
So there are two points here. One of which is that is--
there is no suggestion that Ms. Williams violated the law by
taking in and then passing along, according to proper
procedures, that check that Mr. Chung gave her. Second, there
is no evidence that Mr. Chung, in fact, could not have covered
that contribution with his own money.
Now, we do have evidence of the ubiquitousness of Mr.
Chung. That we have evidence of. What we have here is more or
less the return of Forrest Gump, this time as an ethic
businessman. He is everywhere. He is with Republicans. He's
with Democrats. He's at the Statehouse. He's at the White
House. But nothing says that he should be going to the big
house.
Mr. Burton. Does the gentleman yield back the balance of
his time?
Mr. Kucinich. I yield my time back to Mr. Fattah, if he
wishes to continue that point.
Mr. Fattah. No, I just want in addition to, in response to
Congressman Cox's, I think, very appropriate question, that
that does only relate to the House's rules. But there's a
Senate rule that I would also like to put in the record which
is quite similar and is also one that governs the White House.
In addition, the Office of Personnel Management, in its
regulations which governs all Federal employees, says
essentially the same thing; and that is, that administrative
activities which precede or follow the acceptance and receipt,
such as handling, disbursing, accounting for contributions, are
not covered under the definition of accept and receive.
So I think that what we need to be clear about is that
clearly, based on all of the accepted norms, the fact that she
received a check and sent it over to the DNC is not something
that is dissimilar to what happens throughout the Federal
Government and is generally accepted as a normal part of doing
business here. And for people to try to make that into a crime
is in of itself quite offensive, and it should be to the
majority even on this committee.
Mr. Kucinich. Reclaiming my time. Thank you, Mr. Fattah.
You helped to elucidate that further.
Mr. Burton. The gentleman's time has expired. Mr. Horn.
Mr. Horn. I will be glad to yield the chairman such time as
he needs.
Mr. Burton. Let me just take a second here. One of the
things that we're trying to find out is, were illegal foreign
contributions made to either party. In this particular case,
we're talking about the Democrat National Committee. What do
these transactions mean?
Now, we could sit here and argue about whether or not Mr.
Chung had funds in one bank account or another and on and on
and on. But we honestly don't know. We don't know if this was a
conduit contribution. Was that $150,000 legitimate income that
was earned by Mr. Chung's business? We don't have the answers
yet. We hope to get those answers from Mr. Chung tomorrow.
We're going to be talking to him about that, taking a
deposition in the morning before the hearing. But the fact of
the matter is the appearance, the appearance is one that needs
to be investigated very thoroughly. And that's what we're
trying to do.
Mr. Horn.
Mr. Horn. I thank the gentleman for yielding.
Mr. Cox. Would the gentleman from California yield? Would
the gentleman yield?
Mr. Horn. I will.
Mr. Cox. I thank the gentleman.
Mr. Chairman, it's also important for us to focus on the
fact that while surely we would empathize with anyone who
unwittingly received a campaign check and tried to do the right
thing with it, what we've got here is, first, consistent long-
standing advice of the White House Counsel's Office, the same
memoranda that we used to circulate when I worked in the White
House Counsel's Office, that makes it clear to all the White
House office employees and certainly who run those offices such
as the Chief of Staff of the First Lady that you cannot accept
contributions.
We have a Chief of Staff who then did not consult with the
White House Counsel's Office; neither did she consult with the
National Security Council concerning people that I take it were
complete strangers.
I'll ask you on the record, Ms. Williams, were the people--
we're not so much concerned frankly about Johnny Chung as we
are about what's going on behind him. And therefore, these
pictures that we're looking at of Johnny Chung with various
people or with the President of the United States are not so
troublesome as the fact that he didn't even go to the main
event which he apparently purchased for his People's Republic
of China visitors; but rather we had representatives of the
China Petrochemical Corp., COSCO, CITIC, and so on, none of
whom I would classify as a political groupie, and none of whom
I would say is beyond engaging in policy discussions, walking
right in and having meetings for the First Lady, the President
of the United States and so on.
But let me ask you, because we left on this before, whether
or not the people who you arranged to meet with President
Clinton on that Saturday on March 11 to watch him give his
radio address and so on, was any of those people known to you
prior to the request by Mr. Chung that they would be permitted
these meetings?
Ms. Williams. I did not arrange for Mr. Chung to go to the
radio address or any of his associates to go to the radio
address or meet with the President.
Mr. Cox. Did you meet with these people yourself?
Ms. Williams. I didn't meet with them. I was introduced to
them, as I said before, and I----
Mr. Cox. You were introduced to them.
Ms. Williams. They didn't speak any English. I----
Mr. Cox. Were any of these people known to you before?
Ms. Williams. No.
Mr. Cox. So they were complete strangers.
Ms. Williams. Yes, they were.
Mr. Cox. And I think part of the concern here is that
exactly contemporaneously with the exchange of significant
funds, $50,000, complete strangers are given extraordinary
favors by the White House. That is a different issue. And that
is--it is that sort of total picture that makes us focus on why
this money is--changes hands inside the White House. But these
people to you were total strangers.
On April 7th, the National Security Council opined that Mr.
Chung should be treated with suspicion and that he was a
hustler. Do you know how many times he was admitted to the
White House after that advice was given on April 7?
Ms. Williams. I do not know that. But you--that advice was
not given to me.
Mr. Cox. So you never heard from the National Security
Council about Mr. Chung at all?
Ms. Williams. No, I didn't. In fact, the only contact I
ever had with the National Security Council with respect to Mr.
Chung that I recall was having spoken to someone a long time
after the radio address, when Mr. Chung was trying to get his
pictures, and he wrote me a note. So I was not aware of the
National Security Council--I don't know if it was a memo or
whatever on April 7 or whatever the date was. Sorry.
Mr. Cox. Let me ask a question about these complete
strangers, because it's been suggested that Johnny Chung is a
sort of wealthy Mr. Magoo who is just kind of aimlessly bumping
into people and showing up places. Would you characterize the
vice president of the China International Trust and Investment
Corp., as a political groupie who was uninterested in
discussing any policy?
Ms. Williams. I don't know him.
Mr. Cox. But do you think that someone who occupies that
position is likely to be a naive waif?
Ms. Williams. I don't know him to say.
Mr. Cox. Or the vice president of China Petrochemical, does
that sound like the kind of person who is just interested in
being a political groupie?
Ms. Williams. Well, I don't know him. And, boy, you know,
Washington is full of surprises. People you least expect to be
one way are another way, so I'm hesitant to say----
Mr. Cox. Just amazing.
Ms. Williams [continuing]. Just based on the title.
Mr. Cox. It's quite a surprise.
Mr. Burton. The gentleman's time has expired. Mr. Waxman.
Mr. Waxman. Ms. Williams, I think we're sinking to new lows
on this committee. I'm just astounded at the last questions
that you had from Mr. Cox when he said that there was an
advisory from the National Security Council. There was not an
advisory from the National Security Council. It was a memo by
someone at the National Security Council when questioned
whether he should give Mr. Chung and his guests photos. He said
extraordinary reward that was given to Mr. Chung. Well that was
the extraordinary reward, whether he should give his photos.
They were a little nervous about this guy. He was a hustler.
And that's what Mr. Suettinger, I think is his name, said in
his memo. It wasn't an advisory. It wasn't an all purpose
alert.
Second, I think we reached an all time low when people
start talking about the law. You would think that lawyers would
have some sense that they should be honest about it. The law is
very clear. If someone unexpectedly offers a contribution or
unexpectedly mails or delivers a contribution, the contribution
can be accepted provided it's forwarded to the political
committee within 7 days of receipt. That's the law.
What is going on here, and I suspect you already have
figured it out, is Republicans have no indication that you
solicited any contribution. They have no basis for saying that
you violated any law, that you have committed any illegality.
What you're in the process of being is, quote, ``slimed.''
That's what's happening here today. And it really is a new low.
The chairman says we're talking about foreign
contributions. Well, no one has been able to say that it was a
foreign contribution involved here. Maybe there was, but all we
know is that Mr. Chung wrote a check and then received a wire
transfer from a foreign bank. A foreign bank doesn't mean it's
a foreign contribution. And if it's a foreign payment through a
foreign bank, a payment for some business activity of his, that
doesn't make it a foreign contribution.
You know, the thing is this, this is supposed to be an
investigative committee. Before an accusation is made, those
who are doing an investigation should find out the facts. What
we have in this committee is a pattern of allegations before
they know the facts. That's what happened when the chairman
alluded to his claim that the tapes of the White House coffees
were altered. He still has no way--no basis for making that
statement. You don't reach a conclusion before you get the
facts unless you're doing it for political purposes. And of
course I think that's what's really going on.
If we have information about a foreign contribution, let's
get the information out there before the allegation is made.
That's the responsible way for investigators to handle things.
Just for the record, and people should know this, because
there are people who watch this hearing on C-SPAN, this
committee has issued 600 subpoenas and requests for
information, all directed at Democrats. And they've had 10
requests for information and subpoenas where it might pertain
to possible Republican wrongdoing.
The chairman says he's going to do his level best to know
what the facts are, no matter where they may lead, on either
side of the aisle. Well, I'm pleased to hear he said he's going
to subpoena Triad. I haven't seen a subpoena to be issued by
our committee at all.
And I want to make the point for the record that an excerpt
from the 1994 interim regulations that say ministerial
activities regarding contributions like the one you had are
perfectly legal. I'm going to put that in the record. These are
the regulations for the Office of Personnel Management. And Mr.
Cox, who used to work in the White House, said don't you know
the rule is different in the White House. Well, I have now the
information it's not different in the White House.
[The information referred to follows:]
[GRAPHIC] [TIFF OMITTED] T5667.077
[GRAPHIC] [TIFF OMITTED] T5667.078
[GRAPHIC] [TIFF OMITTED] T5667.079
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Mr. Cox. Would the gentleman yield, because the statute is
different as well as the advice memorandum.
Mr. Waxman. I do not yield. I'm submitting for the record
the statement of the Office of Personnel Management dealing
with interim regulations that is pertaining to the White House
itself.
It seems to me that what we have repeatedly is a statement
we're going to go into foreign contributions. And yet, 2 weeks
ago, the subpoenas went out from this committee to the
Teamsters. That has nothing to do with foreign contributions.
What we're trying on this committee on behalf of the
Republicans is to try to see if they can stir up some kind of
claim of illegality out of thin air. And to me, I think that is
the wrong thing for us to be doing. It's a waste of taxpayers'
money. It is partisan. It is just not credible as a serious
investigation. And we've already spent $3 million on this
committee, just to fund this investigation for which we have
nothing new, nothing new. Even your testimony is not fresh for
this committee because you've already given depositions in the
Senate, given depositions here. All of this has been reviewed
over and over again. Nothing new has come out of this hearing.
And I think this whole investigation is a very sad chapter
in the House of Representatives, in the history of what ought
to be our clear responsibility for oversight. This is a
ridiculous process.
And by the way, OPM and the Ethics Committee on this issue
agree on the interpretation of the law. Only Mr. Cox and Mr.
Barr disagree. And I would be pleased to yield to the gentleman
from California if he wants to make any further comments. But
he might want to wait to see what the document that I have and
am putting into the record says so he'll know for sure what the
rules are that pertain to the White House. I ask unanimous
consent it be made part of the record.
Mr. Cox. I would be happy to accept the gentleman's
invitation of time.
Mr. Burton. The time has expired, but if----
Mr. Waxman. Well, then, I don't have time to yield, and
therefore I don't yield.
Mr. Burton. OK. Mr. Mica, you're recognized.
Mr. Mica. I thank you, Mr. Chairman. I might just comment
on a couple of things. First of all, the pictures that we have
over here with the Republican Governors, I heard one of my
colleagues say that they made it into the Statehouse and the
White House. Well, that's not a matter of fact, because these
pictures were all taken on the same day at the Republican
Governors Association. In fact, just look, he's wearing the
same tie in all the photos.
These meetings did not involve arranging 55 visits to the
White House. These photos did not involve $50,000 checks being
passed to a Government employee in any instance that I know of.
These photos did not involve the records of money coming from
foreign sources to make those contributions. These instances
did not, in fact, bring foreign nationals to arrange meetings
while the President of the United States made a national radio
address. And these photos didn't offer the access that we've
seen demonstrated here today by this hearing.
These photos did not arrange for giving of $40,000,
December 14, 1994 to the DNC again through questionable
sources; $50,000, March 9, 1995 to the DNC again from
questionable foreign sources; $125,000, April 8, 1995 again to
the DNC, and a grand total of $366,000, a few more dollars than
he could have covered in his account as alleged by the other
side.
Ms. Williams, do you know Ms. Cara--I think it's Ceandra
Scott at the DNC?
Ms. Williams. Yes, I do.
Mr. Mica. Now you testified a few minutes ago that you had
nothing to do with getting Mr. Chung and his Chinese delegation
into the Presidential radio address on March 11, 1995; is that
correct?
Ms. Williams. That's correct.
Mr. Mica. Ms. Scott in fact has told the committee that she
may have spoken to you specifically and made that request of
you. Do you think she's wrong?
Ms. Williams. I can only recall one time when I spoke with
Ms. Scott regarding a radio address, and that was a radio
address for either her parents or her grandparents.
Mr. Mica. But you did not arrange or make any arrangements
personally? And have you knowledge of your staff making
arrangements to get Mr. Chung and these guests into this event?
Ms. Williams. No, not to my knowledge.
Mr. Mica. You said in your testimony, that Mr. Chung had
asked you about giving money to the President or the First
Lady. Was that from the very beginning of your meetings with
him?
Ms. Williams. Well, as I said before, I never had any real
meetings with him.
Mr. Mica. Well, your conversations with him. You have in
your testimony that Mr.--he said, so when he asked how he could
give and show his support, I told him he could.
Ms. Williams. Yeah. He constantly asked me.
Mr. Mica. He asked you. You didn't say, would you like to
give?
Ms. Williams. No.
Mr. Mica. OK. And then you said you could support, in your
quote, the DNC; give to Clinton/Gore campaign. And you've also
said you were somewhat aware of the law, that you said you
couldn't take that money. That was sometime earlier before you
took the $50,000 on, when was it, March--when did you take the
$50,000 check? March 9?
Ms. Williams. That's the date people tell me. I'm not aware
of the date.
Mr. Mica. But he remembers giving a check.
Ms. Williams. I remember getting a check.
Mr. Mica. And you had suggested to him--these are your
words and your testimony to this committee--support the DNC.
And he brings you a check for $50,000. It doesn't raise a
question, or him giving you a check?
Ms. Williams. I'm sorry. It doesn't raise a question? I'm
sorry. I don't understand the question.
Mr. Mica. Well, you gave him an array of contribution
possibilities, ``Give to the Clinton/Gore campaign.'' This is
from your testimony in your quotes. ``Support the DNC'' in
quotes; ``Give to Clinton/Gore campaign,'' in quotes. ``Help
the President and Mrs. Clinton's legal defense fund,'' in
quotes. You said those were your standard responses to people
who were offering to help; is that correct?
Ms. Williams. That's correct.
Mr. Mica. And that's what you told him.
Ms. Williams. When he asked me, yes.
Mr. Mica. Did you ever receive any other checks or
contributions? Were there any personally handed to you----
Ms. Williams. No.
Mr. Mica [continuing]. For any of these organizations I've
cited or groups?
Ms. Williams. No.
Mr. Mica. This is the only one?
Ms. Williams. This is the only one.
Mr. Mica. And the same day that you received this, Mr.
Chung was also invited to the White House Mess or allowed--it's
not easy to get in the White House Mess.
Ms. Williams. No, it's----
Mr. Mica. Who made the arrangements to get him into the
White House Mess?
Ms. Williams. Well, first of all, it really isn't so
difficult to get into the White House Mess.
Mr. Mica. If the First Lady's chief assistant gets you in.
Ms. Williams. No, because the White House Mess is
essentially personal accounts, which is to say, if I get an
apple from the White House Mess, it's charged to me.
Mr. Mica. Did you get Johnny Chung in before he gave you
the check or after he gave you the check?
Ms. Williams. I believe that I had gotten him in one--
Johnny Chung?
Mr. Mica. Well, the group that went to the White House
Mess; was it the officials, the Chinese officials, the
delegation?
Ms. Williams. Well----
Mr. Mica. And Mr. Chung, and all of the above.
Ms. Williams. First of all, I don't actually know who went
to the Mess with Mr. Chung that day. But I certainly did ask
Ms. Ryan or someone in my office to make a reservation under my
name for Mr. Chung.
Mr. Mica. After he gave you the check or before?
You don't recall?
Ms. Williams. I don't recall. But I do recall him having
used my Mess account before on another occasion before the
check, I believe.
Mr. Burton. The gentleman's time has expired.
Mr. Mica. Thank you, Mr. Chairman.
Mr. Burton. Mr. Davis.
Mr. Davis of Virginia. Ms. Williams, thank you for coming.
I don't have any questions, but I'm going to yield time to my
friend from California, Mr. Horn.
Mr. Horn. I thank the gentleman. Mr. Waxman had some
comments to make, and I want to ask this question while you're
here, because one of the witnesses will come after you're
finished.
Mrs. Hernreich, as I recall from her deposition, said--was
told by President Clinton after the Chinese delegation visited
him in the Oval Office, ``You shouldn't have done that,''
unquote. Or also, ``We shouldn't have done that,'' unquote,
referring to those pictures that were taken of the President
and the members of the Chinese delegation.
Did Mrs. Hernreich talk to you after that picture was taken
and the President was slightly upset about it all as a national
security matter? Did she ever call you and say who brought them
through here?
Ms. Williams. No. I don't recall a conversation with Nancy
Hernreich about that.
Mr. Horn. Let me move to another situation, the Back to
Business situation. What was the basic purpose of that Back to
Business Committee?
Ms. Williams. As I understood, the Back to Business
Committee were a group of people who were primarily
spokespersons who operated outside of the White House to answer
the charges made about the President and the First Lady.
Mr. Horn. What sort of charges are we talking about?
Ms. Williams. Oh, too numerous to--I mean, there are all
kinds of things that were being said about them.
Mr. Horn. Well, did it have to do with things when he was
Governor or when he was President?
Ms. Williams. Oh, I can't remember. Just generally any bad
thing that could be said.
Mr. Horn. This was an all-purpose committee, in other
words?
Ms. Williams. As I understood it.
Mr. Horn. Handling anything that was going to the outfield.
Ms. Williams. As I understood it, yes, sir.
Mr. Horn. Did it concern charges arising from Whitewater?
Ms. Williams. Yes.
Mr. Horn. Was that the primary thrust of the committee?
Ms. Williams. I don't believe so.
Mr. Horn. What was its primary thrust?
Ms. Williams. Like I said, I thought the main thing was to
have other spokespeople to respond. The primary was to have
spokespeople.
Mr. Horn. Who founded that committee?
Ms. Williams. Lynn Cutler was one of the cofounders.
Mr. Horn. Was the other cofounder Anne Lewis?
Ms. Williams. Anne Lewis could have been a cofounder. I
don't know if she was brought in later or she was a cofounder.
Mr. Horn. And what is Mrs. Lewis's position in the White
House now?
Ms. Williams. She is Director of Communications.
Mr. Horn. What is Mrs. Cutler's position in the White
House?
Ms. Williams. I'm really not sure. OK, I'm sorry. She's in
Intergovernmental Affairs.
Mr. Horn. Is she Deputy White House Director of
Intergovernmental Affairs? Does that ring a bell?
Ms. Williams. That could be so. I don't know if that
happened after I left or--but she works at the White House,
yes.
Mr. Horn. Were discussions ever held with the First Lady
about the information or advertisements that the Back to the
Business Committee was promulgating?
Ms. Williams. I'm certain that there was a point that I
told Mrs. Clinton that there were people who were speaking out
on her behalf.
Mr. Horn. Well, did you get some of these advertisements or
leaflets or brochures or different forms of communication and
ever take them in to the First Lady?
Ms. Williams. No.
Mr. Horn. So you weren't involved in approval or
disapproval?
Ms. Williams. Oh, of their materials?
Mr. Horn. Yes.
Ms. Williams. No, not at all.
Mr. Horn. Did the White House or the First Lady's office or
you or anyone else you know in the White House ever provide the
committee with a list of potential donors?
Ms. Williams. With a list of potential donors?
Mr. Horn. Potential donors. Even one donor. One and up.
Ms. Williams. I don't know about anyone else at the White
House or if there was any specific list. But as I said in my
statement today, I was asked by Lynn Cutler for people to go on
the television and people who might contribute to the group.
And I gave her some names, three or four names.
Mr. Horn. At your suggestion, Ms. Cutler contacted Chung
for a contribution the day after the December 8, 1995 White
House Christmas party, and Ms. Cutler introduced herself as a
friend of the First Lady who was referred to him by you,
according to an August 9, 1997 Los Angeles Times article; is
that correct?
Ms. Williams. Well, I did give her his name. I wasn't there
at the Christmas party when she talked to him, but I did give
him her name.
Mr. Horn. Did Mrs. Cutler know Chung at that point when you
gave the name? Had she met him during some of the tours?
Ms. Williams. I don't know. I don't know.
Mr. Horn. Did you suggest that Mrs. Cutler contact other
potential contributors? And how many were they?
Ms. Williams. As I said before, I gave her three or four or
five or six names. I remember a Mr. Chung as a contributor, but
I primarily gave her names of people I thought could go on
television. And given my communications background, I thought
that's what she thought I would be able to give her. In
addition, I gave her Mr. Chung and I don't know who else.
Mr. Horn. Well, Mr. Chung let's say is one of the four. Who
were the other three?
Ms. Williams. I do remember that I gave her the name of
Kiki Moore as someone who could go on television. I don't
remember the other three, but those two names I should
remember.
Mr. Horn. Is that a celebrity that I ought to know and
don't know?
Ms. Williams. No, no, not a celebrity at all. Just a young
woman who is very good at speaking on television.
Mr. Horn. And did she do that?
Ms. Williams. Speak on television?
Mr. Horn. Yes.
Ms. Williams. Yes, I believe she did once or twice, yeah.
Mr. Horn. So we assume Mrs. Cutler contacted her and got
her involved.
Ms. Williams. I don't know who contacted her, but that was
the name I did give to her.
Mr. Horn. Why did you suggest Mr. Chung and these other
individuals to Mrs. Cutler to contribute to Back to Business?
Was there any particular reason?
Ms. Williams. Only that I was trying to think of people who
had asked to be helpful to Mrs. Clinton. And he had on numerous
occasions. And so his name was a name that I gave to her.
Mr. Horn. Did Johnny Chung ever contact you inquiring about
Lynn Cutler?
Mr. Waxman. Point of order, Mr. Chairman.
Ms. Williams. I'm sorry. Can you repeat the question?
Mr. Horn. Did Johnny Chung ever contact you inquiring about
Lynn Cutler?
Mr. Burton. The gentleman's time has expired.
Ms. Williams. No, I don't recall that he did.
Mr. Burton. The gentleman's time has expired.
Mr. Portman.
Mr. Portman. Mr. Chairman, I'm happy to yield some time to
you or, in your discretion, to Mr. Horn.
Mr. Burton. If the gentleman will yield to me, I'll take a
minute or so.
Mr. Portman. Can I make a brief statement first and then
I'll be happy to yield? I don't have any questions.
Mr. Burton. Fine.
Mr. Portman. I would like to make a quick statement. I've
listened carefully today. We started off with my friend from
California, Mr. Waxman, saying the only useful purpose here is
to develop new campaign finance laws. I think that's
inaccurate. I think the oversight is very important. I think
that's what the committee is supposed to do. I think it's a
useful public hearing of specific ethical issues, in this case
surrounding Johnny Chung. And among the concerns I've heard
today are inappropriate White House access, improper use of
that access, potential use as a conduit for foreign money, even
potential and national security issues related to the People's
Republic of China.
And I think, at the very least, this has been a very useful
public hearing, because it helps to establish what the ethics
rule should be and puts this administration and future
administrations on notice; and that is, that the ethics rules
need to be followed, that they do exist, the current rules in
those gray areas, and they always exist to seek to adhere to
higher ethical standards particularly in the Nation's White
House.
Mr. Waxman. Will the gentleman yield to me?
Mr. Portman. I think this is an important service to the
country and I commend the chairman and I will not yield time.
Mr. Waxman. If the gentleman would yield to me for one
comment, I don't disagree with what you are saying but I hope
we will learn also to change the campaign finance rules that
encourage this payment of money for access, which we see
permeating throughout both the White House and Federal
campaigns, but Congress as well.
Mr. Portman. Reclaiming my time, that is an issue that
there is not a consensus on in this committee, much less this
Congress and this country, and I think in the meantime this is
a very important exercise, and I will now yield my time to the
chairman.
Mr. Burton. Thank you, Mr. Portman.
First of all, Ms. Williams, to clear up one thing, you were
here, I guess, of your own volition to be at the First Lady's
50th birthday party; is that correct?
Ms. Williams. No.
Mr. Burton. Oh, you were not?
Ms. Williams. I did go to it, but that was not the reason I
came.
Mr. Burton. Did you go back to Paris after that?
Ms. Williams. I was on my way to Paris--back to Paris when
my lawyer called me and told me that----
Mr. Burton. You didn't leave the country? You stayed.
Ms. Williams. I stayed because it was a week from----
Mr. Burton. I appreciate that.
According to the information we have, you said you did not
solicit money from Johnny Chung, and you did not discuss with
him the money to the DNC owed the White House, and you do not
know how he was aware of that.
Now, on page 110 of Evan Ryan's deposition, which was
released today, here is what she said, talking about Ms.
Williams' response:
``Her response was we would see, you know, we'd see if we
could set those things up for him and that it was helpful to
know about his donation because then maybe that would enable
the DNC to pay off some of their debts.''
And then on page 112 she says, ``Oh, I don't know, it was
more--I don't remember exactly what she said but it was
something along the lines of that's helpful to know that they
are getting this donation. Maybe it will help with some of the
debts that they owe the White House. That's the general gist of
what I got from her.''
That seems inconsistent with what you have told us here
today, and I just wondered if you can explain that
inconsistency?
Ms. Williams. Well, as I said, I have no specific
recollection of this discussion with Ms. Ryan. But as I said in
earlier questioning, it was not a secret for Ms. Ryan or people
at the DNC that the DNC owed the White House money.
Mr. Burton. But the point is that this was discussed prior
to your getting the check from Johnny Chung?
Ms. Williams. Well, that is her recollection. That is not
my recollection.
Mr. Burton. I see, OK. I will yield back to Mr. Portman and
he can yield.
Mr. Fattah. Mr. Chairman, a quick question. When you read
the deposition, it seemed to me that Ms. Ryan was speaking
after the fact of the contribution, not prior to the fact of
the contribution. So maybe it wasn't clear.
Mr. Burton. No, I'll be glad to give you a copy so you can
take a look at that. I yield back to Mr. Portman.
Mr. Portman. I am glad to yield to the gentleman from
Florida.
Mr. Mica. Mr. Portman, thank you for yielding and, Mr.
Chairman, I just want to make a general comment too about what
has been said on the other side about the cost of these
hearings. That it costs too much, that it's cost $3 million.
When, in fact, the cost of operation of this committee,
including the investigative function, is far less than the
other side spent for similar activities in the time that they
controlled this committee.
I submit, Mr. Chairman, that the cost to close down this
hearing, this investigative process for future generations
would be much more than we want to pay, because in fact this
process is what separates our Government from dozens of other
governments, scores of other governments around the world where
they don't examine their executive branch, their executive
agency, so this is very important.
We appreciate the witness' cooperation, and we are not
trying to condemn this witness; we are trying to find out the
facts from this witness, and we hope to also find out from Mr.
Chung where this money came from, how he could gain such access
to the White House and to the President and First Lady in this
manner, and then take corrective steps so this doesn't happen
again, if, in fact, this does lead to foreign contributions. So
I thank the chairman and yield back my time.
Mr. Burton. The gentleman's time has expired.
Let me give everybody some information here quickly. It is
the intent of the Chair after the last questioner, which will
be Mr. McIntosh, to break for about 15 minutes so everybody can
get just a quick bite of something, come back and get to the
second panel.
I have been informed by the Cloakroom, that we will
probably have a vote in an hour or hour and a half. If we take
10 minutes, we will still have an hour and a quarter before we
have to break for another vote. Mr. McIntosh.
Mr. McIntosh. Thank you, Mr. Chairman. I would like to
yield my 5 minutes to Mr. Barr.
Mr. Barr. I appreciate the gentleman for yielding.
Ms. Williams, I was somewhat intrigued by your attorney's
reference to the letter that he wrote setting forth his opinion
on some of the matters that we've touched on here today with
regard to that provision of the U.S. criminal code that relates
very explicitly to receipt of campaign donations and the place
of solicitation and by whom.
I might very respectfully suggest that you discuss with him
some further documents. One would be an opinion by the Office
of Legal Counsel at the U.S. Treasury Department in 1979, a
Democrat administration, 3 U.S. opinion O.L.C. 31, in which
there is some discussion, not directly on point with regard to
the use of the word ``receive'' in the statute. It deals
primarily with the location. But there is language in there
that indicates very clearly that the issue of ``receive'' is
not black letter law the way Mr. Dennis may wish it to be. And
certainly he is your advocate and I understand his position and
he argues it very eloquently, as always.
Mr. Dennis. Could you give me that citation again?
Mr. Barr. 3 U.S. opinion O.L.C. 31, and there are a number
of footnotes that relate to the issues that we are speaking
about here.
Mr. Dennis. 1979?
Mr. Barr. Right. I would also, Ms. Williams, direct your
attention to 18 U.S.C., section 607. There has been some
discussion and I think an effort on the part of the folks on
the other side of the aisle to deliberately misconstrue this.
Section 607 has two parts to it, (a) and (b); (a) is the
operative part that we have been talking about here that states
very, very clearly that any person defined as we have seen in
603, any person who is paid by funds drawn on the U.S. Treasury
cannot solicit or receive contributions for Federal elections
in any room or building occupied in the discharge of official
duties, so on its face I think very, very clearly it applies to
your situation.
Section or subsection (b) of the statute, which has been
referred to by folks on the other side, has nothing whatsoever
to do directly with your situation. It deals very explicitly
with Representatives or Senators. It very clearly does not
refer and does not cover members of the executive branch. And
that is the provision that allows for persons in Senate or
Representative offices to receive unsolicited checks or moneys,
and then transfer those within 7 days, so if anyone in your
situation were relying on that as a defense, I think they would
be sorely disappointed. I think if anybody in your situation
were relying on the defense that it would be rude to abide by
the statute, they could be sorely disappointed as well.
My point is that we have a law here. We also have an
opinion and a review of Federal laws, including criminal laws,
by Mr. Mikva, the Counsel to the President, not quite
contemporaneously but within a month or so of what we are
talking about here. That does not go into the detail that your
counsel did in giving us his opinion. And I think that is very
revealing.
The memorandum of April 27, 1995, that I referred to
earlier and that has been put forward as exhibit 153, states
very clearly that no person in your situation can receive
campaign moneys. It does not have any convoluted definition of
what exactly ``receive'' means. As a matter of fact, it says it
means a commonsense definition, which means somebody hands you
something and you take it. It does also, as the Federal
statute, have an explicit and an express exception for things
received by mail.
The fact that both this opinion and the statute that I
referred to have express exemptions for certain activities
leaves one very clearly under rules of statutory construction
with the conclusion that other activity that does not fall
within those exemptions is, in fact, covered. And I would,
therefore, repeat that under your testimony under oath today, I
believe that a case very clearly has been set forward of a
violation of 18 U.S.C. 607(a).
Now, what this Department of Justice wishes to do with that
is certainly not anything over which we have concern. That has
been obvious for quite some time. But for folks on the other
side to say there is no evidence of this, and the statute does
not apply, I think is laughable. The statute is very clear. The
opinion of the White House by Abner Mikva is very clear. One
could certainly argue about the fine points of it, but I think
you have a serious problem here.
Mr. Cox. Mr. Barr, would you yield for just a moment?
Mr. Barr. Happy to yield to the gentleman from California.
Mr. Cox. There is something else in the White House
Counsel's memo that concerns me. In addition to stating clearly
that White House employees may not ever accept a political
contribution from any person----
Mr. Barr. If the gentleman would yield back just for a
moment, I have one point that I do want to make before my time
expires and that is that I do intend to write a letter to the
Attorney General requesting prosecution because I think very
clearly there is a violation of the law. Mr. Dennis obviously
does not agree, but I think that is a clear----
Mr. Cox. Will the gentleman yield? If I could just finish
the point, that the memo says that one should please consult
our office, the Counsel's Office, before undertaking any action
implicating an exception to this general prohibition, and I
would wonder why Ms. Williams did not contact the Counsel's
Office if it is, as you say, extraordinary to receive a $50,000
check.
Mr. Burton. The gentleman's time has expired. The
gentlewoman can answer.
Mr. Dennis. If I might, Mr. Chairman, again my client is
not a lawyer. I would point out that the regulations that I
cited which define official acceptance and receipt under the
statute in question, the interim regulation were published in
1994, which is some 15 years after this O.L.C. U.S. opinion,
whatever it might say, and that the final regulations were
adopted in 1996 and the citations set forth in my letter some 2
years later.
Mr. Burton. The gentleman's time has expired. Does that
conclude your comments?
Mr. Dennis. Just one other thing. The Counsel's Office,
White House Counsel's Office, also agrees with that
interpretation, the interpretation that I have stated here. And
it is in writing in various documents.
If I might, Mr. Barr, before you write a letter to the
Department of Justice, I hope you will accept something in
writing from me addressing specifically the points that you
have made in your last statement, and Mr. Cox as well. I'll
address that to you as well.
Mr. Burton. Did that conclude the last part of the
question?
Mr. Cox. Mr. Chairman, I have a pending question to the
witness. The counsel is certainly entitled to speak and I am
pleased that he did so.
Mr. Waxman. Mr. Chairman, regular order. I think Mr. Barr
had the time. His time has expired.
Mr. Barr. And I did yield for that final point and he was
in the middle of asking it.
Mr. Burton. Go ahead. You may answer it.
Ms. Williams. I am sorry; what is the question?
Mr. Cox. The question is, why you did not, even though the
advice of the White House Counsel was before implicating any
exception to the prohibition on accepting a contribution, you
should contact the Counsel's Office, why, if it's so unusual
for you to receive a $50,000 check or a check at all because
you have testified that this was the only time it happened, why
you did not contact the White House Counsel's Office?
Mr. Burton. Let her answer.
Ms. Williams. I didn't think of it. I was in a situation,
just human, I guess. Didn't have the memo in front of me when
it happened. I just acted.
Mr. Burton. Mr. Sanders.
Mr. Sanders. Thank you, Mr. Chairman. I would like to yield
to Mr. Fattah.
Mr. Fattah. Thank you, Mr. Sanders.
Let me--last week we had a witness here, a Deputy Counsel
to the White House and she was accused of obstructing justice
and now you have been accused of violating the criminal code.
There are a lot of allegations flying around but, nonetheless,
just so we can settle to the facts one more time. The DNC has
returned every dollar that was received from Johnny Chung, even
though there is no evidence at this moment that any of those
dollars were illegal in any respect. And all of his
contributions, with the exception of the check that was handed
to you, were sent through some other mechanism. And so if one
is chasing foreign contributions they would not just be
focusing in on this one incident.
Congressman Cox asked you when you arranged for these
strangers to meet with the President on that Saturday, did you
and so on--you never testified that you arranged such a
meeting, right? You didn't arrange for them to go into the
press conference at all, radio address.
Ms. Williams. Right.
Mr. Fattah. So that was never your testimony. And as far as
you were concerned, and your counsel is concerned, contrary to
all of this, these wild allegations, you don't believe that by
accepting this check and passing it on that you violated any
criminal statute or any civil statute and it was not your
intent to; was it?
Ms. Williams. No, of course it was not my intent to.
Mr. Fattah. I know you are probably amazed at the hypocrisy
of the Members here on the Hill. We had the chairman of the
Republican Conference handing out checks on the floor of the
House from the tobacco industry in which Members on the other
side of the aisle thought that this was just fine and dandy and
now here they are--if they have a political problem with the
President, I'm sure the President can handle it. You did
nothing other than receive this check and send it to the DNC.
If you were working here as the chief of staff to a Member of
Congress, you would have had 7 days to do that and not violated
any law. Don't you think that the rules reasonably assume that
there may be circumstances in which citizens, and Mr. Chung is
a citizen of the United States, may make a contribution and so
that it not be an unlawful situation that you can just pass
that check along? Don't you think that that law makes a lot of
common sense?
Ms. Williams. Well, I've refused to give my opinion. On any
of this.
Mr. Fattah. Fine. You need not share your opinion. I just
want to make it clear that you did not solicit the contribution
from Mr. Chung, that you did not do anything other than forward
in an administrative way through someone else in the office the
check over to the DNC.
Ms. Williams. That's correct.
Mr. Fattah. Is that correct?
Ms. Williams. That is correct.
Mr. Fattah. And at this point in time you have appeared
voluntarily before the committee?
Ms. Williams. Yes.
Mr. Fattah. And that notwithstanding the abuse, at least
what I think has been abusive allegations of criminal conduct,
which is obviously an attempt to smear your good name, you have
served this country faithfully for many years in a high public
office, and I want to thank you for your service, and I want to
wish you well.
Ms. Williams. Thank you.
Mr. Sanders. I take back my time and yield it to Mr.
Barrett.
Mr. Barrett. Thank you, Mr. Sanders.
What I would like to do is take a minute or two. Evan Ryan,
who is Ms. Williams' aide, is not here today, but she was--her
deposition was taken by minority counsel. And what I'd like to
do is read key excerpts from her testimony into the record. I
think that they are relevant here for several moments. This is
from her deposition:
Question: Second sentence, ``He showed her the business
cards of his Chinese companions and asked if arrangements could
be made for them to eat lunch in the White House Mess.''
Mr. Burton. Excuse me. What page are you on so we may
follow you?
Mr. Barrett. I don't have the page number here.
Mr. Burton. There should be a page reference on the top.
Mr. Barrett. I have it retyped.
Mr. Burton. OK. We will try to figure it out.
Mr. Barrett. Quote,
He showed her the business cards of his Chinese companions
and asked if arrangements could be made for them to eat in the
White House Mess and meet Hillary Clinton. Quote, to the best
of your recollection are all the elements of that response
correct? Answer: No.
Which ones are incorrect? Answer: He never showed me
business cards on that day and he also asked about the radio
address and a tour of the White House.
Question: Quote, Chung also asked if there was anything he
could do to help the White House? Quote, is that sentence
correct? No.
Question: And how is it incorrect? Answer: That day he
stated he was making a contribution to the DNC, quote.
Then we move down. New section.
Question: Then she said, quote, Maybe you can help us,
unquote. Is that sentence correct? Answer: No.
How is that incorrect? I didn't say anything about helping
us. I mentioned that we were going to check and see if we could
set up any of the things he was hoping to set up.
Question: The next paragraph reads, quote, the aide told
Chung that the First Lady had some debts with the DNC from
expenses associated with White House Christmas parties, quote.
Is that sentence correct? Answer: No.
And question: How is it incorrect? Answer: I never
discussed expenses and that Christmas with Mr. Chung.
Question: The next sentence reads, quote, Chung believes
that Ryan mentioned a figure of $80,000, quote; is that
sentence correct? Answer: No.
How is that incorrect? Answer: I never mentioned a figure
of $80,000. I never mentioned any.
Question: Skip the next paragraph because it is a
parenthetical not bearing on facts.
Paragraph following that reads, quote,
Ryan told him Chung said that she was relaying the question
on behalf of Williams who hoped Chung could help the First Lady
defray these costs, quote. Is that sentence correct? Answer:
No.
Question: And how is it incorrect? Answer: I was not
relaying anything on behalf of Maggie Williams regarding
defraying costs of the First Lady.
And we go down.
Question: We have already covered that. I apologize for
bringing it up again.
The next sentence reads, quote, and Lewis said Ryan is sure
that she had no discussion of financial contributions with
Johnny Chung, quote; is that sentence correct? Yes, and no
discussions he made that statement to me, but there were never
any discussions.
I just wanted to make sure that--these are questions from
minority counsel and I wanted to make sure those were in the
record.
Thank you, Mr. Chairman.
Mr. Burton. The gentleman's time has expired. The last
person to question will be Mr. Shadegg. Even if somebody else
comes in.
Mr. Waxman. You can't do that. I hope nobody else comes in
but you can't do that.
Mr. Burton. I will assume that Mr. Shadegg will be the last
person to question and we will then break for 10 minutes.
Mr. Shadegg. Ms. Williams, following on this deposition,
because I don't know what pages of the deposition they were
reading from, but I have the same deposition, a deposition of
Mrs. Evan Ryan who is not here today. She is out of the country
and not available. Although I think at some point in time she
will be before this committee and I am trying to get some
clarification.
We, for example, know that Mr. Chung was seeking some
things from the White House. And everybody has agreed on that.
We also know that at one point in time Mr. Chung tendered a
$50,000 check and you accepted that $50,000 check. But I have
some questions that go to this deposition that Mrs. Evan Ryan
gave. For example, in that deposition Mrs. Evan Ryan says point
blank----
Mr. Dennis. What page?
Mr. Shadegg. I do have a page. Page 109, line 16.
Mr. Dennis. 109, line 16, OK. I'm sorry for being slow.
Mr. Shadegg. What did you tell Mrs. Williams? I told her
that Johnny Chung was here and that he had some businessmen
from China and that he was hoping to get a tour, the radio
address, the Mess, and the photo with Mrs. Clinton. And he was
also going to donate money to the DNC while he was here.
Do you see that question and that answer? Now, what I want
to do is clarify for the record, do you recall her telling you
that Johnny Chung was there, and that he had businessmen from
China with him?
Ms. Williams. On what day is this? The same----
Mr. Shadegg. I presume it's March 9th, because the radio
address was on March 11th and we know that Mr. Chung did, in
fact, attend the radio address with the Chinese colleagues.
Even if we can't pin down a date, did you have a conversation
with Mrs. Evan Ryan, whom I think you knew well, in which she
indicated that Mr. Chung was there and that he was anxious to
get a tour, a radio address, a visit to the Mess and a photo
with Mrs. Clinton and in which Mrs. Evan Ryan said to you he
was also donating some money to the DNC while he was here?
Ms. Williams. I don't recall this conversation exactly. I
know that she said that Johnny Chung was here, and told me
about the photo and wanting the photo and wanting to eat at the
Mess. That's what I recall.
Mr. Shadegg. It is very important for us to figure out who
is right and who is wrong. We are trying to get to the bottom
of this and we have two conflicting stories.
Ms. Williams. I am not saying necessarily that they are
conflicting stories. I am saying----
Mr. Shadegg. I am trying to find out the degree to which
they conflict.
Ms. Williams. She may have a more specific recollection of
some of these issues simply because her job was to deal with
these requests. With all due respect, as Chief of Staff to the
First Lady, these were among some of my concerns but
necessarily not my primary concerns. So, you know, I absolutely
remember----
Mr. Shadegg. Can we just walk through the other things that
she said so that you will have an opportunity to say whether
they are true or not true or you recall them or whether you
just have no recollection?
Ms. Williams. Fine.
Mr. Shadegg. She then gets asked again the question: You
told her what he wanted and you told her at that time he was
going to donate money to the DNC? And Mrs. Williams reaffirms
that. You still have no recollection.
Ms. Williams. I'm sorry, I don't----
Mr. Shadegg. I'm sorry, Ms. Ryan reaffirmed that.
Ms. Williams. Could you give me what is the question?
Mr. Shadegg. There is a reaffirmation by Mrs. Ryan that she
told you two things. One, he wants a tour, a radio address, the
Mess, and the photo with Mrs. Clinton, and he's making a
donation to the DNC. She's now said that very clearly at two
different points, as you can see. Now we are looking at lines
22 to 24 which your counsel has showed you. Do you have a
recollection of that?
Ms. Williams. I have a recollection definitely of the Mess
and of the photo and that Mr. Chung was there.
Mr. Shadegg. No recollection of being told about the fact
that he was making a donation to DNC?
Ms. Williams. No, I don't.
Mr. Shadegg. Let's go to page 110, lines 6 through 9. Here
she gets very specific and she talks about what you said back
to her. She said that you had said to her we could see if we
could get those things for him, and that you said it was
helpful to know about this donation because then that maybe the
DNC would be able to pay off some of their debts.
Ms. Williams. No, I don't have a recollection of this, and
Mr. Chung had, prior to I guess March 9, already been a
contributor to the DNC and had been making donations to the
DNC. So, I guess I think news about a donation from Mr. Chung
would not strike me as extraordinary or unusual.
Mr. Shadegg. So you are saying that you didn't say it was
helpful to know about the donation?
Ms. Williams. No, I don't recall saying that.
Mr. Shadegg. We then go on. You were aware of the debt,
though; is that right? The debts by the DNC to the White House
were significant?
Ms. Williams. Oh, I was aware. Lots of people were aware.
Mr. Shadegg. Going on to page 112, lines 12 through 16.
Ms. Williams. Uh-huh.
Mr. Shadegg. Mrs. Evan Ryan again says that you had said it
was helpful to know and that getting this donation, maybe it
will help with some of the debts in the White House. So she
again says that your response----
Ms. Williams. Well, I think you should read--first she
says, oh, I don't know.
Mr. Shadegg. Right. But it was something along the lines of
that's helpful to know that they're getting this donation,
maybe it will help with some of the debts. So, again, she
quotes you as being aware that he's going to give a donation to
the DNC.
Ms. Williams. Well--OK, I just want to make sure that there
are two things, because what you have read has been the lines
that are in between. What you haven't read or the first thing
is ``When Ms. Williams had mentioned that she seemed pleased to
you''--this is the question ``that Mr. Chung mentioned he was
going to donate to the DNC, do you have any idea how she knew
that perhaps that donation would go to pay off some debts?''
``Oh, I don't know,'' it says.
Mr. Shadegg. And then?
Ms. Williams. Then it was more, I don't remember exactly
what she said.
Mr. Shadegg. And then that's where I began reading.
Ms. Williams. ``It was something along the lines of that's
helpful to know, that they're getting this donation, maybe it
will help with some of the debts that they owe the White House.
That's the general gist of what I got from her. I don't know.''
Mr. Shadegg. Once again, she is saying that she made you
aware that he was going to make a donation to the DNC and that
you said--she's now said it twice and she's used the exact same
phrase twice--that your response was, that's helpful to know.
Ms. Williams. Could you explain to me then what the meaning
of her saying ``I don't know'' at the end of that?
Mr. Shadegg. Sure. That was a response to the question put
to you; how did you, Mrs. Williams, know about the debt to the
DNC. That's a different issue.
Ms. Williams. There are two ``I don't knows.'' There's a
top one and a bottom one.
Mr. Shadegg. That's right. But there are still--your bottom
line testimony is even though she says at two different
points----
Ms. Williams. I have no recollection.
Mr. Shadegg [continuing]. That you responded saying it was
helpful, that you have no recollection of that.
Ms. Williams. No, I do not.
Mr. Burton. The gentleman's time has expired. I want to
thank you, Ms. Williams, for your patience and your legal
counsel and everybody else who is with you here, Lanny. I know
it has been a difficult time for you. I hope you have a safe
trip back to Paris with your new husband and that everything
goes well with you, and once again thank you very much for your
help. We appreciate it. We stand in recess for 10 minutes.
[Recess.]
[The depositions of Margaret Williams, Evan Ryan, and Gina
D. Ratliffe follow:]
Executive Session
Committee on Government Reform and Oversight,
U.S. House of Representatives,
Washington, DC.
DEPOSITION OF: MARGARET WILLIAMS
Wednesday, August 27, 1997
The deposition in the above matter was held in Room 2247, Rayburn
House Office Building, commencing at 10:06 a.m.
Appearances:
Staff Present for the Government Reform and Oversight Committee:
Barbara Comstock, Chief Investigative Counsel; Jennifer M. Safavian,
Investigative Counsel; Sophia Nelson, Counsel; Kevin Binger, Staff
Director; David N. Bossie, Oversight Coordinator; Kenneth Ballen,
Minority Chief Investigative Counsel; Kristin Amerling, Minority
Counsel; and Andrew McLaughlin, Minority Counsel.
For Ms. Williams:
EDWARD S.G. DENNIS, JR., ESQ.
Morgan, Lewis & Bockius, LLP
1800 M. Street, N.W.
Washington, D.C. 20036-5869
Ms. Comstock. We can get on the record here.
Good morning, Ms. Williams. I would like to begin by thanking you
on behalf of the members of the Committee on Government Reform and
Oversight for appearing here today.
This proceeding is known as a deposition. The person transcribing
this proceeding is a House reporter and notary public. I now request we
have you sworn in. We have a notary public here to swear you in.
THEREUPON, MARGARET WILLIAMS, a witness, was called for examination by
Counsel, and after having been first duly sworn, was examined and
testified as follows:
Ms. Comstock. I would like to note for the record those who are
present at the beginning of this deposition.
My name is Barbara Comstock. I am the designated Majority counsel
for the committee. I am accompanied today by Jennifer Safavian, who is
also Majority counsel. Minority counsel today is Ken Ballen, who is
accompanied by Kristin Amerling. The deponent is represented by Mr.
Dennis. The deponent this morning is Margaret Williams.
Although this proceeding is being held in a somewhat informal
atmosphere, because you have been placed under oath, your testimony
here today has the same force and effect as if you were testifying
before the committee or in a courtroom.
I would like to note for the record, also, the committee's Staff
Director, Kevin Binger, who just entered the room, so you know.
As we go along, just so you know, various members of Minority and
Majority staff often come in, so, if you would like, we will identify
them; but nobody else besides staff are allowed to come into the room.
Mr. Ballen. Or Members of Congress.
Ms. Comstock. Or Members, yes. It is recess, but I know we have a
few.
If I ask you about conversations you have had in the past and you
are unable to recall the exact words using the conversation, I would
ask you please state that you are unable to recall exact words but
still, to the extent you can recall, give the gist or substance of any
such conversation to the best of your recollection. If you recall only
part of a conversation or only part of an event, please provide us with
the best recollection of those events or parts of conversations that
you do recall.
If I ask you whether you have any information about a particular
subject and you have overheard other persons conversing with each other
regarding it or have seen correspondence or documentation regarding it,
please tell me that you do have such information and indicate the
source, either a conversation or documentation or otherwise, and how
you derived such knowledge. In other words, it is not just personal
knowledge that you learned firsthand but other information you may
know. Please indicate how you know that so that we can indicate for the
record and you can make clear that you got something thirdhand or
secondhand or you really don't know if it is true but this is what you
heard.
Before we begin the questioning, I want to give you some background
about the investigation and your appearance here. Pursuant to its
authority under House Rules 10 and 11 of the House of Representatives,
the committee is engaged in a review of possible political fund-raising
improprieties and possible violations of law within the committee's
jurisdiction.
Pages two through four of House Report 105-139 summarizes the
investigation as of June 19, 1997, and encompasses any new matters
which arise directly or indirectly in the course of the investigation.
Also, Pages four through eleven of the report explain the background of
the investigations. All questions related either directly or indirectly
to these issues or questions which have a tendency to make the
existence of any pertinent fact more or less probable than it would be
without the evidence are proper.
The committee has been granted specific authorization to conduct
this deposition, pursuant to House Resolution 167, which passed the
full House on June 20, 1997. Committee Rule 20, of which you received a
copy, outlines the ground rules for the deposition.
Majority and Minority counsels will ask you questions regarding the
subject matter of the investigation. Minority counsel will ask
questions after Majority counsel has finished. After the Minority
counsel has completed questioning you, a new round of questioning may
begin. Members of Congress who wish to ask questions will be afforded
an immediate opportunity to ask their questions. When they are
finished, committee counsels will resume questioning.
I would also like to note for the record that we also have another
Majority attorney present. Sophia Nelson is with us also this morning.
Pursuant to the committee's rules, you are allowed to have an
attorney present to advise you of your rights. Any objection raised
during the course of the deposition shall be stated for the record. If
the witness is instructed not to answer a question or otherwise refuses
to answer a question, Majority and Minority counsel will confer to
determine whether the objection is proper. If Majority and Minority
counsels agree that a question is proper, the witness will be asked to
answer the question. If an objection is not withdrawn, the chairman or
member designated by the chairman may decide whether the objection is
proper.
This deposition is considered as taken in executive session of the
committee, which means that it may not be made public without the
consent of the committee. Pursuant to clause 2(k)(7) of House Rule XI,
you are asked to abide by the rules of the House and not discuss with
anyone other than your attorney this deposition and the issues and
questions raised during this proceeding.
Finally, no later than 5 days after your testimony is transcribed
and you have been notified that your transcript is available, you may
submit suggested changes to the chairman.
I would just like to add for the record that we have been working
with Minority counsel on this and if you need additional days--I
understand your counsel is out of town. I think you may be out of town,
too; is that correct?
The Witness. That is correct.
Ms. Comstock. We can make arrangements, mailing it to you, and have
waived that with the consent of the Minority in situations where you
have physical proximity and distances, that you need to accommodate
that.
The Witness. Can I ask a question? With respect to making the
deposition public, now the deposition is made public by the committee
when the committee chooses to do so?
Ms. Comstock. It has to be by vote of the committee.
The Witness. By vote of the whole committee?
Ms. Comstock. Yes.
The Witness. That would only be after I reviewed my deposition?
Ms. Comstock. Exactly. And just so you know, the depositions, when
they become available and we get the transcript before it has been
corrected, the Minority does get a copy of the uncorrected version, as
do we, but then nothing would ever been be an official copy until you
have the opportunity to review and make the changes. I will go into
that a little bit on the changes but, just so you know, there are
copies that are circulated to the Majority and Minority staff.
The Witness. That are uncorrected but still not made public prior
to?
Ms. Comstock. Exactly. And it is the committee's responsibility--
Majority and Minority responsibility to make those corrections and make
sure they are accurate for the record.
The transcript will be available for your review at the committee
office or, as we discussed, we can mail it to you. And when we do mail
it, we ask you sign a form that it hasn't been copied or shared with
anyone because, since it is an executive session, it is not made public
and none of our copies physically go outside of our offices. Even our
members have to come in to see copies of the actual deposition.
The Witness. Okay.
Ms. Comstock. Substantive changes, modifications, clarifications or
amendments to the deposition transcript submitted by you must be
accompanied by a letter requesting the changes and a statement for your
reasons for each proposed change. A letter requesting any substantive
changes, modifications, clarifications or amendments must be signed by
you. Any substantive changes, modifications, clarifications or
amendments shall be included as an appendix to the transcript,
conditioned upon your signing the transcript. I believe we also make
typographical changes within the body of it and technical changes like
that.
Do you understand everything we have gone over so far?
The Witness. Yes, I do.
Ms. Comstock. Do you have any questions?
The Witness. No.
Mr. Dennis. I just want to put on the record that Jim Wilson and I
had a conversation when I believe the issue of trying to set a date for
the deposition was decided upon and, at that time, I asked him about
the scope of the deposition. He advised me that it focused primarily on
this Chung matter, and I asked him if there were other areas that might
be inquired, and he said that he would let me know a little closer to
the deposition.
I have not heard back from him, so we are operating on the
assumption that it is going to be confined to the political fund-
raising and primarily this Chung issue and some related areas. But in
terms of being prepared to get outside of that, you know, if we get
into an area that my client hasn't had a chance to really consider, I
will let you know, but that is one thing I have some concerns about.
Ms. Comstock. I am sorry if there has been any misunderstanding on
that, and I think that will encompass--we are going to go through the
general fund-raising issues and matters of how, you know, in the First
Lady's office, any involvement in any of those matters.
Mr. Dennis. No problem with that.
Ms. Comstock. And then, obviously, the issues of Mr. Chung. There
is some matters relating to Mr. Hubbell that I think we will briefly,
you know, some of these areas----
Mr. Dennis. We can go through that.
Ms. Comstock. The main characters--John Huang, Charlie Trie, the
Riadys--the general people I think you are familiar with in the
newspapers. I think most of the things should fall within that area.
Mr. Dennis. None of those areas would present any problems.
Mr. Ballen. And I have a statement I want to put on the record as
well.
First of all, it was mentioned--and this is the first time I have
heard it--that hearsay is appropriate. In other words, if you learn
things second- or thirdhand, to let us know that. I think in the
Minority we would take a very dim view if we are going to start getting
hearsay for the depositions.
Technically, it is not excluded here because we don't operate under
Federal rules of evidence, but it has been excluded from both civil and
criminal trials. And our Anglo-American jurisprudence for some 300
years and for very good reasons--because it is not reliable, no one can
confront the accuser and other reasons; and I think it would be
inappropriate if we started in this forum to rely on that.
So that is one thing for the record; and certainly today, if there
is anything you do not know firsthand, you should identify it as such.
Ms. Comstock. I think my statement was to make clear that
oftentimes people have heard something from somebody else, that
somebody told me that there was a contribution made, I do not know that
firsthand. What we are asking for is--we aren't just asking,
necessarily--that you clarify for the record so that it is clear when
someone is making a statement where the information comes from. That is
the statement we have been reading at the beginning of the deposition.
Mr. Ballen. Our view--and we will have to work this out between
ourselves, but today you can identify. But our view is that kind of
evidence is not appropriate.
Ms. Comstock. I don't think we have a disagreement. I think we just
want to have the witness make clear her knowledge of that information.
Mr. Ballen. That would be fine.
The other thing I wanted to point out is under House Rule XI,
2(k)(a), objections as to relevancy and pertinency are ultimately
matters for the committee to decide. In other words, if the Chair makes
a ruling on an objection to relevancy or pertinency, that is appealable
to the committee; and it is the province of the committee to ultimately
rule under the House Rules as to those kinds of objections.
Thank you very much.
Ms. Comstock. This morning I will be asking you questions
concerning the subject matter of this investigation. If you don't
understand a question, please say so and I will repeat or rephrase so
you understand the question.
The reporter will be taking down everything you say and will make a
written record of the deposition. It is important you give verbal,
audible answers because the reporter cannot record what a nod of the
head or other gesture may mean.
If you can't hear me, please say so and I will repeat the question
or have the reporter read back the question to you.
I would ask that you wait until I finish each question before
answering and I will wait until you finish your answer before I ask the
next question so that we don't end up going over each other in the
record.
Your testimony is being taken under oath this morning as if we were
in court, and it will be assumed you understood the question and the
answer was intended to be responsive to it.
Are there any questions you have about those matters?
The Witness. No.
Ms. Comstock. Are you here voluntarily this morning or as a result
of the subpoena?
Mr. Dennis. Well, voluntarily.
I'm sorry. You are here voluntarily.
The Witness. I am here voluntarily.
EXAMINATION BY MS. COMSTOCK:
Question. Okay. If we can get started. Just give your full name for
the record.
Answer. Margaret Williams.
Question. And I am going to skip over what we have gone through
before on previous depositions. I am going to skip over the usual sort
of background, if that is okay?
Answer. I appreciate it.
Question. Okay. Could you just update us, though, on when you left
the White House?
Answer. May 3rd, 1997.
Question. And where are you currently working?
Answer. In my home, packing boxes.
Question. Have you been asked by the White House counsel or anybody
else at the White House to collect documents for any of the subpoenas
or document requests from this committee?
Answer. Yes, I was asked by my counsel to--in response to a letter
he received from the committee to check personal materials to see if
they were things that were responsive.
Question. All right. And are you aware of document reviews being
done in your offices at the White House?
Answer. I assume so. Generally, White House counsel does that.
Question. And who was in charge in particular in gathering
documents from the First Lady's office?
Answer. I am sorry. I do not.
Question. Do you know, in general, that there has been a person
designated in the First Lady's office to assist the White House
Counsel's Office in gathering documents?
Answer. Depending upon the request--depending upon the request and
the area, it would differ. White House counsel in the past goes through
phone records, goes through--I mean, they physically do it.
Question. Could you describe how you have kept your records--how
you kept your records while you were at the White House?
Answer. How I kept them?
Question. What kind of files--if you had correspondence files,
phone logs, the type of different things that you maintained routinely.
Answer. Routinely, exactly that--correspondence, phone messages,
schedules, news clips, subject files, foreign trip files--I can't
remember--speech files. I mean, the whole compliment of files that
might be in an office.
Question. And who maintained those files generally in your office?
Answer. Evan Ryan, generally; interns at other times, volunteers.
It has varied.
Question. Did you routinely keep correspondence that were sent to
you then? You said alphabetic files or chronological files?
Answer. Depending on what it was. I was not a very good file
keeper. Depending on what--on the area, it might be chron or it might
be alphabetic. On a foreign trip file, for instance, I probably did
that by chron and, inside that, alphabetically. On correspondence
files, chron or alphabetically, although we had a different file for
health care correspondence, for instance. So it just--I mean, kind of
whatever the particular issue was, whatever was easiest to get to is
how we kept them.
Question. Do you know, on the foreign trip files, was that when the
First Lady went on a foreign trip?
Answer. Well, actually, it was when I did a pre-advance for the
foreign trip. Most of the official records for her trip would be kept
in the scheduling office. I tried hard never to actually duplicate any
file. If I thought somebody else had them someplace, I usually did not
keep them.
But in the foreign trip file, for instance, it would be the pre-
advance. It would be all of the things that we looked at. It would be
my recommendations of what she should do, perhaps the Secret Service
recommendations, that kind of thing. More preparatory.
Question. Would that include people who wanted to go on those trips
or be involved in those trips, correspondence you may have gotten about
requests to be involved?
Answer. Generally, on her trips on the plane, there was only press
that was carried with her on trips. There wouldn't be--I am sure there
were people who wanted to go; but, as a general rule, I didn't get
correspondence about who wanted to go. That might fall under more, you
know, substantively who wanted to go. I didn't generally get those
kinds of requests.
Question. While you were at the White House, beginning last fall
when revelations about John Huang and some of these fund-raising issues
first came to light, did anyone from the counsel's office come to your
office or send any kind of memos asking you to collect documents
pertaining to any particular individuals?
Answer. I am sure they did.
Question. Do you recall any memos that were sent around by the
counsel's office?
Mr. Ballen. Can we have a time frame on this?
Ms. Comstock. Starting last fall.
Mr. Ballen. Before the subpoenas were issued by the committee?
Ms. Comstock. Actually, this committee initially made requests
under the previous chairman in October of 1996--in November of 1996. I
believe the counsel's office did. I mean, we received--and I won't play
hide the ball with you here. We did receive information that they were
starting to request documents back there, and some memos went out.
examination by ms. comstock:
Question. What I am trying to get a sense of is your familiarity
with that and what actions may have been taken, particularly in the
First Lady's office, in response to those.
Answer. Although I can't tell you specifically what memos were sent
and at what time, I do remember a series of, it seems to me, a series
of memos that were sent asking for information about John Huang, about
the Riadys and two or three other names that I wasn't necessarily
familiar with.
Generally, when that happens in our office, we would send a copy of
that to everybody. But, generally, counsel's office is fairly good at
making certain that the entire place was papered. And then there would
be a deadline; and then there would be someone who would follow up from
the counsel's office to say, have you looked here? Have you looked
here? What have you got? Please send it to us.
That was the routine. Although I can't remember a specific date,
that was our routine based on past requests that we had had.
Question. And do you know, in fact, if your office did begin
providing documents, when they did begin providing documents?
Answer. I would say that, in general, that we in my office were
very responsive. So if there were documents that were requested, they
were turned over to the White House Counsel's Office.
Question. Okay. Now if you had documents, for example, with--that
were from '93 or '94 that may have been responsive, would those have
already been cataloged and filed away in another room or office?
Answer. No, probably not. Probably not.
Question. They probably still would have been maintained?
Answer. They probably would have been maintained within the office
at that point. Although, I mean, '93, '94--I mean, it would depend. I
mean, it would depend on what was there, if we still had them.
Question. And so while you have been there, you have not--I mean,
prior to your leaving in May, you didn't box up any particular areas of
things you were working in and move them out?
Answer. Yes, I did box some. What I did was to leave the--in the
office, because most of them I thought might be continuous files and
people would want to work off of them.
Question. I'm sorry, are you talking about when you left----
Answer. Right.
Question. I am talking about before you left, while you were there,
if--you started January 20, 1993?
Answer. Right.
Question. Then you left in May of this year?
Answer. Right.
Question. Prior to leaving, had you had occasion to box up any of
your correspondence or--if it had been anyplace before you left?
Answer. Right.
Question. Besides your office?
Answer. I didn't myself box up. I know that after the health care
project that we did box health care files and I guess move them to
wherever the files go in the White House, I assume record management. I
am not intimately familiar with that. I would probably say, you can box
up the health care files or, you know----
Question. Okay. I would like to discuss with you while you were at
the White House any DNC employees that you had working with you in the
First Lady's office in particular, if you recall that and how that came
about?
Answer. I don't recall that I did have any DNC employees working in
the First Lady's office.
Question. On health care matters or anything like that?
Answer. No, the DNC actually had a health care campaign that was
based at the DNC, that was based at the DNC, so they had their own
project and their own staffing. And, obviously, around substantive
issues, we would confer with them, but I really don't know of DNC staff
working on health care at the White House.
Question. Any DNC interns, anything like that that you recall.
Mr. Ballen. Working in the First Lady's office?
The Witness. Oh, working in the First Lady's office. I can't
recall.
EXAMINATION BY MS. COMSTOCK:
Question. Or working on health care matters in general, maybe not
physically located in the First Lady's office.
Mr. Ballen. Your question is not whether there are any DNC
employees working on health care matters but whether they are working
at the White House or the First Lady's office.
Ms. Comstock. I am really asking if she is familiar with DNC
employees working at the White House. You know, why don't I go ahead--
--
The Witness. I do know there were DNC employees who worked at the
White House. I do not know of any who worked on health care or
specifically in my office. I can't--I mean, I can't recall.
Ms. Comstock. Let me show the witness CGRO-11946, which is a
document we received from Mr. Ickes; and it is pertaining to DNC
personnel related to White House support.
EXAMINATION BY MS. COMSTOCK:
Question. I am directing your attention to the first area. Sara
Grote worked in the First Lady's office?
Answer. Actually, she worked in advance and scheduling, but she was
detailed to work on First Lady issues.
Question. All right. And do you recall how that came about?
Answer. No, I really don't, because it was done--she actually
worked for advance and scheduling.
Question. Do you recall if you were involved in any discussions
about having DNC employees work at the White House?
Answer. No, I was not.
Question. Directing your attention to the section that says health
care media campaign staff, it has about six names there. Did you work
with any of those folks on health care matters?
Answer. Dwight Holton, I recognize; and Barbara Woolley I
recognize. Jon-Christopher Bua, I recognize, but I believe that he
worked at the DNC.
Question. That is B-U-A, Jon-Christopher Bua?
Answer. The only other person here that I recognize as working at
the White House is Barbara Woolley, and I believe she worked for public
liaison. I was not aware until after media reports that she actually
was--she actually worked for the DNC.
Question. Okay. And your testimony is that you don't recall any
discussions about having DNC employees work at the White House or any
matters related to that?
Answer. No. I do recall press reports about this.
Question. Referring to press reports this year?
Answer. Yes. I don't know if it was this year, but--I don't know if
it was this year or last year. I can't really speak to that. But with
the exception of Barbara Woolley, who I thought worked for public
liaison, I thought these people--some I don't recognize, but others I
thought worked at the DNC.
Ms. Comstock. Okay. We will make that Deposition Exhibit 1.
[Williams Deposition Exhibit No. MW-1 was marked for
identification.]
[Note.--All exhibits referred to can be found at end of
deposition.]
Ms. Comstock. And this is EOP 59044. It is a document received from
the White House, which I believe is a message pad kept at your office;
and there is a phone message here attached from May 22nd. It doesn't
indicate the year on here, but it is very difficult to read on the
first page, but I believe it may be '95. But I think we can all agree
it is hard to read, so it could be '93, '94 or '95.
Answer. Where does '95----
Question. I'm sorry. On the front page there. That is the message
pad it was from.
We could try to further clarify. I don't want to make any
representations on the record, but here it is. When we tried to
highlight that and figure that out, '95 is our best bet.
But I think it's a message to Maggie from Adam in Leon Panetta's
office. It is regarding a meeting from the Chief of Staff Office, re:
DNC Employees Working at the White House.
Now as we have discussed, it is difficult to read the year, but I
am wondering if you recall anything in '95, in general, any issues
around May of '95 regarding White House employees----
Answer. No.
Question [continuing]. Working at the White House you may have
discussed with Mr. Panetta?
Answer. No, I don't.
Question. Okay.
Answer. No.
Ms. Comstock. Okay. I will make that Deposition Exhibit No. 2.
[Williams Deposition Exhibit No. MW-2 was marked for
identification.]
Mr. Ballen. Would you like the additional staff identified for the
record?
Ms. Comstock. We have Mr. McLaughlin here this morning and Mr.
Bossie.
Mr. Dennis. Who is who?
Ms. Comstock. Mr. McLaughlin is Minority staff; Mr. Bossie is
Majority.
I will show the witness two different documents here: CRGO 1670, a
memo to Martha Phipps that I received from Mr. Ickes; and this is a
second memorandum of May 5, 1994, to Ann Cahill from Martha Phipps, EOP
36287 through 88.
Both of these memos begin by saying, in order to reach our very
aggressive goal of $40 million this year, it would be very helpful if
we could coordinate the following activities between the White House
and the Democratic National Committee. I am reading from the May 5,
1994, memo. The earlier--well, actually, there isn't a date on the
initial one. We have other copies of this. It does have a fax date on
it of March of '94.
Mr. Ballen. Mr. Dennis, would you like a copy as well?
Mr. Dennis. That would be helpful. Thank you.
EXAMINATION BY MS. COMSTOCK:
Question. Actually, the first paragraph, on the earlier memo, says
to Martha Phipps--just discusses coordinating the following activities.
The second memo discusses coordinating the following activities between
the White House and the Democratic National Committee.
I will just ask if you are familiar with either of these documents?
Answer. No, I am not.
Question. Do you know who Ann Cahill is?
Answer. She worked in the political division of the White House.
Question. And that would be--with whom did she work then? Who would
be her direct supervisor?
Answer. Oh, Harold Ickes.
Question. She was in the Deputy Chief of Staff office?
Answer. No, in the political division, it would be one of the
divisions that Harold as Deputy Chief of Staff was the liaison to.
Question. So she was in the political division, and the political
division was an area Mr. Ickes was in charge of?
Answer. Yes, that is correct.
Question. And do you know who Martha Phipps is?
Answer. Martha Phipps worked at the DNC.
Question. All right. And did you have occasion to interact with
Miss Phipps?
Answer. Yes.
Question. And could you describe what those interactions generally
were?
Answer. A broad range of issues, usually having to do with Mrs.
Clinton's schedule for the DNC.
Question. Is that all?
Answer. Well, there would be different kinds of events. A lot of
times they would involve her traveling or standing in as a speaker
somewhere. I mean, it could be any kind of event; but, generally, it
was Martha trying to get her to do the event or trying to get on her
schedule.
Question. And Miss Phipps worked for David Wilhelm in the Chief of
Staff office at the DNC, is that correct?
Answer. I know she worked for David Wilhelm. I wasn't quite sure
how they were organized.
Question. Do you recall at or around sometime in the spring or
summer of 1994 any discussions about utilizing--coordinating activities
between the White House and DNC to raise $40 million or to raise any
amount of money?
Answer. I could not tell you of any specific conversations, but I
would say that there definitely was. Especially around the areas of
scheduling, that it was important that, from my vantage point, that
Mrs. Clinton be available to do fund-raising events for the DNC and
that it was very important to coordinate her schedule so she could do
that.
Question. Okay. The memo here particularly discusses utilizing
things at the White House such as Air Force One trips, White House
private dinner, spots at White House events, the White House mess,
Kennedy Center tickets, photo opportunities in the fund-raising effort.
Do you recall generally discussing utilizing any of these sort of perks
at the White House in connection with fund-raising?
Answer. Quite frankly, not necessarily in connection with fund-
raising.
Our office, which had a great deal to do with being the welcoming
office or welcoming at the White House--because of Mrs. Clinton's role
as national hostess, we were always concerned that we have a broad
range of people at any of the dinners, any of the events, and that
would also include contributors.
Question. But, again, returning to this memo which is discussing--
maybe if you want to take a chance to review it. The second memo has 19
items and contact people to apparently coordinate between the White
House and the DNC. The initial memo only had 10 items. Maybe if we
could focus on the second memo with the 19 items.
Mr. Ballen. I want to note for the record, you say initial memo.
There is no date on the memo.
Ms. Comstock. We have received other copies that do have a March of
'94 date. This copy does not. That is correct.
The Witness. Yes, she is looking at this one.
EXAMINATION BY MS. COMSTOCK:
Question. And directing your attention on this second memo, EOP
36287 through 88, number 16, it says, one lunch with the First Lady per
month, contact Maggie Williams.
Answer. That would be a scheduling issue, and I would hope that
they would contact me or contact the schedule of Patti Solis.
Question. Did you have generally any effort at the White House to
arrange one lunch per month with donors to the DNC?
Answer. Actually, I don't believe that we did one lunch. I don't
think that the one lunch issue ever came up.
I do know that what we did try and schedule was a list of DNC
contributors as well as DNC political people, issue coffees, for Mrs.
Clinton at the White House. So I do not know of one lunch with the
First Lady per month.
And I am sorry, just based on this list--now there could have
been--I don't know if they meant individual donors, but certainly we
tried to do a Women's Democratic Leadership Fund lunch at least once a
month. I mean, I am sure we did. So I tried to be as helpful as
possible with respect to the schedule at the request.
Mr. Ballen. Have you ever seen this document before?
The Witness. No.
Mr. Ballen. Did you ever have any specific discussions about this
document?
The Witness. No.
Ms. Comstock. Well----
Mr. Ballen. Well, it is unclear from the record.
The Witness. No, I did not.
EXAMINATION BY MS. COMSTOCK:
Question. Did you ever have any discussions--this memo is
discussing in order to reach a very aggressive goal of $40 million this
year--this year being 1994--talking about coordinating particular
activities that are listed here, 19 of them, with contact people. Did
you ever have any general discussions with anybody about how this lunch
with the First Lady would be part of a general fund-raising effort in
1994?
Answer. I absolutely knew that we would be helping the DNC to raise
money and that scheduling the First Lady for lunches, for fund raisers,
for like activities was something that we should consider when we
looked at her agenda and her schedule, because raising money for the
Democratic National Committee was an important thing to do.
Question. And when--would Martha Phipps, if she had somebody to
schedule it, would she call you?
Answer. More than likely, she would call Patti Solis, Mrs.
Clinton's scheduler. And, actually, we had a much better process than
that. The first call would go to the political division as a part of
what they would present as, you know, an agenda or what they would be
interested in. Then it would go to Mrs. Clinton's schedule to be sorted
through as a request, as other requests for her schedule.
If there were a particular difficulty with respect to timing, then
I might be called in. Martha Phipps might call me. Or if there was an
event where there needed to be an immediate substitute, then I would be
called to see if Mrs. Clinton could fill in, especially around issues
of traveling, which were much more difficult, would involve much more.
Question. So the process would be Miss Phipps would call somebody
in the political office, someone like Mr. Sosnik or Miss Hancox----
Answer. Someone in the political office.
Question [continuing]. And make this request for we want somebody
from the DNC, a donor or whoever wants them to be able to have lunch
with the First Lady. Would they provide some kind of memo on who this
was?
Answer. If it got that far. I don't remember really individual
lunches that she had with donors. For the most part, I remember that
she did, you know, kind of major crowd events, smallest kind of thing
being the coffees, which were 15 or 16 people.
Question. Okay. And so 15 or 16 was the smallest type of group that
you recall that would be organized?
Mr. Ballen. Can we have a time frame? You are still talking about
1994 or in general?
The Witness. Well, I guess I am talking in general.
Mr. Dennis. The last election?
The Witness. I am just talking generally. Because, I mean, from,
you know, 1993 on my office's view was that Mrs. Clinton's time would
be divided in a number of categories.
There would be the substantive agenda that she was interested in,
there would be her role as the national hostess that she would be
involved in, and there would be issues that have to do with the DNC or
her husband's role as the leader of the party. So we always were
interested in being aggressive about making sure that all those
different parts of a schedule were, you know, taken care of.
Question. Particularly here, if we can sort of return to your--not
necessarily the '94 time period but these type of events that are
described here in the '94 memo as, you know, having contact people to
organize them. Why don't we go through the process you described? It
would go initially through the political office. Then it would come
over to the scheduling office with some type of memo or paper from the
political division.
Mr. Ballen. I am going to have to object. She has been testifying
generally, and you keep referring back to the memo she says she is not
familiar with. If you want to ask her was there a specific process that
resulted from the memo, fine, that she is not familiar with, or if you
want to ask the general process for scheduling the First Lady's time.
Ms. Comstock. If the witness doesn't understand the question----
Mr. Ballen. The record is confused. I don't understand the
question.
Mr. Dennis. I think that is a fair point. I mean, the memo she has
not--as I understand the record, the memo she has not seen. But on the
subject matter of how her office dealt with lunches or events like that
in which contributors might be invited or have a fund-raising purpose,
I think she described generally what that was. But she in no way ties
that into this memo or any specific conversation she had about, you
know, one lunch per month as reflected in the memo.
Ms. Comstock. If we could let the witness testify to that, I would
also like to generally discuss the process--the general process of
separately using the memo as a reference point.
EXAMINATION BY MS. COMSTOCK:
Question. And I think you made clear your knowledge or lack of--of
the particular memo, but I would like to discuss this process that you
described going from the political office to the scheduling office.
Answer. Okay. Can I just step back for a moment? Because maybe I
can provide a little bit of clarification and make it clear.
I am familiar with the idea of a White House event called the
Jazzfest or the Rose Garden ceremony or official--I am familiar with
these things as part and parcel of what it is the White House does. I
would never need a memo like this to say that when you are thinking
about an event at the White House and invitations to that event that
contributors should also be considered in the body of people that you
want to have.
When we have a White House dinner, for instance, we want to make
sure that congressional people are invited. We want to make sure that
contributors are invited. We want to make sure that the media people
are invited. And then we--you know, so we want to look across every
category.
And I think what I was saying to you, that from my standpoint and
given the office that I worked in, I would never need a memo like this
that would suggest to me that contributors, as well as the other
categories that we looked at in terms of people, should be included in
any event that we had at the White House.
Now with respect to your second question, which has to do with a
process, there was a process not only for having invitations sent for
contributors, but there was a process at the White House for having
congressional participation in events. There was a process for making
sure that women were invited to things. There was a process for making
sure that we looked across the United States regionally. It would be
nothing to suggest--to look at a list or say do we have anybody at all
from the south coming to this.
So by virtue of the kind of work that we were involved in in the
First Lady's office--and I can speak to that more so than, I don't
know, the political office--we would never need a memo like this to
suggest that we aggressively include contributors as part of our
category of invitations.
And so there was a process. The process was if the DNC was
interested in having Mrs. Clinton do something or scheduling her, they
would go to the political office. The political office would generally
make a recommendation to us, I assume, based on whatever factors they
use or criteria.
In the same way that if we were having some kind of dinner and the
Congressional Office would come to us, they would get requests from the
Hill. Those requests would come to the Congressional Office. The
Congressional Office would make recommendations, based on whatever
criteria they had, to us to say these people, it makes sense, public
liaison. These were parallel, from my standpoint, although I do not
know the criteria that each division was working on. But these were
parallel kind of processes for feeding in to any of the things that we
had to deal with, including Mrs. Clinton's schedule. So that speaks
generally to that.
Question. Okay. And when the scheduling request came in, say for a
donor, do you recall any memos that described this person as a DNC
donor, they've given X amount? Or these group of people are all donors,
they're trustees, or whatever they are, we would like to arrange a
lunch with the First Lady?
Answer. Yeah, at some point. If the event was accepted, at some
point, certainly, once, again, like for any other event that we would
have, there would be, you know, this is a guest list for this. This
person, you know, is an artist who works at such and such, this person
is a contributor for the DNC, this person sits on a foreign affairs
committee of such and such. There would be something that would say----
Question. Some type of briefing paper that would tell the First
Lady who she's sitting down with and going to lunch with?
Answer. Yeah, more than likely. It would be not a briefing, but
there would certainly be a list with a notation. If it got to the point
that it was accepted, then you could work on a list. But otherwise,
what you were taking essentially in the process was the recommendation
from the office that this made sense to do. And once you kind of got to
that threshold, then everything normally would follow--would follow.
Question. And were you involved in making recommendations one way
or the other on any of these?
Answer. Sometimes I made recommendations, yes.
Question. And like you said, Ms. Phipps would come directly to you
if there was a scheduling issue?
Answer. Generally, if there was some difficulty. Because, like I
said before, in our office, very early on it was clear to me and clear
to us that in terms of balancing Mrs. Clinton's schedule that there
were a number of areas that she would be a participant in. And so I had
laid a framework for the people who worked for me that these were the
areas that must be considered when we were doing scheduling. These were
the areas. Just like substantively, these were the areas we are
interested in.
We generally don't do environmental events, so you know that we
don't have to put those down. We generally do events that have to do
with child health. We generally do events that the DNC requests, and we
have a special interest in doing events where women are concerned. So
that people had a general view of the kinds of things we were feeding
into our schedule.
So if that process didn't work for us in any area, I would get a
call from the ``Martha Phipps of the world,'' or the, you know, the
other person or the other person. So I tried to be there when there was
a difficulty or if it involved an extraordinary amount of energy. For
instance, pick up tomorrow night and go to Kansas, then someone would
contact me and say, we need your involvement in this.
Question. Were you ever aware at any time of the President or the
First Lady complaining that donors hadn't been given enough involvement
or attention in terms of getting them to the White House for various
events?
Answer. Donors?
Question. DNC donors.
Answer. Not in particular donors. This is on the record, and not to
be released, but they complained that we never had enough people coming
to the White House, of just regular people coming to the White House.
Question. Not enough overnights?
Answer. They couldn't have enough people come, because coming to
the White House was a huge deal for people. And they knew that. And so,
I mean, you know, it would be, you know--we would push to get 50 more
kids in, even though it didn't make any sense to us in terms of
arrangements.
Yes, they complained that we didn't get enough people in the White
House. Which is why in terms of just visitors we almost tripled the
amount of visitors that came through the White House. It was a big deal
for them to have people inside the White House.
Question. I'm showing you a document. It is a Washington Post
article and there is not a date on it. It's EOP 52397. The body of the
document discusses fund-raising--directing your attention to the
circled area--yes, and I believe that's the way we received it, the
copy you have. It says, Democratic sources said that despite the DNC's
success in raising money in 1993, the party's several million dollars
in debt and one Democrat described, quote, ``turmoil in the donor
community,'' end quote, because of hard feelings among major
contributors who have complained that they have been ignored by the
Clinton White House.
Mr. Dennis. What was the date of this? I'm sorry; I missed that.
Ms. Comstock. Well, it doesn't have a date on it. I believe given
it is talking about fund-raising in '94--I mean '93. It is sometime
after '93, it could be '94 or '95. It is somewhat unclear on the
article. This is a document we received from the White House.
EXAMINATION BY MS. COMSTOCK:
Question. Do you recall anything about in '94, '95, any discussion
about turmoil in the donor community because people felt there hadn't
been enough donors at the White House?
Answer. No. Turmoil in the donor community? I--I've worked in
politics for 20 years. I've never lived in a period where there hasn't
been turmoil in the donor community.
Question. Okay. Do you recognize the handwriting that's on the
right of that document?
Answer. Right here?
Question. Yes.
Answer. Looks like the President's handwriting. Although he usually
signs things ``BC,'' so I don't know.
Question. On the side of the article it reads, Mack, what's this
about? Who's been ignored? Let's nail down the specifics. We sure gave
them--and then it's just a line and then it's signed B.
Answer. I don't----
Mr. Dennis. Before the record, I don't know whether I misheard you,
but as I read this, the article is not a complaint about donors coming
to the White House. It just says, have been ignored by the Clinton
White House.
EXAMINATION BY MS. COMSTOCK:
Question. Yes, that's why I'm wondering if you ever had any
discussion with the First Lady or the President about donors being
ignored.
Answer. No.
Mr. Ballen. Your answer was no?
The Witness. No, not donors specifically. As I said in my earlier
answer, they complained about not having enough people in the White
House, period.
Ms. Comstock. I'll make that Deposition Exhibit No. 3. And we still
are reviewing the other two memos that we have not made exhibits.
[Williams Deposition Exhibit No. MW-3 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. I guess returning to the May 5th, 1994, memo, do you know
Ann Stock?
Answer. Yes.
Question. And her job is social secretary at the White House; is
that correct?
Answer. Right.
Question. She arranges various events at the White House?
Answer. Yes.
Question. Do you have any knowledge of her working with the DNC in
any way to reserve various spots as is described in this memo for
things like six seats at White House private dinners, six to eight
spots at all White House events? Her name is under the White House
residence visits and overnight stays, item number 7. Then guaranteed
Kennedy Center tickets. And then the second page, 10 places per month
at White House film showings, and then use of President's box at the
Warner Theater and at Wolf Trap.
Mr. Ballen. Excuse me. The question is ambiguous. Are you asking
the witness if she's aware that Ann Stock may have done these kinds of
activities or----
Ms. Comstock. What I'm asking----
Mr. Ballen. Can I finish, please?
Ms. Comstock. I was asking the question.
Mr. Ballen. But you are not allowing me to state my objection.
Ms. Comstock. If the witness doesn't understand the question----
Mr. Ballen. No, I am entitled to object. I'm sorry; under the
rules, I'm going to object, whether you like it or not. The objection
is----
Ms. Comstock. You're objecting that you don't understand the
question?
Mr. Ballen. I'm objecting--the question is unclear and ambiguous,
and I'm objecting to the form of the question. It is unclear and
ambiguous. It is asking two different things and I am objecting to the
question and I am going to state my objection.
The objection is--is the question is the witness aware of
particular activities as described that might have been part of Ann
Stock's duties, or whether Ann Stock was, as this memo seems to
suggest--in order to reach our aggressive fund-raising of over $40
million--was specifically providing White House residence visits and
overnight stays to contributors in order to reach this specific fund-
raising goals? There are two distinct questions. It is not clear what
the witness is being asked. I object to the question.
Mr. Dennis. Can we have the question reread, please?
[The reporter read back as requested.]
Mr. Dennis. Do you want to take it one at a time?
Ms. Comstock. Yeah, if we want to do it one at a time.
EXAMINATION BY MS. COMSTOCK:
Question. Are you aware of her working on--first of all, generally,
were you aware of Ms. Stock setting aside these type of items for DNC
donors?
Answer. I am not aware of her setting--first of all, let me just
say that this memo from Martha Phipps to me--and I may be reading into
it--looks like Martha Phipps' wish list. And it suggests to me she
doesn't really have a good knowledge, based on some items here, of who
actually is a contact for them or not.
And I state that because while I'm well aware that White House
private dinners and White House events are in the purview of the White
House secretary, and possibly film showings, some of these other
things, it is news to me that she is the contact person for them.
Question. Okay. And what items are those?
Answer. I didn't know that she was the contact person for White
House residence visits and overnight stays or guaranteed Kennedy Center
tickets at least one month in advance. I'm not quite sure how that's
done.
I also don't think that--I'm not sure--but I'm not sure the
President has a box at the Warner Theater. I know he does at the
Kennedy Center, but I'm not sure he does at the Warner Theater. And I
do not know what our access would be at Wolf Trap. I can only remember,
quite frankly, one event--and I'm not the source of the Wolf Trap
tickets, but I could only imagine one event where either the President
or the First Lady ever went to Wolf Trap.
So with respect to all these other things, I can't speak to them
because I never knew that they were Ann's responsibilities or I didn't
think so. And some of them, I think, don't even exist as--as items.
But with respect to White House events as some mentioned here, Jazz
Fest, Rose Garden, whatever, did Ann reserve places for the DNC? To be
accurate, I would say she did not reserve places. Did Ann make certain
that DNC contributors were invited, as she made certain that other
groups and categories were? I would say absolutely. She considered
contributors important people and people who should be a part of White
House events, yes.
Question. And would she get this list of those people from the DNC,
then?
Answer. Yeah, she would get a recommended--yeah, she would get a
list. Uh-huh.
Question. And would that again come through the political office to
her?
Answer. I think when--in the best of all conditions when it was
working, yes, I think so.
Question. And what would be the other conditions?
Answer. The other conditions would be what you have a lot of in the
White House, where people who call in and say, I'm a big contributor,
there's an event at the White House, I need to come. Or I sit on the
committee of such and such. I need to be at the state dinner. Or I do
work--and so you would get those kinds of calls of people that you
might not necessarily know about and then they would go back to
whatever division handled that group.
So if it was a political person, it would go back to political. If
it was congressional, it would go back to congressional. If it was a
constituency group, it would go back to public liaison. And that's how
it would get around.
Question. And if Ms. Stock was getting information about particular
donors for private dinners, would that again be memoed from somebody? I
mean, if it was a private dinner in the residence with 8 or 10 people,
would the President and First Lady be briefed on who these people were
and who was coming to dinner in the private residence?
Answer. You would have to ask her. I don't know what her----
Question. What her practices were?
Answer. Yeah.
Question. But that would all be handled by Ann Stock, those
arrangements for private dinners?
Answer. In conjunction with----
Question. The various offices?
Answer [continuing]. Whatever various offices. Right.
Question. All right. So you didn't have any involvement, then, or
input into who was having private dinners at the White House at various
events? That went through the various offices through Ann Stock?
Answer. Yeah, generally, but then there would be times when I would
be asked for suggestions or recommendations of people, depending on
what the event was. And if I had them, I would give them.
Question. But is it your understanding that usually when these
people would go, that somebody would brief the President and the First
Lady on who it was that was coming for dinner?
Answer. Right, yeah. Generally, there would have to be a list and
they would have to go through security.
Question. And you had said the White House residence visits and
overnight stays, which is number 7 here, contact Ann Stock, it was your
understanding that Ann Stock was not the contact for that?
Answer. Yeah, I thought it was--I thought it was--since it was
their house--when you are talking about the White House residence
visits, you know--a lot has been made about the Lincoln bedroom. The
Lincoln bedroom actually is a guest bedroom in the President's
residence. The President has two floors and so it would be like, you
know, if you wake up in the morning and you've got your bath robe on,
who is ever in that room is likely to see you because it's at your
house.
So the residence visits were recommended by, you know, all kinds of
people. Including political people, including DNC people, and I think
that a decision would be in some ways a family decision. I mean, does
this work out this night? You know, it was a little bit different than
someone coming to the Blue Room and having dinner.
Question. Do you know the people who were involved in arranging the
residence overnights?
Answer. I would imagine the same residence staff that has been
there forever, the Usher's Office.
Question. I mean in particular, the people on the First Lady's
staff or the President's staff who were involved in that?
Answer. Well, we didn't really have anything to do with the
residence visits, unless we had made--unless we had made a suggestion
and it was family or something. We had very little to do with the
residence visits.
Ms. Comstock. Okay. Since we are discussing a few different
documents here, and I'm going to also introduce another one here, I
would like to go ahead and make the first Martha Phipps memo, the
undated one here--but we believe it is March '94--make that deposition
Exhibit 4. Make the May 5th, 1994, Phipps memo, deposition number 5
that we have been discussing.
[Williams Deposition Exhibit No. MW-4 was marked for
identification.]
[Williams Deposition Exhibit No. MW-5 was marked for
identification.]
Ms. Comstock. And we will continue. And then we have a document
that I'm showing the witness CGRO-1569 through 1570. It's dated January
5th, 1993, memo to Nancy Hernreich from Terry McAuliffe, national
finance chairman. This is generally the ``Start Overnights Right Away''
memo that's been in the press over, you know, the past 8, 9 months or
so.
I believe as the record printed, the date has been indicated
January 5th, '93, was an incorrect date on here and that people--there
is various speculation on whether it is 1995 or 1994. So I won't
represent what it is, but I think it was probably not '93 is I think
the general consensus.
But at any rate, this discusses Carolyn Huber and the First Lady
being involved in the overnights generally. I believe at the top of the
memo it says, Mr. President, do you want me to pursue number one with
Billy? It may be cut off on your copy. It is a little on mine. Number
two, which was the overnights was with HRC and Carolyn, which I believe
is Carolyn Huber, is what has been indicated. And number three, was
handle, run it by Harold, I think is what was on the original. We have
a cutoff version of this document. I'm sorry.
This is a document received from Mr. Ickes back in February of this
year and it talked about getting people to stay, you know, who was
going to handle overnights, referring to--the President's handwriting
is on the second page, CGRO-1570, which says, yes, pursue all three and
promptly and get other names at 100,000 or more, 50,000 or more. And
then that was cc'd to Harold, Leon Panetta, and Webster--which I
believe was Billy Webster, and then it reads, Ready to start overnights
right away. Give me the top 10 lists right away together with the 150
over.
Does that refresh your recollection--actually in the first page,
number two, as to whether the First Lady and Carolyn Huber were
involved in overnights?
Mr. Ballen. I am going to object that in the question you said that
it was the President's handwriting. If you want to ask the witness
whether she recognizes it as such, but to the extent that the question
assumes a fact not in evidence----
Ms. Comstock. I believe the President and the White House and
everyone else has indicated that it is his handwriting. But if you
would like to identify it for the record, that is fine. We could drag
it out for the witness longer.
EXAMINATION BY MS. COMSTOCK:
Question. And I apologize. Would you like to identify the
handwriting on the second page, CGRO-1570, and if you recognize the
handwriting on the right that I have just read and indicated was the
President, do you recognize that as the President's handwriting?
Answer. Okay. Which are we looking at? This?
Question. The handwriting on the right.
Mr. Dennis. This right here, yeah.
The Witness. This? It could be. I really don't--I mean, I have seen
this document in the newspaper. I can't personally identify----
Mr. Dennis. The handwriting?
The Witness.--the handwriting. It could be. These both look the
same.
EXAMINATION BY MS. COMSTOCK:
Question. Has anyone at the White House--you have seen press
reports on this document and this whole issue of the President writing
``start overnights right away''?
Answer. Uh-huh.
Question. Have you had any indications from anyone at the White
House that the document that became public and was in the newspaper was
not the President's handwriting on that document? Has anyone ever told
you that at the White House?
Answer. No.
Question. Do you have any reason to believe that ``start overnights
right away'' wasn't the President's handwriting? Has anyone ever told
you anything, like he got a bum rap? That's not his handwriting on the
``start overnights right away'' document?
Answer. To be frank, I've only read press reports. I've read what
the press reports have said. I have never discussed this memo with
anyone at the White House, nor have I ever seen the actual memo or a
copy of the actual memo until now.
Question. Okay.
Answer. Outside of press reports.
Ms. Comstock. And it has been--I will for the record say that it
has been identified by the White House as the President's handwriting.
If the Minority would like us to have the President certify in some way
that this officially is his handwriting----
Mr. Ballen. That's enough. We have a deposition where we are asking
the witness questions. I thought that was the purpose of it. Not to
engage in other--you asked the witness a question, does she know the
document? Is she familiar with the handwriting? Did she have any
discussions? It should be simple----
Ms. Comstock. Well, I'm not mischaracterizing this document as
being the President's handwriting.
Mr. Ballen. I didn't say you were mischaracterizing. I said there
was no evidence in the record from this witness that it is. That's all.
Mr. Dennis. I think from my client's standpoint, I mean, I
understand your question to be that, you know, you are representing
that that's the President's handwriting and that would be the basis
for, you know, the question that you really want to get to. And you
can--you understand what I'm saying in terms of what is being
represented?
The Witness. Yeah.
Mr. Dennis. Okay. You're not testifying that this is his
handwriting, but it is being represented that it is as a part of
another question. And I guess the question is--what is that other
question? I've kind of forgotten, because it was buried in a question
that was really going to another point, I believe.
The Witness. Okay.
Mr. Dennis. Do you want to repeat?
Ms. Comstock. I'm sorry; we probably lost track here a little of
what the question was. I think initially I had asked if this document
in general refreshed your recollection as to whether the First Lady and
Carolyn Huber were the people involved in scheduling the overnights.
Mr. Dennis. That's the question.
EXAMINATION BY MS. COMSTOCK:
Question. I think you may have already answered, but just so we can
go back and make the record clear now.
Answer. Yes, I know that Carolyn Huber was involved in the
overnights. And as I said before, because these were overnights in the
President's home, it was a family--I assume a family decision, so the
First Lady would be involved.
Question. Okay. And do you have any knowledge, other knowledge
about that process?
Answer. No.
Question. In terms of do you know lists were brought to them and
they said----
Answer. No.
Question [continuing]. Checked off on Steven Spielberg or, you
know, Mr.----
Answer. No.
Question [continuing]. Rapoport or people like that?
Answer. I'm not aware of that process.
Question. But your general understanding is that because it was the
family residence, that the family----
Answer. I would assume so.
Question [continuing]. To some degree was involved?
Answer. I would assume so, yes.
Ms. Comstock. I'll make this Deposition Exhibit No. 6.
[Williams Deposition Exhibit No. MW-6 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. This is a document from the White House numbered EOP
29074, which is titled, ``Overnight guests in response to request.'' It
is not a dated memo, but it just has a list of names and indicates name
and dates of stay.
Have you ever seen this document before?
Answer. No.
Question. Do you know--are you aware of anybody at the White House
being asked to prepare a list of overnight guests who may have been
donors?
Answer. Prepare a list of overnight guests who may have been
donors?
Question. Uh-huh.
Answer. No.
Question. I would note for the record that some of the names that
were on Deposition Exhibit 6, the ``start overnights right away'' memo,
which had listed the top 10 supporters and had John Connelly, Carl
Linder, Skip Hayward, Miguel Lausell, Arthur Coia, Finn Casperson, Paul
Montrone, Larry Hawkins, Stan Shuman, and Ernie Greene, some of those
names then in turn appear on this list. So I am not necessarily
representing that this is a donor list, but actually I believe most of
these names have--are identified in one way or another as donors and
fund-raisers. But do you have any knowledge of any such list being
prepared at the White House?
Answer. A list of overnights for donors?
Question. Yes.
Answer. No.
Ms. Comstock. I'll make that Deposition Exhibit No. 7.
[Williams Deposition Exhibit No. MW-7 was marked for
identification.]
Mr. Dennis. I think that her answer to the last question obviously
does not include what she may have read in the newspaper.
Ms. Comstock. Sure, I understand.
EXAMINATION BY MS. COMSTOCK:
Question. And I think generally, I mean, if you do have knowledge,
you know, that is only from the newspaper, you know, you can indicate.
This is a memo of April 21st, 1994. It's on White House stationery.
It's to Mark Middleton from Ann Stock. It was cc'd to Maggie Williams
and Phil Lader. It was, re: potential guests. EOP 56609 through 56617.
And it begins, the paragraph reads, ``I think our meeting on Thursday
was very productive. Thank you for bringing a list with you of key
fund-raisers. It gives us an opportunity to see exactly who has been
invited and who hasn't. I had Helen run a check on the attached list.''
Beside each name are four columns ``invited'' ``accepted''
``regretted'' and ``dinner.''
And then the attached memo has uninvited list and has names of
lists alphabetically for numerous pages. And then has dollar amounts
next to them in a column all the way down.
Answer. These are the dollar amounts of what they've--of what
they've given?
Question. Well, I'm--it is--this memo says, ``I had Helen run a
check on the attached list.'' Why don't we start with, since the memo
is cc'd to you, do you recall ever seeing this memo?
Answer. No.
Question. Do you recall ever having a meeting with Mark Middleton
or Ann Stock about getting lists of key fundraisers for the purpose of
getting them invited for White House events?
Answer. I remember being in a meeting with Ann Stock and other
people about lists in general and how we got them and gathered them
from both the DNC, the DLC, the State chairs, you know, early friends,
whatever. I remember being in a list--in a meeting that included Ann
Stock and several other people about lists, and one of which lists was
talked about was getting contributor lists.
Question. Okay. And so this was a meeting at the White House?
Answer. Yes.
Question. Do you recall if Mark Middleton was involved in that
meeting?
Answer. No, I don't believe that Mark was involved in that meeting.
Question. Besides Ann Stock, do you recall any of the other people
involved in the meeting?
Answer. I think we had representatives from each of the divisions.
I think somebody was there from public liaison. I'm a little confused
by the dates because I thought there was another deputy, but maybe it
was Phil Lader still. I don't know who was deputy when. But I do
remember a meeting about lists.
Question. And could you just describe, you know, your full
recollection of that meeting?
Answer. It was basically trying to make sure that there was an
organized way for people who were making recommendations for any event
at the White House to get their list in, to get all the information
that was needed to send them invitations. There was a huge discussion
there about late invitations, that people came with recommendations far
too late to politely send them an invitation for an event.
And so it was a kind of cracking down on getting complete lists,
recommendations, so that, you know, decisions could be made about
invitees.
Question. Do you have any recollection of Mark Middleton being
involved in that process at all?
Answer. No, I really--no, I don't.
Question. Do you have any knowledge of Mark Middleton supplying any
type of list of fundraisers, to have those type of lists available at
the White House?
Answer. No, I have no firsthand knowledge of him supplying lists.
Question. And you said you generally discussed in the meeting how
to get a hold, I mean how to get lists about donors?
Answer. It was--what we generally discussed in the meeting was how
the list process worked, which included donors but was not limited to
donors, because many of these events had a huge mix of people. And so
whether it was a representative from the constituency group or the
congressional group or the media group or whatever, you know, it was
kind of a ``Come to Jesus'' meeting on getting lists that were full,
with addresses and phone numbers, and getting them in a timely fashion.
Question. Okay. In this particular memo, the April 21st, 1994 memo,
it has, as we were discussing, a list of names and how much has been
given and then it has columns, if they were invited accepted,
regretted, or dinner. And then there's handwriting----
Answer. Right.
Question [continuing]. Indicating--making some indication on
whether people have been invited or not. Do you recognize this
handwriting?
Answer. No, I don't. But I have a question about this list. I'm
still trying to figure out--maybe it's--I'm still trying to figure out
this--I mean what this lists.
Question. The column with the figures, the numbers?
Answer. The column with the figures, because these are not--I mean,
these have like $30, $25.
Question. I think we are trying to figure it out also. My best
understanding is that this is probably $30,000, $116,000, $145,000,
because these people probably didn't give amounts of--Bernard Aidenoff
probably didn't give----
Mr. Ballen. Then how do you explain $31.30, which is on the list?
Ms. Comstock. Well, I think we will have to obviously ask Ms. Stock
about it because it's her list, but----
Mr. Ballen. May I respectfully suggest----
Ms. Comstock. It could be $31,300, I would suggest. But when Ms.
Stock is in, she can tell us if it was a person who gave $116. The FEC
list would probably indicate that Ann Getty probably gave more than
$50.
Mr. Ballen. May I respectfully suggest that we ask Ann Stock this?
EXAMINATION BY MS. COMSTOCK:
Question. I am not trying to suggest to you what this is. You were
cc'd on this. I am not making representations about it. But the memo
that it's attached to discusses a list of key fundraisers and the
amounts. They ran a check on the attached list and beside each name
they had these various indications of whether they had been invited or
not.
Answer. I just have one more question, just about the list. Was
this--so this list was attached to this memo?
Question. Yes.
Answer. Okay.
Question. And this is how we received it from the White House.
Answer. So this is not a separate list of something? Okay.
Question. Do you know who Helen is who worked with Ann Stock, or if
there's a Helen who worked with Ann Stock?
Answer. There was a Helen Dickey who worked for Ann, I think for
about a year.
Question. Okay. And do you know if she would have been working for
her at or around 1994?
Answer. I'd have to check. I don't know.
Question. And do you know how she would run a check on the
attached--what facilities they had in the office on running checks on
who had been where at the White House, invited, accepted, regretted,
what type of system they had?
Answer. No, no.
Question. Do you know if Ms. Stock's office utilized the White
House database for purposes of inviting people?
Answer. I'm sure they utilized the database. I hope, yeah. I know
it was some computer program they had.
Question. So your understanding is they did have some type of
computerized system?
Answer. Yes.
Question. So when they talk about running a check on things, on the
names, that it was some type of computer, your understanding is that--
--
Answer. Well, I don't understand how they ran a check. I mean, did
they have a computer in their office? They did. I don't want to assume,
because I really don't know what they did.
Question. Okay. In the third paragraph in the meeting, I mean of
the memo, it says, ``If you can provide me with addresses we can start
to correct this situation immediately.'' You had discussed that there
was an effort in the meeting you recall, whether or not it was this
meeting.
Answer. There was an effort to get addresses? Accurate addresses.
Yes.
Question. Is that correct?
Answer. Yes.
Question. ``Also, per our discussion, each Friday I will send you
guest lists for the following week so that you and Phil can identify
any key fundraisers who are in town.'' Do you know anything about Mark
Middleton or Phil Lader identifying key fundraisers to Ann Stock or
anyone?
Answer. No.
Question. Were you ever asked to identify key fundraisers to Ann
Stock for inclusion----
Answer. No.
Question [continuing]. In events?
Answer. No.
Ms. Comstock. I will make that Deposition Exhibit Number 8.
[Williams Deposition Exhibit No. MW-8 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. This is a May 17th, 1996 memo to Leon Panetta and Evelyn
Lieberman from Harold Ickes re: Marsha Scott VIP operation at the
Democratic National Committee. It's EOP 36085 through 87. And the memo
discusses a number of things, but directing your attention to the
second--why don't I let you have an opportunity to review it first
before I ask you any questions about it.
[Witness reviews document.]
The Witness. Okay.
EXAMINATION BY MS. COMSTOCK:
Question. Have you ever seen this memo before?
Answer. Yes, I have.
Question. And do you recall when?
Answer. Around convention time.
Question. Of last year?
Answer. Yes.
Question. Of '96?
Answer. [Nonverbal response.]
Question. And then the beginning of it reads, ``On 15 May, the
President approved the following with regard to Marsha Scott and with
regard to the VIP operation at the Democratic National Committee----
Mr. Dennis. Convention.
Question. ``Convention,'' I'm sorry. And then it says, ``These
recommendations are made with the understanding that over the past 3
years a sophisticated process, involving several key people, has
evolved at the White House for ensuring contact and follow up with
friends and key political and financial supporters of the President and
the First Lady.''
And then it goes on to say, ``For example, Maggie Williams and Ann
Stock manage a number of functions in connection with the residence,
invitations to Camp David, etc.''
Could you describe, if you do indeed manage--if you did over the
three years in a sophisticated process that Mr. Ickes is discussing, if
you had managed a number of functions in connection with the residence
and invitations to Camp David or other things with Ms. Stock, what he
may be referring to there, if you know?
Answer. I'm flattered. Sophisticated process. Essentially, first of
all, nothing to do with invitations to Camp David. Nobody ever went to
Camp David much, except for the Clintons. And they didn't go much.
With respect to the number of functions in connection with the
residence, Ann Stock reported to me in theory, and everything that
happened at the residence by tradition, everything that happened in the
house was considered a First Lady--a First Lady event, even though what
Ann actually is is the event person at the White House for both sides,
the East Wing and the West Wing. was I aware of most events in the
residence? Yes, I needed to be aware. My management of them was
minimal, but I take credit for all the really good events we had. But
Ann Stock, her staff and the residence staff actually really made these
events work and I think did a very good job of that.
So the sophisticated process here, I think, was slightly
embellished. What I believe, as I read this memo, as I read it, my
interpretation of this memo was that Marsha Scott wants to work at the
convention in Chicago and she wants to focus on VIPs. The people who
generally would handle VIPs--and that would include from our
standpoint, actually, family and friends, because the DNC at the
convention took care of its VIPs. They had their own program, so we had
very little to do with it. But we did take care of the mothers, the
brothers, the college friends, the high school friends, the long-time
Arkansas friends. So this was an area that we expected that we would
handle at the convention, since we tended to handle that group
generally when they were around.
So I think what Harold was suggesting here was that Marsha Scott
become a part of--of, you know, of that. It appears a few friends and
other political--I remember when I read this, I didn't understand this,
especially as it related to the convention, because I believe that the
political and financial people were really having a lot of attention
paid to them by the DNC.
Question. Okay. And directing your attention to page--the second
page of this memo, which is EOP 36086, the middle paragraph there says,
``Although early on there undoubtedly were a number of friends and
other political and financial supporters who may not have received the
attention and follow up they should have (or at least thought they
should have), given the close and much more effective coordination
among the political and other departments of the White House, with
Nancy Hernreich, the social office, etc., it appears that few friends
and other political/financial supporters are not being,'' quote,
``taken care of,'' end quote, ``in appropriate ways.''
Do you know Nancy Hernreich?
Answer. Yes.
Question. And she is the President's secretary; is that correct?
Answer. She the President's assistant, yes.
Question. And do you know what her role was in sort of taking care
of political or financial friends of the President or First Lady?
Answer. Well, let me say that my interpretation of this
specifically has to do with, I would add the words ``early friends and
supporters.'' Nancy Hernreich is from Arkansas. Marsha Scott is from
Arkansas. There were a lot of people who had supported the President
when he was Governor, when he was Attorney General, and there was a
concern that these friends, you know, not be forgotten when they came
to Washington, so if they came to town, that they should be included in
anything that was going on.
And Nancy did have a particular interest in this because she was
from Arkansas, and had been with the President and knew all of his
friends from his Attorney General days through his governorship in
Arkansas. And Marsha Scott, in addition to that, focused on those
people.
Ms. Comstock. Okay. I'll make that memo Deposition Exhibit Number
9.
[Williams Deposition Exhibit No. MW-9 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. Directing your attention to the third page of that
document, in the middle of it it says, quote, ``Any friend or supporter
of the President who feels overlooked or not attended to in the
appropriate way will be referred by Marsha to Nancy Hernreich, Ann
Stock or other appropriate person in the White House for follow-up.''
Were any of these people ever referred to you from Marsha Scott or
Nancy Hernreich or Ann Stock?
Answer. No.
Question. Okay. And again if we could return to the May 5th, '94,
Phipps memo, let's go through a number of the other items on there. Do
you have any knowledge about Air Force One and two trips including
donors, or any efforts made to include donors on Air Force One?
Answer. I know that contributors were--did get to fly on Air Force
One. I don't know about Air Force Two.
Question. And how did you learn about that?
Answer. I don't know specifically how I learned about it. I don't
know. I just----
Question. Do you have any recollection of anyone ever calling up to
put a donor on Air Force One?
Answer. Calling me? No.
Question. Or calling----
Answer. No.
Question [continuing]. Anyone in the First Lady's office?
Answer. No, we had people who called--actually not--actually not so
much contributors, but just people who wanted to fly with her on the
plane. Friends, we got a lot of friends who would be interested, or
depending on what she was doing, people who had substantive, you know,
issues. But she has such a teeny plane that, you know----
Question. Oh, for the First Lady's plane, you mean?
Answer [continuing]. Yeah, couldn't accommodate anybody.
Question. Did anybody ever call the First Lady's office to get on
Air Force One or make an effort or pitch to get a donor on Air Force
One?
Answer. I don't have any specific recollection. But I can't imagine
that someone at some point didn't.
Mr. Ballen. There were two questions there. There was one, donor or
anyone, or----
EXAMINATION BY MS. COMSTOCK:
Question. I'm sorry; I meant donor. I was just referring to getting
a donor onto Air Force One, and if that wasn't clear, I'm sorry.
Answer. Like I said, I don't have a specific recollection, but we
have all kinds of people who would call, who could be contributors, to
say, ``What I would really like to do most is get on Air Force One.''
Or, ``My wife and I gave in 1992, and we would really like to get on
Air Force One.''
Question. And that's more of the context. If you recall anyone ever
calling you saying ``I've given this much'' or ``I'll give this much''
or ``I'm a big donor'' or ``So-and-so is a big donor, can you get us on
Air Force One?"
Answer. People would always say, ``I'm a big donor, get me on Air
Force One.'' I mean, it was pretty typical. I mean, it is a very
typical thing for people to always preface what they're saying by ``I'm
a big donor.'' It's the same way when someone calls me and says, you
know, ``I'm a Congressman, I sit on such and such a committee, I need
to be on that plane.'' It just happens. And, you know, I think of my
job as listening politely.
Question. So you have a general recollection of that, but you can't
recall specific people who may have called?
Answer. Yeah; right.
Question. Number 4 on here, it says invitations to participation in
official delegations, trips abroad, contact Alexis Herman. Do you have
any knowledge about any efforts to include donors, and specifically
where someone said, ``So-and-so is a donor, we'd like to get them on an
official delegation trip abroad,'' any knowledge of that type of
effort?
Answer. Once again, I am not going to be helpful in the specific
recollection, but in a general way to say that contributors, along with
other people, were not considered for official delegation trips abroad
would--I may not have to say that. And also people who are big
contributors, also, in addition, sometimes have some substantive input
that they can bring some place.
So while, you know, there is kind of this sense that donors or
contributors have nothing but their money, there are a lot of donors
and contributors that we dealt with who had some expertise to bring to
an official delegation. And that certainly would be taken into account
or I would hope it would be a smart thing to do. So that you would get
a group of people, supporters, people with expertise, that you're
picking from a cross-section of people who both support the President
and may have something to offer on an official delegation trip.
Question. But I'm talking more about specifically if you have any
general recollection or knowledge about efforts made to go to Alexis
Herman or somebody in her office to get, you know, in coordination with
the DNC where a DNC person would not really, in this general process
which you have described, you know, a number of times today about
reaching out and including people, but, you know, efforts where it was
DNC people calling and saying, you know, ``We are raising money. We are
trying to get this. Getting this guy on this trip would be helpful.''
You know, ``He's been a big donor; we want to get more money from
him.''
You know, maybe he has substance to offer, maybe he doesn't.
Obviously it would help if he does, but do you have a general
recollection of any instances like that where it's people from the DNC
calling to get a donor, you know, identifying the person as a donor and
identifying that we'd like to get them on the trip?
Answer. I do not have a specific recollection, but you know, I
really want the record to show that I have a general recollection of
not only the DNC, but Members of Congress, but members of specific
interest groups, all calling and saying would you put this person or
that person because he's good at what he's doing, he will continue to
be helpful to us, or any number of reasons.
Question. Sure, I understand.
Answer. It would just be very hard. To me, I cannot pick them out.
Like I said, maybe it's just from being in politics for 20 years where
you kind of--I mean, who hasn't heard this? I mean, people were getting
in on Jimmy Carter's plane. This is not----
Question. Do you recall any general discussion, given this memo is
discussing coordinating activities between the White House and the DNC,
and your getting a goal of $40 million, do you ever recall generally--
and maybe in relation to any of these things--saying, ``Hey, you know,
it is July, we haven't gotten to our $40 million goal yet, and we need
to do this?'' Any kind of discussion or pressure to get--we need more
people, we need more donors in here because that will end up getting up
more money at the DNC? Do you have a general recollection of any
discussions like that?
Answer. I have--I have no recollection that there was an
extraordinary amount of pressure in any campaign season. Because of how
wacky the campaign laws are, and how expensive it is to go on
television, every campaign, at some point someone says we need to get
more money.
Question. But I'm talking about specifically----
Answer. Everybody----
Question [continuing]. In relation to these itemized things at the
White House. Not we want the First Lady to come out to Ohio and speak
to a woman's group, but we need to have more lunches with the First
Lady at the White House so that we can get more money, or we need to
have more seats--they need to have more private dinners where we can
get donors in so that we can get more money. Do you have any type of
general recollections of any type of discussions about those kind of
matters?
Mr. Ballen. May I interject here? Was there a specific plan to
reward DNC donors with perks as laid out in this memo? A way to fund
raise, to use the White House to get the perks out to fundraisers? I
think that is what these questions are going at.
Ms. Comstock. Mr. Ballen, when it is your opportunity question, you
can ask your questions. But I would like to ask my questions.
Mr. Ballen. The questions are going around the issue rather than
dealing directly with the issue. You keep producing a memo----
Ms. Comstock. You may ask your----
Mr. Ballen. Can I finish my sentence? Is that possible here?
Ms. Comstock. You aren't making objections. You are just making
speeches. Is that what you want to continue doing?
Mr. Ballen. I am making a record. You have been asking the witness
about a memo that talks about a plan to coordinate these activities, to
provide these kinds of----
Ms. Comstock. And you are going to be free to ask the witness about
the very same document and ask your questions.
Mr. Ballen. But your questions are not clear. Your questions----
Ms. Comstock. And the witness has the opportunity to tell me when
she doesn't understand my questions.
Mr. Ballen. Well, you--all right. I want to make clear for the
record whether or not there was any kind--if the witness is aware of a
specific plan to award donors----
Ms. Comstock. And you will have that opportunity at the time of
your questioning.
The Witness. Okay. Proceed.
EXAMINATION BY MS. COMSTOCK:
Question. My question was: Do you recall any general discussions of
efforts to get more events at the White House of any type to raise
money?
Answer. Quite frankly, no more than usual, starting in 1993. We
always had strong interest in getting more contributors there, more
people of color there, more women there. We had a strong driving
interest to do that, and it started in 1993. It is no secret that we,
perhaps more than any other White House, had triple the number of
activities, the number of nights to see Christmas decorations. We
worked very hard at it.
Now, I can speak only from my vantage point. Did I think of myself
or my office in any specific plan to raise money for the DNC? Yes, I
thought that as a support to the party, whenever we could we should try
and invite contributors of the party to the White House. That they
should be included, like other people, as much as possible in
everything we did.
Question. Do you recall having discussions with people from the DNC
about specifically having more private events at the White House?
Things such as private dinners, overnight stays, things such as that
specifically, not the Christmas parties or the big things or bringing a
lot of people in, but specifically, you know, the get more donors into
these small little events or get them in for movies and popcorn with
the President, those type of things. Were there ever those type of
discussions with DNC people?
Answer. There were those type of discussions with DNC people and
other people. DNC, if they had not been advocating to get more of their
contributors into everything, would really not have been doing what
they should have done. They are advocates.
Question. To get people into the White House?
Answer. They are advocates in the same way that a congressional
person calls up and says, ``I need four more places at the Jazz
Festival.'' Democrat or Republican. They are advocates. It is their job
to push for their constituency. Did the DNC push for their
constituency? Yes, they did. Sometimes we responded well; sometimes we
didn't so well, I'm sure they thought.
Question. Do you recall who you had those discussions with?
Answer. No, no, just general discussions. Depended on who called. I
didn't have, you know, a person.
Question. Was it a large group of people who would call or was it a
particular office?
Answer. It was sporadically. Just people would call. Because
otherwise we did have a process in place for including them, which was
a good thing. There was a process in place so that they could--so that
they could advocate. There was a process so that they could advocate,
so that--I mean from my--for me, and I can't speak for everyone else,
so that the kind of calls I would get of this nature would be sporadic.
Otherwise, you know, there was a process.
Question. Do you know who else was involved in the White House in
these discussions that you recall with DNC people?
Answer. I mean, I couldn't say. I mean, I could only make an
assumption, the political department. That's the most logical place.
Question. And did you ever provide any names of people, or
specifically donors, for any events? Not here's somebody who's--but
generally here is a $50,000 donor, here is a $100,000----
Mr. Ballen. Donor to who and what and when?
Ms. Comstock. Donor to the DNC.
Mr. Ballen. What time frame?
Ms. Comstock. At any time.
The Witness. Did I ever recommend a donor? I don't know a specific
case, but I can't imagine--I'm sure I did. Someone said, ``Give me 10
people you think who would enjoy coming to something at the White
House,'' I could in a second come up with two media people, maybe a
donor that I knew of, maybe somebody who worked with Hillary at a
women's event. I'm sure that I did at one point or another.
EXAMINATION BY MS. COMSTOCK:
Question. Did you ever keep any list of donors that were to be
utilized for----
Answer. No.
Question. I've gotten through five of them; here is the next five.
Answer. No, no, nothing that----
Question. You had generally--you had said that you thought of your
office as being a support for the party in a way. Could you elaborate
upon that, what your understanding was of----
Answer. No, I thought that one of the things that must be taken
into consideration in putting together a schedule for Mrs. Clinton was
that she would be called upon to support the party publicly in speeches
or meetings or whatever else. And so----
Question. But I'm talking generally about use of the White House
and White House events, if you could----
Mr. Ballen. I'm going to object. The witness didn't finish her
answer. You cut her off.
Ms. Comstock. I thought maybe she misunderstood. I didn't have want
to have a misunderstanding of my question.
EXAMINATION BY MS. COMSTOCK:
Question. I was directing it towards how you saw the White House
as--events at the White House as being support for the party.
Mr. Dennis. I didn't understand it to be the question either. This
sounds like a different question. You want her to answer that question?
Ms. Comstock. Yes, and I'm sorry.
Mr. Ballen. There are several questions pending.
Mr. Dennis. There are actually a couple of questions. Let's try it
this way. Could we do this? Can we go back to the question you just
asked and the question before that so I can----
Ms. Comstock. Maybe I should just strike my last question and the
answer, so there is not any misunderstanding in the record because----
Mr. Dennis. It is confusing to have two questions.
EXAMINATION BY MS. COMSTOCK:
Question. I asked what understanding you had of how the White House
could be utilized as a support for the party.
Answer. As I said before, primarily, in my office, Mrs. Clinton
would be a part of the White House, and I felt that her schedule and
how we allotted time prevented our support of the party.
Ms. Comstock. Off the record.
[Discussion off the record.]
Ms. Comstock. Back on the record.
EXAMINATION BY MS. COMSTOCK:
Question. You indicated that Ann Stock reported directly to you;
you're her direct supervisor, is that correct?
Answer. On paper, yes.
Question. And can you describe generally the practice of how Ms.
Stock reported to you?
Answer. We generally worked on--if something was really wrong, she
would talk to me. She had a pretty good handle of, you know, how to run
those events, and I absolutely trusted her. So, I mean, we would talk,
I would think that we talked every day about something or the other,
and then I would, you know, hear about--you know, I would definitely
know about her plans and what the events were, but I felt myself more
consultative than in charge. But if there was a problem and she needed
some support for something she was advocating for, I would always help.
But also on the staffing side, I was probably most helpful to her in
that regard.
Question. In hiring people for her office?
Answer. Well, just in making sure she got the help she needed. A
lot of times the kind of help she needed might be seasonal, you know;
Christmas would be a high season, Easter would be a high season. The
White House, I understand, as a rule doesn't have a lot of flexibility
with that, but that is kind of what she needed. So in those areas I
think I was much more of a support and much more focused on her work in
those times.
Question. Would she generally cc you on just generally what was
going on, or send you memos to here are the events we have for this
week, so you know what is going on; here is who is overnight at the
White House, so in case they are wandering around, you know who is
here?
Answer. Right. I mean, that particular kind of information wouldn't
come from Ann Stock, but in general there were opportunities to see
what the whole--I mean, what the whole schedule was.
Question. And who would that information come from then?
Answer. On events it would, you know, come through a President's
scheduler, or if it was an event Mrs. Clinton was involved in, through
that scheduler. But, you know, Ann was able to work with, you know,
each of the schedulers in whatever division was putting it on, and if
there was a difficulty, generally I would be brought in.
Question. And did she ever bring you in on any issues that arose in
relation to DNC requests of the White House?
Answer. Well, yes, in particular, which I don't think necessarily
initiated the meeting, but, you know, she tried to be a very orderly
person, and she felt when the DNC made recommendations, they didn't
give complete information.
Question. And besides that, were there other areas of DNC requests
she talked to you about?
Answer. That was her big kind of thing. She felt that people needed
to have the lead time to receive an invitation from the White House,
that the protocol was very late, and if she asked every department to
give her a list of the recommendations in order to begin to build an
invitation list, that the DNC tended to be very late, and she thought
that it made the White House look bad to send very late invitations,
and so she was very much concerned about that with them.
Question. Okay. And were you aware of how she worked with the White
House Ushers' Office, how, in coordinating events?
Answer. I think like everybody else has before. I mean, you know,
they really know the house. I mean, they know, you know, what a tent
will cost. You know, I mean, they just know the house, and if you are
planning any events, I mean, they know what it can take.
Question. And in regards to the DNC, did there come a time when the
DNC wasn't paying bills for events that had been held at the White
House?
Answer. Oh, well, come a time. They were habitual late payers, but
so was the Olympic committee, and so was the, what is it, the Madison
Group from the Library of Congress. I mean, the bills certainly weren't
as big because the DNC had, you know, large chunks of bills because
they were responsible, as in the Bush administration, the RNC, for
almost anything that wasn't official, and then we had, you know, the
Olympic committee, the Kennedy Center, the whatever theater, whatever
group was putting on something at the White House.
Question. Do you recall any discussions with Mr. Walters about the
DNC not paying bills?
Answer. About what?
Question. About the DNC not paying bills for events?
Answer. Yes.
Question. Can you just describe those conversations?
Answer. Just in general the gist would be----
Mr. Ballen. These are conversations with Mr. Walters?
The Witness. That is how I understood the question.
Ms. Comstock. Yes.
The Witness. Okay. These would be the DNC hasn't paid its bills,
the Education Department is late with the bill, the Olympic committee
wants to have another event here, it hasn't paid its bills. I have sent
out three notices. Can you call them, or do you want me to send out
more notices?
EXAMINATION BY MS. COMSTOCK:
Question. All right. And then did he generally then memo you on
these types of things?
Answer. Sometimes he did, yes, sometimes he did. I don't know if
there was with frequency, but I saw Gary enough through the halls that
if he wanted to tell me, he did. I remember seeing one or two memos,
and he may have sent me more that I didn't see, but mostly I would just
talk to him.
Question. You said the DNC was a habitual late payer?
Answer. They did not pay on time.
Question. And what was your understanding of what the time frame
was of when they were supposed to pay, 30 days or----
Answer. I actually had no real sense of it, just my own kind of
internal for when I might want to see something paid. I would think,
you know, 60, 90 days.
Question. Do you recall how often you had--were these regular
conversations you had with Mr. Walters about the DNC?
Answer. Intermittent. They were intermittent because, I mean, Mr.
Walters essentially did what he normally would do. As I understand it,
he would send out his own kind of dunning notices and make his calls
and follow up, and then if he, you know, hadn't heard from him, he
would, you know, want to know what was going on.
Question. Is it your understanding he would first directly call
whoever it was who was paying the bill?
Answer. I don't know if he called them, but I know he would contact
them and that he would send the bill, maybe send a letter, I mean, I
don't know what, and then he might even call himself, I assume.
Question. Did he generally apprise you of when things were running
late?
Answer. Yes. I mean, he would say in passing--you know, I think he
wasn't necessarily my responsibility, but I think he knew if he said
something to me about it that I would, you know, try and get people to
pay attention to it.
Question. And what did you do when he told you about that?
Answer. I might call somebody at the DNC.
Question. Do you know who you would call?
Answer. It would just depend on who I saw, and I might call them, I
might see them, I might tell Harold, somebody in the political
division, you should call somebody over there, if I saw--I can't think
of that guy's name. He works with the DNC.
Question. A finance person?
Answer. Dark hair. I'm sorry, I will just make a note of it. I can
see him, but I can't think of his name.
Question. Is it Mr. Sullivan?
Answer. No.
Question. I don't know.
Answer. I know you probably can't help me. You can't help me, but
it was someone.
Question. Do you know if it was who worked in the Finance Office in
particular?
Answer. I believe he was in the Finance Office.
Question. Or billing services?
Answer. I don't know how they were cut up that way.
Question. Do you know if you ever wrote any memos or notes to DNC
people about paying the bills?
Answer. Who?
Question. If you did.
Answer. I never did write anything.
Question. When Mr. Walters talked to you, you would talk to
somebody orally about, get after this, somebody should look into this,
and direct somebody else to do something about it?
Answer. It would just depend. I mean, if I happened to talk to Gary
and walked into Harold, I would say, Harold, the DNC has not paid its
bill, or I would write it down, and I would say, today I will call the
DNC, I will call the Library of Congress, and I will call this one. It
is very haphazard.
Question. Were you familiar with the First Lady being asked to make
DNC fund-raising calls?
Answer. I am, from the newspapers, from a question that she was
asked in a news conference, and from a memo from Harold Ickes that made
a suggestion about it, but whether or not she made the calls, I am not
aware of that. But those are the two places I have heard about that.
Question. Okay. And did the memo you mentioned from Harold Ickes,
is that something you recall being contemporaneous with the request for
the calls?
Answer. I don't quite understand that.
Question. Do you recall that--Harold writing a memo about something
asking the First Lady to make calls last year or in '95?
Answer. I would be very bad on a memo. I mean, it just--you know,
it's just one in his continuing series of memos. I mean, it doesn't
stand out in my head.
Question. You got a lot of memos from Mr. Ickes?
Answer. Yes.
Question. Do you recall having any discussion with Mr. Ickes about
the First Lady making DNC fund-raising calls?
Answer. No.
Question. Okay. At or around the fall of 1995, do you remember
discussions about the media fund and--to get a lot of media in the fall
of 1995? And if it helps you, that is the time of the budget battle,
and Mr. Morris was encouraging a large media buy for the fall of 1995,
and particularly encouraged a $10 million fund be utilized in that
time. And sort of putting it in that context, do you recall Mr. Ickes
asking you about having the First Lady make phone calls to assist in
this media fund?
Answer. No, I mean, I certainly do recall Dick Morris wanting to
put a lot of money into media. I didn't realize it was called the media
fund.
Question. Okay. Were you involved in some of the discussions with
Mr. Morris advocating the media, you know, large media buys?
Answer. I was involved inasmuch as I attended the Wednesday night
strategy sessions, but they were more focused on substance than--but I
certainly know that, you know, Mr. Morris used that as a forum to say
we needed to get more media.
Question. What was your understanding of sort of the discussion
back and forth about having this large fall '95 media campaign?
Answer. Well, actually, at this particular meeting, it was not----
Question. I'm sorry, what is this?
Answer. The meeting that--the times that I heard Dick Morris
advocate for more money for media was our Wednesday night strategy
meeting. The focus of the meeting was not a discussion of the media
budget, it was the--the focus of this was to talk about policy. There
would be times that we would screen the advertising, but mostly to
screen it in the context of whether or not we thought it worked, said
the right things, whatever, so it was more substantive. So peripherally
Mr. Morris would advocate for a media budget, but a discussion of it
was not--that was not the place where they had that discussion.
Question. Can you describe, when you said you viewed the media,
where that occurred, what the process was?
Answer. I mean, not much of a process. They would set up a
television and VCR, and if there was a commercial on a certain subject,
they would ask us--Mr. Morris would ask us to look at it and invite
comments.
Question. And who was involved in these meetings?
Answer. Well, the President, the Vice President.
Question. Mr. Ickes?
Answer. Mr. Ickes, Mr. Panetta, Mr. McLarty, you know. Actually,
New York Times ran a picture of the seating of that meeting where they
had everybody there.
Question. That was the group?
Answer. That was it. You remember that.
Question. I recall that.
Answer. That is it. Mr. Sosnik.
Question. Mr. McCurry was involved in that sometimes?
Answer. Yes, sometimes, yes.
Question. Okay. And were there discussions of what should be added
to the commercials?
Answer. Yes, critiquing them.
Question. Was the President involved in that discussion then; the
President, Vice President were present at these discussions?
Answer. Oh, right, because it had to do with substance and policy,
yes.
Question. Did the President ever make any suggestions on changes in
that, in the media, in the commercials?
Answer. Oh, yes, he had his say.
Question. In the meetings do you recall what he said about any
particular one?
Answer. I mean, you know, there are dozens of them.
Mr. Ballen. Excuse me, I am going to object to the relevancy of
advertising and the President. I object to this line. It is not
relevant to the committee's inquiry into the campaign finance fund-
raising abuse or any possible violations. The President may have made a
suggestion about an ad or not.
Ms. Comstock. I am just asking the question about the President's
role in these meetings you are describing.
EXAMINATION BY MS. COMSTOCK:
Question. Do you recall him discussing--was he usually a vocal
participant in the meetings?
Answer. The focus of the meeting was substance and policy, so a lot
had to do with his interest in whatever policy or substantive matter
was going to be made public, you know, so, yes, he certainly was
interested.
Question. Any comment on the commercials that Mr. Morris would
show?
Answer. He was interested, yes.
Question. Did he make comments on change that, or try this,
anything like that?
Answer. I don't remember specifically, but I can't imagine that
that wouldn't be the case in a situation where everyone could critique.
Question. All right. And in any of these meetings, do you recall
any general discussion about the benefit or wisdom of this large media
campaign in or around the fall of '95?
Answer. No, because--well, I don't recall specifically. I mean,
there could have been. I don't recall specifically, but just that the--
and I don't remember everything that happened at these meetings, but
what sticks out in my mind is what the core of the meeting was, which
was substantive and policy-related issues, so----
Question. Do you recall Mr. Ickes ever discussing his opinion on
the wisdom of spending this kind of money on an early media buy in '95?
Answer. You know, I don't really recall specifically, but I do know
from newspapers now he is characterized as having been against it. That
was not the sense that I got, nor did I ever hear that.
Question. So at the time in the fall of '95, you had no knowledge
of his being opposed to that plan?
Answer. Yes, not to that plan, no.
Question. Did you have any knowledge of anybody generally being
opposed to why are we doing this in the fall of'95?
Answer. My good, I can't imagine that someone wasn't, I mean, it is
the Clinton White House. I mean, I can't imagine someone wasn't opposed
to it. I mean, I just didn't focus on those discussions or happen to be
involved in them, I guess.
Question. And were you aware--in the fall of'95, were you aware of
increased--any increase in efforts to utilize the White House for fund-
raising purposes or have events at the White House or----
Answer. An increase in efforts?
Question. Yes.
Mr. Ballen. I am going to object. What does counsel mean by ``using
the White House for fund-raising purposes''?
Ms. Comstock. Have events at the White House.
Mr. Ballen. Where there would be fund-raising?
The Witness. We can't have those at the White House.
EXAMINATION BY MS. COMSTOCK:
Question. Do you recall the DNC making additional requests for
events at the White House?
Answer. Sure. I can't imagine that they didn't.
Question. Do you have any knowledge of if there was any effort in
connection with this media fund to have more events at the White House
in the fall of '95?
Answer. Well, since, as I said before, I wasn't aware--I mean, I
didn't focus on there being a media fund that we were all supposed to
be raising money for. I just don't have that idea in my head of a media
fund. The question is did the DNC--was the DNC interested in having
events at the White House? Yes.
Question. Okay. Let me return a little bit to the bills. After the
DNC had an event, do you know the process by which the bills would be
submitted for that event?
Answer. No.
Ms. Comstock. I am showing the witness a memo from the DNC,
actually DNC finance call sheets, DNC by State number, 3234, 6944. The
next page is 34 through--I'm sorry, these are somewhat out of order.
Actually, I don't know--do you have 44 on the top of your copy? Why
don't we correct it. I think it starts 323, 6934, and then it goes
through 45. That one that was on the top page should be the second to
the last page. And these are call sheets for Hillary Rodham Clinton.
The documents indicate they were prepared by Marvin Rosen.
EXAMINATION BY MS. COMSTOCK:
Question. Do you have any knowledge about DNC call sheets prepared
by the First Lady?
Answer. I have never seen this, no.
Question. Do you have any knowledge of Mr. Rosen talking to the
First Lady about making DNC fund-raising calls?
Answer. No, I don't have any knowledge.
Question. Okay. Then directing your attention to reason for the
call, it says us to--on the first page, 3236934, says, ``Ask to
contribute an additional $50,000 for the DNC media fund,'' and actually
a number of these, as you go through, I think most of them are asking
for money for the DNC media fund. There isn't a year date on this.
Answer. It says December 4. Well, on one of them.
Question. I believe the time frame is 1995. I think they have been
written about in the press.
Well, we don't have the year on here, but it is talking about
contributions made in '94 and '93, and presumably no one was asking her
to make fund-raising calls in December of '96, unless you have
knowledge about anybody asking, but I am assuming that. So given the
dates on here and what seems to be logical appears they may have been,
they probably were, December of '95.
Is it your testimony then you have no knowledge of any efforts for
the First Lady to raise money for the DNC media fund?
Answer. Not--first of all, not through call sheets or calling. I
have never seen these. As I said before, the idea of the DNC media fund
is something that just doesn't strike me as what I am familiar with.
Was Mrs. Clinton asked to help raise money for the DNC? Absolutely.
And, you know, I am assuming here this DNC media fund is a part of the
DNC. Yes, as I said before, they did,.
Question. All right. Do you have any knowledge about the First Lady
ever making fund-raising calls for the DNC?
Answer. No.
Question. So you have never seen her make a fund-raising call or
talked to her about a fund-raising call?
Answer. I haven't, and I have never seen this packet.
Question. And then maybe just review any of the names in here that
were directed to call. See if you have any knowledge of the First Lady
contacting any of these people on here for--you know, if you had
contact with them in connection with the First Lady or the White House?
Answer. Well, I had contact with them in connection with the First
Lady, but not in connection to the--to fund-raising. Sue Bailey was at
the Department of Defense at some point, then she went to work for
Clinton/Gore. I don't----
Question. Because this document indicates that Dr. Bailey resigned
her position at DOD in June to work with the Re-elect Committee on
women's fund-raising. Is that your knowledge of Ms. Bailey?
Answer. That is right.
Question. Was she involved in any events at the White House, to
your knowledge?
Answer. I am sure any event that had to do with women, that she was
probably there.
Question. Okay. And the events, sort of coffee-type events or
lunches, is that what you are referring to?
Answer. I was just thinking more generally. I would have to see the
list of the coffees to know if she went to that. I don't know if she
did or not.
Question. Were you ever aware of any luncheons or events that Dr.
Bailey was involved in where donors were primarily--like women's
leadershipship funds, donor types?
Answer. Right. Women's--I would have to look at a list to tell you
whether or not Dr. Bailey was there. I believe there was a Women's
Democratic Leadership Forum gathering at the White House. They
generally were all over the country, but I believe there was, but I
would have to see a list to find out whether she was there or not, I
just couldn't say. I don't know these people.
I think maybe I heard of Denise Rich.
Question. That is on DNC 3236931.
Mr. Ballen. Can I understand the question pending?
Ms. Comstock. If Ms. Williams had any contact with the people who
are identified on the finance call sheets at the White House.
Mr. Ballen. In general or in connection with the financing.
The Witness. I understand the question in general. I don't know if
I am wrong.
EXAMINATION BY MS. COMSTOCK:
Question. Yes, in general.
Answer. I don't know. It just sounds familiar. I think because she
won a Grammy. Susie Tompkins I have met. I don't know in what context.
Question. Do you have any knowledge of her being involved in fund-
raising or----
Answer. It says here--I think I do recall something about her
holding the fund-raiser for Clinton/Gore in San Francisco.
Question. That is indicated on 3236941. That sounds familiar to
you?
Answer. I mean, I know about Ralph Lauren, but not in connection to
his donation. He helped one Christmas in decorating for the White House
Christmas.
Question. And did a lovely job, too.
Answer. Right, which is how I heard that.
Those are the only people that I recognize.
Question. Okay. Directing your attention to page 3236937, it is for
somebody--it is Ayse Kenmore. The additional notes on that page
indicate that?
Answer. I'm sorry?
Question. The additional notes indicate--it says she has been to a
number of events at the White House. Do you know generally how the DNC
learned about how many events people attended at the White House?
Answer. No.
Question. Do you have any knowledge of whether anybody at the White
House ever used the White House database to tell DNC people about how
many events somebody had attended at the White House?
Answer. No.
Ms. Comstock. Okay. I will go ahead and make that Deposition
Exhibit No. 10.
[Williams Deposition Exhibit No. MW-10 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. Did you know Marvin Rosen at all?
Answer. Yes.
Question. Was he at the White House often, or did you see him at
the White House often?
Answer. No, I saw him as he--I think I saw him at a couple of
dinners maybe. You know, occasionally I would see him, but not a lot.
Question. Okay. Do you recall any sense as to where he had meetings
with the First Lady, particularly at the White House?
Answer. Not particularly. I would have to look at his schedule.
Question. And we have generally discussed the coffees that you
referenced earlier?
Answer. Yes.
Question. What was your understanding of what the purpose of what
the coffees was?
Answer. The coffees were to gather supporters of the President and
Mrs. Clinton for issue discussion.
Question. Were you aware of any discussion at the White House about
people talking at these coffees in reference to fund-raising?
Answer. Not in reference to fund-raising, but that they were DNC
lists, they were people the DNC was proposing.
Question. And did you have an understanding that these people
generally were donors?
Answer. Well, from the look of some of the lists of Mrs. Clinton's
coffees, a fair number of them were not donors actually. I don't know
about the President's coffees, but we had, you know, from the list,
because I don't know who actually attended ultimately, but we tended to
have people who worked on different kinds of issues, people who maybe
were State chairs, people, and some contributors, too. But I think that
the coffees that she attended had a healthy mix because I remember at
one point, I think she was asking to get people who had worked on
health care, so it was really a kind of an issue meeting. She never
thought she had long enough to discuss the issues at length that people
wanted to talk about.
Question. Did you usually attend these coffees?
Answer. No, I didn't go to any of them.
Question. Do you know who attended, staff, with the First Lady, who
attended?
Answer. From our staff, her policy person went, Melanne Verveer.
Question. She was generally the person who attended?
Answer. Yes.
Question. Do you know how these were set up or who made the
arrangement, is that Miss Solis?
Answer. Yes.
Question. S-O-L-I-S.
Answer. I assume it just went through the process of if the DNC or
Clinton/Gore had suggested it, that it probably came through our
political office, Patti Solis agreed on a date and on participants.
Question. And did the invitations go out from the DNC or from the
White House?
Answer. I can't imagine they would go out from the DNC. It would be
seen as a White House event. An invitation to the White House goes out
from the White House.
Question. So do you know somebody then from the White--how are
invitations done at the White House, if you can generally describe the
process?
Answer. Well, once again, if the list process works, and so they
have agreed by schedule that, let's say, Mrs. Clinton will go to
coffee, this event is sponsored by the DNC, and so they would submit a
list of who would be included, and then that list would go to the White
House social secretary and her people will usually write the
invitation.
Question. So if I were an invitee to one of these First Lady's
coffees, I got an invitation from--one of those pretty ones from the
White House?
Answer. I would--I mean, the rule is that if you are invited to the
White House, the invitation must come from the White House. I didn't
hear of anybody breaking that rule, so it is my assumption that is what
you would get.
Question. That is sort of the social secretary prototype rules,
that Emily Post type things?
Answer. It is very much so and very much enforced.
Question. So if you get something inviting you to the White House
from the DNC, it is sort of a bogus invitation, that is the White House
rule?
Answer. Right.
Question. Were you ever aware of anyone at the DNC providing back
feedback to your office or other offices at the White House about how
much money had been raised as a result of the coffees, people had been
contacted before, after?
Answer. Not to me, not to my office.
Question. Did you ever see any spreadsheets showing how much was
contributed, generated from any particular coffees?
Answer. I don't recall seeing a spreadsheet.
Question. Have you--I mean, some of the spreadsheets, Mr. Ickes'
spreadsheets, he turned over to the committee have been in the
newspapers somewhat. Did you ever see anything like that while you were
at the White House?
Answer. I mean, not that I can recall. I mean, I can't say if it
was in an Ickes memo where I was cc'd. I may have; it just doesn't jump
up at me.
Question. Were you ever aware of any type of targets or numbers,
amounts of money that would try to be raised as a result of any events
at the White House?
Answer. As a result of an event at the White House?
Question. Yes.
Answer. Not at the White House. I was more aware of if there was an
event outside of the White House.
Question. I am talking----
Answer. What the target would be, yes, I would know that.
Question. I am talking more about the events in the White House,
and generally, I had----
Answer. No.
Question. I will provide that. I don't want to be talking past you
without a document here, but we have a number of spreadsheets which
indicate, you know, targeted amounts of $400,000 to be generated from a
coffee and then how much was raised, which was often $400,000. Did you
ever see anything like that in a spreadsheet?
Answer. I don't recall seeing anything like that.
Question. Did you ever have any discussions with anyone or hear
anything about, you know, each of these coffees is worth a certain
amount to us?
Answer. Oh, no.
Question. Anything like that?
Answer. No.
Question. Okay.
Question. Do you know who Ernie Greene is?
Answer. Oh, yes.
Question. All right. And when did you first meet him?
Answer. Sometime in the '80s.
Question. And are you social friends with him or no--just know what
type of acquaintance?
Answer. I knew him when he worked for Jesse Jackson, on Jesse
Jackson's campaign. That is how I first came to know him. I would think
we would be friends.
Question. And do you know if he was involved in fund-raising at all
for the DNC or Clinton/Gore?
Answer. I believe he is a trustee. I don't know. Either one or the
other or maybe both. I don't know for sure.
Question. Did you generally have a knowledge of individuals who are
trustees?
Answer. Yes, yes, kind of, yes.
Question. And how did you learn about that?
Answer. Well, I think that DNC has--I was trying to think about
this the other day. DNC sponsors at the White House at least once a
year a dinner for managing trustees of the DNC, and I think, you know,
just in my kind of goings and comings I picked up on it. I didn't have
a real formal way of knowing, but I think I knew generally who they
were.
Question. Did you ever attend any of those events?
Answer. You mean sit down at them?
Question. Or just attend, in any capacity, a reception?
Answer. Yes, I mean--I thought about this since my last deposition,
all these events were like the same event to me. I mean, not just the
DNC event, all the events. I would usually stop by an event at the
White House to see how it was going. I would, almost without fail, as a
matter of protocol, be invited to every event. But they pretty much had
a standard form, so I would walk into a DNC event, I would walk into a
Kennedy Center event, so I was around.
Question. Okay. Did you become aware of an individual named Charlie
Trie from any of these trustee events?
Answer. No.
Question. Or Johnny Chung?
Answer. I don't know if I met Johnny Chung at one of the events,
but I did meet Johnny Chung at some places.
Question. Did you ever get any lists from the DNC on trustees?
Answer. Not that I recall a list. I am trying to think if they had
any publications that would list their trustees or any kind of
letterhead. There is something that makes me think I have seen a list
of the trustees at some point.
Mr. Ballen. Did you see them in the newspaper?
The Witness. I just don't recall where.
Mr. Ballen. These were public events?
The Witness. At the White House?
Mr. Ballen. Yes.
The Witness. Oh, yes, they were trustee events.
EXAMINATION BY MS. COMSTOCK:
Question. Were you aware of any private dinners or private lunches
or anything with trustees, or set up particularly for trustees?
Answer. I just have to look at a list to see.
Question. Were you aware of any connections that Mr. Ernie Greene
had with Charlie Trie?
Answer. No.
Question. Do you have any knowledge of any business matter that he
was working on with him?
Answer. No.
Question. So in your knowledge, with Ernie Greene, you never even
knew he knew Charlie Trie?
Answer. That is correct.
Question. Have you ever talked to Mr. Greene about Charlie Trie to
date?
Answer. No.
Question. And do you know Mark Middleton who worked at the White
House in the chief of staff office?
Answer. Yes.
Question. When did you first meet him?
Answer. I think he started with Mack McLarty in '93. I mean, I met
him at the White House when he worked for Mack.
Question. And what kind of interaction did you have with Mr.
Middleton while he was employed at the White House?
Answer. While he was the chief of staff assistant or executive
assistant, we were very friendly. If I needed to speak with Mack
McLarty, he would make sure that I got in to speak with him. He was,
you know, just seemed to be an extremely competent and very friendly
towards me.
Ms. Comstock. Okay. I am sorry, I wanted to return, just briefly,
to Mr. Greene, before we move on to Mr. Trie. I want to show the
witness EOP 59099, which is a message pad from sometime between 8-17-95
to 8-29-95. This is a message pad, either from somebody in the First
Lady's office or in Melanne Verveer's message pad. Message to Melanne
of 8-29, which says, Mr. Ernie Greene, at suggestion of Alexis Herman,
was calling, and then the part of the memo says, ``Trip to China,'' and
``Supporter from Arkansas, Charlie Trie.''
EXAMINATION BY MS. COMSTOCK:
Question. I was wondering if that refreshed your recollection as to
whether or not you ever had any discussions with Mr. Greene about
Charlie Trie or if there is any knowledge about Melanne Verveer talking
to Mr. Greene or Mr. Trie relating to anything related to China?
Answer. No, but this is to Melanne.
Question. Yes, this is not your message. I was just wondering if
you have any recollection of talking to Melanne about Greene and
Charlie Trie?
Answer. No.
Question. Do you have any knowledge about Mr. Greene trying to get
anybody on to trips to China?
Answer. No.
Question. Okay.
Answer. On trips to China?
Question. Any kind of official delegation trips to China?
Answer. No.
Ms. Comstock. Make that Deposition Exhibit No. 11.
[Williams Deposition Exhibit No. MW-11 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. I am going to return to discussing Mr. Middleton. We
previously discussed the April 21st, 1994, memo which--where Mr.
Middleton provided the fund-raiser list. Do you have any knowledge of
Mr. Middleton at a meeting with fund-raisers or anything while he was
at the White House, or that being any type of role that he had?
Answer. No, not especially. I mean, he sat out front of Mack's
office. Everybody walked in there.
Question. Okay.
Answer. I don't know if that was a role of his.
Question. Did he have a role of sort of catering to bigwigs or
anything like that, in terms of being in the chief of staff office?
Answer. I think he had to be nice to everybody, I think.
Question. What was your knowledge of, or if you have any knowledge,
about Mr. Middleton being involved in his White House duties with
anything connected to Asia policy?
Answer. I have no knowledge of his White House duties.
Question. Okay. Did you have occasion while you were at the White
House to ever meet the Riadys?
Answer. No.
Question. Do you have any knowledge of what Mr. Middleton's
interaction was with the Riadys?
Answer. No.
Question. Do you know somebody named Joe Giroir, G-I-R-O-I-R?
Answer. No.
Question. From Arkansas?
Answer. No.
Question. A former law partner at Rose, an Asian businessman?
Answer. No.
Question. Does business in Asia?
Answer. No.
Question. Okay. After Mr. Middleton left the White House, what was
your understanding of what he was doing when he left the White House?
Answer. Some kind of international business.
Question. Did you keep in touch with him?
Answer. Yes. From time to time, yes.
Question. And for what occasions did you keep in touch with him?
Answer. Well, he would call my office and want to use my Mess
account.
Question. Can you describe what that is, what that involved?
Answer. People at the White House have an account at the cafeteria,
and----
Question. Now this isn't the cafeteria that anyone can eat at, this
is the White House Mess within the West Wing?
Answer. Yes, it's in the basement of the White House.
Question. And only certain people, sort of senior level staff have
access to that, generally, have privileges?
Answer. Actually, that was the way it had been in the past, but
when we came we extended it to anybody who actually worked in the West
Wing because it was easier for them to get to than going across the
street. So people in the Old Executive Office Building tended not to
have them. Everyone who was an assistant to the President, even if you
worked in the Old Executive Office Building, had them, but if you
worked in the West Wing, whoever you were, you had access to the Mess.
Question. And I guess we can return, you said Mr. Middleton would
call----
Answer. And Mr. Middleton called and said to me or Evan, Evan Ryan,
who worked for me, would say, I want to use your Mess account to go to
the Mess.
Question. And what was the policy on that?
Answer. Well, at the time there was no policy that I knew of. There
was no policy that I knew of, since, you know--I mean, you pay for--I
mean, it's like a personal account. They send you a bill; you write
them a check.
Question. You got a bill at the end of the month or after the
event?
Answer. I think they do it--I think they do it at the end of the
month. Maybe they do it every 2 weeks. I get it and then I write a
check.
Mr. Ballen. So you pay for the lunches you have there?
The Witness. Yes, if you have an apple, a cup of coffee, you fill
out a slip of paper and you pay for it. You get back, you know, five
cups of coffee and you write them a check. So he would call and say, I
want to eat at the Mess today, can I use your account, and I would say,
sure, have Evan clear you in or you call Evan and Evan would say, Mark,
wants to use your Mess account, do you care, and I would say, I don't
care.
Question. So somebody from the Mess would call?
Answer. No.
Question. How does that work?
Answer. The Mess account is your own account. No one from the Mess
calls. So if you wanted to go to the Mess, you would call me. I mean,
if you were my friend, you would call me and say, can I use your Mess
account.
Question. And would you give the account number, too?
Answer. No, you have to make the reservation. I think that really
is probably the only policy. The reservation is in your name and only
you are--I guess Evan or your office can make the reservation, and then
you have the additional responsibility, your office, you know, doing
the usual White House process, which is to submit the names of anyone
who comes. You submit their names to WAVE so they can be brought in.
Question. So you would--you or someone in your office would call
down and make the reservation?
Answer. Make a reservation and they would clear Mark in.
Question. And then the WAVE's office would kind of physically get
them in. They would go there and you would have provided the names to
the WAVE's office if they can be cleared in?
Answer. And I would get a badge or something and let them go in.
Question. And now when they come into the West Wing, they have to
be escorted; is that correct?
Answer. No, if they would be cleared in for the Mess, and I don't
know what all the badges mean at this point, but as I understand it, if
you are cleared in just for the Old Executive Office Building, which
sometimes happens with WAVEs, then in order to get to the White House,
which is another level of security, then you would have to be escorted,
but you can get cleared in, depending on how good the person is doing
the clearance and the one accepting it, to go straight to the White
House. And they would demand, you know, more information for that
security job.
Question. And so when Mr. Middleton would call to get his to come
there, was it your understanding he was bringing people with him?
Answer. I actually had no understanding. If Mark Middleton called
to use my Mess account, he called to use my Mess account. If he brought
people in, I mean, I guess I assumed he brought people in. People bring
their mothers or friends to the Mess.
Question. You didn't have any understanding whether it was his
mother or business associate?
Answer. No.
Question. He never told you anything about why he wanted to come,
that he was having other meetings at the White House or anything like
that?
Answer. No. I mean, I just thought he wanted to use my Mess account
so I let him use my Mess account.
Question. And did you do this often with other people, too?
Answer. With other people, yes.
Question. How many?
Answer. Oh, I don't know, anyone who was at the OEOB who wanted to
go, come in, other colleagues who had left who wanted to, I probably
let them use my Mess account. I wasn't--I rarely myself ever got a
chance to go to the Mess to have lunch, though. I mean, it was just not
a----
Question. Would these individuals pay you back for----
Mr. Ballen. Did you finish your answer?
The Witness. I forgot what I was going to say. I allowed other
people to use it. I mean, it wasn't necessarily special to me, but I
would let other people use it.
EXAMINATION BY MS. COMSTOCK:
Question. I am wondering, was it running up big bills you then had
to pay back or how does that work?
Answer. I guess I just mostly wrote the checks. This happened a lot
for people, especially OEOB, when you have people who work for you,
because it is the only place that is open late at night. It is open at
late and the cafeteria on the OB closes, and so generally, you get a
lot of, put it on, use Maggie's Mess account, and then like 10 people
eat off of it. So I wasn't necessarily as focused on the bills. I would
let people use it and the bills would, you know, 100, 200, something
like that.
Question. And then particularly with Mr. Middleton, would he, like,
write you checks afterwards?
Answer. You know, I don't know if he did or not. If he did, he
would have given it to Evan Ryan or someone else in my office. Usually
what I got was a note that said your Mess bill is such and such, sign a
check, get a check to me.
Question. And then did you go out and sort of personally collect
from everybody what they had?
Answer. No, actually, I rarely collected from anybody. I rarely
collected from anybody. I really didn't think about it. If Evan thought
about it, she would. If not, I would just write the check.
Mr. Ballen. So this wasn't a big deal to you; this was just an
accommodation?
The Witness. It started out, like I said, primarily as an
accommodation, and the staff in the OEOB could use it and it was the
only place open late so you just get to do it, you know, because you
are the one who has it. And, you know, Mark was a former colleague and
a friend.
EXAMINATION BY MS. COMSTOCK:
Question. I mean, were you running up hundreds of dollars of tabs
here?
Answer. It is not like my legal bills, okay. It is small change
compared to that. But you would find, in the White House, you would
find a lot of people who do that for other people.
Question. Okay. Can you generally distinguish, was it mostly people
internally as opposed to former colleagues who were coming in?
Answer. I have no distinguishing. I mean, it was just--it was at
the level of minutia for me on this thing. It just didn't matter to me.
I didn't make any distinguished--it was basically a level of
familiarity for me. It could be internal; it could be external. They
have since developed a rule about it, but I was not aware of any such
rule at the time.
Question. Okay.
Ms. Comstock. I am just going to show the witness phone messages
EOP 59039. Actually, these are not sequentially ordered. It is a
grouping of phone messages, referencing Mark Middleton, calling, trying
to get into the Mess. Some are to you, some are to others. On 59041, it
is to Marj from Mark Middleton, says, please make lunch reservation for
seven on Friday. It says, ``Make under Maggie's name.''
EXAMINATION BY MS. COMSTOCK:
Question. Do you know who Marj is?
Answer. Marj used to work for me.
Question. Okay. And that is 5-17-95.
And then there is one to Evan on 6-7, Monday, Mess, two people, and
October there, it is very hard to read, then July, 12:00 o'clock, for
three people, the names are there. Do you know who Larry Jaynes or Jim
Messec is?
Answer. No.
Question. Then there is 1-17-96, to Evan. It says, ``Please make a
reservation for him in the Mess for January 24, a table for four.'' So
your testimony is that you don't--you didn't really know who he was
bringing in, he was just using your account?
Answer. He used my account.
Question. Okay.
Mr. Ballen. If anyone.
The Witness. Pardon?
Mr. Ballen. If anyone, if he was bringing in anyone.
Ms. Comstock. Well, I think these messages indicate he was making
reservations for seven, so presumably he was bringing someone with him
on this, EOP 9451.
Mr. Ballen. We are talking about the witness' knowledge.
EXAMINATION BY MS. COMSTOCK:
Question. Was it your understanding Mark Middleton was coming in
alone to have lunch at the Mess?
Answer. He could have. I never thought about it at all, one way or
the other.
Question. I think you previously testified he was bringing somebody
with him, or did you----
Mr. Ballen. Objection.
The Witness. I hope my previous testimony was that if he brought
his mother or whatever, he could bring whoever. I mean, I didn't think
about it.
EXAMINATION BY MS. COMSTOCK:
Question. You didn't know who he was bringing?
Answer. Right.
Ms. Comstock. I will make that Deposition Exhibit No. 12.
[Williams Deposition Exhibit No. MW-12 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. Did you ever refuse the Mess privileges to Mark Middleton
or say, no, my tab is up too high or I haven't been collecting on this?
Answer. No, that wouldn't be my nature.
Question. Are you aware of other people who he called at the White
House to use their Mess privileges?
Answer. No.
Question. I believe Miss Ryan has indicated she really wasn't
involved in the collection process on the bills. Do you know anybody
else in your office who may have been trying to collect the bills?
Answer. Probably nobody. If she wasn't, nobody was.
Question. If Evan wasn't, you don't know of anybody else who may
have been trying to follow up on these, after people to use the
account?
Answer. No. That would have been great. No, if Evan wasn't, then it
wasn't happening.
Question. I would like to show you Mark Middleton WAVE records,
generally, not just in the Mess things, and see if you know some of the
people he was meeting with or if you recall any of the occasions of the
meeting. These are EOP 20376.
Answer. Okay. Let me see.
Question. 20376, again, these are a little out of order. There are
other people in here so these aren't necessarily sequential, so as we
go through them, I will note the numbers so the record is reflecting
what page we are looking at.
On the first page, 20376, there is a four--generally, before we go
into these item by item, do you recall generally having meetings with
Mr. Middleton after he left the White House in the spring, summertime
of 1995?
Answer. No, I might--he might have dropped by to see me. I am
trying to think. He might have dropped by to see me. I remember
scheduling a meeting with him. When did he leave the White House?
Question. Approximately mid-February, '95.
Answer. No, I would see him around. It seems to me I saw him
around.
Question. Okay. Then maybe this will be fairly quick to go through
if you don't recall the meeting.
There is a 4-21-95, bottom line on the first page there from Mark
Middleton. It shows the requestor was Ryan and the visitee was Ryan?
Answer. I'm sorry, go ahead.
Question. Are you familiar with these documents or how to read
them?
Answer. I am just trying to read the 1310. Is that like 1:10?
Question. Yes, military time.
Answer. So it is probably lunch time. Okay. All right.
Question. Then there's another one on the next page which the
number is a little cut off, but I think it is 20377. There is--the
fifth item down is a 5/9/95----
Answer. Uh-huh.
Question [continuing]. Mark Middleton WAVE where the request is
Ryan and the visitee is Williams and 5/19 also. I was wondering in this
April or May time frame if you recall any topics that may have been
coming up that you may have been meeting with Mr. Middleton on?
Answer. Topics?
Question. On what he may have been visiting your office for?
Answer. No, all I can think is lunch or to stick his head in to see
me. I really don't. I'm trying to think.
Question. Do you know if----
Answer. 1 o'clock?
Question. Here is a highlighter, if that helps you. I notice that
you are underlining, and if that helps you.
Answer. I'm just trying to----
Mr. Dennis. What's the date on that?
The Witness. I think it's----
Mr. Dennis. I can't figure out from the WAVE what the dates are.
The Witness. The dates wouldn't mean anything to me.
Ms. Comstock. We can go off the record for a minute, and I can show
both of you how it sort of works.
[Discussion held off the record.]
Ms. Comstock. We can go back on the record.
The witness has been reviewing the WAVE records, and we have
generally been discussing how to read them so that the witness
understands what she is referring to.
Mr. Ballen. And what is the pending question?
The Witness. I thought, did any of these strike me as significant
or did I recall?
EXAMINATION BY MS. COMSTOCK:
Question. Did this refresh your recollection as to meetings with--
any meetings or times you met with Mr. Middleton or any of his
associates?
Answer. Well, the dates always mean nothing to me. I can't--dates--
--
Question. I understand specific dates, but if--the general time
frame?
Answer. I guess a lot of these look like lunches, except for a
couple here which I don't--it doesn't refresh my recollection, and I
really don't know what----
Question. There's a seating at the mess for 1:15? At 12:00 and at
1:15?
Answer. Yeah, I think it's 1:15 or 1:30.
Question. Specific times?
Answer. They're specific times, kind of. They're specific times,
but the mess closes--I think it closes at 3:00, so, you know, you can
be under the wire a little bit.
These--I mean, they don't--you know, I saw Mark around. I don't
remember, you know, what I talked to him about, other than how're you
doing?
Question. Do you recall if Ms. Ryan was ever meeting with Mr.
Middleton for any purpose that you know of?
Answer. I mean, I would think there would be no purpose.
Question. Okay. And I wanted to direct your attention to 5/19/95,
one on the second page here?
Answer. 5--I'm sorry?
Question. On the second page. The one that's hard to read the Bates
stamp number. There's a 5/19. It says Ryan requesting and Williams is
the visitee and says second floor, West Wing.
Answer. Would you just mark it?
Question. I'm sorry. I'm forgetting. Is the mess technically on the
second floor? Is that the first----
Mr. Dennis. Basement.
The Witness. It's really in the basement. But when WAVEs show--
depending on where you make, sometimes, the reservation for, they'll
say, you know,--they'll give me office number as the----
EXAMINATION BY MS. COMSTOCK:
Question. Place?
Answer [continuing]. Number that you're coming to. They won't
necessarily say mess. They'll give like an office number.
So like here, Mack McLarty. They're a little bit more exact here.
They say ground floor. Mack's office is the ground floor, West Wing.
The same above. They have West Wing. I mean, kind of depending on who,
like I said, is doing the WAVEs thing on the end. I had an office
second floor, West Wing, and an office 100 OEOB. So that could be--you
know, they have to come up with a destination and they use your office
generally.
Let me see if that's consistent throughout.
Mr. Dennis. You have 100 here.
The Witness. Right. They go back and together.
EXAMINATION BY MS. COMSTOCK:
Question. In reference to the 5/19/95 meeting--I apologize in
advance. It's a document numbered EOP 56855, but this is another WAVE
record we've got from the White House. It's for Mr. Ng Lap Seng.
Answer. Where is that?
Question. I'll highlight it for you. You can see it if it's
highlighted.
Answer. Okay.
Question. Lap Seng is on the left-hand side there.
Answer. Okay. Okay.
Question. 5/19. And----
Mr. Ballen. We would stipulate that that's what it is, if you want
to write it out.
Mr. Dennis. Yeah. You can see it L-A-P, S-E-N-G.
The Witness. I can see----
Ms. Comstock. You can see the ``N-G'' a little to the right, and
then it's ``Williams.''
Mr. Dennis. But then it is Khapra on the line there.
Ms. Comstock. There is also--because these were WAVEs--a number of
his WAVEs--that's a separate time for Khapra.
Mr. Dennis. Below that it looks like a Larson--oh, maybe that is
Lap. Yeah, it is both of them.
The Witness. And these are the same dates for the one above and
below?
Ms. Comstock. Yes.
The Witness. So he went--is that noon?
Mr. Dennis. 13:15.
EXAMINATION BY MS. COMSTOCK:
Question. Yes, noon.
Do you know Yusef Khapra at the White House? Do you recall who he
was?
Answer. I think he worked for Mack at some point. I'm not sure--or
Mark at some point.
Question. And--but this is--the 5/19, your name is the same time as
visit time at 1:15 as Mark Middleton; and I was wondering--and this
is--Ng Lap Seng is also known as Mr. Wu, the partner of Charlie Trie.
Do you recall ever meeting a Mr. Wu or a Mr. Ng Lap Seng?
Answer. No.
Question. Do you have any knowledge of Mr. Middleton bringing this
individual to your office?
Answer. No.
Question. Or to the White House?
Answer. No, huh-uh. Not at all.
Question. So on this date, whatever, this May 19th, '95, when Mr.
Middleton came to the White House the same time as Mr. Ng Lap Seng both
under your name, you have no knowledge of what he was doing there or if
he was with Mr. Middleton?
Answer. Right, or not with him. I don't know him. And you say his
name is Lap Seng?
Question. Yes.
Answer. But he's known as----
Question. Mr. Wu.
Answer. I don't--I don't know.
Question. What is it? It was two different names they usually have.
Mr. Ballen. You don't know either one of them?
The Witness. Either one of them.
Ms. Comstock. I just wanted to give you all the aliases just in
case.
The Witness. No, I don't know him.
EXAMINATION BY MS. COMSTOCK:
Question. Did you have any knowledge of the any of the Asian
clients that Mr. Middleton had?
Answer. No. I didn't know what clients he had.
Ms. Comstock. I will go ahead and make this, the Ng Lap Seng WAVE
record, EOP 56855, make that Deposition Exhibit 13.
[Williams Deposition Exhibit No. MW-13 was marked for
identification.]
Ms. Comstock. I'll make this other group of WAVEs for Mark
Middleton Deposition Exhibit 14.
[Williams Deposition Exhibit No. MW-14 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. Maybe we could just briefly go through a few of the other
ones in there.
Answer. Okay.
Question. The third page has meetings on June 5th, June 20th--or
entrances to the White House--why don't I characterize them as
entrances to the White House on June 5th, June 20th and June 29th,
where the requester is Ryan and the visitee is Williams. In the
summertime of '95, again any recollection?
Answer. I mean, I just don't know. I've got no recollection of
what----
Question. One of them is at 2:30 in the afternoon. One is at 11:00
in the morning. One is at 5:00. Does that assist at all?
Answer. For the same day?
Mr. Ballen. Excuse me. I believe the witness has already testified
she's going through all of these documents, and it doesn't refresh her
recollection. Going through them individually, I don't know whether
that will refresh--she has always testified. This has been asked and
answered. She doesn't recall any specific meetings.
EXAMINATION BY MS. COMSTOCK:
Question. We are just going through and pointing out some of the
time frames on that, if that helps. I think we will be fairly brief
going through these. But that doesn't assist you in any way of
recalling what he might have been doing there?
Answer. No.
Question. Do you know of Mr. Middleton ever meeting with Mr.
McLarty on bringing any of his clients to talk to Mr. McLarty?
Answer. I don't know that.
Question. I believe these go through--the most recent ones are--the
last page has a 9--the second entry is a 9/25/96, so last September,
'96--September 25th, 1996.
Mr. Dennis. The last page.
EXAMINATION BY MS. COMSTOCK:
Question. The last page of the document EOP 20392, where he comes
into----
Answer. Okay.
Question [continuing]. Room 100. The requester is Ryan, and then
the visitee is Ryan. And just to put this in context, this is a time
when there had been--I think there had been a couple of stories, maybe
only just one, on some Asian fund-raising problems. I think the Chung
Am company out in California. That story had been in the L.A. Times.
Did Mr. Middleton during the fall of '96, September-October '96
time frame, ever contact with you at any time or talk with you any time
about any of the Asian fund-raising issues?
Answer. No, absolutely not. Huh-uh.
Mr. Dennis. Same day? That's the next day, the 27th. Still--2:30 in
the afternoon.
The Witness. And this is what?
Mr. Dennis. 10 o'clock in the morning.
The Witness. Right. Uh-huh. I don't know.
EXAMINATION BY MS. COMSTOCK:
Question. Maybe we could--some of the names here, I think--do you
know who Button is? Who that is? Whose office that person is?
Answer. Katy Button. I don't know if it is ``I-E'' or ``Y.'' She
works for Melanne Verveer, but I can't--I don't know if she was an
intern then or not. I don't know.
Question. Okay. And I wanted to direct your attention back to
20378. There was a 6/29/95 entry where Ryan waved in Mark Middleton and
the visitee was Williams.
And I wanted to show you a phone message log that was--it's EOP
59079 through 80 which was--the message was to Evan from Shawn in Mark
Middleton's office; and the message reads, the meeting for tomorrow at
5 p.m. is great for Maggie, Lynn Cutler and Mark Middleton. And this
message is 6/28/95, as I said, and is referencing a meeting tomorrow,
which presumably would be 6/29 at 5 p.m., and the record on here does
reflect an entry time of 1700, which would be 5 p.m. on the WAVE's
records.
Mr. Ballen. Counsel, what page, please?
Ms. Comstock. This is page 20378.
EXAMINATION BY MS. COMSTOCK:
Question. And so I was wondering if that refreshes your
recollection as to that particular meeting or if you ever had a meeting
with Mark Middleton and Lynn Cutler?
Answer. I'm trying to think if this was the same day as--'95?
Mr. Dennis. '95.
If we could just have a second.
Ms. Comstock. We can go off the record for a moment.
[Recess.]
Ms. Comstock. We can go back on the record.
EXAMINATION BY MS. COMSTOCK:
Question. When we broke we were talking about a June, '95--June 29,
'95, entry on the WAVEs record; and then they referred to a June 28th,
'95, phone message that was for a meeting for June 29th at 5 p.m.,
which is the time frame reflected on the record; and the meeting was to
be with Maggie, Mark Middleton and Lynn Cutler. And the question
pending was if you recall generally in this time frame or any time of
meeting with Mark Middleton and Lynn Cutler?
Answer. What I recall--and, once again, I'm not sure of the time
frame--is that there was a meeting for Lynn and Mark which I wanted to
put together. I believe this was--and I'd have to check--this is--it
was a meeting about the women's delegation to Beijing.
We had had, 2 days earlier--I think 2 or 3 days earlier--once
again, I don't know about these dates--a meeting to explain to people
who might support the women's delegation in Beijing, you know,
everything about it--anybody who was in business or had an interest in
it, foundations and everything.
And I had wanted Mark to be a part of it because I knew that he was
involved in international business. And I don't think that he could
come, but I remember--and like I don't know if this is the date, but I
remember getting Mark and Lynn Cutler together. Lynn had been one of
the presenters at that meeting, and I wanted her to talk to him about
the delegation.
Question. Okay, and was Ms. Cutler going to be involved in the
delegation going to Beijing?
Answer. Oh, she--not involved in going. She actually was involved
in a whole series of events around the delegation that happened in the
United States about U.S. support for the delegation, which is why she
was one of the big presenters at a meeting that had been held at the
White House a few days earlier. But, like I said, that--seeing Lynn's
name refreshes my memory about wanting to put her together with Mark
Middleton, but I'm not sure if this is the date or the time, but I know
at some point that I did that.
Question. Okay, I am not recalling when the Beijing trip was.
Answer. I don't either, but I--they were selecting a delegation,
and that I remember because we held a big meeting with foundations and
all kinds of people who were interested in international businesses.
And I remember Lynn was a presenter, and I wanted Mark to go to that
meeting. I think that would have been good for him.
Ms. Comstock. Okay. We'll make that Deposition Exhibit No. 15.
[Williams Deposition Exhibit No. MW-15 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. I think when we were talking about Mr. Greene earlier you
had no recollection of Mr. Greene ever talking to you about Mr. Trie?
Answer. No.
Question. Do you have any knowledge of anybody trying to get Mr.
Trie involved in the Beijing delegation or trip?
Answer. No, no.
Question. And this is--again, this is a WAVE record for May 19th,
'95. We had previously been referring to the Middleton documents that
had a May 19th meeting and then the Ng Lap Seng ones that had a May
19th visit to the White House.
And, again, this is a May 19th, '95, WAVE for it says, Yah Trie or
Yah Lin Trie, I guess it is, on May 19th, '95. And it's requested by
Ryan and the visitee is Williams. And it appears from the records that
he came in with Mr. Middleton and Mr. Ng Lap Seng for that which you
testified you weren't aware of.
But does that assist you a lot, all that grouping, being together,
the three of them?
Answer. No, no.
Ms. Comstock. I'll just make that Deposition Exhibit No. 16.
[Williams Deposition Exhibit No. MW-16 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. And you have no knowledge of Mr. Trie meeting with Mr.
Middleton on any occasion----
Answer. No.
Question [continuing]. Or having any business----
Answer. Relationship at all.
Question [continuing]. Relationship? Okay.
Did there come a time last fall when the stories about Mr.
Middleton possibly soliciting money from Taiwan, the $15 million that
is alleged--that somebody in Taiwan alleged he was trying to raise for
the DNC, did you ever talk with him about----
Answer. No.
Question [continuing]. That story or those allegations?
Answer. Oh, no.
Question. In any way?
Answer. No.
Question. Were you aware of him--did you ever learn of him, aside
from press accounts of being in Taiwan with Mr. Trie?
Answer. No, I did not know that.
Question. Were you aware of the DNC raising money for health care
media in 1994?
Mr. Ballen. I'm going to object as to the relevancy of the
question.
The Witness. I--I don't know what--can you give me some more
context?
EXAMINATION BY MS. COMSTOCK:
Question. Well, if you're generally aware of efforts to raise money
in 1994, specifically designated for health care purposes.
Answer. For health care? The DNC had a health care project itself.
Question. And do you have any knowledge of any particular people
who were donating to the DNC for health care purposes?
Answer. No, not offhand, I couldn't--donating to the DNC for health
care purposes.
Question. For the health care campaign?
Answer. For theirs? No, not offhand, I can't.
Ms. Comstock. Okay. I'm showing the witness a document that's F
38902, which is received from the DNC and directing your attention to
the first two entries there. It says, 5/12/94, two entries for $20,000
health care campaign, and it is a--donations from Charlie Trie is what
is indicated on here.
The Witness. Where? Oh, up here.
Ms. Comstock. The top of it says, DNC Finance Executive Summary.
Then it says, Mr. Charlie Trie. And then it has written and then it
says 5/12/94, amount $20,000 entry and a $60,000 entry. And both of
them are identified as 1994 health care campaign, and the solicitor was
Mr. Richard Mays.
The Witness. And these are--these are contributions to the DNC?
Ms. Comstock. Yes.
The Witness. Oh, okay.
EXAMINATION BY MS. COMSTOCK:
Question. And these are--do you know who Mr. Richard Mays is?
Answer. Yes, uh-huh.
Question. And how do you know him?
Answer. He's from Arkansas. He's a long-time friend of the
President and Mrs. Clinton.
Question. Did you have any knowledge of Mr. Mays raising money in
particular targeted for the health care campaign and health care bill?
Answer. No, not particularly, no.
Question. And it's your testimony that you had no knowledge of any
particular donors who were donating money----
Answer. Money to----
Question. Say large sums, anything over 5, 10,000, to the DNC for
the purposes of health care?
Answer. For the purposes of their----
Question. Of the health care campaign?
Answer. Of their--the DNC's health care campaign?
Question. Yes.
Answer. Not that I can recall.
Mr. Ballen. It has been asked and answered.
The Witness. No.
Ms. Comstock. Make that Deposition Exhibit No. 17.
[Williams Deposition Exhibit No. MW-17 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. This is EOP 43683. It is a February 15th, 1995,
memorandum for Harold Ickes from Terry McAuliffe and Laura Hartigan and
Ari Swiller regarding managing trustees dinners. We had previously
discussed just generally managing trustee dinners at the White House.
And I would direct your attention to--it says, the President and First
Lady's tables; and under the First Lady's table the sixth person
identified is Charlie Trie.
Answer. Uh-huh.
Question. I was wondering if that refreshes your recollection as to
if you had any knowledge of Mr. Trie being a trustee or being involved
in any events at the White House?
Answer. No, I--I wouldn't know him if I saw him.
Question. Other people indicated at the President and First Lady's
table here, at the President's table, Mark Jimenez is identified as
being at the table. Did you ever have occasion to deal with any matters
related to Mark Jimenez?
Answer. He went to--there was in Florida--he went to a fund-raiser
that--I don't even know whose fund-raiser it was. Maybe it was a DNC
fund-raiser, but I remember him.
Question. And you met him?
Answer. No, I wasn't there. I've never met him.
Question. Do you know--so how do you know of him?
Answer. Because he was at a fund-raiser for Mrs. Clinton in
Florida, went on one. I don't know if it was a DNC fund-raiser or a
candidate fund-raiser. I remember he had a huge family. And he had--a
huge family--and he had some wives of people from somewhere with him,
and there was a discussion about if he could bring all of them into the
fund-raiser or something. But there was something--which is why his
name rings a bell. There was something with the Florida fund-raiser and
his guests.
Question. And this--and how did you learn of this?
Answer. Oh, I think probably through my scheduler.
Question. And what was the discussion----
Answer. I'm trying to remember. I don't know--I just know that his
name rings a bell for me. Florida fund-raiser, maybe DNC. He had
guests. I don't know if they were foreign guests. He also had a huge
family, and there was some mix-up about who he could bring or couldn't
bring, and I just remember it being drawn to my attention.
Question. And there was a mix-up with he wanted to bring foreign
people and there was an issue of whether or not he could bring foreign
people to the fund-raiser?
Answer. It seemed to have been foreign people to the fund-raiser or
the number of people in his family who wanted to be at an event. But I
just remember there was a big kind of bugaboo about it, which is why I
always remember his name.
Question. And who was involved with this bugaboo?
Answer. I just remember my scheduler talking to me about it.
Question. Were DNC people involved in that process also?
Answer. Yes, and I don't know who, but yes. Somebody from the DNC
also I think called me about it.
Question. Do you----
Answer. I mean, I don't remember the specifics of it. But, you
know, seeing his name rings a bell.
Question. And, generally, do you recall who at the DNC--this is
just generally aside from this matter--who you generally would be in
touch with, who would call?
Answer. It varied so much, especially if you were in a State. It
might be somebody related to a State party completely, you know, kind
of not in the Washington DNC mix.
But I do remember this Florida thing and his name and it being
brought to my attention as a problem. But I don't know how we worked it
out, you know, but I know that it was--there was an issue. There was
something about his name that rings a bell.
Question. Do you recall if Mack McLarty ever talked to you about
Mr. Jimenez?
Answer. No, I don't remember Mack ever talking to me about him.
Huh-uh.
Question. Generally, what was the practice on these fund-raisers on
who could come? You said there was sort of a bugaboo about this one.
What kind of issues would arise in terms of who could be at fund-
raisers with the First Lady? Were there other instances where issues
arose about someone shouldn't be from or----
Answer. No, mostly, I just--I remember this. The only issues for us
would tend to be crowds and how many events and how long that she had
to work them. And, for us, the issues almost inevitably were the number
of people and whether or not the number of people at a fund-raiser
would require that she shake hands with every person, which was usually
a requirement. So that was something that we always talked about--size,
number, how many, how long. These were our major issues.
But there was something on this particular front, talking about--
I'm not sure about--I just remember it happened as an issue, and it had
to do with Florida, and it had to do with size and how much time she
had to be somewhere, but I don't know--remember the particulars, but
that's what I remember.
Question. And when there were fund-raising events--and I'm talking
now about--you know, we've talked a lot about events that were held at
the White House, so I'm talking now about events that were fund-raisers
that you would go out----
Answer. Uh-huh.
Question [continuing]. To Florida----
Answer. Out some place.
Question [continuing]. Some place where official DNC fund-raising
type of things--was the First Lady usually memoed by somebody? Like
saying if it was going to be a small event or who the--these are the
people who paid 10,000 each for this DNC event? Was there ever any
memos or documents informing her about who was going to be there and
who the people who should be recognized are?
Answer. If there were, it would be a part of her schedule. It would
come to the schedule, and it would be a part of the schedule.
Question. Did that go through you at all?
Answer. Oh, I would generally see the schedule the night before.
I'd take a look at the schedule. But, you know, we--we had pretty
competent help in the scheduling.
Question. And that's scheduling that you saw on a daily basis the
night before. Did that usually include briefings about people who would
be at events?
Answer. Yes, sometimes it did. If it got--if they came to us. I
mean, you know, if it got to us on time.
Question. And then returning to EOP 43683, the February 15th, '95,
memo for Harold Ickes--at the President's table is also seated Pauline
Kanchanalak. Do you recall ever seeing or knowing of Ms. Kanchanalak
being at the White House?
Answer. I think only from press accounts.
Ms. Comstock. I'll make this Deposition Exhibit No. 18.
[Williams Deposition Exhibit No. MW-18 was marked for
identification.]
Ms. Comstock. This is EOP 63612. It is a memo to Alexis Herman,
Maggie Williams and Mack McLarty from Lynn Cutler, re: Request of Mark
Jimenez, September 25, 1996.
I'll just let you take a look at that.
EXAMINATION BY MS. COMSTOCK:
Question. Do you recall getting this memo?
Answer. No.
Question. If you recognize the handwriting on that, could you
identify any that you recognize?
Answer. No.
Question. I believe the note on one of them does look to be signed
by Mr. McLarty, the right-hand side, the script.
Answer. No, I really--I don't recognize the handwriting.
Question. Do you know any connection--do you recall discussing with
Lynn Cutler anything having to do with Mark Jimenez?
Answer. Not that I can recall.
Question. Do you know if she was involved in any of these
discussions that you relayed about the Florida trip or anything about
that?
Answer. No, huh-uh. I don't remember her being--I remember talking
to someone in Florida about it.
Question. And do you recall who the Florida person was?
Answer. No, I don't think I knew the person. I don't know if it was
a State party person or someone just involved locally. I'm not really
clear who I was talking to.
Question. And Alexis Herman, could you just, for the record, just
give us her position and what she did at the White House?
Answer. She was the director of public liaison for the White House,
the public liaison office.
Question. All right. And the memo we were discussing earlier today,
May 5th, 1994, you know, had identified her as the contact person on
official delegations abroad?
Answer. Uh-huh.
Question. On the May 5th, 1994, memo, item number 4 had been
invitations to participate in official delegations' trips abroad.
Again, this was in connection with an order to reach our very
aggressive goal of $40 million.
Do you know--and I think from the previous docket we were reviewing
Mark Jimenez was at a trustee dinner. Do you know, was there ever any
effort to assist these trustees on these official delegation trips?
Answer. I mean, I don't know. I didn't--I would be asked from time
to time if I had any suggestions for the delegation. I don't know if
there was any special outreach work done for the trustees.
Question. Do you know why this memo was directed from Lynn Cutler
to you? Why you were included in this circulation?
Answer. No, I just think Lynn wanted me to be aware.
Mr. Ballen. Don't speculate. If you know, answer. Counsel's
admonition to you at the very beginning was that we didn't want
speculation.
The Witness. Well, it would be speculation. I don't know.
EXAMINATION BY MS. COMSTOCK:
Question. Previously we had--the meeting that you had with Lynn
Cutler and Mark Middleton had been about the Beijing trip?
Answer. Uh-huh.
Question. This one she's referring to the APEC conference in the
Philippines. Do you know any particular reason why Ms. Cutler is sort
of involved or if she is involved in Asian affairs or has Asian
interests and is involved in any matters related to this?
Answer. No, not that I know. She was involved in the Beijing
conference, I believe, because of her relationship and work in the
women's community. But I don't know about the APEC----
Question. Was she involved in fund-raising in '96?
Answer. I don't know--I don't know for sure.
Question. Do you know of--how often would you meet with Lynn
Cutler?
Answer. Well, we worked on a women's committee together on women's
issues and women's votes, which had--which was once a week or once
every 2 weeks.
Question. And were there other matters you worked with Ms. Cutler
on?
Answer. That was the primary one where I saw her. I mean, I've
known Lynn Cutler for, I don't know, 15, 20 years. I mean, I've known
her in Democratic politics for a very long time.
Question. Would those meetings be at the White House?
Answer. On women's issues? Yes.
Question. And were those meetings that you orchestrated or centered
in your office or did someone else--was someone else in charge of them?
Answer. The White House had a women's office. So Betsy Myers--it
would really involve most of the women in the White House--women from
Cabinet affairs, from public liaison--representing each of the
divisions.
Question. Okay. In this memo Lynn Cutler writes that Mark Jimenez
of Florida, who has been very helpful to us on a variety of fronts, has
called asking if he could be on the delegation to the APEC conference
in the Philippines taking place April 22nd to the 25th. Do you know
what she was referring to and how Mark Jimenez had been helpful on a
variety of fronts?
Answer. No, I don't know with respect to this memo what she was--
no.
Question. Or if you have any general knowledge of Mark Jimenez, the
variety of fronts that he may have been helpful to anybody at the White
House or at the party?
Answer. Well, I mean, just based on the document, it's----
Mr. Ballen. No, she's asking for your knowledge.
The Witness. From my knowledge, no.
EXAMINATION BY MS. COMSTOCK:
Question. And then it goes on to say, you will remember that Mark
is from the Philippines and I know that this means a great deal to him.
Do you know if Lynn Cutler had any reason to believe that you had any
particular knowledge about Mark Jimenez when she is directing this memo
to you?
Answer. No.
Question. Do you know if you did any follow-up to this memo?
Answer. No.
Question. Or can you recall any discussions with Alexis Herman or
Mack McLarty about Mr. Jimenez?
Answer. No, because I don't even remember this memo.
Question. Okay.
Ms. Comstock. I will make that Deposition Exhibit No. 19.
[Williams Deposition Exhibit No. MW-19 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. I wanted to return to talking about Charlie Trie a little
bit. Was it your testimony that you were not aware of him being at the
White House at any time?
Answer. No.
Question. Did there come a time when you learned about his
donations to the President's legal defense fund?
Answer. Yes.
Question. And could you describe----
Answer. His?
Question [continuing]. When you learned of that and what you
learned? From whom, et cetera?
Answer. I learned from Michael Cardozo, who was one of the trustees
of the President's legal defense fund.
Question. And how did you learn about it from Mr. Cardozo?
Answer. He asked for a meeting. I was included in that meeting
where he--excuse me, I'm sorry--told us about donations that had been
given to the President's legal defense fund by a religious sect of
people and that the President's legal defense fund trustees were
concerned about the donations and had decided to return them.
Question. And did he describe what those concerns were?
Answer. Oh, gosh. The gist of it, I believe, was that members of
the sect had written checks--no, wait. It had something to do with
serial numbers. The serial numbers on the checks were consecutive or
something, and there was a question about whether or not the donations
that these people were making were their donations. I think that's the
gist of it.
Question. Okay. And do you recall if this was--you were informed of
this by phone or in a meeting?
Answer. No, it was a meeting.
Question. And do you recall who else was at the meeting?
Answer. Michael Cardozo and some lawyers who I do not know, Harold
Ickes, Evelyn Lieberman, Cheryl Mills. That's what I recall.
Question. Is that the May 9th, '96 meeting? Do you recall generally
when the meeting was in the spring of '96? Do you know--maybe it would
help. Do you know if you had a number of meetings with Mr. Cardozo on
this or did you only have one?
Answer. I remember being invited to two, going to one, which was
the first one, and getting to, I guess, to the second one at the end of
the meeting, that they had broken up.
Question. And do you recall if this was the first meeting?
Answer. I believe this was the first meeting that I just talked
about.
Question. Generally, that's been identified as a meeting--I believe
we have a number of calendars; I don't think we have your calendar--but
it was a May 9th meeting that Mr. Cardozo has testified to and Mr.
Ickes notes and others from that day that identify you as being there.
Do you recall prior to this May 9th meeting if anyone--if Harold
actually had told you about anything related to Charlie Trie or these
contributions?
Answer. No, that was the first I ever heard about it from Mr.
Cardozo.
Question. So the First Lady hadn't mentioned anything to you about
this before?
Answer. No.
Question. Do you recall in that meeting if anyone breached the fact
that Charlie Trie was a--had been raising money for the DNC?
Answer. No, I know that his name was raised in connection, but I
don't know if this was Charlie Trie, DNC member. I just remember his
name.
Question. Did anyone in this meeting--when you went to this
meeting, you didn't know who Charlie Trie was from Adam, right?
Answer. No, the only thing I knew about Charlie Trie was that he
was from Arkansas.
Question. And when you had this meeting set up, did somebody tell
you, like why am I going to this meeting with Mr. Cardozo or tell you
that it was related to Charlie Trie?
Answer. No, I mean, I don't know who got the--you know, how the
message came in or how, you know, Evan got word to schedule me. But
just that there was a meeting, and Mr. Cardozo wanted me to be there.
So I went.
Question. Had you ever been involved in any discussions about the
President's legal defense fund prior to this date?
Answer. I think the first time that it was announced I, you know,
for sure had the press materials. And then I believe--and I don't know
if this is before or after May 9th, but the first time that they
released information about--about what the amounts that were raised.
But they were going to do a press conference. They called, you know, me
in and the press people to say we are releasing this tomorrow, so you
should know about it. Other than that, those are the only two times.
Question. Did you ever discuss the Clinton's personal legal bills
with Mr. or Mrs. Clinton?
Answer. Their personal legal bill, no.
Question. The legal bills that this defense fund was paying for?
Answer. No, it was pretty much the trustees. I mean, that was
nothing----
Question. You had said that Mr. Cardozo wanted you to be at the
meeting? Was that your understanding?
Answer. Yes.
Question. Do you know how Mr.--why Mr. Cardozo was inviting you?
Mr. Ballen. If you know.
EXAMINATION BY MS. COMSTOCK:
Question. If you know.
Answer. No, but--well, I assume that he wanted to have someone
there from Mrs. Clinton's office, since this also was the President and
Mrs. Clinton's legal defense fund.
Question. I just trying to get a sense of why--I mean, it was your
understanding that this legal defense fund was to pay for their
personal legal bills?
Answer. Right.
Question. And if you have an understanding of why you were involved
in discussing a fund that related to the President and Mrs. Clinton's
personal legal bills.
Answer. I think that because, even though we can easily make the
distinction between personal and public, it's rarely made with respect
to the press, and I think that Mr. Cardozo felt that telling us what
they were planning to do--I mean, it wasn't a deliberative meeting, but
telling us what they planned to do was something we needed to know in
case we had inquiries about it at some point.
Okay. I believe Mr. Cardozo's indicated that he called you to set
up the meeting. Do you recall him calling your office to set up the
meeting?
Answer. No, no, he didn't call my office to set up the meeting. He
may have called my office to ask to use a conference room in room 100,
which is where my office is, but he didn't call me to set up the
meeting.
Question. And do you recall where the meeting occurred?
Answer. Room 100 conference room.
Question. That's where the meeting was held?
Answer. Uh-huh.
Question. And so you don't recall talking to him on the phone about
setting up this meeting? Somebody else set it up?
Answer. Setting up this meeting?
Question. Yeah.
Answer. No.
Question. Do you know how the other people at the meeting had been
invited to the meeting?
Answer. No.
Question. You have no knowledge of who invited them or how they
ended up in your office about the meeting?
Answer. No.
EXAMINATION BY MS. COMSTOCK:
Question. And I'm sorry, maybe this is my fault for not being clear
on this, but you don't have a recollection of Mr. Cardozo calling to
set up the meeting?
Answer. No.
Question. Do you know how you ended up having the meeting and who
set it up, who was in charge of setting it up?
Answer. I assume, since Mr. Cardozo was an outsider, that perhaps
he called my office and left a message or something and said, would you
attend a meeting, and then probably spoke to someone about where to
have it, which wouldn't----
Mr. Ballen. But you don't know?
The Witness. It wouldn't necessarily have been me. I don't know.
Mr. Ballen. You are assuming this?
EXAMINATION BY MS. COMSTOCK:
Question. I am just trying to figure out the origin of the meeting?
Answer. I don't know.
Question. Because I think Mr. Cardozo indicated he called you, so I
am trying to figure it out if you have a recollection of how it came
about.
Mr. Dennis. Are you asserting that Mr. Cardozo has testified or
stated that he called Ms. Williams to have her arrange for the meeting;
is that what you are saying?
Ms. Comstock. That is my understanding.
Mr. Ballen. For the record, if you are going to ask her, where did
he assert this?
Ms. Comstock. I believe it is in the records we have.
EXAMINATION BY MS. COMSTOCK:
Question. But if that is your recollection. That may not be the
case. Obviously, whatever your recollection is, we can check on his
recollection. If I am inaccurate what his recollection of it is, I
apologize. I am trying to figure out sort of how it came about that you
all were in this meeting on May 9, and who sort of was the generator of
getting this group together that was there, and who might have selected
the people that were there, and it is your testimony that you don't
know why Harold Ickes was there?
Answer. Right, I don't know. I didn't put the meeting down.
Question. So the people who were there got there by somebody else
calling them other than you?
Answer. Right, it wasn't me.
Question. Now, in this May 9 meeting, did anyone indicate there had
been an earlier meeting several weeks before with the First Lady and
Harold Ickes about Mr. Trie?
Answer. No, no.
Question. And in this May 9th meeting, did Mr. Cardozo talk about
the investigative group's investigation of Mr.--well, the donations in
general?
Answer. I don't know if they were at that point if they had
investigated or they were going to, but he mentioned that there would
be some kind of investigation.
Question. And what did you learn more about; did there come a time
when you learned more about this investigation and what it included?
Answer. I think I did, but I don't know when. I don't remember what
I learned from the investigation. As I said before, I don't know if it
had--if, when he talked to us, he brought us a conclusion on whatever
that meeting was, or if he was just starting an investigation. I don't
remember, but I remember that he said something about an investigation.
Question. Okay. Did you take any notes in this meeting?
Answer. No.
Question. Do you know if anyone else at the meeting was taking
notes?
Answer. I wasn't paying any attention.
Question. You did not direct anyone from your staff to take notes
in this meeting or keep any account of it?
Answer. No.
Question. Did you talk with Mrs. Clinton about this matter after
the meeting?
Answer. No.
Question. You said you thought that Mr. Cardozo was talking to you
about this, that someone in the First Lady's Office would know about
this. What was your understanding then of--after you got the
information, was there any reason not to tell Mrs. Clinton about it or
talk about it?
Answer. It's like most things, nothing had happened yet. The
trustees had made a decision. Most times these things are told to us
because there is a possibility of press inquiries. This wasn't a
decision-making meeting, so I said--you know, just had it in my head.
Question. Okay. Did anyone in the meeting bring up the fact that
Charlie Trie claimed to be a friend of the President?
Answer. I know that Charlie Trie was involved in some way with the
donations. I don't remember exactly how, but I know his name was a part
of a--whatever narrative it was that Mr. Cardozo was sharing with us. I
don't remember anyone specifically saying Charlie Trie is a friend of
the President.
Question. Okay. But do you recall any discussion of who is Charlie
Trie, this guy who--was there some curiosity about who is this guy who
came in and dropped 600 grand on the legal defense fund, like do we
know him, where did he come from?
Mr. Ballen. I am going to object. There has been no indication that
600,000--that Charlie Trie dropped it on anyone. You are assuming facts
not in evidence.
EXAMINATION BY MS. COMSTOCK:
Question. Did Mr. Cardozo tell you Mr. Trie had brought in money to
the legal defense fund?
Answer. As I said before, in the--I guess the narrative of Mr.
Cardozo, Charlie Trie was mentioned. How he was mentioned
specifically--but it was next to these donations, that is what I
remember. As I said before, the gist of my memory is that there was
something wrong with the way these were collected, and the trustees had
decided to give them back,. That is what I remember from that.
Question. Did Mr. Cardozo tell you he had--that Mr. Trie had
actually come in himself personally to deliver all these contributions?
Answer. I don't remember that.
Question. Okay. Mr. Cardozo has publicly testified to that, that
Charlie Trie did come in and bring all the donations down. Does that
refresh your recollection as to whether or not he shared that with you
at that time?
Answer. As I said, I don't remember. What I took away from the
meeting was they were giving money back.
Question. Okay.
Answer. And that there was a procedure to be responsible for
collecting the money. That is what I remember.
Question. Do you recall any discussion of who is this guy, who
brought the money in?
Answer. No, that is pretty much what I remember.
Question. There was no curiosity about who he was?
Answer. Well, I guess what I am saying is there very well could
have been, but I don't remember.
Question. Do you recall if you had any curiosity about who this
person was?
Answer. Pretty much what I recall, I have told you.
Question. Okay. These are notes that Harold Ickes made from the May
9th meeting. They are difficult to read. It is CGRO-2595 through 2598,
and it is a little bit cut off at the top. I am not sure how cut off
yours is, but these are May 9, 1996, notes. The initial entry discusses
the investigative group. It says, ``Need to check background.'' Then
the next line says, Charlie Trie, dollars, and mentions 463,000;
179,000.
Does that refresh your recollection as to whether Mr. Cardozo, in
this meeting, had discussed, you know, that Charlie Trie was
specifically the person giving these large donations, and that they
might need to check his background?
Mr. Dennis. Before you answer, is there a date?
Ms. Comstock. It is 5-9-96 is the date on these, on the copy we
have, the copies you have have cut that off.
EXAMINATION BY MS. COMSTOCK:
Question. And I guess the question pending question was does this
refresh your recollection as to the discussion that Mr. Cardozo may
have related that he had with Charlie Trie and the money that he
brought in?
Answer. As I said before, I know Charlie Trie was involved. These
are Harold's notes--that I just don't recollect all this discussion.
Mr. Ballen. So the record is clear, you are not sure of the date of
the meeting?
The Witness. Well, right, that is what I said at the very
beginning.
EXAMINATION BY MS. COMSTOCK:
Question. You said you thought you had two meetings----
Answer. Well, I attended one meeting, and a second meeting I know I
was invited to, but I got there after the meeting broke up.
Question. Do you know if that meeting was--what that was about, the
second meeting?
Answer. No.
Question. So the only meeting you recollect is the meeting where
Mr. Cardozo related that there was a problem?
Answer. Right, yes, exactly.
Question. Okay. I am not aware of any other meetings where Mr.
Cardozo initially relayed this, besides the May 9 one and the meeting
with Harold Ickes and the First Lady. Do you know of any other meetings
besides the meeting that--well, you may not even know about the meeting
with--I assume maybe from press accounts you know about the meeting Mr.
Cardozo had with the First Lady and Harold Ickes; is that correct?
Answer. Right, I do know that.
Mr. Ballen. There were several questions before you. Do you know
from press accounts or independent knowledge?
The Witness. Well, the First Lady had a meeting with Michael
Cardozo that Michael Cardozo asked me to set up, said he wanted to meet
with Mrs. Clinton. I told the scheduler to put them together, so I do
not know if this was the same meeting that Harold Ickes attended,
because no one told me that Harold Ickes was attending, nor did I set
up a meeting where Harold attended. I do know Mrs. Clinton and Cardozo
had a meeting because Mr. Cardozo asked me to put him on the First
Lady's schedule.
EXAMINATION BY MS. COMSTOCK:
Question. Do you recall generally, in relation to this first
meeting where you learned of these matters, when the meeting with the
First Lady is?
Answer. I could not tell you.
Question. I mean, was it a year before?
Answer. Oh, gosh, I just really don't--on the timing issue, I am
literally of no help. They are all together, all these things. I don't
know.
Question. Are there any other meetings Mr. Cardozo asked you to set
up with the First Lady?
Answer. That is the only one I recall.
Question. There was one occasion Mr. Cardozo asked you to set up a
meeting the First Lady?
Answer. That I recall, yes.
Question. Did he tell you what that was about?
Answer. No.
Question. You generally knew it was about the legal defense fund?
Answer. I didn't know that for a fact, but I assumed that is what
it would be.
Question. And you set that up; you put that on the First Lady's
schedule and had it set up?
Answer. Right.
Question. Do you recall where that meeting was?
Answer. No, I don't really remember.
Question. Okay. And then you do recall it being before this meeting
where you learned of it?
Answer. I don't.
Question. You don't. Okay.
But your testimony is that you have only been involved in two
meetings, and the second meeting was at the end of it, and you aren't
really sure what the second meeting was about?
Answer. Not even the end of it. People had dispersed.
Question. So the only meeting you had been at----
Answer. There was a meeting I was at where Mr. Cardozo related the
issue and what they had planned to do.
Question. This is a meeting with Mr. Ickes present and others, and
I understand you may not be aware of the date. I mean, the date has
been publicly identified by the White House by numerous records. I
don't want to go on--I mean, I think we are talking about the May 9
meeting. You know, we could get a lot of records in here, but I think
what we are talking about is fairly clear that it was a May 9 meeting.
But do you have any reason to believe there were other meetings
with this group of people you are talking about where Mr. Cardozo
relayed this--I guess there couldn't be another one because Mr. Cardozo
told you--this is the only one you recall?
Answer. That is the only one I recall.
Question. Your account is he says he had one meeting with the same
group, too, so it doesn't appear there can be another one?
Mr. Dennis. Let me make a statement on this. If you have
information that you can put together that, along with what my client
recollects, you can establish it was May the 9th, I have no problem
with it. My client is not saying it is not May the 9th, she just has no
recollection. She provided a substantial amount of detail. She said it
was number 100, and that was her conference room there, and she recalls
who was there. So she does not have any recollection of any dates, and
she can't really confirm that for you.
But there is just so much--you are not going to be able to get or
to ask her to draw inferences from other information that you are
giving her. That would not be fair for her to confirm that, you know,
she believes it is May the 9th now because you told her certain things,
but I think she is fairly----
Ms. Comstock. I understand you can't recall the date. We could have
everybody's calendar here and look at those, and it probably still
wouldn't help.
Mr. Ballen. And I think the witness, we have been going on this for
quite some time, she stated a number of times what she recalls from the
meeting, and I don't see----
Ms. Comstock. But I think Minority counsel raised an issue that
this was not the meeting.
Mr. Ballen. Excuse me, counsel, I raised no issue. I simply asked
her a question could she remember it was May 9th or not, when you gave
her somebody else's notes of a particular meeting and she said she
didn't know what the date was, simple as that. You are asking the
witness to testify about somebody else's notes.
Ms. Comstock. I am asking her if these notes helped refresh her
recollection.
Mr. Ballen. She said they did not.
Ms. Comstock. But we introduced the notes because they are the
notes of the only known meeting that this same group of people had, and
Ms. Williams testified this was the only meeting she was at. Mr.
Cardozo has publicly testified this is the only meeting he had with
this group of people informing him of these events. It didn't seem to
be a real leap of logic this was the same meeting, but that is what we
have been trying to go through is additional establishment that there
weren't other meetings about this, and I think that is fairly clear,
and I think the record will speak for itself, and other documents will,
that this was the May 9 meeting. But I am not asking you to come up
with a date. I think other records will reflect that.
I would like to go ahead and make that Deposition Exhibit No. 20.
[Williams Deposition Exhibit No. MW-20 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. Directing your attention to the second page of Mr. Ickes
notes again. I am sorry, if I could have you turn to CGRO-2596. There
is--the bottom two lines talk about 1.5 million, and it is difficult to
read there, and then some amount in the bank. I wonder if this
refreshes your recollection as to whether there was a discussion of how
much money was actually in the legal defense fund at that time?
Answer. How much money was----
Question. In the legal defense fund, or just the amounts of money
that generally were in the legal defense fund, if there was a
discussion in the meeting?
Answer. I don't know if there was a discussion in it. It seems to
me in the narrative that Mr. Cardozo said how much was in the legal
defense fund.
Question. Okay. When he was telling you about these events on that
day, the meeting you recall?
Answer. Uh-huh.
Question. And was he telling you that, you know, without this
money, there wasn't a lot there; or give you a sense of, you know, kind
of we need this, it wouldn't be bad to have this funding?
Answer. I think his sense was--I mean, I think my interpretation of
his presentation was very, very cut and dry, and, you know, he was
announcing that they had decided to return the money, and just as a
part of his report he indicated to us how much was there, and he--this
matter seemed settled in his mind.
Question. And do you recall if there was any discussion about if
the money was returned, if that would be reflected in reports, the
reporting that the defense fund had to do?
Answer. No, I don't recall.
Question. Do you recall if there was any discussion among the
participants in the meeting of not wanting to return the money, or, you
know, that we really need to return the money?
Answer. I think the one thing I remember from the meeting
specifically which did have an impact on me, but seemed to have no
impact on anyone else in terms of returning the money, is that Cheryl
Mills was saying we ought to be very careful in making certain that we
were clear, that we thought that there was something--and I am
paraphrasing here--that we were clear that we weren't going to be in a
position to make a comment about Asian people giving; that we ought to
be certain that we took some care in making certain that the kind of
judgment we made would be the same kind of judgment we would make no
matter who these people were. And I just was struck by that and thought
it was a good comment to make.
Question. And was there any discussion back and forth on that
point?
Answer. Not really. I think she just made her point. As I said
before, it seemed to me that Mr. Cardozo was very clear about what he
was going to do.
Question. And I just wanted to correct something for the record,
because you had testified that Mr. Cardozo called you to set up the
April 4 meeting, and my notes indicated when I said that I thought
Cardozo called you about the May 9 meeting, it was actually the April 4
meeting. So I wanted to make that clear so--my notes aren't clear. I
believe Mr. Cardozo indicated he may have called Mr. Quinn about the
May 9 meeting.
Does that refresh your recollection on the May 9 meeting, whether
or not Mr. Quinn called you about it or set up anything with you on the
May 9 meeting?
Answer. It only refreshes my recollection inasmuch as I think Mr.
Quinn was there.
Question. And I apologize for the mix-up. I am looking at my notes.
It was April 4. I was looking at it as if it were May 9th.
Do you recall Jack Quinn being in that May 9th meeting?
Answer. I recall him being in this meeting where Mr. Cardozo said
there was a problem.
Question. I will keep the date off of it.
So the meeting you recall with Mr. Cardozo?
Answer. Yes, I remember him being there.
Question. Okay. And do you recall Evelyn Lieberman also being in
that meeting?
Answer. Yes, I believe she was there.
Question. Do you know why she was there?
Answer. Whoever invited her. No, I don't.
Mr. Dennis. What was her position at that time?
EXAMINATION BY MS. COMSTOCK:
Question. In May of '96, if it was May of '96?
Answer. Deputy chief of staff, I believe, at that point.
Question. Okay. Following this meeting, what was the next time you
ever had any discussion with anybody about Charlie Trie money or the
legal defense fund, these events that were relayed to you in the
meeting with Mr. Cardozo?
Answer. As I said before, I don't necessarily remember any follow-
up. Kind of where I left off on this meeting was with returning the
money. The next time I heard anything about this specifically was I
think there had been a media inquiry about it, either to Mr. Cardozo--I
think it was Mr. Cardozo. That was the next time I heard about it.
Question. Was that when it was about to become public that the
contributions--is that when you recall?
Answer. It could have been. I forget when it became public. I
really don't recall.
Question. If it refreshes your recollection, it was in December of
'96 when that became public?
Answer. That could have been about the time.
Question. So between the time you were in this meeting, whenever it
was, with Mr. Cardozo, the next time you recall hearing anything about
it was when there was some media calls about it.
Answer. Right, that is the next time I remember having any, you
know, radar pointed in the direction of this issue.
Ms. Comstock. Let me show the witness a document. It is identified
as PTO 2326, from the Presidential Legal Expense Trust, dated August
12, 1996, to Cheryl Mills, from Mr. Cardozo, and it reads:
Dear Cheryl: You may want to circulate by hand the enclosed letter
from David Lawrence to: Mrs. Clinton, Jack Quinn, Harold Ickes, Bruce
Lindsey, Evelyn Lieberman, Maggie Williams. Thank you for your
assistance, Sincerely, Michael Cardozo.
Attached is a letter from a Mr. David Lawrence, dated July 5, 1996,
where he indicates that--essentially that, ``Unfortunately, as you
suspected, the funds were raised by the efforts of a concerned party
who was unaware of some of the terms mentioned in your letter,'' not
being the terms of what type of standards for compliance.
Do you recognize this letter at all?
Answer. It was shown to me. I don't recognize it as coming to me.
Question. I'm sorry, I am unclear what you mean by that?
Answer. In the previous deposition, someone showed it to me.
Question. But that is the first time you had seen this letter was
in a previous deposition?
Answer. Right.
Question. And you don't recall then receiving it in August of '96?
Answer. No.
Question. At or around--any time?
Answer. I mean, I made the comment there that I believe by then I
was in Chicago. I mean, if this was convention month, I mean, I am not
sure, but there is a lot that could have been sitting on my desk, so I
had not seen it prior to that deposition, and if it actually came to me
anywhere in this month, I mean, it is clear that I wouldn't have seen
it for a while.
Question. Okay. But do you recall any time prior to your
deposition----
Answer. No.
Question [continuing]. Being told about a David Lawrence, who, you
know, wrote back and said, you're right, this money wasn't raised in
the appropriate way, or anything to that effect?
Answer. No, I really don't. That was just it. It was just like a
time when this would have taken a huge back seat to anything, given the
convention and everything. That is the only thing I can figure. I just
don't remember.
Question. Okay. You were working on the convention when you were
out in Chicago in August?
Answer. I had been out to the convention several times, plus Mrs.
Clinton had a major speech to give.
Question. That was at the end of August?
Answer. Oh, you know, in planning for the convention.
Question. This is entitled, ``The Republican Convention,''
actually, at the August 12 time?
Answer. Well, still we were preparing.
Question. But you were physically out in Chicago?
Answer. Yes, back and forth. I mean, I wasn't living there, but
physically. I guess I am saying all this to say, in essence, July and
August were very busy times and especially high times in terms of the
campaign and things that were going on, and so I do not remember seeing
it, and I am merely trying to--probably more for me than for you--to
try and think, you know, if I had seen it, what was I doing, so that I
missed it.
Question. Do you recall any conversations then you had with Cheryl
Mills about the legal expense trust after this meeting with Mr.
Cardozo?
Answer. Quite frankly, I don't think I have thought about it again
until there was a press inquiry about it.
Question. Do you have any knowledge of anyone informing--the first
name on here to circuit this to is Mrs. Clinton; do you have any
knowledge if Cheryl Mills or anyone else at the White House informed
Mrs. Clinton about this?
Answer. I have no knowledge if they did.
Ms. Comstock. I will make that Deposition Exhibit No. 21.
[Williams Deposition Exhibit No. MW-21 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. Once the press inquiries came out about Mr. Trie, did you
ever talk with the First Lady about Mr. Trie at all?
Answer. No, I don't recall that I did.
Question. Were you aware of him being at a trustee dinner in
December of '96?
Answer. No. If I had seen the list, maybe, but I don't recall it.
Ms. Comstock. I am handing the witness an e-mail. It is an e-mail,
Evan Ryan, of May 9th, to Peggy Lewis.
EXAMINATION BY MS. COMSTOCK:
Question. Do you know who Peggy Lewis is?
Answer. Yes, she worked for me.
Question. What were her responsibilities?
Answer. She worked for me. She worked on policy issues for me. She
would work on getting me to return my calls, worked on particularly
issues that had to do with the White House preservation fund, just a
range of different things.
Question. Okay. And the text of the e-mail reads, Maggie wanted to
add John Huang to her call list. And we have some issues here on
whether May 9 was the day of the meeting that you had with Mr. Cardozo,
but assuming that it was, I am wondering, do you recall, as a result of
that meeting, whether you reached out to John Huang to talk to him
about Charlie Trie?
Answer. A result of which meeting?
Question. As a result of the meeting Mr. Cardozo, if you made any
efforts to talk with John Huang about Charlie Trie, anything like that?
Answer. No, absolutely not.
Question. Do you know what you were putting John Huang on your call
list for, in May of '96?
Answer. Well, the only thing I can think of since I only met John
Huang once, and I don't know the date, is if he had called me and I
wanted to return the call. I wouldn't have initiated a call with John
Huang.
Question. Do you recall generally how you met Mr. Huang?
Answer. Yes, and I don't know the date, but I got a call from the
Ambassador of Micronesia.
Question. That would be March Fong Eu?
Answer. Exactly. Who was in town and wanted to talk to me, and so
she was one of our Ambassadors and she wanted to, what I assumed was a
courtesy call, come and see me.
When she came, she brought two gentlemen with her, and one of them
was John Huang. I thought that he worked for her. I didn't know he even
worked at the DNC until at the end of the meeting, he gave me his card.
Question. And that card was from the DNC?
Answer. Yes. And I said, Oh.
Question. So March Fong Eu is the person who set up the meeting
with you?
Answer. Yes, she called and asked for the meeting and, you know, I
gave a, you know, gave a time for her to come, and then she asked that
two other people be cleared with her.
Question. And do you recall who the other person was?
Answer. No. Someone who I believe worked with March.
Question. That is March, Fong Eu, E-U.
When--you got this call personally from Miss March Fong Eu?
Answer. I don't know if I did or not. I don't remember if I did or
not.
Question. Do you recall generally what your understanding of what
the purpose of the meeting was?
Answer. Just that she wanted to have a--to make a courtesy call,
that she was a U.S. Ambassador and if any U.N. Ambassador called my
office and wanted to stop by, I would sit down and talk to them.
Question. Okay. Do you know at that time if she was involved in
fund-raising at all?
Answer. No, I thought she was the Ambassador of Micronesia.
Question. Did you have any understanding of any role she played in
fund-raising?
Answer. No, I didn't. It seems to me, I think she had worked during
the campaign, I don't know where, but I don't know if she worked in the
campaign doing fund-raising, if that is what she had told me or not.
Question. You mean the '92 campaign?
Answer. '92, but that is all. I wouldn't know.
Question. So she didn't discuss with you any fund-raising for the
'96 campaign or for the DNC?
Answer. No. I mean, primarily what she discussed with me was
wanting to get out of Micronesia, that she, you know, I am totally
paraphrasing, but she had tired of that post and wanted to do something
else.
Question. Were you aware--did she tell you she talked to the
President about this?
Answer. No, not that I recall.
Question. Were you aware of her being in communication with the
First Lady about any of these matters over any time while you were at
the White House?
Answer. No, not that I recall. Like I said, the only time I
remember her, meeting her or knowing anything about her, is when she
came to see me.
Question. And you think that is what this May 9th reference--the
only time you ever met with John Huang was in this meeting with March
Fong Eu?
Answer. That was the only time I have met him to even know who he
was was in that meeting. Prior to that, I didn't know who he was.
Question. Okay. If you could tell us how your call list works, who
do you--what is the call list?
Answer. There is not really a process. I mean, if I had a lot of
pink slips hanging around my desk or if I have left them on Evan's
desk, they are just trying to catch up and make sure that I returned
calls.
Question. So this call list is a--you know, she has a bunch of
calls?
Answer. They could be for over a month, you know. It could be like,
you know, she has to call these, or in--and the call list doesn't even
have to be a list, it can be that they, you know, staple this together
with all the other calls.
Question. And returning to the meeting then with March Fong Eu and
John Huang, during this discussion, John Huang never raised or
discussed the fact that he was doing DNC fund-raising?
Answer. No. As I said, it was after the meeting when he gave me his
card. Up until then I thought he was a staffer for the Ambassador.
Question. All right. And do you recall then calling him, if it was
before or after this meeting, calling him?
Answer. For some reason I think I talked to him afterwards, but I
think he had--I am not sure, but for some reason I recall him or a
situation where he was thanking me for meeting with March Fong Eu, and
I don't know if it was a call, but that is the only other contact I can
even imagine having with him.
Question. And did--it is your testimony that March Fong Eu did not
tell you she wanted to do fund-raising; any discussion of fund-raising
was that she had previously been a fund-raiser?
Answer. There is something I remember about her having worked in
California in '92, she said, but her--I mean, and this wasn't a very
long conversation, as it turned out, but the thrust of it was that she
did not want to be the Ambassador of Micronesia; she was ready to leave
Micronesia.
Question. And you said it wasn't a very long meeting. Do you recall
how long it lasted?
Answer. No. It just seemed very brief.
Question. What did she say to make you think she really wanted to
leave or how did she express that?
Answer. Well, I mean, I tell you, this is where I would have some
reservations because it was a private conversation and I never want to
be in a position of saying someone feels in some way, you know,
ungrateful or wasn't pleased. It was a private conversation but it was
clear she was ready to leave Micronesia.
Question. Are you sure she was not expressing anything about she
could be used better in fund-raising, put me into fund-raising,
anything like that, that I could do that for the party or for the
campaign?
Answer. I assume with any Ambassador who wants to leave, the
general course is they want to do something else. I don't know what her
something else was, but I assume whatever the next something else was
was something she wanted us to help her with, she wasn't specific with
me, except to say that she was ready to move on.
Question. And do you know why she had picked you to meet with and
discuss this with?
Answer. I have no idea why people pick me.
Question. You hadn't met her before?
Answer. No, I have no idea. I have people who call me all the time.
I have no idea why people pick me. I mean, they clearly believe that
being the First Lady's chief of staff means maybe I will listen to them
and I will listen to most of them but not necessarily do.
Question. And this is to relay she wanted a different job within
the administration?
Answer. She did not say I want to relay; all I recall is that it
was clear she did not want to be in Micronesia.
Question. I am trying to understand why she was telling you that.
Mr. Ballen. I think the witness has testified, these questions are
asked and answered.
The Witness. It is the same reason people write me and say, please
get my son out of prison. I mean, they equate by title some power to do
something, which you may not have at all. I don't understand. There is
a great motivation out there.
EXAMINATION BY MS. COMSTOCK:
Question. Well, did she ask you to relay her sentiments to the
President or the First Lady?
Answer. What she said to me was essentially that she was tired of
being in Micronesia. She did not, as I recall, specifically say to me,
tell them, the President or the First Lady this.
Question. Do you know a John Emerson at the White House?
Answer. Yes.
Question. And are you aware of--could you just tell us what he does
or what he did at the White House?
Answer. I think he was in intergovernmental affairs.
Question. And did he work on issues related to California?
Answer. Yes, I think he was from California.
Question. Were you aware of him being in touch with March Fong Eu?
Answer. No.
Question. Did you ever talk with him about any conversations he had
with March Fong Eu about wanting to leave Micronesia, if she ever
discussed that with him?
Answer. No.
Question. So you never had any discussions with Mr. Emerson about
what you talked with March Fong Eu about?
Answer. I listened to March Fong Eu and then she left.
Question. And that was the end of it?
Answer. As far as--I mean, I don't remember any follow-up, you
know. I don't know if she wrote me a thank you note or anything, I
don't remember. That is the last thing I remember about her.
Question. And I'm sorry, you may have testified to this previously,
are you aware of any correspondence she sent to the First Lady about
the kind of sentiments she expressed to you in this meeting?
Answer. I don't recall any. I mean, I don't recall it. I mean,
there are hundreds of letters that Mrs. Clinton gets. I don't see all
of them. So I don't recall.
Question. Well, a letter from an Ambassador, would that be brought
to your attention?
Answer. Not necessarily, depending on how it was sent.
Question. Can you generally describe what the process is? Not just
sort of the average, if I am the guy calling to write a letter, but if
I am an Ambassador or some type of dignitary writing a letter to the
White House, what is the process that goes through?
Answer. I don't know if every dignitary has this available to them
but I do know for people who have known them over time, there is a
special zip code that takes that particular mail into personal
correspondence and outside of kind of the regular mail of all the
people, and then those letters don't come to me, they can go to Mrs.
Clinton's assistant, Pam, they can go to personal correspondence. If
they are a friend, they will be answered there, and some of those
letters can make their way up to her.
Question. Okay. So your testimony on the March Fong Eu meeting is
that you had not met her before?
Answer. No.
Question. She called, the meeting was set up, you had this
discussion, and then you never met or discussed these matters again?
Answer. No.
Question. No, you never met again?
Answer. No, I never met her again, no.
Question. Then with John Huang, this was the first time--he was
brought along and this was the first time you met him?
Answer. The first and only time I have met him.
Question. Then as to the call list, you believe you may have called
him after this meeting?
Answer. I can only--there is only--I mean, this is total
speculation, and I will speculate, since this is printed here. I
remember John Huang thanking me. Now it could be because he called me
to thank me for seeing March Fong--I forget her name.
Question. Eu.
Answer. Eu. And I called him back, I was returning a call. But
otherwise I had no--I didn't know him.
Ms. Comstock. We have got Deposition Exhibit No. 22.
[Williams Deposition Exhibit No. MW-22 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. Let me stay in the general area of John Huang. When the
issues about John Huang's fund-raising arose during October of '96,
during the campaign in the closing weeks, did you have any discussions
with people at the White House about John Huang?
Answer. I don't remember any specifically, but I can't imagine I
never had a conversation about, you know, the news, he was in the news.
Question. Do you recall any conversations with people about, you
know, the issues involved on how he raised money or what he was doing?
Answer. No.
Question. Do you recall telling anyone in the counsel's office or
elsewhere that you had met with John Huang?
Answer. No. I guess I had characterized him as meeting with John
Huang. I had, up until the time he left, thought I was meeting with
Ambassador Eu and her two assistants.
Question. Okay. So you never talked with the First Lady or the
President about John Huang?
Answer. No, I never had to.
Mr. Ballen. I'm sorry?
The Witness. I said, no, I wouldn't have a need to.
Question. Turning over to Charlie Trie and the meeting that you had
with Mr. Cardozo, do you have any knowledge of Mr. Trie--have you
learned any to date of Mr. Trie being at the White House on the same
day that you had the meeting with Mr. Cardozo?
Answer. No.
Question. Do you have any reason to believe that he had been
invited to the meeting or was there to explain to anybody anything
about the contributions?
Answer. No, no.
Question. Okay. And at the time, if you recall, that the
information about Charlie Trie and legal defense fund was becoming
public and the process inquiry, what happened then? What was your
involvement?
Answer. I think the issue was that--and I don't know if it was a
network or a newspaper, but I believe the issue was that--whether or
not simply to answer the one inquiry that had come in, or whether or
not to kind of call all the media people up on, you know, all the media
people in, talk to them all at once about this particular issue. That
was the heart of it.
Question. And do you recall suggesting--anyone suggesting Mark
Fabiani be called, involved in this?
Answer. Oh, yeah, I did.
Question. And what was your suggestion?
Answer. Oh, you know, I said the person I think who would know
whether or not to call one or to call all would probably be Mark
Fabiani.
Question. And at the time in December when this was being
discussed, how to respond to making it public, did anyone raise the
issue that Mr. Trie had just been at a White House dinner or had been
at a trustee dinner?
Answer. You know, I vaguely remember something about this, but I
don't--I kind of more remember it literally in terms of hearsay. And I
don't know if it was from press accounts or whatever. I don't remember
discussing it.
Question. Do you recall who else was involved in these discussions
and meetings?
Answer. Oh, about the press inquiry?
Question. Uh-huh.
Answer. I know that Evelyn Lieberman was.
Question. And do you recall what her role was in discussions or
suggestions?
Answer. No, I think it was just on the--I'm pretty sure that I have
the issue right, that it was responding to one press inquiry or
responding to--or--or trying to make information available to everyone
at once.
I remember that Evelyn was involved in giving advice. I don't
remember what her advice was, but she's the former communications
director. I'm trying to think if anybody else was around. For some
reason I just remember Evelyn.
Question. And have you ever had any conversations with the
President or the First Lady about Mr. Trie or anything having to do
with Mr. Trie?
Answer. No, I haven't. Not about Mr. Trie, huh-uh.
Question. Do you know someone named Crawford who works at the White
House? Is it Kelly Crawford or is it somebody----
Answer. Oh, there's a Kelly Craighead.
Question. No, Mr. Trie was meeting with a Crawford on May 12th,
'94.
Answer. Huh-uh.
Question. Which was the date of the health care donations that we
were previously discussing with Mr. Trie?
Answer. Kelly Craighead. I don't know Kelly Craighead.
Question. I don't know if it's Kelly. I was thinking of that name,
too. It was Crawford on the names in the WAVEs, and I don't know what
the first name is. You don't know a Crawford who was involved in health
care matters?
Answer. No, although there were a lot of people involved in health
care, I don't know of one.
Mr. Ballen. Excuse me, counsel, could we have a brief break?
Ms. Comstock. Okay. How about if I just finish up this area on Trie
and then we could break. Would that be okay? And then I think we would
just be going to the Johnny Chung matters and then we will be done.
Mr. Dennis. That will be fine.
EXAMINATION BY MS. COMSTOCK:
Question. Have you ever had any discussion with anybody at the
White House about Mr. Trie being at the White House, you know,
frequently and meeting with the President and the First Lady?
Answer. I can only think that informally, after the news--I mean, I
can't imagine that I didn't discuss ever what was in the newspaper with
people.
Question. Who arranges, when the First Lady gets pictures taken at
the White House, who arranges for that?
Answer. Usually through scheduling.
Question. And so that would be Patti Solis?
Answer. Patti Solis. It could be Capricia Marshall, depends on
where the picture is being taken, who might arrange for it.
Question. And somebody has to make a request to those people and
they set it up?
Answer. Well, we have--we have a couple of ways. I mean, you can
make a request through those people and they can set it up. Which, you
know, which happens.
In the First Lady's office we have hit upon what I think is a great
idea, since we get so many requests at the last minute for photos, is
that if Mrs. Clinton is on her way out the door to go somewhere, to
give a speech or whatever, we have a couple of things that are already
working for us. One, she doesn't have to spend a long time. She's
walking out the door. And, two, there's a photographer probably in
hand; and, three, she's already made up and whatever.
And so we have a tendency of trying to push as many planned and
unplanned photographs into any time when we know she's walking out the
door, so--and you have got the nice background of the Diplomatic Room.
And so generally that can be done fairly quickly with the scheduler, or
even calling over to--calling over to her personal assistant, Capricia
Marshall.
Question. Is this a daily routine, then?
Answer. It can be----
Question. Or you try to schedule them on particular days of the
week?
Answer. No, the only thing we really try--it really does go with
her schedule. If she's walking out the door, we can do it. And I think
that Patti makes a genuine effort, even on the planned ones where we
might have, you know, like 20 people which we sometimes have, to push
them on days when she's got--when it won't take, you know, more than 10
or 15 minutes. And we might do five, six, seven, eight photos and then
out the door.
Question. Get groups to come in and just line up and do sort of
cattle call and move them through?
Answer. Yeah, whatever we want to do. A staff person is leaving,
this is their last day, call them up, we can do a photo. So we do it
that way. I mean, it takes a lot more if we are doing--and we have done
schools and whatever, you know. That's another kind of photo.
But this method works great for us, and we've also got a method on
receiving lines. Anything that has to do with photos, we pretty much
are the experts in getting them done and doing them quick.
Ms. Comstock. I believe we can take a little break here.
[Recess.]
EXAMINATION BY MS. COMSTOCK:
Question. I just have a few little miscellaneous things I want to
go through first. Then we will go into the other areas.
This is a phone message to you from Yusuf Khapra in Erskine
Bowles's office for October 13, 1996, from Mark Middleton, and it
says--he said that it's very important that you get in touch with Mark
Middleton, who is at the following number. And then it says call Yusuf
if you have any questions.
This is mid-October, during the middle of the campaign, if it helps
in placing it in time. The John Huang stories were well in circulation
at this time, along with the Webb Hubbell issues, the Safire column and
things like that. Do you recall ever talking to Mark Middleton in the
middle of October, first, at all?
Answer. I don't recall. I could have. I mean, if he called me, I
would have talked to him.
Question. Do you recall if you talked to him about any matters
related to John Huang and Webster Hubbell in the time frame of October
1996?
Answer. No. First of all, I can't imagine talking to Mr. Middleton
about John Huang, who I didn't know, or what could be said about Webb
Hubbell. If I was asked to call Mark Middleton, I know I would call
him. So, I mean, I wouldn't deny that if I was asked to call him that I
wouldn't call, but I don't know necessarily what this is about.
Question. It says that he said that it's very important.
Answer. I don't know. Very important to Mark Middleton could be
``I've got to get into the mess.'' I mean, I just really do not know.
But I'm happy if you have anything else that might refresh my memory on
it.
Question. Actually, this phone number that's on here, I did make a
call to it and it is a Dominican Republic hotel, if that helps at all.
Answer. Get out.
Question. Do you recall if you called him, or why you would have
called him, if you knew what he was doing in the Dominican Republic?
Mr. Ballen. Well, is that what it is now or what----
Ms. Comstock. That's what it is now when I called this past
weekend. That's what I got. I don't know. Apparently that exchange must
be the Dominican Republic. I don't know if it was a hotel.
Mr. Dennis. That's the Caribbean.
The Witness. I just don't know.
EXAMINATION BY MS. COMSTOCK:
Question. It doesn't ring a bell, him being in the Dominican
Republic and him calling you with something very important from the
Dominican Republic?
Answer. No, it just doesn't.
Question. Okay.
Answer. I'll try and think about it. I just don't know.
Question. Do you recall generally ever discussing any matters
related to Mr. Hubbell with Mark Middleton?
Answer. No.
Question. Let's see, there were just a few other items. We've
generally discussed a few Harold Ickes memos today, and I'm not going
to go a lot into Mr. Ickes's documents, but a number of them--a lot of
them were cc'd to you. I'll just give you--I'm not sure if this is a
whole package or this is all together. I am sorry.
This is a June 5, '95 memo about '96 reelect fund-raising
projections and expenses, and you are cc'd on this memo. It's a memo to
the President and the Vice President. It's marked ``the President has
seen.'' Do you recognize the handwriting that's in sort of dark pen?
Answer. This right here?
Question. Yes.
Answer. This looks like the President's.
Question. And I think the other handwriting on there is just
somebody's translation of the President's handwriting because it says
the exact same thing, just in somebody else's handwriting that's a
little easier to read.
Do you recall generally, first, before going into this
specifically, getting the Harold Ickes memos circulated to you on a
regular basis?
Answer. Yes, I do.
Question. And can you describe what, you know, being on the
circulation of those memos, what was your role in getting them or what
did do you with them?
Answer. If I had time, I would read them. If not, I would collect
them hoping to read them, and then after a week or so I'd just throw
them away.
Question. You did not maintain them anywhere?
Answer. I mean, there were thousands of memos from Harold. I mean,
no one could--could both do their work and read Harold's memos.
Mr. Ballen. When you say thousands, is that a literal number or
just a figurative number?
The Witness. I'm sorry; figurative. I'm sorry.
Mr. Ballen. A lot?
The Witness. Quite a few.
EXAMINATION BY MS. COMSTOCK:
Question. Do you generally recall the memos that you got from
Harold Ickes, generally what they were about?
Answer. It seemed like they were about everything. It could be
about campaign, could be about convention, could be--I mean, it could
be about any number of things.
Question. The DNC?
Answer. It could be about the DNC.
Question. What understanding do you have of Harold Ickes' role vis-
a-vis the DNC?
Answer. Main liaison. The President's political person.
Question. Were you aware of people at the DNC having to get
Harold's approval before they could--for basic day-to-day--him
controlling--they have to tell him what they're doing before they spend
money or take major actions at the DNC?
Answer. I'm not aware of what they asked Harold day-to-day. I would
say that he had some reasonable influence there.
Question. Did you understand him to have a day-to-day working
relationship with the DNC?
Answer. Day-to-day? I don't know if he talked to them day-to-day.
Question. In particular, say, from fall '95?
Answer. I just don't know.
Question. Through the election?
Answer. Honestly, we are in two different buildings so I don't know
what he did day-to-day. As I said before, it was clear to me he had a
reasonable influence upon people at the DNC. But anybody who was
involved in the President's political business, he had an influence.
Question. And you had indicated previously that you didn't realize
until recent press accounts that Harold was opposed to the large media
campaign that Dick Morris had recommended. Did you ever get any of the
memos from Harold Ickes sort of opposing Dick--did you ever get any
memos from Harold Ickes that were opposing this campaign of--spending
campaign that Mr. Morris was recommending?
Answer. I could have gotten it--if it came in his regular
circulation of memos, I could have gotten one that said that.
Question. I'm just asking if you recall getting any such memos
where he was discussing, you know, being opposed to Mr. Morris's
efforts or----
Answer. No, I guess I didn't think of Harold as being opposed to
anything that was going on in the campaign. I think he was opposed to
Dick Morris. I just think it was a personality thing. That's how I
always viewed any opposition he had.
Question. And you had an understanding of that at the time, that
they were antagonistic with each other on everything sort of generally?
Answer. It was in the newspaper every day during the campaign.
Mr. Ballen. I object to this line of questioning about the friction
between Morris and Ickes.
Ms. Comstock. I don't think it is a line of questioning here. The
witness brought up----
Mr. Ballen. I object to the question. It's irrelevant and beyond
the scope.
EXAMINATION BY MS. COMSTOCK:
Question. When you got the type of memos here, this CGRO-13451 and
its attachments, when you got this type of memo, what was--do you know
if you ever had--provided any feedback to Mr. Ickes or discussed it
with the First Lady or kind of took any action based on this type of
memo, or if you recall this one in general, anything you did?
Answer. I mostly stacked them. I figured if there was anything that
was really of importance that Harold wanted me to focus on, he or Doug
would call me.
Question. Okay. And were there particular things that Harold would
call you about to focus on?
Answer. Scheduling. Hillary's scheduling.
Question. And what type of scheduling was that?
Answer. He wanted her out in the country.
Question. Okay. And previously you had said you thought you may
have gotten a memo from Mr. Ickes about the phone calls. And I just
wanted to show you----
Ms. Comstock. Why don't I make this previous, this other memo
Deposition Exhibit Number--oh, yeah, I'm sorry, the Yusuf Khapra
message about Mark Middleton that had the Dominican Republic phone
number, we will make that Deposition Exhibit Number 23.
[Williams Deposition Exhibit No. MW-23 was marked for
identification.]
Ms. Comstock. And then we will make this June 5th, '95 memo Exhibit
24.
[Williams Deposition Exhibit No. MW-24 was marked for
identification.]
The Witness. Is this the best copy?
EXAMINATION BY MS. COMSTOCK:
Question. And moving on to a new memo, which is a November 28th,
'95, memo to the President and Vice President from Harold Ickes and
cc'd to Leon Panetta, Erskine Bowles, Maggie Williams, Ron Klain, David
Strauss, Doug Sosnik, Karen Hancox, Chairman Dodd, Chairman Fowler,
Marvin Rosen and Scott Pastrick, regarding fund-raising efforts for DNC
media.
And I direct your attention to the bottom of the page where it
says, number 1, Based on our 28 November meeting, Marvin Rosen thinks
it unrealistic to expect the raising of new money that will actually be
deposited during calendar year 1995 in excess of $1.2 million. This
amount can be raised, in his opinion, only under the following
circumstances. And then it lists approximately 20 phone calls by the
President, approximately 15 phone calls by the Vice President, and
approximately 10 phone calls by HRC. It goes on to have some other
items, too.
But does this refresh your recollection in terms of any discussion
about the phone calls or knowledge you may have had about the phone
calls?
Answer. No. Once again, this was raised or shown to me at a
previous deposition. My sense is, once again, if they wanted me to do
something with respect to Mrs. Clinton making phone calls, they would
have called me. I mean, everything that was written down in a memo, I
couldn't take as--if someone wanted to follow up on it, I figured I'd
be called.
Question. And did, in fact Mr. Ickes or Mr. Sosnik ever call to you
ask you to----
Answer. No.
Question [continuing]. Discuss the phone calls with the First Lady?
Answer. No.
Question. And the $1.2 million here, generally, like this is the
only way to raise the money, do you ever recall any discussion about
the only way we can kind of get to some targeted goals is by having
these phone calls?
Answer. No. I mean, I don't recall discussions that said the only
way we can get to those goals is by these phone calls.
Question. Okay. Do you have any other--aside from what you
testified today about the phone calls, do you have any other knowledge
about the phone calls, aside from press accounts, phone calls made by
the President, the Vice President or the First Lady for DNC fund-
raising?
Answer. By press accounts only.
Question. Okay. So for any--you weren't involved in any of the--
whether there was controlling legal authority to make phone calls or
where phone calls should be made from or anything like that?
Answer. Oh, no, I was not.
Ms. Comstock. I will make that Deposition Exhibit Number 25.
[Williams Deposition Exhibit No. MW-25 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. This is a January 31st, 1996 memo to the President and
the Vice President from Harold Ickes, again. You're cc'd on this about
estimated DNC and other expenditures for calendar year 1996. CGRO-13667
through 69.
Just in general, are there any particular memos that you recall
from Harold, I'm just providing you this as an example, but any
particular memos that you received from Harold, that you recall sort of
taking action on or becoming involved in issues that he had generated
from his memos?
Answer. Once again, if there was any particular action that Harold
wanted me to take or Doug wanted me to take, I knew that I could expect
that they would call me and they would lay out to me what it was that
they were interested in. I mean, I just did. I couldn't possibly have
followed up on everything that was written in these memos.
Half of it I didn't understand. But, more than that, a lot of it I
didn't think that it was--had anything to do with my purview. I mean,
my view was that my job in the campaign was to keep Hillary Clinton out
there and on the road. That was my first--I think that was my first job
in relationship to the campaign.
Question. Okay. Showing you an August 6th, 1996, memo from Harold
Ickes to the President and the Vice President, marked the President has
seen, 8/5/96. And it's regarding DNC budget/fund-raising meeting of
August 1st, '96.
Do you recall generally discussions in any meetings you were
involved in or having discussions with Harold Ickes or others at the
White House about the DNC budget in general? Was that something that
you were involved in discussions about?
Answer. I think I attended one meeting early on--I don't know when;
it seems to me way before the campaign about the DNC budget--in the
residence. That was the only meeting I remember; and it was mostly just
what their budget was, as I recall. But it seemed, you know,--I do
remember one meeting about the DNC budget.
Question. And do you recall any discussions about having Mr. Ickes
have more control over the budget or reviewing the budget of the DNC?
Answer. Having more control over it? No, I don't remember any
discussion.
Question. Were you aware of any people at the White House who
worked with Mr. Ickes who reviewed DNC budget numbers or contracts or
anything like that?
Answer. No, I was not aware of that.
Question. Do you know a Jennifer O'Connor who worked for Mr. Ickes?
Answer. Yes, I do.
Question. What was your understanding of what her role was at the
White House of her job with Mr. Ickes?
Answer. I don't know. I just thought she worked in political. I
don't know what she did specifically.
Question. Do you have any knowledge of her being involved in
reviewing any budget matters for the DNC?
Mr. Ballen. I'm sorry, counsel, I can't hear the question.
EXAMINATION BY MS. COMSTOCK:
Question. Do you have any knowledge of Ms. O'Connor doing any
budget matters for the DNC, working on that?
Answer. No, no, I didn't.
Ms. Comstock. I will mark this document Deposition Exhibit 26.
[Williams Deposition Exhibit No. MW-26 was marked for
identification.]
Ms. Comstock. Can we just go off the record for just a minute?
[Discussion held off the record.]
EXAMINATION BY MS. COMSTOCK:
Question. Were you aware of Harold Ickes ever meeting with any
labor union PAC people at the White House?
Answer. No, I wasn't aware of his schedule--if I wasn't involved in
it.
Question. Were you ever involved in any meetings where Mr. Ickes
had labor union people at the meetings discussing media buys or media--
the kind of commercials the unions were going to run or anything like
that?
Answer. No, no.
Question. Okay. I just wanted to go through a few questions on Mr.
Hubbell.
Mr. Ballen. I'm sorry?
Ms. Comstock. On Mr. Hubbell, Webster Hubbell.
Mr. Dennis. Hubbell.
EXAMINATION BY MS. COMSTOCK:
Question. While you were at the White House you came to know
Webster Hubbell; is that correct?
Answer. Yes.
Question. When he was Associate Attorney General?
Answer. Yes.
Question. Did you know him prior to your joining the White House
staff?
Answer. I met him in the campaign. I never worked with him, but I
met him. Well, actually, I met him right after the election.
Question. And you knew him to be a close friend of the President
and the First Lady?
Answer. Yes.
Question. Did you work on any matters with him while he was at the
Justice Department?
Answer. No.
Question. So any occasion when you would be calling him or dealing
with him at all, would that be sort of a social or sort of a
ministerial kind of--you know, come over for an event or anything like
that?
Answer. No, I didn't have any substantive matter that I worked with
Webb on. No.
Question. Do you know if he was involved in any health care matters
that you worked on?
Answer. Not that I--not that I worked on. He may have been involved
in tort reform issues around health care, but that would be the only
thing that makes sense.
Question. At any time prior to his announcing his resignation,
which is March of '94, were you aware of any problems that he had with
his law firm?
Answer. No.
Question. Were you aware of any sort of, in the months leading up
to his resignation, of people from the law firm attempting to get in
touch with the First Lady with Mr. Hubbell?
Answer. No, huh-uh.
Question. Have you ever discussed with the First Lady any of Mr.
Hubbell's problems related to the Rose Law Firm?
Answer. No, not related to the Rose Law Firm.
Question. And in that--the meetings in relation to the billing
problems and the mail fraud, I guess the things that he pled guilty to,
that kind of thing?
Answer. No.
Question. Did the First Lady ever express anything to you about Mr.
Hubbell had defrauded her or anything like that?
Answer. No.
Question. And--at any time?
Answer. No.
Question. No? She had made some statements on Larry King this year
when she was on TV, you know, that he was a partner; you know, I was a
victim, too. Did you ever hear the First Lady say anything like that to
you at any time over the past 4 years or so?
Answer. No, the only thing that she's ever expressed to me
regarding Webb Hubbell is, you know, tremendous sense of sadness about
it, about him.
Question. About his situation?
Answer. Yes, uh-huh.
Question. And nothing about specifics?
Answer. No.
Question. Or anything about what he--did she--did the First Lady
ever mention what he said to her? You know, he told me he didn't do
anything like--anything like that?
Answer. No, she would never say that to me.
Question. Do you know a gentleman named Jim Blair?
Answer. Yes.
Question. And do you have occasion to see him at the White House
frequently?
Answer. I didn't see him frequently, but I've seen him at the White
House at events.
Question. And in the 1993 time frame, is it correct that Diane
Blair stayed at the residence quite a bit?
Answer. I don't know quite a bit, but I know that she's a friend of
Mrs. Clinton, and she's stayed at residence. I don't know how many
times.
Question. Do you have any knowledge of her being camped out or
living at the White House in '93?
Answer. Camped out?
Question. She had a class, I think she was teaching, something to
that effect, where she was kind of based at White House in '93.
Answer. Oh, I think that she was based--I think that she had a
class, and I don't know if it was every 2 weeks or every 1 week, and
she would fly in and fly back out. That's what I thought. But I wasn't
at the residence, but I do remember that she was teaching a class
somewhere.
Question. And do you have any knowledge about Mr. or Mrs. Blair's
involvement in any matters related to Webster Hubbell?
Answer. No.
Question. Did you have any knowledge about Mr. Blair calling the
President or the First Lady to discuss any matters related to Mr.
Hubbell?
Answer. No.
Question. When did you first learn about that Mr. Hubbell was going
to resign?
Answer. I don't know--I don't know if I learned the day he resigned
or the day before he resigned, but it was very tight in there.
Question. He resigned on March 14th, 1994; and there has been
reported in the press a meeting that Sunday, March 13th, that even, the
night before, a meeting where at the end of the meeting Mr. McLarty
brought up the issue of, you know, I'm going to help Webb. He said
something to that effect. It may have been an afternoon meeting. It was
sometime on Sunday of March 13th.
Do you have any general recollection of a meeting that was close in
time prior to Mr. Hubbell's resignation where anything like that was
discussed?
Answer. I have a recollection of a morning meeting, maybe a Sunday
morning meeting--actually, a Sunday morning meeting. I don't know the
date of it. And this is pure--I mean, this is kind of based on having
read news accounts, but the only meeting I can think of is a meeting
that was held actually to discuss, I think, the resignation of Bernie
Nussbaum, the White House.
Question. Which had been approximately I think on March 4th, '94,
or thereabouts, a week or so before Mr. Hubbell resigned?
Answer. Yeah.
Question. 10 days.
Answer. I mean, I remember attending a meeting on a Sunday morning
about the White House Counsel's Office.
Question. And do you recall Mr. Ickes being at that meeting?
Answer. No.
Question. Or Mr. McLarty?
I'm sorry. I'm not representing that Mr. Ickes was there. I'm just
seeing if you--I know Mr. McLarty was at a meeting on the 13th, so if--
--
Answer. Well, I don't actually recall Mr. Ickes being there. I'm
trying to think. I mean, I recall--I recall Mrs. Clinton being there. I
recall the President being there. I recall--I don't know if I recall
Mack being there. I just think he ought to have been there. But I
recall Mack McLarty--but there was a meeting on Sunday morning about
Mr. Nussbaum's resignation.
Question. And could you just tell us generally about that meeting?
Answer. Well, I just think it was about his replacement, what
issues, and generally about the arrangement and organization of the
counsel's office.
Question. And were you aware of any sort of general discussion of
sort of how sort of damage control operations were going to be handled
on these and matters of Mr. Hubbell?
Answer. I guess I wouldn't have talked about it in terms of damage
control. I would really talk about it in terms of----
Mr. Ballen. Excuse me. The question was related to Mr. Hubbell.
The Witness. Oh.
EXAMINATION BY MS. COMSTOCK:
Question. I'm sorry. Maybe, just generally, did you discuss--was
there any discussion--why don't I strike the last question and start
over? was there any discussion in this Sunday morning meeting that you
recall of generally of how we are going to approach sort of Whitewater
matters, Mr. Nussbaum, Mr. Hubbell, or was it--I'm trying to see if
there was a more general discussion of--sort of on March, '94, was sort
of a problem----
You had subpoenas coming in at that point, and Mr. Nussbaum had
resigned, and Mr. Hubbell was about to resign, and would those matters
all going on--the special counsel, Mr. Fiske, had been appointed in
January. And I was wondering if there was general discussion in this
meeting about how to approach all of these things as you go forward
with your other duties.
Mr. Ballen. Excuse me. I am going to object to this question on two
grounds: One, you have asked, I think, three questions in that last
question, so it's going to be hard for the witness to separate them
out.
Secondly, I'm going to object to it generally. The witness has
testified that this meeting was about the Nussbaum resignation, not
about the Hubbell resignation. So I'm going to object to any questions
as to the circumstances of the Nussbaum resignation.
If you want to ask the witness was Hubbell discussed and the
resignation, I would have no objection to that. But insofar as it goes
beyond to yet another matter, I would object to it.
EXAMINATION BY MS. COMSTOCK:
Question. Well, I mean, we've--you know, we are generally talking
about the Sunday morning meeting here that you recall. We--the White
House--we've reviewed notes from the White House that indicate--and
others whether this is the same one or a Sunday meeting on March 13th,
which is the day prior to Mr. Hubbell resigning--which indicate there
were sort of a general discussion of this.
What I'm trying to find out is if you recall at this or another
meeting a general discussion of sort of how to handle all of those
various matters that I just previously described.
Answer. I don't recall a discussion about Webb Hubbell's
resignation at this Sunday morning meeting. What I recall is it was a
meeting about the Nussbaum resignation and how to handle the different
areas that the Counsel's Office would have to involve itself in, and
that really was the focus.
Question. Was there a discussion of how to respond to subpoenas or
how you were going to go forward with matters at that time?
Answer. Those things could have been discussed, but my
recollection, my recollection of the meeting, and maybe it is just
because I bring a certain perspective, was it was much more structural
and more about the leadership of the office itself, a structural and a
personnel issue, which was quite frankly where I would be focused.
Question. Was there any discussion of what Mr. Ickes's role would
be in responding to any of these Whitewater matters or Mr. Hubbell or
any of those, what his role would be?
Answer. I really don't recall a focus on Mr. Ickes. I mean, I just
don't recall that. I mean, in my mind, I just remember--this is the
meeting on the Counsel's Office.
Question. If it is not this March 13th meeting that we have
reviewed notes on, or if it is not the Sunday morning that you recall,
do you recall at any other time discussing Mr. Hubbell's resignation or
any issues related to that prior to his resignation?
Answer. No, I do not.
Pardon me, let me just amend that a little bit, because I don't
know if I learned about Webb's resignation the day of his resignation
or the day before. It was pretty tight, so I don't know if there was
any discussion, or if it was just announced the day before to the
staff.
Question. Okay.
Answer. That is kind of what I think happened.
Question. Okay. And this meeting the night before where Mr. McLarty
has indicated that at the end of the meeting he said to the First Lady,
you know, I am going to be helping Webb, do you have any recollection,
do you have any knowledge about that?
Answer. No.
Question. You don't recall that exchange or that discussion?
Answer. No.
Mr. Dennis. Do these notes place my client at that meeting?
Ms. Comstock. Yes, the White House notes. But I am trying to be
fair here and make the record clear. It has been indicated--the notes
from that March 13th meeting indicate she was there. The notes do not
have any--they do not discuss the actual notes that are on the meeting.
There are some separate notes, and Mr. McLarty has publicly indicated
that at the end of the meeting, so I want to clarify that.
EXAMINATION BY MS. COMSTOCK:
Question. But do you recall any discussion with Mr. McLarty about
Mr. Hubbell?
Answer. Me?
Question. With you.
Answer. No.
Question. Okay. Were you aware of any efforts by anybody at the
White House to assist Mr. Hubbell in obtaining employment?
Answer. Only what I know from the newspapers.
Question. Okay. So from the time he announced his resignation until
the newspapers, you had heard nothing about anybody at the White House
or any friends of the President or First Lady attempting to assist Mr.
Hubbell in getting a job or consultant contract?
Answer. No, I have not.
Question. So I can assume you had no knowledge of him attempting to
settle any of his legal problems with the Rose Law Firm?
Answer. No, I don't know anything about that.
Question. Do you have any knowledge of Mr. Hubbell being in touch
with the First Lady after his resignation, what his--how often he was
in touch with her?
Answer. No, I do not.
Ms. Comstock. Okay. I am showing the witness EOP 58979 through--
actually, it is a variety of things. It is a grouping here. On 58980
there is a message to Pam. It says, Webb Hubbell, he wants to talk with
Mrs. Clinton.
EXAMINATION BY MS. COMSTOCK:
Question. Is there a Pam in your office?
Answer. No, she actually works in the West Wing in Mrs. Clinton's
office, Pam Cecetti.
Question. Okay. And that message was dated April 8, and then there
is an April 13th message with Mrs. Clinton, and then a June 10, '94
message with Mrs. Clinton.
Did you have any knowledge about--does this refresh your
recollection as to whether Mr. Hubbell was in contact with Mrs. Clinton
during this time frame?
Answer. No.
Question. I'm sorry, I gave you my copy.
Answer. I'm sorry.
Question. That is okay. You are looking at my little scribbles,
that is okay.
Answer. They don't mean anything to me.
Question. So generally did you have any sense of whether the First
Lady continued to be in touch with Mr. Hubbell, or didn't or did you
not know either way?
Answer. I do not know either way.
Question. Do you have any knowledge about Mr. Hubbell working out
of Mr. Cardozo's office?
Answer. No.
Question. Do you know a Michael Berman?
Answer. Yes.
Question. All right. He was in touch with the First Lady's Office
and people at the White House somewhat frequently?
Answer. Somewhat frequently, yes.
Question. Do you have any knowledge that Mr. Berman was assisting
Mr. Hubbell in any way?
Answer. No, I do not.
Question. I assume you have no knowledge, then, of anything related
to the Lippo Group or Mr. Hubbell receiving $100,000 from the Lippo
Group?
Answer. No.
Question. Have you had any discussions with anybody at the White
House about Mr. Hubbell working for the Lippo Group?
Answer. No.
Question. When any of those articles appeared, did anyone at the
White House ever comment to you about, gee, I had heard about that, or
that is not true, no, he didn't make that much money or make any type
of comment in general about, first, the allegations, then sort of later
the account of Mr. Hubbell making that kind of money?
Answer. Not specifically. There may have been a general discussion
as there is about the news.
Question. Can you recall who generally who you discussed that with?
Answer. Oh, God, I don't know. It could have been anybody.
Question. Do you know if you ever spoke with the First Lady about
that?
Answer. No.
Question. Generally people in your office you would have discussed
that with?
Answer. Oh, I don't know. It's so general. I mean, it is just
like--you know, becomes kind of a current event, I mean, did you read
the newspaper about such and such, yes, I read it.
Question. Were you surprised to read that Mr. Hubbell got upwards
of half a million dollars in the year after he left the Justice
Department?
Answer. Nothing surprises me.
Question. Did anyone ever comment to you about they were surprised?
I mean, can you think of anyone in particular that ever made a comment
one way or the other about knowing about anything related to that?
Answer. No.
Question. Have you ever discussed any of those matters with Mr.
Lindsey?
Answer. No.
Bruce Lindsey?
Question. Bruce Lindsey.
Answer. No.
Question. After Mr. Hubbell had resigned from the Justice
Department, did you have any knowledge about him taking any foreign
trips or foreign travel?
Answer. No, I didn't.
Question. Were you in touch with Mr. Hubbell at any time after he
left the Justice Department?
Answer. Yes.
Question. And do you recall on what occasions those were?
Answer. I wrote him a letter when he was in--when he went to
prison.
Question. Just as a friend?
Answer. Yes.
Question. Okay. And did you--have you ever contacted him besides
that, or did he write back?
Answer. He wrote me back.
Question. And I don't want to get into the real details of this,
but can you generally discuss what you wrote?
Answer. I think I wrote that I was thinking of him and praying for
him, and I believe he wrote back what he was reading and--what books he
was reading, and I am not sure, did I give that letter to you?
Mr. Dennis. I don't remember.
The Witness. Or Ken Starr or somebody. I no longer own my own
letter from Webb.
Mr. Dennis. Nothing related to this topic?
The Witness. No, not at all.
EXAMINATION BY MS. COMSTOCK:
Question. And did you have any other contact with him after that?
Answer. No.
Question. Was that then the last contact you had with him was him
writing back?
Answer. I was afraid to.
Question. Were you aware of any legal defense funds set up from Mr.
Hubbell?
Answer. No, I didn't think there was a legal defense fund set up
for him. I thought there was a scholarship fund for his children.
Question. That is correct. I think there was some family trusts,
separate trusts set up?
Answer. I heard about that, yes.
Question. Do you have any knowledge of any efforts of anyone in the
White House to assist in raising money for those trusts?
Answer. No, I don't, not specifically anybody.
Question. Were you aware of Mr. Hubbell getting contracted to write
a book while he was in jail?
Answer. I read about it. I think I read about it in Publishers
Weekly.
Question. And were you ever aware of any discussions at the White
House about what Mr. Hubbell was writing about in his book?
Answer. No.
Question. Any concerns ever expressed about that?
Answer. No.
Question. Why don't we move on to Mr. Chung. Could you tell us when
you first met Johnny Chung?
Answer. Very soon after the election, I met him someplace in
Washington, either at an event or he was introduced to me by someone,
but I remember that it was very early after the election.
Question. Okay. Can you describe that meeting?
Answer. He told me he was very enthusiastic--he was a very
enthusiastic gentleman. He told me that Mrs. Clinton had--this is total
paraphrase--that Mrs. Clinton had made him a success in his business,
that she was his inspiration, that she had given him advice that, you
know, had more or less changed his life.
Question. And did he describe what that was?
Answer. I think she wrote him a letter, and I think she--he didn't
say this, but I got the feeling he actually talked to her in Arkansas,
and I don't know when he had talked to her, but, you know, prior to her
becoming First Lady of the United States.
Question. Okay. Have you ever learned from any other source what
that meeting involved or if that meeting occurred?
Answer. Well, at some point I talked to Mrs. Clinton, and I related
the story of having met Johnny Chung and what he had said, and she said
that she--once again paraphrasing--that she had remembered meeting him,
was not aware that she had changed his life, remembered meeting him in
Arkansas, remembered his energy, and remembered that he said that he
was going--you know, that he was going to work really hard and make a
success of himself and of his family, and that she had been
encouraging, but she had not known that she had become such a figure in
his life.
Question. All right. Do you recall if she said she met him in
Arkansas?
Answer. Yes. As I said, I am paraphrasing, but it seems to me, as I
remember, she met him--she met him in the Governor's Mansion, I think,
in Arkansas. That is what I think it was.
Question. And how did Johnny Chung come to be at the Governor's
Mansion in Arkansas?
Answer. I have no idea.
Question. So did the First Lady tell you he had been at the
Governor's Mansion?
Answer. I believe that is what she said.
Question. And when you discussed this with the First Lady, did
she--did she tell you, you know, anything about what he was in business
doing or what?
Answer. No. In fact, she was trying to remember him, but she had
remembered that there had been this Asian American man and that the
name sounded very familiar to her, and I kind of told her the story,
and it seems to me she tried to remember who he was, had a vague
remembrance of him, and that pretty much was it.
Question. All right. Now do you recall in time, like when you--I
know you don't recall exactly when you met Mr. Chung, but do you recall
in relation to when you met Mr. Chung and when you had this
conversation with the First Lady if that was fairly contemporaneous,
like, I met a guy, you changed his life; or did that come up later
after Johnny Chung had made visits or done whatever?
Answer. I think it was fairly contemporaneous because, as I said,
for some reason, I am--one thing I feel very clear about is that I met
him early in the administration, I just kind of remember meeting him
early. And I believe the conversation was contemporaneous because it
was kind of an interesting, you know, kind of an interesting tale to
tell. I mean, you have a person who says, you changed my life. You say
something about it maybe.
Question. Is there anything else about this first meeting you
recall, if it was a large event or a small event?
Answer. I really don't remember, but I just remember the story, and
kind of, you know, short, stout man who had some difficulty speaking
English, but he was a character.
Question. I'm sorry, do you recall if this was or was not a fund-
raising event that you met him at?
Answer. I really don't recall.
Question. Someplace in Washington, D.C.?
Answer. Yes.
Question. This is a document we received from the DNC, 1096988
through 89, which is a March 28, '94, Los Angeles Business Journal. And
there is a feature article on Mr. Chung, which in the beginning
describes him watching the election and I guess the debate between
George Bush and Bill Clinton in '92, and that inspires him to go to
Little Rock and I guess essentially knock on the door, where he met the
First Lady.
Does that at all refresh your recollection of anything he told you
or the First Lady might have told you?
Answer. Well, that gets to the mansion part. Yes, I--I really
didn't remember that he was inspired to go to Arkansas because of the
debates.
Question. And then--but when you had this meeting with him, he did
say he had gotten a letter from the First Lady or something that
inspires him to, or he had a discussion with her?
Answer. It seems like he had a discussion with her, and then I
think there was a letter that came, or he had written to her, and then
there was a letter that came back.
Question. Okay. Were you aware of this letter at the time when you
discussed, you know, Mr. Chung?
Answer. No.
Ms. Comstock. Why don't I make that article Deposition Exhibit No.
27.
[Williams Deposition Exhibit No. MW-27 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. Then this is April 26, 1993, a letter to Johnny Chung
from Hillary Rodham Clinton, with the White House stamp on it, which
reads:
``Thank you for your letter and my apologies for not getting back
to you sooner.
``It appears from the correspondence you have had with Federal and
State officials, and the private sector, that you are already on the
right track. Nevertheless, I wish you good luck with your innovative
system.''
Did you ever see this letter or know about this letter at all?
Answer. I have seen it in recent times. I mean, I don't remember
seeing it in April of 1993.
Question. Okay. You have seen it at a recent deposition?
Answer. No, actually, before that. I don't know what the
circumstances were, but I have seen this letter before.
Question. Do you know if it was in conjunction with compiling
documents or trying to review any matters related to Johnny Chung
within the White House?
Answer. Yes, it could have been. That may be, it could have been.
Question. Did anyone at the White House ask you to compile
documents about Johnny Chung in particular?
Answer. I think at the point of some subpoena, yes.
Question. And do you recall who asked you to get some of those
documents together?
Answer. No. I think it was probably written, and I don't know who I
talked to.
Question. Did you talk with someone in the Counsel's Office about
the various documents?
Answer. I don't really believe I had any documents.
Question. Or documents from the First Lady's Office?
Answer. They would have gone directly to correspondence people and
people who keep her correspondence, but I do remember seeing this
letter.
Question. Would that be Carolyn Huber who keeps the First Lady's
correspondence?
Answer. It more probably would be Pam Cecetti, Pamela Cecetti.
Ms. Comstock. I will make this Deposition Exhibit No. 28.
[Williams Deposition Exhibit No. MW-28 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. Are you aware of Mr. Chung having offices in D.C. for his
business?
Answer. No, I don't think I was.
Question. At any time did you learn of him having offices here in
Washington?
Answer. No, I don't think I knew he had offices in Washington.
Question. And this is DNC 1786472 through 81, which is a DNC
Presidential birthday celebration at the Sumner Wells estate, Fort
Washington, Maryland. The cochair for the events are identified as--
Johnny Chung is there with 10 guests, and then these records do
identify you as attending as one of the VIPs on page 1786479.
Do you recall attending the President's '94 birthday celebration?
Answer. This is when--I just have to figure this out. Somebody
really good was there. The long and short of it is I didn't get to go
because I was in a deposition that night, so I didn't go. I think Patti
LaBelle sang at that.
Question. Okay.
Answer. Right, Patti LaBelle.
Question. Good recall.
Answer. I remember that because I really wanted to go.
Question. I think the first WAVEs records that we have of Mr. Chung
were in July of '94, and I will get you a set of those.
Mr. Ballen. Can I take a minute break at this point?
[Brief recess.]
EXAMINATION BY MS. COMSTOCK:
Question. Back on the record here. We were just looking at the
WAVEs of Johnny Chung, and actually, I misspoke. I think the first WAVE
we have is February 2nd, '94. Do you have any recollection of--you say
you recalled meeting Mr. Chung outside of the White House early on. Do
you recall when you first had occasion to meet with him at the White
House or see him at the White House?
Answer. I don't remember the first occasion. I don't remember the
first time I saw him at the White House.
Question. Okay.
Answer. Although there was a first time, but I don't remember the
date.
Question. Okay. Prior to the March 8th and March 9th events, which
involved the $50,000 check in those events, do you recall having a
meeting with him prior to that date?
Answer. Seeing him, yes.
Question. Do you recall him ever coming by your office?
Answer. Yes.
Question. Prior to that date?
Answer. Yes.
Question. And what would be those occasions when he would come by
the office?
Answer. I don't think they were any particular occasions. I think
he was just dropping by to say hello.
Question. And do you know why he was at the White House and
dropping by?
Answer. Well, I don't know why he was dropping by. I mean, I had a
sense why he was dropping by our office; he liked to come to our office
because it was Mrs. Clinton's office.
Question. Were you aware of other people who he was stopping by and
talking to?
Answer. I really didn't pay any attention to it.
Question. I am just going to keep the WAVEs as a reference point as
we go through these other documents. This is an October 11, 1994,
letter to Reta Lewis from Johnny Chung. It says Reta Lewis, special
assistant in political affairs. Do you know Reta Lewis?
Answer. Yes, I do.
Question. In this letter, he talks about receiving a letter from
the President, and says: ``Due to my busy schedule, I was unable to
meet with you during my last trip,'' and goes on to discuss processes
setting up a Washington, D.C., office, ``This will allow us to work
closely together.''
Did you ever have occasion to talk with Reta Lewis about any
contact she had with Johnny Chung?
Answer. I think I once saw Reta with him. I don't think that we had
a conversation about Johnny Chung but I once saw Reta with him, and--I
once saw Reta with him in the hall.
Question. Just walking down the hall?
Answer. Yes, I am sure I stopped to talk and----
Question. This is at some point, obviously after you met Mr. Chung,
you knew who he was, he knew who you were?
Answer. I can't say when exactly. I mean, I think he knew who I
was. Just from our first meeting ever. So I would--this was definitely,
I believe, after that because I believe I met him sometime in 1993, but
I do remember seeing him with Reta.
Question. In the third paragraph, he says, I also want to inform
you that I am arranging a meeting for Chairman Y.C. Wang with President
Clinton. Chairman Wang will be arriving on the 15th of October and
staying approximately 2 weeks. I am discussing with Mr. David Wilhem
regarding the setup of this meeting.
Do you recall any efforts by Mr. Chung to get a meeting for Y.C.
Wang with the President?
Answer. No.
Question. Okay. Around this time, around the fall of '94, do you
remember any discussions with anybody in Political Affairs, Reta Lewis
or anybody else, about Mr. Chung's contacts with the White House?
Answer. No.
Question. Okay.
Answer. No.
Question. And prior to the March 8th, 9th, events, do you have any
recollection of discussing Mr. Chung with other people at the White
House prior to that time?
Answer. No. I wasn't--it wasn't a focus of anything. I would see
him around and he would definitely stop in to the office and sometimes
I would see him there, and--but he wasn't the focus of anybody's
conversation.
Question. And when he would stop by the office, what did he do when
he stopped by the office?
Answer. Well, I actually was in my interoffice most of the time,
but when I had seen him in the office, he would--we would change the
pictures or put knew pictures up of Mrs. Clinton in her travels. They
were all over the place. I mean, certainly not museum quality but there
were loads and loads of pictures of her trips and her events and he
would love to see the new pictures, and look at them and spend a great
deal of time looking at them.
He would then sit in the foyer of the office and he would talk to
Evan or talk to anyone who was out there. One time I heard him relating
to some interns the story of meeting Mrs. Clinton, which I think he did
quite a bit, and then he would--I believe that sometimes he waited for
me to come out of my office so he could say hello to me or whatever.
But he just liked coming there.
Question. Were you aware of him stopping by other offices, prior to
like March 8th and 9th? Were you aware--do you know how he had gotten
in there? I mean, did he sort of appear and you wondered how he got in
here, who let him in?
Answer. I never thought about it.
Question. Were you aware of--did there come a time he was coming
and asking your office to ask him to let him into the White House?
Answer. Oh, clearly, yes.
Question. And how did he go about doing that?
Answer. Generally, he would call Evan Ryan.
Question. And what did you tell Evan about him?
Answer. I said whenever Mr. Chung calls and he wants to come in, we
should let him in and we should treat him well.
Question. And why is that?
Answer. Because he was a human being and we had a very, I think,
was very focused on our office being available for people to come into,
although I don't know at what point. I also knew he was a managing
trustee at the DNC, so--but generally, every single person who came
through that office, whether they were a contributor or not was to be
accommodated, to be treated well, as well as people should bend over
backwards and they should tolerate people. As a public office, we kept
our office open, and if people got past the threshold of, say, the WAVE
security and were not a security threat, it was in fact a building that
belonged to people.
Question. Did you have a sense that Mr. Chung was coming in and
sort of, you know, wandering around to see people, stopping in your
office, he would get in and then kind of linger around?
Answer. To be quite frank with you, I never thought that much about
Johnny Chung or what he was doing or was that concerned. If a person
was not a security threat, I really wasn't focused on kind of what he
did once he was there.
Ms. Comstock. I would like to make this October 11, '94, letter
deposition Exhibit No. 29.
[Williams Deposition Exhibit No. MW-29 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. In this October 11th letter he talks about getting, I
guess, in the second to the last paragraph there, getting a political
report card from the DNC on economic achievement and how he is going to
broadly utilize this.
Did he ever have discussions about his interaction with the DNC or
anything like that when he was in your office?
Answer. About his interactions with the DNC, in general, no.
Mr. Dennis. I don't want to become witness in this, but I think it
may be important for you to know Room 100 is on the first floor of the
Old Executive Office Building. It is the only office that the door is
constantly open and you can walk that whole hallway around and every
door is shut, but that door is open, so that really people can just
walk right in, unannounced, without any particular, you know,
reservation or appointment or anything. It is set up more like a
Congressman's or Senator's office would be, to accept people,
constituent service, that sort of thing. So I wanted to give you the
feel for why someone could just come in and lounge a little bit more
than they might in one of the other offices.
EXAMINATION BY MS. COMSTOCK:
Question. Do you recall if Mr. Chung ever provided a reason when he
wanted to come over, what he said he was doing?
Answer. Rarely. To my knowledge, no, but I generally was on the--
not on the original request, and I mean, I generally would get Evan and
volunteer someone, either yelling into the office or buzzing me or
saying that Johnny Chung is outside the gates and he would like to come
and stop in the First Lady's office, and I would say, let him in, clear
him in.
Question. And do you recall if this was before or after the March 8
events or before--if you can place it in time.
Answer. I can't place it in time. I was somewhat interested when I
talked to Ed----
Mr. Dennis. Well, you can't describe that. Let me put on the record
that she has of course reviewed the WAVE records and--what she is
referring to is the fact it appears from the record we saw he was first
WAVE'd in by her office around March 8 or March 9, and prior to that it
seemed he was WAVE'd in by other offices, I am not sure if she was
aware of that, other than prior to looking at the records themselves,
but that is based on the records, not her recollection.
EXAMINATION BY MS. COMSTOCK:
Question. And then, actually, you know, given, I mean, the records
do reflect the first time he was waved in by your office is March 9th,
'95.
Do you have any knowledge of the people prior to that? You know,
when he would come by to your office, did he mention a meeting with
Brian Foucart or, you know, I came here for a Presidential event or
something or anything like that?
Answer. I didn't really have conversations with Johnny. I mean,
mostly, if he got me, it was because I was walking out the door and
going some place and I would pass him by and, of course, I would say
hello to him. But all of these offices, with the exception, obviously,
of those in the West Wing, these OEOB offices are in very close
proximity to our office, the Foucart offices is right underneath us.
Reta's office at this time was right on the same--down the corridor
from us.
Question. That is Reta Lewis?
Answer. Reta Lewis.
Question. Which is reflected on Page 3 of the documents, says
having WAVE'd him in on August 2nd, '94, which I believe is the day of
the birthday events, also.
Mr. Ballen. Just so the record is clear, the witness is reading
from the WAVE record. When you are referring to other offices, these
are ones you are referring to as you are reading them?
The Witness. Yes, that is correct. I'm sorry.
EXAMINATION BY MS. COMSTOCK:
Question. Maybe we can go through them and identify some of the
offices he had been visiting up to that time. You have Mr. Foucart. Do
you have any knowledge of Mr. Foucart talking to Mr. Chung?
Answer. No.
Question. Just tell us generally who Mr. Foucart was and what he
did at that time?
Answer. Boy, what did he do at that time. For some reason, I think
he was in administration at that point in time. The office right below
us is one of the administrative offices for the building.
Question. Do you know if he ever asked anyone in the administration
office about using his blast fax capability, if he talked to anyone at
the White House about that?
Answer. Oh, yes. I don't know who he talked to, but I remember
seeing him with Reta Lewis, and her describing his work as blast
faxing.
Question. So your recollection of Reta Lewis having at least--you
got the impression she discussed his blast fax with her?
Answer. Yes.
Question. And do you know--I guess the second page, EOP 7800, 7-22-
94 meeting----
Answer. I am not with you on this. Wait a minute, 8663.
Question. 8708 on top.
Answer. Oh, wait, I have a couple. Is this it?
Question. Yes.
Answer. Okay.
Question. The second page in that grouping, which is 8700. Do you
know who Anderson is--I'm sorry. You must have a bad copy. I will give
you this one instead. That one was missing that one page. That is what
happened.
Answer. Okay.
Question. Do you know an Anderson that was in Room 1 something,
115, or something like that?
Answer. No.
Question. Then it referred to Lewis. Is it Lewis here on the third
page at 8-29-94, Room 474? Would that have been Reta Lewis? She was on
the fourth floor at that time?
Answer. She is in the political office. Maybe her office, but the
main political office was on the first floor, down the hall from us, if
that is the Lewis.
Question. Okay. And then the third entry there, it says visitee is
POTUS, on the South Lawn, presumably an event, and Dickey is the person
who requested it.
Were you aware of any requests by somebody in the social office to
get Mr. Chung in?
Answer. It looks like--I mean, I don't know, but based on this
event in time, there was probably an event on the South Lawn and Robin
Dickey cleared huge numbers of people.
Question. Did you ever have any conversation with Robin Dickey? Did
she tell you anything about Mr. Chung trying to get into the White
House or White House events?
Answer. No.
Mr. Ballen. Can we ask the question whether the witness is aware if
any other offices scheduled meetings?
Ms. Comstock. I am asking her some of these people, if she might
know who they are. As we are reviewing this, she discussed Miss Lewis.
I am trying to identify some of the other people who Mr. Chung may have
been visiting at the White House.
EXAMINATION BY MS. COMSTOCK:
Question. Do you know someone named Atta?
Answer. No.
Question. Then on the next page, which is 8-7, it is hard to read
it, if that is 88 or 38, the second entry there is Quinn, requested by
Kelly.
Do you know of him ever meeting Jack Quinn?
Answer. I don't know.
Question. Okay. And then down at the bottom of the page is 9-26
entry, the visitee is Kristoff. Kristoff is the NSC office.
Do you recall if Mr. Chung ever, just a meeting, Sandra Kristoff?
Answer. I don't even know Sandra Kristoff. I don't know.
Mr. Ballen. Counsel, which entry are you referring to?
Ms. Comstock. The second to the last on the bottom.
Mr. Ballen. EOP 003738, that says John Huang visit.
Ms. Comstock. I'm sorry. I am looking at the wrong one. These are
mixed in here. I want to correct that for the record. That was not
Johnny Chung visiting Kristoff.
EXAMINATION BY MS. COMSTOCK:
Question. Okay. The next page, John Chung, if that is the same one,
is meeting with someone named S-H-A-K-O-W, Shakow.
Answer. I don't know who that person is.
Question. And the ones on the bottom.
And then the next page is 5041, is a meeting with somebody named E-
D-E-R, who waved him in.
Answer. I don't know who that is, either.
Question. Next entry there on the next page is W-O-Z-N-I-A-K,
WAVE'd him in and the visitee was Mitchell. Do you know who that is?
Answer. Not that I know.
Question. And then the last page of this group, which is 5040,
somebody Don, is that, who WAVE'd him in?
Answer. It looks like Don over here, too. I don't know who that is.
Question. Okay. Then there is a Brown in the next entry. The next
entry does say Jonathan Chung. I am presuming that that is a mistake
there.
Answer. I'm sorry, I don't----
Question. Next is 12-20-94, POTUS event, and the residents, do you
recall generally if Christmas time of '94, or thereabouts, if Mr. Chung
had been at any Christmas events at the White House or ever told you
about anything like that?
Answer. No, but it wouldn't surprise me. Those are huge, huge
things.
Question. I think there is going to be a lot of similar names here.
Don. Middleton. He has requested him in on January 1st, '95.
Do you know who Frank Footer is, January 10, '95?
Answer. I don't know that, no.
Mr. Ballen. Maybe it would be better to ask the witness.
Ms. Comstock. Yes, see if you recognize any on that page.
The Witness. Bailey.
EXAMINATION BY MS. COMSTOCK:
Question. Brian Bailey?
Answer. Brian Bailey.
Question. And deputy chief of staff office?
Answer. Yes, that is right.
Question. Okay. Which says, and this is getting us into the March 8
day so we might as well go into that area now.
Could you just describe, to the best of your recollection, the
events leading up to the receipt of Mr. Chung bringing the $50,000
check to the White House?
Answer. Yes. I think one of the things that Mr. Chung often asked
me when he would make his visit would be how can I give to the First
Lady, and how can I help her, how can I give to the First Lady, I can
give to the First Lady. And a number of occasions I had suggested to
him that instead he give to the DNC, that he could not give money to
the First Lady, he could not give money to the White House, but he
could give money to the DNC. I don't recall if I have told him that he
could give money to the legal defense fund, but those were the--
whenever anyone asked me where they could give money, I would say, you
need to contact the DNC, the President's legal defense fund, and I
think at some point when the campaign started, I would say Clinton/
Gore.
So he asked me, I do not know the dates of this, because I see them
actually all as kind of separate, separate occasions, but at some point
in time, I was, I believe, leaving the office and coming out into the
vestibule, at which point Mr. Chung enthusiastically said, I give to
the First Lady, I give to the First Lady. I said something to the
effect of, Johnny, I have told you that you cannot give money to the
First Lady, you can give to the DNC, and I believe I told him that
again and he said, I am giving to the DNC, I am giving through you, I
give through you, I give through the First Lady's office. I told him
again that he should just give it to the DNC. He continued to be
somewhat insistent. I wanted out. I said, you know, I will take it, I
will give it to the DNC, and I think our encounter was, I don't even
know if it was a minute or a minute and a half.
Question. And that is all you recall about that?
Answer. That is all I recall about that actual check giving.
Question. Do you recall the events leading up to that or Mr. Chung
wanting to get his friends into the White House, visitors visiting from
China that he wanted to have?
Answer. Well, let me tell you what I remember. I don't remember him
wanting to get his friends into the White House on that particular day.
As I said, I see these all as separate incidents, even though the paper
now reports them as all together. I know at some point in time I was
asked probably by Evan to arrange a photo for Mr. Chung, or if she
could, and I said, yes, that she should, and I also remember on a
couple of different occasions, where Mr. Chung had asked to go to the
White House Mess, and Evan had asked me, and I had said, yes,
accommodate him, use my Mess account.
Question. So Mr. Chung had used your Mess account?
Answer. Yes.
Question. Prior to the time when you received this check from him?
Answer. Yes, I believe so, yes.
Question. And he had brought friends with him to visit the White
House?
Answer. I don't know who he brought with him, but I know that I had
okayed him using my Mess account.
Question. Do you know generally when?
Answer. No.
Question. Have you been able to review any documents from your
mess--from mess records or any accounts or anything like that?
Answer. Well, those that I still have, but I can't--I mean, I just
don't know. But I do know that there was--at some point before that
he'd used my White House mess account.
Question. And on the mess account you got the bill either every
other week or----
Answer. Every month or something.
Question. Do you know who sent that bill out?
Answer. The White House Mess.
Question. Does that come out of Gary Walter's office or is that
separate?
Answer. No, that's a whole other--different.
Question. Somebody sets that up and sends it out?
Answer. Yes, it is totally different.
Question. And you have maintained those records or you have some of
them? You don't know what you have? Or----
Answer. No, I mean, I pretty much--I mean, once I paid them, I
never thought about them again.
Question. But prior to this telling Mr. Chung, presented you with a
check, he had--your recollection is that he had used your mess account
for whatever reason?
Answer. Yes.
Question. And you did not--were you aware of who he brought into
the White House with him?
Answer. No. I do remember--just another in the series of kind of
events is that I do remember at one point bowing to a group of people
who could not speak English, and I could not speak Chinese, and I
remember them being out in a hall. I don't know the time, but they were
with Mr. Chung, and he presented them to me and me to them, and we all
bowed. And I do remember that because it stood out in my mind as----
Question. Uh-huh. Okay. And, again, can you place that in time
before or after that check or contemporaneously or if his friends were
with him on that day?
Answer. I really don't know. I mean, I just kind of all--I mean, I
all saw them as separate events.
Question. Okay. Well, leading up to the time when he----
This is a document from DNC 3233326, February 27th, 1995, letter to
Richard Sullivan from Johnny Chung. Have you seen this before?
Answer. No, I have not.
Question. Okay. In this later he's requesting that Mr. Sullivan--he
tells him he's bringing a delegation from China and, as I have
mentioned on the phone, their main purpose will be as follows: One,
meet President Clinton; two, meet Vice President Gore; three, have
lunch at the mess; four, tour the White House; five, meet Secretary Ron
Brown.
Were you aware of any such requests coming from anyone at the DNC
offices leading up to the March 8th and 9th--actually, can you place in
time--if we could go back to--you're saying you remember him, Mr.
Chung, being there one day and wanting to give you a check.
Answer. Uh-huh.
Question. Do you have a general recollection of when it is? Do you
have a date or time frame?
Answer. Only what I've, you know, read. I really don't--I really
don't have a sense of the time. I mean, I know there was a time that he
gave me a check. I know that there was a point in time that I bowed to
him and Chinese people. I know there was a point in time that--that
someone asked me, I believe Evelyn, to get a picture. And I also--my
recollection is that he had gone to the mess on my account at another
time or at least one other time or two other times. But that wasn't the
first time I'd heard about Johnny Chung wanting to use the mess.
Question. Okay. And do you recall, leading up to him coming in and
wanting to give the check, did he--had Ms. Ryan asked you, you know,
anything about him being able to get access to the mess privileges or
if he could get a picture with the First Lady or the President or
anything like that? Or any of these items--tour the White House or
anything like that?
Answer. Well, I--I mean prior to him bringing that check, it seems
to me that we would have accommodated him and probably had at the mess
or if he'd asked for a tour of the White House or that he'd had other
pictures. So that with the exception of probably, on this list, meeting
the President--I don't know if he met Al Gore or if he met Secretary
Brown. I mean, seems to me that prior to 1995, Johnny Chung had pretty
much done all of this anyway, at least a couple of times. I mean, that
was my--my recollection.
Question. Okay. Did you ever see any--the names that are attached
here to the delegation or any descriptions of these people? Did anybody
ever provide with you any information like that?
Answer. I don't remember seeing--I mean, I don't know if I saw
these names in a newspaper or whatever. For some reason, I think I know
the people who came. I mean, maybe it's because they gave me card when
they bowed, because they did give me a card. So seems like I remember
this Sun guy was in the delegation. He seemed really young. I mean, but
I don't--I don't remember getting this list of these people.
Question. Prior to getting the check from Mr. Chung, do you recall
any conversations with Ryan about the day--about a particular day or
the day before or close in time to when you got the money--of Evan Ryan
telling you anything about this delegation that he wanted to bring and
how big at the White House?
Answer. I don't remember--like I said, I don't remember the
delegation. And, once again, I don't see these all as events.
I do remember that Evan would ask me about clearing in Johnny
Chung. I have a recollection that Evan asked me about using the mess
account, I think on more than one occasion, for Johnny Chung. And I do
have a recollection that Evan, at one point, asked me about a picture
with Mrs. Clinton for Johnny Chung.
I remember all of those things. I don't see them as occurring all
at once; and some, I think, happened prior to the time that he brought
the check.
Mr. Ballen. Can I ask you so it is clear, you said he brought the
check. Did he give you an envelope? Did he give you a check? Did he say
what was inside? Did you see what was inside?
The Witness. I knew that when he handed it to me it was a check. I
don't know if it was in an envelope or whatever.
Mr. Ballen. How did you know it was a check?
The Witness. Because he kept saying--he had something in his hand.
He said, I give to the--I give to Mrs. Clinton. I give to Mrs. Clinton.
And it was the first time he ever had anything in his hand. He was
always saying, I want to give. I give to Mrs. Clinton. I give to Mrs.
Clinton.
And then I said--I mean, I had a realization at some point it was a
check because I said, you cannot give to Mrs. Clinton, at which point
he said, I'm giving to the DNC. I gives--I remember this. It was such
an awkward construction--I give through you. I give through the First
Lady's office.
And, you know, and at that point I just--I mean, you know, that it
was a check for the DNC, that he had somehow--I don't remember his
exact words, but he had somehow made clear to me that it was a check
for the DNC; and, at that point, I thought, okay, I'll give it to the
DNC.
Mr. Ballen. Did you look at it or open it?
The Witness. It's funny. I think that I--I don't remember looking
at it, but I had a sense that it was a $10,000 check. But I don't know
why I had the sense, but I thought for some reason it was a $10,000
check. I--I was surprised to learn it was $50,000, which I learned kind
of around a news inquiry much later.
EXAMINATION BY MS. COMSTOCK:
Question. But that's the first time you learned how much money was
in it?
Answer. Right, uh-huh.
Question. And what did you do with the check after you received it?
Answer. I think I just put it in my basket, in my out basket, as I
had done with--you know, we would get checks that came in the mail that
would be, you know, for Clinton-Gore, for something that didn't belong.
It would come in the mail addressed to Mrs. Clinton. I would just put
them in the basket; and I assumed that Evan or, you know, whoever,
whoever took out my basket of things would get the check to wherever it
needed to go.
Question. It was a basket that was designed for things to go to the
DNC?
Answer. No, it was my out basket.
Question. And it was in an envelope at that point?
Answer. I really don't remember if it was.
Question. That's the last--you put it in your basket, and that's
the last you saw of it?
Answer. I never thought about it again.
Question. And nobody asked you, what am I supposed to do with this?
Answer. Well, we had received other checks through the mail. Not
just for the DNC. There would be checks that would come saying we need
to pay off the--take this check and pay off the deficit or give this
check to Mrs. Clinton. I want her to have it to do--I would put--if
they got to me, and some did, I would put them, just as a matter of
routine, in my basket. And Evan or someone would either send it, if it
was for the DNC, send it back to correspondence if the check had to be
returned to someone who was trying to give a check to Mrs. Clinton.
So that--or you got checks that were made out to the Treasurer, and
they wanted Mrs. Clinton to give it for the reduction of the deficit.
We would send it over to the U.S. Treasurer.
So that checks that had come before, I would just put them in the
basket and, you know, just assume they would get to the right place.
Question. Was this--you had said that, you know, that he said, I
want to give to the First Lady. Was this the first time he had said
that kind of thing?
Answer. No, well, no, every time I saw him. Every time I had a
chance encounter with him, he wanted to give to the First Lady.
Question. Did you ever mention anything to him about any bills
from--regarding Christmas parties?
Answer. No, I don't recall that.
Question. Do you have any knowledge of anybody in the office--in
your office or anyone at the White House ever mentioning anything about
DNC bills for Christmas parties?
Answer. To him?
Question. To Mr. Chung.
Answer. No, not that I'm aware of.
Question. Previously, we have been looking at Mr. Middleton's WAVEs
records. It appeared you know, when he came into the mess that he had
been WAVE'd in by someone from your office, that Mr. Chung was not
WAVE'd in by anybody from your office prior to March 9th. Do you know
how, if he had used the mess privileges prior to this time, how that
came about? If it was done through your office or if it was coordinated
with somebody else?
Answer. I don't. I don't know. I mean, that's--I indicated I was
surprised this was the first time that we had waved in him, since I'd
seen him so often before in the White House.
Question. You have specific recollections that you had seen him--
that you thought--that he had been in there in your office prior to
March 8th?
Answer. Uh-huh.
Question. This wasn't the----
Answer. The first time that Johnny Chung had ever been in our
office? No, no.
Question. And did you ever have--as you turn to the Sullivan letter
from Mr. Chung, you never had any contact with anyone from the DNC
about Johnny Chung?
Answer. No.
Question. At any time?
Answer. No.
Ms. Comstock. We'll make this letter Deposition Exhibit No. 30.
[Williams Deposition Exhibit No. MW-30 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. This is a February 28th, 1995, letter--I'm sorry. The
Bates Stamp Number is JCH 15011; and the previous one, the Bates Stamp
Number was DNC 3233326.
This letter was to Ann McCoy; said, I would like to request your
assistance again. I am bringing with me the delegation from China. This
is a group of very important and powerful business leaders from China.
They will be in D.C. from March 7th to 11th, and as usual, please
arrange for a tour of the White House.
Do you have any knowledge of Ann McCoy assisting Mr. Chung?
Answer. Yes. Worked in the visitor's office, and she often gave
tours to family or, you know, anyone who had missed the tour had to
come in the day or whatever, so she was always giving tours.
Mr. Dennis. Do you recall this specific----
The Witness. This letter? No. Oh, no, I've never seen that letter
before, but I know Ann McCoy.
Mr. Ballen. Or that she had given Johnny Chung a tour--that was the
question.
The Witness. Yeah, I think I do recall Ann giving Johnny Chung a
tour.
EXAMINATION BY MS. COMSTOCK:
Question. And how do you recall that?
Answer. For some reason I think that she had--she told me that. Or
asked me if I knew a Mr. Chung or did I know about him. I--I'm pretty
sure I had a conversation with her, and she had given him a tour or
maybe more than once, even.
Question. And what had she told you about him?
Answer. Oh, kind of just that he was a funny sort of man, but, you
know, loved walking around the White House, and asked me if I knew him,
and I said, yes, that I knew him, and I thought he was a good guy.
Question. Okay. Ann McCoy--the document we have been discussing
earlier today, May 5th, 1994, list which had listed various perks.
The Witness. I think this is what you----
EXAMINATION BY MS. COMSTOCK:
Question. Yeah, I'm sorry. I was thinking of Ann Stock on here,
because Ann McCoy's name is not on here. I wonder, do you know what--
that was just her--she would arrange for the visitors?
Answer. Yeah, the visitors office.
Question. Basic tours?
Answer. Not just basics.
Question. This was a different tour than the people--this is the
tour that you--go-to-the-head-of-the-line kind of tour, see a little
bit more?
Answer. Yeah, there's at least seven or eight different
formulations of tours, and the Ann McCoy kind of walk-around is one of
them.
Question. And now, in some of the news accounts have shown, you
know, Mr. Chung sort of all over the White House. Do you know who was
bringing him all over the White House in different hallways and in the
mess and in the kitchen or wherever?
Answer. In the kitchen?
Question. I don't think he was in the kitchen, I think it was in
the mess, but he was in a lot of different spots. Were those
photographers going around on the tour with him? Do you know if he had
his own photographer with him as he went on the tour and took those
pictures? Can you do that?
Answer. I'd have to see the pictures. The only picture that I've
seen in the press is a Christmas picture. And if it's in the hallway it
more than likely is part of a large receiving line, because that's how
they're generally done. So if it is in a hallway or in a room in front
of a picture or a tree or something like that, it's probably a
receiving line.
Question. Okay. Then this February 28th letter continues, ``I have
asked Mr. Richard Sullivan, Mr. Eric''--small ``L'' there ``led''--I
don't know if that's correct--``of DNC and Mr. Mark Middleton to assist
me in arranging a meeting with President Clinton, Vice President Al
Gore, and a lunch at the Mess in the White House.''
Do you have a recollection of Mark Middleton assisting Johnny Chung
at the White House?
Answer. No. No, I didn't know he knew him.
Question. You had no knowledge of Mr. Middleton knowing Johnny
Chung?
Answer. No.
Question. Are you sure then that Mr. Middleton didn't ask you to
ask help Mr. Chung in any way?
Answer. Oh, no. Mr. Middleton wouldn't have to ask me to help Mr.
Chung. I mean, I would have helped Mr. Chung on my own.
Question. I mean, Mr. Middleton never asked you or said----
Answer. No.
Question [continuing]. Johnny Chung called me up?
Answer. No.
Question. February 28th, '95, I believe Mr. Middleton had left the
White House at this point?
Answer. No.
Question. Did he ever call you up and say, hey, Johnny Chung is
asking me to get him into the mess----
Answer. No.
Question [continuing]. Can he go on your account since I'm not
there anymore?
Answer. No, no.
Question. Nothing like that?
Answer. No. Huh-uh.
Question. And do you have any knowledge of--this time frame that
he's working on was the March 7th to March 11th time frame when Mr.
Chung is writing to Ann McCoy asking for assistance?
Answer. Uh-huh.
Question. But it was the time frame when he ends up arriving at the
White House with the $50,000 check----
Answer. Uh-huh.
Question [continuing]. And--and then also having lunch at the mess
with his five friends from China.
So do you know how he ended up asking Ms. McCoy about help with
this to coming to your office? What happened in the interim, if you
have any knowledge?
Answer. No, I mean, what happened in the interim--which interim?
Question. Well, he's asking here Ms. McCoy whether or not she can
assist with lunch in the mess.
Answer. Uh-huh.
Question. And then, later in March, he is asking your office to
help him with that.
Answer. Oh, no, I wasn't aware that he had asked Ann McCoy.
Question. Do you know if he was turned away or, sorry, we'll give
you the tour, but that's the best we can do?
Answer. No, I don't know. Huh-uh.
Question. Now, just so I can get this clear, you say you recall
these as separate events so you don't recall him in this time frame. Do
you recall him in this time frame, when he gave you the check, having
his friends there to go to lunch or for a picture or for any event
contacted with his friends?
Answer. See I saw them all as separate events in my head. I see
them all, each, as separate. I didn't put them all together. I saw the
check as a separate thing that happened. I remember meeting his
friends, but I did not tie them together. I just remember them as
individual events. It may or may not be that, but that's the way I
remember them.
Question. Do you have any recollection of Evan Ryan discussing with
you anything about that he wanted this group to be able to come to the
mess and get their picture with the First Lady and all, and he wanted
to know what he could do to help the White House or anything like that?
Answer. No, I mean--as I said before, I recall that if there was a
time that Mr. Chung made a request, he would make it to Evan, and she
would ask me about it. I know that she asked me about getting him in
the mess and getting a picture with Mrs. Clinton, both of which, you
know, I tried to accommodate. But not in relationship to his check or
contribution. I mean, he'd been in lots of times before. He had lots of
pictures before; and he was already a managing trustee, which meant he
was a contributor.
Question. And you had recalled the time before when he had come in
and used your mess privileges before. Did he pay you back or----
Answer. No, I don't--I don't recall him--you mean pay me back for
the mess?
Question. Yes.
Answer. Like I said before, I never thought about it. I don't
recall him paying me back, no. Like I said, unless Evan got a check
from him, he didn't pay me back.
Question. Do you recall ever saying anything to Evan Ryan about the
check from Mr. Chung in any way going towards the DNC Christmas party
debts?
Answer. No, I don't.
Question. Do you have any recollection of saying to anyone in your
office anything about what Mr. Chung's money would be used for?
Answer. No.
Question. Did you have any idea in your mind what the money that
he'd donated would be designated to or for?
Answer. I would have no way of knowing. I mean, there would be no
way of designating money at the DNC.
Ms. Comstock. We will mark this February 28 Ann McCoy letter,
JCH15011, Deposition Exhibit No. 31.
[Williams Deposition Exhibit No. MW-31 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. Okay. Have you talked with Ms. Ryan about her
recollection of these events?
Answer. No, I have not.
Question. Has anyone described to you in any way her recollection
of these events? Has anyone else told you what her recollection of the
events is?
Mr. Dennis. Ms. Williams has had discussions with me, but those
discussion----
EXAMINATION BY MS. COMSTOCK:
Question. Aside from your attorneys?
Answer. No.
Question. Aside from you remember bowing to a group of people that
Mr. Chung was with, was that only on one occasion that you recall him
welcome a group of people?
Answer. Uh-huh.
Question. You saw them out in the hall somewhere?
Answer. Yes, near my office.
Question. Did you have an understanding of what they were doing
there at that time?
Answer. No, I just thought they were exactly as he described them,
friends of Mr. Chung.
Question. And did he tell you that they were friends, business
associates from China?
Answer. Yes, he told me they were from China. That's right.
Question. And they couldn't speak English?
Answer. Right.
Question. Did you have an understanding that they were foreign
friends?
Answer. That was my understanding, yes.
Question. And did you have an understanding that they were at lunch
at the mess that day that you saw them--or had been?
Answer. I don't know if I thought anything about what they were
doing. I just think I--I mean, I just think I saw them in the hall, saw
Johnny Chung, bowed and went wherever I was on my way to.
Question. And when is the next time you recall having any
interaction with Mr. Chung after you got the--actually, can you place
the time where this bowing and meeting his friends, whether it was
before or after the receiving the check?
Answer. I just don't--I don't know.
Question. And do you have any knowledge about them having a picture
taken with the First Lady, that group of people that you thought
couldn't speak English?
Answer. I don't know. Like I said, I know that I arranged for a
picture with Mr. Chung. I don't know who he took with him, if anyone.
Question. Can you place in time when you arranged this picture in
terms of just in relation to when you received money from Mr. Chung?
Answer. No, I'm sorry.
Question. Would you know if it is a year apart or----
Answer. Oh, I just don't--I just don't know in time. I mean,
there's so many--there's so many pictures I've arranged for so many, I
just could not--I can't place it.
Question. To your knowledge, Mr. Chung then did have somebody who--
he had his picture taken with the First Lady and then whoever else was
with him. You just know about him having his picture taken; is that
right?
Answer. I was asked to arrange a picture for Johnny Chung. I
believe that's what Evan asked me, and I said arrange it.
Question. Was it your understanding that Evan then arranged the
picture?
Answer. That would generally be my understanding, that Evan would
arrange it.
Question. And then--did you learn then that that did occur then?
That they went ahead and arranged----
Answer. Probably never thought about it again.
Question. And then did you ever have an occasion to have Mr. Chung
call and ask for his pictures from the First Lady or anything?
Answer. I don't believe he called and asked for his pictures from
the First Lady. I think he probably would have called Evan for his
pictures with the First Lady. I think the way the photographers may do
it is that they take a card after they take the picture and mark the
date and then send them out. I don't know quite--or send them to our
office, one of our offices, saying, you know, attached to the card and
we might send it out. I don't know how he got his pictures with the
First Lady.
Question. Do you know if there was ever any issues about don't send
the pictures out with the First Lady and Mr. Chung's friends if there
had ever been an issue of the pictures that she had taken with Mr.
Chung's friends?
Answer. No, I believe that there was, as I learned in my
deposition, that there was an issue about sending Mr. Chung's picture
with the President out, I think.
Question. Okay. But in regards to the First Lady, have you ever--
was there ever any discussion about that?
Answer. I don't believe so, no.
Question. Is that a process that ever happens in the First Lady's
office, don't send----
Answer. Rarely. Rarely. I mean I can't think of an occasion. Unless
she looks really awful in the picture, I can't think of why really we
wouldn't send a picture to people who had had them taken.
Question. Or if you find out after the fact that it's Jorge
Cabrerra, that's a drug dealer, with you and somebody says don't send
that picture out, we didn't know he was a drug dealer when he came in?
Answer. That would be a determination that we would make, but I
can't imagine that we would have made that determination with Mr.
Chung, he had had so many pictures before.
Mr. Dennis. And that's with the understanding that this all is
hypothetical, right?
Ms. Comstock. Right. I think Mr. Cabrerra had his picture taken
with someone, but I have no idea. I think it was the Vice President. I
don't know if he had a First Lady picture. I'm just generally talking
about--putting that in a hypothetical.
The Witness. I understand.
EXAMINATION BY MS. COMSTOCK:
Question. These are the copies of pictures that we received from
the White House with the----
Answer. With the people who----
Question [continuing]. The people who Mr. Chung brought to the
White House on March 9th. And I will note for the record there aren't
any dates on these pictures. But generally these are the ones, the
names. And the names that are on these pictures, a number of them
coincide with the people he had listed on his name list of delegation
in the February 27th, '95 letter that he had sent.
I am not good at pronouncing these names. I just notice the first
name on the name list of delegation on DNC 3233327 is the name of the
person in the picture that's reflected on EOP 029612. And----
Mr. Ballen. Is there a question for the witness about this?
EXAMINATION BY MS. COMSTOCK:
Question. Well, I just wanted to sort of establish that these were
the same people, so I'm not asking you in a vacuum. I think Wang Ren-
Zhong, who is the last picture in this group, EOP 129165 is represented
as number 4 here on his name list of delegation. The third picture,
Huang Jichun, J-I-C-H-U-N, is also on the list as number 3 on the name
list of delegation, and then there's a second page, EOP 029613 has a
Yan Sanzhong, and I don't know if that--I don't see that exact spelling
there. I don't know if that is any different spelling on one of these
names on here. They often have different--sometimes there's different
spellings, like when we talked about Mr. Ng Lap Seng before, he goes by
Mr. Wu also.
But three of the names do line up with the people that he had
wanted to bring. And I was wondering if that refreshes your
recollection in terms of in connection with this donation and giving to
him, you know telling you about his friends that he wanted to bring and
who they were, and you know, why they wanted to have their picture with
the First Lady, if that helps you in being able to place these things
in time at all?
Answer. No, in my mind, the check that he gave had nothing to do
with the picture or the mess or the tour, because we had a history of
doing these things for him anyway.
Question. So there were from previous events he had had pictures at
Christmas events and things of that sort?
Answer. He'd had tours, he'd eaten in the mess. I mean, there--and
they seem unrelated to it.
Ms. Comstock. I'd like to make these pictures Deposition Exhibit
Number 32.
[Williams Deposition Exhibit No. MW-32 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. Did Mr. Chung ever invite you or anyone else in the White
House to your knowledge on any trips to China?
Answer. Invite us to China? He was always inviting us to China.
Question. And what did he----
Answer. Just, come, I will show you China.
Question. Did he ask you, if he was able to take you on trips or
take you--take people from the White House, pay for their trips to
China or do anything like that?
Answer. No, huh-uh.
Question. Was he ever giving you any gifts or providing any things
for you to your office?
Answer. He brought to our office three sweaters.
Question. And who were those for?
Answer. The President, Mrs. Clinton, Chelsea and I think he brought
a sweater for me. But we did what we normally do, just turned it all
over to the gift unit.
Question. Okay. I will show the witness EOP 63825. And directing
your attention to 63829 in this grouping.
Answer. 63----
Question. 829. Would these be the--these reflect--63831 and 32
reflect donor information with a gift intended for the President from
Johnny Chung and the First Lady from Johnny Chung, and the date is
March 9th, 1995, the same day reportedly the check was provided?
Answer. Uh-huh.
Question. Do you recall him giving you the sweaters and the check
at the same time?
Answer. No, no.
Question. And this indicates that these sweaters were handed to
Margaret Williams?
Answer. No, I remember that.
Question. You remember the sweaters?
Answer. I do remember the sweaters.
Question. But you don't remember the sweaters occurring on the same
day as the check?
Answer. No.
Question. Okay. And then could you just describe the process that
you go through on the gifts? That is reflected here in this group of
documents?
Answer. I would hand them to Evan and she or an intern or a
volunteer would fill out a gift form. There's a gift form that offices
have. And then they would send it up to the--or wherever it is, the
White House gift unit. The White House gift unit would then take them
and send out a thank you note. And then they--I don't know quite how
they do it, but they dispose of the gifts in some way. I don't know
what they do with them.
Question. Okay. And do you know what you did with your sweater?
Answer. No, I gave--everything I had I gave to them. Even staff.
Staff gifts----
Question. We didn't--these are part of the documents we just
received last night, so the only two we have or have been able to
locate, and since we haven't--we've only had them since last night we
got this donor information for the President and the First Lady?
Answer. We received one for Chelsea.
Question. And then one for you?
Answer. Yeah, I'm pretty sure that was it. But even staff gifts go
straight to the gift unit.
Question. Okay.
Question. And then the 63829 document, which has a thank you note
to Mr. Chung, do you know whose handwriting is reflected on that?
Answer. No, but it looks like it says gift unit draft. It's whoever
works in the gift unit.
Question. So they would just write the thank you letters?
Answer. They would take care of the letter and everything, yeah.
Question. And would those be signed by the President then?
Answer. Well, yeah, this--this reads gift unit draft of Bill
Clinton letter.
Question. Okay. And so----
Answer. Uh-huh.
Question [continuing]. Do you know if you wrote any note to Mr.
Chung after receiving the sweater?
Answer. No, no, I didn't. They handle all of this.
Mr. Ballen. When you say signed by the President, would it be
signed by an auto pen?
The Witness. Auto pen.
Mr. Ballen. It's not something that the President would sign
personally?
The Witness. No, auto pen.
EXAMINATION BY MS. COMSTOCK:
Question. EOP 063828, the page before that, is the letter that goes
out to Mr. Chung from the President signed by the auto pen or however?
Answer. Right.
Question. And then there's a cc on here. Is that you got cc'd on
these so that you knew? Is that the process?
Answer. Right. It's just that if they were handed to me, or
whomever, they would cc, so that you knew that the--a letter had gone
out.
Question. Okay. And then the page previous to that, EOP 63827, a
March 12th, '95, there's gift of a large heart-shaped piece of jade
with stand, which apparently was presented during the radio address.
Did you learn about that?
Answer. No, I wasn't there.
Question. And do you know any of the handwriting on this sheet or
is this from the gift office?
Answer. This looks just like the gift register.
Question. None of that handwriting is anybody from your office that
you know of?
Answer. Huh-uh.
Question. Okay. And the first page of this EOP 63825. It says per
Betty. Do you know, there's a Betty Currie in the President's office.
Do you know was she the person who would ordinarily handle sort of
these gifts if they were presented directly to the President?
Answer. Yeah, I imagine so. I mean I don't know. She's in that
office though. I don't know if she has assigned any work.
Question. Do you know whose handwriting this is on this note?
Answer. No.
Question. It indicates Johnny Chung's friends presented this on his
behalf when they visited with the radio address. And it says they don't
know the friends' names?
Answer. Right.
Question. Did anyone ever come back to you after the radio address
and say who were those guys with the President, we need to write a
letter and find out who they are?
Answer. No, no.
Ms. Comstock. We'll make that Deposition Exhibit Number 33.
[Williams Deposition Exhibit No. MW-33 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. Now, you had indicated the letter--the pictures with the
First Lady that we reviewed, those generally would just go out when
they came back in and you had no knowledge of in this case them being
held up in any way or any issues that arose about them?
Answer. The only--as I said before, the only issue I think there
was was about the President's pictures with them at the radio address.
Question. And your testimony is that you only learned of that in
the press accounts this year or did you--at the time did you learn that
there were any issues with the NSC holding up pictures with the
President?
Answer. Yeah, yeah, I think I knew about it at the time.
Question. Oh, could you tell us about that?
Answer. Just that I--just that I knew about it. I mean, I couldn't
be helpful. I only knew that they were held up. Somebody called me from
the NSC.
Question. And what did they ask you about?
Answer. I don't know if someone called me or I called somebody.
Think Johnny Chung asked me to get--he hadn't received pictures from
the radio address that he had attended.
Question. Okay. What did he tell about that?
Answer. I don't know. Just that he hadn't gotten them.
Question. Did he tell you who--you know, who had----
Answer. I don't remember.
Question. Did he just complain, you know, where are my pictures?
Answer. Yeah, pretty standard.
Question. Were you aware of him calling the office and asking for
the pictures?
Answer. I don't know. For some reason I have a sense that he--I
mean there's something about him not getting his pictures, the pictures
from the President.
Question. And you remember personally talking with him about that?
Answer. I don't know if a person talked to him about it.
Question. No, do you remember talking to him about the pictures?
Answer. I don't know if I talked to him about it or someone told me
about it. I mean, I could have talked to him, I don't know.
Question. This is some phone messages from April of '95. The first
one is April 3rd to Evan from Johnny Chung. It says re: pictures?
Answer. Uh-huh. Excuse me.
Question. Actually he called for Gina, who wasn't here, and then he
asked for you. Can you tell us who Gina is?
Answer. Yeah, she was an intern of ours.
Question. And did she deal with Mr. Chung?
Answer. Oh, yes, uh-huh.
Question. And what can you tell us about Gina's interactions with
Johnny Chung?
Answer. Well, she was there during the periods he was popping in,
and he also offered her a job which she took for a short time in China.
I think China.
Question. Is that Gina Ratliffe, is that her name?
Answer. I don't know her last name.
Question. And your recollection is that she took a job with him in
China?
Answer. I think it was in China or that she was definitely going to
China or maybe that she started out in California.
Question. Do you have a knowledge about her working in the office
in D.C. here for him?
Answer. No, I don't remember that. But I know that she worked for
him. I don't know where he worked. I didn't know there was an office in
D.C.
Question. Do you recall when she worked for him?
Answer. No.
Question. Now in this memo, this phone message of April 3rd, 1995,
indicates that he called for Gina. Presumably she's still there at that
time?
Answer. Yeah, I don't know.
Question. Do you know generally if it was '95 or '96 when she left
to work for him?
Answer. I--I have no idea.
Question. And do you know what she was going to be doing for Mr.
Chung?
Answer. No, I have no idea.
Question. Did you talk with her at all about going to work for Mr.
Chung?
Answer. I definitely encouraged her to talk to her--I think her
mother about it before making such a move, but she seemed very
enthusiastic about it.
Question. And how old was she, if you recall generally?
Answer. I don't know.
Question. In her 20's?
Answer. Uh-huh.
Question. Young gal?
Answer. Uh-huh.
Question. And do you know where she is today?
Answer. No.
Question. Do you have any idea what happened to her after she
worked for Mr. Chung?
Answer. I don't think she kept working for him.
Question. Do you know what happened with that job?
Answer. I know she left. She complained that he did not pay her.
Question. At all?
Answer. I don't know at all, but didn't pay her some money.
Question. Okay. Did you think that was strange?
Answer. I thought it was awful.
Question. Did you ever talk with him about it?
Answer. Oh, yeah.
Question. And what.
Mr. Ballen. To who about it?
The Witness. Ever talk to Mr. Chung about it? Yes.
EXAMINATION BY MS. COMSTOCK:
Question. And what were your discussions?
Answer. It was just that if he owed her money, he should pay her
because it was the right thing to do. And I was very unhappy. And I
said I'm very unhappy about this, you know, something, too, like I
thought much more of you. If you owe her money, you should pay her.
Question. Can you recall generally when this conversation occurred?
Answer. No.
Question. Was it--presumably it was some time after April 3rd, '95,
if----
Answer. Could be. I don't know. Whenever she told me, and I don't
know if she told me or Evan told me. But, you know, I knew and the next
time I saw Johnny Chung, you know, I told him that this was not the way
to operate.
Question. And what was his response?
Answer. I think I maybe petrified him a little bit.
Question. Why so?
Answer. Because I was--you know, I think that he was much more used
to a kinder, gentler Maggie, but I was very unhappy if he had
mistreated her, and I said that's just the wrong thing to do. That's
not a fair thing to do, you know, I would expect so much more of you.
Question. And what did he say?
Answer. I'm sure it ended up with him saying he was going to pay
her.
Question. And do you know if he did in fact do that?
Answer. I believe that he did, because I didn't hear any more from
Evan about it or Gina and I would have heard something else from Evan,
I imagine.
Question. Do you know, did you just run into him at the White House
somewhere, or how this occurred, this conversation, this situation?
Answer. I think he was on one of his visits, one of his pop-in
visits.
Question. Now at this time, you were aware that he was a managing
trustee, right?
Answer. Uh-huh.
Question. Did you find it strange that he wasn't paying his
employees, someone who was giving large amounts to the DNC but won't
pay his employees?
Answer. No, that was really not the connection that I made. I mean
at that moment, him being a managing trustee had very little to do with
my disappointment in him.
Question. No, but in the sense that he--a managing trustee
generally is someone who presumably has some means and money. Would
that be a fair assumption? Or is that how you would think of someone,
that they are not someone who is scraping by?
Answer. I did not have any thoughts, quite frankly, about him being
a managing trustee or if he could pay her or not pay her. For me the
issue was very simple. If he had had only two sticks to rub together,
if he had promised to pay her, the fair thing to do was to pay her,
whoever he was.
Question. You said--I'm sorry, the word you used was--he was used
to a kinder, gentler Maggie?
Answer. Yeah, I think he was kind of a little bit startled, but I
just felt it was not a good thing to treat a young person unfairly.
Question. And so you don't know what happened after that with Gina?
Answer. I believe I would have heard if I had not been successful
in making my point to him.
Question. So that as a result of your talking to him, that Gina got
paid?
Answer. I cannot say directly, but I can say I do not think it
hurt.
Question. Did you mention to anybody else that he hadn't been
paying Gina?
Answer. No, I didn't think that it needed to go beyond that. I'd
spoken to him, and if the matter was resolved, which I assumed it was
or I would hear it differently, it was over.
Question. Do you know how much she was supposed to be paid?
Answer. No, I didn't know any of the particulars.
Question. Was she a paid intern or a volunteer?
Answer. She was a volunteer.
Question. So when she was in the First Lady's office she wasn't get
any salary or was she getting paid by the DNC or anybody?
Answer. Oh, no, she wouldn't--I believe she was just a straight
volunteer.
Question. Okay. So when she left to go work for him, she was
leaving an unpaid job to go----
Answer. Get a paying job.
Question. And do you have a sense generally of how long she stayed
there?
Answer. I just never focused on it.
Question. Aside from hearing that she wasn't getting paid, did you
hear anything else about her job?
Answer. No, I never--I mean, I really never thought any more about
it there. We get lots of interns passing through our shop, but these
were the two things I heard about Gina.
Question. Prior to when Gina left, do you know how long she had
been at the White House?
Answer. I--I don't know.
Question. And after she left and she was working for Mr. Chung, did
she ever call to try to get appointments or setups or anything or use
her mess privileges with Mr. Chung?
Answer. I have no idea. Not that I knew.
Question. Did you continue to--despite this somewhat being upset
with him for not paying Gina, did you continue to allow him to get into
the White House if he would call? Did you ever say anything to Evan
about let's not let him in any more or----
Answer. You know, probably not. I'm the kind of person that once a
situation is resolved, I believe that nobody is perfect and many times
people just need to have a situation brought to their attention so that
they can handle it in the right way. And after that's done, everything
is fine.
Question. Did--when you discussed this with Mr. Chung and you
indicated, you know, that you didn't think--you know, that you expected
more of him and things like that, did you ever mention anything about
the First Lady would be disappointed or that--anything about----
Answer. No, no, I was--I was confident in my own right that I could
say these things to him.
Question. And you knew he thought highly of you, and----
Answer. Well, I don't know.
Question [continuing]. And wanted access to you?
Answer. I don't know whether or not he thought highly of me or not.
I don't know what he thought. But I do know that I felt confident that
as a person who could see clearly the difference between what was wrong
and what was right with respect to this young person, I certainly felt
I could speak to the issue.
Question. Okay. And then continuing on the pictures then, after the
call, there's a call to Gina on 4/3, then there's a call to Evan on 4/1
from Irene at AISI. Do you recall an Irene from his office ever
calling----
Answer. I don't remember.
Question [continuing]. Asking about pictures? It could be a 4/4
there, it's difficult to read. And then there's another message on 4/7.
I'm not clear there if it's Marge or Maggie. Because some of his visits
were to Marge Tarmey, so I don't know. This is 59029 and it is a 4/7
phone message. It's Irene and Johnny Chung's office, AISI and it has a
310 number. I don't know if that's California or----
Answer. I don't know.
Question. Do you recall calling him in his California office or
discussing----
Answer. I don't----
Question [continuing]. The pictures with him?
Answer. I don't know if I talked with him in person, if I talked to
him on the phone, if Evan talked to me about it, but I remember that
there was an issue about his pictures.
Ms. Comstock. We will make that Deposition Exhibit Number 34.
[Williams Deposition Exhibit No. MW-34 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. You have previously discussed that you did hear about the
President's--the pictures with the President from the radio address
which had been, I guess, on April 11th. That you had heard that the NSC
had some questions. Could you just describe in a little bit more
detail, you know, what--how you learned what the NSC had any issues
about--the pictures of Mr. Chung's friends?
Answer. I don't know if I called the NSC. If I asked Evan to call
the NSC, and said--I mean, basically, the NSC is, as a unit, not very
talkative, but I would say that my indication from them was that they
preferred not to send the pictures with the President to Johnny Chung.
Question. And why was that?
Answer. I really don't recall what the reason was, but it was clear
that they--I don't know if they told me a reason or they said they
preferred not to.
Question. Do you recall who you talked to then?
Answer. No, I mean, the NSC, their office.
Question. Do you know if you--I guess have you seen this e-mail?
Answer. Only in the last deposition.
Question. Okay.
Answer. I have never seen it before.
Question. The way these read is the first e-mail is on the bottom
of the page and I believe--actually, the timing looks different,
actually, maybe the top one is the first. So I will start at the top.
Okay. I am a little confused here because the time on the e-mail
makes it look like the top one is earlier than the bottom one, yet the
bottom one seems to--and the top one seems to be responding to the
bottom one, but at any rate, why don't we start at the bottom.
Mr. Ballen. In any case, the first time she saw these was at a
deposition.
Ms. Comstock. That is fine.
EXAMINATION BY MS. COMSTOCK:
Question. Do you know Melanie or Brooke Darby at all?
Answer. No.
Question. Do you know if you ever talked with her, if this is a
person--if you talked to a man or woman in the NSC, if you recall if it
was male or female?
Answer. I don't know. I mean, I called the NSC. I don't really
recall. Like I said, I just don't recall. I only recall the gist of it.
Question. Okay. And the portion from Brooke Darby reads:
``An odd situation on which I need some guidance for the
President's office asap:
``A couple weeks ago, late Friday night, the head of DNC asked the
President's office to include several people in the President's
Saturday radio address. They did so, not knowing anything about them
except they were DNC contributors.
It turns out they are various Chinese gurus and the POTUS wasn't
sure we'd want photos of him with these people circulating around.
Johnny Chung, one of the people on the list, is coming in to see Nancy
Hernreich tomorrow and Nancy needs to know urgently whether or not she
can give him the pictures. Could you please review the list asap and
give me your advice on whether we want these photos floating around?
FYI, these people are major DNC contributors and if we can give them
the photos, the President's office would like to do so.''
Mr. Ballen. Is there any purpose in reading this?
Ms. Comstock. So we know what we are talking about for the record.
Mr. Ballen. The witness indicated she never seen this before.
Ms. Comstock. She also testified she talked to somebody in the NSC
about it.
Mr. Ballen. So.
Ms. Comstock. And we can go through documents to refresh the
recollection of a witness who has testified that she has talked to
people about the NSC.
Mr. Ballen. Then ask if this document refreshes her recollection.
Ms. Comstock. You can ask your questions during your time and I
will ask the questions I would like to during my time.
Mr. Ballen. We have been here for 8\1/2\ hours now asking
questions. We need to have consideration for the witness' time in terms
of getting to the point.
[Discussion off the record.]
EXAMINATION BY MS. COMSTOCK:
Question. Back on the record. Do you recall talking to Nancy
Hernreich in the President's office about the pictures of Johnny
Chung's friends?
Answer. I don't recall talking to her.
Question. Okay. The memo here says that Johnny Chung was going to
go in to see Nancy Hernreich. Do you recall if he told you he was going
to go in and see Nancy Hernreich about the pictures?
Answer. No.
Question. What is your knowledge of how Mr. Chung got the pictures?
Answer. I don't know.
Question. You have no knowledge of how he ended up with them?
Answer. No, I don't. I don't remember.
Question. Okay.
Answer. I don't. I mean, did he get them.
Question. I believe those are the pictures that we had referred to
earlier. The pictures of his friends were the ones who had been there
in the radio address, with the First Lady?
Answer. Well, I mean, I don't know if he got them.
Mr. Dennis. These are pictures of Mrs. Clinton, not of the
President.
EXAMINATION BY MS. COMSTOCK:
Question. Okay. This is a DNC, Office of the Chairman, memo to
Johnny Chung from Carol Khare, K-H-A-R-E, regarding photo, and the
comments on here are: ``The White House assures me that you now have
the pictures, hurray. If you don't, give me a call. Have a good trip,''
and that is fax date 4-11-95 on the top.
Answer. Can we go off record for a second?
[Brief Recess.]
EXAMINATION BY MS. COMSTOCK:
Question. Back on the record. Returning to the Suettinger and Darby
e-mail, do you recall any--other than you talked to somebody in the
NSC, do you recall any other exchanges within the White House about
these NSC concerns?
Answer. I don't.
Question. And you had indicated that you thought the NSC didn't
want to send him the pictures?
Answer. That was my sense, yes.
Question. And is your testimony that you don't know whether or not
it was--how it was resolved?
Answer. Right.
Question. So you didn't know whether or not he ever got his
pictures?
Answer. No.
Question. He never asked you again or?
Answer. No, I only remember that one instance, and if the NSC said
they preferred not to, I didn't do anything else past that----
Question. Okay.
Answer [continuing]. That I can recall.
Question. Okay. These are two letters. One is to Don Fowler and one
is to you from Mr. Chung. They are similar letters. Is that your fax
number, [redacted]?
Answer. Right.
Question. Okay. And do you recall receiving this from Mr. Chung?
Answer. Could be. This may be how I heard or got the request that
he didn't get the pictures.
Question. Okay. Do you know if you would have kept a document like
this?
Answer. A fax, no.
Question. A letter from Mr. Chung asking about these?
Answer. No.
Question. Okay. In the letter, it says, ``I have an important issue
here that needs your assistance. As you always know, I am 100 percent
supportive of the First Lady's office, always delighted to work with
the DNC on every occasion,'' and then he goes on to discuss the
business delegation, trying to get the pictures and he says, ``I have
learned from Mr. Richard Sullivan at the DNC, National Security Counsel
is holding on to those pictures.''
Do you know anything about how he learned--how Richard Sullivan
learned of the pictures being held up?
Answer. No.
Question. Did you ever talk to Mr. Sullivan?
Answer. No.
Question. Do you know of anybody at the White House who talked to
Sullivan?
Answer. No.
Question. Do you know who from the DNC was in touch with people at
the White House to get pictures, when DNC people tried to get pictures?
Answer. I think it varied from office to office. It probably
depended on the event or----
Question. Do you know--so you don't know if Mr. Sullivan ever
called anyone in your office?
Answer. No.
Question. And in the second paragraph, he says, ``If we are going
to get our pictures taken with the President, you know, we should be
courteous enough to let them have the pictures.''
Did he ever express anything like that to you about, you know, we
are going to take our pictures and, you know, they are my friends and
then you are not giving me my pictures?
Mr. Dennis. This is a letter addressed to her.
The Witness. This letter is addressed to me.
EXAMINATION BY MS. COMSTOCK:
Question. That is what I am saying, do you remember discussing that
with him?
Answer. You mean verbally?
Question. Yes.
Answer. No.
Question. Did he ever indicate that, you know, he needed to take
the pictures with him to China, which is reflected in the next
sentence?
Answer. Only here.
Question. And then he closes with saying, ``I look forward to
seeing you this weekend at Mr. Steven Spielberg's party. Thank you
again for everything.''
Did you in fact see him at a Steven Spielberg party?
Answer. No, I wasn't invited to a Steven Spielberg party.
Question. I am assuming he means the producer, which is misspelled.
Answer. I understand that, but, no.
Question. And the other letter that he wrote to Mr. Fowler is,
Donald Fowler, Chairman of the DNC, is essentially similar.
Do you know if Mr. Fowler talked to anybody in your office about
getting these pictures from Mr. Chung?
Answer. No.
Ms. Comstock. I would like to make the April 5th letter to Don
Fowler--I'm sorry. Why don't I make the e-mail we were previously
discussing, the Suettinger e-mail, Deposition Exhibit No. 35, and then
the April 5th letter to Fowler, Deposition Exhibit 36, and the April
5th letter to you from Mr. Chung, to Margaret Williams from Mr. Chung,
make that Deposition Exhibit No. 37.
[Williams Deposition Exhibit No. 35 was marked for identification.]
[Williams Deposition Exhibit No. 36 was marked for identification.]
[Williams Deposition Exhibit No. 37 was marked for identification.]
EXAMINATION BY MS. COMSTOCK:
Question. And then we had previously shown you, I think it was
before we went off the record, the DNC fax to Johnny Chung. This is
Johnny Chung, JCH 1251, which it says, ``The White House assures me you
now have the pictures.''
Do you know of anybody in your office being in touch with Carol
Khare at the DNC?
Answer. No, and I don't know who she is.
Question. You don't know who she is; you never talked to her?
Answer. No.
Question. Okay.
Ms. Comstock. I will make that Deposition Exhibit No. 38.
[Williams Deposition Exhibit No. 38 was marked for identification.]
EXAMINATION BY MS. COMSTOCK:
Question. And this is a March 28th, 1995, memo from Betty Currie.
It is a redacted--it appears to be a redacted memo. It is not marked as
redacted, but portions of it appear to be missing. But number two here,
the only part on here, talks about, Ceandra Scott called, said she was
concerned about Johnny Chung.
Do you know who Ceandra Scott is at the DNC?
Answer. Yes.
Question. Do you know who she is?
Answer. Yes. She worked in the chairman's office at the DNC.
Question. Okay. And does Betty Currie normally do memos for the
President at the White House?
Answer. I don't know.
Question. Or does she do them for--besides--I mean, she is the
President's secretary, is that correct, and in his personal office?
Answer. Yes, but I don't know how they are arranged.
Question. Okay. I am wondering, do you know, aside from the
President, anybody that Betty Currie does work for or writes memos to?
Answer. I don't--I really don't know----
Question. Okay.
Answer [continuing]. How they arrange their work.
Question. Did you ever have any conversation with Ceandra Scott
about Johnny Chung?
Answer. Not that I can recall.
Question. Do you know if anyone in your office did?
Answer. I don't know.
Question. Have you seen this document before?
Answer. Prior to my deposition.
Question. In a previous deposition or in reviewing documents prior
to that?
Answer. At a deposition.
Question. And I don't mean to go into if you discussed documents
with your attorney.
Answer. At a deposition I saw this.
Question. Okay.
Answer. And----
Question. But the memo indicates she stated that we should have
called them prior to their coming to the radio address, and I guess
``them'' meaning the DNC. Ms. Scott works at DNC in the chairman's
office?
Answer. Yes, she does work there.
Question. Do you recall any discussions that you should have called
the DNC before allowing these folks to go to the radio address?
Answer. I couldn't make any sense of what she meant.
Question. So where she is saying here, apparently, they were in
Maggie's office when requests came, and Maggie said she didn't know but
to contact DNC, you don't know----
Answer. I don't know what she meant by this.
Question. And you had no discussion with anybody that allows you to
make any sense of this document?
Answer. I have read it over several times. I don't quite know what
they mean, ``when requests came'' and ``Maggie said she didn't know but
to contact DNC.'' I mean, I don't know.
Question. Did the radio addresses normally get set up by the DNC,
who would go on the radio addresses?
Answer. No, but I think that the DNC, as I said before, can
certainly, you know, recommend people they would like to come to the
radio address, as anyone can.
Ms. Comstock. Okay. I will make this EPO 55492, the March 28
current memo, Deposition Exhibit 39.
[Williams Deposition Exhibit No. 39 was marked for identification.]
EXAMINATION BY MS. COMSTOCK:
Question. Now I have given you this March 6, '95 memo to Bobby,
which was Bobby Watson, from Richard Sullivan, and it discusses Johnny
Chung trying to get work from the DNC. Did you have any knowledge about
him, his blast fax being used at the DNC?
Answer. No.
Question. Had you seen this document before?
Answer. This is the first time I have ever seen it.
Question. And in this document they discuss AISI, Mr. Chung's
company, as used by many political clients, including Governor Chiles
and Senator Kennedy and others. Did Mr. Chung ever tell you Senator
Kennedy or Governor Chiles used the system?
Answer. Not that I remember.
Question. Okay. And so you have no knowledge about him getting this
contract at all?
Answer. No.
Ms. Comstock. Make that Deposition Exhibit No. 40.
[Williams Deposition Exhibit No. 40 was marked for identification.]
EXAMINATION BY MS. COMSTOCK:
Question. And just returning to when Mr. Chung gave you what--what
you recollect of him giving you a check, you did not know the amount of
the check at that time?
Answer. No.
Question. You didn't open the envelope--or you don't recall if it
was in an envelope?
Answer. I don't recall.
Question. But you had some recollection you thought it was $10,000?
Answer. For some reason, I thought it was $10,000.
Question. And do you recall him giving you any note with the check
or anything like that?
Answer. No.
Question. He has indicated that the note, it said something like,
``I do what I can to help,'' something to that effect. Do you recall
him giving you any type of note like that?
Answer. No.
Question. Do you have any knowledge of how Mr. Chung would know
anything about debts that the DNC owed for White House Christmas
parties?
Answer. I don't know. It would--I mean, I don't know.
Mr. Dennis. Don't speculate.
EXAMINATION BY MS. COMSTOCK:
Question. You never discussed that with him?
Answer. With Johnny Chung?
Question. Yes.
Answer. No.
Question. And this is a memo to Margaret Williams to Gary Walters
of March 24, 1995, regarding unpaid bills for collection issued by the
executive residence at the White House for fiscal years '94 and '95.
Did you deal with Mr. Walters on these type of bills?
Answer. Yes.
Mr. Ballen. She testified to this already.
EXAMINATION BY MS. COMSTOCK:
Question. Do you recall receiving this memo? I'm sorry, you have my
copy again.
Answer. I don't recall this one specifically, but as I testified, I
said from time to time he would talk to me or give me a memo.
Question. This is DNC document 3078128 through 31. Do you recall on
or around, you know, late February, early March of
'95, discussing the bills with Mr. Walters?
Answer. I don't recall the specific time, but as I said, you know,
from time to time I would get a memo or I would see him and he would
tell me about it, and I would talk to him about it and say I will call
somebody at the DNC or, as I said before, I would tell Mr. Ickes, ``I
think they should pay their bills'' or, you know.
Question. And do you know what Mr. Ickes would do?
Answer. No.
Question. And so you would--Mr. Walters would--do you know where in
the process he would--he is writing you a memo here. Was this after
having had a number of discussions with you about it, or if he had
talked to others, or where in the process of the sort of efforts to
collect on the bills that this memo may have come, if you know?
Answer. I mean, I don't know if he had a process or any kind of
timing around writing a memo or talking to me about it, about the
bills. I don't think it is anything that he had a planned time or
process.
Mr. Dennis. I will just make a note that on this document there are
a number of instances in which the bill had not been submitted, no
address, question mark, DNC. I will just bring that to your attention.
EXAMINATION BY MS. COMSTOCK:
Question. But in early 1995, were you aware of the DNC--you said
they had been habitually late in paying bills.
Answer. Yes.
Question. Were you aware of them not having paid Christmas bills?
Answer. Whatever Mr. Walters had alerted me to, I knew that they
hadn't paid.
Ms. Comstock. I will make that Deposition Exhibit No. 41.
[Williams Deposition Exhibit No. 41 was marked for identification.]
EXAMINATION BY MS. COMSTOCK:
Question. Then this is another document, DNC 3080883 through 6,
which was immediate attention, a fax from the White House to Joe
Sandler from Jodie Torkelson. Can you tell us who Jodie Torkelson is?
Answer. I don't know what her title was, but she was ahead of
administration at the White House.
Mr. Dennis. I think this is your copy again.
Ms. Comstock. Sorry. Thank you.
EXAMINATION BY MS. COMSTOCK:
Question. Do you know, the previous memo we reviewed had not been
sent to Jodie Torkelson. Do you know why Jodie Torkelson by August of
'95 had been brought in and memoed on this from Mr. Walters, if you had
any discussion with Mr. Walters about that?
Answer. No.
Question. Do you know if you had any meetings with Ms. Torkelson
and Mr. Walters about these matters?
Answer. I don't know if we had a meeting. I was aware that Jodie,
obviously aware that she received it, since I see her name here. But I
would just be speculating as to why they went to Jodie.
Question. Directing your attention to--it actually was on the
previous document, on the third page of it, the March memo from Mr.
Walters, and on the third page of this memo there is an indication that
there was a partial payment of $198,714.56 made on March 15, 1995 for
various events up to that time, apparently, that were overdue.
Mr. Ballen. Counsel, where on the document are you?
Ms. Comstock. 3080886, in the September 5, 1995 fax, I should say
August 1, 1995 memo, and then it's on page 3, DNC 3078130 of the
previous memo we were discussing from Gary Walters, March 24, 1995
memo. There is an indication that close to--approximately $200,000
payment for receptions and events was paid by the DNC on March 15,
1995. Do you recall in or around mid-March----
Mr. Dennis. I'm sorry, where does it say about the DNC? I want to
make sure.
Ms. Comstock. It says partial payment. This is saying partial
payment for the events, so I don't know that they are all--you are
correct, it doesn't say DNC, it just says partial payment. I'm sorry
about that.
Mr. Dennis. I don't know, because there are other things that are
kind of mixed in.
Ms. Comstock. There are press events in here, some of them are the
press not paying; other people are involved in this.
EXAMINATION BY MS. COMSTOCK:
Question. Do you know, at or around mid-March, 1995, anything about
the DNC making payments to the office?
Answer. No.
Ms. Comstock. Okay. I will make that Deposition Exhibit No. 42.
[Williams Deposition Exhibit No. 42 was marked for identification.]
EXAMINATION BY MS. COMSTOCK:
Question. Aside from the one conversation that you have relayed
already today with the First Lady about Johnny Chung, did you have any
other conversations with the First Lady about Johnny Chung?
Answer. Ever have any?
Question. To date, if you have had any conversations about Johnny
Chung.
Answer. To date, yes.
Question. And can you tell us when those--approximately when and
what the substance of those conversations was, would be?
Answer. It was after there was a newscast about the Johnny Chung
check for the DNC being handed to me by Johnny Chung, and she called me
and she said, you know, ``How are you doing?'' She was trying to find
me. She beeped me, she said, ``How are you doing? What is going on?''
And I said I essentially took this check and gave it to the DNC.
Question. Did she ask you about what happened or what this is
about?
Answer. Yes, and that is what I told her.
Question. So she asked you, you know, what is this, what can you
tell me about it?
Answer. She said, ``What happened?"
Question. All right. And you told her?
Answer. I told her, because she had seen this on the news, I told
her Johnny Chung gave me a check for the DNC and I sent it to the DNC.
Question. And what did she say?
Answer. She agreed with me that this seemed rather ridiculous, to
lead the news with something like this.
Question. Did you have any further discussion, do you recall?
Answer. No. Then I just said to her, you know, ``Don't worry about
it.''
Question. And did the press people at the White House also talk
with you about that, or did you have your attorney handle the matters?
Answer. I had my attorney.
Question. So the only person you talked about this with when the
press stories came out was Mrs. Clinton?
Answer. Yes, and--oh, at the White House, yes, and my attorney
dealt with everyone else.
Question. Did they ever talk with Evan Ryan about Mr. Chung when
the news accounts came out?
Answer. Yes, when there was a particularly tough article about her
in Time magazine, she was very upset, and I talked to her and I told
her that this was the price of public life in the nineties.
Question. Did she talk to you about her account, her recollection
of what Mr. Chung had done in connection with the check?
Answer. No.
Question. Do you know if she had any?
Answer. No. If there is one thing that these experiences have
taught us over the 4 years, it is not to talk to each other.
Question. You had mentioned that Johnny Chung generally talked
about, you know, you should come to China and that kind of thing. Were
you aware of Don Fowler ever planning on making trips to China with
Johnny Chung or going on any business trips with Mr. Chung?
Answer. No.
Question. He never mentioned that to you, or anything like that?
Answer. No.
Question. Okay. Returning to the WAVEs, Mr. Chung continues--after
this March 8th, 9th time frame, he continues to be WAVEd into the White
House, usually by Ms. Ryan. Do you know what he was coming in for in
any of these other cases?
Answer. I think no differently than before, wanting to stop by,
wanting to walk around. I don't have any other information.
Question. Okay. If he needed to use the mess and that kind of
thing, that still went on and continued to go on, or did that stop at
some point?
Answer. It depends. At whatever point that the White House counsel
issued a policy memorandum, I think about the use of mess accounts, so
if he had asked me prior to that time--and I don't know what this time
frame is and how it fits in, when the White House sent out their memo
about use of mess accounts--that if he had come prior to that, I would
have let him use my mess account. If he had come after that memorandum,
then I would not have.
Question. Okay. I think from the WAVE records we have, his last
visit appears to be June 15th, 1996. Does that help you recall at all?
Answer. You would have to--I don't know when that memorandum was
issued.
Question. Actually, he wasn't WAVE'd in by Ryan at that time, it
was Forster who WAVE'd. Do you know Forster in the West Wing?
Answer. No.
Forster?
Question. Forster.
Answer. No. You can let me see the spelling. I don't know anyone
offhand.
Question. F-O-R-S-T-E-R, page EPO 5029?
Answer. No, I don't know anybody with that name.
Ms. Comstock. We will make this WAVE grouping Deposition Exhibit
No. 43, and it is the WAVEs records we have been discussing throughout
the deposition, just so it is clear for the record.
EXAMINATION BY MS. COMSTOCK:
Question. Did Evan Ryan ever complain or raise to you anything
about Johnny Chung, like when he kept continuing to call?
Answer. Yes.
Question. And what did she say?
Answer. She was irritated by it.
Question. And what did she say that led you to thing she was
irritated?
Answer. Knowing Evan, she said, I am irritated by it.
Question. And why, that it was frequent, he is a nuisance?
Answer. Yes, she just found him annoying.
Question. And what did you tell her?
Answer. Pretty much a lot in life is annoying, but if he was not
hurting anybody, and there didn't seem to be any indication of it, I
expected her to work harder at her tolerance level, and that he should
still be treated very well.
Question. These are some phone records from September '95; again, a
message to Evan Ryan on 10-20-95, says, sending flowers to you and
Maggie.
Do you recall receiving flowers from Mr. Chung?
Answer. Maybe. I don't know. Could be.
Question. What is the process--when you get flowers at the White
House, do they have to get checked out?
Answer. Yes, they go through a check and an X-ray machine, and
somebody brings them up, and it is probably the only thing you can keep
in the White House because they know that it will die.
Question. Are flowers frequently delivered to the First Lady's
Office?
Mr. Ballen. I am going to object. This witness has been here almost
10 hours, and we are talking about flowers.
Could I finish my objection, please?
The witness has been here, we have been here for 10 hours now, and
we are now going to ask her about the procedure for flowers.
The Witness. They have been delivered. I don't think it is terribly
frequent.
EXAMINATION BY MS. COMSTOCK:
Question. Do you recall getting flowers from Mr. Chung?
Answer. No.
Question. Okay. And then on another occasion, September 29th, 1995,
he also indicates in the message, sending a couple of baskets of
flowers for you and Evan.
Do you have any recollection of that?
Answer. No.
Question. Do you know of any particular favors or anything he was
asking at this time that would generate sending flowers?
Answer. No. Once again, there is nothing that Johnny Chung would
have to do for us to have treated him well, nothing.
Ms. Comstock. Why don't I make the 9-29 message from Johnny Chung,
EPO 59074, Deposition Exhibit 44; and EPO 59059, which is the 10-20-95
message, make that 45.
[Williams Deposition Exhibit No. WM-44 was marked for
identification.]
[Williams Deposition Exhibit No. WM-45 was marked for
identification.]
EXAMINATION BY MS. COMSTOCK:
Question. The WAVE records indicate that Johnny Chung was at the
White House on 10-19-95. I believe it's at or around the time, if not
the date, at or around the time of the Hazel O'Leary check of $25,000
that was given to Hazel O'Leary.
Do you know if anyone at the White House ever discussed with Mr.
Chung anything regarding Hazel O'Leary?
Answer. No. The first I have heard about that was on the news last
week.
Question. Okay. Did Johnny Chung ever tell you he was interested in
meeting Secretary O'Leary about any energy matters?
Answer. No, Johnny Chung never asked to meet with anyone. He never
asked me about meeting with anyone.
Question. Okay. Did he ever talk about--at least one of them was
one of the ones of the five people who were in the radio address--but
any people involved in the petrochemical business or the oil business?
Answer. No.
Question. Were you aware of him talking with George Stephanopoulos
about his oil business or any of his businesses?
Answer. No.
Question. Or any efforts to get together with Mr. Stephanopoulos
over any business matters?
Answer. No.
Question. Do you know if he ever talked to George Stephanopoulos
about getting in touch with any Chinese VIPs?
Answer. I didn't know he ever talked to George Stephanopoulos.
Question. So you have no knowledge of him talking with George?
Answer. None at all.
Question. Aside from what you have read in the press, do you have
any knowledge of the Hazel O'Leary Africare contribution? I am sort of
shorthanding it here, you know, referring to the recent press articles.
This is a copy of an NBC News transcript on this, which is discussing
his allegations regarding Secretary Hazel O'Leary providing $25,000 to
a favorite charity.
You have no knowledge of any of the events or cannot enlighten us
to how any of these events came about?
Answer. No, I didn't know he even knew Secretary O'Leary.
Ms. Comstock. I will make that Deposition Exhibit No. 46, just so
the record is clear, kind of what we are referring to here, since we
are moving through that fairly quickly.
EXAMINATION BY MS. COMSTOCK:
Question. You indicated you thought he may have given you the
business cards of the gentlemen who you recall bowing to?
Answer. Uh-huh.
Question. Do you recall if you kept those or what you did with
them, or was that sort of going in a drawer?
Answer. I think they were in Chinese. I just never saw myself as
having any use for them.
Question. Do you know if any type of--in the discussions with the
NSC people, do you recall if there was any type of background check run
on these guys, the five guys who went to the radio address that raised
the red flags?
Answer. I don't know what they do, what they would do.
Question. Was there anything in particular you recall that made
them leery of them, that they wouldn't want--you said you had a sense
they didn't want the pictures out. Did you have an understanding of,
gee, who was it that I let in there that the NSC doesn't want the
pictures out?
Answer. Well, the NSC----
Mr. Dennis. Well, before you answer that question, that question
assumes she let them into the radio address.
The Witness. I didn't even think about that.
EXAMINATION BY MS. COMSTOCK:
Question. To the extent they were in, and people are asking you now
or you are talking about them, you know, who are these people who came
in, and they are asking about it, did you have a sense of what their
concerns were about these people?
Answer. In general the NSC and any people who are concerned with
security at the White House never explained. I mean, they just never
explained.
Question. No one said anything like, these are Chinese nationals
that are connected with anything, it is just sort of we have a general
concern, you don't have a need to know?
Answer. I don't know the specifics, but I do know they expressed
some kind of preference that going any further really wasn't, you know,
worthwhile.
Question. And the e-mail that we have previously looked at, the NSC
e-mail, referred to them as a hustler. Do you recall them ever saying
anything about him trying to use his access to the White House and how
he might use these pictures?
Answer. No.
Question. Do you recall--are you familiar with the picture that he
had with the beer executives that has been on the news quite a bit?
Answer. I don't really recall.
Question. Do you have any recollection about him bringing the beer
executive people from China into the White House?
Answer. No. I mean, I wouldn't know who they were.
Question. After, given the NSC had raised concerns about the people
who were with Mr. Chung, did that ever cause anybody in your office or
for you to re-evaluate the continued access of Mr. Chung to the White
House?
Mr. Ballen. Excuse me. Was it your testimony that they raised
concerns or that they just weren't using pictures?
The Witness. They weren't really seeing the pictures.
Mr. Ballen. There is a difference.
EXAMINATION BY MS. COMSTOCK:
Question. You weren't aware at that time they considered him a
hustler or might use his access to the White House, the NSC, anyone at
the NSC?
Answer. I wasn't, but, my God, if we kept hustlers out of the White
House and the halls of Congress, who would there be?
Question. I wanted to ask you just a few questions about the Back
to Business Committee. You have previously testified that Lynn Cutler
gave frequent meetings at the White House regarding women's issues?
Answer. Yes.
Question. Did you ever discuss with Ms. Cutler the Back to Business
Committee?
Answer. Over the phone, I remember when Lynn and I, and I guess
some others, talked about the idea of having this kind of committee
that would mostly do public responding to some of the issues that had
been raised, that seemed to have very little to do with governing, and
she told me about the idea, and, you know, I was delighted to hear
there were people outside who were going to be doing that.
Question. And was it your understanding Ms. Cutler was going to be
involved in orchestrating that?
Answer. Well, that she was going to be involved with other people.
There were a good number of people who had already been responding on
television who were not in the White House. Lynn Cutler had been one of
them, and there were other people, and they decided to be more
organized about it.
Question. Okay.
Mr. Ballen. I am going to object to this line of questioning on the
Back to Business Committee as being outside the relevant scope of this
inquiry. Is there a specific question related to specific campaign
fund-raising improprieties or law? Perhaps I could recall the
objection.
EXAMINATION BY MS. COMSTOCK:
Question. What was Anne Lewis's role with the committee?
Mr. Ballen. Same objection.
The Witness. She was a spokesperson.
EXAMINATION BY MS. COMSTOCK:
Question. All right. And she is currently the communications
director at the White House; is that correct?
Answer. That is correct.
Question. Did you ever have discussions with her about the Back to
Business Committee?
Answer. About the committee?
Question. Uh-huh.
Answer. Not about the committee itself. I certainly knew when they
had people they were putting on television.
Question. And did you ever discuss the Back to Business Committee
with the President and First Lady?
Mr. Ballen. Same objection.
The Witness. I don't believe I have discussed it with the
President. I can't imagine that I didn't mention to Mrs. Clinton that
there were outside people who were actually getting on the airwaves and
taking on some of these charges.
Mr. Dennis. Before we go any further, point of procedure. When an
objection is made, is that basically preserving for the record?
Mr. Ballen. If you want to join in the objection, in terms of the
witness not answering, then we proceed in to the Chairman and the
committee rules.
Mr. Dennis. So if the witness answers the question, the objection
becomes lost.
Mr. Ballen. It doesn't become lost, the committee can still make a
judgment on that, and the judgment is it is not relevant, it will be
stricken.
Mr. Dennis. Stricken from the dep.
Mr. Ballen. That is correct.
EXAMINATION BY MS. COMSTOCK:
Question. Was the First Lady then aware of what the Back to
Business Committee was going to be doing?
Answer. Well, yes. As I said before, I know at some point I told
her there are groups outside of the White House who are going on
television, and for all the people who are saying mean and untrue
things, there are people who are answering those things.
Mr. Ballen. Excuse me, please. Let me just clarify something in
your response to counsel's question.
The committee won't necessarily take it up. So that the objection,
the single fact that a Minority counsel makes an objection, I cannot
guarantee to the witness or counsel that that will be taken up by the
committee and stricken from the record.
If counsel wants to make an objection now, then the questions won't
proceed. Or if counsel wants us to take this up with the committee,
then you can make that kind of a request.
Mr. Dennis. Let me do that. Can I have the witness leave the room
shortly while I discuss this matter with counsel? I want you to step
out in the hall. We will stay on the record.
[Witness left deposition room.]
Mr. Dennis. This is my concern about this. One, it is getting very
late; and we've been here quite a long time. I understand that this
Back-to-Business issue is one that Chung has raised in some press
accounts in which he has said that Ms. Cutler had approached him and
mentioned Ms. Williams as the source of a referral and he might be
interested in supporting the Back-to-Business initiative.
Now, for that reason, it certainly has something to do with fund-
raising; but I don't see on that basis whether it has to do with any
improprieties, just taking his statement as absolutely true. So my
question is, what is the basis for really going over this area as one
that would involve any kind of, you know, impropriety or fund-raising
misconduct? And that's--you know, particularly at this hour, to get
into this----
Ms. Comstock. I don't think--I think we are--this is--we are going
to be moving into all the events with--with Ms. Cutler and the
references and that type of thing. I think, given Mr. Chung's
connections with the White House, these are matters related directly or
indirectly, certainly. But having the U.S. ambassador to China become
involved in this and any connections regarding--these are factual
matters that are connected to a number of matters we are investigating,
Mr. Chung, obviously, being a major figure. So looking at how Mr. Chung
was involved in any number of areas where he was giving money to
various sources----
And I would like to state for the record I appreciate you asking
your client to leave the room so we are not both testifying about the
matters in front of her, and I appreciated that courtesy of not
infecting the records. I do want to reflect that the witness isn't
present.
I think we can be fairly brief, just discussing the news accounts
and, you know, her knowledge of Ms. Cutler's--and references on that.
And I think that's where we are going in this area.
Mr. Dennis. Well, let me proffer to you as a way of hopefully
cutting this somewhat short that, you know, my client can certainly
testify concerning the fact that, you know, she knew of the Back-to-
Business efforts and what that involved in some general fashion. But I
will not object unless this becomes too drawn out. I mean, I would hope
that we could cooperate and get to the point where you could just ask
her the general question and let her describe in her own words what her
involvement was in that and what the involvement was of Johnny Chung.
If you want to have some follow-up questions, that's fine. But her
to be sort of the--she wasn't the organizer of Back to Business and
your questions are eliciting a lot of ``I don't knows''--I don't know,
I don't know. And, of course, when you question somebody about
something they don't know about--you understand what I'm saying?
Ms. Comstock. I think we can be fairly brief and ask her some
follow-up on that.
Mr. Dennis. Is this the last area?
Ms. Comstock. Basically, it is. I want to check on a few other
things, but we are getting close.
Mr. Ballen. I want to note for the record----
Mr. Dennis. I am not making an objection.
Mr. Ballen. I didn't understand the answer to Mr. Dennis' question,
which was the basis of my objection as well, as to how this relates to
campaign financing.
Ms. Comstock. I think we have moved on, and the witness is not
objecting. If we could just move through this quickly.
Mr. Ballen. Well, I have an objection pending.
Mr. Dennis. I can't--I'm not----
Mr. Ballen. I want to know how the Back to Business Committee
relates to our investigation. There is a specific question as to
campaign fund-raising improprieties. Can you answer the question?
Ms. Comstock. Your objection is noted.
Mr. Ballen. I am going to note for the record that you are refusing
to provide an explanation----
Ms. Comstock. I have already provided the explanation, and I think
the public record is clear on this and that it is relevant, and we
would like to proceed on the Back to Business Committee and the
contributions made by Mr. Chung to that committee.
Mr. Dennis. Okay. I'll have the witness come back in.
[Witness returns.]
EXAMINATION BY MS. COMSTOCK:
Question. Okay. Why don't you just tell us--give us kind of what
you know about Lynn Cutler and any conversations you may have had with
her about Johnny Chung.
Answer. Lynn Cutler asked me if there were people that I knew of
who would be interested in helping the Back to Business Committee. And
not only was she looking for--she said contributors, people who could
go on television, who could be helpful. And I said, well, these are
people I think you might want to call. And Johnny Chung, I included his
name as one of the people.
Question. And did you provide her with a list of other names?
Answer. I didn't give her a list. This was just a verbal
conversation. I believe I gave her some other names. There were a
couple of people I gave her that I thought would be really good on
television that I suggested that she contact.
Question. And who were the other people that you told her to
contact? Just to be clear, you told her that Johnny Chung would be a
person to contact about raising money?
Answer. Yes. She said, I'm looking for people--if there are people
who would be interested in helping the Back to Business Committee,
contributors, people who would be good on television. And I said, yeah.
I gave her Johnny Chung's name, and I gave her a couple of names of
people for television.
Question. Did you give her a phone number or way to contact Mr.
Chung?
Answer. I don't know if I did right then and there. I don't know if
I did. I don't know if I did.
Question. Do you have any knowledge as to how she learned how to
contact him?
Answer. No, I don't have any knowledge.
Question. Mr. Chung has indicated that he was called the morning
after he attended a White House Christmas party. Do you recall if you
ever told Ms. Cutler that, hey, he's going to be in town, he's going to
be at the Christmas party, you might want to talk to him then?
Answer. No, I mean, more than likely I would have--if she asked for
a number, called the office for a number, we would have given it to
her.
Question. And can you just continue as to after you gave her----
Answer. That's----
Question. Did you ever learn whether or not he had contributed?
Answer. No.
Question. Did he ever tell you that he wanted to let you know that
he had done this to help the First Lady or the President?
Answer. I don't know. I don't recall. I don't know. I don't know if
he contributed. I don't know.
Question. When--you had previously discussed when he gave you the
$50,000 check he talked a lot about ``I want to help the First Lady''--
--
Answer. Uh-huh.
Question. And that he was anxious that you take the check; is that
correct? That you----
Answer. Yes, or the First Lady's office. He was anxious that I take
the check. He said, ``I want to give through the First Lady's office,''
definitely.
Question. Did you recall him saying that he wanted to get credit
with you or wanted you to get credit for getting the check?
Answer. No, I don't think he--I mean, I don't know if he said that
to anyone. I mean, or--and I have no reason to believe he would--would
think that. Would get any credit?
Question. When he had given you the $50,000 check, did you get a
sense that he wanted you to know that he gave so the First Lady would
know?
Answer. No, I got the feeling that he wanted me to give the check
to the DNC.
Question. But if he'd given it direct--I mean, he had--we don't
have the record here today, but he had met--I don't know if you're
aware, but he had met numerous times with DNC people on many occasions.
He could have given checks to them.
Answer. Which he had.
Question. Do you know why in particular he felt giving you this
check was something that would----
Answer. You would have to talk to him about his motivation.
Question. But did he ever say anything to you about, tell the First
Lady that I gave this check or I hope you let her know I've done this
to help her?
Answer. No, he never--no, he never said that to me.
Question. So you cannot recall if he ever told you anything about
the check that he gave the Back to Business Committee?
Answer. No, I can't.
Question. Did Ms. Cutler ever tell you whether she was successful
in getting money from him?
Answer. No, I don't believe she did.
Question. So, to date, you have had no other conversations with
Lynn Cutler about Johnny Chung?
Answer. No.
Question. Okay. The White House--well, I will just give you this--
the August 9th one. This is an August 9th, 1997, L.A. Times article
entitled, Donor Speaks Out on Clinton Group. On the second page of the
article at the top of the page, a little ways down, fourth paragraph,
it says, ``White House officials confirm that Cutler arranged a meeting
for Chung with a Commerce Department official.''
Do you have any knowledge about when--Lynn Cutler arranging
meetings for Johnny Chung?
Answer. No.
Question. And do you have any knowledge about when Cutler--Lynn
Cutler arranging any meetings with the U.S. Embassy in China or with
Ambassador Sasser?
Answer. No.
Question. So was the first time you learned of that in the news
accounts?
Answer. Yeah, I just read them yesterday.
Question. In this article also Lanny Davis was quoted as saying
that there were frequent--White House involvement with Back to Business
included frequent contact.
Just generally--I don't want to dwell on this for a long time. Can
you generally describe what the frequent contact was and who was having
the frequent contact with the Back to Business Committee, if you know?
Answer. Well, I don't know what it is that Lanny was speaking
about. I can say that if Back to Business put out a press release or if
they were going to be on any of the shows over the weekend, talk shows
or anything like that, generally they would fax me a copy of the press
release and they would fax me a list of who they had on the weekend
shows. And for a while they were pretty active. So, with me, I knew
what they were doing, so that would be frequent contact. I don't know
with respect to Lanny.
Question. Was anybody at the White House writing or working on any
of the material that they put out?
Answer. No.
Question. Do you know what Mr. Ickes' involvement with the group
was at all, if any?
Answer. I think very little, actually.
Question. Do you have any knowledge of Back to Business Committee
ever hiring any private detectives or anything like that to investigate
chairmen of committees who were investigating Whitewater or other
matters?
Mr. Dennis. You mean chairmen of congressional committees?
The Witness. No.
EXAMINATION BY MS. COMSTOCK:
Question. Congressional committees. Do you know an individual by
the name of Jack Palladino?
Answer. I've heard his name.
Mr. Ballen. Objection as to relevancy.
EXAMINATION BY MS. COMSTOCK:
Question. He's a private detective from San Francisco who allegedly
worked in the '92 campaign. You don't--have you ever met him?
Answer. No.
Question. Do you have any knowledge of Harold Ickes hiring Mr.
Palladino at any time for any purposes while you have been at the White
House? Have you ever heard anything like that?
Answer. No.
Question. The middle of the page or so here in the article it
indicates that a source close to Cutler said that she learned of Mr.
Chung and his potential interest in helping from a number of different
places as a result of her involvement with the Democratic Party. Do you
know--aside from yourself mentioning him, do you know of others who
told Lynn Cutler of Johnny Chung?
Answer. No.
Mr. Dennis. I believe--was she a vice chair of the DNC?
The Witness. Yeah. Yes, she was.
EXAMINATION BY MS. COMSTOCK:
Question. And, to your knowledge, was she in frequent contact with
the DNC----
Answer. I don't know.
Question [continuing]. The DNC finance officials?
Answer. I really don't know what the contact was.
Question. You had mentioned that you had given--did you give Lynn
Cutler other names of people besides Johnny Chung?
Answer. Yeah, I believe so.
Question. Do you know how many names you gave her?
Answer. Four, maybe three.
Question. Do you recall who else, other names you gave her?
Answer. I know I thought that she should contact a woman by the
name of Kiki Moore because she was very good on television.
Question. In terms of donations, was there anyone besides Mr. Chung
whose name you gave her?
Answer. That's all I can recall.
Question. Do you recall why you came up with Mr. Chung's name of
all the people out there that would be donating that would be
interested in helping the President or the First Lady?
Answer. Because it seemed to me for weeks and months Mr. Chung had
stopped me and said: How can I help? How can I help? How can I give? So
I thought of him.
Question. Mr. Chung's account of the call from Mr. Cutler says that
he received a phone call at his Washington apartment. Did you know of
him having a Washington apartment?
Answer. No.
Question. And you have no knowledge of--did you have a phone number
in D.C. to contact him at, if you know?
Answer. I don't know. Evan would have had his number. I had no
reason to call him. I can't remember.
Question. Do you know if she would have maintained those records,
had them on any type of Rolodex or file or anything?
Answer. You'd have to ask her. I don't know.
Question. Mr. Chung's account also has indicated that Lynn Cutler
introduced herself as a friend of the First Lady who was referred to
him by Williams. Do you--is Lynn Cutler a friend of the First Lady, to
your knowledge?
Answer. Oh, I think that's pretty subjective. If she thinks she
is----
Question. Does she have frequent contact with your office, aside
from the meetings that you had occasion to be at, events with the First
Lady or have worked with her in the past on various events?
Answer. Lynn Cutler's been in Democratic politics for 40 years. I'm
sure that she has known the President and Hillary through their
governorship. She actually ran for Congress. I mean----
Question. Do you recall if you told Lynn Cutler that she could use
your name, you know, so that--or that she could say----
Answer. Let me ask a question just for one second. Has Mr. Chung
been deposed?
Question. No.
Answer. And so these questions are based on this news article?
Question. Right. I have the news article, and I'm pretty much
referring--I'm kind of in the bottom paragraph here. I'm just referring
to his allegations.
Answer. So we don't know if these are real allegations? These may
be----
Question. He's not testified to these.
Answer. So we don't know if the reporter has put these down as what
he says. Do we have any way of validating what has been said here?
Question. Not until Mr. Chung comes in.
Answer. Well, I just--with all due respect, I am here and I am here
voluntarily and I have been here for almost 10 hours. And I'm perfectly
willing to do this because I want this thing to work out and I want
people to get to the truth. But I want some fairness accorded to me.
And so when Mr. Chung says something and he is on the record, I
will respond to it. But I really feel very uncomfortable and not very
happy that I have to walk through the L.A. Times, to have what some
reporter whose work cannot be validated be up against me who is sitting
here and to be on the record with this.
Question. Well, I would just like to, you know--we are discussing--
these are only things he has talked about here and you have indicated
that you gave his name to Lynn Cutler.
Answer. Which I said--I don't know past that.
Question. You don't know if you said anything about----
Answer. I gave--I gave her his name. I gave her his name. I did
that.
Question. Do you recall if you gave Lynn Cutler any dollar figures?
Like you could ask him for this much or gave her a ballpark figure of
what he might----
Answer. I would never have.
Question. You just gave her the name and that was it?
Answer. That was it.
Question. Did you have any understanding whether she was going to
use your name in approaching him?
Answer. I had no understanding of it, but if you live in
Washington, D.C., I think you have a sense that people use people's
names all the time. And if he wanted to try and verify that she
actually got his name from someone, I'm sure he might even ask her and
she would say Maggie Williams told me to call. It doesn't strike me as
out of the realm of possibility.
Question. Did you hear about Johnny Chung calling around about Lynn
Cutler: Should I give her money? Should I be talking to anybody at the
White House or the DNC about it?
Answer. I only know what I read in the news accounts with respect
to that.
Ms. Comstock. Okay. Just so it's clear, we have been discussing
about the news account. I will make that deposition number 47.
The Witness. Thank you.
[Williams Deposition Exhibit No. 47 was marked for identification.]
Mr. Dennis. Are we getting pretty close here? Because it's almost 8
o'clock; and, of course, Minority counsel has----
Mr. Ballen. I didn't hear what you said.
Mr. Dennis. I was asking whether or not we are getting close to the
end here. Because you have an opportunity to ask questions, and we have
been sitting--we have been going pretty----
Ms. Comstock. We are getting very close.
EXAMINATION BY MS. COMSTOCK:
Question. The White House database had been incorporated into the
First Lady's office; is that correct? On somebody's computer? Do you
have any knowledge of that?
Answer. Which database?
Question. The White House database which had--it's referred to as
WHoDB, which had information on people who had come to the White House
and when they had made visits or----
Answer. As I understand it, there was a screen in the social office
or two screens in the social office which used it primarily--which used
it primarily.
Question. And what was your understanding of how it was used?
Answer. To know the names of people who had attended White House
events so that other people can be invited or, you know, just to have
them on. I mean, I don't think it was a system different than the
previous administration's system. It might have been more--more
modernized. But, you know, having a database that gave you information
about people who were invited to the White House and people who came to
the White House, accepts, regrets, phone numbers, addresses, that kind
of thing, I thought was pretty----
Mr. Ballen. Excuse me, I'm going to object to this line of
questioning. It is now 8 o'clock. At 4 o'clock, this witness was told
there were two matters left, Johnny Chung and Webster Hubbell. We are
going into the Back to Business Committee, other matters, the White
House database. I just don't think this is fair any longer. There is no
sense of proportion in either the questions or the topics, and we are
just getting into entirely another topic now which God knows how long
it is going to last.
Ms. Comstock. I think it is going to be a fairly brief topic.
Mr. Ballen. Nothing has been fairly brief today. I think we can all
agree on that.
Mr. Dennis. Is there a need to go into this?
EXAMINATION BY MS. COMSTOCK:
Question. Just--there is one document that we had discussed earlier
today and I just wanted to--that had--this is Deposition Exhibit No. 8,
which had listed the various guests and how many events they had been
listed in. I was wondering if you know if any kind of information like
this on who was invited and that kind of thing at the White House was
ever shared with the DNC about who was invited to various events. Like
information from the White House database was ever referred to or
shared with anyone at the DNC to your knowledge?
Answer. No, not to my knowledge.
Question. Okay. Because we have just been discussing the Back-to-
Business matters and I did want to show--this is a December 8th, '95,
phone message from Mr. Chung to Evan Ryan about wanting to get cleared
into the White House, saying he's on his way to the DNC and he wants to
talk to you. This was the day before, apparently, that he says he got
the call from Lynn Cutler.
So I just wanted to see if that refreshes your recollection at all
in terms of whether he had been at the White House, if there was ever
any discussions with him about Lynn Cutler might call or, you know, his
presence at the White House at or around the time he says he was
contacted by Mr. Cutler--I mean Ms. Cutler?
Answer. No. Says, ``To Evan.''
Question. Yes, the message is to Evan Ryan, not to Ms. Williams.
Answer. Okay.
Ms. Comstock. We have another message that's somewhere around there
but it's unclear, so I'm not going to bother with you it.
I'll make this 12/8/95 Deposition Exhibit No. 48.
[Williams Deposition Exhibit No. 48 was marked for identification.]
Ms. Comstock. Let me just take a minute here. I think I may be
done.
EXAMINATION BY MS. COMSTOCK:
Question. Okay. Were you aware of Mr. Chung contributing to any
other groups connected with the President or First Lady, any political
groups?
Answer. No.
Question. Were you aware of him contributing to any legal defense
funds of any White House employees or anybody else?
Answer. No. No, no. I don't know if he contributed to the
President's legal defense fund, but those records are public.
Question. Those are public. I was wondering if you have any
knowledge of any people at the White House or anything like that?
Answer. No. Not mine.
Question. Are you aware of any attempts by Mr. Chung to contact
individuals in the Vice President's office?
Answer. No.
Question. Were you aware of Mr. Chung attempting to try and get
some credential letters from the President for a trip to China?
Answer. No.
Question. Did you ever hear anything about----
Answer. Credential letters?
Question. I guess it's----
Mr. Dennis. Letters of introduction?
EXAMINATION BY MS. COMSTOCK:
Question. It's national security type of lingo. A letter to use
when he's traveling to China or traveling overseas to----
Answer. No.
Question [continuing]. Show some bona fides of who he's connected
to or anything like that?
Answer. No, I don't recall that.
Question. Did you ever learn of Johnny Chung talking about efforts
that he was making to get Harry Wu, the human rights activist, released
from prison in China?
Answer. Yes, at my last deposition.
Question. You had no knowledge of that at the time back in--I
believe it was 1995?
Answer. I thought--I thought I'd heard something about it, but I
was unable to distinguish. I mean, they showed me something, and I
thought, oh, maybe I did hear about this, but I was unable to
distinguish when.
Question. In other words, was it live or Memorex?
Answer. Yes.
Question. Do you recall anybody at the time, anybody from the NSC,
raising what is he doing now?
Answer. No.
Question. There were concerns about Jimmy Carter going to Haiti,
which is probably less concern about, but did you ever hear, what is
Johnny Chung up to----
Answer. No.
Question [continuing]. Going to China and trying to say he has the
President's----
Answer. No, I did not.
Question. The only knowledge you have, you aren't able to
distinguish?
Answer. I'm not able to distinguish.
Question. Okay. Have you ever had anyone request any kind of
credential letters for foreign travel from your office? Do you have any
knowledge of what office that goes through?
Answer. Or what they would be. I've never heard of such a thing.
Question. When is the last time you have been in touch with Mark
Middleton?
Answer. I don't--I don't know. I--I don't know. Probably not since
his name has been in the newspaper.
Question. Were you aware of him doing any type of fund-raising
overseas?
Answer. No, I didn't--I didn't know what his business was.
Question. Did you have any knowledge about him doing any fund-
raising in the '96 campaign cycle?
Answer. No, no. No, I don't. Huh-uh.
Question. Did you have any knowledge of him providing any lists of
supporters to anybody at the White House or the DNC?
Answer. Not that I know of, no.
Question. I don't want the record to be unclear. We had a memo
earlier today that discusses him providing lists, but I think you
answered about your knowledge of that, so I don't want that to be
confused.
And can you place your last contact with Johnny Chung in time? At
all? The past year? Or----
Answer. Oh, God, I don't know. I don't know.
Question. Were you aware of him trying to contact the White House
as various fund-raising stories started coming out in the fall of '96?
Answer. No.
Question. There are a number of phone messages in November of '96
that he made phone calls to Richard Sullivan at the DNC. Do you know if
he ever tried to contact anybody at the White House about anything?
Answer. Oh, no.
Question. And to your knowledge has he tried to----
Answer. Contact me? No, no.
Question. Or contact anybody prior to news reports about him?
Answer. No, not that I know of.
Question. Okay. And do you know Roger Tamraz? Have you ever met him
or know anything about him?
Answer. No, I don't know him. But in my last deposition, it was
brought to my attention that I was at the same party he was at once,
but I don't remember him. I couldn't recognize him.
Question. That being an event in the residence with 20 or so people
or something like that?
Answer. I forget what it was, but----
Question. June of '96?
Answer. I forget the date, but they said I was at the same party
that he was at, and I agreed that I was at that party.
Question. Okay. So you did attend that event. You don't recall
anything about Roger Tamraz?
Answer. No, huh-uh.
Question. And do you have any knowledge about Roger Tamraz trying
to make contributions to the DNC?
Answer. No, I don't know who he is or what he's done. I don't know
anything about him.
Question. And do you have any knowledge about any particular fund-
raising that went on for the President's birthday party of last year,
of August of '96?
Answer. Particular fund-raising?
Question. Any people who were involved as cochairs of events or any
people that you dealt with?
Answer. I certainly know about it. My participation in the
President's birthday event was to make sure that--that the
entertainment would be wholesome.
Question. And were you able to attend that event?
Answer. No, I did not attend that event.
Question. So you did not run into Charlie Trie or Johnny Chung or
any of those people at that event?
Answer. No, I did not.
Question. I believe that's all I have at this time.
Answer. Thank you.
Mr. Ballen. I'll need a moment before I begin.
The Witness. Okay.
[Recess.]
EXAMINATION BY MR. BALLEN:
Question. Ms. Williams, I'd like to begin by thanking you. It is
now 10 after 8:00 in the evening. This deposition began at 10 o'clock.
We have gone pretty much straight. We have had three 10-minute breaks
and several much shorter breaks so that people could use the
facilities.
Your patience has been extraordinary. Any fair-minded observer
would see that you have made every possible human effort to answer
questions fully and completely and to wrack your memory.
What's not reflected in the record, because it's just going to be a
bare bones record of a transcript, is how when you were asked in
excruciating detail about certain issues that, frankly, were a very
small part of your duties you would think very hard and your facial
expressions would show that you were trying to the best of your human
ability to find an answer. And I want the record to reflect your
extraordinary effort today. And I don't think anyone in this room would
disagree with that.
And I think that's important to note for the record because records
are cold things. They don't have human emotions or the human expression
in them. And I think that you have made every possible effort here
today.
You have had a very fine record of public service, both with this
administration and prior to that, and your patience here has been
extraordinary.
I also would like to note for the record that at no time was the
Minority ever consulted with by the Majority as to how much time we
would have to question or when we could fit that into the schedule and
what would be appropriate. And so I'm very hesitant to ask you any
questions to keep you one moment longer here.
Ms. Comstock. I think--for the record, I think we have always had
very, very brief Minority questions except on rare occasions. So I'm
sorry for perhaps assuming that. But there usually hasn't--there has
been very few, if any, Minority questions. But in the future we will be
happy to consult you on time.
Mr. Ballen. That would be a decided shift from past practice,
because we have not been consulted as to when we may want to ask
questions or what topics or how long we might have.
Ms. Comstock. I think the record will reflect the interest of the
Minority in asking questions.
Mr. Ballen. Are you representing that we were consulted prior to
this deposition as to what questions we might have?
Ms. Comstock. You never asked to discuss it.
Mr. Ballen. Was the--did the Majority consult with the Minority as
to what questions we might have?
Ms. Comstock. Did the Minority ask the majority to consult? Let's
don't waste the witness' time.
Mr. Ballen. You don't talk about wasting the witness' time when you
sit here reading documents. You never consulted about our time. You
began this deposition talking about Johnny Chung being the subject
matter of the deposition. That didn't begin until 4:45, almost 7 hours
into the deposition. This witness was dragged through extraneous
matters in great detail before you even got to the main matter.
The Minority was never consulted as to--and I repeat--never
consulted at any time as to what questions it may want to have for the
witness. And, you know, it's just----
To say that what we've asked in the past with different witnesses
is totally irrelevant to that fact that we were never consulted and the
timing of this was never consulted and the scope went on and the
witness' patience with this process--frankly, if I were the witness--I
mean, I'm just astounded by her extraordinary patience.
EXAMINATION BY MR. BALLEN:
Question. In that regard, Ms. Williams, I'd like to ask a couple of
questions. This is not the first time you have had to testify about
these matters, is it?
Answer. No.
Question. Did you testify in a deposition in the Senate?
Answer. Yes, I did.
Question. How long did that deposition last?
Answer. 6:30----
Mr. Dennis. 10:30 to 6:30. Something like that.
EXAMINATION BY MR. BALLEN:
Question. 10:30 to 6:30? Any other investigative bodies?
Answer. One night at 8 p.m. the FBI came to my door and questioned
me about it.
Question. Did these questions, Senate and the FBI, substantially
overlap with the kind of questions that you received today?
Answer. Yes.
Question. And you spent time preparing for this deposition and the
Senate deposition; is that a correct assumption?
Answer. Yes.
Question. And can you estimate how much time you spent preparing
for depositions and collecting documents and----
Answer. I only keep time in billing hours. I'm sorry.
Question. But apart from the time, let me ask you this question:
There's an element of worry and stress and concern, is there not? I
mean, I know you are working hard to answer each question diligently,
but there's a stress factor involved in this, isn't there?
Answer. There's always a stress factor involved in anything where
there is an investigative body involved. Yes.
Question. You mentioned the billing hours. Have you incurred
expenses in the nature of all these requests that you have received and
testimony that you have given?
Answer. Yes.
Question. Can you estimate how much expenses have been involved?
Answer. On this particular investigation, I don't know. On all of
them, a little more than a quarter of a million dollars.
Question. A quarter of a million dollars?
Answer. A little more than that.
Mr. Dennis. That's probably conservative.
EXAMINATION BY MR. BALLEN:
Question. That's probably conservative? That's a substantial
burden, is it not?
Answer. If it is you don't have any money at all.
Question. Not only is there a huge expense involved, but there's
the time and the effort; is that fair to say?
Answer. I'd say that's fair.
Mr. Ballen. I have nothing further. Thank you.
Mr. Dennis. Thank you.
Ms. Comstock. I just want--let the record reflect that on a number
of occasions, on Mr. Ickes' documents and some of the other matters, we
did confer--sometimes off the record, sometimes on--as to whether or
not the witness had particular knowledge on that. And we did--we
shortened, I think, a number of Mr. Ickes' documents. Even though the
witness had been cc'd on a lot of them, we spent a fairly brief amount
of time on that. So there were certainly attempts on the Majority's
side to shorten the areas that may have previously been gone over and
the witness did not have knowledge about. So----
Mr. Ballen. No, I completely disagree.
Ms. Comstock.--I appreciated the witness' counsel in assisting us
with that, because it made it helpful and able to discuss with him
those matters so that we could shorten sometimes a number of different
areas we discussed.
Mr. Ballen. I am going to, for the record, completely disagree with
that characterization. There was one moment, after 20 minutes of
questioning on the documents the witness knew nothing about, at
counsel's request we went off the record and counsel off the record
said, is it really necessary to continue questioning on documents this
witness is unfamiliar with? Because she's going to repeatedly give ``I
don't know'' answers to them, and----
Ms. Comstock. Is that your characterization of what we----
Mr. Ballen. Can I finish my sentence?
Ms. Comstock. That is not what I said. I asked the witness if there
was knowledge on particular matters or if we could shorten things. I
don't think characterizing or mischaracterizing what I said is
necessary at this point. Why don't we just end the deposition?
Mr. Ballen. No, no, I'm not finished. I was interrupted in the
middle of a sentence. I've never had the discourtesy to interrupt the
Majority counsel in the middle of her sentence.
Ms. Comstock. Only to interrupt entire questions.
Mr. Ballen. There, you just did it again. And that is not what
occurred off the record, and the record should reflect that is not what
occurred. What occurred is that after 20 minutes of questioning on
Harold Ickes' documents the witness didn't know about, we went off the
record and counsel----
Ms. Comstock. The witness did have some testimony on those things,
and I think the record will reflect it. And I don't think you need to
characterize her knowledge or the lack thereof. The record will speak
for itself.
[Whereupon, at 8:24 p.m., the deposition was concluded.]
[The exhibits referred to follow:]
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[The deposition of Evan Ryan follows:]
Executive Session
Committee on Government Reform and Oversight,
U.S. House of Representatives,
Washington, DC.
DEPOSITION OF: EVAN RYAN
Wednesday, August 20, 1997
The deposition in the above matter was held in Room 2203, Rayburn
House Office Building, commencing at 2:45 p.m.
Appearances:
Staff Present for the Government Reform and Oversight Committee:
Jennifer Safavian, Investigative Counsel; Edward Eynon, Investigative
Counsel; David Bossie, Oversight Coordinator; Barbara Comstock, Chief
Investigative Counsel; James C. Wilson, Senior Investigative Counsel;
Kenneth Ballen, Minority Chief Investigative Counsel; Andrew J.
McLaughlin, Minority Counsel; Kristin Amerling, Minority Counsel.
For EVAN RYAN:
BILL LAWLER, ESQ.
Vinson & Elkins
1455 Pennsylvania Avenue, N.W.
Washington, D.C., 20004
THEREUPON, EVAN MAUREEN RYAN, a witness, was called for examination by
counsel, and after having been first duly sworn, was examined and
testified as follows:
Ms. Safavian. Good afternoon, Ms. Ryan. On behalf of the members of
the Committee on Government Reform and Oversight, I appreciate and
thank you for appearing here today.
This proceeding is known as a deposition. The person transcribing
this proceeding is a House reporter, and although he is not a notary
public, you were just sworn in by a notary public and were placed under
oath.
I would like to note for the record those who are present at the
beginning of this deposition. I am Jennifer Safavian, the designated
Majority counsel for the committee. I am accompanied today by Edward
Eynon, who is with the Majority staff. Andrew McLaughlin is the
designated Minority counsel for the committee, and Mr. McLaughlin is
accompanied by Ken Ballen, who is also with the Minority staff. And the
deponent is represented by Bill Lawler.
Although this proceeding is being held in a somewhat informal
atmosphere, because you've been placed under oath, your testimony here
today has the same force and effect as if you were testifying before
the committee or in a courtroom. If I ask you about conversations you
have had in the past and you are unable to recall the exact words used
in the conversation, you may state that you are unable to recall those
exact words and then you may give me the gist or the substance of any
such conversation to the best of your recollection. If you recall only
part of a conversation or only part of an event, please give me your
best recollection of those events or parts of conversation that you
recall. If I ask you whether you have any information upon a particular
subject and you have overheard other persons conversing with each other
regarding it or have seen correspondence or documentation regarding it,
please tell me that you do have such information and indicate the
source, either a conversation or documentation or otherwise from which
you've derived such knowledge.
Before we begin the questioning, I want to give you some background
about the investigation and your appearance here. Pursuant to its
authority under House Rules X and XI of the House of Representatives,
the committee is engaged in a wide-ranging review of possible political
fund-raising improprieties and possible violations of the law.
Pages 2 through 4 of House Report 105-139 summarizes the
investigation as of June 19, 1997, and encompasses any new matters
which arise directly or indirectly in the course of the investigation.
Also, pages 4 through 11 of the report explain the background of the
investigation. All questions related either directly or indirectly to
these issues, or questions which have a tendency to make the existence
of any pertinent fact more or less probable than it would be without
the evidence, are proper.
The committee has been granted specific authorization to conduct
this deposition pursuant to House Resolution 167, which passed the full
House on June 20, 1997. Committee rule 20, of which you have received a
copy, outlines the ground rules for the deposition.
Majority and Minority committee counsels will ask you questions
regarding the subject matter of the investigation. Minority counsel
will ask questions after Majority counsel has finished. After the
Minority counsel has completed questioning you, a new round of
questioning may begin. Members of Congress who wish to ask questions
will be afforded an immediate opportunity to ask questions. When they
are finished, committee counsel will resume questioning.
Pursuant to the committee's rules, you are allowed to have an
attorney present to advise you of your rights. Any objection raised
during the course of the deposition shall be stated for the record. If
the witness is instructed not to answer a question or otherwise refuses
to answer a question, Majority and Minority counsel will confer to
determine whether the objection is proper. If Majority and Minority
counsels agree that a question is proper, the witness will be asked to
answer the question. If an objection is not withdrawn, the chairman or
a member designated by the chairman may decide whether the objection is
proper.
This deposition is considered as taken in executive session of the
committee, which means it may not be made public without the consent of
the committee. Pursuant to clause 2(k)(7) of House rule 11. You are
asked to abide by the rules of the House and not discuss with anyone
other than your attorney this deposition and the issues and questions
raised during this proceeding.
Finally, no later than 5 days after your testimony is transcribed
and you have been notified that your transcript is available, you may
submit suggested changes to the chairman. The transcript will be made
available for your review at the committee office.
Committee staff may make any typographical and technical changes
requested by you. Substantive changes, modifications, clarifications,
or amendments to the deposition transcript submitted by you must be
accompanied by a letter requesting the changes and a statement of your
reasons for each proposed change. A letter requesting any substantive
changes, modifications, clarifications, or amendments must be signed by
you. Any substantive changes, modifications, clarifications, or
amendments shall be included as an appendix to the transcript,
conditioned upon your signing of the transcript.
Do you understand everything we've gone over so far.
The Witness. Yes.
Ms. Safavian. Do you have any questions about anything we've gone
over so far?
The Witness. No.
Ms. Safavian. I will be asking you questions concerning the subject
matter of this investigation. Do you understand that?
The Witness. Yes.
Ms. Safavian. If you don't understand a question, please say so and
I will repeat it or rephrase it so that you understand the question. Do
you understand that you should tell me if you do not understand one of
my questions?
The Witness. Yes.
Ms. Safavian. The reporter will be taking down everything we say
and will make a written record of the deposition. You must give verbal,
audible answers because the reporter cannot record a nod of the head or
other gestures. Do you understand that you cannot answer uh-huh or uh-
uh?
The Witness. Yes.
Mr. Lawler. She'll even try to abide by that.
Ms. Safavian. I will, too. How is that?
If you cannot hear me, please say so and I will repeat the question
or have the court reporter read the question to you. Do you understand
that?
The Witness. Yes.
Ms. Safavian. Please wait until I finish each question before
answering and I will wait until you finish your answer before I ask the
next question. Do you understand that this will help the reporter make
a clear record because he cannot take down what we are both saying at
the same time?
The Witness. Yes.
Ms. Safavian. Your testimony is being taken under oath as if we
were in court. If you answer a question, it will be assumed that you
understood the question and the answer was intended to be responsive to
it. Do you understand that?
The Witness. Yes.
Ms. Safavian. Are you here voluntarily or are you here as a result
of a subpoena?
The Witness. Voluntarily.
Ms. Safavian. Do you have any questions about the deposition before
we begin the substantive portion of the proceeding?
The Witness. No.
Mr. McLaughlin. I have two notes for the record. First, it has been
the practice that deposition transcripts are available for your review
by mail upon agreement of the Minority and Majority counsel.
Mr. Lawler. That's fine.
Mr. McLaughlin. The second thing, that pursuant to House rule 11
2(k)(8) objections, as to pertinency and relevance, are ruled upon by
the committee. Accordingly, objections that are ruled upon by the chair
are appealable to the full committee.
Mr. Lawler. Okay.
Mr. McLaughlin. That's all I have.
EXAMINATION BY MS. SAFAVIAN
Question. Ms. Ryan, can you please state your full name and spell
it for the record?
Answer. Evan Maureen Ryan, E-V-A-N, M-A-U-R-E-E-N, and Ryan is R-Y-
A-N.
Question. Have you ever used or been known by any other names?
Answer. No.
Question. What is your date of birth and social security number?
Answer. [Redacted].
Mr. McLaughlin. I'm going to object to the social security number.
That's not relevant to the investigation.
EXAMINATION BY MS. SAFAVIAN:
Question. Please continue. Your social security number?
Mr. Lawler. We don't have any objection to that.
The Witness. [Redacted].
EXAMINATION BY MS. SAFAVIAN:
Question. And what is your current address?
Answer. [Redacted].
Question. How long have you lived there?
Answer. Since the end of May of '97.
Question. Where did you live prior to that?
Answer. [Redacted].
Question. Have you ever lived outside the United States?
Answer. I studied in London for a semester during college.
Question. And when was that?
Answer. That was the spring of '92.
Question. And so as you just mentioned, you did attend college.
Answer. Yes.
Question. Where did you attend?
Answer. Boston College.
Question. And when did you graduate?
Answer. May of '93.
Question. Can you tell me what your degree was in?
Answer. Political science.
Question. Did you receive any other degrees or go on to any
graduate school?
Answer. No, I haven't.
Question. Have you spoken with anyone other than your counsel about
this deposition today?
Answer. No.
Question. Have you spoken with anyone on the committee about the
deposition today?
Answer. No.
Question. Did you review any documents in preparation for this
deposition?
Answer. One or two.
Mr. Lawler. As you know, Ms. Ryan was deposed by the Senate
committee 2, 3 weeks ago.
The Witness. Yes.
Mr. Lawler. There were exhibits used during that deposition. We
reviewed some of those before we came over today.
Ms. Safavian. Some of the ones that were used in the Senate
deposition?
Mr. Lawler. Yes. I guess some that we were given that weren't
actually used as exhibits as well.
Ms. Safavian. Can you tell me a little bit more about those
exhibits?
Mr. Lawler. Frankly, we would assert privilege. If it's anything
relevant. I mean, she reviewed some exhibits. If you want to ask
whether they relate to any particular area or relate to any of your
questions, I think that's appropriate.
EXAMINATION BY MS. SAFAVIAN:
Question. Can you tell me, is there any way for you to clarify as
to what subject or what area these documents were that you reviewed?
Did you review these this morning, today?
Answer. Today.
Question. You reviewed them today?
Answer. Yes.
Mr. Lawler. Not even all. The only things she reviewed today was a
package of telephone messages, sheets from message pads.
EXAMINATION BY MS. SAFAVIAN:
Question. Message slips to you, I assume, or from you?
Answer. Some were to me. Some were to other people in the office.
Question. And that's pretty much it?
Answer. That's it.
Mr. Lawler. There were other things we used as exhibits in the
Senate deposition.
EXAMINATION BY MS. SAFAVIAN:
Question. But that was all that was reviewed for this deposition?
Answer. Yes.
Question. Have you been asked by White House counsel or somebody
else to collect documents with regard to the House, Senate, or the
Department of Justice subpoenas?
Answer. They issued memorandums from White House Counsel's Office
that were document requests, so they were pertaining to these
investigations.
Question. These were memorandums that went to----
Answer. All White House staff, yes, all White House staff.
Question. Did everyone get the same memo?
Answer. Yes.
Question. And this was from the counsel for the White House?
Answer. Yes.
Question. Can you tell me what that memo said? I mean not verbatim.
Answer. Yes. I don't know exactly. To look through phone records,
calendars, files, any paper with--and then there would be a list of
what names were relevant and what names should be searched for.
Question. Can you tell me, when did that memorandum come out or
when did you receive it?
Answer. I don't know quite exactly when it came out.
Question. Can you give me an idea? A couple of months?
Answer. Yes, a couple of months ago. Not terribly recently.
Question. Do you remember who drafted the memorandum, who it was
from?
Answer. I remember it was White House counsel. I don't remember
which member White House counsel signed it.
Question. Was it just from one individual?
Answer. I don't remember. It was probably from Charles Ruff. But I
don't remember. I remember White House counsel.
Question. Did the memorandum, was it just asking for all these
documents with regard to both, the House, the Senate, and the
Department of Justice subpoenas or were there different ones issued for
each different subpoena?
Answer. There were separate memos for each subpoena.
Question. So you are aware that there was a distinction between
these subpoenas?
Answer. Yes.
Question. So then I assume that each memo, what you were looking
for varied with regard to each subpoena?
Answer. I remember in each of these memos, they would say pursuant
to the House committee, or pursuant to the Senate committee. That's my
only recollection of how I know that they were separate.
Question. Besides getting this memorandum from the White House
counsel, was there anybody else that directed you or provided you with
any other information in which to collect these documents?
Answer. Anyone else that asked for the documents?
Question. Was there anybody else in your office or anybody else
besides White House counsel who asked you to do a search for these
documents?
Answer. I'm not quite sure I understand the question. We each
received these documents and then we would work with different members
of the staff to go through for the search, to actually search the files
or to search the calendars. So I'm sure I spoke with different people
about the actual searches.
Question. What I was just trying to get at is besides the White
House counsel memorandum that you received, did anybody else in the
office where you work supervise the collection of these documents and
also instructed you how to collect these documents or was it just the
memorandum from the counsel?
Answer. I don't really--I am now in a different job than I was 6
months ago. When I worked in the First Lady's office, in the main
office area, I worked with the chief of staff in terms of collecting
the documents. In the job I'm in now, I'm in the scheduling office; I
worked with the director of scheduling in terms of finding the
documents and where we should look.
Question. So you have been involved with looking for documents in
two different areas?
Answer. Yes.
Question. In two different jobs?
Answer. Yes.
Question. Do you recall if you were asked--well, I guess, tell me,
what did they tell you to do? Did they ask you to look through file
cabinets, all documents?
Mr. Lawler. ``They'' meaning the memos?
EXAMINATION BY MS. SAFAVIAN:
Question. I'm sorry, the memorandum, yes.
Answer. Any paper. They just asked to--any sort of paper that was
kept or that is around with any of the names.
Question. Did you also look through computer records?
Answer. Yes.
Question. You were asked to do that, also?
Answer. Yes.
Question. And then can you tell me, was there a process after going
through the documents and you found something that you thought was
relevant to the White House counsel memorandum, what did you do, what
was the process?
Answer. I think I worked directly with White House counsel on that.
I think the process was to Xerox the information and put it in a
folder, an envelope, and give it to the White House counsel member who
was assigned. The White House counsel usually assigned a White House
counsel staff person who followed up with you to make sure that the
search was going on and that you were searching documents, and so I
would contact that person and give them the relevant information.
Question. And who would that person have been for you?
Answer. It varied. Usually it depended on each memo. I think they
just assigned people----
Question. When you say ``each memo,'' you mean the House memo,
Senate memo?
Answer. Yes. I think so. I don't know. I think so. I mean, I don't
know if maybe, if the search was the same, they had one person assigned
to the same search or not. I don't remember.
Question. Did you generally deal with then three different people,
one for each subpoena?
Answer. I dealt with several staff members and White House counsel
regarding document requests. I've been there now for about 3\1/2\ years
so I've dealt with several staff members on several searches.
Question. So you would collect these documents and then you would
give these copied documents to the assistant and that person--what
would happen next?
Answer. I don't know what happened with the documents from that
point on.
Question. That was the end of what you had to do with it?
Answer. Yes.
Question. Did you work with anybody else in collecting the
documents? I mean, was it like a team of people?
Answer. I did insofar as I checked with other First Lady staff
members to make sure they had checked their own personal files, papers,
records, phone logs. I responded usually on behalf of the office that
the whole office had made their search.
Question. I see. So you were responsible pretty much for looking
through your own documents and your own paper?
Answer. Yes.
Question. And not anybody else's?
Answer. I also looked through the chief of staff's phone logs,
calendars, et cetera, and helped with her search.
Question. Would those be things that were normally kept in your
possession?
Answer. Some were in my office and some were in her office.
Question. That was just something that you were helping out with?
Answer. Well, I was her assistant, so it was part of my duties, so
to speak.
Question. So other than your own and the chief of staff's, did you
go through anybody else's documents?
Answer. No.
Question. Do you recall if you were given a date as to when these
documents were supposed to be reviewed and turned over to the White
House counsel?
Answer. Yes. I don't recall the specific date, but I remember that
there were always dates on those memos.
Question. Did they provide you with enough time to go through the
documents?
Answer. I think so. I think it usually varied. I don't know if
there was usually a 7-day period or how long the period was. I just
remember there were usually dates by which point you were supposed to
have responded to the White House Counsel's Office.
Question. Did you usually complete your search by that date?
Answer. Yes.
Question. Did most people usually complete the search by that date?
Answer. As far as I know.
Question. After you collected the documents and you would hand them
over on the assistant, did you then ever sit down with the assistant
and go through the documents?
Answer. No.
Question. They never asked you about any of the documents?
Answer. Not that I remember, no.
Question. Do you plan on speaking with White House counsel after
this deposition today?
Answer. No.
Question. Moving on to something else. Ms. Ryan, can you briefly
describe to me your employment history after college?
Answer. In September of '93, I started working at the Corporation
for Public Broadcasting in their Office of Correspondent
Communications. I was there until December of '93, and then I began in
January of '94 as a White House intern in the Office of the First Lady.
In September of '94, I started on the staff of the First Lady's office.
Question. That was September of '94?
Answer. Yes.
Question. And can you tell me, how is it that you even got the
intern job in January of '94?
Answer. In the fall of '93, I applied to the White House internship
program and was accepted in late fall, and then started in January.
Question. Did you tell me you were an intern for the First Lady's
office?
Answer. Yes.
Question. And what did you do as an intern for the First Lady's
office?
Answer. Answered phones, drafted correspondence, distributed mail,
filed documents, updated the filing system. General intern-type duties.
Question. Were you assigned to any one person to assist them or
just kind of everybody?
Answer. I worked for the Special Assistant to the chief of staff
and the chief of staff.
Question. Just those two individuals?
Answer. Mainly. But they worked out of the main First Lady's office
area. So we received all of the general public--the main phone calls to
the First Lady's office came through that office as well as the mail.
We were kind of at the center point of the office.
Question. Where were you located while you were an intern?
Answer. In Room 100 of the Old Executive Office Building.
Question. And they were over in the White House?
Answer. No, they worked in Room 100 as well.
Question. They worked in Room 100 also. Okay. Can you tell me the
names of those two individuals?
Answer. The special assistant to the chief of staff at the time was
Diane Lemo. And chief of staff to the First Lady was Maggie Williams.
Question. And then you told me you became a staff member in
September of '94?
Answer. Yes.
Question. Do you remember when in September?
Answer. Late September.
Question. How did that happen? Were you approached about that?
Answer. Diane Lemo, the woman who I had been working closely with
as an intern, I had worked with her as an intern for 8 months, she got
a new job, and I had learned a lot of the ropes through Diane and so I
was offered her job.
Question. Did Diane leave to--did she leave the White House or did
she take another job in the White House?
Answer. She started working for the Office of Management and
Budget.
Question. Obviously you accepted the job. Did you have to go
through an interview process or anything?
Answer. I don't remember--I don't really remember it. I don't know.
I remember it was--Diane had begun looking for a new job sometime in
the summer, so I remember it was a long period where Diane was trying--
she kind of was training me and passing a lot of stuff on to me. I
don't remember there ever being any formal interview type of process.
Question. Did you speak with Maggie Williams about taking that job?
Answer. She was the one that offered me the job, yes.
Question. And you're still with the First Lady's office today--no,
I'm sorry, you told me you recently left. And where are you now?
Answer. I am now the deputy director of scheduling for the First
Lady, which is in the Office of Scheduling and Advance Staff.
Question. And where is your office located now?
Answer. It's in Room 185 1/2 of the Old Executive Office Building.
Question. 185 1/2?
Answer. Yes.
Question. Where was your office located as the special assistant
for the chief of staff?
Answer. Room 100 of the Old EOB.
Question. Where was the chief of staff's office during this time?
Answer. Room 100 of the OEOB consists of three rooms. The main area
where the door from the hallway is, off to the left of that room is the
conference room, off to the right of that room is the chief of staff's
office.
Question. And you were?
Answer. In the middle.
Question. In the middle?
Answer. Yes.
Question. Is that where people would enter?
Answer. Yes.
Question. The reception area?
Answer. Yes.
Question. Was there anybody else in the Room 100 area?
Answer. Volunteers and interns sat in the main reception area as
well as me.
Question. Can you tell me a little bit about the First Lady's
office? Because I understand it's divided up. First, you're over at the
Old Executive Office Building and so is the chief of staff. Who else is
over there?
Answer. Most of the staff is in the Old Executive Office Building.
The Executive Assistant to the First Lady is in the West Wing, Mrs.
Clinton's office is in the West Wing, the Social Office is in the East
Wing, and that's about it.
Question. Otherwise, everybody else is----
Answer. Most everyone is in the Old Executive Office Building.
Question. Did the chief of staff have another assistant besides
you?
Answer. Yes.
Question. Who was that?
Answer. When I started it was Evelyn Lieberman, and then it was
Marge Tarmey, then it was Debbie Both, and then it was Peggy Lewis.
Question. Who is it now?
Answer. Melanne Verveer is currently the chief of staff and her
assistant is Katie Button.
Question. How long was Debbie Both the assistant to the chief of
staff?
Answer. Debbie Both, I believe was the assistant to the chief of
staff 8 months perhaps.
Question. Do you know when her term started?
Answer. I seem to remember that it started in June of '95. I think.
I think either May or June of '95. And I think she was there until
around February, but I don't really remember.
Question. And how about Peggy Lewis, when she would have started?
Answer. She started then at around, February of '96, I think. And
was there until April of '97, late March, early April.
Question. Can you tell me as the special assistant to the chief of
staff, what were your job duties or responsibilities?
Answer. General assistant-type responsibilities. I kept track of
the chief of staff's calendar, her phone messages, her phone log, her
correspondence, oversaw the drafting of her correspondence, helped keep
track of the filing system, served kind of as the main contact for the
staff in terms of just general staff information. That's all I can
really think of in terms of a specific description.
Question. Can you distinguish for me the difference between your
job duties and responsibilities and that of the assistant to the chief
of staff?
Answer. The assistant to the chief of staff, I think, had more
project-oriented work with the chief of staff, where I think I was more
assistant-type duties. The assistant to the chief of staff also
served--I was a point of contact for the staff in terms of letting
people know we're having a staff meeting or get your vacation time in
at this point, but the assistant to the chief of staff served the
function of dealing with the staff on more substantive issues, if
someone was working on a project or, for instance, the director of the
Correspondence Office usually reported to the assistant to the chief of
staff in terms of correspondence issues for the First Lady.
The Social Office would report to the assistant to the chief of
staff in terms of updating the chief of staff on Social Office updates
and stuff like that. So they served in a slightly different capacity I
think.
Question. Can you tell me, who was your immediate supervisor then?
Answer. I pretty much reported directly to Maggie Williams, purely
because of the fact that I was there through the duration and there
were different assistants in and out.
Question. Would the assistant have been in a supervisory role over
you?
Answer. Yes, I suppose. But it never really seemed like that,
mostly because honestly I was there longer and so they usually--it was
more of a team relationship just because of the fact I think I had been
there and just in general information type of sense. But we generally
worked pretty separately on different things, so I worked with Maggie
on certain things and the assistant would work with her on other
things.
Question. And when did you tell me you recently left as assistant
chief of staff?
Answer. I started this job in late March of '97.
Question. With your office in the Old Executive Office Building,
were you at the White House very often?
Answer. It would depend. If I were delivering something or picking
something up or going to a meeting, then I would be in the White House.
Other than that, no.
Question. Did you ever assist--I know you mentioned organizing
staff meetings. Did you ever assist in organizing senior staff
meetings?
Answer. Yes.
Question. What did you do? How did you go about doing that?
Answer. I would find a time that worked with everyone in terms of--
I would set up meetings. That was a typical duty of mine. Just in terms
of finding the time when everyone could do it on a certain day and
finding the people. I would just call other people's assistants and set
it up through that manner.
Question. And who would normally be included in those senior staff
meetings?
Answer. Senior staff meetings in the First Lady's office? The chief
of staff, the deputy chief of staff, the social secretary, the press
secretary, the director of scheduling. I think that's about--and the
speech writer perhaps.
Question. Did you plan any other senior staff meetings besides
those in the First Lady's office?
Answer. I took care of setting up a lot of different meetings. I
would set up meetings--any meeting that Maggie was involved with. I
wouldn't always set up, but I would also respond to people's calls who
wanted to set up meetings.
Question. Would you generally always be notified if Maggie Williams
had a meeting with somebody else or they wanted a meeting with her?
Answer. Generally, yes.
Question. They would go through you?
Answer. Yes.
Question. Did you ever attend any of these senior staff meetings?
Answer. No.
Question. Did anyone ever go and just take notes?
Answer. Generally, no. No.
Question. Did you ever attend--besides regular staff meetings, did
you ever attend any other meetings with Ms. Williams?
Answer. Generally, no. She pretty much went to meetings on her own.
Question. Did the assistant to her chief of staff go?
Answer. They both went to the resident's meetings, which were the
meetings that kind of kept track of the Social Office, and what was
going on in the actual White House in terms of events, both the
assistant to the chief of staff and Maggie would attend those meetings,
but those are the only ones I think that the assistant attended, a
meeting with her.
Question. Only the resident's meetings?
Answer. I think so.
Question. How often did those occur?
Answer. Those were weekly.
Question. Do you know who generally would attend that?
Answer. I think the President's schedulers, the First Lady's
scheduler, the social secretary, and the chief of staff, Maggie
Williams, and the assistant.
Question. Do you know if Maggie Williams had a practice of taking
notes during meetings?
Answer. I don't know. I was--I can hardly remember ever being at a
meeting other than staff meetings, big staff meetings, with her. So I
don't know, and she never gave me notes, so I don't know.
Question. She never gave you notes to type up?
Answer. To file or type up, exactly.
Question. Do you know if Ms. Williams, did she type her own letter
or memoranda or was that one of your duties?
Answer. Her correspondence was typed usually by the interns in the
office. Memorandums, she sometimes typed them herself. Sometimes I
would type them.
Question. When you would type them, would she give you handwritten
notes of what she wanted or did she dictate the memorandum to you?
Answer. I don't really remember. I don't know. I can't remember. I
don't remember dictation or anything like that.
Question. So she must have maybe handwritten it out?
Answer. Yes.
Question. Did Ms. Williams have a call list?
Answer. Yes.
Question. Did she keep the list or did you keep that list?
Answer. No. I would gather the messages generally from the outer
main office area and the list--unless the assistant to the chief of
staff was otherwise occupied and would switch it over to me, the list
was generally kept on the assistant to the chief of staff's computer.
Mr. McLaughlin. Do you want to identify your staffers who are here
now for the record?
Mr. Lawler. I'm curious.
Ms. Safavian. I was going to say, Ms. Ryan, it's up to you.
Mr. McLaughlin. No, this is just a practice. You haven't taken any
depositions before at this point. Usually just when somebody comes into
the room we stop and identify who it is.
Ms. Safavian. That is fine.
Ms. Ryan, this gentleman sitting right here is David Bossie. He's
the chief investigator with the Majority, and next to him is Jim
Wilson. I just gave you a card. He's the senior investigative counsel
with the Majority. I apologize for that.
EXAMINATION BY MS. SAFAVIAN:
Question. We were talking about the call lists and you were telling
me that the assistant to the chief of staff, it would be kept on her
computer?
Answer. Yes.
Question. Was she also the one, then, that would add the names and
update the list?
Answer. Generally, yes.
Question. Did you ever add names to the list?
Answer. I kept track of the phone messages themselves in the outer
office area so I would pass them along to her. So in that respect I
did. Or if Maggie mentioned to me she wanted someone on the list, then
I would let her know.
Question. So you would let the assistant know Maggie would like so
and so on the list and they would take care of that?
Answer. Yes.
Question. Was the call list mainly for business, or was it also
personal? Can you give me an idea of what was on the call list?
Answer. I think it was anybody that called the office for her, from
what I can remember, any messages we received for her. So they were
probably both business and personal.
Question. Ms. Ryan, I'm going to hand you this document. This is
copy of an e-mail that you sent to Peggy Lewis on May 9, 1996. Would
this be the time when she was assistant to Maggie Williams?
Answer. Yes.
Question. You're telling her that Maggie wanted John Huang's name
to be added to her call list?
Answer. Yes.
Question. Is this normally the procedure you would go through to
get names added to the call list?
Answer. Usually I would just tell her or call. I would imagine that
she was not around at the time or it wasn't on a phone message slip.
Question. Who do you mean by ``she''?
Answer. I'm sorry, Peggy Lewis.
Question. Can you tell me, do you know if there's any specific
reason why Ms. Williams wanted to add John Huang to her call list on
this specific date?
Answer. I don't know why, no.
Question. Would Ms. Williams usually tell you why she would want
someone added to a call list?
Answer. No.
Question. She would just provide you with the name and number?
Answer. Yes.
Question. It also mentions, is Chuck Supple still on the list?
Answer. Yes.
Question. Do you recall who Chuck Supple is?
Answer. No. I'm just trying to figure that out. No, I don't know.
Question. Do you know if Ms. Williams was in contact often with
John Huang?
Answer. I don't know, no.
Question. Do you recall taking messages for Ms. Williams from him?
Answer. I don't, so I would have to guess that--you know, I think I
would remember, so I don't know.
Question. Do you recall setting up meetings with Ms. Williams and
John Huang?
Answer. I don't, no.
Ms. Safavian. I was going to mark this as an exhibit. This will be
ER-1.
[Ryan Deposition Exhibit No. ER-1 was marked for identification.]
[Note.--All exhibits referred to can be found at end of
deposition.]
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Ryan, did you ever travel professionally with Maggie
Williams?
Answer. No.
Question. Would anybody? Would her assistants?
Answer. She really didn't travel much. The--most of the staff went
to the Democratic National Convention last year, but other than that,
Maggie didn't do a lot of traveling. If she did travel, she traveled on
her own.
Question. On her own, for business, she wouldn't even bring her
assistant with her?
Answer. No.
Question. Did she travel often with the First Lady?
Answer. No.
Question. Do you know if Maggie Williams would interact at all or
have any meetings with Harold Ickes?
Answer. I think so, yes.
Question. Was it often?
Answer. I don't remember how often it was or when it was. I
remember that they met, but I don't remember how frequent or if there
was any regularity to it.
Question. Would these be scheduled meetings?
Answer. I remember scheduling meetings. I don't remember when, but
I remember at some point they were definitely on the schedule.
Question. Do you recall if these meetings with Mr. Ickes were just
between Ms. Williams and Mr. Ickes or was it other people involved,
also?
Answer. Probably both, but I don't remember specifically.
Question. Do you recall the purpose behind any of these meetings?
Answer. No.
Question. Ms. Williams is no longer the chief of staff as you
already mentioned. When did she resign?
Answer. The beginning of May of 1997.
Question. Have you kept in contact with her since she's left?
Answer. Yes.
Question. How often do you speak with her?
Answer. Usually once or twice a week.
Question. Oh, really?
Answer. Uh-huh.
Question. And she's over in France; is that correct?
Answer. Not yet.
Question. Oh.
Answer. She leaves in a week or two, I think. Very soon.
Question. Do you get together for lunch?
Answer. Yes. She actually is a very close friend of mine. So I
speak with her and occasionally see her.
Question. Ms. Ryan, can you tell me, were any DNC employees working
at the White House from May 1995 through the 1996 election?
Mr. Lawler. I don't want to cut you off, but just anticipating a
following question you might want to ask her, and she can speak for
herself, she may not discuss this investigation. They keep in contact,
but Evan once this stuff came out was the first time she contacted us,
we have asked Evan not to discuss the substance of any investigation or
stories or whatever, particularly about the Johnny Chung stuff, with
Maggie, so their contacts are personal and social rather than
substantive.
Ms. Safavian. I'm sorry, were you trying to say that Ms. Williams
contacted you after the articles regarding Johnny Chung were published?
Mr. Lawler. No, no, she contacted us. Me.
Ms. Safavian. Ms. Williams contacted you?
Mr. Lawler. No, no, Evan contacted me. She's my client.
Ms. Safavian. That's why I was trying to understand that.
Mr. Lawler. Right.
EXAMINATION BY MS. SAFAVIAN:
Question. You were speaking to him about whether or not you could
talk with Ms. Williams?
Answer. They just advised me not to.
Question. And so you have not spoken to Ms. Williams?
Answer. We have not spoken about any of this, no. Personal.
Question. You didn't talk at all about Johnny Chung or anything
that was written in the newspaper articles?
Answer. She once mentioned to me that she was sorry that I was
involved in this, she was speaking of the L.A. Times article, but
that's all she said.
Question. And no further conversation on that subject?
Answer. She was inquiring as to how I was and said that she was
sorry that my name is now out there and involved and she's sorry about
that and I said, that's okay, and that was the end of it.
Question. We'll talk a little bit further about Johnny Chung, but
getting back to the DNC, do you recall if there were any DNC employees
working in the White House during the election?
Answer. I don't recall DNC. Just because of the news I know that at
one point Barbara Woolley was employed by the DNC but a volunteer at
the White House, but I'm not aware of that.
Question. I'm sorry, who was that?
Answer. Barbara Woolley. I just remember it from ABC News, but
other than that, that's my only knowledge.
Question. Ms. Ryan, I'm going to hand you another exhibit. And you
see that is a telephone message slip. It's to Maggie, who I assume is
Maggie Williams.
Answer. Yes.
Question. It's from somebody named Adam, calling from Leon
Panetta's office on May 22. From the cover sheet, you can barely make
it out but it looks like '95 to me. Do you agree?
Answer. Yes.
Question. It's talking about a meeting from 2:00 to 2:30, a half-
hour meeting on Wednesday, May 24, regarding DNC employees working at
the White House.
Answer. Yes.
Question. Do you know who took this message? Do you know who those
initials are?
Answer. I can't quite--it looks like an ``E'' and something else.
It generally would have been a volunteer or an intern, and it looks
like at 6:45--it must have been one of our evening volunteers. I would
have to go back and--I don't know. I could check volunteer logs.
Question. Do you recall scheduling this meeting for Ms. Williams?
Answer. Not specifically, no. It's possible, but I don't recall it.
Question. Do you recall--did Ms. Williams ever speak with you later
about this meeting regarding DNC employees working at the White House?
Answer. No.
Question. So as far as you know, you do not know of any DNC
employees working at the White House?
Answer. I, as I said, heard it on the news one time, but other than
that, no, I have no knowledge myself.
Ms. Safavian. We're going to go ahead and make this exhibit ER-2.
[Ryan Deposition Exhibit No. ER-2 was marked for identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Can you tell me, did you have any specific contact with
any DNC employees?
Answer. At the DNC?
Question. Yes.
Answer. Yes. I don't--I remember getting phone calls from the DNC
or returning calls or talking to people at the DNC. I didn't have a
specific person at the DNC that I spoke with, but I'm sure I spoke with
the DNC on occasion.
Question. Do you recall speaking to any one individual more often
than another?
Answer. No. I'm responding to this because I've been asked this
before. I don't. I didn't have a person that I knew to call at the DNC.
I probably was returning a phone call. There was no one person that I
would call there.
Question. If you had to call someone at the DNC, who did you decide
you would call or who do you speak to?
Answer. It would probably depend on what I was calling about, and I
think I would call the main number and asked for whichever office I
needed.
Question. How would you know which office you needed?
Answer. Depending on what it was, depending on what I was calling
about.
Question. Were you calling on behalf of Maggie Williams or somebody
else?
Answer. Oh, I don't know. I'm just speculating here.
Mr. McLaughlin. Don't speculate. The committee's not interested in
guesses or speculation. Just stick to what's in your personal
knowledge.
The Witness. I have no specific memory of contacting the DNC about
any one specific event. I can't rule out. I'm sure I talked to them,
I'm sure I did on occasion, but it's nothing that's imprinted on any
memory.
EXAMINATION BY MS. SAFAVIAN:
Question. Could you tell me, would you have contacted the DNC
because somebody asked you to?
Answer. Perhaps. But as I said, I don't remember.
Question. Was there--do you know if there was a specific liaison
between the First Lady's office and the DNC?
Answer. Not to my knowledge.
Question. Do you know whether Maggie Williams participated in any
DNC fund-raising activities during the 1996 election cycle?
Answer. Not to my knowledge.
Question. Do you know if Maggie Williams participated in any way
with the 1996 Clinton/Gore Re-election Campaign?
Answer. I don't know.
Question. Do you recall ever scheduling any meetings for Ms.
Williams regarding DNC fund-raising activities?
Answer. When I set up meetings for her, they generally weren't by
topic. They were by individuals, so I don't remember specifically, no.
Question. So you don't have any specific recollection of scheduling
a meeting for Ms. Williams with anybody at the DNC?
Answer. It's possible. I don't remember specifically.
Question. Okay. That's fine.
Did you ever arrange any meetings between DNC donors and the First
Lady's office?
Answer. No. Not that I remember.
Question. Do you know if there was somebody in the First Lady's
office who would arrange these meetings?
Answer. Between who?
Question. DNC donors and the First Lady or anybody else, Maggie
Williams, anybody in the First Lady's office?
Answer. I would imagine any meetings that were set up between Mrs.
Clinton and DNC donors or DNC employees would be set up by, where I am
now, her scheduling office, which sets up all of her meetings. I don't
remember setting up any meetings between Maggie and DNC donors myself.
But, as I said, I typically knew them as individuals in terms of their
names, not in terms of always who they were or what the meeting was
about.
Question. Right. Okay.
Were you ever involved at all in arranging any meetings with the
President's staff?
Answer. No.
Question. Was there anybody in the First Lady's office who would
have been in contact with the President's staff to arrange meetings?
Answer. Between whom?
Question. Well, we could start just general. Any meetings. Have you
had to schedule a meeting with the President or with somebody in his
office? Is that something that you would do or would somebody else in
the First Lady's office have a contact in the President's office?
Answer. I would only have been involved if it involved Maggie
meeting with the President. If in terms of the President and the First
Lady, that would be the First Lady's scheduling office who would deal
with a meeting that anyone else was involved in.
Question. So her scheduling office would be the ones who would
perhaps schedule a meeting with the President?
Answer. If it involved her. If it involved Mrs. Clinton.
Question. If it did not involve Mrs. Clinton at all?
Answer. We didn't deal with it, yes.
Question. Did you refer that person to somebody at the President's
staff, in his office?
Answer. If somebody was looking to meet with the President?
Question. Yes.
Answer. We would refer them to the President's scheduling office.
Not to a person specifically, but a phone number.
Question. Did you ever arrange any meetings with agency officials
and DNC donors?
Answer. No.
Question. Do you know if anyone in the First Lady's office arranged
such meetings?
Answer. No.
Question. Was the White House Mess ever used to entertain DNC
supporters or donors?
Answer. Not that I remember. I know that Johnny Chung did eat
there. That was by his request. No, it was never used to my knowledge
to entertain DNC donors.
Question. Were you ever asked to make White House Mess
reservations?
Answer. Yes.
Question. Did you always know who you were making them on behalf
of?
Answer. Generally, I made them for lunches Maggie was going--for a
lunch she was having with someone. I don't remember everybody that she
had lunch with, so I don't know.
Question. Would you just make White House Mess reservations only
when Maggie Williams was going to be having lunch there, for instance?
Answer. I dealt with her reservations, yes. On occasion, she--we
used her account at the White House Mess and someone ate there on her
account without her presence.
Question. So she would not always have to be present for someone to
be able to eat in the White House Mess?
Answer. Right. Yes.
Question. But you would always schedule reservations under her
name?
Answer. With her permission, yes.
Mr. Lawler. You want to explain how you need an account? I mean,
you couldn't make a reservation.
The Witness. Yes. I don't have a White House Mess account. People
who work in the West Wing of the White House have Mess accounts, as do
assistants to the President. So in order to eat at the White House
Mess, you have to have an account or be there on somebody's account.
EXAMINATION BY MS. SAFAVIAN:
Question. So how would somebody pay? Did you have to pay if you ate
in the White House Mess?
Answer. It would be billed to that person's account and they would
receive a bill monthly.
Question. When you say ``that person's account,'' do you mean, for
instance, Maggie Williams' account?
Answer. For whomever's account you're eating on, yes.
Question. What would Ms. Williams then do?
Answer. Generally she was reimbursed by whomever it was that ate
lunch on her account. This wasn't often, though.
Question. So, for instance, you earlier mentioned Johnny Chung has
eaten in the White House Mess. Do you know if that would have been on
Ms. Williams' account?
Answer. Yes.
Question. So she would have gotten a bill showing that Johnny Chung
had lunch there?
Answer. Yes.
Question. And showing the amount?
Answer. Yes.
Question. What would she then do to get reimbursed from Mr. Chung?
Answer. I can't remember how we worked that reimbursement or how
that happened. I don't know if that day he reimbursed her. I don't know
if later on. I don't remember how that worked. I'm sure there was
reimbursement, but I don't remember.
Question. Would he have known right away how much it cost to have
lunch there? Could Mr. Chung have known before he finished that it was
going to cost him X dollars?
Answer. I suppose if he asked the people at the Mess he may have
been able to find out. If not, it would appear on her bill that month.
Question. So she got a monthly statement?
Answer. Yes.
Question. Would the statement--how would she know on the statement
who ate there and who gets the bill?
Answer. The statement just would say lunch for five or lunch for
four. It would have the date and the amount.
Question. So how did they know? Did she keep track of it somehow?
Answer. I don't remember in this case; I don't know. I feel like I
would be guessing.
Question. I don't want you to do that.
Answer. I don't remember specifically in this situation how we
handled the billing. I don't remember.
Question. Is that something that you would have handled for her?
Answer. Probably.
Question. Is there anybody else who would have handled that for
her?
Answer. If not me, then the assistant to the chief of staff would
have been the other person. It would have been one of us. I don't
remember specifically. It could be just because it didn't leave an
imprint on my memory, but I don't know.
Question. Do you recall if--you would receive the monthly
statement, and then would you like send out a letter?
Answer. I don't know. Perhaps. I don't know.
Mr. McLaughlin. Don't guess.
EXAMINATION BY MS. SAFAVIAN:
Question. I know you said it didn't happen very often. Do you
recall who would have lunch at the White House Mess under Ms. Williams'
account?
Answer. The only other person that I think had lunch on the White
House Mess account and Maggie was not present was Mark Middleton.
Question. Was Ms. Williams usually present for all the other
lunches?
Answer. Yes. She didn't really eat at the Mess that often.
Question. Would guests of hers be able to eat on her account? What
I'm trying to get at, would she accompany the guests who would eat at
the White House Mess more often that not or were they on their own
without her present?
Answer. More often than not, she was with them. But even then that
wasn't that often.
Question. And so you're telling me perhaps the only time when she
wasn't present for lunch was when Mark Middleton was eating on her
account?
Answer. I believe I remember one time when Mark Middleton had lunch
at the Mess and she wasn't present.
Question. Is there any specific reason why she would or would not
accompany somebody who was eating lunch on her account?
Answer. It was Mark Middleton's request of her after he had left
the White House, he wanted to have lunch there and was wondering if he
could put it on her account.
Question. Did he wonder if he could have lunch there without her
present?
Answer. I think so. I think. It wasn't in terms of do you want to
come to lunch. It was more like, I wanted to go to the Mess; do you
mind if I use your account.
Question. And she didn't have a problem with that?
Answer. And she said it was okay, yes.
Question. Did she normally always say it was okay for somebody to
eat on her account?
Answer. Generally it wasn't a request that was made that often from
what I know, and she really didn't eat at the Mess that often.
Question. So to your knowledge you do not know if any DNC donors
ever had lunch with Ms. Williams in the White House Mess?
Answer. I don't know.
Question. Do you recall ever requesting the DNC to reimburse for
bills that were on the account?
Answer. I don't remember that, no.
Question. Did you ever arrange for a DNC donor to spend the night
at the White House?
Answer. No.
Question. Did you ever arrange for anybody to spend the night at
the White House?
Answer. No.
Question. Do you know if anybody in the First Lady's office was in
charge of that responsibility?
Answer. I don't know.
Question. Did you ever arrange for DNC donors to fly aboard Air
Force One or Air Force Two?
Answer. No.
Question. Did you ever arrange for anybody to fly aboard Air Force
One or Air Force Two?
Answer. No.
Question. Do you know if anyone in the First Lady's office was
charged with that responsibility?
Answer. Not that I know of.
Question. Did you ever arrange for DNC donors to attend White House
private dinners?
Answer. No.
Question. Did you ever arrange for anyone to attend White House
private dinners?
Answer. No.
Question. Do you know if there was anybody charged with that
responsibility in the First Lady's office?
Answer. I would imagine White House dinners were Social Office
functions. So I'm sure the social secretary was generally in charge of
the guest lists.
Question. Did you ever arrange for any DNC donors to attend any
function at the White House?
Answer. No.
Question. Did you ever arrange for anybody to attend a function at
the White House?
Answer. Functions at the White House fell under the Social Office.
They did all the inviting of any guest, whether it be by phone or by
formal invitation in the mail, so it wasn't part of my duties.
Question. If someone would contact you or call you up and ask you,
can I be invited to a function or dinner, what would you do with that
request?
Answer. I would call the Social Office and give them that person's
name and number and they would then handle it from there.
Question. Did you ever arrange for DNC donors to attend the
President's radio address?
Answer. No.
Question. Did you ever arrange for anybody to attend the
President's radio address?
Answer. If anyone made a request to attend the radio address, which
I really don't recall, I would call Oval Office Operations and speak to
someone. They were in charge of the radio address.
Question. You would speak to them and try and set up----
Answer. Pass on the person's information.
Question. And they would take it----
Answer. I think generally there's a waiting list. I've just heard
of other people who have had family members get off the waiting list. I
don't know. I don't remember ever doing it, no.
Question. So you would refer their name to somebody at that office?
Answer. Yes.
Question. Did you ever arrange for DNC donors to use the
President's box at the Kennedy Center?
Answer. No.
Question. Did you ever arrange for anybody to use the President's
box at the Kennedy Center?
Answer. Yes.
Question. And who would that have been; do you recall?
Answer. Maggie Williams. Perhaps another staff member. I don't
remember. I just remember people have come to me either asking who they
talk to or maybe I called, but I don't know. I remember calling on
Maggie's behalf.
Question. Were you able to get her tickets?
Answer. Sometimes yes, sometimes no, I think. I don't remember. No,
not often, but I would just remember it being maybe three times or so.
I don't remember.
Question. Do you remember who the staff person was that you also
tried to get tickets?
Answer. No. I think mostly people were asking me who they contacted
if they wanted to go into the box. I don't remember, no.
Question. Do you remember who you would contact to get the tickets
for Ms. Williams?
Answer. Yes.
Question. And who would that be?
Answer. Debi Schiff.
Question. And who is she?
Answer. She sits in the main reception area in the West Wing of the
White House on the first floor.
Question. And who does she work for?
Answer. I'm not quite sure who her immediate superior is. I don't
know what her title is. I think she is the VIP receptionist, the person
who's in that main reception area in the West Wing.
Question. Is she the only person that you would contact about that?
Answer. She is in charge of the Kennedy Center box, yes.
Question. Did you ever arrange for DNC donors to attend movies at
the White House?
Answer. No.
Question. Did you ever arrange for anybody to attend a movie at the
White House?
Answer. No.
Question. Was there anybody in the First Lady's office who would
arrange such evenings?
Answer. Not that I'm aware of. Ann Stock, the social secretary, but
once again I don't know.
Question. You believe Ann Stock may have been the one to arrange
that?
Answer. I believe she was in charge of all functions like that in
the White House, any event, movies, dinners, official events, anything
that took place in the White House. I believe Anne Stock was the person
who was the point of contact or in charge of the event.
Question. Did anyone ever call and ask you to help them get a place
at the White House movie, a spot to watch?
Answer. No.
Question. Did you ever arrange for DNC donors to use the White
House tennis courts?
Answer. No.
Question. Did you ever arrange for anybody to use the White House
tennis courts?
Answer. White House staff can use the White House tennis courts.
They can call an office. I think there are certain days or certain
hours it's available for White House staff to use the tennis courts. So
I've done it myself. But other than that, I haven't arranged it for
anyone else.
Question. Was there anybody in the First Lady's office who was in
charge of arranging?
Answer. The tennis courts?
Question. Yes.
Answer. No. No.
Question. Did the DNC ever ask you to secure photos for DNC donors
with the First Lady?
Answer. No.
Question. Did you ever secure photos with the First Lady with
anybody?
Answer. I do now in my job as a scheduler, but, no, then, I never
set up photos with Mrs. Clinton, no.
Question. Who would normally have set up those photos?
Answer. The scheduling office. The First Lady's scheduling office.
Question. Did you ever get requests from anybody asking if you can
help them get a photo with the First Lady?
Answer. I think we received letters from the general public. I'm
sure she received different requests. The volunteers in our office
looked forward to having a photo with her. I remember they would talk
about it. And Mr. Chung, as we know, was looking to get a photo with
her in March of '95. Other than that, I can't recall specifically
people asking for photos.
Question. Mentioning the interns and Johnny Chung, would they
approach you about getting a photo with the First Lady?
Answer. Yes.
Question. And what would you do when a request like that came?
Answer. Generally the intern sessions last through the fall, the
spring, and the summer. Each intern session we try to set up a photo at
the end of the session with Mrs. Clinton and the First Lady interns. I
would contact the scheduling office and they would try to find a time
where it fit into her schedule.
Question. Would that be a group photo?
Answer. Group photo. Sometimes she would shake hands with the
interns, and they would be able to take individuals. It depended.
Question. With regard to Johnny Chung, because you also mentioned
him, he personally asked you to set up a photo with the First Lady?
Answer. He asked if I thought it would be possible to get a photo
with the First Lady, yes.
Question. What was your response to that request?
Answer. I would check to see if it was possible.
Question. Was it possible?
Answer. Yes.
Question. How many times did he ask you to help him get photos with
the First Lady?
Answer. That's the only time I can think of.
Question. It was one time?
Answer. Yes.
Question. And you were able----
Answer. He attended several Democratic Party events where he had
photos with the First Lady, so he expressed an interest this time
because he had guests with him.
Question. Do you recall what this time is?
Answer. March of '95.
Question. Was there any process you had to go through to be able to
get this photo opportunity for him with the First Lady?
Answer. I mentioned it to Maggie Williams, and that was the last I
dealt with it in terms of setting it up.
Question. So in that instance you went directly to Ms. Williams to
take care of it instead of calling the First Lady's scheduler?
Answer. Yes.
Question. Any particular reason?
Answer. Well, because on this occasion Mr. Chung had several
requests: He wanted to have lunch at the mess, he wanted a photo with
Mrs. Clinton, he wanted a tour of the White House, and he wanted to see
if he could get into the radio address. So I took all those requests in
to Ms. Williams.
Question. I understand that you just scheduled the intern photos
and one with Johnny Chung. Do you know----
Mr. Lawler. Actually, she didn't schedule the one with Johnny
Chung.
EXAMINATION BY MS. SAFAVIAN:
Question. Excuse me, you arranged at least for the interns to have
a photo?
Answer. Yes.
Question. And you spoke with Ms. Williams about Johnny Chung's
photo?
Answer. Yes.
Question. Do you know what the process was? Does someone have to
pay for these photos with the First Lady?
Answer. Not to my knowledge, no.
Question. So you don't know if Johnny Chung or his guests had to
pay for the photo they had?
Answer. I don't--I have no knowledge of anyone ever being charged
for a photo, no.
Question. I want to just show you these. They are copies of four
pictures that are taken with the First Lady with four different
individuals. What I'm interested in with these photos is at the bottom
of each photo.
Answer. Yes.
Question. They are addressed, I assume, to the individual in the
photo?
Answer. Yes.
Question. For instance, the first one, which is Bates Stamped EOP
029612, says, ``To,'' and I will try to pronounce this correctly,
``Zheng Hongye,'' I am not really sure. It says, ``With best wishes,
HRC,'' Hillary Rodham Clinton?
Answer. Yes.
Question. Do you know the process, the procedure to get photos with
the First Lady addressed and signed like this?
Answer. Yes. The Office of Correspondence does the calligraphy
portion on the bottom, and they also have an autopen machine that can
be used, although Mrs. Clinton also signs photos as well.
Question. She does?
Answer. Yes.
Question. So is there any way for you to tell whether this is an
autopen or Mrs. Clinton's own signature?
Answer. No. I am fooled by the autopen, so I don't know which--I
don't know.
Question. And who was it that you said had the autopen?
Answer. The Office of the First Lady's Correspondence.
Question. Would they be the only office who had the autopen with
her signature?
Answer. I don't know if the general Office of Correspondence may
have an autopen for her as well. I don't know.
Question. Was this normal? Would every photo with the First Lady be
addressed to the individuals and then signed with her name?
Answer. We tend to do them for a lot of the photos, if the person
requests it.
Question. And as far as you know, there is no charge for the photo
or for the signature or anything like that?
Answer. Not to my knowledge.
Question. Do you happen to know the individuals in these photos? I
know that's kind of hard to tell their faces, but their names are at
the bottom. Do any of these names mean anything to you?
Answer. No, they don't.
Question. Do any of the faces? Do you recognize any of the faces?
Answer. I can tell that these are Johnny Chung's business friends
that he had with him, but I don't know the names at all, no.
Question. Was this the March meeting that you mentioned earlier?
Answer. Yes.
Ms. Safavian. I'm going to go ahead and mark this as Exhibit ER-3.
[Ryan Deposition Exhibit No. ER-3 was marked for identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Were DNC donors ever sent a birthday card from the First
Lady?
Answer. I don't know.
Question. Were you in charge at all of sending out birthday cards
from the First Lady?
Answer. No.
Question. Do you know if anybody was in the First Lady's office?
Answer. Probably the correspondence office, the Office of the First
Lady's Correspondence. I can't say for sure.
I know that the Office of Presidential Correspondence sends
birthday greetings from both the President and the First Lady. So I
don't know if the First Lady's office sends just from the First Lady. I
don't know.
Question. Have you ever gotten a request for a birthday card or
anniversary card or any special event like that from the First Lady?
Has someone contacted you about that?
Answer. We have a form. When I worked in this office, we had a form
for events, a correspondence form, we could fill out for a birthday
greeting, anniversary, birth of a child, graduation, congratulations-
type form that you would fill out with the person's information and
address, and we would send it down to the correspondence office. But it
was for something from both the President and the First Lady. It wasn't
specifically a First Lady letter, so to speak.
Question. And you would fill out those forms why? Was it in
response to a request from somebody?
Answer. We filled them out for anybody that wrote into the office
or called into the office.
Question. Anybody could do that?
Answer. Uh-huh.
Mr. Lawler. I got a birthday card from Ronald Reagan once.
Ms. Safavian. Did you?
Mr. Lawler. I got a postcard from Amy Carter.
Ms. Safavian. Well, I am even more impressed.
Mr. McLaughlin. I got one from Millie.
Ms. Safavian. Okay, you win.
EXAMINATION BY MS. SAFAVIAN:
Question. Were DNC donors or potential donors ever invited to have
lunch with Maggie Williams?
Answer. Not to my knowledge, no.
Question. Do you recall ever scheduling any of these lunches for
Ms. Williams?
Answer. I recall scheduling lunches for her, but they would be the
individuals, same as her meetings. I don't know who they were
specifically or what the lunches were for, but, no, I don't know that
she ever had a lunch with donors or potential donors, no.
Question. When you were scheduling these lunches, did you ever have
a list? Did you provide her with a list of the attendees?
Answer. No. I would schedule, I would put something on her schedule
with the people's names who she was having lunch with, but I never had
lists of--I don't believe she ever had a lunch where she needed a list
of people.
Question. It was usually small lunches?
Answer. Yes. But, actually, she really didn't have many lunches;
very, very few.
Question. About how many people would attend the lunch with Ms.
Williams?
Answer. There's no set amount of people. There would be--I mean,
this is if she was having lunch with someone, I would schedule it. I
don't recall there ever being--there was never a set lunch where it
would be a group of people for a specific purpose. That I have no
knowledge of.
Question. And you said these lunches were not very frequent?
Answer. She rarely had lunches with people. She was pretty much at
her desk or working. She wasn't out having lunch with people or in the
mess having lunch with people.
Question. Do you recall then how many lunches you scheduled for Ms.
Williams?
Answer. No, I don't know. I worked for her for a long time. I don't
know. It's tough to gauge specific numbers.
Question. When you would schedule one of these lunches, was that
usually Ms. Williams asking you to schedule a lunch, or somebody would
contact you?
Answer. Or vice versa. If someone wanted to have lunch with her,
you know, we would ask her if she was able to have lunch with them. If
she had someone that she wanted to have lunch with, then she would say
maybe I should contact them.
Mr. McLaughlin. Counsel, is this going somewhere relating to
campaign fund-raising?
EXAMINATION BY MS. SAFAVIAN:
Question. Can you tell me were DNC donors or potential donors ever
invited to have lunch with the First Lady?
Answer. I don't know. That's something that the Scheduling Office
probably would have dealt with. Nothing that was in my scope at that
point.
Question. So nobody ever contacted you to arrange a lunch with the
First Lady?
Answer. No, not that I remember. No.
Question. Let me show you this memorandum. As you can see, it is
dated May 5, 1994. It's addressed to Ann Cahill from Martha Phipps
regarding White House activities.
First of all, can you tell me do you know who Ann Cahill is?
Answer. The name is somewhat familiar, but no, I don't know
specifically who she is.
Question. So you have never had any contact with Ms. Cahill?
Answer. Not that I remember. The name is vaguely familiar, but I
don't remember her specifically.
Question. Do you know who Martha Phipps is?
Answer. Martha Phipps, I remember that name as a DNC name. I don't
know how I know that.
Question. Did you ever have any contact with Ms. Phipps?
Answer. Possibly, because I do recognize that name more than I do
Ann Cahill, but I don't remember a specific instance.
Question. Do you recall ever--first of all, ever seeing this
memorandum? Please take a look at it and tell me if it looks familiar
to you at all.
Answer. No, it doesn't.
Mr. McLaughlin. I note for the record that Evan Ryan's name does
not appear in the memo.
EXAMINATION BY MS. SAFAVIAN:
Question. Let me start with the first paragraph. ``In order to
reach our very aggressive goal of $40 million this year, it would be
very helpful if we could coordinate the following activities between
the White House and the Democratic National Committee.''
Were you aware that there was a $40 million goal for 1994 to reach?
Answer. No, I was not.
Question. Did anyone ever discuss any goals with you to reach for
'94 or any year?
Answer. No.
Question. If you turn to the second page, number 16, it says, ``One
lunch with the First Lady per month. Contact: Maggie Williams.''
Were you aware of these lunches with the First Lady once a month?
Answer. No.
Question. Do you know if Ms. Williams in fact scheduled these
lunches with the First Lady?
Answer. I don't know, no. And, actually, I'm just noticing that at
the time, I had been an intern there for three or four months in May of
'94, so--but I don't know. No, I don't remember that at all.
Question. So this is not something that you assisted Ms. Williams
in arranging?
Answer. No.
Ms. Safavian. Let's mark this exhibit ER-4.
[Ryan Deposition Exhibit No. ER-4 was marked for identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Do you know whether the DNC ever asked the First Lady to
make fund-raising phone calls?
Answer. No, I don't know. I have seen in another deposition,
memorandums, but I had never seen them before.
Question. Do you know who Marvin Rosen is?
Answer. The name is familiar as a DNC name, but no.
Question. So you mention that you saw these call sheets during your
Senate deposition?
Answer. Yes.
Question. Had you seen them before that?
Answer. No.
Question. Had you ever heard anybody talk about DNC call sheets for
the First Lady prior to your deposition with the Senate?
Answer. No, I had not.
Question. That was your first knowledge of such call sheets?
Answer. Yes.
Question. Are you aware of whether or not Ms. Williams ever
contacted the First Lady about these calls?
Answer. I don't know.
Question. Would you know whether the First Lady made any fund-
raising calls?
Answer. I don't know.
Question. Are you aware that the First Lady attended a series of
coffees held at the White House during 1995 and 1996?
Answer. I believe both the President and the First Lady did, I
think. My knowledge is basically based on media accounts, though, so I
don't have any specific recollection from my work experience, no. Once
again, that is a scheduling issue which I was not a part of.
Question. So you never scheduled for the First Lady any of these
coffees?
Answer. I was working last year still for Maggie Williams. I only
moved over to the Scheduling Office in March of '97. So, no.
Question. Did Ms. Williams ever ask you to assist in scheduling one
of these coffees?
Answer. No.
Question. Let me back up, I guess, for a second. Were these coffees
with the First Lady ever discussed? Did Ms. Williams ever discuss
these?
Answer. No.
Question. So the only way you even know that the First Lady
attended coffees was from news accounts?
Answer. I think that's what my knowledge is based on. I don't
remember ever in the office hearing about the coffees specifically, no.
Question. And you never assisted Maggie Williams with scheduling
coffees?
Answer. No. I would be surprised if Maggie was involved in the
scheduling of the coffees. I don't know.
Question. Why do you say that?
Answer. Well, because I think I would know if she were involved in
setting up these coffees. But I don't remember that at all, so----
Question. Do you ever recall Maggie Williams having to approve an
attendee list for one of these coffees?
Answer. I don't remember that, no.
Mr. Lawler. Would this be a good point to take a break for a couple
of minutes?
Ms. Safavian. Absolutely.
[Brief recess.]
EXAMINATION BY MS. SAFAVIAN:
Question. Just finishing up real quickly with the coffees we were
talking about before the break.
Did you ever happen to see any spreadsheets prepared by the DNC
regarding the coffees and how much money they raised or may have
raised, given to Maggie Williams or for the First Lady or anything like
that?
Answer. No.
Question. Do you know who Truman Arnold is?
Answer. I believe that name is associated with the DNC, but I don't
know in what capacity.
Question. Have you ever had any contact with him?
Answer. No.
Question. Do you know whether or not Mr. Arnold ever visited the
First Lady or Maggie Williams?
Answer. No.
Question. Do you know who Bernard Rapoport is?
Answer. No.
Question. Michael Berman?
Answer. Yes.
Question. Who is he?
Answer. I forget name of the firm he works with, but I have met him
on occasion.
Question. Where have you met him?
Answer. In the office.
Question. And why was he there?
Answer. I believe he was at meetings in our office.
Question. Who was he meeting with; do you remember?
Answer. I believe there were big meetings because--I remember there
being a lot of people. I don't remember specifically who was in the
meeting.
Question. Do you recall if Maggie Williams was in the meeting?
Answer. I think she was.
Question. Do you recall if the First Lady was in the meeting?
Answer. I don't think so, no.
Question. Was he around often? Can you give a number to the number
of times?
Answer. No, I'm not sure.
Question. How about Ron Perelman?
Answer. I know who he is, not--I just know the name.
Question. Have you ever met him?
Answer. No.
Question. How about John Phillips?
Answer. No.
Question. Do you know who Webster Hubbell is?
Answer. Yes.
Question. Have you ever met Mr. Hubbell?
Answer. No, I haven't.
Question. Have you ever spoken with Mr. Hubbell on the telephone?
Answer. No.
Question. Do you know if Mr. Hubbell ever had meetings with Maggie
Williams?
Answer. No, not that I know of.
Question. I can try to summarize this a little bit. Are you aware
of any legal problems that Mr. Hubbell had with his former law firm,
the Rose Law Firm?
Answer. No.
Question. Do you recall any discussions around the office about Mr.
Hubbell and any of these problems?
Answer. No.
Question. Did Ms. Williams ever discuss with you Webster Hubbell or
any of these problems?
Answer. No.
Question. Do you know who Amy Stewart is?
Answer. No.
Question. Do you know who David Kendall is?
Answer. Yes.
Question. Who is he?
Answer. He is the Clintons' attorney.
Question. He's the Clintons' personal attorney?
Answer. I believe he's Mrs. Clinton's attorney. I don't know if he
is the President's as well.
Question. Does he work for the White House?
Answer. No. Personal attorney, yes.
Question. Have you ever met Mr. Kendall?
Answer. Yes.
Question. And what were the circumstances surrounding that meeting?
Answer. I have met him--I know him, and I have met him. I don't
remember meeting him. I don't remember at what point I met him. I'm
sure it was in the office, but I don't remember.
Question. Did someone introduce you to him?
Answer. No. If he came to my office, he probably introduced
himself.
Question. Do you recall a meeting in March of '94 that Ms. Williams
may have attended with David Kendall regarding Webster Hubbell?
Mr. Lawler. Were you even in the office in March of'94?
The Witness. I had just started as an intern then. I don't remember
that, no.
EXAMINATION BY MS. SAFAVIAN:
Question. Would you say that Ms. Williams knew Mr. Hubbell fairly
well? Did they meet often?
Answer. I never saw them meet. I don't know if she knew him well or
not.
Question. Do you know if she knew him at all?
Answer. I don't know.
Question. Do you know who Ernie Green is?
Answer. I have heard the name before. I believe he might be
involved with an African organization, but I don't remember which.
Question. Have you ever met him?
Answer. No.
Question. Do you know if he's ever been in contact or had a meeting
with Maggie Williams?
Answer. I don't know.
Question. And you mentioned Mark Middleton's name earlier?
Answer. Yes.
Question. How well do you know Mr. Middleton?
Answer. I have met him on several occasions, and I have talked to
him on the phone. I definitely know who he is.
Question. What were the circumstance surrounding the first time you
met Mr. Middleton?
Answer. He used to work at the White House, so I probably met him
when he was an employee still at the White House.
Question. Do you know when Mr. Middleton left the White House?
Answer. I don't remember.
Question. Do you know while he was at the White House, did Maggie
Williams and Mark Middleton have much contact with each other?
Answer. I don't remember.
Question. Do you know whether or not they had much contact with
each other after he left the White House?
Answer. I remember that he called her on a couple of occasions, and
he may have met with her, too, on a couple of occasions, but that's all
I remember.
Question. Do you recall what any of those meetings or those phone
calls were about?
Answer. No. He would call me sometimes to leave messages for Maggie
or to get in touch with Maggie. I don't remember specifically what it
was about.
Question. Did he ever tell you the purpose of his phone call?
Answer. I have a memory of--no. Phone calls, no. I have a memory of
one meeting being about a Presidential library, something or other, but
I don't remember anything more than that.
Question. Do you recall the time frame of this meeting?
Answer. No.
Question. Were you present during any meetings that Maggie Williams
would have had with Mr. Middleton?
Answer. No.
Question. Did you ever clear or wave Mr. Middleton into the White
House?
Answer. Not that I remember, but I probably did.
Question. Do you recall any of the times you may have, was it just
Mr. Middleton, or did he have guests with him?
Answer. I don't recall.
Question. Ms. Ryan, I am handing you WAVE records, Worker And
Visitor Entry records, in which you asked access for Mark Middleton. I
want to quickly go through these.
On the first page you will see that on April 1, 1995, you were
listed as both the requester and the visitee?
Answer. Yes.
Question. Did Mark Middleton meet with you on this day?
Answer. Not that I remember.
Question. Can you maybe give me some background on these WAVE
records and actually requesting somebody be waved into the White House?
Answer. On the computer WAVE request, it automatically comes up
with your name, the person's name whose computer you are at, so that
would be the requester. A visitee is something that can be typed in
right there next to the requester's name. You have to type in the time,
the date, the room number they are going to, and the person's name,
date of birth and now social security number.
Question. Is this something that you would do personally when you
were waving someone into the White House?
Answer. Yes.
Question. So do you actually have to go to the computer and type
all this in?
Answer. Yes.
Question. Is that located where a visitor would enter the White
House?
Answer. This is my computer at my desk. I'm able to type this
information in. It goes to the WAVE center, and the uniformed Secret
Service guards who are at the gate have computers at the gate.
Question. So they would get this information that you typed in?
Answer. Yes. I believe it goes through--I don't understand the
process, but I believe it goes through a Secret Service WAVE center and
goes then to the uniformed guards at the desk.
Question. How much time before a visitor would enter the White
House would you need to get this information into the computer?
Answer. Generally, I think, at least within the half-hour before.
Question. So just a minimum of a half-hour before the person was
waved in?
Answer. I don't know what the specific time frame needs to be, but
I can do it up until pretty close to when a person is coming.
Question. So someone could call you and say, I'm coming over in 10
minutes, and that would be no problem? You could still get the
information in, and they could still come into the White House?
Answer. I could either type it into the computer, or I could call
the WAVE center and deliver the information over the phone.
Question. So if I see your name as the requester, does that mean
that you are the one that personally typed this information into the
computer?
Answer. Yes.
Question. Is there any specific reasoning why you would put your
name as a visitee if Mr. Middleton was not visiting with you?
Answer. I sometimes just put my name in, probably because I knew
him, and he called and said he was coming over. It is just habit
sometimes. I sometimes put my name in and sometimes put Maggie's name
in. There was really no--if I knew Mark Middleton, which I did, I
probably just typed my name in.
Question. So on this specific date, April 21, 1995, do you remember
if Mr. Middleton met with you on that date?
Answer. I don't remember why he was there.
Question. Would Mr. Middleton ever stop by the White House to have
a specific meeting with you?
Answer. No.
Question. They would always be with somebody else?
Answer. Yes, or he may have wanted to come drop something off. At
one point I remember he picked a photo up from us, so I don't know if
this was when that was. I don't know.
Question. Who would Mr. Middleton usually meet with if he asked you
to wave him into the White House?
Answer. I remember he met with Maggie on a couple of occasions. So
possibly it was Maggie.
Question. If you turn to the next page, it shows the next visit is
on May 9, 1995, and this time you have the visitee as Williams?
Answer. Yes.
Question. Would that be Maggie Williams?
Answer. Yes.
Question. Do you recall the circumstance or the purpose of this
visit?
Answer. No.
Question. Can you tell me, would you meet Mr. Middleton down at the
entrance or the gate and actually bring him into the White House? Or
what was the process for him to get into the White House?
Answer. No, he would come up to our office.
Question. So you would not actually go down to the door, the front
door, for instance?
Answer. No.
Question. Did people who normally visit the White House or your
office have to be accompanied by somebody?
Answer. No. They can enter the White House and come up to our
office on their own. Only press are escorted within the Old Executive
Office Building.
Question. Is that the same policy for the White House?
Answer. No, in the White House you need a staff member with you.
Question. At all times?
Answer. Yes.
Question. So the fact that Mark Middleton used to work at the White
House, that didn't give him any special privileges to be able to walk
around freely without being accompanied by somebody?
Answer. In the White House?
Question. In the Old Executive Office Building.
Answer. In the Old Executive Office Building people can walk around
unaccompanied unless you are a member of the press.
Question. Okay. And in the White House even Mr. Middleton would
have to be accompanied by somebody?
Answer. Yes.
Question. So when I see that the location and the room, and for
that I see O and 100, that would stand for?
Answer. Room 100 of the Old Executive Office Building.
Question. And that's where you're located?
Answer. Yes.
Question. The next one, the next visit, is May 19, 1995. There it
shows once again that you requested it, he's meeting with Maggie
Williams, or at least Williams' name is listed?
Answer. Yes.
Question. And this time there's a W, a 2FL, slash, WW. What does
that stand for?
Answer. Second floor, West Wing.
Question. So would that mean that is where the meeting took place?
Answer. Yes.
Question. Do you recall this meeting on this date?
Answer. No.
Question. Now, for this instance where he is actually going to the
White House, would you go down and meet with him and then escort him to
this meeting with Ms. Williams?
Answer. Possibly, but not necessarily. It's also possible that when
he entered, Debi Schiff, who is in the reception area, can call Maggie
up in her office, and she can come and get him.
Question. But somebody would have had to?
Answer. Somebody, yes.
Question. Do you know where in the West Wing meetings were held?
Answer. For Maggie Williams?
Question. Yes.
Answer. She has a West Wing office as well as an office in the Old
Executive Office Building.
Question. So they would normally be held in her office?
Answer. Yes.
Question. How about meetings with her in the Old Executive Office
Building?
Answer. They would occur either in her office or in our conference
room.
Question. How about in the East Wing?
Answer. I don't know--I have never dealt with meetings in the East
Wing.
Question. Let's see. Let's turn the page. The next one is May 19,
1995. Again you are the requester and Williams is the visitee. Do you
recall the circumstance of this visit? I'm sorry, are these--I think
this is----
Answer. It's the same one.
Question. I think this is perhaps out of order. I'm sorry, that's
right. The next page, I'm sorry, does not show Middleton, and it is
hard to read, but it says Ng Lapseng.
Mr. Lawler. I think we are off on the pages.
Ms. Safavian. Bates Stamp Number 056855.
Mr. Lawler. Okay.
Ms. Safavian. Are we on the right one now?
Mr. Lawler. Yeah, it's the right page.
EXAMINATION BY MS. SAFAVIAN:
Question. And this is for a May 19, 1995 visit?
Answer. I don't think we can see that.
Mr. Lawler. We are on the bottom?
Ms. Safavian. The very last line.
The Witness. Oh, right.
Mr. Lawler. I can't make any name out at all.
The Witness. We cannot really read it.
EXAMINATION BY MS. SAFAVIAN:
Question. Do you see in the beginning where it says Ng, N-G?
Mr. Lawler. No.
EXAMINATION BY MS. SAFAVIAN:
Question. At the end, Lapseng, L-A-P-S-E-N-G.
Mr. Lawler. Ng is the only thing on this copy.
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Ryan, can you make that out?
Answer. I can make out Ng, yes.
Question. First of all, do you know who Ng Lapseng is, also known
as Mr. Wu?
Answer. No.
Mr. Lawler. If you say that's what's on here.
EXAMINATION BY MS. SAFAVIAN:
Question. It is my belief that is the name that is there. I agree
with you it is hard to read.
You do not know who this individual is?
Answer. No.
Question. Not knowing who this individual is, why would you have
requested his entrance into the White House?
Answer. At someone's request. I don't know. I mean, I have down
here that he's visiting Maggie Williams, but I don't remember this.
Question. This entry and the one prior that we just talked about
for Mark Middleton show that they are meeting both with Maggie Williams
for the same time meeting and that they arrived at the same time. And
you can take a look at that real quick to verify that I am accurate
with that.
Answer. Yes.
Question. Would that have been the same meeting with Ms. Williams?
Answer. Yes.
Question. Does that at all refresh your recollection as to the
purpose behind this meeting?
Answer. No. I would not--and, no, I don't know the purpose. There's
one thing that I can speculate. As I recognize this meeting is at 1:15,
which is--there are two lunch times at the Mess. One is at noon and one
is at 1:15. And as I say, I can remember Mark Middleton having lunch at
the Mess on occasion on Maggie Williams' account, and this may have
been the occasion.
Mr. McLaughlin. So the answer to that question is based on
speculation?
The Witness. Speculation only on the fact I have cleared them in at
1:15, which is one of the two times for lunch at the Mess. If they met
with Ms. Williams, I have no idea what they met about.
EXAMINATION BY MS. SAFAVIAN:
Question. So you don't actually recall, once again, actually
bringing this individual Ng Lapseng to the meeting with Ms. Williams or
to the White House Mess?
Answer. No.
Question. Do you know if Ms. Williams met often with Ng Lapseng?
Answer. No.
Question. The next page shows three entries. They all have you as
requester, and they all have Williams as the person being visited. The
dates are June 5, 20 and 29th, 1995.
Do you recall the circumstance of any of these visits with Mr.
Middleton?
Answer. No, I don't.
Question. The next one is a July 21, 1995 visit. Once again you
requested him, and he's meeting with Williams.
Do you recall the circumstance of this visit?
Answer. No, I don't.
Question. The next page shows four entries: September 12th, twice
on the 15th, and once on the 26th.
Do you recall the circumstance of these visits?
Answer. No, I don't.
Question. Do you know why he would be visiting twice on the same
day?
Answer. No. No.
Question. Can you give any reason why the second time on the 15th
was at 8 p.m.?
Answer. I don't know.
Question. Did Ms. Williams often have meetings late into the
evening?
Answer. No.
Question. Could this have been a function at the White House or----
Mr. Lawler. That would be speculation, and she said she doesn't
know.
The Witness. Yeah, I don't know.
EXAMINATION BY MS. SAFAVIAN:
Question. The next page shows a November 25th, 1995 visit.
Do you recall the circumstances of that visit?
Answer. No.
Question. The one after that is November 2nd, 1995.
Do you recall that visit?
Answer. No.
Question. The next one is February 14th, 1996. Once again, you are
the requester, and it shows that he's meeting with you.
Would he have met with you on that date?
Answer. I don't remember that, no.
Question. The next one is September 25th, 1996. Do you recall the
circumstances of this visit?
Answer. No, I don't.
Question. And once again it shows that he's meeting with you.
Mr. Lawler. Well, Jennifer, in all fairness, I think what it shows
is, based on her testimony, that she would put her name in sometimes if
he was coming to the office at which she was physically located.
I don't think it's her testimony, nor is it accurate, that the name
in the visitee column where she appears means necessarily a meeting in
the sense of any formal substantive contact or agenda.
The Witness. That is true.
EXAMINATION BY MS. SAFAVIAN:
Question. I understand that just because your name is down there
does not mean he actually met with you. That is all I'm asking. I just
want to know if you recall any specific instance where he actually did
come to meet with you specifically.
Answer. No.
Question. Do you recall any time that Mr. Middleton would come and
meet with Maggie Williams and then meet with anybody else?
Answer. No.
Question. September 25th, 1996. Do you recall the circumstance of
that visit?
Answer. No.
Ms. Safavian. I will mark that for the record ER-5.
[Ryan Deposition Exhibit No. ER-5 was marked for identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Do you know whether Mr. Middleton ever met with the First
Lady?
Answer. I don't know.
Question. Would Mr. Middleton contact you often regarding being
able to enter the Old Executive Office Building or the White House or
for any other reason?
Answer. I think he contacted me occasionally, not often. I would
say no.
Question. Can you tell me what the purpose of those calls were for?
Answer. The only one I remember specifically is that there was a
photo he was looking for, and we located it for him, and he came to
pick it up at the office.
Question. Let me pass this to you. This is going to be, again,
several telephone messages that were taken, that were calls from Mark
Middleton or somebody in his office. Most of them, if you will flip
through them, you will see the messages are to you. The first one,
however, which is EOP 059041, who is that? I can't read--I don't know
who that is addressed to.
Answer. That's to Marge Tarmey.
Question. And then the other ones, I believe, are each addressed to
you; is that correct?
Answer. Yes.
Question. We will just go through these quickly. The first, which
is not to you, but it shows Middleton calling to make--he is asking for
lunch reservations for seven be made under Maggie's name.
Is this something then that you would have taken care of even
though this is not addressed to you?
Answer. Either myself or Marge Tarmey.
Question. I'm sorry, who is Marge Tarmey?
Answer. She was the assistant to the chief of staff at the time.
Question. So you don't specifically recall setting up this
reservation for Mr. Middleton?
Answer. No.
Question. The next one, the message is dated 6/7/95. The message
says, Monday, Mess, two people, 12 or 1:30. Do you recall arranging
this reservation for Mr. Middleton?
Answer. Not specifically, no.
Question. The next one is dated 10/4/95. He is once again asking
for Mess reservations for four people in this instance.
Do you recall this reservation?
Answer. I don't recall it specifically, no.
Question. The next one is dated 7/20/95. It says, 12 for three
people. I'm guessing that would be a 12 noon reservation for three
people?
Answer. Yes.
Question. And it looks like they are listing the names. Those
numbers next to the names, would those be birthdates?
Answer. Yes.
Question. And those are necessary for what?
Answer. To clear people into the building.
Question. Do you recall making this reservation for Mr. Middleton?
Answer. I don't.
Question. And the last one is dated 1/17/96. Once again he is
asking for reservations in the Mess for four people.
Do you recall making this reservation for him?
Answer. I don't, no.
Question. Now, we spoke earlier about mess reservations and Mark
Middleton, and you told me that on at least one occasion he called and
asked for reservations to be made under Maggie Williams' name, and she
did not attend.
Answer. Right.
Question. Do you think that for these other times when he called--
first of all, do you think for these other times he called you would
have made these reservations?
Answer. It's possible.
Question. Every time he would call, what was the process you would
go through to see if you could get him these reservations?
Answer. I would ask Maggie, and if she said yes, then I would
contact the Mess.
Question. What was Maggie's usually response when you asked her or
told her Mark Middleton was asking for reservations?
Answer. Usually yes.
Question. Usually it was yes?
Answer. Yes.
Question. Do you know if Ms. Williams would have attended each of
these?
Answer. No, I don't think she did.
Question. Did you ever meet any of the guests that he brought with
them?
Answer. Not that I remember.
Question. Was anyone ever concerned that Mark Middleton was using
the White House Mess too often?
Answer. Not that I know of.
Question. And once again you mentioned who would pay for using the
Mess. Middleton would have had to pay for his use of the White House
Mess; is that correct?
Answer. Yes.
Question. And once again he would have received a bill you believe?
Mr. McLaughlin. We have already been over this, counsel. This has
been asked and answered.
The Witness. Maggie received the bill, and then she is reimbursed.
EXAMINATION BY MS. SAFAVIAN:
Question. And this would apply to Mr. Middleton also?
Answer. Yes.
Question. Were you the sole person who took care of White House
Mess reservations?
Answer. No. I took care of Maggie's reservations.
Question. So you would most often be in contact with Middleton
because he would usually call to have them made under Williams' name?
Answer. That would be why he was calling me, yes.
Question. Debbie Both?
Answer. Yes.
Question. You mentioned her earlier. Would she also have taken care
of any reservations for Middleton?
Answer. It's possible.
Question. Do you know who Lynn Cutler is?
Answer. Yes.
Question. Who is she?
Answer. She works in the Office of Intergovernmental Affairs at the
White House.
Question. There's another telephone message slip that I am showing
you. This one is dated--oh, I'm sorry, I think that's the wrong one.
Would Maggie Williams meet with Lynn Cutler often?
Answer. I think she knew Lynn Cutler. I don't remember how often
they met or if they met.
Question. Would you have any reason for Maggie Williams, Mark
Middleton and Lynn Cutler to have a meeting together?
Answer. I don't know.
Question. Do you know who Yusuf Khapra is?
Answer. Yes.
Question. Who is he?
Answer. I believe he used to work for Erskine Bowles when Erskine
Bowles was deputy chief of staff.
Question. Would he often contact your office on behalf of Mark
Middleton?
Answer. I don't remember. I don't know.
Question. If you will take a look at that for me. This is another
telephone message slip. It looks like it's addressed to you; is that
correct?
Answer. Yes.
Question. And the caller was Yusuf Khapra; is that correct?
Answer. Yes.
Question. And the message says Mark Middleton?
Answer. Yes.
Question. Do you know why he would be calling on behalf of Mark
Middleton?
Answer. No.
Question. Did you speak to Mr. Khapra often?
Answer. Not really, no.
Ms. Safavian. Why don't we go ahead and make that exhibit ER-6.
[Ryan Deposition Exhibit No. ER-6 was marked for identification.]
Mr. Lawler. Are you making the other one----
Ms. Safavian. Yes. I'm sorry, why don't we make that one ER-6 and
then this latest one ER-7.
[Ryan Deposition Exhibit No. ER-7 was marked for identification.]
Mr. Lawler. Counsel, just for the record, I have been looking at
the clock. We have been going about half an hour now since the break
asking Ms. Ryan questions that she doesn't know anything about; or if
she knows anything about, she knows very little about. She took phone
messages as part of her job.
We are here voluntarily. We want to answer your questions. I am
certain--and you told me that you want to ask her about Johnny Chung's
March 9 visit. We talked about a time deadline. It is 20 minutes of
5:00. We can let the deposition go until 6:00. Again, you can do
whatever you want, but Ms. Ryan does have information about the Johnny
Chung visit that I think would take you some time to go through; and to
the extent that we waste time this afternoon on questions that she
doesn't know anything about, or that I fail to see any relevance to, it
will be difficult for us to agree to continue this deposition to talk
about the stuff she does know about.
So, again, do whatever you want, but I am concerned about the time.
Ms. Safavian. I understand the time constraint, and I am doing the
best I can to get through this. However, because I do not know what Ms.
Ryan's knowledge is, I do have to ask. And I understand that you say
she doesn't have knowledge about these areas, but I don't know that
until I ask.
Mr. Lawler. Even if she does, I am saying she does have knowledge
about Johnny Chung, and her name has been brought up in a way
completely false. News reports about her and Johnny Chung are false.
The story about Johnny Chung last night, the quotes attributed to her
are false. She wants an opportunity to put on the record that those
things were false. They are directly relevant, it seems to me, to your
investigation. It was certainly something she was asked about in the
Senate investigation.
All I'm saying is she knows about that. It is an important point to
set the record straight on, and I suggest since we are here, you might
want to do that, make sure we get that on the record, and then continue
on with some of these other ancillary issues, if you will. It's just a
timing thing.
Ms. Safavian. I understand what you are saying, and I appreciate
that.
EXAMINATION BY MS. SAFAVIAN:
Question. Before we get to Johnny Chung, I want to ask you about
Charlie Trie. Do you know who he is?
Answer. I know of him through news accounts.
Question. Only through news accounts?
Answer. Yes.
Question. Did you ever meet him?
Answer. No.
Question. Do you know if Charlie Trie ever visited with Ms.
Williams?
Answer. No.
Question. Do you know if Charlie Trie ever had any business in the
White House?
Answer. No.
Question. Let me show you another telephone message. Can you tell
me who it is addressed to, because I'm not sure I can read that name?
Answer. Melanne, M-E-L-A-N-N-E.
Question. And who is she?
Answer. She was the deputy chief of staff at the time.
Question. For the First Lady?
Answer. Yes.
Question. As you can see, this says Charlie Trie called, that he
had spoken with HRC, Hillary Rodham Clinton, in Little Rock about going
to Beijing. Wants to know if he can go with her.
Do you know what Beijing trip that this is referencing to?
Mr. Lawler. She has testified she doesn't know anything about
Charlie Trie other than news reports. This document is not addressed to
her.
Ms. Safavian. But I am asking about the Beijing trip for the First
Lady.
Mr. Lawler. You could have asked her that separately from the
document than to try--well, do it however you want. It just doesn't
seem, particularly tied to her previous answers and in general, the
Beijing trip doesn't seem of any relevance since it's so broad.
The Witness. I would only say Mrs. Clinton went to Beijing at
around this time, so that must be what it refers to.
EXAMINATION BY MS. SAFAVIAN:
Question. Were you at all involved in the arrangements for Mrs.
Clinton going on this Beijing trip?
Answer. No.
Question. Was Ms. Williams?
Answer. Possibly. I was not aware of her involvement.
Question. Do you know whether Charlie Trie attended this trip with
her?
Answer. I don't know.
Question. Do you know whether Johnny Chung attended this trip with
the First Lady to Beijing?
Answer. I don't know.
Ms. Safavian. Let's make this Exhibit Number ER-8.
[Ryan Deposition Exhibit No. ER-8 was marked for identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Moving on to Johnny Chung. Obviously, you know who Mr.
Chung is?
Answer. Yes.
Question. Can you tell me when you first met Mr. Chung?
Answer. I don't remember my first meeting with him.
Question. Do you recall when it was?
Answer. No, not specifically, I really don't.
Question. Do you recall how you met him?
Answer. I recall meeting him at some point in the Old Executive
Office Building, stopping by our office, but I don't remember when it
was.
Question. Did somebody introduce you to him, or did he just kind of
introduce himself to you?
Answer. I believe he introduced himself.
Question. After you met him, did you inquire with anybody else in
the office as to who he was?
Answer. At some point I remember finding out who he was. I don't
remember how that came about or what the instance was.
Question. And what did you find out about him?
Answer. That he was a trustee of the DNC.
Question. Was that all that you heard about him?
Answer. That he was from Los Angeles and ran a fax business from
out there.
Question. Do you know who told you all this about him?
Answer. I think Maggie Williams, but I don't remember specifically.
Question. Were you aware he was a large contributor to the DNC?
Answer. I became aware of that.
Question. Would Johnny Chung visit the First Lady's office often?
Answer. Yes.
Question. Could you say how many times?
Answer. He visited Washington, and I would say any time he was
visiting Washington, he would stop by. I don't know what the frequency
was or exactly how many times it was.
Question. Did it seem to be every time he was in Washington he
would stop by?
Answer. That was my impression.
Question. And what gave you that impression?
Answer. It was just the way he was. I had the impression that if he
were in town, he would definitely take the opportunity to stop by.
Question. Was there any reason to him stopping by?
Answer. It was my impression that he thought that he was friendly
with people in our office, and it was definitely my impression that he
thought rather highly of Mrs. Clinton and was a fan of hers, so to
speak. So it seemed he liked to come by the office, and any sort of
association he could have he enjoyed. That was my impression.
Question. Who did he normally meet with when he would stop by?
Answer. He didn't have meetings in the office. He would stop by and
generally say hello, and I sat in that main reception area, so he
generally would talk to me.
Question. Would he then move on and speak with other people, or can
you just tell me a little about some of his visits, what he would do?
Answer. His visits consisted of him talking. That was about it. He
would stop by and he would talk and talk, and that was about it.
Question. What would he talk about?
Answer. He would talk about himself, his business, his travels, any
events he had been to recently. He, on a couple of occasions, requested
tours of the White House.
Question. On a couple of occasions?
Answer. Yes.
Question. Who would he make that request to?
Answer. Either myself or the Visitors Office directly.
Question. And when he made the request to you, what did you do
about them?
Answer. Contacted the Visitors Office.
Question. Was that as far as you went with his request?
Answer. It generally is not a problem to set up tours. It's a
relatively easy thing to set up. So I would try to check with them as
to the availability and then see what we could do.
Question. How many times do you recall that he asked for a tour to
the White House?
Answer. At least twice, maybe more than that.
Question. Did he have other people with him that he wanted to be on
the tour?
Answer. Yes, usually.
Question. Large groups of people?
Answer. No. The largest group I remember is the group he brought in
March of '95.
Question. When he asked you for a tour, you would just contact----
Answer. The Visitors Office.
Question. The Visitors Offers. And they would take care of it from
there?
Answer. Yes.
Question. Did Mr. Chung usually call before he would stop by?
Answer. Yes.
Question. And who would he contact when he would call?
Answer. Me usually.
Question. And what would he say to you?
Answer. That he was in Washington, he would love--he generally
would say, I would love to stop by and say hello. And then when--I
think when I resisted more, he started calling from the lobby to be
cleared in.
Question. From the lobby of where?
Answer. Of the Old Executive Office Building.
Question. And what do you mean you started resisting?
Answer. I think it became more apparent to him that I would say we
were busy and we didn't have the time, or I think actually maybe a
couple of times he would call and I either wasn't there or didn't take
the call. So I think he then figured out if he was standing in the
lobby, he could pretty much insist on why couldn't someone clear him
in.
Question. And would somebody normally clear him in?
Answer. Yes.
Question. And how often would he just show up in the lobby and ask
for clearance?
Answer. That was something I think--it seemed to be a pattern he
developed later. Initially he would call from his office or from his
car. But I remember several occasions where he would call and say I'm
in the lobby.
Question. And once again, did he give you any reason for wanting to
stop by?
Answer. It was to visit the office and to say hello and I'm in
town. He thought of himself as a good friend of--you know--I think he
thought that, you know, we were excited to see him the way he was
excited to see us. That was my impression.
Question. Was that the case? Were you excited to see him?
Answer. No, not necessarily, no.
Question. Why do you say not necessarily?
Answer. I think, you know, at first I didn't really know who he
was. He's perfectly nice, he really is. He's fine. But he just has a
tendency to talk a lot and to linger, and my desk being where it was
situated, it was difficult to get work done if someone's standing and
talking to you for an extended period of time.
Question. How long would he normally stay and talk?
Answer. It depended and it varied. I'd say probably the longest
would be close to 25 to 30 minutes.
Question. And would he spend most of that time with you just
talking?
Answer. Yeah. I was really the only person that he could get to,
because I was in the reception area.
Question. So in the beginning I guess you didn't have a problem
with Mr. Chung?
Answer. No.
Question. Did he at some point become a nuisance?
Answer. Yes, I think at some point I found it to be a nuisance, his
visits being a nuisance.
Question. And do you recall when you started to feel he was a
nuisance?
Answer. I don't remember when it was. No.
Question. Can you just give me a general time frame? Would it have
been 1995, 1996? Before that?
Answer. I would say 1995 at some point, but I don't remember when.
Question. Do you remember was it like towards the end of the year?
Answer. I don't know.
Question. When he would just stop by to chat, did he usually have
somebody else with him?
Answer. Occasionally, he did.
Question. Do you recall who any of those people were?
Answer. Usually, they were somebody who worked with him, an
assistant or someone would accompany him.
Question. Who worked for him?
Answer. Yes.
Question. Did Mr. Chung attend any luncheons with the First Lady?
Answer. Not that I know of.
Question. And once again you told me you did not prepare the list
of attendees for the First Lady's lunch.
Do you know if Mr. Chung was invited to a lunch, how he would have
been invited?
Answer. No.
Question. You mentioned earlier that he felt that he was a friend
of the First Lady's?
Answer. Yes.
Question. Do you happen to know what the First Lady thought of him?
Answer. No, I don't know.
Question. Did Maggie Williams ever comment to you at any time about
Mr. Chung?
Answer. I'm sure--I don't remember specifically. I remember I knew
about Mr. Chung from Maggie Williams, so--I mean, I knew of him through
her.
Question. Did Maggie Williams and you ever talk about the fact that
he's stopping by too often, I can't get my work done, what am I
supposed to do? Did you ever have any of those type of conversations
with Ms. Williams?
Answer. Yes.
Question. And what was her response?
Answer. Her response was, you know, he was harmless, it seemed to
please him, so you know, what was the harm. We might as well just put
up with him.
Question. So Ms. Williams never felt like you should put a stop to
him stopping by and chatting?
Answer. No, no.
Question. So she didn't have any problem with him coming up as
often as he did?
Mr. Lawler. My problem is characterizing how Ms. Williams felt
about him. Her testimony is what she said.
EXAMINATION BY MS. SAFAVIAN:
Question. That's fine. But Ms. Williams never said, okay, don't
stop sending him up, you can tell him, no?
Answer. She never said that, no.
Question. Did the DNC ever contact you or anybody else in the First
Lady's office regarding Johnny Chung and any special request on his
behalf or ask you to help him out with any favors?
Answer. Not that I know of, no.
Question. No one at the DNC ever contacted you?
Answer. No.
Question. Why don't we talk about the March 8, 1995, meeting with
Johnny Chung. Do you recall meeting with him on that date?
Answer. Yes.
Question. Do you recall him asking you whether he could get a five-
member delegation of executives from the China Chamber of Commerce to
have lunch in the White House Mess?
Answer. Yes.
Question. Do you recall him asking for a meeting with the First
Lady?
Answer. Yes.
Question. What else did he ask for?
Answer. A tour of the White House and to have he and his guests
admitted to the radio address that Saturday.
Question. How did Mr. Chung ask these requests of you?
Answer. He stopped by the office and he asked to speak with me and
he said he had these men visiting from China, and that he would like to
see if he could get them a tour of the White House, to the White House
Mess, if he could get them into the President's radio address and if he
could get a photo with Mrs. Clinton.
Question. And what was your response to those requests?
Answer. I said we would check and see. But he had also mentioned at
the time that he was donating money to the DNC.
Question. If you could, let's try and backtrack a little bit here.
Did Mr. Chung call you on his way over that day?
Answer. No.
Question. How did he get to your office that day?
Answer. He showed up.
Question. Do you know who let him in?
Answer. Only because I've seen WAVE records and the Senate
deposition, I believe they show that Brian Bailey waved him in.
Question. And who was that?
Answer. He worked for Erskin Bowles, who was Deputy Chief of Staff
at the time.
Question. Let's just take a quick look at that.
I'm handing you WAVE records from March of 1995, showing Johnny
Chung being waved into the White House.
It shows--did you say the name was Bailey that you mentioned
earlier?
Answer. Yes.
Question. And it shows the room was 174.
Answer. Yes.
Question. Where is that?
Answer. That's in the Old Executive Office Building down the hall.
Question. Who does Bailey work for?
Answer. At the time he worked for Erskin Bowles who was then the
Deputy Chief of Staff.
Question. Do you know why Johnny Chung would have met with Bailey?
Answer. No.
Question. Have you ever spoken to Bailey about Johnny Chung?
Answer. No.
Question. So Mr. Chung just appeared in the reception area of your
office?
Answer. Yes.
Question. And you were not aware that he was there that day?
Answer. No.
Question. He then asked you to help him out with these requests for
his business associates?
Answer. Yes.
Question. When did he mention to you that he was donating money?
Answer. When he was asking me for these requests. For the tour, the
lunch, at the same time.
Question. I'm just trying to get an idea of the sequence of the
conversation that you had with him. I know you can't, of course, recall
the exact words that were used.
Answer. I don't remember the sequence. I don't remember whether he
mentioned it first or second in terms of the requests and the donation
or vice versa.
Question. What did he tell you about the fact that he was going to
make a donation?
Answer. He said he was in town, he was here in Washington, he often
mentioned that, too, when he would stop by, and said while I'm here,
I'm donating money to the DNC.
Question. And that was what he said to you on this visit?
Answer. Yes.
Question. Did he tell you how much he was donating to the DNC?
Answer. At some point I became aware of the $50,000 amount. I don't
remember when that was. I don't know if it was at this time or if it
was the next day when he actually came. I don't know when. But I did
know at some point $50,000.
Question. And you knew that from Mr. Chung himself?
Answer. Yes.
Question. You are aware that Mr. Chung has--there's been an account
of this day in the Los Angeles Times as well as other newspaper
articles. There was also an interview with Mr. Chung with Tom Brokaw
just last night on NBC Nightly News and Dateline. Are you aware that
Mr. Chung relates the account that he asked for these requests and he
had asked if you could help in any way and after meeting with Maggie
Williams, you came back and said, well, yes, the First Lady could use
some help paying off an $80,000 Christmas party bill that she owes the
DNC. Are you aware of that account?
Answer. I'm aware that that is his account, yes.
Question. Did you talk to Maggie Williams about Mr. Chung's
request?
Answer. Yes, I did.
Question. When did you speak with her?
Mr. Lawler. Can you just ask her if that account is true?
Ms. Safavian. I will. My first question is, is she aware of it, and
she is aware of it.
Mr. Lawler. Yes.
EXAMINATION BY MS. SAFAVIAN:
Question. So you did meet with Ms. Williams?
Answer. Yes.
Question. And when was that?
Answer. Right after I spoke with Mr. Chung, I went to speak to
Maggie Williams.
Question. Was Mr. Chung still there, still in the reception area
when you spoke with Ms. Williams?
Answer. Yes.
Question. What did you tell Ms. Williams?
Answer. I said that Johnny Chung was here and he had some
businessmen from China here and he was hoping to get the tour, the
radio address, the Mess and the photo with Mrs. Clinton, and he was
also going to be donating money to the DNC while he was here.
Question. You told Ms. Williams as you were telling her what he
wanted, you told her at that time that he was going to donate money to
the DNC?
Answer. Yes.
Question. Did you give her an amount?
Answer. I don't remember giving her an amount. So I don't think I
knew it at that point, but it's possible that I did. I don't remember.
Question. What was Ms. Williams' response?
Answer. Her response was we would see--you know, we'd see if we
could set those things up for him and that it was helpful to know about
his donation because then maybe that would enable the DNC to pay off
some of their debts.
Question. What do you mean by their debts?
Answer. Some of the DNC's debts to the White House.
Question. The DNC's debts to the White House?
Answer. Yes.
Question. Did the First Lady owe any--did she have any debts with
the DNC?
Answer. No. It was my understanding that the DNC owed the White
House money.
Question. Was that for a Christmas party, as Mr. Chung has
mentioned in his account?
Answer. I didn't know what it was for.
Question. Did Ms. Williams ever tell you or suggest to you an
amount of money that Mr. Chung could donate or could contribute?
Answer. No, she never did.
Question. Do you have any idea where Mr. Chung has come up with you
suggesting $80,000 to help pay off a Christmas party for the First
Lady?
Answer. No, I don't.
Question. Did you ever mention a bill of $80,000 to the DNC to Mr.
Chung?
Answer. No.
Question. Did you ever mention any debts that the DNC owed to Mr.
Chung?
Answer. Not that I remember, no.
Question. After you spoke with Ms. Williams, what did you do next?
Answer. I went out to Mr. Chung and I told him we were going to try
to set up what we could, set up of his requests, and he was going to
contact me later that day.
Question. What did he say in response to that?
Answer. He was very pleased. He was excited at the prospect of
being able to get at least some, a couple--some of these things done.
And he said he hoped that Maggie got credit for his donation.
Question. What did he mean by that?
Answer. I don't know. I have no idea what he meant some of the
time, but I don't know what he meant at that time, either.
Question. When did he mention that to you, that he hopes Maggie
gets account----
Mr. Lawler. Credit.
EXAMINATION BY MS. SAFAVIAN:
Question. I'm sorry, credit for his donation?
Answer. I can't remember if that's verbatim or how he said it, but
it was something along those lines, like I hope Maggie gets this credit
for this donation, and it was more a statement, but I remember that's
what he was saying as he left.
Question. When Ms. Williams had mentioned that she seemed pleased
to you that Mr. Chung mentioned he was going to donate to the DNC, do
you have any idea how she knew that perhaps that donation would go to
pay off some debts?
Answer. Oh, I don't know. It was more--I don't remember exactly
what she said, but it was something along the lines of that's helpful
to know, that they're getting this donation, maybe it will help with
some of the debts that they owe the White House. That's the general
gist of what I got from her. I don't know.
Question. Did Mr. Chung ever tell you about these guests that he
wanted to bring with him?
Answer. He had told me that they were businessmen visiting from
China.
Question. Did he ever tell you who they were? Specifically by name?
Answer. He may have. I don't remember that.
Question. Did he happen to give you their business cards?
Answer. Not on that day, no, he did not.
Question. Did he give you their business cards on another day?
Answer. The next day when they arrived, they, themselves, handed me
business cards.
Question. But Mr. Chung never gave you their business cards?
Answer. No.
Question. Did you inquire with him as to who are these people that
you want to bring to meet with the First Lady?
Answer. No, I just knew that they were businessmen visiting from
China.
Question. Was it something that is normally done when people want
to bring individuals or guests to meet with the First Lady, do you
normally have to know who these individuals are and is there usually a
security clearance? What's the process generally to meet with the First
Lady?
Answer. Well, when I would clear them in, I would need their
passport numbers, if they were from another country, and that would go
through the WAVE system, so that would be the security check for them.
Question. And that was all that you would have to do?
Answer. Yes.
Question. For instance, with these businessmen, you did eventually
get their passport numbers?
Answer. Yes.
Question. Mr. Chung left on the 8th?
Answer. Yes.
Question. You told him you would look into his requests?
Answer. Yes.
Question. And that he was supposed to call you later that day?
Answer. Yes.
Question. Did he contact you later that day?
Answer. Yes. I don't remember it specifically, but he must have,
because we did set everything up. I did communicate to him. I don't
remember my conversation with him.
Question. Can you tell me--when did you know that this was all set
up? Was it later that day?
Answer. I contacted the Visitors Office about the tour. I contacted
the Mess about the lunch, and I don't know how Maggie Williams handled
the photo, setting up the photo with Mrs. Clinton. And the radio
address, I don't remember how that was handled.
Question. So by the end of that day, March 8, the day that he
requested these favors, if we want to call them that, by the end of
that day, each one with the exception of the radio address, because you
said you don't know about that, the White House Mess, the tour, the
photo with the First Lady, each one of those were scheduled, they were
set?
Answer. Yes.
Question. And you had notified him by the end of that day?
Answer. Yes. I don't remember specifically talking to him later
that day, but as I said, it was set up so it's probable that I spoke
with him that day.
Question. Do you recall Mr. Chung returning on March 9, the next
day?
Answer. Yes.
Question. And were you aware that he was returning on that day?
Answer. Returning?
Question. I'm sorry, that he was arriving on March 9?
Answer. Yes.
Question. This was not a surprise visit?
Answer. No.
Question. Tell me a little bit about that visit.
Answer. I remember when he and his guests came to the White House,
I escorted them over to the White House Mess for their lunch and I
can't remember how it worked, although the WAVE records have helped me
in the sequence, and I believe what then happened is Ann McCoy from the
Visitors Office took them on their tour following lunch. I believe they
then left the White House because they returned later that day and I
only know this from these WAVE records.
Question. And we can take a look at that right now. They do show
that there are two entries for March 9?
Answer. Yes.
Question. An your name is listed for both of those. So you would
have entered this into the computer for both times?
Answer. Yes.
Question. And do you know why he would have left and come back?
Answer. I believe, this is based on how I've seen these WAVE
records. I have a recollection of when they returned that they were
late--I remember that they were late in coming to the White House when
they came to have their photo with Mrs. Clinton.
Question. How late were they?
Answer. I just remember in my mind thinking to myself, where are
they, because I remember the photo had been set up and so I remember
when they arrived, I went to go meet them at the entries of the OEOB so
we could go directly over to the White House.
Question. So they arrived in the reception area, Mr. Chung and the
delegation, and you then escorted them to the White House Mess?
Answer. That's my memory, yes.
Question. And they had lunch there. And then is it your----
Answer. I don't have a real memory past that. I'm guessing, because
I don't remember escorting them out of the Mess and I don't remember
them again until they came to the OEOB Pennsylvania Avenue entrance
later that day. I would imagine that Ann McCoy had done taking them on
their tour directly after the Mess.
Question. And then the next time you saw them was when they were
entering the Old Executive Office Building again?
Answer. Yes.
Question. And you then escorted them to the First Lady's office for
the photo?
Answer. Actually, to the Map Room on the ground floor of the White
House.
Question. When Mr. Chung arrived on that day, it is his account of
the story that he handed you an unsealed envelope, is that true?
Answer. No.
Question. Did he hand an envelope to Maggie Williams?
Answer. Yes.
Question. So Ms. Williams did meet with him that day?
Answer. I believe it was after the photo. I remember that Mr. Chung
was insistent that he wanted to hand this envelope directly to Maggie
Williams. I remember he really wanted to see her and hand the envelope
to her. I think it was after the photo that we went back to the office
since they had been late arriving for the photo, and I remember telling
Maggie that he was there and that he wanted to hand her this envelope.
Question. This is returning after the photo shoot to the Old
Executive Office Building, returning there?
Answer. Yes, returning.
Question. Did he return with the delegation or was it just Johnny
Chung?
Answer. With the delegation.
Question. And that is when you contacted Ms. Williams that he was
there and that he wanted to speak with her?
Answer. That's my memory, yes.
Question. And so what happened next?
Answer. I remember relaying that to her and she looked up at me and
she looked a little bit confused at why he wanted to do this or why he
was doing this, but then she just, okay, fine, let's just get it over
with or whatever.
Question. And what did she think she wanted to do? What was she
confused about?
Answer. Why he was delivering a donation to the DNC through her.
Question. So you had told her that he wanted to hand this check
personally to her?
Answer. Yes. I mean, I had never seen the check, I knew he had an
envelope and he said it was his contribution and that he wanted to--he
wanted to deliver it to her to deliver to the DNC. He was rather
insistent. So I explained that to her and she seemed a little confused
by that, but then she just said, okay, fine, whatever, let's just deal
with him.
Question. So you never actually looked at the check?
Answer. No.
Question. But he told you that I have a check in my hand and I want
to give it to Maggie Williams?
Answer. He--I don't know at some point implied--he had an envelope
that he wanted to give to her and he referred to it as the conclusion.
Question. So you told Ms. Williams about that and she seemed
confused at why he wanted to do it that way, but she still went to meet
with him?
Answer. Yes.
Question. What happened next?
Answer. As I remember, she said fine, so I went and got Mr. Chung,
he came in to her office in the Old Executive Office Building, I walked
in with him and he handed her the envelope. I remember it being very,
very brief and then he left.
Question. Did he say anything to her?
Answer. I don't remember standing near them. I think I stood by the
door and she was over by her desk and I believe he just walked over and
gave her the check, or the envelope, and--I don't remember hearing
anything between the two of them. I don't know.
Question. How long do you think this meeting lasted?
Answer. Oh, it was like a minute, maybe 2 minutes.
Question. And then what did Mr. Chung do?
Answer. Then he left.
Question. And his delegation left with him?
Answer. Yes.
Question. Had Mr. Chung mentioned any time prior to this that he
had a donation he wanted to give to Maggie Williams?
Answer. I remember at some point hearing from him that that's what
he wanted to do. I don't remember when. I remember immediately prior
standing with him and he was insisting that that's what he wanted to
do. I can't remember if he had mentioned it to me before that as well
or not.
Question. Do you know if Mr. Chung tried or wanted to give this
donation to the First Lady?
Answer. I don't know that he did, no.
Question. After Mr. Chung left, did Maggie Williams do anything
with the check, with the envelope?
Answer. Not that I know of, no.
Question. Did she say anything to you about it?
Answer. No.
Question. Nothing further was mentioned about it?
Answer. No.
Mr. Lawler. Evan had to leave. Her brother was playing in a big
east tournament in New York, so she left.
The Witness. I left immediately after Mr. Chung left.
EXAMINATION BY MS. SAFAVIAN:
Question. And what time do you think that was?
Answer. Somewhere in the area of 3 o'clock or so, somewhere in that
vicinity I just remember part of the reason why I remember him being
late is I was conscious of the fact that I had to leave and I had to
leave by a certain time, so I remember being very conscious of the
time, and I remember leaving almost immediately after he did.
Question. Do you know how much time he spent with the First Lady,
taking these photos?
Answer. Just a couple of minutes.
Question. Did you stay with him the whole time?
Answer. Yes.
Question. And it was just a couple of minutes?
Answer. Yes.
Question. Can you tell me what happened there?
Answer. I remember we got to the Map Room and she showed up a few
minutes later, walked in, and shook everyone's hand as we saw in the
photos and then took a group photo and then she left.
Question. Do you recall the First Lady saying to Mr. Chung as she
entered the room, ``It's good to see you again, my old friend,'' or
anything like that?
Answer. She did not say anything regarding--I know he has said that
she said ``Welcome, my good friend.'' She did not say that.
Question. She did not say that, you know that for sure?
Answer. Yes, I would remember that and that's not at all what she
would say. I remember a general greeting like, hello.
Question. She knew who he was?
Answer. Yes.
Question. So she immediately greeted him, went right to him?
Answer. I think so.
Question. Then, did he introduce her to the delegation?
Answer. I just remember she went and shook everyone's hand.
Question. And the photos were taken?
Answer. Yes.
Question. Did anything else occur?
Answer. No.
Question. And then the First Lady left the room?
Answer. Yes.
Question. And then you brought them back to the Old Executive
Office Building?
Answer. Yes.
Question. And the reason you brought them back to the Old Executive
Office Building, is that because Mr. Chung insisted on meeting with
Maggie Williams?
Answer. Probably, yes. There would have been no other reason.
Question. You mentioned that the First Lady knew Mr. Chung and
greeted him by name.
Mr. Lawler. She said hello.
The Witness. Yes, I don't remember if she greeted him by name. She
recognized him.
EXAMINATION BY MS. SAFAVIAN:
Question. She recognized him.
Do you know what relationship Mr. Chung has with the First Lady?
Answer. I don't know. I know Mr. Chung talks about meeting Mrs.
Clinton in Little Rock and I know he credits her for inspiring him in
his business and inspiring him, so to speak. So I think that was the
basis of his fondness for her. But that's only from Mr. Chung that I
know that.
Question. Do you know if they had met numerous times, I mean other
times besides Little Rock and then this one photo opportunity?
Answer. I don't know.
Question. Did Mr. Chung ever comment to you on having just visited
the First Lady or going to see the First Lady or any of his contacts
with the First Lady?
Answer. No. He mentioned attending Democratic party events, but he
didn't mention Mrs. Clinton specifically.
Question. Do you know whether or not the First Lady was aware of
the contribution that Chung had later that day given to Maggie
Williams?
Answer. I don't know.
Mr. Lawler. I think to set the record straight, Chung has stated in
media accounts that Evan said she did know, that the First Lady did
know about the account. Again, just to close the loop, I think out of
fairness you might ask that and then ask if it's true.
Ms. Safavian. I was about to.
Mr. Lawler. Again, I know it's hard to keep track, before when we
asked whether Chung--you said whether Evan was aware of Chung's version
of whether Evan then solicited $80,000 and I asked you to ask if it was
true and you said you were going to get to it and you haven't. Again,
that's something that's not true. Just to keep the record straight.
Ms. Safavian. I believe we did go through each of those accounts.
You have given me your version of what happened and you claim that
Chung's version is not accurate; is that correct?
Mr. Lawler. She's testified it's not true.
Ms. Safavian. We've gone through that.
Mr. Lawler. But for clarity of the record, I think if there's a
media account and his version is false, to put on the record what his
version is categorically for her to say, she answered the question,
obviously, but the answer is that it's not true.
Mr. McLaughlin. Is there any reason not to ask the witness that
question?
Ms. Safavian. I think we've already covered that.
Mr. Lawler. I know we did because I asked you to.
Mr. McLaughlin. He's made a request. It's a perfectly reasonable
small request. Why don't you just ask her on the record if Chung's
account is true as to those matters.
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Ryan, I believe I did ask you the question whether
the account was accurate. I will give you this opportunity to say what
you would like to about that.
Answer. Which part are we talking about?
Question. They're talking about the news accounts.
Mr. Lawler. Whether it is true that you ever solicited $80,000 for
a debt for a Christmas party from Mr. Chung.
The Witness. I never did, no.
And I think the other point was he says that he asked me whether
Mrs. Clinton was aware of the donation.
EXAMINATION BY MS. SAFAVIAN:
Question. Right. That's where we were.
Answer. Right. No. He never asked me and I never responded, so I
never responded to such a question because he never asked me that.
Question. So his version, him asking you does the First Lady know
about the contribution and him saying you said, oh, yes, she does.
Answer. Is not true.
Question. That's not accurate?
Answer. Correct.
Question. You mentioned earlier Mr. Chung also asked you to help
get his guests admitted to the radio address of the President?
Answer. Yes.
Question. Did you do anything in response to that?
Answer. I don't recall--I don't recall how that was handled. I
don't recall if I called over to the Oval Office operations or if
Maggie did. I don't remember dealing with the radio address at all.
Question. So you're not aware of how he gained access to the radio
address?
Answer. No.
Question. This is a memorandum----
Mr. Lawler. You want to mark this as an exhibit?
Ms. Safavian. We may go back to it.
Mr. Lawler. And mark it then?
Ms. Safavian. Yes, I will.
EXAMINATION BY MS. SAFAVIAN:
Question. This is the memorandum from Betty Currie dated, March 28,
1995. Who is Betty Currie?
Answer. She works right outside the President's Office in the Oval
Office.
Question. Do you know what her duties are?
Answer. I'm under the impression she's an assistant.
Question. The memo states, Ceandra Scott called. She was concerned
about Johnny Chung. She stated that we should have called them prior to
their coming to the radio address. Apparently they were in Maggie's
office when the request came and Maggie said she didn't know, but to
contact DNC.
First of all, who is Ceandra Scott?
Answer. I don't know Ceandra Scott. I've heard her name before, but
I don't know her.
Question. Do you know what this memo is in reference to?
Answer. I could speculate. I've never seen the memo and I don't
know specifically what they're talking about.
Mr. McLaughlin. Don't speculate.
EXAMINATION BY MS. SAFAVIAN:
Question. Do you know whether the DNC was contacted?
Answer. No.
Ms. Safavian. Why don't we mark this as an exhibit. We're on ER-9.
[Ryan Deposition Exhibit No. ER-9 was marked for identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Are you aware that, first of all, are you aware that Mr.
Chung and his delegation attended the Presidential radio address?
Answer. Yes.
Question. Are you aware that after the radio address the President
had his picture taken with the Chinese delegation?
Answer. Yes.
Question. And how were you aware of that?
Answer. Because Mr. Chung approached me to obtain those photos.
Question. Do you recall when he did that?
Answer. I believe it was late March, early April of '95.
Question. Let me show you some more telephone messages. There are
three contained in this. The first two are addressed to you from Johnny
Chung, and the third one, if you could tell me who that's addressed to.
Answer. Marge Tarmey.
Question. Each one of these are talking about the pictures. The
first one addressed to you, the date is April 3 of '95. It says, and
the message, ``regarding pictures,'' in parentheses, ``actually he
called for Gina who wasn't here and then he asked for you.'' Who's
Gina?
Answer. Gina was an intern in our office.
Question. Was this the first time that Mr. Chung contacted you,
around this date was the first time Mr. Chung contacted you about these
photos?
Answer. I don't know, because I don't remember this message
specifically, so I don't know.
Question. Do you recall the next message, which is to you from an
Irene over at the AISI?
Answer. Not this particular message. It's hard for me to recall
exact phone messages from that time.
Question. And yet the third one is another one from Irene in Johnny
Chung's office. Each one of these are talking about photos, pictures.
Would these have been about these photos with the President?
Answer. Yes.
Question. So Mr. Chung contacted you and what did he ask of you?
Answer. He asked if I could find the photos for him.
Question. And what did you say?
Answer. I said I would check and see, that I would look into it.
Question. And did you?
Answer. Yes.
Question. And what did you find out?
Answer. I found out that they were being withheld pending NSC
looking into the individuals in the photos, to make sure it was okay to
release them.
Question. Did you find out anything else?
Answer. No.
Question. Did you get a date as to when they were going to be
released?
Answer. No. They just told me that the National Security Council
was looking into who these people were, so they were holding on to the
photos until they knew it was okay to give it to them.
Question. Do you know why the NSC was looking into these
individuals?
Answer. No.
Ms. Safavian. Let me make this an exhibit, these message sheets.
This will be ER-10.
[Ryan Deposition Exhibit No. ER-10 was marked for identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Do you know if Mr. Chung contacted anybody else, for
assistance, with getting these photos?
Answer. I don't know.
Question. Do you know who Don Fowler is?
Answer. Yes.
Question. Who is he?
Answer. He's the former Chairman of the DNC.
Question. Let me just show you this letter which is addressed to
Don Fowler from Johnny Chung, dated April 5, 1995, and you can quickly
go ahead and read that, if you will.
Mr. McLaughlin. I would note for the record Evan Ryan's name
doesn't appear on the document. We haven't been noting Bates numbers in
this deposition, but I'll note that it's Number DNC 3102463.
EXAMINATION BY MS. SAFAVIAN:
Question. Are you finished?
Answer. Yes.
Question. Can you tell me what Mr. Chung is asking of Mr. Fowler? I
don't want to read the whole thing.
Mr. Lawler. Right. Have you ever seen it?
The Witness. No.
Mr. Lawler. Then it speaks for itself, right?
Ms. Safavian. It does.
Mr. Lawler. Okay.
EXAMINATION BY MS. SAFAVIAN:
Question. Did Mr. Chung ever mention to you that he contacted Mr.
Fowler for his assistance in getting these photos?
Answer. No.
Question. Did he ever mention any other individuals' names that he
contacted in trying to get these photos?
Answer. No.
Ms. Safavian. Let's mark this as an exhibit, ER-11.
[Ryan Deposition Exhibit No. ER-11 was marked for identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. You mentioned that you were aware that the NSC was doing
a background check on these individuals?
Answer. Yes.
Question. After you made that first inquiry into the photos, did
you make any further ones?
Answer. No, not that I remember.
Question. Did Mr. Chung get in contact with you again about that?
Answer. Apparently. I mean he called on more than one occasion, but
I don't remember it specifically.
Question. Do you recall telling Mr. Chung what the status of his
photos were?
Answer. Not specifically, no.
Question. Did you later learn about what the NSC, what their
background check into these individuals had come up with?
Answer. No, I actually never found out what happened with those
photos.
Question. Do you know who Robert Suettinger is?
Answer. I believe he works for the NSC.
Question. Are you aware that there was an April 7, 1995, e-mail
from him regarding these individuals in the photo with the President
and Johnny Chung?
Answer. I believe I've seen it in another deposition.
Question. Had you seen it prior to the other deposition?
Answer. No.
Question. Were you aware that the NSC considered Chung to be a
hustler?
Answer. No.
Question. Are you aware of it now that the memo----
Mr. Lawler. She was shown the memo during the deposition over on
the Senate side.
Ms. Safavian. Right.
Mr. Lawler. And she read it and it says what it says.
EXAMINATION BY MS. SAFAVIAN:
Question. Yes. So you are now aware that the NSC considered him a
hustler?
Answer. Yes.
Mr. Lawler. Well, she's aware that the memo says what it says, and
whether that can be fairly said that the NSC as a body considered
Johnny Chung anything is debatable from my recollection from the terms
of the e-mail.
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Ryan, are you familiar with a charity called
Africare?
Answer. No.
Question. Are you familiar with Back to Business Committee?
Answer. I've heard of hit.
Question. And what have you heard about it?
Answer. I know that they tried to, or maybe they did run
advertisements urging people get back to the business of government,
rather than the focus of Whitewater, et cetera.
Question. Do you know who founded the committee?
Answer. I believe Lynn Cutler did.
Question. Do you know whether Maggie Williams suggested to anyone
that they should contribute to the Back to Business Committee?
Answer. No, not to my knowledge.
Question. Do you know if Maggie Williams ever suggested to donors
that that was the way to support the First Lady?
Answer. No. Not that I know of.
Question. Do you know if Maggie Williams ever suggested to Cutler
individuals she might want to contact to donate to the committee?
Answer. Not that I was aware of, no.
Question. Would you happen to know how Lynn Cutler learned of
Johnny Chung?
Answer. No.
Question. Do you know whether or not Johnny Chung donated to the
Back to Business Committee?
Answer. I don't know.
Question. Did Mr. Chung ever contact you about Lynn Cutler? Did he
ever ask you anything about her?
Answer. Not that I remember, no.
Question. Do you know what the White House data base or WhoDB is?
Answer. Yes.
Question. What is it?
Answer. I believe it's a system set up with people's names who come
to events at the White House.
Question. Is that the only reason that it's set on, that you know
of?
Answer. That's my understanding.
Question. Did you have access to this data base?
Answer. Yes.
Question. Do you recall when you got access to this?
Answer. No, I don't recall when.
Question. Let me show you this computer service request. Does this
refresh your recollection as to when you may have received service?
Answer. Yes, I suppose it would have been late, October '96.
Question. Why did you request that the data base be installed on
your computer?
Answer. I didn't request it. I remember that it was assigned to
certain people in the office and I was one of the people it was
assigned to.
Question. Do you know any reason why it was assigned to different
people in the office, including yourself?
Answer. I believe it was assigned to me because I worked for Maggie
and as Chief of Staff she would be the person to have access to it, and
my recollection is that they gave it to me as well because Maggie would
be more likely to have, if she had any need for it, to go through me
than to use it herself.
Question. Do you know why in October you would have needed the data
base to be installed on your computer and not prior to this date?
Answer. I don't know. As I said, I didn't request it. I just
remember that it was assigned to me.
Question. Did you have a security level for using this data base?
Answer. I don't know if it was a requirement or not. There's
certain security clearances you have to get in order to be a staff
member there, but I don't know if--to be logged on to WhoDB, I don't
know if it was necessary to have a certain security level.
Question. Did you have unlimited access to the data base?
Answer. I didn't really use the data base terribly often. I don't
know. I don't know.
Question. What would you use it for?
Answer. I used it to get people's addresses normally. People in the
office knew I had it. All the photos with Mrs. Clinton from her travels
and at events at the White House would come back to our office and so
in order to send the photos out, we usually, if we couldn't find
people's address or phone number, it was the easiest way to find them.
Question. And you would usually do that at the request of somebody
else?
Answer. Yes.
Question. Was there any one person who would normally ask you to
conduct those searches?
Answer. No. Generally a lot of interns in the office tried to--it
was part of their duties to send the photos out. So if there had been
an event at the White House and we had the person's name, we generally
had their address and phone number in the WhoDB and that would be how I
would be able to send the photos out to them.
Question. Would the interns be able to access the data base?
Answer. No.
Question. Do you have any knowledge of the purpose for which other
people in the office would use the data base?
Answer. No, I don't know.
Question. Did you have any discussions with Maggie Williams about
the data base?
Answer. No.
Question. Do you know if Ms. Williams ever used the data base?
Answer. Not that I know of. I don't think she did.
Question. Do you know if the First Lady ever used the data base?
Answer. Not that I know of.
Question. Do you have any knowledge of the transfer of data from
the data base to any other organization or group that wasn't involved
with the White House?
Answer. No.
Ms. Safavian. If we can just go off the record for a few minutes, I
may be close to finishing.
[Off the record.]
Ms. Safavian. Let me make this computer services request exhibit
ER-12.
[Ryan Deposition Exhibit No. ER-12 was marked for identification.]
Mr. Lawler. That's fine. I would note for the record and there's no
disagreement, although you have been asking Evan about the WhoDB
element of this document, it is a computer request submitted by, not by
Ryan, not by Evan Ryan but by some Van Praagh for a series of computer
work, remove IBM hard drive, install 486 hard drive, network computer,
install U.S. 2000 load. I don't know what that is. Finally, the fifth
element is install WhoDB software.
So just for the context, this looks to be a general request by
someone other than Evan to update the computer at her desk rather than
any specific request on her part for access to a specific data base.
Ms. Safavian. Okay. That's fine.
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Ryan, we did speak briefly just a little while ago
about an e-mail from Robert Suettinger and you mentioned that you had
seen this before in your Senate deposition. I now have that document
and I would like to go ahead and put that in front of you again so we
can discuss it.
If you would like, please take a moment to read through that.
Is it your prior testimony that the first time you saw this was in
your Senate deposition?
Answer. Yes.
Question. As you can see, the second paragraph of the e-mail says,
quote, ``Having recently counseled a young intern from the First Lady's
office who had been offered a dream job by Johnny Chung, I think he
should be treated with a pinch of suspicion.'' Do you know who the
young intern is that is referenced in this e-mail?
Answer. Yes.
Question. Who is that?
Answer. Gina Ratliffe.
Question. Did you mention her name earlier?
Answer. I may have. I don't know.
Question. In case you hadn't, who is she?
Answer. She was an intern in our office at that time.
Question. And, first of all, how do you know that that is the young
intern that is referenced here?
Answer. Because I remember Johnny offering her a job. That's the
only intern that I know of that he offered a job.
Question. Do you know what this dream job was that he offered her?
Answer. It was the type of job where she would be his assistant in
Washington. She would be based in Washington.
Question. And how did you find out that he offered her this job,
was it through Mr. Chung?
Answer. Through Gina Ratliffe.
Question. Through Gina.
Question. And what did Gina tell you about that?
Answer. Just that she had been offered this job by Johnny Chung.
And that it sounded great. She was going to be based out of Washington,
and she seemed excited about it.
Question. Did she accept the job?
Answer. Yes.
Question. Do you know why Mr. Chung would have offered this job to
Gina?
Answer. I think he----
Mr. Lawler. Do you know?
The Witness. I don't know.
EXAMINATION BY MS. SAFAVIAN:
Question. Did he have a lot of contact with Gina?
Answer. He would see her in the office and she's one of the people
that would answer the phone. In that respect, yes.
EXAMINATION BY MS. SAFAVIAN:
Question. Did Johnny Chung ever offer you a job?
Answer. No.
Question. Did he ever offer anybody else in the office a job?
Answer. Not to my knowledge.
Question. The e-mail continues: Quote, ``My impression is that he's
a hustler and appears to be involved in setting up some kind of
consulting operation that will thrive by bringing Chinese entrepreneurs
into town for exposure to high-level U.S. officials, end quote.''
We talked about this very briefly. When was the first time you
learned that the NSC considered Johnny Chung a hustler?
Answer. I believe whenever this came out in the news or when I
saw--I don't remember when I saw this.
Mr. McLaughlin. Your question assumes the NSC considers Johnny
Chung to be a hustler. Why don't we just stick to the text of the e-
mail. The document speaks for itself. I don't think it indicates what
the NSC does and does not think.
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Ryan, do you know if the First Lady's Office was ever
made aware of this e-mail?
Answer. I don't know.
Question. So you don't know if it was ever sent over to the First
Lady's Office?
Answer. I don't know.
Question. Real quickly, you mentioned that Gina accepted the job
with Johnny Chung?
Answer. Yes.
Question. Do you know for how long she worked for him?
Answer. No. I believe it was a matter of months, but I don't know
how long.
Question. Did you keep in contact with her after she left and
started working with him?
Answer. Yes, somewhat.
Question. Did you ever ask her how her new job was; did she ever
tell you anything about Johnny Chung?
Answer. She was not happy in her new job. She initially may have
been, but eventually was not happy because she wasn't being paid as she
had been promised.
Question. It was less salary than she was promised?
Answer. Or I think had not been paid for an extended period of
time.
Question. Did she say anything else to you?
Answer. She was upset about that, and I think she, you know,
therefore was going to leave the job.
Question. Did she leave?
Answer. Yes.
Question. Can you put a time frame on that at all as to how long
she was with him?
Answer. Maybe 4 months. I can't say specifically, but that's my----
Question. Do you know what she did for him?
Answer. She was based in Washington. She was in charge of setting
up reservations at restaurants for dinner--this is what she told me, I
don't know for a fact--checking out museum exhibits that might be
interesting to the visiting guests. It was something along those lines.
Question. Do you know where she is now?
Answer. She left Washington, I think, about a year ago, because I
remember there was a going away party for her, and it was sometime late
last summer.
Question. Do you know how much she was promised for her salary?
Answer. I don't know the amount, no.
Ms. Safavian. I will make the e-mail from Robert Suettinger ER-13.
[Ryan Deposition Exhibit No. ER-13 was marked for identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Ryan, what I would like us to do very quickly, these
are WAVE records of Johnny Chung.
Mr. Lawler. There are different than the ones we already looked at?
Ms. Safavian. Well, no, I gave you '95? That is another copy. Stick
with what I have in front of you so we do not get confused. They are
separated by '94, '95 and '96.
Mr. Lawler. Since we talked about that one, can we mark that as an
exhibit?
Ms. Safavian. Sure, I will just put this one away.
EXAMINATION BY MS. SAFAVIAN:
Question. What I want to do is go very quickly through some of
these from the times when Johnny Chung was waved into the White House,
and I would like to know if you happen to know who the names are on the
WAVE records; who was requesting and who he was meeting with, and, if
you happen to know, any of the circumstances of the meetings.
We can start with the first page, which shows----
Mr. McLaughlin. Which EOP page?
Ms. Safavian. Starting with 008708.
EXAMINATION BY MS. SAFAVIAN:
Question. The date on the first one is February 2nd, 1994. It shows
that it was requested by somebody named Botwin, B-O-T-W-I-N, and was
visiting with someone named Foucart, F-O-U-C-A-R-T.
Do you know who either of those individuals are?
Answer. I don't, no.
Question. The next EOP is 008700, which shows a date of July 22nd,
1994, requested by and visiting with Anderson.
Do you know who that is?
Answer. No, I don't.
Question. Would you happen to know anything about this meeting?
Answer. No.
Question. The next one is EOP 08698, and we have a couple on this
page. We can start with the first one at the top. It's August 2nd, 1994
is the date, and the visitor, and is requested by somebody named Lewis.
Do you know who that is?
Answer. I don't.
Question. The next entry is August 4th, 1994, Anderson?
Answer. No.
Question. The next one is August 8, 1994. We show it's requested by
somebody named Dickey, and the visitor is POTUS, which is the President
of the United States.
Do you know who Dickey is?
Answer. Robin Dickey. Or at that time it was someone by the name of
Helen Dickey. They both worked in the social office.
Question. Do you have any reason to know why Johnny Chung would be
meeting with the President on the South Lawn on that day?
Answer. It must have been an event. They only have events on the
South Lawn.
Question. The next one is August 8th, 1994, requested by somebody
named Atta, A-T-T-A.
Do you know who that is?
Answer. No.
Question. Once again, we have Lewis, and you don't know who that
is?
Answer. No.
Question. The next one is August 11th, '94. Once again that's
Anderson?
Answer. No.
Question. And then August 12th, '94 is Anderson and Lewis, and you
don't know who they are?
Answer. No.
Question. The next one is EOP 003738. The date is September 20th,
1994.
Once again it is requested by Lewis, and Lewis is the visitee?
Answer. No.
Question. September 21st, '94. This time it is requested by
somebody named Kelly.
Do you know who that is?
Answer. No.
Question. And the visitee is Quinn.
Do you know who that is?
Answer. I believe that's Jack Quinn.
Question. Do you have any reason to know why Johnny Chung would be
meeting with Mr. Quinn?
Answer. No.
Question. The next date is September 23rd, '94.
Once again Lewis is the name?
Answer. No.
Question. The next page is EOP 008694. The date is October 5th,
'94. Requested and visitee by somebody named Shakow, S-H-A-K-O-W.
Do you know who that individual is?
Answer. No.
Question. And then again at the bottom there's a date of October
20th, '94, and that's Anderson again.
Mr. Lawler. And you still don't know Anderson.
The Witness. No.
EXAMINATION BY MS. SAFAVIAN:
Question. No. The next page is EOP 005041. The date is November
1st, 1994. Johnny Chung's appearance was requested, and he was visiting
with somebody named Eder, E-D-E-R.
Do you know who that is?
Answer. No.
Question. The last entry on that page is November 29th, 1994. The
requester was somebody named--I'm not sure how to pronounce that--W-O-
Z-N-I-A-K.
Do you know who that is?
Answer. No.
Question. And visitee being Mitchell.
Do you know who that would be?
Answer. No.
Question. The last one in '94 is EOP 005040. We have a date of
December 19th, 1994. It looks like the requester was Dunn.
Is that what that looks like to you?
Answer. Yes.
Question. Do you know who that is?
Answer. Donald Dunn.
Question. Who is Donald Dunn?
Answer. I believe he worked in political affairs at the time.
Question. And the visitee is Lewis?
Answer. I don't know.
Question. The next one is December. Again we have December 19th,
'94. This time the requester is Anderson, and he's visiting with
Anderson?
Answer. No.
Question. We have another entry with Dunn on December 27, perhaps,
hard to read.
Would you have any reason to know why Dunn would be meeting with
Johnny Chung?
Answer. No.
Question. The next one is December 10th of '94.
Do you know who Brown is?
Answer. No.
Question. And the last one on that page is December 20th of 1994.
The requester is Burke.
Do you know who that is?
Answer. No.
Question. Do you have any reason to know why Johnny Chung would be
meeting with the President on that day?
Answer. I don't, but I see that it's Christmastime, so I'm guessing
it was a Christmas event.
Question. Let's move on to 1995. EOP 005039. Once again on January
11th, '95, the requester and the visitee is Dunn.
Do you have any reason to know why Dunn would be meeting with
Johnny Chung on that date?
Answer. No.
Question. The next one is January 13th, '95. It appears that Johnny
Chung is meeting with Middleton.
Do you know why he would be meeting with Middleton?
Answer. No.
Question. We have a January 30th, '95, again Dunn.
Any reason for that visit?
Answer. I don't know.
Question. January 10th, 1995, the requester and the visitee is
Frankfurter.
Do you know who that is?
Answer. No, I don't.
Question. Then we have January 12th, '95, the requester and the
visitee is Middleton.
Do you know why he would be meeting with Middleton?
Answer. No, I don't.
Question. The next page is EOP 008683. We have a couple entries on
this page where your name is mentioned. We have already talked about
the March 8 and March 9.
Examination by looking at this and seeing the dates that you
requested Johnny Chung be admitted, do you have any recollection as to
why you requested him be admitted on these dates besides March 8 and
March 9?
Answer. No. I think I stated before that Johnny Chung would stop by
or call to be cleared in just to visit and just to talk. I have no
specific recollection of a date and a specific reason that he stopped
by the office.
Question. Speaking about that, can you tell me, could anybody just
stop by in the lobby and ask to be waved in?
Answer. It's possible, yes.
Question. And there would be no problem with that?
Answer. I knew Johnny Chung. I had been made aware of who he was. I
had met him, so I definitely knew who he was. No one else really does
that. If anyone else wants to try, but----
Question. At the bottom there is a March 10, '95 date, and the
visitor and the requester is Tarmey.
Who is Tarmey?
Answer. Marge Tarmey, who was the assistant to the chief of staff
at the time.
Question. Let's turn to page EOP 005038. The date is March 11th,
1995. This time the requester is somebody named Crawford.
Do you know who that is?
Answer. I believe that's Kelly Crawford.
Question. And who is she?
Answer. She worked in Oval Office operations.
Question. Do you know why Johnny Chung would be meeting with the
President of the United States on that date?
Answer. I believe that's the radio address.
Question. Oh. The next page is EOP 008680. On May 19, 1995, Shulman
has requested Johnny Chung.
Who is Shulman?
Answer. I don't know.
Question. The visitee is Matsui.
Do you know who that is?
Answer. Doris Matsui.
Question. Do you have any reason to know why Mr. Chung would be
meeting with Ms. Matsui?
Answer. No.
Question. And there's another date there with your name.
Do you know why he would you would have waved him in on May 4, '95?
Answer. No.
Question. The page is EOP 003717. Once again we have three entries,
May 3, May 19 and May 24th, and they all have your name.
Do you have any recollection as to these visits?
Answer. No.
Question. The next page is EOP 003713. We have three entries again,
July 10th, July 11th and July 21st. Your name is on this.
Do you recall the circumstances of these visits?
Answer. No.
Question. Do you know why he would have visited on the 10th and
then the 11th?
Answer. No.
Question. The next page is EOP 005035.
The requester is Widdess?
Answer. Yes.
Question. Do you know who that is?
Answer. Yes.
Question. Who is that?
Answer. Kim Widdess.
Question. And who is she?
Answer. She worked in the Social Office.
Question. Do you know why Mr. Chung would be meeting with the
President of the United States on July 11th?
Answer. All I know is that Kim Widdess' job was guest lists. She
cleared everyone in for any events at the White House.
Mr. Lawler. And again Evan doesn't know whether he meets with the
President. Again, it is a fair question, but it is somewhat misleading
as well because she doesn't know whether he was meeting with the
President or in a room with 500 other people.
Ms. Safavian. Sure.
EXAMINATION BY MS. SAFAVIAN:
Question. I'm asking for what you may know.
Answer. Any time Kim Widdess has cleared someone in, it usually
means it is an event with a big group of people. That's her job, and it
says ``state floor,'' so I would assume it's an event on the state
floor.
Mr. Lawler. But my point is the visitee column is not, I don't
think, fairly equivalent, as far as she knows, and her testimony has
also been, equivalent to a meeting with, a substantive meeting, with
the person there.
EXAMINATION BY MS. SAFAVIAN:
Question. The page is EOP 003710. We have three visits;, looks like
two visits on September 25th and one on September 26th, and your name
is on all those with the exception of one time on the 25th when McCoy's
name is mentioned.
Do you happen to recall any of these, the circumstance of any of
these visits?
Answer. If I cleared him in, and the visitee was Ann McCoy, that
meant she worked in the Visitors Office, so she was probably giving a
tour for him.
Question. Is that all you recall about those dates?
Answer. Yes.
Question. Let me hand you another telephone message. It's dated
September 27th or 29th, it's hard to read, but it is of 1995, and it is
from Johnny Chung. It's addressed to you. The message says he is
sending two baskets of flowers, one for Maggie, one for you.
Answer. Yes.
Question. Did Johnny Chung send you and Maggie Williams flowers?
Answer. I don't recall specifically, but he must have.
Question. Did he often send you flowers? Did he ever send you
flowers?
Answer. I don't remember it specifically, but I don't know. I mean,
if he said he was, maybe he did.
Question. Do you know why he would send you flowers?
Answer. No.
Ms. Safavian. I would like to make this an exhibit, ER dash 14.
[Ryan Deposition Exhibit No. ER-14 was marked for identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Turning to the next page, EOP 005032, Johnny Chung, we
have dates of 10/16--I'm sorry, October 16, 19, 26th and 28th of 1995.
Besides your name, we have Philips as a requester for October 26th.
Who is Philips?
Answer. I don't know.
Question. Who is Brown? That's the requester for October 28th.
Answer. I don't know.
Question. Do you happen to recall the circumstances surrounding the
visits on October 16th or 19th?
Answer. No.
Question. Let me hand you another telephone message. This one is
dated October 19th, 1995. I'm sorry, October 20th, the day after one of
his visits, which was October 19th. Once again it states that he is
sending flowers to you and Maggie.
Do you recall him sending flowers on this date?
Answer. No. No, I don't.
Ms. Safavian. Let me mark that as Exhibit ER dash 15.
[Ryan Deposition Exhibit No. ER-15 was marked for identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. And then the last page of '95 is EOP 003703. The date is
December 8th, 1995. The visitee is McCoy.
Do you know why he would be there on that day?
Answer. As I said, Ann McCoy works in the Visitors Office, and I
know she had given him tours before, so that would be----
Question. Do you know if that's the date of the Christmas party at
the White House?
Answer. I don't know.
Question. Okay. Then we just have two entries in '96. EOP 008663,
February 9th, 1996. The visitee is once again you.
Do you recall the circumstance of this meeting?
Answer. I don't, no.
Question. And then the last one is EOP 005029, and the date of that
is June 15th, 1996. The requester and the visitee is listed as Forster.
Who is Forster?
Answer. I don't know.
Ms. Safavian. I will mark all of these WAVE records as Exhibit ER-
16 for all 3 years.
[Ryan Deposition Exhibit No. ER-16 was marked for identification.]
Mr. Lawler. And the part of Exhibit 16 that covers '95 is the WAVE
records we talked about earlier in the deposition.
Ms. Safavian. From March 8 and March 9.
EXAMINATION BY MS. SAFAVIAN:
Question. Just to summarize our discussion about Johnny Chung,
besides what we have already discussed, do you recall any of the topics
or discussions with Johnny Chung that you may have had?
Answer. No.
Question. Do you recall any discussions you may have had with
anybody else in the First Lady's office about Johnny Chung besides the
ones we already discussed?
Answer. No, not that I recall. No.
Question. Have you had any discussions with anyone else in the
First Lady's office since Johnny Chung has given his account of the
March 8th and March 9th, 1995 visits in the news accounts to Tom Brokaw
last night? Have you spoken with anybody else in the First Lady's
office since that has been made public?
Answer. No.
Mr. Lawler. And again, that is on advice of counsel.
Ms. Safavian. Ms. Ryan, I believe I'm done. At this time Minority
counsel probably has a few questions to ask you.
Mr. McLaughlin. I will try to keep them very brief because I know
you are anxious to get out.
Mr. Lawler. A sentiment shared by other people in the room.
Mr. McLaughlin. Shared by me.
EXAMINATION BY MR. MCLAUGHLIN:
Question. I will show you a document. Majority counsel doesn't seem
to be particularly interested in letting you address each of the
allegations that Johnny Chung has made in the L.A. Times story, so I
want to go through it now.
Do you recognize----
Ms. Safavian. Objection. That is an inaccurate portrayal of the
testimony we have had here today.
Mr. McLaughlin. Are you directing the witness not to answer?
Ms. Safavian. I'm objecting to your portrayal of my questions.
Mr. McLaughlin. I will actually be happy to respond to your
questions in saying that I don't believe that you gave her a fair
opportunity to respond to each of the allegations in this article. We
are now going to go through some of the ones you missed.
And I apologize in advance if I am a little repetitive. We might
hit one or two things you already addressed. We will try to skip those.
EXAMINATION BY MR. MCLAUGHLIN:
Question. Do you recognize what I have just put in front of you?
Answer. Yes.
Question. What does the document appear to be?
Answer. It's an article from the Los Angeles Times, July 27th,
1997.
Question. And you have seen this article before?
Answer. Yes.
Question. I'm going to--rather than go through in it in any kind of
detail, I'm going to skip ahead. If you can turn to the fourth page,
the beginning sentence on that page is, ``And in the First Lady's
office.'' The second paragraph reads, ``Here is Chung's version of
those disputed events.'' The first sentence refers to that March day,
which I believe is Chung's first visit that has been the subject of our
discussions here.
Is it your belief that that was March 8th, 1995?
Answer. Yes.
Question. The first sentence reads, ``Chung was greeted by Ryan,
who was then a staff assistant.''
To the best of your recollection, is that sentence accurate?
Answer. Yes.
Question. Second sentence: ``He showed her the business cards of
his Chinese companions and asked if arrangements could be made for them
to eat lunch in the White House Mess and meet Hillary Clinton.''
To the best of your recollection, are all of the elements of that
sentence correct?
Answer. No.
Question. Which ones are incorrect?
Answer. He never showed me business cards on that day, and he also
asked about the radio address and a tour of the White House.
Question. ``Chung also asked if there was anything he could do to
help the White House.''
Is that sentence correct?
Answer. No.
Question. And how is it incorrect?
Answer. That day he stated he was making a contribution to the DNC.
Question. Next paragraph. ``Ryan left for about 15 to 20 minutes
and returned, saying he had spoken with Williams''--``she had spoken
with Williams.''
Is that sentence correct?
Answer. Yes.
Question. Then she said, quote, ``Maybe you can help us,'' unquote.
Is that sentence correct?
Answer. No.
Question. How is that incorrect?
Answer. I didn't say anything about helping us. I mentioned that we
were going to check and see if we could set up any of the things he was
hoping to set up.
Question. The next paragraph reads, ``The aide told Chung that,''
quote, ``the First Lady had some debts with the DNC,'' unquote, ``from
expenses associated with White House Christmas parties.''
Is that sentence correct?
Answer. No.
Question. And how is it incorrect?
Answer. I never discussed expenses and that Christmas with Mr.
Chung.
Question. The next sentence reads, ``Chung believes that Ryan
mentioned a figure of around $80,000.''
Is that sentence correct?
Answer. No.
Question. How is that incorrect?
Answer. I never mentioned a figure of $80,000. I never mentioned
any money.
Question. Skip the next paragraph because it is a parenthetical not
bearing on facts.
Sentence--paragraph following that reads, ``Ryan told him, Chung
said, that she was relaying the request on behalf of Williams, who
hoped Chung could,'' quote, ``help the First Lady,'' unquote, ``defray
those costs.''
Is that sentence correct?
Answer. No.
Question. And how is it incorrect?
Answer. I was not relaying anything on behalf of Maggie Williams
regarding defraying costs for the First Lady.
Question. We will skip the next paragraph.
Paragraph after that begins, ``After making that commitment, Chung
said''--did you regard him--is it your belief that he made a commitment
to you at that meeting?
Answer. No. It was left in terms of we would be talking later that
day about setting up the different requests he had made.
Question. Okay. The next paragraph begins, ``The next morning.''
Is it your belief the next morning would be March 9, 1995?
Answer. Yes.
Question. The sentence states, ``The next morning, Chung said, he
went back to the White House and was escorted to Ryan's desk in the
reception area of the First Lady's office.''
Is that sentence correct?
Answer. I don't remember when he came. He came around lunchtime the
next day, and he and the group came to the office the next day.
Question. ``He said he gave her an unsealed envelope.''
Is that sentence correct?
Answer. No.
Question. And how is it incorrect?
Answer. He didn't give me an envelope. Never gave me an envelope.
Question. The next paragraph reads, ``According to Chung, Ryan
lifted the flap and examined the contents.''
Is that sentence correct?
Answer. No.
Question. How is it incorrect?
Answer. I didn't lift the flap, I never had the envelope, and I
didn't examine the contents.
Question. The sentence reads, ``Inside was his check and a note to
Williams, which he recalled said something like: To Maggie--I do my
best to help. Johnny Chung,'' unquote.
Do you have any knowledge as to whether that sentence is correct or
not?
Answer. No, I don't know.
Question. The paragraph begins, ``A short time later, Chung said,
the chief of staff joined them, and Ryan handed the envelope to her.''
Is that sentence correct?
Answer. No.
Question. How is it incorrect?
Answer. Johnny Chung handed the envelope to Maggie Williams
directly himself.
Question. Next sentence reads, Williams, he said, immediately led
him to a private office and called to reserve a table for the Chinese
delegation at the White House Mess.
Is that sentence correct?
Answer. No.
Question. How is it incorrect?
Answer. At that point, by the time he handed the envelope to Ms.
Williams, he had already had lunch at the Mess.
Question. The next three paragraphs we will skip because they don't
allege facts that concern you.
The paragraph following begins, ``Later, waiting for Hillary
Clinton in a White House reception room, Chung said he asked if the
First Lady had been informed of his donation, and Ryan responded,''
quote, ``yes, she definitely knows,'' unquote.
Is that sentence correct?
Answer. No, he never asked me that. I never said yes, she
definitely knew.
Question. Turning to the next page that begins with the phrase,
``Shortly before 4:00 p.m.'' I would like to direct your attention to
the fourth paragraph down that begins, ``But they agree.'' And I
believe ``they'' in that paragraph refers to White House officials,
which begins the prior paragraph. The second sentence of that paragraph
reads, ``They maintain that Williams and Ryan did not solicit the
donation and did not provide any benefits as a result of it.''
Is that sentence correct?
Answer. Yes.
Question. Let me just ask you a more general question based on that
point. Did you ever take any actions in your capacity working in the
First Lady's office that were connected to, in response to, or designed
to encourage political or other kinds of campaign contributions?
Answer. No.
Question. Let's turn to the next paragraph. It says--and I believe
this is quoting Anne Lewis, who is the White House communications
director--quote, ``Maggie Williams recalls that, on several occasions,
Johnny Chung told her that he wanted to make a personal contribution to
the Clintons,'' unquote. Lewis said, quote, ``She told him that he
could not make a personal contribution. She eventually told him he
could give to other entities, such as the Democratic National
Committee,'' unquote.
Do you have any anything in your personal knowledge as to whether
or not those statements are true?
Answer. Whether or not Maggie Williams told Johnny Chung that?
Question. Exactly, the statements, the facts that are set forth in
Ms. Lewis's account?
Answer. I myself wasn't present. No, I don't remember it
specifically.
Question. The next paragraph reads, ``Lewis said Chung was told the
First Lady's office could not arrange his attendance at the President's
radio address.''
Is that statement correct to the best of your knowledge?
Answer. I don't remember much of the radio address or dealing with
it, so I don't know what he was told.
Question. We have already covered that. I apologize for bringing it
up again.
The next sentence reads, ``And, Lewis said, Ryan'' quote, ``is sure
that she had no discussion of financial contributions with Johnny
Chung,'' unquote.
Is that sentence correct?
Answer. Yes, and no discussions he made that statement to me, but
there were never any discussions.
Question. Let me direct your attention to the next page. This page
begins with the phrase, ``Williams, who has served Hillary Clinton.'' I
would like to point you to the sixth paragraph down. It begins, ``On
Friday.'' On Friday; do you believe that that refers to March 10th,
1995?
Answer. Yes.
Question. Sentence reads, ``On Friday, Chung returned to the White
House, was admitted into the compound by the First Lady's office, and
repeated his request to Ryan.''
Is that sentence correct?
Answer. No, it's not. I was not around on Friday, March 10th. I was
in New York.
Question. You were in New York. And you have already represented
that you were anxious to leave the day before?
Answer. Yes.
Question. And is it the case you wanted to get to New York to be at
a basketball tournament your brother was in?
Answer. Yes.
Question. I would like to turn briefly back to one of the exhibits
you were just shown, Exhibit 16, and this would be the WAVE summaries
for 1995, and the second page of that group, which is Bates stamped EOP
008683.
The third line up from the bottom shows a visit from Johnny Chung,
and the requester requested by category then a visitor are both Tarmey.
They are not Ryan. So this document is consistent with your
recollection that you were not present there on Friday; is that
correct?
Answer. Yes.
Question. So this account confirms that Johnny Chung was not
telling the truth when he said that he met with you on Friday, March
10th?
Answer. Yes.
Question. I would now like to ask you----
Ms. Safavian. Counsel, are we going to make this an exhibit?
Mr. McLaughlin. I don't have exhibit stamps. If I could use one of
yours?
Ms. Safavian. Sure. The next one is ER dash 17. So we will make
this ER-17. Thank you.
[Ryan Deposition Exhibit No. ER-17 was marked for identification.].
Mr. Lawler. If that is not cooperation, I don't know what is.
EXAMINATION BY MR. MCLAUGHLIN:
Question. Next, I would like to ask you some questions that Mr.
Condit, who is a Member of the committee, has asked that we ask
witnesses concerning the burden of the investigation.
Have you been asked by any other official investigative body to
testify or provide evidence on any of the fund-raising or other matters
being investigated by this committee?
Answer. Yes.
Question. And before what body was that?
Answer. The Senate.
Question. Have you provided documents to, been interviewed by, or
been involved in a deposition by the Senate?
Answer. Yes.
Question. Is it fair to say that the matters that were covered in
today's deposition were all, or substantially all, matters that were
also covered in the Senate deposition?
Answer. Yes.
Question. Would it be fair to say that had this committee reviewed
the Senate deposition, relied on the testimony you gave there, that we
could have avoided much of the time that was spent in today's
deposition?
Answer. Yes.
Question. Have you received any requests to provide documents, be
interviewed or be deposed in the future by any other investigative
body?
Answer. No.
Question. Can you estimate how much of your time you have spent in
responding to requests from this committee for testimony, information
or documents?
And maybe we can divide that into two categories. One would be if
you can estimate how much of your time that you spent in the First
Lady's office working in response to requests of the Executive Office
of the President, and maybe how much of your time you spent on your own
preparing for this deposition today. Estimates will be fine.
Answer. In the First Lady's office dealing with this document
request on this?
Question. Exactly, from this committee.
Mr. Lawler. Can you do that?
The Witness. Not really.
EXAMINATION BY MR. MCLAUGHLIN:
Question. Can you give a figure for all of them put together?
Answer. All of?
Question. Are we talking weeks, days?
Answer. Are you talking about this investigation?
Question. I'm sorry, the Senate and House investigations put
together and any other subpoenas you have spent time responding to.
Mr. Lawler. Can you do that?
The Witness. Not really.
EXAMINATION BY MR. MCLAUGHLIN:
Question. Okay we will move on.
Can you estimate any time you have spent other than in your
official capacity preparing for this deposition?
Answer. I don't know. Bill may have a better idea.
Mr. Lawler. A substantial number of hours.
EXAMINATION BY MR. MCLAUGHLIN:
Question. Have you taken time from your job to respond to this
committee's request?
Answer. Yes.
Question. Have you incurred expenses in responding to the demands
from this committee?
Answer. Mr. Lawler. I paid for the cab on the way over.
Mr. McLaughlin. That's all the questions that I have.
Mr. Lawler. Can we go off the record for one second?
Mr. McLaughlin. Sure.
[Discussion off the record.]
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Ryan, I just have maybe two final questions. Really,
just two.
Mr. Lawler. I'm going to count. Got to be careful about promising
two questions. They may have subparts.
Ms. Safavian. That's right.
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Ryan, Mr. McLaughlin just went over and quoted from
the Los Angeles Times article, and I will not requote that. But I'm
just referencing that. Some of the quotes that were read into the
record were actually quotes from Anne Lewis; do you recall that?
Answer. Yes.
Question. Who is Anne Lewis?
Answer. She's the White House communications director.
Question. Do you know if she was ever involved in the Back to
Business Committee?
Answer. I don't know. I'm not sure. She could be. I don't know.
Mr. McLaughlin. Are you speculating?
The Witness. Yes, I'm speculating. I'm only saying that because she
started the White House recently.
EXAMINATION BY MS. SAFAVIAN:
Question. She started at the White House recently?
Answer. Yes.
Question. Do you know when?
Answer. Around Inauguration.
Question. Okay. And then one final question. Are you aware that
Johnny Chung contributed $25,000 to the Back to Business Committee?
Answer. No.
Ms. Safavian. That's all I have. Thank you very much for your time
today.
[Whereupon, at 6:20 p.m., the deposition concluded.]
[The exhibits referred to follow:]
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[The deposition of Gina D. Ratliffe follows:]
Executive Session
Committee on Government Reform and Oversight,
U.S. House of Representatives,
Washington, DC.
DEPOSITION OF: GINA D. RATLIFFE
Tuesday, November 4, 1997
The deposition in the above matter was held at the Law Office of
David N. Zacks, Lewis Clay & Munday, P.C., 660 Woodward Avenue, Suite
1300, First National Building, Detroit, Michigan, commencing at 12:05
p.m.
Appearances:
Staff Present for the Government Reform and Oversight Committee:
Jennifer M. Safavian, Investigative Counsel; and Kristin Amerling,
Minority Counsel.
For MS. RATLIFFE:
DAVID N. ZACKS, ESQ.
Lewis Clay & Munday, P.C.
660 Woodward Avenue
Suite 1300, First National Building
Detroit, Michigan
Ms. Safavian. Good morning. On behalf of members of the Committee
on Government Reform and Oversight, I appreciate and thank you for
appearing here today. This proceeding is known as a deposition. The
person transcribing this proceeding is a House reporter and notary
public. I will now request that the reporter place you under oath.
THEREUPON, GINA D. RATLIFFE, a witness, was called for examination by
Counsel, and after having been first duly sworn, was examined and
testified as follows:
Ms. Safavian. I would like to note for the record those who are
present at the beginning of the deposition. My name is Jennifer
Safavian. I am the designated Majority counsel for the committee; Ms.
Kristin Amerling is the Minority staff; and Ms. Ratliffe is represented
by David Zacks.
Although this proceeding is being held in a somewhat informal
atmosphere, because you have been placed under oath, your testimony
here today has the same force and effect as if you were testifying
before the committee or in a courtroom.
If I ask you about conversations you have had in the past and you
are unable to recall the exact words used in the conversation, you may
state that you are unable to recall those exact words, and then you may
give me the gist or substance of any such conversation to the best of
your recollection.
If you recall only part of a conversation or only part of an event,
please give me your best recollection of those events or parts of
conversation that you recall.
If I ask you whether you have any information upon a particular
subject and you have overheard other persons conversing with each other
regarding it or have seen correspondence or documentation regarding it,
please tell me that you do have such information and indicate the
source, either a conversation or documentation or otherwise, from which
you derive such knowledge.
Before we begin the questioning, I want to give you some background
about the investigation and your appearance here. Pursuant to its
authority under House Rules X and XI of the House of Representatives,
the committee is engaged in a wide-ranging review of possible political
fund-raising improprieties and possible violations of law.
Pages 2 through 4 of House Report 105-139 summarize the
investigation as of June 19, 1997, and encompass any new matters which
arise directly or indirectly in the course of the investigation. Also
pages 4 through 11 of the report explain the background of the
investigation.
All questions relating either directly or indirectly to these
issues, or questions which have a tendency to make the existence of any
pertinent fact more or less probable without the evidence, are proper.
The committee has been granted specific authorization to conduct
this deposition pursuant to House Resolution 167, which passed the full
House on June 20, 1997. Committee rule 20, of which you have received a
copy, outlines the ground rules for the deposition.
Majority and Minority counsel will ask you questions regarding the
subject matter of the investigation. Minority counsel will ask
questions after Majority counsel has finished. After the Minority
counsel has completed questioning you, a new round of questioning may
begin.
Pursuant to the committee's rules, you are allowed to have an
attorney present to advise you of your rights. Any objection raised
during the course of the deposition must be stated for the record. If a
witness is instructed not to answer a question or otherwise refuses to
answer a question, Majority and Minority counsel will confer to
determine whether the objection is proper. If counsel agree that a
question is proper, the witness will be asked to answer the question.
If an objection is not withdrawn, the Chairman or a member designated
by the Chairman may decide whether the objection is proper.
This deposition is considered as taken in executive session of the
committee, which means it may not be made public without the consent of
the committee pursuant to clause 2(k)(7) of House Rule XI. You are
asked to abide by the rules of the House and not discuss with anyone,
other than your attorney, this deposition and the issues and questions
raised during this proceeding.
Finally, no later than 5 days after your testimony has been
transcribed and you have been notified that your transcript is
available, you may submit suggested changes to the Chairman. The
transcript will be made available for your review at the committee
office. Also, we can send a copy out, and we will provide a
confidentiality agreement that you will have to sign prior to us
sending that out. But that will not be a problem.
Committee staff may make any typographical and technical changes
requested by you. Substantive changes, modifications, clarifications or
amendments to the deposition transcript submitted by you must be
accompanied by a letter requesting the changes and a statement of your
reasons for each proposed change. A letter requesting any substantive
changes, modifications, clarifications or amendments must be signed by
you. Any substantive changes, modifications, clarifications or
amendments shall be included as an appendix to the transcript,
conditioned upon your signing of the transcript.
Do you understand everything we have gone over so far?
The Witness. [Affirmative nod.]
Ms. Safavian. Do you have any questions?
Ms. Amerling. You need to verbalize.
The Witness. Yes, I understand.
EXAMINATION BY MS. SAFAVIAN:
Ms. Safavian. Do you have any questions?
The Witness. Not right now.
Ms. Safavian. I will be asking you questions concerning the subject
matter of this deposition. Do you understand?
The Witness. Yes.
Ms. Safavian. If you don't understand a question, please say so,
and I will repeat it will or rephrase it so you understand the
question.
Do you understand that you should tell me if you do not understand
any of my questions?
The Witness. I do.
Ms. Safavian. The reporter will be taking down everything we say
and will make a written record of the deposition. You must give verbal,
audible answers because the reporter cannot record what a nod of the
head or other gesture means.
Do you understand you cannot answer with an uh-huh or unh-unh?
The Witness. Yes.
Ms. Safavian. If you can't hear me, please say so and I will repeat
the question or have the court reporter read the question to you.
Do you understand that?
The Witness. Yes.
Ms. Safavian. Please wait until I finish each question before
answering, and I will wait until you finish your answer before asking
the next question.
Do you understand this will help the reporter make a clear record
because he cannot take down what both of us are saying at the same
time?
The Witness. Yes.
Ms. Safavian. Your testimony is being taken under oath as if we
were in court. If you answer a question, it will be assumed you
understood the question and the answer was intended to be responsive to
it.
Do you understand that?
The Witness. Yes.
Ms. Safavian. Are you here voluntarily, or are you here as a result
a subpoena?
The Witness. Voluntarily.
Ms. Safavian. Do you have any questions about the deposition before
we begin the substantive portion of the proceeding?
The Witness. No.
Ms. Safavian. Can we go off just for a second.
[Discussion off the record.]
Ms. Safavian. Let me just note for the record that Ms. Ratliffe has
voluntarily provided the committee this morning with several manila
folders full of documents, including letters and cards and other
miscellaneous things. She did that voluntarily, and we will be using
some of those during the deposition.
Ms. Amerling. Just so the record is clear, those documents were
provided in response to a request from the Majority; is that correct?
Ms. Safavian. That is correct.
Ms. Amerling. For documents relating to Mr. Johnny Chung?
Ms. Safavian. That is correct.
Ms. Amerling. Thank you.
Mr. Zacks. Just so the record is clear, the documents produced by
Ms. Ratliffe today constitute any and all documents in her possession
or control that relate to either her White House internship and/or her
dealings with Mr. Chung.
EXAMINATION BY MS. SAFAVIAN:
Question. Okay. Ms. Ratliffe, could you please state your full name
and spell it for the record?
Answer. Gina, G-I-N-A, Devee, D-E-V-E-E, Ratliffe, R-A-T-L-I-F-F-E.
Question. Have you ever been known by any other names or used any
other names?
Answer. No.
Question. What is your date of birth and Social Security number?
Answer. [Redacted].
Question. And your current address?
Answer. [Redacted].
Question. And how long have you resided at that address?
Answer. It has been my permanent address for 10 years, but I have
lived in numerous places.
Question. Do you presently live there with your family?
Answer. Yes.
Question. As far as your other numerous places that you have
lived----
Answer. I lived in Kalamazoo, Michigan, for 3 years when I went to
school. I lived umpteen places when I was in D.C., all throughout D.C.
I lived in Boston for 5 months. I did some campaign work, so housing
was fairly sporadic.
Question. Was this when you were in Boston that you did campaign
work, or Washington?
Answer. Yes. I went out to Seattle for a while, up in New Hampshire
for a little bit.
Question. Have you ever lived outside the United States?
Answer. No.
Question. And you mentioned that you attended college. Which
college did you attend?
Answer. Western Michigan University.
Question. Did you graduate from Western?
Answer. Yes.
Question. What was your degree?
Answer. It was public law, political science, BA in '95.
Question. Did you receive any other degrees?
Answer. No.
Question. Have you spoken with anyone other than your counsel and
with, perhaps, my staff in scheduling your deposition? Have you spoken
with anybody else about this deposition?
Answer. Yes. Two friends know that I have to give it.
Question. And are these friends located here in Michigan?
Answer. [Affirmative nod.]
Mr. Zacks. You have to answer verbally.
The Witness. Okay. Yes, they are.
EXAMINATION BY MS. SAFAVIAN:
Question. And did either one of these friends ever work or live in
Washington, D.C.?
Answer. No.
Question. Was it a matter of just mentioning to them you had to
give this deposition?
Answer. Yes.
Question. Did you review any documents in preparation for the
deposition?
Answer. What do you mean? Did I review----
Question. Any documents?
Answer. What I showed you and what was sent to me by your
committee.
Question. Okay. Have you been asked by White House counsel or
anybody else to----
Ms. Amerling. Excuse me, I have a question here. Do you have copies
of the documents that you sent to Ms. Ratliffe, because we didn't
receive a copy.
Ms. Safavian. They are just the normal letter.
No, I don't have copies. It is just the normal letter and rules
that we send to every deponent. I am surprised you didn't get a copy.
Ms. Amerling. I am not talking about that. I wanted to clarify what
documents she had received. She mentioned she reviewed documents.
EXAMINATION BY MS. SAFAVIAN:
Question. Would you like to clarify that?
Answer. I received a letter from Dan Burton requesting my
deposition, and my attorney received a letter also from Richard
Bennett, and then I received the House Resolution 167 package. That is
it.
Ms. Amerling. Thank you.
EXAMINATION BY MS. SAFAVIAN:
Question. As I was asking you, have you been asked by White House
counsel or anybody else to provide any documents in response to a
subpoena?
Answer. No.
Question. Can you briefly describe your employment history after
college, and if it is going to be a lot, tell me.
Answer. No, it is not a lot.
Question. Okay.
Answer. My first job out of college was working for Johnny Chung,
and that lasted very briefly, a few months. Then I worked for a group
called Campus Green Vote, which is a student environmental action
committee.
Question. Where was that located?
Answer. It was in D.C. And partially while I worked for Campus
Green Vote, they were part of a coalition called Youth Vote '96. That
is when I went to Boston, to Harvard.
I also worked for a political action committee called the New
Democrat Network, and that was all in Washington.
And then I came home last fall and work at a counseling clinic
currently.
Question. Can you give me a date when you returned home?
Answer. It was the end of September.
Question. Of '96?
Answer. Yes.
Question. And you currently work----
Answer. At a counseling clinic----
Question. The name of it?
Answer [continuing]. Here in Michigan.
Question. Can you provide the name of it?
Answer. It is called Access Christian Counseling.
Question. What do you do there?
Answer. I am the marketing director.
Question. You have held that job since last fall?
Answer. Um-hmm.
Question. Okay. Let's just back up a little bit.
You mentioned your first job after college was with Johnny Chung.
When did you begin your employment with him?
Answer. The spring of '95.
Question. Can you be any more specific?
Answer. I believe it was April, end of April.
Question. Towards the end of April?
Answer. Yes.
Question. And how long did that go until?
Answer. I believe I wrote a resignation letter in July. I included
that in what I gave you.
Question. What brought you out to Washington, D.C.?
Answer. I started interning out there the summer of my junior year
of college. I had an internship at the Supreme Court the fall of '94. I
worked in the Curator's Office.
And then I also was involved with the American University
Washington Semester program. I was working on a research project.
Question. For a semester?
Answer. Yes.
After that, I got the internship at the White House, and so I
stayed in D.C. my senior year, but still graduated from Western.
Question. Where did you attend school, American?
Answer. I went to American the first semester, and then I received
other credits for my internship and papers that I wrote for my second
semester credits.
Question. This would have been for 1995?
Answer. Um-hmm.
Question. Okay. The internship that you got with the White House,
when did you get that?
Answer. If started January '95.
Question. And how did you get that? Did you apply for it?
Answer. Um-hmm.
Question. Can you just give me the process of that?
Answer. There is a standard White House internship process. You
fill out an application. I did go for--I wanted to be in the First
Lady's office, and I went and spoke with a couple of people on her
staff, sort of like informal interviews.
Question. Was this after you sent in your application?
Answer. Um-hmm. I think so. This all happened at sort of the same
time. And then I was placed in Maggie Williams' office.
Question. Why did you want to work in the First Lady's office?
Answer. Because of my admiration for her and the work that she has
done.
Question. Okay. Did you get any school credit for this internship?
Answer. I believe so.
Question. Do you remember how many credits?
Answer. Not exactly.
Question. Did you have to write a paper or report at the end of the
internship?
Answer. I don't think about the internship per se. I think what I
wrote--what I wrote was actually for the school paper, and I think it
was more about student and political activism, but I don't remember
exactly.
Question. And this was something that you became aware of while you
were at American University?
Answer. The internship? Yes.
Question. I am sorry?
Answer. I knew there were White House interns before that, but I
applied the fall of '94.
Question. The fall of '94. And you didn't begin until January '95.
Is that when the internships pretty much started?
Answer. Um-hmm.
Question. And you said there was an application process.
Answer. Um-hmm.
Question. And then you met with a few people in the First Lady's
office? Did you happen to know them before you met them?
Ms. Amerling. You need to have allies.
The Witness. I am sorry. I knew a girl that interned in the health
care war room. She told me about her internship, and she sort of helped
get me the application and sort of showed me the ropes and how to apply
and introduced me to some of the people that worked in the First Lady's
office.
EXAMINATION BY MS. SAFAVIAN:
Question. And what was her name?
Answer. Suzy Pollack.
Question. She was also doing an internship when you were speaking
with her?
Answer. She finished hers in the fall of '94.
Question. Who did she introduce you to at the First Lady's office?
Answer. I think she introduced me to Evan Ryan. She was Maggie's
assistant at the time. I just went in and she sort of showed me around
the office, introduced me to----
Question. Is this Ms. Ryan you are talking about?
Answer. Yes. Suzy Pollack introduced me to Evan Ryan, I think, and
maybe Katy Button, who was Melanne Verveer's assistant at the time. The
people that I initially had an interview with was Elisa Muscatine in
speech writing. These were different--I think that actually went
through a different person, Gabriel Bushman. I don't know if these are
names you want or not.
Question. That is fine. I am interested in the process.
So you met with all these people and spoke with them?
Answer. Yes.
Question. So was Evan Ryan the only person you mentioned with whom
you spoke within the First Lady's office?
Answer. I had an informal interview with Elisa Muscatine.
Question. Did she interview all the potential internship
applicants?
Answer. I don't know what her procedures are.
Question. Did you interview with anybody else?
Answer. No, not formally. I spoke with Evan. I think she might have
talked to me a little bit about what the responsibilities are in the
Chief of Staff's office and what the interns do there. She was
previously an intern and then was hired on.
Question. Was this a paid or unpaid internship?
Answer. Unpaid.
Question. And how long were you an intern in the First Lady's
office?
Answer. I was an intern and a volunteer in the First Lady's office.
Question. At the same time?
Answer. No.
Question. Okay.
Answer. My internship, it started in January of '95, and ended
sometime in April of '95, and I am not exactly positive on exact dates,
but then once my internship ended, I filled out paperwork to be a White
House volunteer. So I had a blue badge, and my badge went from intern
to volunteer.
Question. Was it immediate, like you turned in one badge and they
gave you another badge?
Answer. I imagine. I think so. I might have turned in the badge for
the internship and then I went on the trip to China, and when I came
back--it would have been fairly soon.
Question. Do you recall filling out the paperwork to become a
volunteer while you were still interning?
Answer. I don't remember exactly when I did it. It was a fairly
simple form. It was mostly contact information. I don't remember
exactly when I filled that out.
Question. So if I ask you for a time frame, as for when you were a
volunteer, can you give me one of those?
Answer. Yes. I was then basically a volunteer spring of '95--off
and on, I think, until the following maybe June of '96. There were
times when I was in between jobs and I would go back and volunteer and
help out, or if I had extra time doing whatever job I was doing; just
because I knew what to do there, I would go and help out.
Question. Let's go back. Let's stay with the volunteer.
Were you a volunteer in the First Lady's office?
Answer. Um-hmm.
Question. So you stayed with the First Lady's office?
Answer. Um-hmm.
Ms. Amerling. When you say um-hmm----
The Witness. Yes.
EXAMINATION BY MS. SAFAVIAN:
Question. Did your job duties, responsibilities, vary at all from
an intern to a volunteer?
Answer. No. The responsibilities varied depending on what was
needed.
Question. And I assume when you were a volunteer, you also did not
get paid?
Answer. Correct.
Question. So when you say ``off and on,'' did you have like any set
hours when you were a volunteer or set days you would come in, or how
did that work?
Answer. There wasn't a specific schedule made out. I guess it was
basically depending on my availability.
Question. So it could have been one day a week, or it could have
been 5 days a week?
Answer. Yes.
Question. Did you have for yourself any set routine? Did you try to
make it in so many days a week or anything like that?
Answer. No. It wasn't regimented like that.
Question. It was just random?
Answer. However my scheduled worked out.
Question. Okay. And when you are talking about your schedule,
because you said you were a volunteer in and out with other jobs also,
so it was pretty much whenever you had free time you would then
volunteer in the First Lady's office?
Answer. Yes.
Question. So the other jobs took precedence?
Answer. If I had a responsibility to paid employment I had, yes, I
was there.
Question. Okay. Going back to your internship, can you kind of
describe for me what you did as an intern? What were your
responsibilities?
Answer. Um-hmm. It varied. Mostly answering phones, opening mail;
running an errand within the White House; dropping off something, say,
to the Press Office or Correspondence Office; greeting White House
staff or guests as they came in, whoever they had meetings with, anyone
within the First Lady's suite.
I don't know. Sometimes getting lunches or beverages, that sort of
thing. It sort of varied.
Question. Were you the only intern at the time?
Answer. No, no. There are always many interns.
Question. There were several others?
Answer. Yes.
Question. Was it like a set number of interns?
Answer. There were typically two--typically two interns assigned to
Maggie's office when I was there, but it did depend on--interns were
mostly students, so it would depend on their schedules if they were
there 5 days a week or 3 days a week or off for breaks, that sort of
thing.
There were other interns assigned to other parts of the First
Lady's office, like her Press Office, Correspondence Office, Speech
Writing.
Question. You were simply assigned to Maggie Williams' office?
Answer. Yes.
Question. So even with your hours for the internship, that was also
pretty varied?
Answer. From January '95 to April, I was there pretty much 5 days a
week.
Question. Full days?
Answer. Yes.
Question. Was that a requirement for getting credit in school, or
was that just what was needed?
Answer. That is how it worked out. Since I wasn't going back to
school, I wasn't taking classes, and I had that time available.
Question. You were not attending class at the same time?
Answer. No.
Question. Did you have an office or a desk or anything that was
your area in the First Lady's office?
Answer. Not one that was specifically mine, no.
Question. Where would you normally sit or hang your hat, as the
saying goes?
Answer. There is a coat rack when you walk in. I would put my coat
there, and I would go and there were two desks that were available.
Typically there were interns, and occasionally there were volunteers as
well. So if the volunteers were there, usually elderly women, they
would sit at the desk and answer the phone and open the mail. They
would sort of have the interns wherever space was available to work,
file, whatever was needed.
Question. So you wouldn't necessarily be sitting at a desk all day
answering phones or correspondence?
Answer. No.
Question. You said this is kind of in the general reception area,
like when you walk into the First Lady's office, it is a reception
area. Is that generally the area you were talking about where you would
spend most of your time?
Answer. Yes.
Question. Who else was in that area besides volunteers and interns?
Answer. Evan Ryan.
Question. That is where her desk was located?
Answer. Yes.
Question. Was there anyone else permanently located in that
reception area?
Answer. No.
Question. And I guess if you could explain to me how close from
where the reception area is to where Maggie Williams' office is?
Answer. They are connected by a door.
Question. So Maggie Williams, her office is right there?
Answer. Yes.
Question. Did you as an intern have a supervisor or have to report
to anybody?
Answer. Evan was my supervisor. That is who I checked in with, who
basically assigned the project.
Question. Was she the supervisor over all interns?
Answer. Over the interns in Maggie's office.
Question. Of course, that is what I meant. I am sorry.
What about over the volunteers? Was there somebody who kind of
oversaw the volunteers?
Answer. Evan did in Maggie's office.
Question. So would Evan Ryan then be the one that every day would
kind of tell you what needed to be done that day, or you would go to
her when looking for something to do?
Answer. Um-hmm. Yes.
Question. Besides the First Lady's office, did you ever work out of
any other location?
Answer. I helped out in the Press Office, I helped out in the
Social Office. I helped out a little with whoever was working on Mrs.
Clinton's briefing book, the Research office.
Question. Was this just a day here and there----
Answer. Yes.
Question [continuing]. If someone needed to be there to help out?
Answer. Yes.
Question. So it wasn't anything----
Answer. Regular, no.
Question. Right. As an intern, did you ever help schedule any
events, any White House dinners or lunches with the First Lady?
Answer. Are you asking me if I scheduled those?
Question. Were you ever involved in doing anything like that?
Answer. I never scheduled any events, no.
Question. Who would have scheduled those events?
Answer. Perhaps the Social Secretary. She was pretty much in charge
of the First Lady's social events.
Question. Would you ever at any time assist in preparing a guest
list or helping set up, or--I don't know--anything?
Answer. I helped out with the Social office, yes.
Question. Did you ever assist anybody in scheduling events for DNC
contributors or Clinton-Gore contributors to events in the White House?
Answer. No. No. The events that I helped out, I helped out an a
state dinner. I don't know, I think I was making some calls for some
women's tea thing. I can't remember exactly. But it wasn't fund-raising
that I remember.
Question. Did you ever help plan any movies that they had at the
White House?
Answer. No, I never got to go to those.
Question. That is too bad.
How about any of the photos with the First Lady?
Answer. What about them?
Question. Did you ever help plan any photo sessions with the First
Lady?
Answer. I never planned anything for the First Lady. I helped out
at whatever. I did help out at event where she was at, where the White
House photographer may have been at.
Question. Were you involved at all with any of the--what are called
now the ``White House coffees'' that Mrs. Clinton would have attended?
Answer. To my knowledge, those started after I left. I didn't know
of any of those going on when I was there.
Question. Okay. And then you said, pretty much your job duties and
responsibilities really didn't change once your internship was over and
you became a volunteer?
Answer. No.
Question. They pretty much stayed the same?
Answer. Um-hmm.
Question. You mentioned earlier that you began your employment with
Johnny Chung around the end of April, 1995.
Answer. Um-hmm.
Question. Is that correct, to the best of your knowledge?
Answer. Um-hmm.
Question. The time period you were working for Johnny Chung, from
the end of April of '95 to July of '95, you were also a volunteer in
the First Lady's office; is that correct?
Answer. I have a question for you.
Mr. Zacks. Off the record.
[Discussion off the record.]
Mr. Zacks. Can you read back the last question, Mr. Reporter?
[The reporter read back, as requested.]
The Witness. Yes.
EXAMINATION BY MS. SAFAVIAN:
Question. Your answer is yes to that?
Answer. Yes.
Question. If we can just discuss that a little bit, because I know
you mentioned you were a volunteer in the spring of '95.
Answer. Yes.
Question. And your internship ended in April of '95.
Answer. Um-hmm.
Question. I am just trying to make sure I have a time frame.
Ms. Amerling. When you say um-hmm, you mean yes?
Ms. Safavian. We have to make sure we get a verbal response.
If you want to explain that to me?
The Witness. Can you repeat that?
EXAMINATION BY MS. SAFAVIAN:
Question. I am just trying to get an understanding as to the time
period from when you went from an intern to a volunteer in the First
Lady's office, and when you first started working for Johnny Chung, if
you can kind of give me a sequential of all that happened.
Answer. Okay. I would have started volunteering when my internship
ended, whatever specific date in April that was; I don't remember
exactly. My internship would have ended when I started employment for
Johnny Chung, which was, I believe, at the end of April.
Question. So your internship would have gone from the beginning of
January to the end of April. It would have been from like the second
day of January to the end of April?
Mr. Zacks. Just so the record is clear, Counsel, I think she has
indicated she is not sure of the exact date in April, but she believes,
to the best of her recollection, it was towards the end of April.
The Witness. Yes. Internships are roughly a semester. It depends on
schools and dates. It is not, you have to be here from this date to
this date.
EXAMINATION BY MS. SAFAVIAN:
Question. It is normally maybe a certain number of dates or hours
or something for most internships? Anyway, you think it is pretty much
from the beginning of January to the end of April?
Answer. Yes.
Question. You said you would have gone from that immediately into
the volunteer program at the White House?
Answer. Yes, whenever the internship ended.
Question. So you would--while you were still an intern towards the
ends of April, you had already filled out the paperwork necessary to
become a volunteer; is that correct?
Answer. I don't know if I filled out the paperwork while I was an
intern. I could have. I think my internship was supposed to go until
the end of April. I was hired by Johnny sometime in April, so that cut
my plans short of completing the internship scheduled to last through
the end of April. I believe we went to China at like the last week of
April, so that was sort of my first project in working for him.
It might have been when I came back from that trip that I decided I
wanted to still volunteer in the First Lady's office and I might have
filled out the volunteer paperwork then.
Question. So you cut your internship short, you believe?
Answer. I don't remember exactly what dates the internship was
scheduled to run for.
Mr. Zacks. Excuse me.
[Discussion off the record.]
Ms. Safavian. Back on the record.
Oh, will you read the last question back, please.
[The reporter read back, as requested.]
The Witness. I don't know exactly what dates.
EXAMINATION BY MS. SAFAVIAN:
Question. That is fine. Just give me what you can recall or your
best recollection.
You mentioned that you went on a trip to China with Johnny Chung at
the end of April.
Answer. Yes.
Question. I believe, going through some of the documents that you
produced today, I did see a travel itinerary.
Answer. Yes.
Question. We don't have it in front of us right now, but was that
the trip you took to China with Johnny Chung?
Ms. Amerling. Was what the trip? Excuse me.
Ms. Safavian. The itinerary you produced this morning.
The Witness. That schedule was created in China, yes.
EXAMINATION BY MS. SAFAVIAN:
Question. Once we get it back, it will be clearer. That might have
a date on it then.
Answer. Sure. I think I have plane tickets too that show. I think I
got there a day or two before the Oklahoma bombing, because I remember
that was on TV there. I was so surprised, but I was watching it over
there.
Question. Okay. We will get back to the trip to China. But you
believe, when you returned from your trip to China, that you then
decided you wanted to become a volunteer in the First Lady's office,
and that is pretty much when that started?
Mr. Zacks. Counsel, just so the record is clear, I believe what she
previously testified to was that she is not sure whether she filled out
the volunteer forms while still an intern, but it is possible she did
it upon her return from China.
The Witness. Yes.
EXAMINATION BY MS. SAFAVIAN:
Question. In either case, you believe you began to volunteer after
your trip to China?
Answer. Yes.
Question. Did Johnny Chung know that you were volunteering at the
White House while you were working for him?
Answer. I believe so.
Question. Did he have a problem with that?
Answer. Not to my knowledge, no.
Question. Let me ask it this way. Did you ask him if that was okay,
if you volunteered at the White House?
Answer. I don't remember asking him for permission to volunteer at
the White House.
Question. Did he encourage you to do that?
Answer. No.
Question. When you filled out the paperwork to become a volunteer,
did you also have to include that your other employment was with Johnny
Chung at AISI?
Answer. I don't remember. From what I remember from that form, it
was fairly simple. The paperwork for the internship was very lengthy
and complex, but I don't know if I got a simpler version because they
already had all of my other background information or what.
Question. Did anyone else in the First Lady's office know that you
were, while you were a volunteer, also working with Johnny Chung?
Answer. Yes.
Question. Who would that have been?
Answer. Who in the First Lady's office knew?
Question. Yes.
Answer. Evan Ryan knew I worked for Maggie--I mean, I worked for
Johnny. Maggie knew. I know that those two knew for sure. I don't--
anyone would have known, Melanne Verveer would have known. Liz Boyer.
She was in research, so I don't know if she did. She did the briefing
book.
Question. Nicole Rabner?
Answer. R-A-B-N-E-R.
Question. Where did she work?
Answer. She was Melanne's assistant.
Question. Where was she working?
Answer. Melanne Rivera is the Deputy Chief of Staff.
Question. So they are both right in the First Lady's office?
Answer. Yes.
Question. Okay. Anybody else who may have known?
Answer. Those are the people that may have known.
Question. Are these the only ones you spoke to about it?
Answer. Those are the ones I worked with most closely.
Question. Did any of the people you just mentioned have a problem
with you volunteering at the White House while you were also working
for Johnny Chung?
Answer. Not that was verbalized to me.
Question. Did anyone suggest that that needed to be checked out
with the National Security Council or somebody else in the White House
who needed to approve that?
I don't know what the process is.
Answer. My volunteer activities were approved. I didn't receive any
hesitation or negative feedback from anybody while I was working there,
if that is what you mean.
Question. Okay. Can you tell me when you first met Johnny Chung, if
you can recall?
Answer. I don't know the date. It was sometime when he came into
the First Lady's reception area. I don't know what he was doing at the
White House, but he came into the office and the whole office was
introduced to him, or whoever was there that day.
Question. And who introduced him?
Answer. I think Maggie did.
Question. And do you recall--she just what, took him around and
introduced him to everybody or how did that go?
Answer. She came into the reception area, I believe she was going
into her office. On her way into her office, she said something--he
wasn't right with her, because she came in and said something about
this--some big DNC donor, you know, the name is Johnny Chung, say hi to
him, or something like that. It was sort of along those lines. I don't
know if she was getting ready to go to a meeting or what.
Question. Was he kind of behind her, walking in the door?
Answer. He came in behind her, because I remember she came in first
and said that to us, and then he came in after that.
Question. I mean, was it so much after that, that maybe he didn't
hear her give that introduction?
Answer. No, I don't think so, no.
Question. So she said, you know, here is Johnny Chung, a big DNC
donor?
Answer. It is just kind of like, I can't--I am not supposed to----
Question. Just generally.
Answer. Right. She said this guy is coming in, he is a big DNC
donor. She said, his name is Johnny Chung. Just kind of letting us know
who was coming into the office next.
Question. He was pretty much right behind her?
Answer. After she said that, then he came in. I mean, it was a
flow. It wasn't like----
Question. It wasn't like she for warned you guys and said at 10
o'clock today we have this person coming in?
Answer. Not at all. It is like she was walking into her office,
along the way, she told the people in the reception area, ``This big
DNC donor is coming in,'' and he was right there behind her.
Question. That was the first time you met him?
Answer. Yes.
Question. Had you seen him around the First Lady's office?
Answer. Never.
Question. I know it is hard to recall exactly when that was. Can
you give me a general time frame?
Answer. My guess would be the end of March, early April, sometime
around there.
Question. Okay. Was this also--if you know this, was this the first
time that Evan Ryan would have met Johnny Chung?
Answer. I have no idea.
Question. Do you recall Ms. Williams introducing Evan Ryan to
Johnny Chung?
Answer. It wasn't a formal situation. I couldn't even tell you who
else was there. I couldn't even say for sure if Evan was standing there
at that time. My sense is there were other either interns or
volunteers, because I wasn't the only one there.
Maggie sort of came in, said it, and people were like shaking his
hand and stuff. That kind of thing.
Question. Was he alone?
Answer. I can't remember that. I think that time he may have been,
but I am not positive.
Question. Okay. So you shook his hand, he introduced himself to
you?
Answer. Yes.
Question. Had you heard anything about him prior to Ms. Williams
announcing him?
Answer. No, I had no idea who he was.
Question. What did you think of him, your first impression?
Answer. He was an Asian man that came into the office that
apparently gave a lot of money to the DNC.
Question. Did he stay very long that day?
Answer. No.
Question. Do you recall?
Answer. No.
Question. Do you recall what he did?
Answer. No. Actually, I mean--yes, I don't know.
Question. So that was the first time you met him. After that, were
there people in the office who talked about him? Did you start to hear
more about Johnny Chung?
Answer. Yes. I mean, he was sort of, I would say, kind of an
irritant to the people in the office.
Question. Why would you say that?
Answer. He didn't really do anything, but he just kept showing up.
It is sort of like, you know, people would roll their eyes and say, oh,
Johnny is here, or it is Johnny, or something along those lines. I
mean, it wasn't anything, you know.
Question. Would he just appear, or like did you guys know he was
coming over? Would he call first?
Answer. Well, he would have to get cleared in, so I wouldn't
necessarily know how much advance notice other people had. I think I
probably typically saw him--I never knew when I was an intern there
when he was coming or not. He was just there.
Question. So it was always a surprise to you----
Answer. Yes.
Question [continuing]. When you would see him?
Answer. Yes.
Question. Did you have the ability to wave somebody into the White
House?
Answer. No. Only staff members can do that.
Question. So Johnny Chung never called you and asked you to get him
clearance into the White House?
Answer. No, no. I couldn't do that.
Question. Do you know who he would normally call to do that?
Answer. My sense is that he called a lot of people, like he made
sure when he came in that he talked to as many people as he could. I
mean, just from the entrance of the OEOB, getting to the First Lady's
office, he always had to stop in every office and shake hands and
kibitz and do his thing.
So I think he called the First Lady's office a lot, and I don't
know if he would call Evan specifically or Maggie specifically or other
people. I don't know.
Question. Okay. When somebody would call or get cleared to get into
the OEOB, did somebody have to greet them at the door and say, bring
them to the First Lady's office, or they just found their own way to
the First Lady's office?
Answer. Johnny tended to find his own way.
If somebody was cleared in, are you asking in general?
Question. Start with general.
Answer. In general, if somebody is cleared in and, to my knowledge,
if nothing shows up on their record, then they can just show their ID
and get their appointment badge and walk in.
I think if something shows up on their record, then they would send
one of us down to go escort them.
Question. What kind of things would show up that would require an
escort?
Answer. I never knew exactly. I think it could be something pretty
minor, like somebody has ever been--I don't know.
I don't know, but I remember asking one time, why did someone need
an escort, because they have been here for meetings before and that
sort of thing. I thought that is what I was told.
But typically, if you are cleared in, you know the room you are
going to, you can just go.
Question. More specifically with Johnny Chung, did he require an
escort or kind of found his own way to the First Lady's office?
Answer. I believe he typically found his own way. I don't know, I
am not saying there were never times--he may have been escorted. I
don't know--I can't recall specifically if it was like a necessary
thing that he needed an escort, if it was like an ego thing.
Question. An ego thing?
Answer. I don't know.
Question. Like, for instance, he would prefer to have an escort?
Answer. It is not even--I mean, if there was--to send somebody out
of courtesy, if you had that, an intern sitting there with nothing to
do, let's say. I don't know.
Question. So you had been asked before to escort somebody, not
necessarily Johnny Chung, but you had done that before when you were an
intern?
Answer. I would go down and pick people up at the front door, yes.
Or packages.
Question. Did you ever do that for Johnny Chung?
Answer. I don't remember specifically. Yet it seems like it. It is
honestly hazy. There were times when he would come with other people. I
don't know if at that point he needed an escort. I can't remember.
Question. Do you recall how soon after your first, very first
meeting him, would you say that you then saw him again?
Answer. That I don't know. To give you an idea, it was sort of
like, when he was in town, you saw him a lot. Then when he was out of
town, he was out your hair kind of thing.
So I know that is not very specific, but that is sort of how he
functions, too, or at least how he functioned then.
Question. You mentioned people started to think of him as an
irritant.
Answer. That was my personal sense.
Question. Of what people were feeling?
Answer. If I am allowed to say what other people are feeling.
Question. That is your sense of what you thought they were feeling;
is that correct?
Answer. Yes.
Question. Did you feel that he was starting to become an irritant?
Answer. Yes. He was annoying, definitely.
Question. Why so? Just because he kept showing up?
Answer. He kept showing up, yes. People had work to do, and he sort
of seemed to want to sit there and talk or shake hands or be catered to
or introduce you to someone, and everybody else was busy meeting these
phone calls.
Mr. Zacks. Off the record.
[Discussion off the record.]
Ms. Safavian. Back on the record. If at any time you want to take a
break, just let me know.
Mr. Zacks. Excuse me, off the record.
[Discussion off the record.]
EXAMINATION BY MS. SAFAVIAN:
Question. Back on the record.
We were just discussing everyone's feelings towards Johnny Chung
because he kept appearing. I may have asked you how you felt about him,
and if you want to just repeat that?
Answer. Johnny was a hassle. He tended to demand a lot of
attention, sort of, even without asking for it. Without asking for it
directly anyways. I don't know, I liked what I normally did in the
First Lady's office with whatever project we were working on, and, you
know, like things sort of stopped when, as things would with any
character that walks in the office.
There were certain people that you just kind of stopped for and
catered to; and when he was in town, he was one of them.
Question. Was that because you were told to do that, or that is
just what happened?
Answer. It is more what happened. I mean, you know, we were trained
to be very courteous to whoever called in, whoever came into the
office, how we treated people--we represented the First Lady's office.
So I used the manners I was trained to.
Question. Do you happen to know how Evan Ryan felt about Johnny
Chung?
Answer. My guess would be similarly. Evan had a lot of work to do,
being Maggie's assistant, and when Johnny came in, as when anyone would
come in, she would be very courteous and stop and she would give them
the attention that they required.
It is not like Johnny was somebody we were, like, excited to see,
like, great, Johnny is in town this week. It wasn't anything like that.
Question. Did anybody ever complain to Maggie Williams or anybody
about his constant interruptions or how everyone felt about him?
Answer. I don't know if any direct complaints to Maggie were made
about him. It was sort of like the buzz in the office.
Actually, other people could come in and out. They could go back
and do their work. It was sort of that main reception area that a few
of us couldn't really leave quite as easily or say we had meetings to
go to, being interns.
Question. Did you personally ever complain to anybody about him?
Answer. About like how frequently he showed up? No. I didn't do
that about anybody that came into the office.
Question. Okay. What would he normally do when he came to the First
Lady's office?
Answer. I don't know exactly. If he was with people, he would come
in the reception area in the First Lady's offices, people like coming
into it. There are huge, colorful photographs of the First Lady from
whatever trips or event she has been at, and they love coming in and
looking at the photos and talking about them. And there is a very large
conference room that is also filled with these photos, and he would
come in and show his guests around and show them photos and that sort
of thing.
That is what I basically saw. That was the area that I functioned
in.
Question. And did he normally always have guests with him?
Answer. He did both. He would come by himself or he had guests.
Question. Who would he--was there anyone in particular in the First
Lady's office who he would kind of go right towards and speak with?
Answer. Ideally, he would probably want to see Maggie, but she was
not always available. Again, this is my guess; I mean, because if he is
going to go to someone, he is going to want to go to the top. Maggie is
the top person in Mrs. Clinton's office. So I think Evan would get
stuff, being like the next one in line, always sort of stationed at her
desk there. Him knowing that she has access to Maggie.
Question. How did you get to know him pretty well?
Answer. From his visits to the First Lady's office. He would talk
about trips that he had taken or whatever, and so I sort of sat there
and listened to him, whatever story, whatever pictures he was showing.
He was really big on pictures.
Question. He would bring in pictures?
Answer. I think so. I think that is where I saw--he brought this
one delegation in, I cannot remember if I saw--I saw pictures of his
trip to San Francisco with some Asian delegation, and I don't know if
he brought those into the First Lady's office.
I remember a lot of people that he brought to San Francisco, or at
least some, were a group he brought to D.C.
Question. So he would tell you about his trips. He would spend a
lot of time talking to you?
Answer. To whoever, yes.
Question. Okay. Did he ever tell you then what his business was,
what he did for a living?
Answer. Oh, yes.
Question. What did he tell you about that?
Answer. He was very proud of his, you know, ``super fax machine''
that can simultaneously fax millions of copies around the world. This
is paraphrasing, but this is sort of the gist of what he would talk
about. He would start name dropping of all these people that were his
clients, Governor of California, the guy that owns Wendy's, whatever.
He might have brought in some of the, I don't know if he brought in
these booklets.
Question. The AISI brochures?
Answer. Yes. I don't think that was in it then, the pictures. He
is, like, very proud of being this engineer from UCLA, who used to own
seven computer stores, to build this machine, how he went close to
bankrupt and had to like sell all these stores just to believe in his
dream; and his wife was saying, you are crazy, you can't do this, but
he believed in his dream and finally got this machine to work, and has
this super fax machine.
Question. I know you said the first time you met him, you believe
was at the end of March, possibly April, of 1995. Do you recall Johnny
Chung bringing a delegation of Chinese businessmen to the First Lady's
office?
Answer. Yes.
Question. That was--I can give you the date--that was March 9th,
1995.
Answer. Oh, was it?
Question. Does that help you at all determine when you may have
first met him?
Answer. I would guess--I think the first time I met him, he was by
himself, is when he came into the office. Soon after that, I remember
him coming in with this delegation.
Question. So that couldn't have been the first time that you met
him?
Answer. Not with the delegation. Honestly, it could have been like
a morning and afternoon thing. It could have been like a week-to-week
thing, a next-day thing. I don't remember.
But I do remember the first time seeing him, Maggie saying, this is
a big DNC donor, and then I remember after that, this delegation coming
in.
Question. Could it have been the next day?
Answer. It could have been.
Question. What do you recall about this Chinese delegation--did you
meet the delegation?
Answer. Yes.
Question. Who introduced them to you?
Answer. Probably Johnny. Again, it was not any sort of formal
event. I remember them all standing there. None of them spoke English,
to my knowledge. Meeting them, shaking their hands. I imagine all the
people in the office did, too. I remember them going through the
conference room looking at the pictures.
Question. Do you recall how long they stayed in the First Lady's
office?
Answer. No, but not long. Most of his visits were sort of like the
superficial tour kind of agenda, lack of agenda. There is no agenda
there, to my knowledge.
Question. Did the delegation give you any of their business cards?
Answer. I don't remember them doing that then. It seemed like a
bunch of old men looking around. There was one young guy in it, and
that was it.
Question. Okay. Do you recall them giving their business cards to
anybody at that time?
Answer. I don't recall. I don't think so. It seemed more like once
we got to China, people were dealing cards like it is Vegas.
Question. Are you aware that the Chinese delegation that day, March
9th, received a tour of the White House, had lunch in the White House
mess, and had their photos taken with Mrs. Clinton?
Answer. They had that that day?
Question. Yes.
Ms. Amerling. Counsel, have we established that it was March 9th
she is discussing?
Ms. Safavian. Well, I have. I mean, I can show you a record that
shows he was there on March 9th and an L.A. Times article that
discusses March 9th as the day.
The Witness. I don't remember what day. Johnny certainly brought--I
remember specifically, though, this initial delegation with
approximately 10 people in it, 10 men in it. But I don't remember the
date.
EXAMINATION BY MS. SAFAVIAN:
Question. Let me show you a photo that is in the AISI brochure, one
of the brochures you brought this morning. It includes a photo of the
Chinese delegation that I am speaking about, with the First Lady. All
their names are listed at the bottom.
Answer. Yes.
Question. It does not provide a date.
Ms. Amerling. Let the record reflect another person has entered the
room. Can we hold on the deposition?
That person has now left the room.
EXAMINATION BY MS. SAFAVIAN:
Question. Is do you recall, is this the same Chinese delegation we
are speaking about?
Answer. I believe so. And then--I take that back, because I know
one guy speaks English.
Question. Who would that be?
Answer. I don't know any of their names. The second one from the
left.
Question. Okay. In the picture?
Answer. Yes.
Question. Hmm, it is kind of hard to tell exactly who that would
be, because he doesn't seem to list them.
Answer. He was, to my knowledge, the translator.
Question. He is the translator.
Answer. I don't know if they didn't put him in. Is that Vice
Premier Lee, the guy to his right?
Question. Right next to Hillary's left on her picture?
Answer. On her right.
Question. You said Li?
Answer. I thought Vice Premier--anyway, he most likely is his
translator. But I don't remember talking to any of them. It was more
like walking into the First Lady's office, shake some hands, show some
pictures. I didn't particularly know that they had a picture taken with
the First Lady. That is not the reception area.
Question. That is not the reception area?
Answer. The First Lady's office.
Question. The gentleman that you identified or were trying to
identify standing next to Mrs. Clinton, let me show you a document, EOP
029612, and tell me, it is just a black and white, if this is you
believe the same guy you are speaking about in the color photo with
Mrs. Clinton?
Answer. I mean, it looks similar.
Question. Okay. Just to identify the name on the photo, is Zheng,
Z-H-E-N-G, and I will spell the last name, H-O-N-G-Y-E. We can mark
this as Exhibit Number 1.
Ms. Amerling. This being the EOP document?
Ms. Safavian. That is correct.
[Ratliffe Deposition Exhibit No. GR-1 was marked for
identification.]
[Note.--All exhibits referred to can be found at end of
deposition.]
Ms. Amerling. So the record is clear, can we give the photo an
exhibit number as well?
Ms. Safavian. We will have to get a copy made of that.
Mr. Zacks. Okay. Do you want it now?
Ms. Safavian. We can do it at the end.
Ms. Amerling. We can do it at the end.
Ms. Safavian. The group photo of Mrs. Clinton will be Exhibit
Number GR-2.
[Ratliffe Deposition Exhibit No. GR-2 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. So, Ms. Ratliffe, these photos I am showing you right
now, GR-1 and GR-2, this is the Chinese delegation we were previously
speaking about, correct?
Answer. Yes.
Question. And did you answer before that you recall that they had a
White House tour, lunch in the White House mess and a photo with Mrs.
Clinton?
Answer. I wasn't aware specifically. It doesn't surprise me, but I
didn't know that for sure.
Question. Okay. So that day, you as an intern didn't have to do
anything with the delegation to get them from one place to the next or
assist in anyway?
Answer. No, not that I remember. I remember meeting them in the
office, definitely, in the First Lady's reception area.
Question. Do you recall Evan Ryan or Maggie Williams discussing
this delegation at any time?
Answer. No.
Well, at any time? There was talk of Johnny and his delegation.
Anything specific, I don't remember them saying anything specific about
them.
If you want to ask me something else about it?
Question. What do you mean by, there was talk about the delegation?
Answer. I mean, Johnny and delegation. Johnny always had some
delegation going on. That is how he used it, anyways.
Question. So you don't recall any specific discussions or
conversations about this Chinese delegation, the photos you are looking
at?
Answer. No. No.
Question. Okay. Do you--how many times that day did you see Johnny
Chung and the Chinese delegation?
Answer. All I remember specifically was in, like, the First Lady's
reception area; it is connected to her conference room. I don't know.
Question. How many times do you recall seeing them that day?
Answer. One.
Question. Just one time?
Answer. The delegation. Johnny came back, and I don't know if it
was later that day--what day of the week was March 9th? Was that a
Friday, by any chance?
Question. I believe it was a Thursday.
Answer. Because Johnny came back at one point and he tried--he
wanted to get them into the President's radio address. I don't know if
it was like later that day or the next day or what. A radio address
would have been Saturday. I remember he was like hustling to try to
make this happen.
Question. So you recall him coming back that same day, trying to
get them into a radio address?
Answer. I don't remember if it was that day or the next day. It was
after this delegation had been brought in.
Question. Let me just show you, these are WAVE records. Have you
ever seen WAVE records before?
Answer. Not like this.
Question. What I have handed you is the year 1995, and I turned to
March of 1995 for you. If you will notice, it shows those dates in
the--actually, I am sorry--in the first column on the left.
Ms. Amerling. Which page?
Ms. Safavian. EOP 8683, and it shows that Johnny Chung entered the
White House on 3-8-1995, he was requested in by Bailey, and he visited
Bailey in room 174. Do you see that? That is the second line.
Answer. Yes.
Question. First of all, do you know who Bailey is?
Answer. No, I was just wondering that.
Question. And then you see the next entry is 3-9, and it shows that
he is requested in by Ryan, and he visited Ryan in room 100.
Answer. That is the reception area.
Question. And if you look further, it looks like--well, according
to these WAVE records, he entered the White House on 3-9 two times. If
you look further down, there is another 3-9 entry, again requested and
visited Ryan?
Answer. Yes.
Question. The next day right under that there is a 3-10 entry.
Answer. Yes.
Question. You see it is requested by and visited Tarmey. Who is
this?
Answer. That was Marge Tarmey. She was another one of Maggie's
assistants. She sat in Maggie's office.
Question. Does this help refresh your recollection at all as to
when he may have come back, trying to schedule this radio address?
Answer. Not particularly. Like Johnny just was there a lot. Like he
kind of bopped in and out. It wasn't ever a set thing; it wasn't ever
scheduled. I never really knew ahead of time. But I remember him
wanting to get this delegation into the radio address.
Question. Did he speak with you about that?
Answer. Yes.
Question. What did he ask of you?
Answer. I don't know if he asked me specifically if I could help
him get in. He was talking about wanting to get them into the radio
address, and I think that was the first--I knew the President gave his
radio address, but I didn't know people could go in and watch it.
I think he said something about wanting pictures, because then they
would get pictures with the President, and I didn't know that that was
part of radio address procedures either. I think I told him that--I
would have said, I am certainly not the person that can get you into
that. He said, oh, forget about it; and he sat and like made some phone
calls, I think, right there, there is like a little table and chairs,
and I don't know exactly who he would have called to try and get him
into the radio address.
Question. Did he mention anything further once he got off the
telephone?
Answer. No.
Question. He didn't mention, oh, never mind, I have taken care of
it?
Answer. Oh, I don't remember exactly. I knew--I remember knowing
that he had succeeded with making this happen. I don't know if it was--
I don't think he found out right then, so I don't know. I don't know if
he came in the next day or something, and if I would have said, oh, did
things work out for you at the radio address; and he said, yes.
But it is not like he made a phone call, got ten foreign
businessmen cleared in, all set, ready to go for a radio address, and
hung up the phone and said, yes, I took care of this.
Question. That didn't happen?
Answer. No.
Question. Did he speak with anybody else in the First Lady's
office, to your knowledge, about trying to get them into the radio
address?
Answer. I don't know about that. Not to my knowledge.
Question. Do you know whether or not he did get into the radio
address?
Answer. Yes, to my knowledge, he did.
Question. How do you know that?
Answer. Because I think he told me that he got in. Like I said,
afterwards he said it worked out. But I think he told me before he
actually went to the address. That is why I was asking if March 9th was
a Friday, because I remember he had like a short time. He was trying to
make this happen and was kind of nervous--I don't know if that is the
right word, but very ``anxious'' to get his delegation in to meet with
the President.
Question. And you said that radio addresses are held on Saturday?
Answer. Saturday mornings.
Question. If you turn to the next page in the WAVES that I gave
you, 005038, it is a little harder to read, but you can make out the
seventh entry down, it shows Johnny Chung visiting POTUS, which stands
for President of the United States. It shows that the date is 3-11, and
it was requested in by Crawford, and it is in the West Wing, ``WW.''
That is 3-11, that would be a Saturday?
Answer. Yes.
Question. So 3-9 would be a Thursday. Does that help you then?
Answer. With what?
Question. With trying to figure out the time period? You were
wondering if it was a Friday?
Answer. Apparently it was a Thursday.
Question. Does that help you at all with when you believe Johnny
Chung came back and talked to you about the radio address?
Answer. No. If he was only there on Thursday, then it must have
been--actually, did he come in----
Question. He was in on the 10th. If you turn to 008663----
Answer. He was in the previous day?
Question. Tarmey, requested by Tarmey, and visited in room 100?
Answer. It could have been then. Did he come in after the radio
address?
Question. The previous page also shows that he was in 3-13, 3-14?
Answer. So he could have told me then too. If I had to guess, it
would have been that he told me before.
Question. He would have told you before he actually went to the
radio address?
Answer. That it worked out.
Question. And why? Any particular reason why you believe it was
before?
Answer. My sense that he was--I remember him, I remember the chair
he was sitting in, and the fury, trying to make these phone calls and
get the delegation in. Then he hung up the phone, whatever. My sense is
if I would have seen him again--soon, before it happened--I would have
said, oh, did things work out--sort of follow through on any project I
would have been dealing with.
And I thought that he told me that it did work out, and I seem to
remember it being before, as opposed to after.
Question. Okay. That is fine. Did he say anything further to you
besides, it worked out, or did you ask him anything that you recall?
Answer. Not that I recall.
Question. That is pretty much most of the conversation that you
remember?
Answer. Yes.
Question. Okay. Did he happen to mention to you how he got into the
radio address?
Answer. I think he did. I think he might have told me who he
called, and I can't remember exactly. I know he worked with, or I know
that he tried to work with Ann McCoy, who was sort of--she is the White
House visitor's something or other, and she would show people around,
including him.
Question. She would give tours of the White House?
Answer. Yes. So I don't know if it was Ann McCoy that he worked
with on that or not, but she seemed like to be another point person he
would try to hook up with to try to show his people around.
Question. Do you recall if he would have mentioned that he
contacted somebody at the DNC?
Answer. I don't know. Johnny would always talking about all of his
friends everywhere, and he is a big name dropper. So it is kind of a
blur whenever he would. I don't remember.
Question. That is fine.
Ms. Safavian. I would like to mark for the record the WAVES
records, years '94, '95 and 1996 as GR-3.
[Ratliffe Deposition Exhibit No. GR-3 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Did anyone else in the First Lady's office ever speak
about the delegation getting into the radio address?
Answer. I think afterwards I heard talk about it.
Question. Do you recall at all what you heard?
Answer. As far as him getting into it? I mean, it is not----
Question. Anything, if there was anything you recall about
discussions held in the First Lady's office about the delegation
getting into the radio address.
Answer. Not about getting into the radio address. The photos that
were taken during it were, to my knowledge, immediately released.
Again, I am not positive on all of this. I seem to remember that
the NSC had hesitation about releasing them, and this might have been
like more than a month later and they hadn't gotten them, and Johnny
wanted the pictures. So I think there was like talk about--I don't know
if Johnny was calling the First Lady's office, bugging them, I want
these pictures, I want these pictures; and there was like talk about
that sort of thing.
Question. Let me show you another exhibit, this is an April 5th,
1995, letter from Johnny Chung to Ms. Williams, the Bates Stamp is
JCH15013. If you will just take a quick look at that.
Answer. All right.
Question. Do you recall ever seeing this letter before today?
Answer. No.
Question. Were you aware that Johnny Chung had contacted Maggie
Williams about trying to get these photos?
Answer. I don't know that I knew that Johnny contacted her
specifically. I know that he was--in his flurry, his anxious flurry of
trying to accomplish whatever he was doing, I seem to remember him
making phone calls to lots of people--like, I want these pictures, I
want these pictures.
Question. Did Maggie Williams ever ask you to look into this issue
for her?
Answer. Me to look into the photos? No.
Question. Okay. Let me mark this letter as GR-4.
[Ratliffe Deposition Exhibit No. GR-4 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. I am going to hand you some phone message slips, if you
would take a look at those.
Answer. Yes.
Question. If you look at the first message slip, EOP 059024, it is
addressed to Evan, dated 4-3, and on the prior page--it is hard to
read--it gives the time period, and the year is 1995.
Answer. Yes.
Question. It shows that he called on 4-3 around 4:50, and in the
message at the bottom of the message slip it says, it looks like ``Re:
Pictures. (Actually he called for Gina, who wasn't here, and then he
asked for you.)"
Answer. Um-hmm.
Question. Did you ever, did Johnny Chung ever contact you about
these photos?
Answer. I remember--I don't remember. I will tell you, what I do
remember, first, was when this was still during my internship, but when
I actually started working for him, he still hadn't gotten these
photos. So right before--I had accepted a position for him, and we were
going to be leaving for China, and he was going nuts to get these
photos for the trip; and it was at that point then--no, I don't think I
was actually in the First Lady's Office then. I don't know if I would
have called Evan saying, Johnny wants these pictures, or can you tell
us about that, that sort of thing.
Question. Are you talking about, after the fact, once you started
working for him?
Answer. Once I started working for Johnny. I was in D.C., he was in
L.A. I was getting ready to fly to L.A. before we left for China, and
he wanted me to come with these pictures. And I think, I don't know if
he had been calling DNC folks to try and get any leverage or whatever,
but nothing seemed to be budging.
Again, I don't know. It seemed they were holding on to them for
whatever reasons, national security. But then I did end up picking up
the photos from--this is not when I was an intern, because I remember
taking a cab and running into the West Wing to pick up this package
before I left for L.A.
Question. Do you recall when that was?
Answer. It would have been right before we left for China, which
should have been towards the end of April.
Question. Did you--if you look at--actually, let me finish with
this document first.
So you were still in the White House doing your internship on this
4-3 message slip?
Answer. To my knowledge.
Question. It does appear he tried to contact you about these
photos?
Answer. Yes. Johnny would--well, I don't know--I don't know that he
was necessarily calling me for these photos. He could have--I don't
know when we exactly had started talking about my potential employment.
So I don't know if he knew I could be reached there. Because there was
a time span after he offered me the job, that I said I wanted to think
about things.
I don't know if he was calling to get in touch with me about that
or what exactly. So if he was calling regarding the pictures in
general, and it is a side note that he was calling for me too----
Question. So you don't personally have any personal recollection
that he called you about the photos?
Answer. That I was some sort of contact person about the pictures,
no.
Question. If you look back at GR-4, the Maggie Williams letter that
Johnny Chung wrote, it does mention in the letter, in the first
paragraph, a couple of sentences down--I had it; in the next
paragraph--``I am going to China next week and I do need to bring those
pictures with me.''
Does that----
Answer. But this letter is April 5th--the next week--I really
thought I was in China sometime around April 25th.
Question. Once we get that--perhaps we have gotten it.
Answer. That is when I went to L.A., the next day.
Question. You are looking right now at a Tops International Travel
itinerary, one of the documents that you brought with you today?
Answer. Yes.
Question. And it shows an April 12th date. It shows you leaving
L.A. and you were going to arrive the next day in Tokyo, on April 13th,
1995.
Answer. That is when it would have been.
Question. That refreshes your recollection as to when it was?
Answer. Yes.
Question. Is that a yes?
Answer. My recollection was, for some reason I had the 25th in my
head. That is definitely when I went to China.
Question. Okay. I was going to say, there are two itineraries here.
The second one actually has your name on it. The first one has Johnny
Chung's name on it. The second one says Gina Ratliffe. The two of you
traveled together to China?
Answer. On the same flight, yes.
Question. And it looks like you left, then, April 12th and you
returned April 25th?
Answer. Maybe that is why that date sticks out.
Question. That could be. Why don't we----
Ms. Safavian. First of all, I would like to mark the message slips
as Number GR-5. Then I would like to mark the itinerary travel slips
from Tops International Travel, the one for Johnny Chung as GR-6 and
the one for Gina Ratliffe as GR-7, just so we don't get confused.
[Ratliffe Deposition Exhibit Nos. GR-5 and GR-6 were marked for
identification.]
[Ratliffe Deposition Exhibit No. GR-7 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Now that we have established that you left L.A. to go to
Tokyo on April 12th, does that help you at all place when you may have
picked up the photos?
Answer. If I left on the 11th, I probably would have gotten them on
the 10th.
Ms. Amerling. I think it was the 12th, according to this itinerary.
The Witness. That I left for L.A.?
Ms. Amerling. Actually, my copy is folded.
Mr. Zacks. I think it is the 12th, leave Los Angeles.
The Witness. So I probably went to L.A. on the 11th, and I could
have either picked them up on the way to the airport--I remember taking
a cab there.
EXAMINATION BY MS. SAFAVIAN:
Question. To----
Answer. The White House.
Question. Let me show you some other documents that may help us out
with the time frame.
Answer. I don't know if they put that on my credit card.
Question. If you look at the bottom one, JCO2932, the reimbursement
check request, it shows it is dated 4-4-95, it just shows the amount of
$398, reimbursed to Tops Travel; and then in the regarding line, it
says Gina Ratliffe's air ticket, LAX, back and forth to Washington,
D.C. Perhaps this is when they paid for your ticket, on April 4th, '95?
I know you don't know. But if you look at the next document, which is
JCO2845, that appears to be dated April 11, 1995. That has you going
from Washington National to Chicago O'Hare and then to L.A.
Answer. Okay.
Ms. Safavian. And why don't I mark the reimbursement request as GR-
8 and the United Airlines passenger receipt ticket showing April 11 as
GR-9.
[Ratliffe Deposition Exhibit No. GR-8 was marked for
identification.]
[Ratliffe Deposition Exhibit No. GR-9 was marked for
identification.]
Ms. Safavian. GR-9 will include JCO2845 through 2846 and 3163,
which is just another copy of that passenger receipt; and at the bottom
it has a request, it looks like for petty cash. It shows once again the
airline ticket and the amount.
The Witness. Okay.
EXAMINATION BY MS. SAFAVIAN:
Question. We can establish then you left Washington on April 11?
Answer. Yes.
Question. And then left out of L.A. April 12th?
Answer. Yes.
Question. And then returned from Japan--I am sorry, from China, on
April 25th?
Answer. Yes.
Question. If you look down at the next document, it is JCO2847, it
looks like, and the one after that, 2848--and I have also included
another copy that combines the two, 3164--you received from petty cash
it looks like $80 reimbursement on 4-11, and it says, for visa to China
for Gina?
Answer. I don't know that I received that reimbursement. I remember
him going with me to get this.
Question. Johnny Chung?
Answer. I think so, to get the visa. I don't know that my--the same
for these--I mean, I don't remember handing someone $80 to get my visa.
Question. Do you recall going to get your visa?
Answer. Oh, definitely.
Question. Does Document 2848 establish that you picked up your
visa?
Answer. I got it that same day, I think. Yes, I had to, because we
were leaving the next day.
Question. And you believe Johnny Chung went you to get that?
Answer. I don't know if Art Liang went too. I don't know if
somebody else from his office might have gone too.
Ms. Safavian. I will mark those three documents as GR-10. That will
be 2847, 2848, and 3164.
[Ratliffe Deposition Exhibit No. GR-10 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. The last document I handed you shows just your passenger
tickets with a date of April 25th. It shows you going back to Detroit.
I believe the one below that is LAX to O'Hare and----
Answer. I probably came home after.
Question. After your China trip you made a stopover?
Answer. I went from Tokyo to L.A. to Detroit.
Question. It also shows at the bottom a check made out to Robert
Ratliffe. Who is that?
Answer. My father.
Question. It was made out on June 1st, 1995 for $1,709. It is at
the bottom for reimbursed air ticket. Did you pay for--originally pay
for your trip?
Answer. I must have. I must have. I must have been using my
parents' credit cards.
Ms. Safavian. Okay. Why don't we just mark that as GR-11.
[Ratliffe Deposition Exhibit No. GR-11 was marked for
identification.]
The Witness. Either that, or they gave me the money. I don't know.
EXAMINATION BY MS. SAFAVIAN:
Question. Your parents?
Answer. Something. The check was made out to him.
Question. Did you use any of your contacts at the White House to
get these photos for Mr. Chung?
Answer. No. That is not--I wasn't actually the one that got the go-
ahead. I mean, I am sure I must have asked Evan, I would imagine,
though I don't recall a specific conversation of, we are leaving for
China, can you? Because I sort of moved over to being his assistant, I
am sure I would have tried to handle that responsibility.
Question. The responsibility of getting the photos?
Answer. Of getting the photos, right.
I think I remember being kind of irritated, this is like my first
job out of college, my first job is to like pick up some photographs,
and this is like the NSC is involved in it. But it wasn't like Evan was
like, okay, Gina, since we know you, we will give them to you. It was a
phone call from Johnny that I got that said, okay, you can pick up the
photos from--who is it, Kelly Crawford? Is that Crawford's first name?
Question. Is there a Kelly Crawford who works----
Answer. In the Photo office?
Question. She worked under Nancy Hernrich at that time in the
President's office.
Answer. Oh, really? I don't know. I remember going into the West
Wing and using the little phone or Secret Service or someone, and she
came down and she handed me this package of photos.
Question. Kelly Crawford?
Answer. I think. I think so. I didn't know her even from working at
the White House--like I knew the name, but I didn't know her. I
remember a girl came and gave me this package, but it was because
Johnny had called me, I think at my apartment in D.C., and said, go
pick up the photos, and you can get them from so and so and bring them.
Question. And do you recall if it was like a day before you left
for L.A.?
Answer. It seemed to be right before, yes.
Question. So it was pretty much already taken care of, you just had
to go pick them up. You didn't have to make any phone calls to get the
photos?
Answer. Like I said, I might have asked Evan or like asked some
people, you know, what is up with the photos? And I think--because,
again, all of this is right around the time of like going from intern
to working for him.
So I know, when he was trying to get into the radio address, I was
definitely an intern, so hearing all of that talk. And then I remember
the situation of him trying to get the photos, and not being able to,
and NSC holding on to them. I remember talking to Liz Boyer.
Question. Boyer?
Answer. Boyer. She was a friend of mine, but she worked on briefing
book, and I think it was her that told me about the NSC situation.
Again, I am not positive. But I remember talking to her about it.
I don't remember if she is the one that told me the NSC is holding
on to them, and something about the President was worried about--or
wanted them checked out or something. But I remember talking to Liz
about that.
And then I am sure I would have tried, once I started working for
him, if he wanted me to get these photos. It was not like I was calling
the Photo office or I was calling Kelly Crawford or the DNC or anywhere
else saying, what can we do to get these photos? The only one I would
have asked would have been Evan or like, what do you--yes.
Ms. Amerling. When you say ``would have,'' you are speculating
about what you would have done?
The Witness. Yes. I honestly don't remember specifically. Seeing
some of this stuff, like I completely forgot I went home after the
China trip. So seeing some of this is jarring some of it.
I totally forgot about Irene, which was like Johnny's assistant in
L.A., who was like trying to do stuff for him too.
Yes, I don't remember placing a phone call to Evan saying, can you
help me get these photos or what is the deal?
EXAMINATION BY MS. SAFAVIAN:
Question. You don't remember?
Answer. I don't remember a specific conversation, no. I mean--no.
Question. Okay. Did Johnny Chung ask you, do you recall him asking
you, you know, are there any efforts you could make to help me get
these photos? Did he ever request you to help him?
Answer. I would imagine so. What sticks out in my mind more is his
anxious flurry to get these photos, and it was similar to his anxious
flurry to get into the radio address. I don't remember a specific--with
the radio address, I think he might have even said, can you help me, or
just forget it, I can make a phone call, that kind of a thing.
I don't remember if with the photos, he definitely wanted me to
pick them up, to bring them to L.A.
Question. He was already in L.A.?
Answer. Yes, he was already in L.A., and I was in D.C.
Question. You mentioned he was in a big flurry to get these photos?
Answer. Yes.
Question. Do you know why?
Answer. This was very important. Who knows what ego trip Johnny was
on, and who knows what he was trying to prove to these people over
there? But this, from my understanding, was going to prove to whoever
we were going to meet in China that Johnny was tight with the President
of the United States and Johnny can get people pictures, and, you know,
more of--much more of a superficial thing than any sort of real power
or significance.
Question. Did he tell you he needed these photos, it was important
to pick these up if you came to L.A.?
Answer. Yes. Yes. Yeah, he definitely had to have these photos
before we left on this trip. I was kind of like, had the attitude of, I
am more relaxed anyways, but you know, if the NSC is not going to give
them to you, you aren't going to get them.
I was kind of surprised he got the photos then, because it seemed
like he had been trying to get them for so long, and it wasn't
happening; and then all of a sudden, I got this phone call to go pick
up the photos. So I was like, okay, it came through.
Question. You didn't ask him how it happened to work out or
anything?
Answer. No.
Question. Okay. Let's backtrack a little bit.
Can you tell me, how did Johnny approach you or make an offer to
you to work with him?
Answer. It was at the White House. One of his--I think he might
have had people with him, but they were always or typically non-
English-speaking people, so he could kind of do his thing anyways. And
he was talking about that he was making another trip to China, and this
China thing was a big deal because it was also before the World Women's
Conference and before Mrs. Clinton had said that she would go.
So Johnny said to me, you know, like I am planning another trip. I
am starting to come back and forth from L.A. to D.C. a lot more, and I
need an assistant in D.C., you know, when is your internship over, you
know, are you looking for a job, that kind of thing.
And it sounded really interesting, and we talked more about what
the job would involve, and that is sort of how it all came about.
Question. Do you recall what he said to you about what your job
would involve?
Answer. It didn't all happen in one conversation, but as the
conversations went on, he explained that he wanted to--Johnny felt that
he had an accomplished all of this financial success, and how he now
wanted to give back to the world and wanted to start this like
peacemaking--he called it ``bridge-building''--mission between China
and the U.S., and how he wanted to be this messenger of peace.
So what I would be helping him with would not really be an
assistant with what he does with his fax machine stuff, but it would be
whatever political involvement--what he, I realize now, created for
himself--so when he would bring delegations over, he would always put
them up in the J.W. Marriott Hotel and take them out to different
restaurants and show them around, and he was having to be tour guide,
plus Mr. Bigwig, too. So basically he wanted to be able to hire someone
that would make dinner reservations and find out what is going on
around town, and be there to kind of like show these people around and
that sort of thing.
The reason why he told me he wanted me to go to China was because
he wanted me to go and learn more about the culture and how--he is
like, you will see how well you are treated over there, this is the
kind of respect and treatment they will expect when they come here. He
is like, I am planning this trip, so I think it would be a really good
thing for you to come to see what their culture is like, that when you
show up, there are flowers and that sort of thing.
Question. So he mentioned the China trip when he was making the
offer to you?
Answer. Yes.
Question. You hadn't accepted at this time?
Answer. No. No. No. That was sort of like the lure.
Question. How many times did he approach you about this job? You
said it was more than one discussion you had with him?
Answer. Yes. My sense is, he must have been in town, and probably
stopped by the White House. I mean, I want to say daily, but who knows
if it was in one day and not another day or whatever.
He would talk about China and how wonderful her people are and how
great it is over there and you have to see it, and what great work
could be done here with this bridge-building process and how, you know,
he was trying to get people from here to go over there. And so I would
say a couple of conversations about it.
Question. Do you know what type of time frame we are talking about?
Answer. It all--I mean--fairly quickly. I was a little off on my
weeks, because I thought it was like the end of April. So, what? The
delegation first came March 9th and I was on a trip to China April 11.
Question. That is correct.
Answer. All within a month, basically, then.
Question. Okay. Were you surprised he approached you about a job?
Answer. Yes. I mean, I didn't have plans for a job right after
school, and wasn't exactly sure what I was going to do. But then this
came along.
Question. Do you know why he approached you in particular?
Answer. No. He said that he liked the way I handled things in the
First Lady's office. He thought I had a professional manner, and I was
there more than like the--the other interns at that time were not full-
time, like they would come in a couple of days a week, so I don't
know--in between their classes and that kind of thing.
So I don't know if he was just more used to seeing somebody there
as opposed to the others, if I had more to do with him because of that.
Then the other people he would have been in contact with a lot were the
old ladies that were there all the time, too. So it was like me or them
in a way.
Question. Did he offer anybody else a job that you know of in the
First Lady's office?
Answer. Not that I know of.
Question. Let me show you one of the documents that you brought
with you today. It looks like it is a March 21, 1995, letter that you
sent to Johnny Chung.
Answer. Yes. Oh, yes, the other part about the job that we
discussed, because he was asking me about what I was interested in and
what I wanted to do with the job. The research project that I had
worked on was all on how to include young people in the political
process, I was real into the youth vote, rock vote, MTV and all that
stuff.
What he told me is, I am looking for an assistant, it is not going
to take up that much time. I basically need an assistant in Washington,
so when I come to Washington, you would be there. In your off time, you
can work on your youth vote stuff. Basically when I am in L.A. or
China, or whatever, you can work on the side stuff. So this was a
letter that I wrote to him after I had accepted the job and told him I
was excited to go to China.
Question. By this date, March 21st, you had already accepted the
job offer, or is it an acceptance letter?
Answer. ``I look forward to discussing more of the details later
this week,'' so things must not have been finalized by then. But it
must have been my acknowledgment of an initial conversation we had.
Question. Let me show you another document, this is a March 26,
1995, letter that is addressed to Maggie Williams, and it appears to be
from Johnny Chung.
Answer. Right.
Question. Did have you seen this before? Obviously you have. This
is another one you produced.
Answer. Yes. Johnny wanted Maggie to know that I would be working
for him, or--yes. So he wrote this letter. I think he actually like
dictated it to me or something.
Question. You think you typed this up?
Answer. Yes.
Question. Is that why you would have a copy of this?
Answer. Yes. Otherwise, I think it would be on his letterhead. But
whatever letter she would have gotten would have been signed from him,
so I don't know exactly.
Ms. Amerling. Let the record reflect that this letter is not
signed.
EXAMINATION BY MS. SAFAVIAN:
Question. Do you believe or do you know whether or not he actually
sent this letter or the original to Maggie Williams?
Answer. Actually, I remember handing Maggie this letter.
Question. Would that version have been signed?
Answer. It must have been.
Question. Would it be on AISI letterhead or pretty much as it
appears here, without any letterhead?
Answer. I don't know. I don't know why he would have given me
letterhead of his at that point though.
Question. Where do you think you typed it for him?
Answer. I have a laptop.
Question. Okay. Let me----
Answer. Wait, I didn't by then. I don't know. I didn't have my own
laptop by then. Where was I living? Did I borrow a friend's computer? I
did have a roommate that had a computer then; it could have been that.
Question. Okay. In this letter to Maggie Williams, he calls in the
third paragraph down, your responsibilities, what he would call
``courtesy visits for the groups of people coming over to America.''
Answer. That is what he called these, what I was talking about.
Question. Also in the last paragraph on that page, the very last
sentence, ``With your approval, I would like Gina to continue to work
and support this administration only with a slight change, that she
switch over from your payroll to mine.''
Answer. It is Johnny's humor. I was never paid at the White House.
It is--yes.
Question. So at this time, I mean, he must have known, and/or
Maggie and yourself, that you wanted to continue to work at the White
House as a volunteer. Did you discuss that with him?
Answer. I don't know about in detail. There was definitely--I knew
with the job we outlined, I would be working for him--that my time
commitments would be to him when he was in town, so when he was out of
town, I would certainly have free time, and I know I was all excited
about this youth vote project that I wanted to work on; and I don't
know if it was specifically said, I am going to become a White House
volunteer now.
Ms. Safavian. Okay. First of all, let me make sure, so I don't
forget, let's mark the March 21, 1995, letter that you wrote to Johnny
Chung as number GR-12, and the letter Johnny Chung sent to Maggie
Williams on March 26, 1995, as GR-13.
Ms. Amerling. Just for the record, I don't think we have
established that this document you just assigned GR-13 is the same
document that was actually sent to Maggie Williams.
[Ratliffe Deposition Exhibit No. GR-12 was marked for
identification.]
[Ratliffe Deposition Exhibit No. GR-13 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Ratliffe, I believe you testified you did hand----
Answer. I handed Maggie a letter. I don't know if it was like this
and signed by Johnny. I don't know if it was on his letterhead. I don't
remember why I have a copy that looks like this. I can't believe I
would handled her something like this unsigned.
Question. But you did hand Ms. Williams a letter?
Answer. Yes. Because I wanted to talk to her about working for him,
or letting her know.
Question. I was going to say, the last paragraph of that letter
mentions, ``Maggie, if you like, I am happy to talk to you about this.
You can call me at,'' and he leaves a phone number, with any questions.
What did Maggie say when you handed this letter to her and
discussed this with her?
Answer. Maggie was always busy. I remember it was like late at
night. She is walking out the door with her coat on. I said Maggie, ``I
have something I want to talk to you about,'' and I handed her this.
And I remember she like kind of skimmed through it, and was walking out
with Marge Tarmey at the time. She said, ``Oh, my God, she is going to
work for Johnny.'' Don't quote that per se, but it was something along
those lines.
Question. That was something Maggie said?
Answer. Like, oh, my gosh, he wants her to work for him, or
something along those lines.
Question. That is what Maggie said?
Answer. Yes.
Question. Did you sit down and talk with her, one on one, about it?
Answer. No. She was definitely walking out the door then.
Question. Was she ever concerned about you accepting a job with
Johnny Chung?
Answer. Not that--I mean, she never like sat me down and said--gave
me warnings or anything. I remember Marge was a little more concerned,
like when I got back from China, Marge was like, you made it back, you
know.
Question. Why do you think she was concerned?
Answer. I mean, I think people were a little skeptical are him.
Question. Was she fearful of your safety, saying she was glad you
made it back?
Answer. Yeah, it was--I don't remember any specific conversations.
It is not like anyone sat me down in their office. They certainly had
other things going on.
Mr. Zacks. Can we take a 5-minute break?
Ms. Safavian. Absolutely.
EXAMINATION BY MS. SAFAVIAN:
Question. Back on the record.
Before the break, we were talking about you accepting the job with
Johnny Chung and speaking with Maggie Williams about it. Besides
informing Ms. Williams, did you speak with anybody else about accepting
the job with Johnny Chung?
Answer. Yes.
Question. Who would that have been?
Answer. My parents, friends, professors.
Question. Did you ever speak with the NSC, the National Security
Council, about accepting a job with Johnny Chung?
Answer. No. I never went to them and said, I am thinking of taking
a job with this guy; will you check him out? I might do that now.
No, I never really worked with the NSC. The only thing that I
really had to do with them was with the photos, when I heard that they
were kind of--they were sort of the holdup there.
I don't know if anyone did check out Johnny or what. I never made a
request myself to the NSC to check him out.
Question. Okay. Do you know, for instance, when Johnny Chung
brought in the Chinese delegation, do you know whether or not the First
Lady's office had the NSC or somebody else look into the backgrounds of
these individuals?
Answer. Not to my knowledge. The only thing that I vaguely remember
about that was, after they got into the radio address--and this is all
hearsay--but I heard that the President said to somebody, or something
like, who are these guys, or check them out or something like that; and
then I guess the NSC was checking them out, and that is why the photos
were being held.
So that is what I remember about that.
Question. You don't believe the First Lady's office did any
background checks on these individuals before they let them in to see
the First Lady?
Answer. I mean, they had to have been cleared in, but I wasn't
involved with anything like that or knew about it.
Question. Were you ever--I am talking generally now--were you ever
involved in helping to vet potential guests into the White House?
Answer. Vet?
Question. The process, that is a term of art that they use--looking
into the background of individuals, clearing them before they enter the
White House.
Answer. No. That wasn't my--I mean, the absolute most would be if
somebody called in and said, ``I am having a meeting with Maggie. I
want to confirm I am cleared in.'' I would take down like a message or
something, or so and so. The most I would probably be involved in would
be a phone message.
Question. Do you know who in the First Lady's office would do that,
if anybody?
Answer. Who cleared people in? Anybody on staff could clear people
in.
Question. You don't know of anyone in particular who would look
into the backgrounds of anybody before they let them into the First
Lady's office? Someone who wasn't a normal visitor?
Answer. I mean, to my knowledge, it wasn't really a need for that.
Question. Okay. Let me show you an e-mail that is dated April 7,
1995, from Robert Suettinger with the NSC. Have you ever seen this e-
mail before?
Answer. No.
Question. Why don't you take a moment and read through that.
Mr. Zacks. This is on April 7th?
Ms. Safavian. Yes. If you look, there are two e-mails on this page.
At the bottom there is one from a M. Brooke Darby, and she was sending
it to the Asian Affairs Department. What the one on top is, is the
response to the bottom e-mail. They are both done the same day, April
7, 1995.
Mr. Zacks. The bottom is a response to the top?
Ms. Safavian. No. The top is a response to the bottom.
Ms. Amerling. It appears that way from looking at the document.
The Witness. I do remember this now.
EXAMINATION BY MS. SAFAVIAN:
Question. First of all, you have never seen this before; is that
correct?
Answer. No, I have never seen an e-mail. I am sorry, I had
completely forgotten. I don't know who this Darby is, but Bob
Suettinger does ring a bell.
Question. Okay.
Answer. I do remember going up to his office now, and I guess I
asked him, said something about--it is really unclear. Like I remember
him more talking about his kids, and like I think this was--and saying
don't take it or whatever. I must have told him something about it.
Question. Just so the record is clear, the second paragraph says
``Having recently cancelled a young intern from the First Lady's
office, who had been offered a dream job by Johnny Chung, I think he
should be treated with a pinch of suspicion.''
Answer. Yes.
Question. So you do recall now----
Answer. Yes, I do. I remember his office, like I remember like--you
have to like press these little buttons to get into the NSC. And I had
delivered whatever, interoffice envelopes, there before. But I do
remember now talking to this guy. I don't really remember what I said.
I remember him talking about, I think he said, I have a daughter your
age, or something, and I wouldn't want her to take a job like this,
something to that effect.
I don't remember actually sitting down and outlining to him, yeah,
Johnny Chung offered me this job; these are going to be my
responsibilities. I had completely forgotten about that.
Question. Do you recall why you would have gone to Robert
Suettinger? Did someone recommend you do that? How did that happen?
Answer. Honestly, I don't remember. My guess would be that Maggie
must have had some involvement in this or looking out for it. I don't
know if it was like after I showed her the letter. I don't know if she
said, go talk to this guy. She is always very busy, but she was good
about looking out for her staff people, not that I was on staff. But,
yes, I don't----
Question. You talked to him?
Answer. Is he short, bald and kind of chubby? I can't even remember
exactly.
Question. I am afraid I can't tell you.
Answer. Okay. I vaguely remember this.
Question. So you just had a brief conversation with him?
Answer. Yes.
Question. Just one time?
Answer. Yes. That is all I remember. I can't imagine more. No, I
don't remember anything.
Question. And he had counseled you not to accept the job?
Answer. The most I remember, if this was the guy, him saying, I
have a daughter your age, and I wouldn't like to see her take that job.
That is like what sticks out.
Question. Okay. What did you think of his advice to you?
Answer. I don't know. Apparently I didn't listen to it.
Actually, I was thinking about this as all this deposition stuff
came up, that no one--I was thinking, you know, it is really funny that
no one advised me not to take this job except for a professor of mine
from Kalamazoo.
He lived and worked in China for a while, and I took a course from
him on Asian political systems, so I called him thinking that he would
know about, you know; and Dr. Tanner, what do you think? And he is
like, ``Don't do it.'' He was saying, ``Chinese men are slimeballs. You
know, you could get a job working for anybody. I would like to see you
find something else.''
I talked to professors at Western, and they are like, go for it,
this sounds great. White House folks were kind of--like as far as like
Maggie or Evan or Marge or any of them, no one really seemed to say
like, great; or, don't do it, from what I remember.
I remember this one professor being the only one that really
suggested not to take it. But then I see this and I vaguely remember
this guy saying that too.
Question. Okay. You read through this e-mail. In this e-mail, Bob
Suettinger calls Johnny Chung a hustler. He says in the second
paragraph ``My impression is that he is a hustler.''
Had you heard anyone call Johnny Chung a hustler?
Answer. No, because that would have really--that label would have
stuck out to me as a big warning sign. Definitely, in looking at this
job, it wasn't your standard first job out of college--you know, set,
safe and secure situation. I mean, I had my doubts, wondering what is
this really going to be, what is going to unfold? I realized it was,
you know, sort of a risk, because I didn't really know what I was
getting into.
But decided to do it.
Everything was sort of, at that point, gray. It wasn't like white
or black. But hearing the word ``hustler'' makes me, I wouldn't have
wanted to work for somebody that had that label.
Question. So you did not know about that?
Answer. No. I never saw this e-mail.
Ms. Safavian. Okay. Why don't we mark this GR-14.
[Ratliffe Deposition Exhibit No. GR-14 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Do you know if Johnny Chung knew that the NSC considered
him to be a hustler?
Answer. I have no idea. He would have been deeply offended. No, the
way Johnny talks, everybody is his friend, everybody loves him, this
was then, you know. My good friend, Maggie, my good friend Don Fowler,
that is sort of the way he talks. He never talked about you have some
friends, you have some enemies. It was never anything like that.
Everybody was his friend. Everybody loved Johnny.
Question. Let me just show you real quick and see if you have any
knowledge about this, this is the same E-mail we just looked at.
However, this is one that was produced by Johnny Chung in response to
our committee's subpoena. Do you know why or how Johnny Chung would
have a copy of this e-mail?
Mr. Zacks. Counsel, do I take it that this was faxed to Mr. Chung
on the 21st of February '97?
Ms. Safavian. Unfortunately, I cannot answer that. The fax
transmission at the top of the page. I just don't know the answer to
that.
Mr. Zacks. The specific question, Ms. Ratliffe, is do you know how
Mr. Chung got a copy of this e-mail?
The Witness. No.
EXAMINATION BY MS. SAFAVIAN:
Question. Did you know that he had a copy of this e-mail?
Answer. No.
Question. Let me just for the record mark that as GR-15.
[Ratliffe Deposition Exhibit No. GR-15 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. So your first duties or your first job that you had to do
was you went to China with Johnny Chung.
Answer. Yes.
Question. We have already established you left April 11th and
returned April 25th?
Answer. Yes.
Question. Who all went on this China trip?
Answer. Johnny, Art Liang, is how you say his last name. It was the
three of us that went over there from his LA office. And he--that is
who went to China.
Question. And what did you do while you were over there?
Answer. Meetings, all the time. Mostly meetings. I did very little
sight-seeing.
Mr. Zacks. Thirty seconds. Nobody move. I will be right back.
[Recess.]
EXAMINATION BY MS. SAFAVIAN:
Question. You were talking about your trip to China. You went to
meetings?
Answer. Meetings.
Question. No sight-seeing?
Answer. A little.
Question. Was there any purpose to these meetings? Were they all
varied, different kinds of meetings? Can you give me any explanation?
Answer. Johnny's mission was to do this peacemaking, bridge-
building thing. It was like an unofficial-official visit sort of thing.
I don't even know what is important or what you want me to say about
it. We met with people that they considered to be in their private
sector, and we met with government officials. I had a translator with
me most of the time, but didn't always translate. To me, it seemed like
a bunch of the same thing he was doing here, just over there. Just the
meet and greet, hi, I am so important, hi, I know so many people, hi, I
have so much money, hi, I can help you. You-need-me sort of ego trip
that he was on.
Question. Was he trying to get clients for his business, his fax
business?
Answer. No. Like he talked about wanting to set up a Beijing
office, but he like went with this messenger of peace mentality, that
he was there to help build this bridge between the two countries. So he
would meet with people there.
I can't even remember all that he talked about. I just remember
being so irritated because it was just a big brag session for him.
Either how much money he had or how much everybody liked him or how
whatever he thought he could do.
Question. You brought in today from the documents you brought with
you, was a folder of materials from your trip to China; is that
correct?
Answer. Yes.
Question. Is this the same trip to China that we are talking about
right now?
Answer. The one and only.
Question. You only took one trip to China?
Answer. Yes.
Question. You also had a--well, we can start with this stack here,
a stack of brochures from different, it looks like different companies.
Answer. Yes.
Question. Are these representative of some the meetings that you
had?
Answer. Correct.
Question. Okay. Do you recall anything in particular about any of
these companies, the brochures you kept? Was there any reason you kept
these?
Answer. It was just stuff that people handed out. I honestly can't
even tell you what was there. We went back to a couple of them more
than once.
Question. Do you recall which one?
Answer. Is there something from the exhibition center in there? I
guess not.
This was a news agency that Johnny talked about.
Question. This, I am not going to try this, K-I-N-H-U-A news agent,
news bulletin?
Answer. It was just like them showing an example of what they do.
Question. And it looks like you went to the----
Answer. That was actually more sight-seeing.
Question. The Yan-Huang Art Museum?
Answer. Yes. The artist, like he did these, I don't even know what
this means, but this was supposed to be really special. I was supposed
to be very honored to receive whatever name he gave me.
Question. Okay. This other one is China Enterprise Management
Association.
Answer. I have no idea.
Question. There is another brochure here called ``China
International Exhibition Corporation.''
Answer. That might be the--I honestly don't remember it looking
like this. I really don't even--they are not like Americans. They don't
like meet, have a meeting to discuss something and do anything about
it, at least that is not what we did. It is like show up, shake hands,
pass out name cards, tour the joint, talk, set up a time to meet for
dinner kind of. At least that is what I got from it. It is not how can
we work together and what can we produce or make or anything like that.
Question. So you don't really recall anything specific about----
Answer. The only tangible thing, Johnny was looking--there was one
place Johnny was looking for office space to set up his Beijing office,
and this was just one example of many. He was looking at this one
space. It had like the Chinese military outside of it, and, you know,
me acting in good faith, I am thinking, I don't think that would be a
good place to set up an American business, if you want other Americans
to know about your business here.
Anyways, he said, yeah, that is a really good point. I am not going
to have office space there. Then we went back the next day and he is
sitting there telling them how interested he is in having office space
there. And I knew he clearly wasn't, and you don't have to be that
blunt about it. But that he was being that blatant to go out of his way
and still saying how interested he was, when we had discussed the night
before that he clearly wasn't.
I said something to him about it the next day, and he got angry.
That is the only thing I remember.
Question. You think that is, what, the China International
Exhibition Corporation or something else?
Answer. I don't know.
Question. Another brochure that you have with you is from China
Xinxing Corporation.
Answer. I have no idea.
Question. And the last one is it looks like a brochure from the
Beijing Tong BRN Tang Group Company in China.
Answer. This is something about ancient medicine. I honestly don't
remember. We just went to place after place after place, back-to-back.
The only thing that sticks out to me, Johnny kept talking about the
number two beer-making corporation, and something about an oil company.
We probably spent more time with those dudes than any of these others.
Question. Okay. You also brought along a set of business cards. Are
these cards that you were given when you were on your trip to China?
Answer. Yes.
Question. Some of them are from just a couple, are from AISI, yours
is in here, and Irene Wu and a couple other people. Are these just ones
you put in the stack or you actually got these in China?
Answer. Those cards would be a pile of cards that I obtained while
working for Johnny. I would say most of them came from the China trip.
There were a couple of delegations when I was working for him that came
here, and they might have given me cards, like when we went to dinner
or something. Irene's I probably got when I was in LA.
Question. You mentioned just a second ago that Johnny talked a lot
about the second beer manufacturer.
Answer. Yes.
Question. The name of that is Haomen Group?
Answer. I have no idea.
Question. Do you remember the name of it?
Answer. It might be one of these guys.
Ms. Amerling. Let the record reflect the witness is looking at
Exhibit GR-2.
The Witness. I am not positive, but there is a chance that Evans,
and like his son, whoever it is, we had dinner with him one night.
There was like a grandpa, a father and a granddaughter.
EXAMINATION BY MS. SAFAVIAN:
Question. This is the beer manufacturer?
Answer. The beer thing, yes. Johnny seemed to be kind of tight with
them.
Question. Let me show you two--first of all, the gentleman that you
were pointing to in GR-2 is the gentleman at the far end of the photo
on the right with glasses and balding. It is hard to say. He doesn't
really list names at the bottom in order, so I don't want to confuse
him.
Let me show you two business cards you have in your stack. They are
both Haomen Group. Do these names help you at all with the dinner you
had?
Answer. No. Honestly, like they all look the same to me. I just
remember the guy we had dinner with was like older than like these guys
were like the norm, and he was----
Question. These guys being Johnny Chung is one of them?
Answer. These guys in here. Most of the guys I would say were in
their like forties and fifties, and this guy was a little older, a
little skinnier, and had a little less hair. So if it was him or
another person.
Question. You are not sure that this is identified as him?
Answer. That is all I am trying to say.
Question. Okay, that is fine. Did you learn anything else about the
beer manufacturing company that you were talking to?
Answer. Johnny was big on them. I don't know why exactly. I don't
know why he was tight with them, how he knew them. He was constantly
bragging about we are going to have dinner with the number two beer-
making corporation in China. I don't know if they did come to the U.S.
Question. Do you know if Johnny Chung owned stock in the beer
manufacturing company?
Answer. He never mentioned to me if he did. I never heard anything
about stock.
Question. Let me just, for just a couple, read off some of the
names. China International Trust and Investment Corporation? See if
they mean anything to you?
Ms. Amerling. Just to be clear for the record, counsel is reading
off business cards.
The Witness. It doesn't sound familiar and it doesn't not. I know
that is not helpful.
EXAMINATION BY MS. SAFAVIAN:
Question. Just let me know if any of them do. The name on the card
is H-U-A-N-G, J-I-C-H-U-N.
Answer. The exact names mean nothing. The beer-making company and
the China petrochemical corporation, he talked about that a lot.
Question. Do you recall in what sense?
Answer. We had dinner, I think, or lunch, at their headquarters. I
might have even gone shopping with his daughter, if that was the same
place.
Question. Okay. How about China Chamber of International Commerce?
Answer. Yeah. You know, what, that is who this guy is, isn't it?
Question. One of the gentleman, the photo with Mrs. Clinton, the
Chinese delegation, one of the gentleman in the picture is from the
China Chamber of International Commerce.
Answer. We spent a lot of time with him. We went to his home one
afternoon.
Question. S-H-E-N-G?
Answer. The names mean nothing to me.
Question. Do you recall anything else about that?
Answer. The Chamber of Commerce dude seemed to be, and I could be
wrong, but he seemed to be the link between the higher-up officials.
When we were there, we got in to meet who I thought was Vice Premier
Lee. Actually that reminds me it wasn't him. This is, I think, the
Chamber of Commerce guy----
Question. You do think this is the China Chamber of Commerce guy?
Answer. Yes.
Question. The one standing next to Mrs. Clinton?
Answer. And not Vice Premier Lee. The Vice Premier lives in the
Forbidden City. I don't know. Chinese residents are not allowed to go
in there. I don't think women usually are either, but somehow Johnny
got us in there. One of the guys that we were kind of with, that was
sort of with our group, he lives over there, but apparently works for
Johnny. I don't know if he is like the Beijing office or whatever
Johnny would call it, I don't know, and he wasn't allowed in.
When we went in, Johnny got his picture taken with this guy. I
absolutely didn't even care about it, didn't even want it. I got my
picture taken with this guy. Art, who was also Johnny's like chief of
staff or whatever you want to call him, got in, but didn't get his
picture taken. Art was like furious about this. It was like a whole big
prestige thing with them. And I don't even know what they sat there and
talked about. But this translator guy was there for that.
Question. Okay.
Answer. And I think this Chamber of Commerce guy was like the link,
the political link.
Question. That is how you got in the Forbidden City?
Answer. Yeah. I mean, Johnny was definitely involved in making all
that happen.
Question. Okay. Does China Everbright Group mean anything to you?
Answer. That sounds familiar. I have no idea why. Are they a bank?
Question. Well, there is one called Everbright Bank of China on
another card that you have.
Answer. It all----
Question. That is fine. Now, you mentioned earlier there was this
flurry to get these photos with the President. You had to have them to
take to China, and you brought them to you. What did he do with the
photos once he got to China?
Answer. I assume he gave it to them.
Question. Did you see that happen?
Answer. I must have, because I was always with him, but honestly it
doesn't like stand out to me as part of the trip.
Question. Do you recall him showing anybody photos? I think, you
know----
Answer. Oh, we took a crate of those books.
Question. Of the brochures?
Answer. To hand out to everybody we met with, yes. So he definitely
passed those things out like crazy.
Question. Would he pass out any letters that he may have gotten
from the President or the First Lady or anybody?
Answer. Well, actually I just saw on the left-hand side of that
packet the Chinese stuff, I didn't even remember that he did, but just
in preparing these for today, I think they were in here and I was
laughing. It was in some stack.
Mr. Zacks. I think they are in those booklets.
The Witness. Are they actually in the booklet?
Mr. Zacks. I think so.
Ms. Safavian. I am not sure what you are looking for. Are you
talking about these?
The Witness. Yes.
EXAMINATION BY MS. SAFAVIAN:
Question. These are letters that you had, that you brought in
today. I was going to ask you about these.
Answer. Johnny had--he gave me just a stack of his correspondence
or whatever, and so but I noticed that there was some packet of
something that he had handed out, and I think a letter from the
President, Al Gore and Mrs. Clinton were in it.
Question. If any of these look familiar to you, why don't you state
that for the record and we can make those exhibits.
Answer. Maybe it wasn't Mrs. Clinton. Maybe it was just Al Gore and
the President one.
Question. Why don't you take a look this stack also.
Answer. The letters are in from, but it was in something that he--I
really thought it was in something like that, that he handed out to
people.
Question. With his brochure?
Answer. I didn't think it was in the book. This is all the DNC-
related stuff.
Question. Do any of those letters that you have been flipping
through, do you recognize any of those as the ones that you copied for
him and he handed out?
Answer. Johnny?
Question. Yes.
Answer. I didn't copy any letters that he handed out.
Question. I thought you--I am sorry, I misunderstood you then.
Answer. No. He had--my involvement in China, he had these booklets
made up, and he had like a big crate of them that we brought to China
with us, and----
Ms. Amerling. ``These booklets,'' for the record, are the booklets
with ``AISI Building the U.S. Fax Highway Today'' on the cover; is that
correct?
The Witness. Yes. And he would hand these out the way people hand
out business cards. And I didn't think there were letters in these. I
thought that I just ran across it in like a packet like that he had
handed out.
EXAMINATION BY MS. SAFAVIAN:
Question. What letters are you recalling?
Answer. It was some boilerplate thank you letter of the President
thanking him for his support for some fund-raiser.
Question. So he had a letter from the President.
Answer. Yes.
Question. Anybody else you can remember?
Answer. I don't remember if it was the Al Gore one, too. They are
like these little like, you know, three-sentence letters of thank you
for your support kind of thing.
Question. And he would pass those out along with these brochures?
Answer. No, no. I just ran across--he would pass these and his
business cards out, or like hand them out in these blue packets with
his business cards in it. I just ran across in my collection of
materials for you, I really thought it was something like this, that
he--if he was like handing this out to somebody, it was just like a one
thing, that it was in there and it looked like he was including these
letters to prove even more so that he was tight with the President or
something. But this is what was handed out. And I don't even know what
version. I'll bet it wasn't this version, because this would have
probably--I don't know.
Ms. Amerling. When you say this, what was handed out, we are
referring to the AISI booklet?
The Witness. He has some different versions with different
pictures.
EXAMINATION BY MS. SAFAVIAN:
Question. You are not sure if the picture of Mrs. Clinton and the
delegation was included in the brochure he handed out?
Answer. Correct.
Question. Okay. Moving away from the China trip, although as I was
rummaging through these documents, I did see one of the things you
produced that says Everbright Bank and Everbright Group. Let me show
this to you, because you mentioned earlier Everbright was a bank. Does
this help you remember who Everbright is?
Answer. Yes. This was a group that--I think, there was a group that
came into town and they were with a bank, and the only involvement that
I had with them was that I went to dinner with them one night. And
there was probably a group of eight of us, and I sat and talked to this
girl all night about the differences between the U.S. and China,
culturally, women's issues. I don't know what all the men were talking
about.
Ms. Amerling. Counsel, can I have a copy of what she is looking at?
Ms. Safavian. It is in that stack right there.
Ms. Amerling. Is it this document?
Ms. Safavian. Yes, it is.
The Witness. I remember Johnny had been showing them around.
EXAMINATION BY MS. SAFAVIAN:
Question. Do you recall the name of the person you were speaking to
that night?
Answer. No.
Question. Okay. Do you recall what this business did?
Answer. In this is the bank, there is something about--some bank
was coming into town, everyone is interested in seeing the White House,
some White House tour. I was really involved with like this kind of
stuff, dinner reservations. Johnny at one pointed talked to me about
some bank wanting to open up a New York branch. Something about
something in New York, and he was wondering if he should get involved
with it or not. But I honestly don't know----
Question. Okay. That is fine.
Answer [continuing]. A lot about it.
Question. Okay.
Answer. Or anything else.
Ms. Safavian. Since we talked about it, let me mark this as Exhibit
GR-16.
[Ratliffe Deposition Exhibit No. GR-16 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. When you returned from China, what did your--first of
all, you were located in the Washington, D.C. office for Johnny Chung?
Answer. Yeah.
Question. Okay. Can you tell me a little bit about that, how many
offices he had, where they were located?
Answer. Physical offices, I saw would be in LA. His Washington,
D.C. office was me, so, I mean, it is not like I got up and went to
work at a location every day or anything like that.
Question. Where was it then?
Answer. That was when all of the problems started basically is when
I got back from China. It was everything that was promised or talked
about or was supposed to happen, or I thought had already happened
actually didn't even exist.
Question. And what do you mean by that?
Answer. An office.
Question. A D.C. office?
Answer. Yeah. Phone, fax machine, desk.
Question. Were you working out of your home?
Answer. It wasn't really work. When I was in LA, he needed some
letters typed, I remember, I think, to Don Fowler, maybe to Secretary
Riley, and I typed some stuff there for him. But that was all out of
the LA office. So when I got to D.C., I don't even think I dropped them
off. I probably just mailed them. I didn't do anything for him when he
wasn't there, when he wasn't in D.C.
Question. Well, you said that there wasn't an office, you didn't
get up and go to an office. If you did anything for him, would it have
been at your home?
Answer. I mean, he definitely called me at my house about things,
but it really--what I learned about Johnny, his wife actually explained
this to me during a conversation once. She said that Johnny is a
dreamer and he gets himself into trouble when he talks about--he talks
about things as if they actually are, rather than saying wouldn't it be
nice if, or I have an idea, and I think this would be great.
So rather than saying it would be great if we could have a $3
million mansion to fly delegations over to that, you could run and, you
know, occupy, he said ``I have a $3 million mansion that I am building.
It just needs some renovations. That is where you will work from,'' is
what he said.
Question. Located where? Where was he planning on----
Answer. I gave you the paperwork on that. He showed me a picture of
it, a map to it.
Question. Was this in D.C. or in LA?
Answer. It was like in McLean, I think in Virginia. I think McLean
anyway. It is the last page on that stack. Yes. So he would hand me
this and say this is where the office is going to be, this is where you
are going to function out of. He told me it was going to be ready by
June 1st. So I got back April 25th, expecting to move into this----
Question. Move into this home, this $3 million home?
Answer. Yes.
Question. Let me mark this so we can refer to it as GR-17.
[Ratliffe Deposition Exhibit No. GR-17 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Okay, go ahead.
Answer. So basically starting at this point, I--basically in China
I wanted to quit the job.
Question. In China you wanted to quit the job?
Answer. Yes. I hated working for him.
Question. Why? What happened?
Answer. Because he was annoying. He was just this big braggart. It
was this, me, me, me, I can do all this, I have all this money, I, I,
I, I. It wasn't what I wanted to participate in. I wanted to work with
the youth vote for the '96 election. So I came back. And then one thing
after another just started unraveling, and that is why it was so short-
lived, that within a couple of months I resigned.
Question. So he had promised you this $3 million home.
Answer. He gave me this paperwork, yes.
Question. Which is GR-17, and he said he was going to purchase this
and this is where your office was going to be?
Answer. My understanding was it had been purchased.
Question. Okay.
Answer. That it would be ready June 1st.
Question. Were you supposed to live in this also?
Answer. Yes. Like a building manager sort of thing.
Question. And work out of it?
Answer. Right. Right. Because he knew I was interested in this
youth vote stuff, he said you are going to have free time when I am not
in D.C. You are going to be able to do your research, work on your
youth vote things, and when I come into town with my delegations, I
want you to have dinner reservations made and things set up. He even
told me how he wanted me to be decorating it. He wanted it done
Victorian style.
Question. So you thought this was a done deal?
Answer. This was my plan. This is what I was told.
Question. Then you found out that wasn't the case?
Answer. Yes.
Question. When did you find that out?
Answer. June 1st when my current--I was living in Dupont circle,
and my lease was up, and so I asked him on a number of occasions,
Johnny, I was excited, of course. I want to go see this place. He says
oh, no, we don't have time now. Not now, not now. I didn't have a car
in D.C., so to schlepp out to McLean wasn't something I was going to
randomly do. I kept asking and kept asking.
Finally, it is not going to be ready for June 1st. So then I needed
to go find another apartment and all of that.
Question. Let me show this to you. It looks like it is a lease for
an apartment in D.C., if you explain that to me. I will mark that as
GR-18.
[Ratliffe Deposition Exhibit No. GR-18 was marked for
identification.]
The Witness. If we are talking about fall-outs, I think something
happened before this. The bank account.
EXAMINATION BY MS. SAFAVIAN:
Question. I don't think I have that copy.
Answer. It was in my correspondence about my job with him. It is a
very simple memo that says here is the Crestar Bank account
information.
Mr. Zacks. I gave you the stack from here.
EXAMINATION BY MS. SAFAVIAN:
Question. Let me hand this back to you, the lease, GR-18. So you
said the troubles began earlier with a bank account?
Answer. Yes. I think. Let me see the date on this. I think the bank
account thing happened first. This.
Question. Okay. This is a May 24--this is a letter you sent to
Johnny?
Answer. Yes. I faxed it to him, I think.
Question. And you want to just tell us about this?
Answer. Yes. He had told me as we were getting ready for all of
this, it is like I want to open up a checking account which will be the
AISI expense account in Washington and when you need to do whatever it
is that you are doing, you can withdraw from this account.
So I said great. He said go start, open up a checking account,
whatever. So I used $20 of my own to go start this account, and I faxed
him all the information. He said get me everything. So I faxed this to
him right away. I think I did it all the day he asked me to do this.
Again, I didn't have too many responsibilities. It was like
waiting. And it never happened. He never deposited any money in it. So
this never happened. And then in June 1st I am supposed to move into
this what I showed you. And that didn't happen. So then I had to go out
and scramble at the last minute and find an apartment, and this is the
apartment I found.
Question. This is the lease, GR-18.
Answer. Yes.
Question. Let me just say for the record that the letter that you
typed, that you gave to him dated May 24, 1995, regarding the Crestar
Bank account that you just talked about, we will mark as GR-19.
[Ratliffe Deposition Exhibit No. GR-19 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. And this lease, is this something that Johnny Chung paid
for the rent on this, this apartment?
Answer. Yes. He was angry because he didn't--I couldn't find
anything that--it was I had literally 48 hours or something to find a
place. I found this place, and I had to sign a year lease on it. I know
he was angry about that. And I said, you know, listen, you put me in
this position, so he did. He paid for--initially he paid for the first
month's rent and the security deposit for this. Because he kept saying
you won't need that for a year, this place is going to be ready, this
place is going to be ready, I don't want you signing a year's lease. I
went, oh, my God, I don't have many other options right now.
Question. In the end, did he just pay for the security deposit and
the first month's rent or did he pay for any more of the rent?
Answer. He paid for, I was there June and July. I think he had paid
for July, too. I don't think he paid for rent beyond that.
Question. Did you move out of the apartment then?
Answer. Eventually.
Question. So it would be pass July that you moved out of the
apartment?
Answer. Yes. I moved out--I actually moved out in December.
Question. And then you paid the rent yourself for the remaining
months?
Answer. Yes. I had to get a roommate.
Mr. Zacks. Excuse me. Just to clarify, during the time he paid the
rent, this was the AISI Washington, D.C. office in effect, correct?
Because there was no $3 million mansion?
Answer. There was no $3 million mansion.
Mr. Zacks. So this was the AISI D.C. office.
The Witness. Yes.
Mr. Zacks. This is where you worked out of for him while you were
still with him?
The Witness. Right.
EXAMINATION BY MS. SAFAVIAN:
Question. Let me show you a fax cover sheet in, an AISI fax cover
sheet, also one of the documents you brought with you today. This shows
that AISI has several offices. Can you explain that to me, please?
Answer. Actually when I was gathering these materials, I never
really paid attention to it before. Johnny always had so much hoopla
going on that you just sort of had to sort, at least that is how I
handled him, I just sorted through whatever, let him talk his talk, and
I was looking at this, Hong Kong, Taiwan, three China offices? I never
saw them, heard about them, know any of the people. Oh, except this one
guy, he must--David Chen I met him in China.
Question. David Chen is the contact person for the China office in
Beijing?
Answer. The Beijing office, yeah. He might also be--he might be the
son of this second largest beer-making company in China.
Question. He might be the son?
Answer. He might be. I can't remember exactly.
Question. And you know you met Mr. Chen, C-H-E-N?
Answer. Yes. He was the one also I believe couldn't get into the
Forbidden City or wherever we went with the Vice Premier, because he
lives there and apparently you are not allowed to go.
Question. You do have in your possession one of the business cards.
There is one for David Chen on an AISI business card that says special
assistant to Chairman, and it gives a California office address and a
China office address in Beijing.
Answer. Okay.
Question. This is the same defense David Chen, this business card?
Answer. He had a cell phone. I never saw any office. I don't know
what his responsibilities were.
Question. You don't know what Mr. Chen did as special assistant to
the Chairman?
Answer. No. He might have been involved in some of the scheduling
for the China trip of all of these random businesses that we met with,
but I just remember him with his phone.
Question. Okay. So the California office that is on this fax cover
page, that is an office?
Answer. That is an office.
Question. You saw that.
Answer. That is a big office.
Question. The Washington, D.C. office listed, 955 26th Street,
Number 709, Northwest. Did that exist?
Answer. That might be Johnny's apartment that he had in Washington.
Question. That is not your apartment?
Answer. That was not my apartment.
Question. The contact person is Dr. Wen C. Lin, senior advisor to
the Chairman?
Answer. I have no idea who that is.
Question. Never met him?
Answer. If I did, I don't remember.
Question. There is a Hong Kong office.
Answer. No, they wouldn't take me to Hong Kong. I wanted to go.
Mr. Zacks. Off the record a minute.
[Discussion off the record.]
EXAMINATION BY MS. SAFAVIAN:
Question. Back on the record. I notice there are two contact people
listed for the Hong Kong office, a Mr. George Liu?
Answer. Oh, that sounds real familiar.
Question. You have his business card also.
Answer. George, I think I met George.
Question. Not in Hong Kong.
Answer. Not in Hong Kong, no. I did meet George, and he has a
girlfriend named Jennie who is a dentist professor at NYU, I think.
This is all totally just coming back.
Question. Do you remember where you met Mr. Liu?
Answer. He flew in--if this is the same guy, he is this chubby dude
that had a ton of money, and I didn't know he really worked for AISI.
Question. I am showing you an AISI business card for George Liu
which says he is special assistant to the Chairman and gives the
California office address and a Taiwan office address on his business
card.
Answer. Johnny is Taiwanese.
Question. Actually, farther on that fax cover sheet there is a
Taiwan office, and Mr. George Liu is the contact person for that office
also.
Answer. Okay.
Question. Do you know what he did for Johnny Chung?
Answer. George had a ton of money of his own, and I can't remember.
Question. Was he a shareholder?
Answer. No, but some other lady was that I met at one point. I
don't know if I met her in China or in LA. I don't know. But George
just seemed to have fun with life.
Question. You said some other woman. There is also a Ms. Emily
Chang listed as the contact for the Hong Kong office. Does that ring a
bell?
Answer. That name doesn't. But I remember meeting some woman that
was probably in her forties or fifties that Johnny introduced to me as
on his board or something like that.
Question. You don't recall her name?
Answer. No.
Question. So you don't know if there is really a Hong Kong office?
Answer. No.
Question. Do you know if there is a Taiwan office?
Answer. I thought----
Ms. Amerling. Can you verbalize here?
The Witness. No, I don't know. I thought Johnny had not been back
to Taiwan since he was 12. I thought he left when he was 12 and never
went back. But, I don't know. Apparently.
EXAMINATION BY MS. SAFAVIAN:
Question. There is also another contact person in the Taiwan
office, a woman, Ms. Li-Ching Chen.
Answer. I have no idea.
Question. Then we mentioned earlier this Beijing office with David
Chen. You don't know if that exists?
Answer. No, I don't.
Question. And another contact person is a Mr. Yei-Jun He.
Answer. I remember people saying a Mr. He, Mr. He, but I don't have
any more recollection other than that.
Question. So you don't know what he did for Johnny Chung?
Answer. No.
Question. There is another China office, actually there are two
more China offices. There is one in--let me spell it, Q-U-A-N-G-Z-H-O-
U. Do you know if that office exists?
Answer. I don't know that any of these offices exist. The only
connection I can make with one of these, if you know which one of them
is in the north, this young dude owns a bunch of hotels there.
Question. Is this Mr. Sun?
Answer. I can't remember his name.
Mr. Zacks. May I ask a point of clarification? During your China
trip, did you visit any of these China offices listed on--this isn't an
exhibit yet.
Ms. Safavian. It is going to be.
Mr. Zacks. This AISI fax cover page?
The Witness. I don't remember visiting any AISI office.
Mr. Zacks. Okay.
EXAMINATION BY MS. SAFAVIAN:
Question. The gentleman you were pointing to in Exhibit GR-2, the
young gentleman all the way on the left of the picture, the fax cover
sheet lists a Mr. Jian-Feng Sun. Mr. Sun, it appears, is one of the
Chinese delegations in the picture, and Johnny writes under the picture
with Mrs. Clinton, the young entrepreneur from Xinjiang. That is also
one of the locations of one of the China offices.
Answer. I never saw it or really heard about it. He was in Beijing
when I was there.
Question. Mr. Sun?
Answer. Yes.
Ms. Amerling. By it, you are referring to the office?
The Witness. I never saw any AISI office other than the one in LA.
Ms. Safavian. Let me mark this AISI fax cover sheet as GR Number
20.
[Ratliffe Deposition Exhibit No. GR-20 was marked for
identification.]
Ms. Amerling. Could we assign an exhibit number to the business
card you were referencing as well so the record is clear, the George
Liu?
Ms. Safavian. Why don't we put these all on one page? I referenced
George Liu and David Chen. We can copy those on one page and make those
Exhibit GR-21.
[Ratliffe Deposition Exhibit No. GR-21 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Okay. So you were having problems with Johnny with your
apartment. Did you end up doing any work for him? Did you do anything
for him?
Answer. I started to. I tried to. He told me that he wanted me to
know about all the finest restaurants in D.C., and I was supposed to go
and check them out beforehand while he was away in LA or whatever, and
get to know the general managers there, the menus, et cetera, so I went
to Martin's once and had dinner. It is like I started to try and
fulfill some of my responsibilities while he was out of town, because I
basically wasn't doing--he didn't give me anything to do. There wasn't
anything to do. So I went to Martin's.
Question. Did he pay?
Answer. Eventually I was reimbursed.
Question. Did you ever schedule any--were you ever this, what was
your title, courtesy----
Answer. Courtesy visits.
Question. Did you ever prepare any dinner reservations or tours
around D.C. or anything for any delegation that may have come to town?
Answer. No. I went to dinner with that bank group that night, but
he had arranged all that.
Question. When you say that bank group, do you mean the Everbright
Bank?
Answer. Yes. He arranged that.
Question. Okay. So he didn't have you arrange----
Answer. I never set up tours, I never made dinner reservations, no.
Question. Did you set up anything for Johnny and/or any of his
guests at the White House?
Answer. No. He came into town one time when I was like technically
working for him, yet a volunteer, and I didn't even know he was coming
into town. He called the First Lady's office and he wanted a tour, and
Ann McCoy, I believe it was Ann McCoy, showed him around. It was
someone other than me. I remember sitting there saying I am not even
doing my job when he comes into town.
Question. Did you schedule that tour for him or did he contact Ann
McCoy directly?
Answer. I don't know if he called the First Lady's office and if
somebody else there called or if he called her directly. I don't know.
Question. You had nothing to do with it?
Answer. No. I don't remember it. I remember thinking it was weird
that Ann was showing them around.
Question. Did he ever have you contact anybody at the DNC on his
behalf?
Answer. We went to the DNC. I went to the DNC with him. I think--
again, it was one of these like meet-and-greet, handshake kind of
things. It was no meeting really. We might have met Don Fowler. Whoever
happens to be walking down the hall, you know, Johnny--of course,
everybody at the DNC knows who he is and runs up to him, ``Johnny, we
have a breakfast coming up in LA,'' and they are like handing him
stuff. He was introducing me to these people.
The person we talked to the most was whoever sits outside of Don
Fowler's office.
Question. Does Carol Caire ring a bell?
Answer. I thought it was like a Selinda.
Question. Sandra Scott?
Answer. Yes. Is she an African-American woman?
Question. I don't know.
Answer. Like topical Johnny fashion, the real--I shouldn't say
that, well, the real people didn't make time or have time for him, and
he was sort of shuffled off to assistants or whatever.
Question. Who do you mean by the real people?
Answer. If you want to, like, relation would be Maggie and Evan,
you know, like Maggie didn't have--I never saw him go and sit in
Maggie's office for any sort of formal meeting. But Evan would have to
entertain him, so-to-speak, when he would come in, so he would still
feel important or whatever. So I remember spending more time with her
than anyone else at the DNC, was my point to that.
Question. Let me show you a----
Ms. Amerling. So the record is clear, more time with whom?
The Witness. Sandra Scott, if that was her name.
Ms. Amerling. You are not certain it was Sandra Scott?
The Witness. I believe it was somebody that was an assistant to Don
Fowler.
EXAMINATION BY MS. SAFAVIAN:
Question. Let me show you a June 5, 1995, letter, to you from
Johnny Chung.
Answer. Yes.
Ms. Amerling. Could you point me where I could find that document?
Ms. Safavian. This is one of the ones that she produced to us
today. It is in one of the stacks.
The Witness. She can have that one.
Ms. Amerling. If you could give me one minute to look at it, I will
give it back in a minute.
EXAMINATION BY MS. SAFAVIAN:
Question. Do you remember receiving this?
Answer. Yes.
Question. This letter. You do recall receiving this letter?
Answer. Yes. It was Fed Ex'd.
Question. It was Fed Ex'd to you?
Answer. Yes.
Question. It shows that he enclosed a paycheck for the month of
May, and a personal check to assist you with your move. The next
paragraph says, ``As you are aware, there is usually a 3-month
probation period for all new hire employees. I would like to request
from you at this time a proposal on what you can contribute and how you
can assist AISI in Washington, D.C. After all, that was the major
reason for your employment with us.
``I am very sorry to say that your performance lately has not been
satisfactory to our agreement. I do expect to see some kind of
improvement and enthusiasm from you in the next 30 days for I do know
that you have a lot more to offer. Under careful reconsideration, your
China trip is temporarily postponed. I also want to inform you that the
Chippewa delegation which was scheduled to arrive in D.C. at the end of
June has canceled their trip.''
Did you know about this 3-month probation period?
Answer. No. Nothing was ever in writing with Johnny. I mean, we sat
down and talked about the job itself or my responsibilities, that
wasn't in writing. There was never any contracts. There certainly
wasn't any 3-month probationary period talked about. Johnny talked
about doing this work for 40 years or so. So 3 months----
Question. For you to do this work for 40 years?
Answer. He would--I don't know about me specifically, but he was
talking to me. He would talk about this is a long journey and this
messenger of peace mission that he has doesn't happen overnight, and
this is 40 years of work ahead of us, and he would just sort of talk
like that.
Question. Okay.
Answer. So I didn't----
Question. He wanted you to determine how you could assist AISI in
Washington?
Answer. Yes. Actually, I don't remember that portion of it. I think
in essence here, Johnny was irritated with me because I kept bugging
him about everything that all of his promises, and he wasn't fulfilling
any of them, i.e. the badge account, the house, anything. And I had to
really put a lot of pressure on him to get the money by June 1st. I had
to make a deposit to move in with this new lease and everything. So
this is what came after that.
Question. Did the two of you sit down and discuss what you could do
for AISI?
Answer. No.
Question. Do you know what he meant by your performance has not
been satisfactory to your agreement?
Answer. Not exactly. We never discussed it specifically.
Question. Did that come as a surprise to you?
Answer. Yes.
Question. Did you talk to him about it ever?
Answer. No. The only tangible thing that I can remember is that
there was--when I was in LA originally in April, he handed me this
stack of correspondence and other pieces of information. I don't know
if it was before or after this letter, but there was something that he
said he gave me to send in an RSVP thing for, and I think it was the
Doris Matsui Asian American something or other event going on at the
White House. I enclosed that in the documents. He was angry--he missed
it for some reason. I don't know if he had forgotten about it, if I
didn't send it in. But I have the RSVP form there. So I don't know what
happened exactly, but he was furious that he missed this meeting. I
can't remember if it was before or after this letter.
Question. And he blamed that on you?
Answer. Oh, yeah. Yeah.
Question. There was another China trip you were supposed to take?
Answer. Yes, I had forgotten about that, too. I am sure this sounds
really whimsical, but the way Johnny talks, it is like he talks about
$3 million mansions and I was also going to have a car and a driver and
a maid, and another trip to China and so it is like you don't really--
at least I didn't hold on to--another trip to China, okay, we will see
what happens. Like I wanted to quit. So I actually had completely
forgotten about that trip.
Question. It never came to be?
Answer. I think he went. I never went.
Question. Okay. Let me mark that as Exhibit GR-22.
[Ratliffe Deposition Exhibit No. GR-22 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Just so the record is clear, mentioned in that letter was
he was giving you a personal check to help you move, and that is JCO
4068. Is that correct?
Answer. Yes.
Question. And that was for $2,000.
Mr. Zacks. That was to the apartment referenced in that prior
lease. Was that marked as an exhibit?
Ms. Safavian. Yes, it was.
Mr. Zacks. This check relates to the move for the lease represented
in GR-18, right?
The Witness. Yes.
Mr. Zacks. Which served as the AISI headquarters as well as where
you were staying for that period of time.
The Witness. Yes.
EXAMINATION BY MS. SAFAVIAN:
Question. Was this $2,000 for the security deposit and first
month's rent?
Answer. Yes.
Question. Let me mark that as GR Number 23.
[Ratliffe Deposition Exhibit No. GR-23 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Let me hand you something else referenced in the letter.
This looks like it was your paycheck.
Answer. Yes.
Question. It is dated June 1, 1995, and it shows it was $1,955.60.
Answer. Sixty-four cents.
Question. I am sorry, 64 cents. What was your agreed upon salary
with Mr. Chung?
Answer. $29,000 a year.
Question. $29,000 a year.
Answer. Yes. Plus the, you know, the house and cars and maid. But
my personal paycheck was to be $29,000.
Question. Okay. Did there come a time when you did not get paid
from Mr. Chung?
Answer. I always received my payroll paycheck to my knowledge.
Question. You did always receive that?
Answer. There weren't that many. Was it June----
Question. May, June----
Answer. And then I quit in July.
Question. So you never had a problem getting your paycheck from Mr.
Chung?
Answer. No.
Question. Okay. Let me mark that as GR-24.
[Ratliffe Deposition Exhibit No. GR-24 was marked for
identification.]
The Witness. I believe he also gave me severance pay when I quit. I
don't know if that counts as that.
EXAMINATION BY MS. SAFAVIAN:
Question. We will get to that when we talk about your quitting. Let
me hand you another document that you produced this morning, a July 11,
1995, letter to Johnny Chung from you. If you will take a quick look at
that. Can you explain this letter to me briefly?
Answer. Resignation.
Question. This your resignation letter? It appears in the letter
that you have set out several complaints, if I can characterize it that
way.
Answer. Yes.
Question. Not having bought the $2.5 million mansion.
Answer. Yes.
Question. Not having opened or not having wired money into the
Crestar Bank account.
Answer. Yes.
Question. There is also something about on top of your salary, you
would be paid a $500 per month clothing allowance.
Answer. Yes.
Question. He did not pay you for that?
Answer. Actually, I did end up getting reimbursed for that.
Question. It also says----
Mr. Zacks. After this letter?
The Witness. Yeah, I think so. Yes. Yes. Some of it might have been
along the way, but there was a Chung--most of it was after the letter.
EXAMINATION BY MS. SAFAVIAN:
Question. Okay. There is a paragraph that says ``reflecting on the
unfulfilled promises, the Spielberg party, the mansion, cars, driver,
maid, rent, equipment for research project, a budget for the project,
clothing allowance, et cetera.'' These are all promises he made to you
that were not fulfilled?
Answer. The Spielberg party was the fund-raising event.
Question. Did he promise you you could go to that?
Answer. Yes. In typical Johnny talk, nothing is ever, you know,
here is a ticket, would you like to go. It is, you know, I am going to
this event. I could get you in. Would you want to go? I think he flew--
I think I was actually in LA at the time of that event, but I never
went to the event. So, yeah, it was like just one thing after the
other.
Question. Do you know who he brought to the event?
Answer. His family. His wife and daughter.
Question. Just the three of them?
Answer. Do you know what? George might have gone to that.
Question. George Liu, L-I-U?
Answer. I think someone else did go. George and his girlfriend,
Jenny. I don't know if Jenny went. All I know is I didn't go.
Question. Okay. Had you talked to Johnny Chung about resigning
prior to you giving him this letter?
Answer. I don't remember our exact flow of conversation. Ever since
I got back from China, things were not good with him. I would call him
to say, you know, where is the mansion, where is the money, where is
this sort of thing. We definitely had discussions. Certainly, if he
would be in town, we would talk. I don't--I mean, I remember a couple
of--I remember a couple of specific places we were in conversation, but
I honestly don't even remember much of the content.
Question. Let me just mark that letter as GR-25.
[Ratliffe Deposition Exhibit No. GR-25 was marked for
identification.]
Ms. Safavian. Let me hand you another letter from you to Johnny
dated----
Ms. Amerling. For the record, there is no signature on the letter
GR-25.
EXAMINATION BY MS. SAFAVIAN:
Question. I am handing you a July 17, 1995, letter that you wrote
to Johnny. If you will just take a quick look at that.
Answer. Okay.
Question. Do you recall the context of this letter?
Answer. Not much. Other than what is there.
Question. Were the two of you thinking about trying this again? In
the first paragraph, ``I am glad we had a chance to talk last week. I
appreciate and value our discussion about starting the new chapter?"
Answer. The new chapter was moving on, and I think somewhat trying
to do it somewhat amicably. Like both starting new chapters, like I
would do mine and he does his. But, no, it wasn't about me continuing
with AISI.
Question. You also wrote continuing the first paragraph, ``I am
sorry about the way our conversation went latter,'' I suppose it should
be later that evening, ``and after rethinking everything, I feel our
agreement is fair and equitable.''
Answer. Yes. He was very angry with me when I--I can't remember if
I mailed him my resignation letter or if he was in town and I gave it
to him and he read it. But either way, when he heard that I was
quitting, that I wanted the money that he owed me, he was furious, and
so I am sure that is what that was referring to, sorry about the way
our conversation went, because he was very angry.
Question. Did you have an argument with him?
Answer. Yeah. It was a very difficult conversation for me to have.
Question. Okay. Let me mark that letter as Exhibit GR-26.
[Ratliffe Deposition Exhibit No. GR-26 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Let me hand you another letter, July 18, 1995, letter
that you also wrote to Johnny.
Answer. Okay.
Question. I will just read it real quick. As we discussed
yesterday, I am faxing you our agreement in writing. I would appreciate
your sending me today 2 months' salary and the $4,000 that you said
would come from your personal account. Then it continues. What
agreement in writing are you referring to there?
Answer. I think this is it. He wanted me to send in writing what--
--
Question. Let me show you something else produced today. Could that
be the agreement?
Answer. No, this came afterwards.
Question. Let's----
Ms. Amerling. What is that?
Ms. Safavian. That is a July 20, 1995 letter. Let's stick with the
July 18th letter for a moment. You were explaining there was an
agreement?
Answer. This is it.
Question. This is it. Okay. That he was going to send you two
months salary?
Answer. It must have been in the $4,000 would be--two months salary
and 4,000. I think that $4,000 was that would be other things that he
needed to reimburse me for, clothing allowance. I don't know if the
Morton stuff was in that. It must have tallied up to about that amount.
Maybe July rent. I don't know. My guess is that it would be he owed me
reimbursement money. I am sure that is what that is.
Question. Did you seek legal representation in this matter?
Answer. Unfortunately, I didn't.
Question. You did----
Answer. Not.
Question. How did the two of you come to this agreement of 2 months
severance pay and he would reimburse you the $4,000?
Answer. That was just me.
Question. That was just you. He agreed to that?
Answer. Eventually, yes.
Question. Do you feel now that, you know, that you didn't get
everything that was owed to you from Johnny Chung?
Answer. There is a whole chapter. I mean, Johnny was a pain. I was
then in--I mean, if you are asking what I really wanted out of the
agreement, like this was a negotiation. What I really would have wanted
was the entire year's lease paid for. It was basically because of him
that I had to enter into this leasing agreement. It was $1,000 for rent
is not the amount of rent that I would normally pay for, if I had a
normal job. It was a one-bedroom apartment, so I had to end up getting
roommates and basically cleaning up a mess that he had created in my
life. To be done with things, I was fine about this, about what the
negotiation we came to was.
Question. Let me mark that as GR-27.
[Ratliffe Deposition Exhibit No. GR-27 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Do you still have the July 20th letter that I handed you?
It is right here. Let's take a look at that right now. It is a letter
from Johnny to you dated July 20th. Also attached to it is a release
agreement, it looks like. Can you tell me a little bit about this?
Answer. I never signed it.
Question. The release you mean?
Answer. Anything. This came to me, and I looked at it, and I just
never signed it. I was just going on with my life.
Question. What did he want you to release him from?
Answer. I think, I haven't read this, I thought it was basically
something about how I am not going to ask him for any more money.
Johnny was very sensitive about his money, and actually almost
paranoid, in my opinion, about people trying to use him for his money.
Imagine that. And he was very disturbed with my behavior and thinking
that I was trying to--something about swindle money out of him or
something along those lines, when he actually owed me like $4,000 or
so. I haven't read this recently, but that is sort of what I remember.
Question. The agreement says ``release, acquit and forever
discharge Automated Intelligence Systems, Incorporated, and Johnny
Chung.'' There is a whole paragraph on it. You didn't sign this
agreement though?
Answer. No.
Question. And he didn't come back later?
Answer. I never heard from him.
Question. You never heard from him again once you got the checks?
Answer. I ran into him once. That has been my only contact with
him.
Question. When was that?
Answer. At the Democratic Convention in Chicago, like a year later.
Question. How did that go?
Answer. It was weird. But he was just walking down the hall. I said
hello, Mr. Chung. He was fine. He showed me another picture of another
kid he has, and it was a fairly brief conversation. He asked me what I
was doing, and I said fund-raising, and he laughed and that was it.
Question. Let me make this July 20th letter with the release
attached GR-28.
[Ratliffe Deposition Exhibit No. GR-28 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Can you tell me briefly, you mentioned earlier you met
Irene Wu out in California. What did she do for Johnny Chung?
Answer. She seemed sort of like a secretary, assistant, right-hand
person. I don't know what she did for him business-wise, because I
wasn't really involved in any of that. She did like the dinner
reservations there and worked for the travel agencies in getting all
the plane tickets. I think she worked a lot with the schedules over
there.
Question. What do you mean by over there?
Answer. In China, in setting up that sort of thing. And I believe
Irene had come to Washington on some occasion and like was the, you
know, his assistant to help out with the chaperoning and that I--that
way, I think.
Question. You mentioned earlier an Art L-I-A-N-G.
Answer. Yes.
Question. What did he do for Johnny Chung?
Answer. I forget what his title was. Some sort of chief of staff. I
think Art actually had a real job with the business part, sales of some
sort. But Art really liked all the prestige of the political arena, so
I think Johnny would kind of like throw these carrots at him or let him
go on trips or whatever.
Question. Have you heard of a Steven L-I-N?
Answer. That doesn't sound familiar.
Question. How about a----
Answer. Wait. The little chief engineer that runs the fax machine,
like, is behind this bulletproof glass like windowless room. If that is
him, I met some little engineer.
Ms. Amerling. You are not certain that is him?
The Witness. I can't remember his name.
EXAMINATION BY MS. SAFAVIAN:
Question. Does a N-A-C-H-I Lee or Nancy Lee mean anything to you?
Answer. Nancy is the accountant, I think.
Question. Where is she located at?
Answer. In LA.
Question. Did you meet her?
Answer. Yes. I think I met her. She works nights, works like all
night. She sends me my--the only reason why I had to contact her, like
a year later was to get the information I needed for taxes.
Question. So she was his accountant?
Answer. To my knowledge.
Question. How about a Steven H-U-A-N-G?
Answer. Wait, that might--I don't remember the name of the
engineer, if that was him or not. There might have been two of them
actually.
Question. Okay. How about a Michael Lynn SHIH, C-H-I-E-F?
Answer. Shoot, they all sound familiar. I keep thinking about this
one engineer guy. Somebody took me computer shopping and new a lot
about computers, and we were supposed to buy a computer for the D.C.
office, and was showing me all about different laptops and everything.
I don't remember who it was.
Question. Okay. Just a few other names. Ever heard of Peter C-H-A-
N-G?
Answer. It sounds familiar, but----
Question. How about Great Wall International Culture Company?
Answer. No.
Question. How about a Susan Chang?
Answer. No.
Question. Also known as S-H-U-C-H-E-N, Chang?
Answer. No.
Question. George H-A-R-A?
Answer. I don't know which George I knew, the fat, chubby guy that
tooled around.
Question. How about Ernest Lee?
Answer. That doesn't sound familiar.
Question. Larry L-I-O-U?
Answer. I never new any Larry.
Question. Okay. How about a S-H-I-H, H-U-N-G, Young?
Answer. No.
Question. Any knowledge of and West Environmental Group?
Answer. No.
Question. Professor Q-G-G-E-P-I-N-G.
Answer. No.
Question. George Tan?
Answer. It sounds familiar. I don't know.
Question. And the last name, H-U-I-Y-U-A-N, the last name, Y-A-O?
Answer. That doesn't sound familiar. But you are missing one, Tina.
Question. Tina who?
Answer. I don't know her name.
Question. Was she an employee?
Answer. Yes, to my knowledge.
Question. Do you know what she did for him?
Answer. The same sort of stuff as Irene, sort of PR secretary,
whatever. Tina actually--Tina told me some stuff at the end now that I
just remember. When I was thinking of quitting, and like at that point
obviously I didn't know who I could trust anymore, and wasn't really
saying much to people. But I forget where Johnny met Tina. I don't know
if he brought her over from China or what.
Tina had some sort of bad situation with a husband and Johnny sort
of bailed her out from that. I don't know if he was like--I don't know.
Johnny told me all this once about Tina. Then when I was in China, I
had this translator that helped me out a lot, that Johnny said he was
going to hire her as his translator. Any time he came to China, she was
going to have a job translating for whoever needed it. She was excited.
She traveled a long ways to come to Beijing away from her family to
translate for me. I think Tina knew her somehow. It was like a sister
of a friend of her's from going to school in China.
Tina told me in the end Johnny was like scamming this girl, said
that he didn't hire her. She didn't take some other opportunity that
she was going to. I don't know, it was something along these lines.
This was like just confirming all of my wanting to get out of working
for him.
But that was Tina.
Question. Okay. Did I forget any other AISI employee that you can
recall?
Answer. [Negative nod.]
Question. Is that a no?
Answer. No.
Ms. Safavian. Okay. I am almost done. If you can believe that. Let
me just cover a few other brief things with you.
EXAMINATION BY MS. SAFAVIAN:
Question. Do you know who Harry Wu is?
Answer. Oh, the guy that was detained.
Question. Over in China?
Answer. Yes.
Question. Do you know about Johnny Chung's efforts to help Harry
Wu?
Answer. Not specifically, but it doesn't surprise me. Johnny told
me something about someone we had dinner with in China, and it kind of
freaked me out. I don't know if it was--I don't know if he said we had
dinner with one of the guys that was involved with ordering the tanks
at Tiananmen or one of the guys that was in charge of detaining Harry
Wu or something like that, but I didn't know Johnny was trying to--I
don't remember him working on the Harry Wu thing.
Question. This was when you were in China in April?
Answer. Yes.
Question. Let me hand you this document. It is dated 7-25-95. I
know that you may have--I don't know if you had completely ceased
working with Johnny at that time?
Answer. Yes.
Question. But this is an AISI fax cover page that he--it looks like
Irene sent to Betty Currie in the White House. Johnny Chung was asking
for President Clinton to write him a credential letter for his trip to
China.
You can just flip through the pages. It starts with EOP 005053 and
goes through to 57. As you can see, 55 is a letter from Bill Clinton
dated October 3, 1994, which is the one Johnny is referencing in this
fax cover page. This is one for Taiwan. He wanted one for China. The
last page, 57, is one from Don Fowler discussing Johnny Chung's efforts
to build a bridge between the people of China and the United States.
Do you have any knowledge of his efforts to get these credential
letters?
Answer. No, I didn't. I wasn't working with him then.
Question. He didn't previously before you left him mention how he
wanted to help free Harry Wu?
Answer. He might have talked about Harry Wu, because it was in the
news a lot. I remember him telling me that I had to like keep up on
current events and that sort of thing. Johnny was always trying to get
Don Fowler, the First Lady, or anyone over there, I mean, it was this
whole bridging thing. But I don't remember specifically. I mean, Johnny
never said to me, I want you to write a letter requesting help for
Harry Wu, not that I remember.
Question. Okay. Let me mark this group of documents as GR-29,
Exhibit GR-29.
[Ratliffe Deposition Exhibit No. GR-29 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. So after you stopped working for Johnny Chung, you were
back as a volunteer in the White House?
Answer. Yes.
Question. You had done that on and off while working for Johnny
Chung?
Answer. Yes.
Question. Was that then your full-time--what kept you occupied
First Lady time?
Answer. I worked there the month of August, and then I started a
new job in September, Campus Green Vote.
Question. Okay. And then how much time did you put in as a
volunteer in the White House?
Answer. Hardly any then.
Question. Hardly any.
Answer. I worked at Campus Green Vote from September until I think
it was like December 4th. Part of that time I was in Seattle working on
an environmental referendum. Then I left for Boston December 4th. So I
was pretty much tied up with Campus Green Vote stuff.
Question. Okay. Did you ever see Johnny Chung in the First Lady's
office after you quit working for him when you were a volunteer?
Answer. Oh, you mean did he come----
Question. Did you ever see him visiting the First Lady's office?
Answer. He might have come back. I don't know if--I don't know if I
was in the office then when he did. I remember it being kind of like
touchy, either knowing he was going to come, I don't know if they had
me run some errand or something. I can't remember exactly.
Question. Okay. Do you recall Johnny sending Evan Ryan and Maggie
Williams flowers?
Answer. Yeah. Vaguely, now that you bring it up.
Question. Let me hand you two documents. These are telephone
message slips again.
Answer. Uh-huh.
Question. And I think I may have them in reverse order. If you will
take a look at EOP 509073 and 4, the message slip is to Evan. It is
dated either 9-27 or 29. It is hard to tell if it is a 9, a message
from Johnny Chung. It says he is sending two baskets of flowers; one
for Maggie, one for you.
Answer. Um-hmm.
Question. Then the next document I hand you is EOP 059058 through
59. It is another message slip to Evan dated 10-20-95. He called again,
and on the message slip says sending flowers to you and Maggie.
Do you recall them receiving these two sets of flowers from Johnny
Chung?
Answer. I don't see how I would have. I think by that time I was
working at Campus Green Vote. He must have brought them flowers
sometime when I was working for him or something.
Question. You are thinking of previous times?
Answer. Certainly not the October 1, I wouldn't have known anything
about. And I am quite sure I started Campus Green Vote by that time in
September. So I wouldn't have been there for that. The only thing I
heard about I thought after like I left the White House was that Johnny
came for a visit once and for somehow or some reason had to be removed
by, I don't know if it was Secret Service, security or something. Like
he showed up and he called, I think he wanted to meet with Maggie and
Evan said she was busy. She didn't have any time available, and I don't
know if he got cleared in from someone else or something, but he just
showed up.
Evan was angry, because she was out doing, I don't know, something,
and came back and Johnny was like there in the office, and they had to
ask him to leave. Something along those lines. Like he was not welcome.
Question. Did Evan have to call the security or the police?
Answer. I don't know what the specifics were. She wasn't the one
that told me. There was this old lady volunteer that I kept up. She
would tell me stuff like that.
Question. You weren't present that day?
Answer. No, no.
Question. Do you recall when that was?
Answer. It was after I left. I think in the fall maybe.
Question. Of '95?
Answer. I don't know exactly when it was.
Question. Did you ever ask Evan about that incident?
Answer. I might have. Something very casually, like, oh, I heard
Johnny got kicked out of the office or something. Like I don't, we
didn't sit down and have a serious talk about it that I remember.
Question. Did either Evan, Ryan or Maggie Williams ever mention to
you that Johnny sent us flowers?
Answer. I don't remember that. We didn't really talk about that
kind of stuff.
Question. Let me just mark those telephone message slips we were
discussing as Exhibit GR-30.
[Ratliffe Deposition Exhibit No. GR-30 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Just briefly going back to the Chinese delegation that
was in the White House, in the First Lady's office in March of '95,
were you--do you have any knowledge whether or not Evan, Ryan or Maggie
Williams solicited a contribution from Johnny Chung?
Answer. No.
Question. Are you aware that Johnny Chung handed Maggie Williams a
check to the DNC in the amount of $50,000?
Answer. I think the only reason I know about that was because I
read about it in the papers, but I don't remember that.
Question. You had no prior knowledge of it before the newspaper
articles?
Answer. No.
Question. No one ever talked about it in the First Lady's office?
Answer. No. I mean, there was talk about Johnny and his money and
Johnny contributing, definitely, but it was more Johnny the fund-raiser
kind of context.
Ms. Safavian. I believe that is all I have at the moment. Minority
counsel will ask you some questions. I want to make sure I didn't miss
anything.
EXAMINATION BY MS. AMERLING:
Question. I want to start by thanking you for taking the time to
talk with us today. You testified, I believe, that Johnny Chung wasn't
fulfilling promises he had made to you.
Answer. Yes.
Question. Is that correct?
Answer. Yes.
Question. I would like to talk about his failure to fulfill
promises to you a little bit more.
Answer. Okay.
Question. Now, I believe that you testified that while he paid you
a salary, he did not fulfill other promises relating to reimbursing
you. Is that correct?
Answer. He reimbursed me eventually.
Question. But there was a time when you were concerned because he
did not fulfill his promises to reimburse you?
Answer. Yes. Yes.
Question. I want to turn to the July 11, 1995, letter that we have
marked as Exhibit GR-25.
Answer. Okay.
Question. I want to turn to page 2. In the fourth paragraph up from
the bottom of the document, it begins reflecting on unfulfilled
promises.
Answer. Yes.
Question. Are you following me?
Answer. Yes.
Question. The letter mentions clothing allowance.
Answer. Yes.
Question. Did Mr. Chung make representations to you that he would
provide some sort of clothing allowance to you?
Answer. He said that I would be given $500 a month for a clothing
allowance.
Question. At the time of this letter, you believed he was not
fulfilling that representation; is that accurate?
Answer. I believe so. To the best of my memory, he had not
reimbursed me for probably June and July. I know I had bought some
clothes. Now I remember, because I thought I was going on this second
China trip, so I was preparing for that, and so I needed reimbursements
that I hadn't received.
Question. You hadn't received them in accordance with the schedule
he had represented he would pay you on?
Answer. Yes. Well, he never--again, he was never specific in that
way. It wasn't ever--that is why we were supposed to have this checking
account, to my knowledge, so that for these allocations that he made, I
would then go and withdraw it from there. Does that answer it?
Mr. Zacks. Counsel, can I have one moment.
[Discussion off the record.]
EXAMINATION BY MS. AMERLING:
Question. Back on the record. This letter also references unpaid
rent. Mr. Chung at this point, the point of the July 11 letter, also
had not fulfilled his promise to you regarding rent?
Answer. Yes.
Question. This letter also references a restaurant bill. Mr. Chung
at this point also had not fulfilled his promises to you regarding
that?
Answer. Correct.
Question. Now, I believe you also testified that when you came back
from your China trip, you found that the D.C. office didn't exist. Is
that correct?
Answer. Yes.
Question. Is it fair to say he had made representations to you
about the terms of your employment that he did not meet?
Answer. As of what we have just discussed?
Question. Yes.
Answer. Definitely.
Question. Would you say that Mr. Chung misrepresented the truth to
you?
Answer. Yes.
Question. You also, I believe, testified that Mr. Chung always had
a lot of hoopla going on that you had to sort through. When you said
that, were you meaning, when you said ``sort through,'' were you
meaning you had to sort through what was the truth and what wasn't the
truth? Is that accurate?
Answer. Yeah. Again, at the time I was fairly trusting and wasn't
naturally that skeptical of him. What I really meant by ``sort
through'' was who knows what Johnny was talking about, mansions, cars,
flowers, dinners, trips. It is like okay, what are we doing today? What
is happening here?
It wasn't until pretty much that I wrote this letter, when it was
like, okay, this guy is not fulfilling anything that he says. So it was
like I just didn't believe him anymore at all.
Mr. Zacks. Can I ask a point of clarification?
Ms. Amerling. Yes.
Mr. Zacks. Would it be fair to say that you consider Mr. Chung on
reflection and in hindsight a dishonest individual? It is a yes-or-no
question.
The Witness. Yes.
Mr. Zacks. Would it be fair to say you felt he took advantage of
you and your naivete at that point in your life?
The Witness. Yes.
Mr. Zacks. Would it be fair to say that by and large, nearly
everything he promised you did not come to fruition with regard to your
employment?
The Witness. Absolutely.
Mr. Zacks. Would it be fair to say that he appeared to you to be--
how can I say this--a great exaggerator of the truth?
The Witness. Yes.
Mr. Zacks. Or lack of the truth with individuals?
The Witness. Yes.
Mr. Zacks. And would it be fair to say as far as you could tell, he
tried to use everyone round him for his own purposes?
The Witness. Yes.
Mr. Zacks. Okay. Thanks. I just wanted to be clear on that.
EXAMINATION BY MS. AMERLING:
Question. A few more questions. You had testified that when you
were in China, I believe you testified, correct me if I am wrong, Mr.
Chung was looking for office space, and you had suggested that
particular office that had Chinese military outside would not be the
best spot and that he agreed. Is that accurate?
Answer. Yes.
Question. And the next day, despite the conversation you had had
with him, you heard him telling other people or another person that he
was interested in that very office space. Is that accurate?
Answer. The people that owned the office space.
Question. Do you believe he was not telling the truth to that
person?
Answer. Yes, that is what I confronted him with. That was very
uncomfortable, working with somebody that operated like that.
Question. So based on your experience with Mr. Chung, would you say
that you would not rely on his word?
Answer. I couldn't.
Question. Based on your experiences with Mr. Chung, would you say
his word is not credible?
Answer. Yes.
Ms. Amerling. I don't have any further questions.
EXAMINATION BY MS. SAFAVIAN:
Question. Just a couple follow-ups from the documents. Let me just
show you, this is something else that you produced today, it looks like
a calendar. If you could tell me what that is, please?
Answer. This was a handwritten schedule for the China trip that I
didn't have involvement with, other than showing up at things. I don't
even know how closely this was followed. I think this was made up sort
of towards the beginning of the trip, and I wasn't involved with this
schedule.
Question. Does looking at that and some of the names that are
listed help refresh your recollection as to some of the people that you
met that you mentioned earlier, and you just couldn't think of their
names?
Answer. I remember meeting Vice Premier Lee. The China
Petrochemical Corporation. The office space. Oh, Charlie Parish. I
forgot about him.
Question. Charlie Parish?
Answer. Yes.
Question. Who is he?
Answer. He worked at the American Embassy, and Johnny bugged him,
too. I saw Charlie there, and he came to D.C., and we had dinner with
him in D.C., too.
Question. Do you know what he bugged him about when he was over in
China?
Answer. Charlie tried to be nice about it, but he said Johnny
called him and was trying to get in or whatever, and Charlie was trying
to do other things or get rid of him, and ended up, like everyone,
letting Johnny in and, I don't know if Johnny was working with him on
visas or something. I don't know.
Question. Let me just mark that--do you recognize anything else?
Does that help you with anybody else?
Answer. Not really.
Question. Okay. Let me just mark that as Exhibit GR-31.
[Ratliffe Deposition Exhibit No. GR-31 was marked for
identification.]
Mr. Zacks. Earlier when you had referenced a $50,000 payment by Mr.
Chung to DNC, what was the date of that check or the date it was
tendered?
Ms. Safavian. I can put into the record an L.A. Times article dated
July 27, 1997, that sets forth Johnny Chung's version of the delegation
and the First Lady's office, and the White House tour, the mess and the
photo with the First Lady and the $50,000 check that he handed to
Maggie Williams.
Mr. Zacks. Okay.
Ms. Safavian. Would you like me to make that an exhibit?
Mr. Zacks. Not necessarily. I am happy to just review it.
EXAMINATION BY MS. SAFAVIAN:
Question. Let me just show you another thing real quick. This is
something else you produced. It looks like pages of copies of business
cards and a printout of names and addresses. Let me hand that to you.
Can you explain to me what that is?
Answer. It was something Johnny gave to me with the rest of his
correspondence. He kept his business cards in this plastic-covered
thing, and he just made Xeroxed copies of it. I think it was most of
his like D.C. or political contacts, I mean that he considered his
contacts.
Question. Was this like for you to keep and if you needed to
contact these people? Why do you have possession of this?
Answer. It wasn't really discussed. I think it must have been in
the stack he gave me of all of this correspondence from before I
started working for him until after.
Question. So you did not put that together for him?
Answer. No. He has this.
Question. That was already done?
Answer. Yes.
Question. Okay. Let me make that Exhibit GR-32.
[Ratliffe Deposition Exhibit No. GR-32 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Then, lastly, also in the documents you brought with you
today, there are a couple of letters. I am just going to kind of group
them together. There is an October 3, 1994, letter from Bill Clinton to
Johnny Chung, an October 13, 1994, letter to Johnny Chung from Al Gore,
a March 14, 1995, letter to the Honorable Zheng Hongye, the Chairman of
the China Chamber of International Commerce, from Don Fowler.
Let me hand these three letters to you. I am just interested in why
you have possession of those three letters, since they were before the
date of your employment with Johnny Chung?
Answer. When I went to LA, Johnny just handed me this stack of
papers, literally in a stack, of political correspondence that he had,
that was either DNC-related or whatever, and I kept it in this stack of
stuff.
Question. Did he ever tell you what he wanted you to do with it?
Answer. No. It was just like, here.
Question. Did you ever do anything with it?
Answer. No.
Ms. Safavian. Okay. Let me just group those three letters together
and make those Exhibit GR-33.
[Ratliffe Deposition Exhibit No. GR-33 was marked for
identification.]
Ms. Safavian.
Question. Let me show you what I just came across. You were
mentioning earlier you thought in the brochures he was handing out in
China there was a group of letters. I just handed you a group of
letters that you produced this morning. Could you tell me, is that what
you were referencing earlier?
Answer. Yes.
Question. And this grouping is what he would--you tell me. What did
he do with these letters?
Answer. I don't know about this particular packet. I wasn't
involved with this. The packets I know about are the color-copied ones
that--I didn't have anything to do with them actually except make sure
I had enough to hand out to people when we were in China for that day's
meetings. So as far as putting them together or anything like that----
Mr. Zacks. The question was earlier you indicated that during the
China trip you recalled a packet also being disseminated, either in
conjunction with those or independently, that were braggadocio letters
from Al Gore, the President, other dignitaries, to impress officials.
The question was, do you recognize these letters as those documents you
earlier referred to?
The Witness. I don't remember packets in China being handed out
that were--that letters were included with. I only in my--in the last
48 hours in preparing these materials for today, saw this packet and
flipped through it and realized that he included letters.
To the best of my ability, I think, AISI and whatever else this
says, it is a company profile sort of thing that he would have handed
out to people, but I didn't----
Mr. Zacks. You don't have personal knowledge that he did?
The Witness. Correct.
EXAMINATION BY MS. SAFAVIAN:
Question. I thought you said earlier that you do recall there was
some package like that when you were in China.
Answer. No.
Question. That is not the case.
Answer. No.
Ms. Safavian. Since we referenced that, let me mark that GR-34.
[Ratliffe Deposition Exhibit No. GR-34 was marked for
identification.]
Ms. Safavian. I think I am done. That is all that I have. Do you
have anything further?
Ms. Amerling. I don't have any further questions.
Ms. Safavian. Thank you very much.
Mr. Zacks. I would only state on the record then that A, I would
make a formal request for a copy of the transcript, if you would be so
kind to forward it to my office, as opposed to us going to Washington
to review it.
Ms. Safavian. Like I mentioned earlier, we can send you a
confidentiality letter which you both have to sign and then we can send
out the transcript for you to review.
Mr. Zacks. Secondly, and then just to confirm, we are going to give
you certain brochures and cards and the like, that are originals, and
you have agreed that you will copy those and send them back to my
office.
Ms. Safavian. That is correct. What I was planning on taking are
the two AISI color brochures, a stack of business cards, and I can
count these up real quick.
My quick count, I believe there are 69 business cards, that I was
also planning on taking with me. Additionally, there were some of the
brochures that you brought back from China that we had already
mentioned on the record that I was also going to take back with me.
That was it.
Mr. Zacks. Okay. Then just for a final point of clarification,
earlier in the preamble or the instruction portion of your questioning,
and I just want to be clear, is the area of my client not discussing
her testimony here today, is that an informal request by Congress, or
does that request carry the rule of law much like 6(e) does with a
grand jury in Federal court? Is she by law prohibited and/or myself
from discussing her testimony here today?
Ms. Safavian. This deposition was taken in executive session, which
means that it is not discussed publicly with anyone outside of the
committee and/or Members of Congress.
Mr. Zacks. Is that a matter of protocol or law? That is my
question.
Ms. Safavian. That is under the committee rules. With regard to you
and your client, I was going to say I don't----
Ms. Amerling. It is my understanding that is a request the Majority
makes.
Ms. Safavian. I believe it is voluntary on your point. My only
point is we do not release this deposition unless the committee votes
to release it. It stays under executive session.
Ms. Amerling. ``We'' meaning the committee.
Ms. Safavian. Is that your understanding of it? Sam.
Ms. Amerling. That is my understanding of how your request, of what
your request means.
Mr. Zacks. Okay. I am clear. Thank you.
Ms. Safavian. Okay. That is all. Thank you.
[Whereupon, at 4:45 p.m., the deposition was concluded.]
[The exhibits referred to follow:]
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Mr. Burton. Would the witnesses please take their seats.
The other members of the committee are on their way back, at
least some of them are. And we will start with Mr. Bennett
doing his half hour of questioning. But first I would like to
introduce our guests; Nancy Hernreich--is that correct?
Ms. Hernreich. Hernreich.
Mr. Burton. Deputy Assistant to the President for
Appointments and Scheduling; Kelly Crawford, former staff
assistant to Ms. Hernreich. And Carol----
Ms. Khare. Khare.
Mr. Burton. Carol Khare, former assistant to Don Fowler at
the DNC; and Ceandra Scott----
Ms. Scott. Ceandra.
Mr. Burton. Ceandra, former staff member at the Democratic
National Committee. Would you rise so I can swear you in?
[Witnesses sworn.]
Mr. Burton. Be seated.
We will start off with Mr. Bennett questioning for 30
minutes and then we will go to the minority.
STATEMENTS OF NANCY HERNREICH, DEPUTY ASSISTANT TO THE
PRESIDENT FOR APPOINTMENTS AND SCHEDULING, ACCOMPANIED BY BOB
CEARLY; KELLY CRAWFORD, FORMER STAFF ASSISTANT TO MS. HERNRICH,
ACCOMPANIED BY DAVID WILSON; CAROL KHARE, FORMER ASSISTANT TO
THE CHAIRMAN, DEMOCRATIC NATIONAL COMMITTEE, ACCOMPANIED BY
EVAN WERBEL
Mr. Bennett. Thank you, Mr. Chairman. In light of some of
the time constraints this afternoon, and allowing appropriate
time for Members----
Mr. Burton. Pardon me. Do any of you have opening
statements you would like to read into the record, or do you
want to go ahead and start? Mr. Bennett.
Mr. Bennett. I will try not to take the full 30 minutes.
Just for the record, in terms of--you are represented by
very able counsel here today. Ms. Khare you are represented by,
I believe, Mr. Neil Eggleston; is that correct?
Ms. Khare. Evan Werbel is with me here right now.
Mr. Bennett. You work with Mr. Eggleston's office? Nice to
have you, sir. And, Ms. Scott, you are represented by Mr. Judd
Best, Judah Best; is that correct?
Ms. Scott. That's correct.
Mr. Bennett. And, Ms. Hernreich, you are represented by Bob
Cearly who is in from Arkansas; is that correct?
Ms. Hernreich. That's correct.
Mr. Bennett. Mr. Cearly, it is nice to see you.
And finally, Ms. Crawford, you are represented by David
Wilson. Mr. Wilson, it is nice to see all four of you. If at
any time there are questions that you want to refer to your
counsel, don't hesitate to seek their advice.
Ms. Khare, you worked in some capacity with Mr. Fowler, Don
Fowler, the former Democratic National Committee chairman for,
I guess, the last 20 years; is that correct?
Ms. Khare. That's right.
Mr. Bennett. And are you still employed with Mr. Fowler?
Ms. Khare. Yes, I am.
Mr. Bennett. You joined his staff at the DNC when he was
chairman of DNC in January 1995?
Ms. Khare. That's right.
Mr. Bennett. And worked there with him until January of
this year?
Ms. Khare. Yes.
Mr. Bennett. And, Ms. Scott, you formerly worked with the
Democratic National Committee; is that correct?
Ms. Scott. That's correct.
Mr. Bennett. If you would just try to swing that mic, I
apologize we only have three microphones for four people.
What is your present employment, Ms. Scott?
Ms. Scott. I am temporarily working for the Democratic
Congressional Campaign Committee.
Mr. Bennett. Ms. Hernreich, you currently work as the
Deputy Assistant to President Clinton?
Ms. Hernreich. That's correct. And let me correct my title.
The chairman indicated that it was for appointments and
scheduling and that was my original title, but my title now is
Deputy Assistant to the President and Director of Oval Office
Operations.
Mr. Bennett. And how long have you worked in the White
House?
Ms. Hernreich. I have been there since January 20, 1993.
Mr. Bennett. The entire term of the Clinton administration.
Ms. Hernreich. Yes.
Mr. Bennett. And, Ms. Crawford, you formerly were an
assistant to Mrs. Hernreich; is that correct?
Ms. Crawford. That is correct.
Mr. Bennett. And you now work at the Department of
Treasury?
Ms. Crawford. That is correct.
Mr. Bennett. Ms. Khare, in your deposition before this
committee, you testified that your first contact with Johnny
Chung was in March 1995.
Ms. Khare. That's right.
Mr. Bennett. Did you have any contact with him prior to
that time? Had you ever heard his name before?
Ms. Khare. Not that I recall.
Mr. Bennett. Exactly what was the nature of your first
contact with Mr. Johnny Chung in March 1995?
Ms. Khare. He telephoned the chairman's office at the DNC.
I was given the call. I don't remember that he asked for me
specifically but I was given the call. He identified himself as
Johnny Chung. He said, I'm a friend of the First Lady's.
Mr. Bennett. Where was he calling from at that time?
Ms. Khare. He was calling from the First Lady's office.
Mr. Bennett. From Mrs. Clinton's office?
Ms. Khare. He said the First Lady's office. Now, I did not
take that to mean he was in her office. He was somewhere in her
complex of offices.
Mr. Bennett. But he did indicate he was calling from Mrs.
Clinton's office?
Ms. Khare. Yes, he did.
Mr. Bennett. Exactly what was the nature of the
conversation you had with him at that time?
Ms. Khare. He told me he was over there, he was a friend of
the First Lady. He said, I have some important Chinese
businesspeople with me. We would like to go to the radio
address on--I believe that it was going to be on Saturday,
sometimes they do that on Friday. And he said, Maggie Williams
said that she cannot get us into the radio address, but that
maybe the chairman's office could do that.
Mr. Bennett. So according to his telephone call, he
indicated that Ms. Williams, from whom we heard earlier today,
had suggested that you call Mr. Fowler?
Ms. Khare. He said that she had told him that perhaps the
chairman's office could get him in. And I don't believe that he
asked for Mr. Fowler when he called.
Mr. Bennett. Did you ever put him in touch with Mr. Fowler?
Ms. Khare. No, I did not.
Mr. Bennett. What step--did you talk to Ms. Williams at
this time?
Ms. Khare. No, I did not.
Mr. Bennett. What steps did you take, Ms. Khare, with
respect to his desire to get into President Clinton's radio
address that Saturday? This was, I think, Thursday, March 9 or
Friday, March 10.
Ms. Khare. I'm sorry; I don't know which day it was prior
to the radio address.
Mr. Bennett. What steps did you take to get Mr. Chung and
his friends into the radio address?
Ms. Khare. I told him that I did not know whether the
chairman's office could get people into the radio address or
not. You understand, I had only been there a few weeks; this
was the first that I knew that people could go to the radio
address. I did not know that anybody could go to the radio
address. And so----
Mr. Bennett. I'm not sure that just anybody can go to the
radio address.
Ms. Khare. Well, I didn't know that anybody was in the room
other than the President when they did the radio address. So I
told him that I would find out what we could do, and I would
call him back. And he gave me the telephone number where he
was, and I went away to--walked out into the reception area of
the office where several people were, all of whom had been at
the DNC longer than I was and knew a lot more than I did about
this kind of thing. And I asked if anybody there knew whether
or how we could get somebody into the radio address.
Mr. Bennett. At that point in time, did he indicate to you
the names of the individuals he was seeking to get into the
radio address?
Ms. Khare. I don't recall that he did. He said that he had
Chinese businesspeople with him. I'm sure that at some point we
had to get the names, but I don't remember that I took those
names down then.
Mr. Bennett. Did Evan Ryan, who--I believe her deposition
transcript indicated that she procured passport numbers for
these individuals. Did you talk to Mrs. Ryan in First Lady
Hillary Clinton's office at that time?
Ms. Khare. Didn't talk to anyone in the First Lady's
office. When I called Mr. Chung back to say that we had
arranged for him to go to the radio address, I just called and
whoever answered the telephone said Office of the First Lady,
and I asked to speak with him. I did not ask for anyone.
Mr. Bennett. Did you have any interaction with Evan Ryan
with respect to the passport numbers of these six individuals?
Ms. Khare. No, I did not. If I did, I don't recall that.
Mr. Bennett. Exactly what did you do to arrange for Mr.
Chung and his friends to get into the Oval Office to be part of
the radio address?
Ms. Khare. When I went into our outer office and asked if
anyone knew how you made arrangements like that, Ms. Scott, as
I recall, indicated to me that she knew someone at the White
House she could call about that. And I asked her to do that and
went back into my office.
Mr. Bennett. Ms. Scott, did you in fact make the telephone
call to the White House?
Ms. Scott. Yes, I did.
Mr. Bennett. Whom did you call with respect to getting
Johnny Chung and the delegation of Chinese representatives into
the Oval Office, into the radio address?
Ms. Scott. I'm not sure, but I believe I called the First
Lady's office.
Mr. Bennett. And whom did you speak with or who do you talk
with in the First Lady's office?
Ms. Scott. I don't remember exactly who it was. I do think
I asked for Maggie Williams. I'm not sure that I spoke with
her.
Mr. Bennett. And if you didn't speak with Maggie Williams,
who might you have spoken with?
Ms. Scott. It was a woman. I just don't remember who.
Mr. Bennett. Was Ms. Williams basically your contact in the
First Lady's office?
Ms. Scott. She was not the only contact, no.
Mr. Bennett. Ms. Williams was a personal friend of yours at
the time?
Ms. Scott. I wouldn't call her a personal friend. We met
during the campaign. She has been helpful.
Mr. Bennett. When was that call made--in fact that was made
Friday afternoon, March 10th, wasn't it Ms. Scott?
Ms. Scott. I don't recall the specific date, but it was an
evening and Friday; correct.
Mr. Bennett. And was there any particular reason why you
called the First Lady's office as opposed to the Visitor's
Office of the White House?
Ms. Scott. For direction.
Mr. Bennett. But in terms of arranging this, just basically
your contact was with the staff of the First Lady's office; is
that the main reason you called the First Lady's office?
Ms. Scott. I'm sorry; repeat your question.
Mr. Bennett. I'm sorry. My question basically is why would
you not have called the Visitor's Office of the White House or
staff of the President? What was your reason for calling the
First Lady's office with respect to Mr. Chung's request?
Ms. Scott. It was late that evening, Friday; I remember it
was late, and I knew I could get good direction from the First
Lady's office. That's it.
Mr. Bennett. Let me ask you this. It was late Friday
evening, March 10th, and this was for the Saturday morning
March 11th radio address; correct?
Ms. Scott. Yes.
Mr. Bennett. It was somewhat of a rushed process, wasn't
it, in terms of trying to check out who these people were and
check out passport numbers and exactly who was being taken into
the Oval Office of the White House?
Ms. Scott. What was your question?
Mr. Bennett. Wasn't this somewhat of a rushed scenario
here? It was late Friday afternoon, March 10th, and someone was
trying to take individuals right into the Oval Office to be
with the President the following morning, that Saturday
morning, March 11th. It was a rush to get this done, wasn't it?
Ms. Scott. It didn't seem to be real rush to me.
Mr. Bennett. Have you routinely--and I'll ask this of you,
Ms. Khare, or Mrs. Crawford, or Ms. Hernreich, for that
matter--have you all routinely ever had a request on a Friday
night, late, with respect to trying to get people into the
radio address the following Saturday morning? Ms. Scott, had
you dealt with a situation like that before?
Ms. Scott. The only other time that I dealt with the radio
address was for my godparents. And I think I called--I'm not
sure exactly when I called. I think it might have been the week
of.
Mr. Bennett. Let me ask you, Ms. Khare, have you had a
similar situation when you were at the DNC, when there was
calls on Friday night trying to get somebody into the radio
address the following Saturday morning?
Ms. Khare. No, I don't remember any other circumstance like
this, although I don't remember this to be night. I remember
this being in the daytime.
Mr. Bennett. I'm sorry. Ms. Crawford, or Ms. Hernreich, do
either of you recall a situation where the afternoon before, or
let's say into the evening before the President makes his radio
address at the White House, that there has been an effort at
the last minute to allow people to go into the Oval Office
itself at the time the President is making the radio address?
Ms. Crawford, as to you, do you recall such a scenario?
Ms. Crawford. On Friday afternoons, yes, that would not
have been unusual.
Mr. Bennett. Have you personally handled such efforts at
the last minute?
Ms. Crawford. To have people come to the radio address on
Friday afternoon?
Mr. Bennett. Yes.
Ms. Crawford. Absolutely.
Mr. Bennett. Would you normally have been the person to
handle that?
Ms. Crawford. Yes, I would have been a normal contact.
Mr. Bennett. Ms. Hernreich, would you have been involved in
that, or would that have been Ms. Crawford's function?
Ms. Hernreich. I would have been involved peripherally. I
think she would bring the list to me, and eventually--or come
to me and say someone just called at the last minute. That
would be the normal process.
Mr. Bennett. Ms. Khare--to you, Ms. Khare--ultimately Ms.
Scott advised you that the First Lady's office said that it
could be arranged that this group could go into the White
House; correct?
Ms. Khare. She advised me that the group could go into the
White House. I don't remember whether she said that the
permission came from the First Lady's office. I just don't
remember who told her.
Mr. Bennett. And, in fact, you are the individual who
ultimately called Mr. Chung?
Ms. Khare. I returned the call to him. And the time period
was not very long. He was still----
Mr. Bennett. Still at the First Lady's office?
Ms. Khare. Still at the First Lady's office, yes.
Mr. Bennett. And you basically advised him that he was
going to be permitted, with his six friends, to go into the
Oval Office?
Ms. Khare. I don't remember the number of friends, but yes.
Mr. Bennett. Ms. Khare, were you ever criticized by any
representatives of the National Security Council with respect
to taking these steps?
Ms. Khare. No one ever came to me from the National
Security Council. I've never talked to anybody from the
National Security Council. The following week or within the
following few weeks, someone on my--on the DNC staff came to me
and in a teasing kind of way said, the National Security
Council is after you because you let those Chinese nationals
have their picture made with the President. And they were--that
was not at all serious, but they were telling me that--they did
explain that the National Security Council was objecting to the
photographs being given to the Chinese citizens, the
photographs with the President.
Mr. Bennett. In fact, Ms. Khare, I will be asking Ms.
Hernreich and Ms. Crawford in a few minutes about the reaction
of the President with respect to the photographs being
released. But you don't know whether it was a jesting concern
on the part of the National Security Council or a very deep
concern. Clearly someone indicated to you that someone was
upset with you at the National Security Council.
Ms. Khare. Yes, I didn't think that the National Security
Council was jesting. I did think that the person on my staff
was making it a more serious thing and making it sound more
serious than it was.
Mr. Bennett. And I believe the individual at the DNC was
Mr. Eric Sildon who indicated that to you?
Ms. Khare. That is what I remember, yes.
Mr. Bennett. Did you personally ever talk with anyone at
the National Security Council about the concern of the NSC for
these individuals who have been been permitted to go into the
Oval Office with the President?
Ms. Khare. No, I did not.
Mr. Bennett. Ultimately, Ms. Khare, you not only arranged
for Mr. Chung to get into the Saturday morning address, but you
also handled the forwarding of the photograph to him in
connection with his visit, didn't you?
Ms. Khare. No, I did not handle the forwarding of the
photograph.
Mr. Bennett. Let me if I can, exhibit 201. You see that
exhibit that is on the screen before you, Ms. Khare?
[Note.--Exhibit 201 may be found on p. 55.]
Ms. Khare. Yes.
Mr. Bennett. It is a fax--covering fax sheet to Johnny
Chung from Carol Khare.
Ms. Khare. Yes.
Mr. Bennett. Subject: Photo. And I believe it reads, the
White House assures me that you now have the pictures. Hurrah,
I guess, is what it says.
Ms. Khare. Something like that. Yes.
Mr. Bennett. If you don't give me a call, have a good trip.
Is that your handwriting?
Ms. Khare. That is my handwriting.
Mr. Bennett. So you were involved with forwarding.
Ms. Khare. I didn't forward the photographs. What I was
saying to him was I understand you now have the photographs. I
did not make the arrangements or send him the photographs.
Mr. Bennett. But clearly you did confirm with him that the
photograph had been sent?
Ms. Khare. Yes, yes.
Mr. Bennett. Now, Ms. Hernreich, I gather that you as the
Deputy Assistant to the President and the Director of Oval
Office Operations--do I have that correct? Is that your title.
Ms. Hernreich. Yes.
Mr. Bennett. You would have had some responsibility in
terms of handling logistical arrangements with respect to this
kind of visit by an individual and/or foreign nationals into
the Oval Office. Wouldn't you have some involvement in that?
Ms. Hernreich. Well, specifically what do you mean by
logistical arrangements?
Mr. Bennett. Did you in any way coordinate the checking of
passport numbers or anything else with respect to the
individuals taken in to see the President?
Ms. Hernreich. On this occasion, to be very honest with
you, I don't recall anything about the--how they came to get
into the radio address. Normally, I would not be the one who
would be checking passport numbers or even forwarding those
to----
Mr. Bennett. Did you interact with Mrs. Evan Ryan, who in
fact checked the passport numbers?
Ms. Hernreich. Again, I don't remember anything about
anything coming up to this radio address or Mr. Chung being in
this radio address. I do not recall ever interacting with Evan
Ryan regarding anything on this radio address or really any
radio address.
Mr. Bennett. If we can just briefly play the videotape of
the March 11, 1995, visit by Mr. Chung and his group.
[Videotape playing.]
Mr. Bennett. Ms. Hernreich and Ms. Crawford, were both of
you there in the Oval Office on this occasion?
I hear some female voices in the background. I am trying to
clarify whether you were both in the Oval office when that
visit was made.
Ms. Hernreich. I don't recall if I was in the Oval Office
right then or not.
Mr. Bennett. Ms. Crawford, were you?
Ms. Crawford. Yes, I was there.
Mr. Bennett. With respect to your appearance there, Ms.
Crawford or Ms. Hernreich, if you were or were not there, who
was responsible for vetting--a phrase in Washington--vetting or
clearing the names of the guest list, clearing the names of
those individuals before they arrived in the Oval Office to
meet with the President?
Ms. Crawford. Are you asking me?
Mr. Bennett. Yes.
Ms. Crawford. I can tell you the standard practice if
that's what you are interested in.
Mr. Bennett. It was your responsibility, wasn't it? Aren't
you the one that was in charge of that?
Ms. Crawford. Of vetting?
Mr. Bennett. Yes, of clearing the names.
Ms. Crawford. No, my responsibility was gathering the
requests that would come into the radio address, and I would
anywhere from a couple of weeks before a radio address to as I
mentioned before, a Friday before the radio address, would take
requests from people, from friends and family of the President,
from various people, and then put the list together, and Nancy
and I would anywhere from 2 or 3 days prior to the radio
address, would sit down and try to determine, you know, who
could attend.
Mr. Bennett. And did you take those steps with respect to
those individuals? Those six individuals with Mr. Chung we just
saw them on the videotape.
Ms. Crawford. I have a vague recollection--I mean, I know
that they attended the radio address--of how they came to--it's
my understanding that the request came from the chairman's
office at the DNC. And as these young women who testified, I
believe it was on a Friday, so it would not have been the
normal practice of sitting down a couple of days ahead of time.
But normally----
Mr. Bennett. I think that is my point, if I can pick up on
that. It would not have been the normal practice. Obviously,
this is an event that has taken on some significance in your
life in terms of depositions and appearances. I guess that's
the point I was trying to make earlier. This was not the normal
event to Friday afternoon, if it was not Friday night, have an
individual indicate he wants to bring six foreign nationals
into the Oval Office of the White House and my question is do
you recall in light of this late minute request what steps you
took to try to find out who these people were?
Ms. Crawford. I do not recall exactly--they were not
described, I don't think, in that manner to me. I understood it
as a request from the chairman's office for a gentleman, Mr.
Johnny Chung, to come along with six people.
Mr. Bennett. Did you do anything about checking of
passports or such things with respect to individuals to come
into the country? Did anyone talk to you about that?
Ms. Crawford. That was not part of our responsibility. The
Secret Service.
Mr. Bennett. Did anyone from the Secret Service talk to you
about how these people managed to get into the Oval Office?
Ms. Crawford. No, I don't believe so.
Mr. Bennett. Ms. Hernreich, I think clearly at some point
in time a photograph of these individuals with the President
was released. Isn't that correct?
Ms. Hernreich. I don't know if it was released or not. My
recollection is that it was never released. At least my
recollection is that I was called about the photograph and I
never released it.
Mr. Bennett. Well, I believe at some point in time with the
photograph having been released, didn't President Clinton--and
I'm just referring to page 67 of your deposition, if you want
to refer to that, Mr. Cearly. I'm not trying to trap you here
on this, Ms. Hernreich, I am trying to clarify. You had
previously indicated, I believe, that with respect to the
release of the photograph of the President with Mr. Chung and
these individuals, that President Clinton said to you, and I'm
referring to page 67 of your deposition, that, quote, You
shouldn't have done that, end of quote, or, quote, ``We
shouldn't have done that.'' Do you see that in your deposition?
Ms. Hernreich. Yes. May I say that my recollection is that
he did not say that in regards to the photograph. I think what
he was saying to me, as I recall it, that we should not have
brought them in there.
Mr. Bennett. I'm sorry. So then it was more than just the
matter of the President talking about a photograph; he was
specifically saying to you that these individuals should not
have been brought into the Oval Office?
Ms. Hernreich. That's my recollection.
Mr. Bennett. Did President Clinton indicate to you what the
basis of his concern was as to the matter of these people being
brought into the Oval Office?
Ms. Hernreich. Not that I recall.
Mr. Bennett. Did he at any time express concern about
National Security Council considerations? I believe at one
point in your deposition I thought you indicated at page 64
that the President, President Clinton, noted--page 64,
Congressman, of Ms. Hern-reich's deposition--that the President
expressed concern about the National Security Council having to
be contacted.
Ms. Hernreich. No, I don't believe so. I don't think it
says that.
Mr. Bennett. Could I have 1 second, please?
Mr. Burton. Can I interrupt? I'd like to ask one question.
Mr. Bennett. Certainly, Mr. Chairman.
Mr. Burton. When I'm talking to my assistant and I tell her
I don't think somebody should be in my office or should be
talked to, she usually says, why. I mean she usually gives me
some kind of a question. Did you not question the President and
say, what did I do wrong or why did you object to them coming
in here?
Ms. Hernreich. No, I didn't. And I'm not really--I normally
don't question him. I think what he says should go. If the
President of the United States says we shouldn't have done
that, then I think we should not have done that. You're the
President.
Mr. Burton. But you have no idea why he said we should not
have had them in there?
Ms. Hernreich. My recollection, Mr. Chairman, is that there
was no followup conversation and that's my recollection.
Mr. Burton. Thank you.
Mr. Bennett. Did you have any further conversations with
President Clinton concerning his concern about these
individuals having come in? Did he ever bring it up again to
you?
Ms. Hernreich. Not that I recall.
Mr. Bennett. Ms. Crawford, I believe that in your
deposition you previously indicated that you remember the
President expressing some concerns about Mr. Chung and his
guests; isn't that correct?
Ms. Crawford. Yes, I vaguely recall.
Mr. Bennett. Did you talk with President Clinton about his
concerns about these people having been brought into the Oval
Office?
Ms. Crawford. No, I did not. I don't recall any specific
conversation, no.
Mr. Bennett. Ms. Crawford, did you take any steps with
respect to these concerns that were raised by the President?
Specifically, did you contact the National Security Council
after the fact to followup on this?
Ms. Crawford. I have--I recall that my concern, because I
would also deal with the photographs from the radio address,
was making sure or seeing if it was appropriate to hand out
these photographs. So I do have a recollection of after the
radio address, very shortly after, contacting or giving a note
to someone in the National Security Council. I'm not sure if it
was----
Mr. Bennett. Did you take the names of Mr. Chung and his
six guests to the National Security Council so someone could do
a little bit of a check on these people?
Ms. Crawford. During my----
Mr. Bennett. Not a little bit of a check; any kind of a
check. Did you take those names to the NSC?
Ms. Crawford. During my deposition I did see a document
that the names were forwarded to Nancy Soderberg, and I may
have been the person that passed that note down or walked it
down.
Mr. Bennett. In that regard, maybe it would help you a
little bit if I could have exhibit 196. If we can increase
the--bring that up a little bit. Ms. Crawford, showing you
exhibit 196, it's on the TV screen and I believe it's in the
exhibit book there before you.
[Exhibit 196 follows:]
[GRAPHIC] [TIFF OMITTED] T5667.426
Ms. Crawford. Yes, I have it here.
Mr. Bennett. Which is a memorandum from Brooke Darby of the
National Security Council to Robert Suettinger of the National
Security Council. Do you see that it is dated April 7, 1995?
Ms. Crawford. Yes, I do see it.
Mr. Bennett. That is approximately 4 weeks after the radio
address. And you'll note the comments there, I believe it says
Johnny Chung, one of the people on the list, is coming in to
see Nancy Hernreich tomorrow, and Nancy needs to know urgently
whether or not she can give them the pictures. Do you see that?
Ms. Crawford. Yes, I do.
Mr. Bennett. Ms. Crawford, I'll show you also exhibit 198,
which is apparently a notation of e-mail in terms of the
response of Mr. Suettinger back to Ms. Darby. In that exhibit
198 there is Mr. Suettinger's comment about Mr. Chung in that
exhibit to the effect that, quote, ``My impression is that he
is a hustler,'' a quote that has been repeated a few times
today by Members of both political parties.
Ms. Crawford, is there any reason why these memos would be
dated April 7th and not March 11th if you immediately addressed
the question on Saturday morning with the National Security
Council?
[Exhibit 198 follows:]
[GRAPHIC] [TIFF OMITTED] T5667.427
Ms. Crawford. I did not write these memos or e-mails, so I
don't know why they would be dated.
Mr. Bennett. I guess my question is, is it your
recollection that you dealt immediately with this that same
Saturday, March 11th?
Ms. Crawford. I believe that I followed up very shortly
after the radio address. I believe I followed up on Saturday,
but you know I'm not sure if it was Saturday or maybe Monday.
Maybe people weren't in on Saturday. I believe I followed up
shortly thereafter.
Mr. Bennett. Looking at exhibit 196, if we could have that
back on the screen, please. There is reference to--trying to
have a visit with you. Do you recall the visit of Mr. Johnny
Chung to see you the following day on April 8th with respect to
the photographs taken in the Oval Office?
Ms. Hernreich. No.
Mr. Bennett. Do you have any recollection of any followup
visit by Mr. Chung?
Ms. Hernreich. No, I don't.
Mr. Bennett. Do you have any recollection of speaking with
Ms. Crawford with respect to her contact with the National
Security Council, whether it was on March 11th or April 7th?
Ms. Hernreich. No, I don't have any recollection of
speaking with her about conversations she had with the NSC.
Mr. Bennett. Ultimately, what was the response of the
National Security Council? What was the position?
Ms. Hernreich. Well, I don't recall----
Mr. Bennett. I'm sorry; Ms. Crawford, you wanted to add
something?
Ms. Crawford. Yes, exhibit 187?
Mr. Bennett. I'm sorry.
Ms. Crawford. Exhibit 187 in my book indicates--which was
shown to me during my deposition--the name and listed the
delegations and a note that went to Nancy Soderberg, who is in
the NSC.
[Note.--Exhibit 187 may be found on p. 85.]
Mr. Bennett. I was going to get to that in a second. We
could go to that now if you like.
Ms. Crawford. This is what I would believe would have been
the contact shortly thereafter, which would have been 2 days
thereafter.
Mr. Bennett. Ms. Crawford, do you recall Ms. Darby calling
you and advising you not to permit this photograph to be
released?
Ms. Crawford. I don't specifically recall a conversation
with Ms. Darby.
Mr. Bennett. I thought at page 62 of your deposition you
indicated----
Ms. Crawford. I'm sure that I talked with Ms. Darby, but I
don't specifically recall what she told me to do with the
photographs.
Mr. Bennett. Well, Ms. Brooke Darby of the National
Security Council is testifying before this committee tomorrow
afternoon and according to comments she has made to members of
the staff of this committee, she indicates that she
specifically told you, Ms. Crawford, not to have photographs of
Mr. Chung and his guests released. And I interpreted that
comment made recently by her in preparation for her appearance
here tomorrow to be consistent with your deposition testimony
where you indicated, I thought, that you recalled her in fact
calling you, saying don't release this photograph.
Ms. Crawford. Can you show me in my deposition--I recall
having a conversation with Ms. Darby about this, but I don't
specifically recall her saying----
Mr. Bennett. Let me address the points you were trying to
make on the exhibit. Ms. Hernreich, directing your attention to
exhibit 187, 187, if we can also put up--first of all, exhibit
171-1--171-1 is the second page of a letter forwarded by Mr.
Chung. And then now looking at exhibit 187, that is handwriting
and notation on that second page. Do you see that Ms.
Hernreich?
Ms. Hernreich. 187?
Mr. Bennett. Yes.
Ms. Hernreich. Yes.
Mr. Bennett. Directing your attention to exhibit 187, that
is actually your handwriting, isn't it, Ms. Hernreich?
Ms. Hernreich. Yes, that's correct.
Mr. Bennett. And referring to that exhibit, correct me if I
am wrong, but I believe--if I am not reading that correctly
tell me--but the handwriting reads someone from DNC asked to
let into radio address before photos are sent out; we need to
know if we should not send them. Isn't that correct?
Ms. Hernreich. That's what it says.
Mr. Bennett. Ms. Khare, ultimately you did learn that the
White House, in fact, sent the photographs, correct, as
reflected by the fax that was sent out?
Ms. Khare. That fax reflects that. I do not independent of
that fax remember what the final outcome was of this.
Mr. Bennett. But clearly the fax reflects that it was sent,
and I guess my question to all of you is do any of you know the
individual at the White House--this is directed to the entire
panel of four--the individual at the White House who made the
decision to send these photographs of President Clinton and Mr.
Chung and his friends out to Mr. Chung, despite the warnings of
the National Security Council? Do you know who made that
decision?
Ms. Hernreich. Mr. Bennett, may I speak for a moment?
Mr. Bennett. Certainly.
Ms. Hernreich. Do we know for certain that that photograph
with the group was sent out? And, you know, my recollection is
that Mr. Chung called quite a bit about these photographs and
that they were never released. Only yesterday did I find out
that he had, in going through some of this that he had received
any photographs, and I'm wondering whether he received only the
photograph of him and his brother, and that the photographs of
the entire group were never released. I've not seen that
photograph in any of his literature or anywhere else. It is my
recollection that those photographs were never sent to him.
Mr. Bennett. Ms. Hernreich, I will tell you on behalf of
the committee, we're going to be interviewing Mr. Chung
tomorrow under oath, and that is one of the many things we
would like to find out. And, Mr. Chairman, if I can have 30
more seconds, I will be finished. Just one last thing, Ms.
Hernreich, if you would--specifically referring to exhibit 215,
you also, Ms. Crawford, or actually, Ms. Hernreich, either one
of you, those of you who were working at the White House, this
is an e-mail at the White House dated November 30, 1995. Do you
see that? Where there is a specific notation that as of
November 22, 1995, we will not honor requests from Johnny
Chung. And there is reference to his, quote, improperly using
photo or business--photo of businesspeople and the President.
Do you recall receiving this e-mail, Ms. Hernreich?
[Exhibit 215 follows:]
[GRAPHIC] [TIFF OMITTED] T5667.428
Ms. Hernreich. No, I don't. The e-mail is not to me.
Mr. Bennett. Do you recall receiving it, Ms. Crawford? Did
you ever see this e-mail?
Ms. Crawford. No, this is the first time I believe that I
have seen this.
Mr. Bennett. Do either of you ever recall any conversations
concerning the policy that was established as of November 22,
1995, at the Clinton White House in light of Mr. Chung's use of
these photographs? Do either one of you recall that?
Ms. Hernreich. Mr. Bennett, what I recall, and my memory is
not great a lot of the time, but what I recall is conversations
with the photo office that we would not send those photographs
of the businesspeople with Mr. Chung from the beginning. That's
my recollection of my conversations.
Mr. Bennett. My question is in terms of this--Mr. Chairman,
I am finished. Thank you--that e-mail clearly establishing a
policy in November 1995, neither of you recall actually seeing
that e-mail or being aware of its issuance at the White House?
Ms. Hernreich. That's correct.
Ms. Crawford. I do not recall, no.
Mr. Bennett. Thank you, I have no further questions, Mr.
Chairman. Thank you.
Mr. Burton. Mr. Waxman.
Mr. Waxman. Ms. Hernreich, I understand you essentially
serve as President Clinton's gatekeeper. Can you explain what
that means?
Ms. Hernreich. Well, I am basically responsible on a daily
basis for who he sees, what paper he sees, what phone calls he
receives, that sort of thing. So for all of those things, I am
his gatekeeper.
Mr. Waxman. And you manage a staff of how many people?
Ms. Hernreich. Yes, I have 9 or 10 people.
Mr. Waxman. And you manage the flow of paper to the
President, memos, letters, notes and other individual orders
that people want to get to the President?
Ms. Hernreich. That's correct.
Mr. Waxman. Do you keep his schedule?
Ms. Hernreich. What we try to do is implement the schedule
every day. That is part of our responsibility, to make sure
that he does what he's supposed to be doing as it relates to
the schedule, and that he accomplishes the goals that he's
supposed to accomplish each day.
Mr. Waxman. And you field a lot of phone calls?
Ms. Hernreich. Yes, we do take a lot of phone calls.
Mr. Waxman. And you handle visitors to the Oval Office?
Ms. Hernreich. That's correct.
Mr. Waxman. Does that include staff who will be meeting
with the President?
Ms. Hernreich. That's correct.
Mr. Waxman. Does your office handle the President's
personal correspondence?
Ms. Hernreich. That's correct.
Mr. Waxman. I would like the committee to understand what a
typical day is like for you. I understand you work 6 days a
week. How many hours do you typically work each day?
Ms. Hernreich. Usually the minimum is 12 hours.
Mr. Waxman. How many pieces of paper do you review in a
typical day?
Ms. Hernreich. I would say at a minimum 150 pieces of
paper.
Mr. Waxman. Do you have to do a quick review of where to
send the pieces of paper? Is that your job?
Ms. Hernreich. Correct. I also review the paper that goes
to the President. Often it will come from the staff or other
sources. I review that. And I view correspondence, other pieces
of paper that come to me, and then I decide where to send them.
Mr. Waxman. How many visitors to the President does your
office deal with on a typical day?
Ms. Hernreich. Including the staff, oh, at least 100.
Mr. Waxman. And you help to determine who gets in and who
doesn't?
Ms. Hernreich. That's correct.
Mr. Waxman. How many phone calls does your office field in
a typical day?
Ms. Hernreich. Including staff, we get a lot of phone calls
from staff, not asking to speak to the President but asking us
what the President is doing or an opinion of what he might want
on something, so I would say probably that same amount, 100,
150 phone calls at least a day.
Mr. Waxman. How many of those do you personally return, do
you think?
Ms. Hernreich. I speak to a lot of the staff people
directly. I return a lot of my own phone calls. If I don't get
them done that day, I will return them the next day or the
first opportunity I have.
Mr. Waxman. In a typical day you are required to review
hundreds of pieces of paper, talk to dozens of individuals in
person, speak to dozens of people on the phone, keep the
President on schedule, manage a staff of 9 and handle any
emergencies that might come up?
Ms. Hernreich. That sounds like a typical day.
Mr. Waxman. And you do that 6 days a week.
Ms. Hernreich. Normally 6 days a week.
Mr. Waxman. It sounds like you are constantly in motion.
Ms. Hernreich. That's true.
Mr. Waxman. Were you involved in organizing the President's
radio addresses?
Ms. Hernreich. Yes.
Mr. Waxman. What was your role in regard to those events?
Ms. Hernreich. My role is to primarily oversee the--to go
over with my assistant the last list and determine who actually
gets into the radio address.
Mr. Waxman. What's the purpose of inviting guests to attend
the radio address?
Ms. Hernreich. The purpose is basically to--because--give
the President an opportunity to visit with his friends and his
friends to see him. Another reason to have people at the radio
address is because staff people often want to bring their
families in to meet the President and we really don't have a
good opportunity during the week to do that. So this is a nice
way to have an audience and then afterwards to have
photographs. And so a chance for them, staff and cabinet
members, to bring their families in to meet the President.
And the third reason is actually it's good for the
President. He enjoys having an audience. He loves people, and
he wants to be accessible to his staff and to his friends and
there's not that time often and so this is a good chance for
that. And it makes him feel good. And I think it puts a nice
tone on the radio address for him. He likes it.
Mr. Waxman. How many radio addresses does he give each
year?
Ms. Hernreich. I think--well, he gives one a week. 52. We
have audiences, I think, for about 40 a year because he
probably does about 40 in the office.
Mr. Waxman. Forty a year in which you have audiences?
Ms. Hernreich. That's correct.
Mr. Waxman. How many people are typically in an audience?
Ms. Hernreich. Probably about an average of 60. Some days
there are 100, some days 40.
Mr. Waxman. So we are talking about over 10,000, maybe
15,000 people attending a radio address since the start of the
Clinton administration in 1993? Does that sound about right?
Ms. Hernreich. That sounds about right.
Mr. Waxman. Do you remember each of the 10- to 15,000
people who attended the radio address?
Ms. Hernreich. No, I don't.
Mr. Waxman. How long have you been working for the
President?
Ms. Hernreich. I've been working for the President since
1985, when he was Governor.
Mr. Waxman. So around 12 years. And you've been at the
White House for 4\1/2\ years now. In your experience, is the
President pretty courteous to people?
Ms. Hernreich. Pardon me?
Mr. Waxman. Is the President a courteous individual?
Ms. Hernreich. He is extremely courteous. He loves people.
And he wants to do things for other people. And this is a great
opportunity for him to do that. He has a heart of gold.
Mr. Waxman. We saw a videotape of the President greeting
Johnny Chung. Would you say that was unusual for the President
when he greeted Johnny Chung?
Ms. Hernreich. No, it's not unusual at all.
Mr. Waxman. He's friendly.
Ms. Hernreich. He greets most of his friends like that.
Mr. Waxman. And does the President get his picture taken
with lots of people?
Ms. Hernreich. Lots of people.
Mr. Waxman. Does the President generally smile when someone
wants their picture taken with him?
Ms. Hernreich. Absolutely.
Mr. Waxman. Because of the nature of your job, do you
generally know who the President's personal friends are?
Ms. Hernreich. Yes, I do.
Mr. Waxman. Was Johnny Chung a personal friend of the
President?
Ms. Hernreich. The President considered Johnny Chung a
personal friend.
Mr. Waxman. Did you have any role in helping Johnny Chung
attend the March 11, 1995 radio address?
Ms. Hernreich. I honestly don't remember anything leading
up to the time that he--what took place that caused him to come
to the radio address.
Mr. Waxman. Did you have any conversations with Maggie
Williams about Johnny Chung's request to attend the radio
address?
Ms. Hernreich. I don't recall any conversations with Maggie
Williams about him coming to that radio address.
Mr. Waxman. Did Evan Ryan contact you to request that
Johnny Chung be allowed to come to that radio address?
Ms. Hernreich. I don't recall that Evan Ryan called me at
all on that.
Mr. Waxman. Did you have any conversations with anyone else
in the First Lady's office requesting that Johnny Chung be
allowed to attend this radio address?
Ms. Hernreich. No, I don't believe so.
Mr. Waxman. And I think you testified you don't remember
seeing Johnny Chung at the radio address.
Ms. Hernreich. I don't remember it, no.
Mr. Waxman. Let me ask you a few bottom line questions
about Johnny Chung. Did Johnny Chung ever tell you that he
would make a contribution if he could attend the radio address?
Ms. Hernreich. Absolutely not.
Mr. Waxman. Did Johnny Chung ever talk to you about
political contributions?
Ms. Hernreich. No.
Mr. Waxman. Did Johnny Chung ever talk to you about policy
matters? Did he ever tell you that he was trying to get a
change in U.S. policy?
Ms. Hernreich. No.
Mr. Waxman. And did you ever solicit contributions from
Johnny Chung?
Ms. Hernreich. No.
Mr. Waxman. While I'm on the subject, let me ask you some
very general questions. While you worked at the White House,
did you ever solicit contributions from anyone?
Ms. Hernreich. Absolutely not.
Mr. Waxman. And did you ever observe any White House
staffers soliciting contributions from anyone?
Ms. Hernreich. No.
Mr. Waxman. Ms. Khare, Johnny Chung called you in March
1995. Did you know who he was at that time?
Ms. Khare. No, I didn't.
Mr. Waxman. And he identified himself as Johnny Chung, I
assume.
Ms. Khare. He did.
Mr. Waxman. And he said, what, he's a friend of the First
Lady's?
Ms. Khare. He said I'm a friend of the First Lady.
Mr. Waxman. Did he say he was calling from the First Lady's
office?
Ms. Khare. Yes, he did.
Mr. Waxman. And he also said that Maggie Williams couldn't
help him get into the radio address.
Ms. Khare. That's right.
Mr. Waxman. You had someone in your office handle the
request after he had called; isn't that right?
Ms. Khare. That's right.
Mr. Waxman. You asked Ms. Scott to see what she could do
about it?
Ms. Khare. I asked if anyone knew what could be done about
it, and Ms. Scott volunteered to try.
Mr. Waxman. You didn't handle that request yourself.
Ms. Khare. No. I really didn't know how.
Mr. Waxman. OK. You didn't tell Chairman Fowler about the
request.
Ms. Khare. Not that I recall. I don't think I did.
Mr. Waxman. You eventually passed it off to Ms. Scott.
Ms. Khare. Yes.
Mr. Waxman. And Ms. Scott told you that the request had
been approved at some point that day.
Ms. Khare. Yes.
Mr. Waxman. And you called Mr. Chung back at the First
Lady's office to let him know; is that right?
Ms. Khare. That's right.
Mr. Waxman. You don't remember his name being mentioned in
the office before that time?
Ms. Khare. No, I don't. I know now from discussions and
depositions and, that kind of thing, that he had been in the
office a few days before, but I was not aware of that at the
time.
Mr. Waxman. Did you know at the time that he had made any
campaign contributions?
Ms. Khare. No.
Mr. Waxman. The way you handled Johnny Chung's request was
the same way you would have handled any friend or supporter's
request that attend a radio address; is that right?
Ms. Khare. I hope so, yes.
Mr. Waxman. You didn't just do this for financial
contributors. You did it for others, as well?
Ms. Khare. Yes.
Mr. Waxman. You didn't accept Johnny Chung's invitation to
travel to China, did you?
Ms. Khare. No, I didn't.
Mr. Waxman. And Chairman Fowler didn't accept his offer
either, did he?
Ms. Khare. No.
Mr. Waxman. OK. There was a question about whether he
should get--let me ask Ms. Scott some questions first. Let me
get to that.
Ms. Scott, you said that Carol Khare asked you to find out
if Johnny Chung and his guests could attend that March 11th
radio address; is that right?
Ms. Scott. That's correct.
Mr. Waxman. OK.
Ms. Scott. She made a general statement in the office.
Mr. Waxman. And did you know how to handle that?
Ms. Scott. Not specifically. I said I would make a call to
a friend.
Mr. Waxman. You made a call to the First Lady's office to
see what you could do?
Ms. Scott. I think so.
Mr. Waxman. And the purpose of that call was to have
someone lead you in the right direction; is that correct?
Ms. Scott. That's correct.
Mr. Waxman. As I recall your testimony, you didn't recall
whether you spoke to Ms. Williams at that time, but you talked
to somebody there.
Ms. Scott. That's correct.
Mr. Waxman. And do you think someone took a message, and
someone called you back. Is that your recollection of what
happened? Or did they arrange it right on the spot?
Ms. Scott. They called me back.
Mr. Waxman. OK. Is it possible that someone from another
office in the White House, someone in the President's office
might have called you back?
Ms. Scott. I don't think so, but I'm not sure.
Mr. Waxman. In addition to the radio address attended by
Johnny Chung, you made arrangements for some family members to
attend a radio address; isn't that right?
Ms. Scott. That's correct.
Mr. Waxman. And at that time, did you call the First Lady's
office?
Ms. Scott. Yes, I did.
Mr. Waxman. Is it possible that your--OK. You're not
confusing this call with the call about Johnny Chung?
Ms. Scott. I don't think so. I'm not sure.
Mr. Waxman. Now, Johnny Chung was at this White House radio
address. And we saw the videotape that some photos were taken
of him and his guests. Wouldn't it have been routine for him to
get the photos? Who would have been in charge of the photos?
Would that be the White House or the DNC?
Ms. Hernreich. It would have been our office. My assistant
normally is the person responsible for sending the photos out
after the radio address.
Mr. Waxman. Ms. Crawford, why was there a hang up about the
photos?
Ms. Crawford. I believe we wanted to make sure that we knew
who these people were and that it was appropriate to send the
photographs out.
Mr. Waxman. And eventually someone from the National
Security Council had to take a look at this; is that right?
That was Mr. Suettinger.
Ms. Crawford. From the e-mails, evidently, that's the
process that happened.
Mr. Waxman. I want to yield to Mr. Fattah for some further
questions on this.
Mr. Fattah. Thank you very much. Let me--Ms. Scott, I want
you to answer the same question that Congressman Waxman asked
of someone else. You were also invited to travel with Johnny
Chung?
Ms. Scott. Yes, sir.
Mr. Fattah. And you declined a trip to China?
Ms. Scott. Yes, I did. It seemed inappropriate.
Mr. Fattah. OK. So Johnny Chung made a lot of invitations,
and people declined it. Let me go back to this radio address. I
was at one of the President's radio addresses.
Ms. Hernreich. We do have Members of Congress to attend.
Mr. Fattah. I appreciated the opportunity to be there.
Ms. Hernreich. Good.
Mr. Fattah. And we've heard that Mrs. Scott's godparents
were also there.
Ms. Hernreich. Yes.
Mr. Fattah. So it was pretty regular that people could get
invited or could get themselves invited to be at a radio
address of the President.
Ms. Hernreich. We had invited guests every week we do the
radio address in town. At times, the President is out of town
or out of the country on a Friday or Saturday, and so, in those
cases, we would not have an audience.
Mr. Fattah. Let me ask a question, because a lot of--this
is an investigation into foreign campaign dollars, getting into
the 1996 elections. And we may seem somewhat far afield
focusing on this radio address on these six gentlemen since
there's no evidence that the committee has that any of these
six gentlemen donated any money in the Presidential election.
So whether they were or weren't at a radio address, whether
they did or didn't receive pictures is pretty far afield only.
The only connection to it is Johnny Chung, because these
gentlemen, from everything that this committee knows, didn't
give a dime to President Clinton's re-election campaign or to
the DNC or to anything. All they--they were visiting. The
person who was escorting them, said, look I can get you in to
get a picture with the President, and he arranged it.
So in terms of Johnny Chung, which is really, I would
assume, our real focus, not how somebody got into the radio
address, since more than 10,000 people had been in radio
addresses, is in terms of Johnny Chung. He was a friend of the
President. He was a supporter of the President.
Ms. Hernreich. That's correct. The President, may I just
mention, has friends that he's had all of his life, his high
school friends and college friends. But he considers friends
people who are helpful to him. He's very----
Mr. Fattah. I totally understand. Bob Dole ran for
President in the same election. He had a friend. His name was
Fireman. He was the chairman or Deputy chairman of his Campaign
Finance Committee. And he went about trying to help Bob Dole,
his friend. And he arranged to launder some money through a
Hong Kong bank back through into the Dole campaign. He pleaded
guilty and had to pay a $6 million fine and was put essentially
under house arrest for a few months.
And in the entire prosecution of the case, it was asserted
by the U.S. attorney that Bob Dole knew nothing about how his
friend went about raising this money, that Bob Dole was never
implicated. There was not even an inference that Bob Dole had
any idea. All he knew was that his friend was helping him.
Now, there's no proof whatsoever that Mr. Chung has done
anything wrong. But do you have any reason to believe that, if
he had done something wrong, that the President would know
about it?
Ms. Hernreich. I have no reason to believe that.
Mr. Fattah. If the President had some knowledge that a
friend of his is doing something wrong vis-a-vis his campaign,
wouldn't the President direct him to stop it?
Ms. Hernreich. Yes, he would.
Mr. Fattah. So now, unless Mr. Chung was operating as an
agent of the President or of his campaign, even if he did
something wrong, don't you think it's kind of strange that,
since, in none of these other cases--let me give you another
example. The Speaker of the House, there was a foreign arms
dealer who gave tens of thousands of dollars to Speaker
Gingrich's campaign, but there's no assertion by anyone that
Newt Gingrich had any idea that this person was funneling money
improperly in to the Speaker's political efforts.
So it is of interest as we sit here today focused on this
silliness of this radio address in these pictures, which has
nothing to do whatsoever with the subject matter of this
investigation. Johnny Chung does. And how he got his money and
where the money came from, that's an important issue, but it
has nothing to do with this radio address unless the chairman
or the majority can show some connection.
Now, supporters of the President, and some of them get cuff
links from the President, some of them get a picture, some of
them get a smile. But as best we know from Johnny Chung, he
never sought any policy or preferential treatment in terms of
policy decisions at all. And in terms of his interaction with
the President, do you have any information to the contrary in
terms of that?
Ms. Hernreich. No. I have no information to the contrary.
Mr. Waxman. Would the gentleman yield for a minute?
Mr. Fattah. I'll be glad to yield.
Mr. Waxman. Ms. Hernreich, we saw the videotape. The
President met with all these people, took the picture. After
that radio address, he said something to you about how they
shouldn't be bringing all those people in. What did he say to
you?
Ms. Hernreich. Well, my recollection of what he said was we
should not--you should not have done that. And that's all I
recall that he said to me, and with no explanation.
Mr. Waxman. In other words, he sort of had some sense that
he was being used.
Ms. Hernreich. Well, it's--I can't tell you exactly what he
meant by it, because he just said that. But that--whether he
was being used or that they were inappropriate people to bring
to the radio address or inappropriate people for him to meet
with. But, again, I did no followup questions. He didn't
explain it. That's my recollection. And so I would only have to
infer what he meant by it.
Mr. Waxman. Now, after that, somebody at the National
Security Council was asked to give some advice as to whether
these pictures ought to be given to Johnny Chung. Do any of you
at the table know how the NSC was asked to give some view on
this?
Ms. Hernreich. Well, I think they were asked to do it
because I sent a note to Nancy Soderberg and asked her whether
it was appropriate to send the photos out. Is that what you're
asking?
Mr. Waxman. Yes.
Ms. Hernreich. Yes. I think that's why they did it.
Mr. Waxman. So Nancy Soderberg then asked Suettinger?
Ms. Hernreich. Well, I don't know. No, I think Nancy
Soderberg's assistant probably just took care of it herself and
then asked Mr. Suettinger about it. That's what it indicates on
this e-mail.
Mr. Waxman. Mr. Suettinger sent an e-mail. You heard some
of the people on the other side of the aisle; they talk about
it as if it was an all points NSC advisory bulletin concerning
Johnny Chung. But as I--as all of you are assuredly aware now,
and we'll hear from Bob Suettinger tomorrow, that they
responded to this request for advice about the release of the
photographs, and then they sent an e-mail saying this guy looks
like a hustler.
But he also said it didn't seem like it was going to
endanger U.S. foreign policy--my words, not his--to give the
man a photo with the President. I think it's critical to note
that Bob Suettinger's e-mail accurately describes Johnny Chung
as a hustler and doesn't even object to the release of the
photos. He said it was OK with him to release the photos. And I
gather the photos were eventually released; is that correct?
Ms. Hernreich. Again, I question whether the photos with
the groups were ever released. I really don't think they were.
Mr. Waxman. Well, Ms. Khare, you sent some note, like,
hooray, the photos are going to be released. What were you
referring to?
Ms. Khare. Yes. And until I saw this fax, I really don't
remember the photos being released. And I see this fax, so some
photos must have been sent to him. But I really don't remember
whether or not--I don't know one way or the other about these
questionable photos.
Mr. Waxman. Johnny Chung evidently was pestering people
about the photos. Who did he call? Did he call you, Ms. Khare?
Ms. Khare. I don't remember whether he called me. I know
that he called some people at the DNC. And I know that he sent
a letter to a couple of people at the DNC. So I was aware of
the photo hunt.
Mr. Waxman. Thank you, Mr. Fattah. I yield back to you if
you have more questions.
Mr. Fattah. Thank you again. Because I think that--when
these gentlemen came in and got their picture taken with the
President, when they were in the radio address, nobody had any
envelopes with them stuffed with cash or anything like that,
right?
Ms. Hernreich. I don't recall being in the room, so----
Mr. Fattah. OK. Ms. Crawford, you were in the room, right?
Ms. Crawford. Yes. I don't believe anyone--not that I saw,
no.
Mr. Fattah. Let me ask you this question, because there is
a lot of attention focused on the fact that they were foreign
nationals. Was it unusual that people who were visiting our
country and had associations with people who knew the President
would want, get a chance for these people to meet the
President?
Ms. Hernreich. No. I don't think it is unusual for anybody
to want to bring their friends and associates in to meet the
President.
Mr. Fattah. When the President travels overseas, you see
tens of thousands of people----
Ms. Hernreich. Absolutely.
Mr. Fattah [continuing]. Line up just to get a glimpse of
him.
Ms. Hernreich. Absolutely.
Mr. Fattah. So the President of the United States is a
pretty important person. That's why you said, when the chairman
asked you, well, did you ask him what he meant, you said, you
don't ask the President of the United States, you just----
Ms. Hernreich. You just do what he says.
Mr. Fattah. Right. So the fact that Johnny Chung, who was a
friend of the President, who was trying to do business in a
foreign land, wanted to bring some associates through, in and
of itself is not something that would be beyond someone's
understanding that it might be something that he would want to
do.
The President, however, sensed that it might have some
inappropriateness and cautioned you about it. So the President,
when given--because he was not aware of any of this, these
other activities leading up to these people showing up at the
radio address. But the minute he sensed something, he felt that
perhaps it was somewhat inappropriate.
So what we do know about the President's actions in this
regard is that, when he sensed that something was
inappropriate, he took some action about it, which was to
direct you that there should be more appropriate concern taken
as to people who Mr. Chung might want to bring into the White
House.
Ms. Hernreich. That's correct, Congressman.
Mr. Fattah. So for those of us who, because there are a few
members of our committee who want to impeach the President of
the United States of America--it's not a widely held view in
the Congress or among the American public, but just so people
can have a glimpse of what he said in private to you when this
group of people were in there and got their picture taken; it
was someone who, as we would suspect, was attempting to do what
was right and honorable.
So I just think that, again, this committee's attempt to
seek out foreign money--let me just go down the line here.
Do any of you have anything that you would want to--that
you know about in terms of illegal foreign contributions coming
into the 1996 elections? Do you have any information about
that?
Ms. Hernreich. Absolutely not.
Mr. Fattah. Ms. Crawford.
Ms. Crawford. No.
Mr. Fattah. Ms. Khare.
Ms. Khare. No.
Mr. Fattah. Ms. Scott.
Ms. Scott. [Nodding in the negative.]
Mr. Fattah. And do you have any knowledge that the
Democratic party or President Clinton sought or solicited
donations, illegal foreign contributions in that campaign?
Ms. Hernreich. No.
Ms. Crawford. No.
Ms. Khare. No.
Ms. Scott. No.
Mr. Fattah. In terms of the subject matter of this hearing,
Mr. Chung, do you know of him violating any laws in our
country?
Ms. Hernreich. No, I don't know of him violating any.
Mr. Fattah. Do you know of him providing any foreign money
that was illegal in the campaign?
Ms. Hernreich. I don't know of anything.
Mr. Fattah. Do you know of him violating--I mean, he didn't
barge into the White House. He requested the opportunity. He
was checked through. Miss Kelly--Ms. Crawford, was he checked
through by the Secret Service for admission into the White
House?
Ms. Crawford. Everyone that comes onto the White House
grounds has to go through the process.
Mr. Fattah. So even if you said that someone could come and
they could be in a radio address, for security purposes, the
Secret Service runs their own check.
Ms. Crawford. We provide the Secret Service--or whoever----
Mr. Fattah. You give them a name and and you give them
information pertaining to that person?
Ms. Crawford. Yes.
Mr. Fattah. And then they get back to you and let you
know--they make a decision, an independent decision based on
their responsibilities to protect the physical health of the
President as to whether that person can come in; is that
correct?
Ms. Crawford. That's my understanding.
Mr. Waxman. Mr. Fattah, before we run out of time, I do
want to yield some time to Mrs. Maloney. And then we'll get
further chances for questions on the 5-minute rounds.
Mrs. Maloney.
Mrs. Maloney. Thank you, Mr. Chairman. I would like to ask
all of you the same question. You can answer yes or no starting
at this end. I would just like to ask you if you have any
reason to believe that Johnny Chung was an agent of the Chinese
Government, yes or no?
Ms. Scott. No.
Ms. Khare. No.
Ms. Crawford. No.
Ms. Hernreich. No.
Mrs. Maloney. I would like to ask again, all four of you,
do you believe that he tried to seek any favors for China? Are
you aware of any favors that he tried to seek for China?
Ms. Scott. No.
Ms. Khare. No.
Ms. Crawford. No.
Ms. Hernreich. No.
Mrs. Maloney. To your knowledge, did Johnny Chung ever try
to seek any policy changes? Did he ever try to advocate policy,
to your knowledge, in front of you, in any way?
Ms. Hernreich. No.
Ms. Crawford. No.
Ms. Scott. No.
Ms. Khare. No.
Mrs. Maloney. To your knowledge, were any policy changes
ever enacted as a result of a Johnny Chung's visits to the
White House or for his contributions? Are you aware of any
policy changes that were enacted?
Ms. Hernreich. No.
Ms. Khare. No.
Ms. Crawford. No.
Ms. Scott. No.
Mrs. Maloney. Do you think that it is unusual for Johnny
Chung to seek to have his picture taken with the President or
the First Lady? Is that an unusual thing?
Ms. Hernreich. No, it's not unusual.
Mrs. Maloney. And do you believe that Johnny Chung was
unique in trying to obtain a photograph?
Ms. Hernreich. No, I don't think there's anything unique
about that.
Mrs. Maloney. What is it like when people come to the
office? Do they usually want their photograph taken with the
President and First Lady?
Ms. Hernreich. Absolutely.
Mrs. Maloney. And do you think that it's unusual for a
businessman or woman to display a photograph that was taken
with him or her, with the President or First Lady? Is that
unusual?
Ms. Hernreich. No, it's not unusual.
Mrs. Maloney. I would like to really ask the President's
scheduler, Ms. Hernreich, a few questions.
How many people typically attend the President's weekly
radio broadcast?
Ms. Hernreich. Anywhere between 40 and 100. Approximately
60 for each radio address.
Mrs. Maloney. And is everyone who attends someone who gave
a donation to the Democratic National Committee?
Ms. Hernreich. Well, No. 1, one certainly doesn't know
about those people. It has no correlation to their being at the
radio address. So I wouldn't know that one way or the other.
Mrs. Maloney. Describe some of the people who have come to
these radio addresses besides Johnny Chung.
Ms. Hernreich. You would normally----
Mrs. Maloney. Mr. Fattah said he went. Did Members of
Congress go?
Ms. Hernreich. Members of Congress. The President's friends
from high school or college, when they come to Washington, will
come to radio addresses. His friends from Arkansas. We have
staff people and family.
Mrs. Maloney. What about school children? Do school
children come?
Ms. Hernreich. School children often come. If we have a
theme radio address, we'll have a group that--for instance, if
we had a radio address on mammography, we would have breast
cancer survivors there. We had radio addresses on tobacco, and
so we would have a group of school children come who had
started an initiative to keep other kids from ever starting
smoking.
We've had absolutely variety. We have----
Mrs. Maloney. So a cross-section of America?
Ms. Hernreich. We have Make-A-Wish children come. We have
the president of the national Rotary Clubs come. We have all
kinds of people come.
Mrs. Maloney. Actually, maybe I would like to come one of
these days.
Ms. Hernreich. We would love to have you. I hope you will.
Mrs. Maloney. I would really like to ask a judgment
question of you. You mentioned earlier that you're not aware if
any of these school children or Congress Members or friends
from home make contributions to the President's re-election
campaign or to the DNC or to a Congressperson.
But in your judgment, do you think it would be right to
deny a person the access to go and listen to a radio address if
they had given a contribution? I was always taught that it--to
be civic, to participate in your Government. But do you think
it would be right to deny someone access because they have made
a contribution?
Ms. Hernreich. I don't think it's right to deny somebody
because of they've made a contribution.
Mr. Waxman. Will you yield? Have you ever heard of anybody
being denied access because they gave $50,000 to the Democratic
National Committee?
Ms. Hernreich. No, I haven't. Or the reverse.
Mrs. Maloney. I would like to ask Carol, the DNC worker,
the former assistant, I would like to ask you, why were you
concerned about releasing the photographs of the President with
the Chinese businessmen that Johnny Chung brought to the radio
address? Why were you concerned about that?
Ms. Khare. I was not really concerned about it, because we
didn't have the photographs. The White House did. I did hear--I
did learn that there was some concern at the White House about
releasing them. And I heard that the National Security Council
had those concerns. I didn't--and that was--when I heard that
they were concerned, that was the first I knew that there was
anything questionable about it.
Mrs. Maloney. And would you have arranged for Mr. Chung to
attend the radio broadcast if you had known that he was going
to bring other businessmen with him?
Ms. Khare. Well, I knew that he had businessmen with him,
because he asked when he called. He said, I'm at the First
Lady's office, we've been in with the First Lady; I have these
businessmen with me, and we would like to go to the radio
broadcast.
Mrs. Maloney. Well, to your knowledge, is there anything
illegal or unethical about bringing businessmen to a radio
broadcast?
Ms. Khare. No.
Mrs. Maloney. To your knowledge, at the same time Mr. Chung
made donations to the DNC, do you have any reason to believe
those donations were improper?
Ms. Khare. No. I have no reason to think that.
Mrs. Maloney. And was Mr. Chung an American citizen at the
time that he made these donations?
Ms. Khare. I believe that he was.
Mrs. Maloney. He was an American citizen. And is there any
reason to believe that he was not the source of the
contributions, that he--was there any reason to believe that
the contributions came from any place besides Mr. Chung?
Ms. Khare. I certainly had no reason to believe that.
Mrs. Maloney. Did you know that when Mr. Chung came to
these--to this meeting, that he had been just named
California's Entrepreneur of the Year for his business
activities? Did you know that?
Ms. Khare. No, I really--that's the first I've heard of
that.
Mrs. Maloney. Didn't know that. My time is up. And I look
forward to asking some more questions the next round.
Mr. Burton. The gentlelady's time has expired.
Ms. Hernreich, you said, I believe, that one of you
indicated that anyone coming--I think it was you, Ms.
Crawford--anyone coming into the White House had to have
security clearance, or else they couldn't get in obviously to
protect the President against something; is that correct?
Ms. Crawford. The Secret Service handles the security.
Mr. Burton. That's for everybody?
Ms. Crawford. Yes. You have to clear someone into the White
House if you're not a White House passholder.
Mr. Burton. So the people that Johnny Chung brought in did
have clearance, or else they wouldn't have been involved in the
radio broadcast that day?
Ms. Crawford. I assume so.
Mr. Burton. Is that right, Ms. Hernreich?
Ms. Hernreich. I would assume so, too. You send the list
with information to the Secret Service, and they make a
determination about who's allowed onto the White House grounds
to see the President.
Mr. Burton. OK. You said you didn't remember Johnny Chung
being there and you didn't know the people who were with him?
Ms. Hernreich. I have no recollection of that particular
radio address or being there in the room when he was there.
Mr. Burton. But the President said to you afterwards, those
people shouldn't have been here?
Ms. Hernreich. Yes.
Mr. Burton. That seems kind of strange to me that you don't
remember Johnny Chung being there, and you don't remember those
people being there--and you don't remember those people being
there, but you remember the President saying, those people
shouldn't have been here.
Ms. Hernreich. Well, I don't deny that they were there. I
certainly--you know, because everything indicates that they
were there. I just don't have any recollection of the
particular radio address and, you know, everything surrounding,
being in the room. Often I don't stay in the room. Sometimes I
do; sometimes I don't. My office is right outside of the Oval
Office. And often I will stay out in the outer office during
the radio address and let the staff handle the radio address.
Mr. Burton. I know. But you said you didn't remember Johnny
Chung being there.
Ms. Hernreich. No, what I meant to say, Mr. Chairman, is I
was not in the room and don't remember, you know, everything
that went on there. I guess what I'm trying to say is, I
certainly--from every indication, Mr. Chung was there. I just
don't remember, I cannot visualize the events that went on that
day or remember everything that sort of transpired----
Mr. Burton. And you----
Ms. Hernreich [continuing]. In the room that day.
Mr. Burton. And you don't remember the people that were
there either?
Ms. Hernreich. I don't have--other than, you know, having
seen----
Mr. Burton. Well, the reason that troubles me is, I'm
thinking to myself now, because we have people running in and
out all the time as well. And sometimes I get a little upset.
And I look at my secretary and say, why did you bring these
people in here--for instance, when we have a bill up, and
people are in there beating on us, we don't want to talk to
certain people--and say, why did you bring these people in? And
usually when I say that, I'm not angry, but she gets the
message pretty easily and pretty quickly, and it makes a very
vivid impression on her.
And I can't understand you being as close to the President
as you are and working with him as long as you have and knowing
him as well as you do, that you wouldn't remember these people
and remember this incident, because obviously he says, hey,
these people shouldn't have been in there.
Ms. Hernreich. That's what I remember, what the President
said to me.
Mr. Burton. But you don't----
Ms. Hernreich. That makes a very vivid impression upon me.
But, no, I do not remember--again, everything indicates they
were there.
What I'm saying is, there's no denial that they were there.
I just cannot tell you anything that transpired in the room. I
have no visualization of what went on that day. And my
recollection, although it could have happened in the Oval
Office, that the President stepped out into the outer office
when he said that to me after the radio address. It could have
occurred in the Oval Office. But that's my recollection.
But what I do remember, Mr. Chairman, is that he said that
to me. And as you said, your assistant would remember something
like that. That's--that's the part that I remember. We have had
15----
Mr. Burton. All right.
Ms. Hernreich [continuing]. Thousand people probably go
through there on radio addresses. It's impossible to remember
everything--everybody that has gone through there. But I do
remember that the President said that to me.
Mr. Burton. I understand. But the pictures weren't sent?
Ms. Hernreich. That's my recollection, Mr. Chairman.
Mr. Burton. Why? I mean, you don't remember the people. You
don't remember Johnny Chung being there. You do remember the
President admonishing you that they shouldn't have been there.
Ms. Hernreich. Correct.
Mr. Burton. And then the pictures weren't sent. Why? Do you
have any idea why the pictures were not sent, why he didn't
want them sent?
Ms. Hernreich. I don't think that's what the President said
to me. He did not tell me not to send the photographs. He just
said to me, we shouldn't have done that. That's my
recollection, that there was nothing--he didn't say anything to
me about photographs. And my recollection is that--that we did
not send the photographs.
I didn't necessarily recall that that's what NSC said,
because in the memo that we now see from Mr. Suettinger, he
said it was OK to release the photographs, although I did not
have that information at the time.
But if I made the decision not to send the photos, it was
either because the NSC said it or because I thought, let's err
on the side of caution here. And if there's any question about
that whatsoever, let's not send the photographs out.
Mr. Burton. Ms. Crawford, you know who Mr. Wiriadinata was,
the gardener that gave $400,000 to the DNC?
Ms. Crawford. No. I--that name I can't recall.
Mr. Burton. Were you in the room when he was there; do you
recall?
Ms. Crawford. I do not know.
Mr. Burton. You said you were in the room most of the time
when these people came in after a radio broadcast.
Ms. Crawford. And did this gentleman attend the radio
address; is that----
Mr. Burton. He was just there for a picture. OK. Never
mind.
Could we play this tape of Richard Sullivan, please? Could
you put that on?
[Videotape played.]
Mr. Burton. Ms. Scott, I know my time has expired, but I
would like to ask you, was there any discussion about this with
the staff and the people at the Democratic National Committee?
Ms. Scott. On what day?
Mr. Burton. About the concerns that he expressed there
about Mr. Chung.
Ms. Scott. I'm not understanding your question.
Mr. Burton. You heard what he just said there.
Ms. Scott. Right.
Mr. Burton. Was there any discussion about Johnny Chung,
about what--about this particular issue, about whether or not
people over there were concerned about getting contributions
from him because of--because of his background and because of
his hustler image?
Ms. Scott. No.
Mr. Burton. There was no discussion whatsoever?
Ms. Scott. No.
Mr. Burton. So the only person was Mr. Sullivan that had
that concern?
Ms. Scott. I can't speak on behalf of Mr. Sullivan.
Mr. Burton. I see.
Who seeks time on your side?
Mr. Waxman. I'll reserve my time----
Mr. Fattah. I'll seek time.
Mr. Waxman [continuing]. And pass at that point.
Mr. Fattah. I'll seek time.
Mr. Burton. Mr. Cummings.
Mr. Fattah. No, Fattah.
Mr. Burton. Oh, that's right. You were in the 30 minutes.
Mr. Fattah.
Mr. Fattah. Yes. Thank you, Mr. Chairman.
Let me just walk back through this, Ms. Hernreich. You're
in charge of a major operation that has to do with access to
the President, him getting his work done----
Ms. Hernreich. That's correct.
Mr. Fattah [continuing]. On behalf of the country. And you
have a number of employees who work for you?
Ms. Hernreich. That's right.
Mr. Fattah. So when the President is doing something that's
on his schedule, more likely than not, you're thinking about
the next thing and the next thing and the next thing that's on
the schedule.
Ms. Hernreich. Usually I have other work to do.
Mr. Fattah. OK. So radio addresses are regular events that
take place?
Ms. Hernreich. That's correct.
Mr. Fattah. And I hate to shatter the public image of this,
but these are not extemporaneous comments by the President into
a radio microphone, right?
Ms. Hernreich. That's correct.
Mr. Fattah. These remarks are prepared well in advance.
There's a sense of what is going to happen. So, for you,
there's not a lot of drama in a radio address.
Ms. Hernreich. That's correct.
Mr. Fattah. So the fact that you say, well, the President
was having a radio address, and I was doing my other work, in
the context of the world that you live in, it makes a lot of
sense, right?
Ms. Hernreich. Yes. I mean, again, that's as I recall it.
You know, I could have been in the room; I just don't remember
it. And I want to make that clear: There are times that I go
into radio addresses, and there are times that I stay outside
and do other work.
Mr. Fattah. I just want to get a sense of this. You know
the President was over on Capitol Hill the other day, and my
staff was up looking out the windows and stuff. You see the
President all the time, right?
Ms. Hernreich. That's right.
Mr. Fattah. So you're not going to be up because they say
the President is walking by, you're not going to be jumping up
to see the President of the United States. I mean, you're on
the inside?
Ms. Hernreich. Yeah, you're correct about that statement.
Mr. Fattah. So the point that the chairman was making about
your recollection about the radio event, there's no
disagreement that these gentlemen came in with Johnny Chung
into the radio address.
Ms. Hernreich. That's correct.
Mr. Waxman. There are pictures of it, in fact?
Ms. Hernreich. That's correct.
Mr. Fattah. There's videotape of it?
Ms. Hernreich. That's correct.
Mr. Fattah. And they were put on a list by Ms. Crawford,
who works under you; is that correct?
Ms. Hernreich. That's correct.
Mr. Fattah. And that list was eventually run by you before
the radio address took place?
Ms. Hernreich. Well, I assume so. I am not absolutely
certain of that, but I assume so.
Mr. Fattah. But it would normally have been?
Ms. Hernreich. That's correct.
Mr. Fattah. OK. So there's no mystery surrounding this
event whatsoever?
Ms. Hernreich. That's right.
Mr. Fattah. Now, there's a mystery--at least on my part,
not on your part--as to why the committee is so focused on this
matter. Because again there's no information whatsoever that
these people's appearance at the radio address in any way,
shape, or form has anything to do with foreign contributions,
illegal contributions into the 1996 elections.
Now, there was testimony under oath by Haley Barbour in the
Senate that he traveled to Hong Kong--he was on a yacht there;
he requested $2 million--that he got those dollars. He put it
into the national policy forum which he was the chairman of
while he was the chairman of the RNC. In fact, when the policy
forum was created, the paperwork chart showed that as a
subsidiary of the RNC. And they spelled out in the paperwork
that they were creating this 501(c)(3) so that they could take
foreign money.
So then he set up an entity to take foreign money. He went
to a foreign land, received a couple million dollars in foreign
dollars. That went into the election of Republicans to the U.S.
Congress. In fact, it was requested specifically to go into
some 60 targeted races.
And then the gentleman who helped facilitate this money
asked him not for a letter like the letter that Don Fowler
wrote for Johnny Chung; he asked him to travel to China with
him. The chairman of the Republican National Committee got up,
took his United States passport and went off to China.
So if we're looking for foreign money in an election,
there's some reason to believe that if we could stop majoring
the minors, we might be able to actually get some people in
front of us who could talk to us about foreign money coming
into an election. Because there is evidence, at least on the
record in the Senate, under oath, that these are the facts.
And we could ask the people involved in this as to why it
was that they sought to have foreign money influence the
outcome of the elections--Federal elections in the--and so, Mr.
Chairman, I would just hope as we go forward that since these
people have given us all the information, I think, that they
have at their disposal, that we would find some time on the
committee's schedule when we could bring in those who have been
involved in these activities, because I know, since we have
been so enthusiastic in our search for illegality, that this
committee would not want to miss the opportunity to scrutinize
these opportunities.
I will yield back.
Mr. Waxman. Will the gentleman yield?
Mr. Fattah. I will yield to Congressman Waxman.
Mr. Waxman. And if we really want to look at the influence
of foreign money, we ought to look at the money that's gone to
Members of Congress. Because one of the things that we learned,
just from reading the press reports about what was made, the
to-do that was made about the Chinese Government maybe doing
something, they were looking at Congress. They were trying to
influence the Congress of the United States. And we've got a
lot of other reports of Members of Congress that have been
influenced with foreign money or by supporters of foreign
policy issues.
If we want to look at that question, let's look at it
across the board, not just at the President, not just at the
Democrats, but some of the Republicans as well.
I thank you for yielding to me.
Mr. Fattah. I yield back the balance of my time.
Mr. Burton. The gentleman yields back the balance of his
time.
We intend to have hearings on the question of foreign
money. We will do that at some point in the future.
Mr. Horn.
Mr. Horn. Thank you very much, Mr. Chairman. I'm going to
be using exhibits 196, 198, and 240. And my question is
addressed to Ms. Crawford who, I believe at the time we're
discussing, which is April 7, 1995, you were Deputy--or you
were former Staff Assistant to Nancy Hernreich at the White
House; is that not correct?
[Note.--Exhibits 196 and 198 may be found on pp. 715 and
717.]
[Exhibit 240 follows:]
[GRAPHIC] [TIFF OMITTED] T5667.429
Ms. Crawford. That's correct.
Mr. Horn. What I'm curious--if you remember, looking at
exhibit 196, did you happen to call up Melanie Darby on the NSC
staff to give her information on the delegation from China that
was coming?
Ms. Crawford. I don't recall specifically calling Ms. Darby
about this. But she would have been the appropriate person. She
worked in the National Security Council for Nancy Soderberg who
this list had gone to on the 13th. And she was--would have been
sort of my counterpart. So it would not have been unusual for
me to contact her and followup on these.
Mr. Horn. Well, what I'm looking at here is April 7, 1995,
10:12 a.m., Melanie Darby sends this e-mail, electronic mail,
to Robert L. Suettinger. Now, here's what it says:
An odd situation in which I need some guidance for the
President's office as soon as possible.
A couple of weeks ago, late Friday night, the head of the
Democratic National Committee asked the President's office to
include several people in the President's Saturday radio
address. They did so and not knowing anything about them except
that they were Democratic National Committee contributors.
It turns out they are various Chinese gurus, and the
President of the United States wasn't sure we would want photos
of him with these people circulating around. Johnny Chung, one
of the people on the list, is coming in to see Nancy Hernreich
tomorrow, and Nancy needs to know urgently whether or not she
can give him the pictures. Could you please review the list as
soon as possible and give me your advice on whether we want
these photos floating around. For your information, these
people are major Democratic National Committee contributors.
And if we can give them the photos, the President's office
would like to do so.
Now, the major Democratic National Committee contributors
are the chairman, China Council for the Promotion of
International Trade; chairman, China Commerce of International
Commerce; the president, China Petrochemical Corp.; the vice
president, China International Trust and Investment Corp.; the
vice chairman and president of Shanghai A.J. Share Holding
Corp.; then James J. Sun is the young entrepreneur in this
Chinese city, self-made multimillionaire; and then the chief of
the American Oceanic Affairs Division Liaison Department and so
forth; and Johnny Chung, chairman and CEO of his own firm.
Now, I take it most of the people on this list are aliens,
are not U.S. citizens. And yet, they're noted here as major
Democratic National Committee contributors. And that, he is
taking, I assume here, or rather Ms. Melanie Darby is taking
this as background that probably someone from the President's
office, either you or Mrs. Nancy Hernreich are the ones. And I
assume perhaps Mr. Sullivan gave it to you. Or whoever it is
that gave the information from the Democratic National
Committee. Am I wrong on these assumptions? It seems to me that
here we have evidence that aliens are contributing to the
Democratic National Committee, foreigners, not citizens of the
United States.
Ms. Crawford. I don't recall a specific conversation with
Brooke Darby and what I may have or may not have told her.
Mr. Horn. Well, you work for Nancy Hernreich. Did you, Ms.
Hernreich, call Melanie Darby and give her the background and
ask for some advice and information?
Ms. Hernreich. I have no recollection of calling Brooke
Darby--she's called Brooke by the way--about this. But I think
in the other, and I can't remember what number it was, what it
appears that I did was, shortly after the radio address, wrote
a note on the list of the people who attended that radio
address to Nancy Soderberg who is, who Melanie B. Darby works
for. And that seems to have been, and that one indicates on
there that the someone from the DNC asked us to let them into
the radio address.
She may have meant--decided from that note, to then phrase
this--this e-mail in this way. I don't know. I don't recall
ever having a conversation with her about this. And, in fact, I
probably would not have had a conversation with her. What I did
was send the note, and you all can read what I put on the note.
And it doesn't say that I thought that these people were DNC
contributors.
Mr. Horn. Earlier, the chairman asked certain questions
about how one is cleared into the White House.
Ms. Hernreich. Yes.
Mr. Horn. I gather, when you have somebody that you've
arranged or somebody wishes you to arrange a meeting with the
President, just if it's sitting in the radio show, having
pictures, photos, whatever, that you make a call to the Secret
Service, I assume, give him the list of people. And do they
have to do more than that? Do they need, if they are American
citizens, the Social Security number? Or what? How do you do it
with foreign nationals?
Ms. Hernreich. We have a new procedure that we have put
into place now.
Mr. Horn. Since this time?
Ms. Hernreich. Yes, since this time.
Mr. Horn. What was it then?
Ms. Hernreich. I don't know what it was then. I think what
we did then, which was probably give, if they weren't American
citizens, give passport numbers and names. We would send those
to the Secret Service. And then they make a determination if
they, if the person can come into the White House.
Mr. Horn. I would like to ask the chairman and the general
counsel for us, chief counsel, do we have those records from
the Secret Service as to who came in and how they were
admitted?
Mr. Bennett. We do not have all those records, Congressman.
We're in the process of talking to Mr. Ruff's office about many
records at the White House. And Mr. Ruff is seeking to be
cooperative, but we do not have all those records, no.
Mr. Burton. But we will check into it.
Mr. Horn. All right. This electronic mail, as I said, was
April 7, 1995, 10:12 a.m. to Robert L. Suettinger. Now, here's
his reply, since it was urgent that they wanted information, 1
hour 12 minutes later, sent at 11:24 a.m., April 7, 1995.
And he says the following to Melanie Darby: ``The joys of
balancing foreign policy considerations against domestic
politics. I don't see any lasting damage to U.S. foreign policy
from giving Johnny Chung the pictures. And to the degree it
motivates him to continue contributing to the Democratic
National Committee, who am I to complain? Neither do I see any
unalloyed benefit either. But as far as the other Chinese on
the list are concerned, they all seem to be bona fide, present
or former, Chinese officials with the possible exception of
James Y. Sun, `young entrepreneur and self-made millionaire' ''
with quotes around it. ``Got some doubts there. Notwithstanding
that, these guys will all hang the pictures on the wall and
feel grateful for a memory.
``But a caution, a warning of futures deja vu. Having
recently counseled a young intern from the First Lady's office
who had been offered a, quote, `dream job,' unquote, by Johnny
Chung, I think he should be treated with a pinch of suspicion.
My impression is that he's a hustler and appears to be involved
in setting up some kind of consulting operation who will thrive
by bringing Chinese entrepreneurs into town for exposure to
high level U.S. officials.
``My concern is that he will continue to make efforts to
bring his friends, in quotes, into contact with the President
of the United States and the First Lady of the United States to
show one and all he's a big shot, thereby enhancing his
business.
``I would venture a guess that not all of his business
ventures or those of his clients would be the ones the
President would support. I also predict that he will become a
royal pain because he will expect to get similar treatment for
future visits. He will be persistent. Signed Bob.'' And this
Bob, I don't know, is not related to CIA Bob we hear about.
Mr. Burton. The gentleman's time has expired.
Mr. Horn. But this is Bob Suettinger otherwise known as
Robert Suettinger.
Mr. Burton. The gentleman's time has expired.
Mr. Cummings.
Mr. Cummings. Mr. Chairman, I was very pleased to hear you
saying that we are going to be looking beyond where we've
looked, because certainly, as Mr. Fattah and Mr. Waxman have
said, we definitely need to look at the Congress of the United
States of America. And we also need to look at both parties and
I'm glad to hear that. And certainly we will hold you to that.
I just want to cite something that I find very interesting,
as we go down this road of leading to nowhere. By the way, the
New York Times on January 27th has a very interesting article,
1997. It says $250,000 buys donors best access to Congress.
It says, for elite donors who contributed at least
$250,000, the Republican party offered a new enticement in it's
gilded invitations to the party's convention in San Diego last
summer. Beyond the smorgasbord of perks like access to the
party's private sky box and a photo session with Republican
nominees, the party promised special benefit, staff members to
help with the problems in Washington.
In fund-raising circles, these $250,000 donors, and I
emphasize $250,000 donors, became known as season ticket
holders. At least 75 corporations and individuals gave $250,000
or more to the Republican party last year setting a new
standard for political giving that by far surpasses previous
election years when top donors generally gave $100,000 to join
the Team 100 Club.
According to solicitation letters, invitations and
interviews with dozens of Republican fund-raisers, the
Republicans have focused on large corporations and individuals
with interests pending on Capitol Hill. Quote, ``there is no
question, if you give a lot of money, you will get a lot of
access, said a senior executive whose corporation gave $500,000
to the Republicans. All you have to do is send in the check.''
The $250,000 season ticket was pitched as an entre to the
party's inner circle and the best access to Congress. And
that's quote. He said, adding, it is literally touted as being
in the inner sanctum and the creme de la creme.
Most fund-raisers and donors spoke on the condition of
anonymity. And he went on to say, I think it is fair to say
that everyone in our organization from the CEO down finds this
atmosphere to be corrosive and unproductive, said an executive
whose corporation donated more than $300,000. Quote, you play
because your competitors play. At least from our perspective,
we would much rather take a number at the door of a Congress
person's office, sit down like any other citizen, and when our
number is called, go in, state our case, and then leave. I
thought that this is what the Constitution says how it should
be, end of quote.
That article and those quotes call out for us, Mr.
Chairman, to look at this entire process. And I'm just curious,
to these ladies that are sitting in front of you, do all of you
have lawyers?
Ms. Hernreich. Do all of--I'm sorry, what did you say?
Mr. Cummings. Do all of you have lawyers representing you?
Ms. Khare. Yes.
Ms. Hernreich. Yes.
Mr. Cummings. And it's interesting, Mr. Chairman, when I
heard the figures that were paid by Maggie Williams to defend
herself in coming from Paris, and I'm sure these ladies, had to
find money, and take time to do this. The question then becomes
what is our aim? Where are we going?
As I've said many times before, I think the American people
basically want to see their tax dollars spent in a cost-
efficient and effective manner. That's all they want. And we
seem like we're on our road down this Alice in Wonderland
situation where we're trying to present something. But it
reminds me of a few years ago when I was a child when HUD had a
commercial, and the commercial was about home buying and
basically telling the people to be careful when they go out to
buy a house. So they had this big wonderful front. I'll never
forget it. I was 6 or 7 years old. Big, big front. And the
person goes and opens the door, and there's nothing behind it.
And so this whole episode reminds me of that. And I think
that it's important that the American people understand where
we're going. The Senate did their hearings. Senator Fred
Thompson, in all due respect, came out with all of these
allegations from the very beginning. And when the door was
opened, even he had to admit that there was nothing behind it.
And here we are again spending taxpayers' money, taxpayers
that are looking at this right now trying to figure out how
they're going to get their kids through college, trying to
figure out how they're going to have food on the table, trying
to figure out how they're going to pay the taxes that are going
to come due very shortly, but at the same time, they watch
their Government bring in these wonderful ladies with their
lawyers sitting right behind them and watch their Congress
people that are paid $130 some thousand a year, sit here and go
down this Alice-in-Wonderland situation.
They, too, are sitting wondering when the doors open and
there is nothing behind it, nothing, they ask themselves a
question, and they must become quite cynical as to where--what
we are doing.
And so I would hope, Mr. Chairman, that we would move on to
the things that are very important; that we look at Congress. I
think that should be very, very interesting. And perhaps, when
we open the door, we will see something behind it, because
maybe there is. Thank you very much.
Mr. Burton. The gentleman yields back the balance of his
time.
Mr. Cummings. Yes.
Mr. Burton. Mr. Mica.
Mr. Mica. Thank you, Mr. Chairman. We are getting toward
the end, ladies, and I appreciate your patience, and I think
you know why we're here. We're here because the very top
assistant to the First Lady, close to the President, accepted a
check. She admits she accepted a check on Government property
for $50,000.
The committee doesn't know the source of that money, but we
know that substantial foreign money was sent to the account of
Mr. Chung. We know that on March 9th he passed that check to
Ms. Williams, who came before you, for $50,000. We know that on
March--that is March 9th--on March 10th that one or two of you
were calling to get him and his Chinese delegation in to a
meeting then with the President. On the 9th, I guess--or the
10th he had his picture taken with the First Lady and used the
White House Mess at the direction of the First Lady's office.
And on the 11th he did appear with the President, and the
President you have testified, is upset about it.
We are a little bit concerned that we don't know where that
money came from. We're a little bit concerned that, Ms. Scott,
you told the committee that you think that you spoke to Ms.
Williams about the request to get these folks in.
Did you speak to Ms. Williams or someone in the First
Lady's office; is that correct?
Ms. Scott. I said that I think that I spoke to someone in
the First Lady's office. I did not specifically say Ms.
Williams.
Mr. Mica. Well, again, we're trying to sort out where these
directives came from, where this money came from, and we hope
to get to the bottom of it by talking to Mr. Chung and see how,
in a matter of a couple of days here, by giving $50,000 he not
only spent time with the First Lady, but also ended up with the
President of the United States, with four foreign nationals at
a radio address.
Some of it seems very coincidental. And then if we look at
other transactions that are made here, $125,000 April 8th, and
other contacts that were made; and we also have, if you go back
to March 13th, I think this--are you left-handed----
Ms. Hernreich. No.
Mr. Mica. Who is left?
Ms. Crawford. Well, I'm left-handed.
Mr. Mica. You are left-handed?
Ms. Hernreich. That is my handwriting.
Mr. Mica. Is that your handwriting?
Ms. Hernreich. It is my handwriting and I'm right-handed.
Ms. Hernreich. There is a left-hand check here.
Ms. Crawford. That may have been mine.
Mr. Mica. Well, someone knew, and it is marked here 3/13.
So we have the 9th the money is given, the 10th we see action
requesting this, and on the 13th already the photos. And no one
remembers the photos, even though we have testimony or
deposition by Ms. Ratliffe, who says she picked them up from
Ms. Crawford. And we have questions raised about who these
dudes are and what they are doing.
So it does raise some questions about a trail of foreign
money, about national security, about access to the President,
about receiving money on Federal property. And we are just
trying to get to the bottom of what, in fact, has gone on here,
and we will continue to pursue it.
It does cost money. In some countries they don't spend the
money. It's all swept under the table. No one knows what took
place. But the American people have a right to know and we have
an obligation to find that information out from our witnesses.
I want to thank the chairman----
Mr. Burton. Would the gentleman yield?
Mr. Mica [continuing]. For holding the meeting and yield
back my----
Mr. Burton. Would the gentleman yield before he yields back
his time?
Mr. Mica. Yes. Yes.
Mr. Burton. I'd like for exhibit 191 to be put up on the
screen. Can you bring that in a little bit closer?
Ms. Scott, you indicated a while ago that there was not a
lot of discussion over at the Democrat National Committee about
Johnny Chung. If you read this it says, Ceandra Scott called.
She was concerned about Johnny Chung. She stated that we should
have called them prior to their coming to the radio address.
Apparently they were in Maggie's office when the request came
and Maggie said she didn't know, but to contact the DNC.
It seems strange to me that there was not any discussion
over there, like you said. You said there wasn't much concern
about Mr. Chung, and yet you called Maggie's office and said
that that should have been cleared prior to them coming over
there. Why were you concerned and why does this memo say that?
[Exhibit 191 follows:]
[GRAPHIC] [TIFF OMITTED] T5667.430
Ms. Scott. The memo is addressed to Betty Currie, who is in
the Oval Office.
Mr. Burton. Yes.
Ms. Scott. What happened was after the radio address, I
made a call in to Ms. Currie, who was not there, and spoke to
someone else, I'm not sure who that person was, and they raised
concern about Mr. Chung being at the radio address with those
guests.
Mr. Burton. So there was some concern at the DNC among the
staff about Johnny Chung.
Ms. Scott. I didn't say the DNC, I said I called over to
the White House.
Mr. Burton. I know, but you were at the DNC.
Ms. Scott. Correct.
Mr. Burton. That's what I'm saying. There was concern about
him over there.
Ms. Scott. I'm unclear as to what your real question is,
Mr. Chairman.
Mr. Burton. You made this call.
Ms. Scott. I didn't make the call regarding Johnny Chung. I
just made an unspecific unrelated call to Ms. Currie. Someone
answered the phone. It was a female. I'm not sure who she was,
but stated that there was some concern about the guests of Mr.
Chung at the radio address.
Mr. Burton. If you read the note there, it says Ceandra
Scott called. She was concerned about Johnny Chung.
And when we asked the question a while ago, you indicated
there was no discussion or concern about Johnny Chung over at
the DNC.
Mr. Best. Well, Mr. Chairman, the real question for the
witness is does this refresh her recollection of such a
conversation, because this is not her memorandum.
Mr. Burton. I understand it is not her memorandum, but Ms.
Currie indicated that this was a concern that Ms. Scott had
when she called over there. That's why I'm asking the question.
Does this stimulate any recollection on your part?
Ms. Scott. Yes, it does.
Mr. Burton. It does. So there was concern at the DNC about
Johnny Chung?
Ms. Scott. I can't say the DNC. I said what happened was I
called over to Betty Currie after the radio address. She was
not in. Someone answered the phone and said there was concern
about Mr. Chung and his guests at the radio address.
I then put in a second call to Betty Currie to try to get
her once I found out, which I never made any contact with Ms.
Currie. So that's what this is about.
Mr. Burton. So then the word ``she'' does not refer to you;
is that what you are saying?
Ms. Scott. I didn't write it, so I'm unclear as to what the
``she'' is.
Mr. Burton. OK, thank you. Do we have any more--Mr. Barr.
Mr. Barr. Thank you, Mr. Chairman. Could we have exhibit
201 up? Ms. Khare, do you know the date of that? There is no
date on it. It's a fax from you to Johnny Chung about the
photos.
[Note.--Exhibit 201 may be found on p. 55.]
Ms. Khare. Apparently it was faxed on April 11, 1995, from
the fax line at the top, but----
Mr. Barr. That would be consistent with an earlier phone
message, I think, that we have seen.
Ms. Khare. I don't know about a phone message.
Mr. Barr. Could we have exhibit 195? Now, that's dated 3/
11. A date of 4/7.
[Exhibit 195 follows:]
[GRAPHIC] [TIFF OMITTED] T5667.431
Ms. Khare. This phone message--I didn't write this phone
message and it's not to me. I don't know what that is.
Mr. Barr. I wasn't saying that you did. I'm just trying to
come up with a time line.
Could we have exhibit 215, please? This document says, as
of 11/22/95, per Bob McNeely, he will not honor request from
Johnny Chung, CEO of AISI. He has been improperly using photo
of businesspeople and the President.
Do any of you have any knowledge of that?
[Note.--Exhibit 215 may be found on p. 721.]
Ms. Khare. No, I don't.
Mr. Barr. That would seem to indicate that the photos did
go out, though; would it not?
Ms. Hernreich. Yeah, again, all I can say is my
recollection of this is that he asked for photos and that we
did not send the ones of the group with him. If he obtained
them through some other office or some other way, I don't know.
You know, I think what's possible, that could have
happened, is that the photo of him and his brother could have
been released but of the large group wasn't. I don't know for
sure. And my memory can be incorrect on this, but my memory is
that we did not send the photos out.
But there are other ways for them to get the photos.
Anybody can order photos, but that was my recollection. And it
could have been another, not the photos of the group, it could
have been just of him and his brother.
Mr. Barr. On exhibit 198, down at the bottom, it talks
again about the photos, way down at the bottom there. And the
last sentence there, the parenthetical, the President's office
would like to do so, talking about giving them the photos.
Who does that refer to? Who would be representing the
President's office in that context?
[Note.--Exhibit 198 may be found on p. 717.]
Ms. Crawford. I mean, I dealt with photographs in the
President's office, but I don't recall a specific conversation
with Brooke, or I don't know why I would have any stake in
whether or not Mr. Chung got his photographs or not.
Mr. Barr. Well, one would presume that Darby Brooke would
not just make that up. I mean, that wouldn't be a fair
presumption, would it; that she just made up----
Ms. Crawford. I assume that she did not make that up.
Mr. Barr. Right, I would presume that, too. But none of you
all, in searching your memory and your vast knowledge of how
things work at the White House can think of anywhere that would
have come from, that the President's office would like the
photos to come out?
Ms. Crawford. The only thing that I can come up with is
that Mr. Chung was persistent about wanting the photographs,
but I don't think----
Mr. Barr. Yes, but he doesn't speak for the President's
office, does he; Mr. Chung?
Ms. Crawford. No.
Mr. Barr. I wouldn't think so. Somebody must have been
speaking for the President's office to cause Darby Brooke to
make a very specific reference to the President's office
wanting the photos to go out. Would that be a fair assumption?
Ms. Crawford. I don't know what Ms. Darby, you know, why
she would have written this. I can't speculate.
Mr. Barr. Well, you could. If you are not speculating,
that's different from saying you can't speculate. I mean all
I'm trying to do----
Ms. Crawford. Would you like me to speculate?
Mr. Barr. There seems to be some confusion here, and nobody
wants to own up to anybody wanting the photos to go out. There
seems to be a clear indication here that somebody over at the
White House did, and I'm just curious as to who at the White
House did want the photos to go out or whether Darby Brooke
just sort of made that up.
Ms. Hernreich. Congressman, I think that the chairman, or
someone has indicated that you will have these people tomorrow
and maybe they can answer the questions and their memories
might be better than ours on it, and certainly accept if they
say they got it from us.
Mr. Barr. That would be nice.
Ms. Hernreich. Yeah, it would be. I would like to know
myself, really.
Mr. Barr. Thank you.
Mr. Burton. Does the gentleman yield back the balance of
his time?
Mr. Barr. Yes, sir.
Mr. Burton. The gentleman yields back the balance of his
time.
Mr. Barrett, we are only going to have two more people
question, in all probability, if the gentleman has any more
questions this evening.
OK. Mr. Cox.
Mr. Cox. I thank the chairman. Ms. Hernreich.
Ms. Hernreich. Yes.
Mr. Cox. As the person responsible for Oval Office
operations, you have some familiarity with what goes in and out
of the President's office. Isn't that essentially the job?
Ms. Hernreich. Yes.
Mr. Cox. And that includes correspondence?
Ms. Hernreich. Yes.
Mr. Cox. Now, as I understand it, some of the
correspondence that the President receives is separately
answered because it's not of a business nature but of a
personal nature; is that the way it works?
Ms. Hernreich. Yes.
Mr. Cox. And the category of whether correspondence is
personal or not is dependent on what?
Ms. Hernreich. Well, we have--at the beginning of the
administration we sent out a letter to a group of friends and
it gave them a private zip code. So, originally, all of the
personal correspondence, where people who were writing in to
that particular zip code--so that is how it started.
And then, as we were able to determine, as other people
would write, the correspondence, the general correspondence
department would then decide, pick those letters out and say,
well, this sounds very personal, send it over to the personal
correspondence department. We would make a determination, yes,
this is somebody the President knows personally and, yes, we
should answer this. This is of a personal nature. So that is
generally how that happens.
Mr. Cox. And does the President see personal correspondence
as it goes out?
Ms. Hernreich. Not every single piece of it, but generally,
yes.
Mr. Cox. Because these are people that he personally wishes
to keep up with?
Ms. Hernreich. Yes. It's people that he will see often, and
would--not often, but would see periodically, and it would be
people that he would want to keep up with as well, but----
Mr. Cox. Now, it's my understanding that in response to a
question from the ranking member you have indicated that Johnny
Chung, not for correspondence purposes, but just in the plain
English sense, was a personal friend of the President's.
Ms. Hernreich. What I said, I would correct it a little
bit, I think the President considers a lot of people his
friends, and he considers his supporters his friends. This is a
man who loves people and he has literally, in my mind, millions
of friends. And he honestly considers a very wide group of
people his friends. So he considers Johnny Chung----
Mr. Cox. All right. Now, the videotape that we saw of----
Ms. Heinrich. Pardon me.
Mr. Cox. The videotape we watched earlier of the Oval
Office meeting with the Chinese guests that Johnny Chung
brought in with him, the President sort of bear hugged Johnny
Chung and was very happy to see him and greeted him by name and
so on. And it is not in the sense that the President has
millions of friends, but in the sense that he actually knew
Johnny Chung that he is a personal friend; is that right?
Ms. Heinrich. I assume so, yes. By the appearance of that
videotape.
Mr. Cox. Was Johnny Chung part of the group of
correspondents who was treated as a personal correspondent?
Ms. Hernreich. That was really initially a very small
group. And Kelly and I put that list together in transition
from a--and we had very little time to do it. So we used a very
limited list to begin with. And there were people, just high
school and college friends and that sort of thing. Because
those were really the only ones that we had to deal with at the
time. And we were in quite a hurry to let people know that they
could, those people could contact the President.
Mr. Cox. And is Johnny Chung in that group?
Ms. Hernreich. He was not in that group of high school and
college friends and Rhodes Scholar friends and that group that
received that zip code. There were only a very small number who
received the zip code.
Again, we had a limited number of time to go through the
list. We had limited lists at our disposal to go through, and
we were in a hurry to get that information out, so----
Mr. Cox. The President himself occasionally gave people
this zip code; right?
Ms. Hernreich. I think he did, yes.
Mr. Cox. So it wasn't just college friends and so on that
had the zip code?
Ms. Hernreich. Eventually, as I--it expanded. And again we
received and would answer letters that came from correspondents
that people, they were able to determine that would fall into
that category as well.
Mr. Cox. So you had to be an even better friend than Johnny
Chung to get a zip code; is that it?
Ms. Hernreich. I'm not sure that, again, that I ever had a
list. The only reason that Johnny Chung didn't fall--the only
list I think I really had at my disposal at that time were high
school, college, Rhodes Scholar and some Arkansans. So I didn't
have a wide variety of lists of everybody in the United States
who was ever his friend to send to him to say mark the people
you want me to send the zip code to.
Mr. Cox. It was a discrete and limited list.
Ms. Hernreich. Yes. It was primarily people, and that was
it. I just didn't have those lists to send to him with every
name of every person he had ever met.
Mr. Cox. Did James Riady get a zip code?
Ms. Hernreich. I don't know if James Riady got the zip
code. I doubt it, initially, because he would not have been on
an Arkansas list and he would not have been on any of those
categories. But I can't say for sure.
Mr. Cox. In your deposition you said you thought he did.
Ms. Hernreich. Yeah, I don't know. Again, I just said--now
I would say I doubt it, for that reason. I can go back and
check and clarify it, but I can't do it in this very--at this
time.
Mr. Cox. OK. It would be informative to know whether in
that inner circle of people if we included James Riady.
I yield back.
Mr. Burton. Would you be willing to answer some questions
that we would write to you and send to you?
Ms. Hernreich. Regarding this?
Mr. Burton. Regarding this.
Ms. Hernreich. Yeah, I would be.
Mr. Burton. We will send you some questions we would like
to ask.
Do we have further----
Mr. Waxman. Just a quick question. If we asked you to take
all the people the President has seen over the course of the
year and rank them in the order how close a friend they were,
do you think you would be able to do that for us?
Ms. Hernreich. All of them that he sees in a year? No, I
can't. Not like that.
Mr. Waxman. Obviously, I'm being facetious, because I just
can't understand how at 5:20 in the afternoon this committee
hearing, which has done nothing but turn over the same
information that has already been made available, we are
already down to a level of how close a friend Johnny Chung was.
Mr. Burton. Henry.
Mr. Waxman. Mr. Chairman, I haven't had my 5 minutes, and I
won't take it if you don't interrupt me.
Mr. Burton. This is your first 5 minutes?
Mr. Waxman. My first 5 minutes.
Mr. Burton. Well, give him the 5 minutes.
Mr. Fattah. Will the gentleman yield for a second?
Mr. Waxman. Certainly.
Mr. Fattah. I know we have the authority to ask for
anything under the sun, but what the relevance is of asking her
about the President's personal correspondence list, unless
there is some evidence that someone has done something wrong, I
think it's--you know, it just shows the stretch of this wide
ranging investigation into nothing.
Now, if we want to investigate whether James Riady has done
something improper, that seems entirely appropriate. But to
know whether or not he is on a list seems to be a stretch, and
I would just hope that the committee would try to confine
itself to focusing in on what was the alleged challenge of the
committee, which was to look at illegal foreign contributions
and improper activities relative to the 1996 list. Who is on my
personal correspondence list or the President's seems to be
somewhat off point.
The last thing I want to say is that the Speaker of the
House has said that President Clinton has a unique ability to
make everyone feel as though they are someone that he is close
to. It is an ability that I'm sure many politicians would hope
that they could emulate.
Mr. Waxman. If the gentleman would permit, the Speaker even
said that he melted in the presence of the President because he
is so charismatic.
Mr. Fattah. Indeed. In fact, part of the revolution against
Newt Gingrich was that they thought he had went over to the
White House and been corrupted by the charisma of Bill Clinton.
So I think that----
Mr. Waxman. I think he could have gotten invited to a White
House radio address or something.
Mr. Fattah. Or something. So I think that we are far
afield. And I think if we look at the questions that have been
emulating from the majority side for this panel, just look at
them, none of them have anything whatsoever to do with what we
are supposed to be investigating.
So I just want to yield back my time, and I don't mean that
as a personal criticism. I just think that it shows that the
investigation of this committee has no focus in terms of its
charge, and that is why the Thompson committee went out of
business. So if we are going to have some reason to be here, we
should at least have a focus of what we are trying to
accomplish.
Mr. Waxman. It keeps us off the streets.
I am going to yield to Mr. Barrett, if he wants to take
some of this time.
Mr. Barrett. Thank you, Mr. Waxman. And I had the
opportunity to watch your testimony in my office. I think you
all did a very good job. I don't think it's necessary, really,
to carry this on further.
But as I was sitting here I was thinking about, frankly,
the President's ability to know people. And I recall when I was
first elected in 1992, the same time he was, and then he came
into the Democratic Caucus and was fielding questions. And he
went around the room and he knew everybody's name and the
issues that were important to them. And I thought, man, he's
not going to know who I am, I'm not going to raise my hand. But
he knew everybody in the room, which I thought was just
amazing.
And then in, it must have been 1994, I was out about 7 a.m.
jogging one morning down the Mall, and who comes running toward
me but the President with his little entourage of Secret
Service agents. And he came over to me and said hi, Tom, how
are you doing, and greeted me and asked me about a bill and how
things were going. And we talked for about 35 or 40 seconds and
then we both went our separate ways.
And even at 7 a.m., there were some tourists on the Mall,
and as I was running, they were now looking at me because the
President of the United States had just stopped to talk to me.
So I turned to them and said, hey, who was that guy.
But my question, I guess for you, Ms. Hernreich, is are you
as good as the President in remembering people and names?
Ms. Hernreich. Not at all. I wish I was. He has a wonderful
memory. And the thing about it is, this is a man who really
cares about people. He loves people. And he considers many
people his friends. And so I--you know, there's--I don't know,
it seems to me that, honestly, and maybe I shouldn't
editorialize here, but what difference that it makes who is on
the personal correspondence list or who isn't, this is a man
who loves people, considers everyone his friend, and would be
happy to have everybody, you know, have his personal
correspondence code and write him personal letters. He would
love to sit and read every one of them and answer every one of
them personally.
Mr. Barrett. OK. Thank all four of you for your time today.
Mr. Waxman. Mr. Chairman, I yield back the balance of my
time.
Mr. Burton. Gentleman yields back the balance of his time.
In conclusion, let me just say--did you have anything else you
wanted to say? Mr. Cox.
Mr. Cox. Well, yes, just because my time expired on the
questions that I began, and I won't resume, but I think it is
rather obvious that in response to my colleague's rhetorical
question that James Riady is, in fact, at the center of an
investigation into illegal foreign payments to the executive
branch of our Government, and inquiring about the level of
involvement of James Riady in the White House, all the way to
the extent of having a special code that he can put on his mail
so that it bypasses the staff, bypasses the correspondence
office and goes directly to the President, I think is very much
to the point.
Mr. Burton. Well, let me conclude by saying that the reason
the investigation continues is because millions of dollars of
illegal contributions have been found and returned, No. 1.
No. 2, we have 66 or so people who have taken the fifth
amendment or fled the country, and so we are having a difficult
time getting this information. And until we get satisfactory
answers, unfortunately very fine people like these ladies are
going to be called up here to try to help us fit the pieces of
the puzzle together.
I do appreciate, and I'm sure the committee appreciates
your patience today, because we had so much that we had to
cover and you had to sit there and wait for many hours. So we
do appreciate that, and we apologize for the amount of time you
had to just sit there and cool your heels.
The committee, unless there is further business, will stand
in recess until 12 noon tomorrow.
Mr. Barrett. Mr. Chairman, just as an inquiry, can you give
us a little preview of tomorrow, what you are planning?
Mr. Burton. Tomorrow there will be a deposition which will
take place starting at 9 a.m. of Mr. Huang--or Mr. Chung,
pardon me. And, hopefully, that deposition will be concluded by
10:30 or 11 o'clock.
What we wanted to do was to start the hearing at noon, and
I think we can stick pretty close to that schedule.
Mr. Barrett. And where will that deposition be? Have we
been informed of that?
Mr. Burton. The deposition will be held at the--what room
will we have that in?
Mr. Bennett. Congressman, the deposition will be held here
in the Rayburn Building, but I've talked to Mr. Ballen,
minority counsel, and in terms of certain considerations of the
witness, we are not really announcing at this point in time
exactly what room the deposition will be in. All the members of
the committee will be advised what room we are going to be in.
Mr. Barrett. Prior to the start of that.
Mr. Bennett. Yes, certainly.
Mr. Burton. We will make sure you and any other Member who
would like to participate in the deposition will be made aware
of where it is. We just don't want a whole gaggle of people
waiting outside.
Mr. Barrett. I understand. Thank you very much.
Mr. Burton. The committee stands in recess until tomorrow.
[Whereupon, at 5:25 p.m., the committee was adjourned.]
[Responses to Interrogatories of Nancy Hernreich follow:]
[GRAPHIC] [TIFF OMITTED] T5667.432
[The depositions of Kelly Ann Crawford and Carol Khare
follow:]
Executive Session
Committee on Government Reform and Oversight,
U.S. House of Representatives,
Washington, DC.
DEPOSITION OF: KELLY ANN CRAWFORD
Monday, November 10, 1997
The deposition in the above matter was held in Room 2247, Rayburn
House Office Building, commencing at 10:00 a.m.
Appearances:
Staff Present for the Government Reform and Oversight Committee:
Jennifer M. Safavian, Investigative Counsel; Jason Hopfer,
Investigative Attorney; and Andrew J. McLaughlin, Minority Counsel.
For KELLY ANN CRAWFORD:
DAVID A. WILSON, ESQ.
Hale and Dorr
1455 Pennsylvania Avenue, N.W.
Washington, D.C. 20004
Ms. Safavian. Good morning. On behalf of the members of the
Committee on Government Reform and Oversight, I appreciate and thank
you for appearing here today.
This proceeding is known as a deposition. The person transcribing
this proceeding is a House reporter and notary public. I will now
request that the reporter place you under oath.
THEREUPON, KELLY ANN CRAWFORD, a witness, was called for examination by
Counsel, and after having been first duly sworn, was examined and
testified as follows:
Ms. Safavian. I would like to note for the record those who are
present at the beginning of this deposition. My name is Jennifer
Safavian, designated majority counsel for the Committee. I am
accompanied today by Jason Hopfer who is with the majority staff.
Andrew McLaughlin is the designated minority counsel for the Committee.
The deponent is represented by David Wilson.
Although this proceeding is being held in a somewhat informal
atmosphere, because you have been placed under oath your testimony here
today has the same force and effect as if you were testifying before
the Committee or in a courtroom.
If I ask you about conversations you have had in the past and you
are unable to recall the exact words used in the conversation, you may
state that you are unable to recall those exact words and then you may
give me the gist or substance of any such conversation, to the best of
your recollection. If you recall any part of a conversation or only
part of an event, please give me your best recollection of those events
or parts of conversations that you recall. If I ask you whether you
have any information upon a particular subject, and you have overheard
other persons conversing with each other regarding it or have seen
correspondence or documentation regarding it, please tell me that you
do have such information and indicate the source, either a conversation
or documentation or otherwise, from which you derive such knowledge.
Before we begin the questioning, I want to give you some background
about the investigation and your appearance here.
Pursuant to its authority under House rules X and XI of the House
of Representatives, the Committee is engaged in a wide-ranging review
of possible political fund-raising improprieties and possible
violations of law under the Committee's jurisdiction.
Pages 2 through 4 of House Report 105-139 summarizes the
investigation as of June 19, 1997 and encompasses any new matters which
arise directly or indirectly in the course of the investigation. Also,
pages 4 through 11 of the report explain the background of the
investigation. All questions related either directly or indirectly to
these issues, or questions which have a tendency to make the existence
of any pertinent fact more or less probable than it would be without
the evidence, are proper.
The Committee has been granted specific authorization to conduct
this deposition pursuant to House Resolution 167, which passed the full
House on June 20, 1997. Committee Rule 20, of which you have received a
copy, outlines the ground rules for the deposition.
Majority and minority Committee counsels will ask you questions
regarding the subject matter of the investigation. Minority counsel
will ask questions after majority counsel has finished. After minority
counsel has completed questioning you, a new round of questioning may
begin. Members of Congress who wish to ask questions will be afforded
an immediate opportunity to ask their questions. When they are
finished, Committee counsel will resume questioning.
Pursuant to the Committee's rules, you are allowed to have an
attorney present to advise you of your rights. Any objection raised
during the course of the deposition shall be stated for the record. If
the witness is instructed not to answer a question or otherwise refuses
to answer a question, majority and minority counsel will confer to
determine whether the objection is proper. If counsel agree that a
question is proper, the witness will be asked to answer the question.
If an objection is not withdrawn, the Chairman or a member designated
by the Chairman may decide whether the objection is proper.
This deposition is considered as taken in executive session of the
Committee, which means it may not be made public without the consent of
the Committee, pursuant to clause 2(k)(7) of House rule XI. You are
asked to abide by the rules of House and not discuss with anyone, other
than your attorney, this deposition and the issues and questions raised
during this proceeding.
Finally, no later than 5 days after your testimony is transcribed
and you have been notified that your transcript is available, you may
submit suggested changes to the Chairman. The transcript will be made
available for your review at the Committee office. The Committee staff
may make any typographical and technical changes requested by you.
Substantive changes, modifications or amendments to the deposition
transcript submitted by you must be accompanied by a letter requesting
the changes and a statement of your reasons for each proposed change. A
letter requesting any substantive changes, modifications,
clarifications or amendments must be signed by you. Any substantive
changes, modifications, clarifications or amendments shall be included
as an appendix to the transcript conditioned upon your signing of the
transcript.
Do you understand everything that we have gone over so far?
Mr. Wilson. I want to note for the record to the extent it is fine,
if you understand, you can answer yes. But I do not think it is
appropriate to construe your understanding as being necessarily an
agreement that everything that has been stated is in fact a correct
interpretation of the authority of the Committee or the scope of the
investigation. But the question was, do you understand what she has
told you?
The Witness. I have heard what you have read. I have a general
understanding, I guess.
Ms. Safavian. Do you have any questions about anything that we have
gone over?
The Witness. I do not think so, no.
Mr. McLaughlin. We have been making it a practice to, if it is
convenient, to send depositions out for review subject to agreement
that you will not show it to anybody. We have been doing that for every
other witness. I can't imagine we wouldn't do it in your case, if it is
more convenient.
Mr. Wilson. That would be great.
Ms. Safavian. That would be subject to both of you signing a
confidentiality agreement before we would send the transcript out to
you.
Mr. Wilson. That is fine.
Ms. Safavian. I will be asking you questions concerning the subject
matter of this investigation. Do you understand?
The Witness. Yes.
Ms. Safavian. If you don't understand a question, please say so and
I will repeat it or rephrase it so that you understand the question. Do
you understand that you should tell me if you do not understand my
questions?
The Witness. Absolutely.
Ms. Safavian. The reporter will be taking down everything we say
and will make a written record of the deposition. You must give verbal,
audible answers because the reporter cannot record what a nod of the
head or other gesture means. Do you understand that you cannot answer
with an ``um-hum'' or nod of the head?
The Witness. Yes, I do.
Ms. Safavian. If you can't hear me, please say so and I will repeat
the question or have the court reporter read the question to you. Do
you understand?
The Witness. Yes, I do.
Ms. Safavian. Please wait until I finish each question before
answering and I will wait until you finish your answer before I ask the
next question. Do you understand that this will help the reporter make
a clear record because she cannot take down what both of us are saying
at the same time?
The Witness. Yes, I do.
Ms. Safavian. Your testimony is being taken under oath, as if we
were in court, and if you answer a question it will be assumed that you
understood the question and the answer was intended to be responsive.
Do you understand that?
The Witness. Yes.
Ms. Safavian. Are you here voluntarily or as a result of a
subpoena?
The Witness. I am here as a result of your request to have me here.
Mr. McLaughlin. Did you volunteer to come here?
The Witness. I guess I did.
Mr. McLaughlin. You got something in the mail?
The Witness. I was asked to come, and I am happy to be here to
cooperate with you all and answer your questions.
Ms. Safavian. Do you have any questions about the deposition before
we begin the substantive portion of the proceeding?
The Witness. No.
Mr. McLaughlin. I will make my usual note as to an omission from
the prior statement of the rules. Pursuant to House rule XI 2(k)(8),
objections to relevance are the province of the full Committee and not
the Chairman to resolve. Accordingly, any ruling on an objection as to
relevance is appealable to the full Committee.
EXAMINATION BY MS. SAFAVIAN:
Question. Can you please state your full name and spell it for the
record?
Answer. Kelly Ann Crawford, K-E-L-L-Y, A-N-N, C-R-A-W-F-O-R-D.
Question. Have you ever used or been known by any other names?
Answer. No.
Question. What is your date of birth and Social Security number?
Mr. Wilson. Objection.
Mr. McLaughlin. Objection. That is totally irrelevant. The person
giving testimony today is not the target of this so-called
investigation. She is a witness. Accordingly, her Social Security
number is utterly irrelevant.
I think that the only implication of the question that can fairly
be drawn is that counsel is trying to intimidate the witness by
suggesting that somehow she may be a target of the investigation. That
implication is unfounded. Accordingly, I object as to either piece of
information.
Furthermore, I would simply note in passing that these depositions
have traditionally been made available on the Internet, and to subject
this witness to the kinds of financial fraud that come along with the
public release of a Social Security number, and frankly even a date of
birth, is to my mind unfounded and frankly borders on the obnoxious.
Mr. Wilson. I would ask that the question be withdrawn with the
assurance from counsel that if you can, if Committee counsel can
provide to me a reason for doing so, for providing this information, I
would be happy to do it in a letter. But I am concerned about the
privacy issues that may be raised by divulging this kind of
information.
Ms. Safavian. The witness' date of birth and Social Security number
is something that we ask of all deponents.
Mr. McLaughlin. That is untrue.
Ms. Safavian. The reason being is we receive documents in response
to our subpoenas which may have date of birth or Social Security
number, and it allows us to make sure that Kelly Crawford who is
sitting here today is the same Kelly Crawford whose name may appear on
the document. We are not aware if there is another Kelly Crawford or
another Crawford. It helps us make sure that we know what documents may
come up which have her name, to make sure it is the Kelly Crawford who
is sitting in front of me and not someone else.
Mr. McLaughlin. First of all, that is absolutely untrue, as the
record will reflect, that we have been asking this question of all
witnesses. I would say it has been asked of substantially fewer than
half of the witnesses that have come before the Committee. In general,
the question has been withdrawn when counsel has offered to make the
information available through other means.
Second of all, I am not aware of any document that has come into
the possession of this Committee that would implicate the date of birth
or Social Security number of Kelly Crawford. As I have said numerous
times, this witness is not a target. We have not received any bank
records or phone records from her, nor would I expect that we ever
would because, as I said, she is not a target.
Accordingly, I think counsel should withdraw the question. If a
plausible reason can be propounded as to why the information is
necessary, then I am sure counsel will supply it in a prompt and
comprehensible manner. To put it on the record just seems to me to be
characteristically inappropriate to this Committee.
Mr. Wilson. If there are documents that you need help deciphering
or identifying--as you say, I do not think there is any other Kelly
Crawford that comes within the scope of this investigation--I am happy
to try to help you with that or even provide the information later on.
But having represented witnesses in other proceedings conducted by this
Committee that were similar, I do know that while depositions begin as
being confidential, they do not always end up that way. I would just
prefer not to have Kelly's date of birth and Social Security number out
there for all to see.
Ms. Safavian. I do not plan on spending much time on this. I will--
that is fine if you are instructing your client not to answer those two
questions--I will then----
Mr. McLaughlin. I do not think that is what he said. He said he
will supply----
Ms. Safavian. I will rely on your representation that if I do have
a question down the road that I can contact you to find out the answer.
Mr. Wilson. Absolutely. And really, I am not instructing her not to
answer. I just requested that you withdraw the question and we will
provide the information.
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Crawford, your current address?
Answer. [Redacted].
Question. How long have you lived at that address?
Answer. About less than two months.
Question. Prior to that address?
Mr. McLaughlin. Objection. We certainly do not need this
information either. I think it is, again, a sort of bizarre signal and
characteristically inappropriate to be sending to the witness, that
somehow her past addresses might be relevant to the Committee. I
suggest that you move forthrightly into the questions that might
actually be relevant to the Committee investigation instead of
dithering around in these questions.
EXAMINATION BY MS. SAFAVIAN:
Question. You may answer the question.
Answer. [Redacted].
Question. Have you ever lived outside the United States?
Answer. I studied abroad for four months when I was a junior in
college.
Question. Where was that?
Mr. McLaughlin. Objection as to relevance.
The Witness. Austria, Vienna.
EXAMINATION BY MS. SAFAVIAN:
Question. Where did you attend college?
Answer. American University here in Washington.
Question. Did you graduate from American?
Answer. Yes.
Question. What was your degree?
Answer. It was a degree from the School of Public Affairs and the
major was called CLEG: Communications Law, Economics and Government.
Question. Did you receive any other degrees?
Answer. No.
Question. Have you spoken with anyone other than your counsel and
my office about scheduling the deposition? Have you spoken with anybody
else about this deposition?
Answer. When I got a call from you, I talked to some people about
finding a lawyer, but not specifically about what we had discussed or
what I was coming here today to discuss.
Question. Did you review any documents in preparation for your
deposition?
Mr. McLaughlin. Other than from counsel? Other than from her
counsel?
Mr. Safavian. She can answer if she reviewed documents.
Mr. McLaughlin. I am asking you a question. The question is not
clear to me. You don't have to snap at me.
EXAMINATION BY MS. SAFAVIAN:
Question. Did you understand my question?
Mr. McLaughlin. Let me finish. The question is, are you asking her
whether she has reviewed any documents other than in connection with an
attorney-client communication? Is that what you are asking?
Ms. Safavian. No, my question was, did you review any documents in
preparation for this deposition?
Mr. McLaughlin. You do intend to go into the attorney-client
confidence or you don't? One way or the other.
Ms. Safavian. If you would just let the deponent answer the
question, if she tells me she reviewed documents with her attorney, I
will not delve into attorney-client privilege. You have just not
allowed her an opportunity to answer the question.
Mr. McLaughlin. If you asked a more carefully crafted question, you
would avoid my objections.
EXAMINATION BY MS. SAFAVIAN:
Question. Did you understand my question, Ms. Crawford?
Answer. If you could describe to me what you mean by--I haven't
reviewed any documents. I do not have documents my possession.
Question. That is fine. That was the answer to my question.
Answer. I don't know what you mean by documents but, no.
Mr. Wilson. I would note for the record that I have shown the
witness the correspondence from the committee that I received.
The Witness. Yes, a letter from Chairman Burton. I guess that would
be a document.
EXAMINATION BY MS. SAFAVIAN:
Question. Have you been asked by White House Counsel or anybody
else to collect documents in response to either the House, Senate or
Department of Justice subpoenas?
Answer. I do not work at the White House any longer. I do not
recall if when I was working at the White House, whether any of this
had started. At that time I may have looked for an answer to a subpoena
but I don't know what it would have been.
Mr. McLaughlin. Why don't you lay some foundation for where she
worked and when? Maybe some of these questions can be skipped over as
being obviously not----
The Witness. I haven't worked at the White House for----
Mr. Wilson. Are you talking about pursuant to subpoena relating to
the subject of this investigation?
Ms. Safavian. Yes.
Mr. Wilson. Okay. So relating to fund-raising.
Mr. McLaughlin. And the other matters which this investigation has
sprawled into.
The Witness. I do not believe so, no.
EXAMINATION BY MS. SAFAVIAN:
Question. Thank you.
Can you please briefly describe your employment history after
college?
Answer. I graduated from American University in May of 1992 and
volunteered at the Democratic Convention in New York. Shortly after the
convention, I started doing advance work for the Clinton campaign. I
did press advance up until the election in November, and after the
election I worked during the transition for the transition committee. I
worked in the basement of the governor's mansion. And after the
transition, I worked as a staff assistant in the Media Office of the
President.
I left there, I believe, in July of 1995 and worked at the Justice
Department in the Public Affairs Office for Attorney General Reno. I
did all of her personal press. I was there for about a year.
I left and went to work at the Clinton-Gore campaign in the
communications office. And then when the election of 1996 was over, I
worked at the Presidential Inaugural Committee. And when the Inaugural
was over I--shortly thereafter, must have been in February or March--
started working at the Treasury Department where I am currently
employed.
Question. February or March of this year?
Answer. Yes.
Question. Can you tell me, you mentioned that you were a staff
assistant in the President's office. Do you recall when you began that
job?
Answer. The day after the President was sworn in as President,
January of 1993.
Question. Then you said you left that in July of 1995?
Answer. Yes, I believe it was right around there, yes.
Question. Were you approached about taking this position, or how
was it that you ended up as a staff assistant in the President's
office?
Answer. As I mentioned to you before, I had worked during the
transition in the basement of the governor's mansion. I worked with
Nancy Hernreich, who then went on to work in the President's office at
the White House. She asked me to come on in this capacity.
Question. Did you have to interview with anybody other than perhaps
Nancy Hernreich?
Answer. I talked with Nancy Hernreich about it. I met with Carolyn
Huber about it. I think that is probably all that I talked to about it.
Question. Who is Carolyn Huber?
Answer. She was--at that time she was also going to be working not
in the President's office but in what they called the Personal
Correspondence Office, which was the area that worked with the friends
and family of the First Family. That was some of what I was going to be
doing. So I met with her at the Blair House prior to----
Question. Can you tell me as a staff assistant what were your job
responsibilities or duties?
Answer. I worked directly for Nancy Hernreich. I answered phones,
opened mail. I talked with the President's friends and family that
would call his office.
Question. Was Nancy Hernreich your supervisor?
Answer. Yes.
Question. Did you report to anybody besides Ms. Hernreich?
Answer. I reported to Ms. Hernreich.
Question. Did you have an office?
Answer. I shared an office.
Question. Was it with one other person or was like it a bigger
room?
Answer. It was a room that there were four desks within one room.
Question. Where was that located, if you could just describe
briefly where it was located in relation to Ms. Hernreich's office, the
President's office?
Answer. It was in the West Wing. Ms. Hernreich switched the
location of her office. She used to be on one side of the Oval Office;
then she went to the other side of the Oval Office. I continued to stay
two rooms down from the Roosevelt Room in the West Wing.
Question. Did you ever work out of any other location or did you
pretty much stay right there?
Answer. I pretty much stayed in that----
Question. Were you the only staff assistant, or were there others
under Ms. Hernreich?
Answer. I was the only staff assistant.
Question. You explained your job duties and responsibilities as
opening mail or speaking with the President's friends. Were you in
charge of the radio address for the President?
Answer. I worked on the radio address, yes.
Question. Who organized the radio address?
Answer. In the beginning--well, it ultimately was Nancy's
responsibility but obviously I worked for Nancy. At one time there was
another gentleman who also worked on organizing the radio address but,
yes, I worked on organizing the radio address.
Question. Who was that other person?
Answer. Dave Levy, who worked also in the West Wing.
Question. Was it just the two of that you would assist Ms.
Hernreich in organizing the radio addresses?
Answer. Yes.
Mr. Wilson. You are talking about just sort of logistically?
The Witness. That I wrote the speech? I mean, I should clarify that
this is the people who came to watch the radio address. I worked with
Ms. Hernreich on, you know, those who came in to watch the radio
address.
EXAMINATION BY MS. SAFAVIAN:
Question. I was going to ask you to just explain what it was that
Ms. Hernreich and yourself and Mr. Levy would do to prepare for the
radio address, if you would like to explain that.
Answer. Sure. The radio address was primarily an opportunity for
the President to see friends and family who were in from out of town.
But as the radio address went on, obviously people heard about the
opportunity to come and listen to the President speak in the Oval
Office and then have pictures made with the President, so we got
requests from Members of Congress and their staff, from members of the
media, from members of the Cabinet, from offices within the White
House.
So we would compile all these requests and then sit down with Ms.
Hernreich and decide who, how many requests we could accept, and then
who was and was not coming. And then on the day of the radio address I
would, or the day before, maybe, clear people in; and then greet people
when they came, and sometimes introduce them to the President as they
came through the line.
Question. Can you tell me, was there generally a certain number of
people who would attend the radio address, like the maximum number?
Answer. Week to week, it just depended. We began to, as more and
more people came, sometimes we would take some of the furniture out.
There was probably maybe 80 people that we could fit into the Oval
Office, 80 to 90.
Question. Did you normally have about 80, 90 people at each radio
address?
Answer. It varied from week to week.
Question. Would you prepare a list of all the attendees for each
radio address?
Answer. Either I would or Mr. Levy would, but, yes, there would be
a list of who was there.
Question. What would be on the list? What would it include?
Answer. Usually just names and maybe one description, like ``Kelly
Crawford,'' you know, something to indicate where this person worked,
or ``friend from high school'' or something like that. There might be
something indicating who the person was or just names.
Question. Okay. You mentioned that you would get requests from all
over for the radio address. Did you ever try to limit it, say, only to
friends of the President or people who work in the White House or
Members of Congress? Did you ever try to limit it to just certain
groups of individuals?
Answer. I don't quite understand the question.
Question. The people who you would let attend the radio address, I
assume that your office would get a lot of requests to attend the radio
address and surely you could not allow everyone to attend the radio
address. Was there any way that your office determined who would be
invited to attend and who might not be?
Answer. I really was just a facilitator. I put the list together,
but Nancy ultimately----
Mr. Wilson. You are talking about priorities in terms of groups,
like friends and family or Members of Congress or----
EXAMINATION BY MS. SAFAVIAN:
Question. If there was any way that you distinguished or determined
who would be invited to a radio address and who might not be invited to
a radio address. I am using that as an example. It may not have
happened that way. I don't know.
Mr. McLaughlin. Why don't you ask, did you give special treatment
to donors? Did you give special treatment to contributors?
The Witness. Let me tell you how I--I did not make these decisions.
I was a facilitator. I gathered requests that came in. But it was my
understanding that the President's friends or family, people from out
of town that he knew were the first priority. In addition, White House
staff and their immediate families. And then after that there were
obviously Members of Congress, if they were--if they had asked to come,
would have been a priority. But those decisions were largely made by
Ms. Hernreich, not myself.
EXAMINATION BY MS. SAFAVIAN:
Question. Was it Ms. Hernreich who would then provide you with a
list of names or somehow tell you who you should include on your list
of attendees, or how did you know?
Answer. We would go through the list, and say another determination
would be if someone was in town just for this weekend, and/or versus
someone who lived in Washington.
Question. But pretty much a decision was left to Ms. Hernreich?
Answer. It was ultimately her decision. I was her assistant in the
President's office.
Question. So then did the two of you sit down and you would just
have a list of everyone who requested to be in attendance at that radio
address, and the two of you would kind of go through each name?
Answer. Yes. We would go through a list, and then I would have
supporting things like a letter from Joe Schmo saying, ``This is the
only time I have been in town and I would love to come.'' So we would
go through those.
Question. When would that process usually begin?
Answer. I guess maybe two days before the actual radio address,
maybe two or three days. On a Wednesday or Thursday, if the radio
address was on a Saturday.
Mr. Wilson. You mean the process of interacting with Nancy
Hernreich to pare down the list of who requested attendance?
Ms. Safavian. Yes.
Mr. Wilson. As opposed to when requests might come in. Which might
be six months in advance or something?
EXAMINATION BY MS. SAFAVIAN:
Question. I meant specifically when you and Ms. Hernreich would
kind of sit down and go over your list of possible attendees.
Answer. It was never a set schedule. Two or three days before the
radio address, I guess is when we would.
Question. And then who would notify an individual that they were
going to be permitted to attend the radio address?
Answer. It depended, because some requests, I should also--Mr. Levy
did some of the requests and I did some of the requests, but also maybe
someone from the Office of Public Liaison would request that a group of
health care advocates would come. That might go back to the person at
the White House who had requested it and they would then extend the
invitation, clear the people in.
Or say in the case of friends of the President, I would then be the
person that would call them back and extend the invitation. So it just
depended on if someone had requested it directly to me or if someone
else within the White House had made the request through me.
Question. Okay. I know you mentioned that David Levy did some of
them and you did some of them. Was there any distinction as to--was it
just random who got in charge of one radio address over another?
Answer. We worked together and, as I indicated before, I primarily
took care of friends of the President, family members. But people knew
that I worked on it and people knew that he worked on it, so it
overlapped as to----
Question. So, in other words, the two of would you work together on
each radio address. It was not like you had one one week and he had the
next?
Answer. No, we would work together.
Mr. Wilson. You have to let her finish talking before you talk.
The Witness. Sorry.
EXAMINATION BY MS. SAFAVIAN:
Question. Do you recall the March 11, 1995 radio address?
Answer. I do not recall a specific date. I am sure that if it was a
Saturday and the President was in town, there would be a radio address.
Question. Do you know who Johnny Chung is?
Answer. Yes.
Question. Have you met Mr. Chung?
Answer. Yes, I have met Mr. Chung.
Question. On how many occasions?
Answer. I don't know. If I had to estimate, I would say maybe a
handful of times.
Question. Do you recall how you first met Mr. Chung or were
introduced to him?
Answer. I don't know if the first time--I don't know when--the
first time that I met him, whether it was a radio address. I don't know
the first time that I met him, no.
Question. When you said you maybe met with him on a couple
occasions, a handful of occasions----
Mr. Wilson. You are saying met with him. I think your question was
how many times did she meet him, and I was going to suggest that that
might be just a little ambiguous. Do you mean see him, or shake his
hand, or have a conversation with him? I just want the record to be
clear about the extent of her contact.
Ms. Safavian. That was going to be my question.
EXAMINATION BY MS. SAFAVIAN:
Question. If you can just explain, you said a handful of occasions.
Do you recall perhaps what the setting was of those handful of
occasions where you saw Mr. Chung?
Answer. I have a vague recollection that I saw him possibly at a
helicopter departure. And other than that, I don't know where I saw
him. Maybe just on the White House grounds, but I do not remember
specifically or have any recollection of exactly when I saw him.
Mr. McLaughlin. Did you ever have a meeting with him?
The Witness. No, I never sat down and met with Mr. Chung.
EXAMINATION BY MS. SAFAVIAN:
Question. Did you ever have any discussions with him, any
conversations?
Answer. Did I ever talk to Mr. Chung?
Question. Yes.
Answer. Yes, I talked to Mr. Chung. Sure.
Question. Would that just be a general greeting or would it have
ever been anything more than that?
Answer. I do not believe that my talking with Mr. Chung would have
been anything more than a typical greeting, as I did with you when we
walked into the room.
Question. Okay. The March 11, 1995 radio address, do you recall it,
if I were to tell you that that is the radio address where Johnny Chung
and the Chinese delegation attended the radio address?
Answer. I have a vague recollection of the Saturday that they
attended a radio address. I have of course seen numerous press accounts
of this radio address. Yes, I have a vague recollection. It is hard for
me to remember exactly what I recall versus what I have read about,
but, yes, I do have a recollection that he attended a radio address.
Question. What I am handing you are WAVE records for the year 1995.
If you will turn to where--on the bottom there are Bates Stamp
Numbers--if you will turn to EOP 005038, if you will look down----
Answer. It is very difficult to read.
Question. If you look about five down, five or six down, you will
see where Johnny Chung, the visit--he is--``visited POTUS,'' President
of the United States, and if you continue to read to the right, to the
middle, it shows a date. It shows that it is March 11, 1995.
Answer. Yes.
Question. And the room is WW, which stands for?
Answer. West Wing, I assume.
Mr. McLaughlin. Have you seen these WAVE records before? Is this
the first time you have seen this document?
The Witness. Yes, this is the first time I have seen this document
or seen a document like this.
Mr. McLaughlin. Do you notice there is no badge number, time of
arrival or time of departure? And I will represent to you that that is
what the last three categories are. I know that he was there, but do
you see that?
The Witness. Yes, I see the dot, dot, dot, dot, dot.
EXAMINATION BY MS. SAFAVIAN:
Question. Do you notice, if we continue down, there is a name who
requested Mr. Chung's clearance. It says ``Crawford.'' Would that be
you?
Answer. I assume it would be me.
Question. Do you recall going through the process, you can explain
it to me, of waving in Mr. Johnny Chung on March 1, 1995?
Answer. I may have waved him in, but I have no distinct
recollection.
Mr. McLaughlin. Would you have waved in everybody for a particular
radio address?
The Witness. As I said, it depended. Some people--I waved in a lot
of people, yes--but some people, anyone in the White House could wave
someone in. So say you had put in a request through the Office of
Legislative Affairs, and Joe Schmo in Legislative Affairs was the
person that requested to me, I might just say, ``Hey, would you go
ahead and clear in your guest?'' So sometimes I cleared people in or
sometimes I did not. It was not a----
EXAMINATION BY MS. SAFAVIAN:
Question. You don't have any recollection, as we sit here right
now, that you waved in Johnny Chung on that day?
Answer. I cleared in many, many people. I do not specifically
recall clearing Mr. Chung in on this date. No.
Question. Do you recall clearing in anybody in the Chinese
delegation?
Answer. Again----
Mr. Wilson. By ``the Chinese delegation,'' just because that
characterization could mean many things, you are talking about the
Chinese gentlemen who have been reported as accompanying Mr. Chung to
the radio address?
Ms. Safavian. That is correct. I can show you a letter that Johnny
Chung sent to Richard Sullivan, dated February 27, 1995, which includes
a list of the gentlemen that I am referring to as the Chinese
delegation. If you turn to the second page, which is DNC 323332----
The Witness. Yes?
Mr. McLaughlin. Before we get confused here, let me make a
housekeeping request. Can you mark the copy that you showed the witness
to go in the record? I know that we do not adhere to the Rules of Civil
Procedure here, but in ordinary deposition practice the copy that the
witness sees is the copy that goes into the record. I would appreciate
it if you would mark that one to go in.
Second thing is, before I move on from this first exhibit, I want
to note all of the EOP page numbers because there are nonconsecutive
pages marked here. They are as follows: EOP 005039, EOP 008683, EOP
005038, EOP 008680, EOP 003717, EOP 003713, EOP 005035, EOP 003710, EOP
005032, and EOP 003703. Are you going to mark that document?
Ms. Safavian. I will, certainly, if you would just give me a
moment.
Mr. McLaughlin. I just want to make sure that you can mark the copy
that the witness has. I do not mean to be a stickler but I like to have
the document numbers read in.
Ms. Safavian. We will be marking the 1995 WAVE records of Mr.
Johnny Chung as Exhibit Number 1, KC-1.
We will be marking the February 27 letter to Richard Sullivan as
Exhibit Number 2, KC-2.
[Crawford Deposition Exhibit No. KC-1 was marked for
identification.]
[Note.--All exhibits referred to can be found at end of
deposition.]
[Crawford Deposition Exhibit No. KC-2 was marked for
identification.]
Mr. McLaughlin. Have you seen Exhibit 2 before?
The Witness. No, never.
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Crawford, you do not have, as you are sitting here
today, a recollection that you did wave in Mr. Johnny Chung or the
Chinese delegation members for this radio address?
Answer. I may have but, no, I do not have a specific recollection.
Question. Ms. Crawford, can you explain to us how Johnny Chung and
this Chinese delegation were able to attend the March 11, 1995 radio
address?
Mr. Wilson. Do you mean explain her knowledge of how they got in,
or how they came to find out about it, or just in----
EXAMINATION BY MS. SAFAVIAN:
Question. Your knowledge as to how they were able to attend the
radio address.
Answer. As I mentioned earlier, I have a vague recollection of this
Saturday, and I believe that the request came to me from the chairman's
office at the DNC.
Question. Would that be Don Fowler?
Answer. I believe he was the chairman at that time.
Question. You said you believe that the request came from the DNC
chairman's office?
Answer. Yes.
Question. Do you recall who that was that made the request to you?
Answer. I do not specifically recall, but I know Ceandra Scott
worked in the office at that time. I have heard press accounts that she
may have been, but I don't specifically recall. Some staffer, I
believe, in Chairman Fowler's office.
Question. Do you know Ms. Scott, Ceandra Scott?
Answer. Yes.
Question. Do you know her well?
Answer. No.
Question. Did you know each other well enough that if she wanted to
ask, request someone to attend the radio address, she would have
contacted you?
Answer. Yes, that would not have been unusual.
Question. Had she ever requested you, or if you recall any other
time, requested that you perhaps admit another individual or
individuals into a radio address?
Mr. Wilson. I do not think she testified that that is what Ceandra
Scott did in this case. Maybe you could ask her how a conversation like
that might go rather than suggesting that--well, suggesting how it did
go.
Ms. Safavian. I was trying to figure out if you recall Ms. Scott
ever contacting you on another occasion. I am not saying that you
testified that she did contact you on this occasion. Did she ever
contact you on another occasion and ask you to get somebody into a
radio address?
Mr. Wilson. That is what I am objecting to, to get somebody into a
radio address, if that suggests that that is what Ceandra Scott said at
this particular time. I do not think it has been established what she
did say, whether it was, ``Can you get somebody in?'' or ``Do you have
room?'' or something else. So I know I am--maybe the best thing to do
is just ask her how a conversation like that with Ceandra Scott would
go, to the extent she can recall.
EXAMINATION BY MS. SAFAVIAN:
Question. Do you recall any such conversations like that, Ms.
Crawford?
Answer. I don't specifically recall other conversations. I am not
saying that there wasn't ever another conversation with Ms. Scott or
another request that came to me through her, but I do not have specific
recollection.
Question. Did you know any other individuals who worked at the DNC
or in the chairman's office who would have contacted you about such a
request?
Answer. What such request? Just general requests that would come
through the DNC? I am not sure I understand the----
Mr. Wilson. You mean a request to see the radio address?
EXAMINATION BY MS. SAFAVIAN:
Question. Yes. For the radio address.
Answer. I knew other people at the DNC, sure, who I believe
probably made requests as well. So it was not completely unusual to
have a request from someone at the DNC.
Question. Can you recall those individuals' names who may have
contacted you?
Answer. Possibly--this is, if you want me to speculate about people
that I know at the DNC who could have called me to possibly request, I
can do that. But I do not have a recollection, sitting here today,
three years ago what requests came in from the DNC. If you want me to
speculate----
Mr. McLaughlin. As it says in the instructions, we are not
interested in speculation.
EXAMINATION BY MS. SAFAVIAN:
Question. You mentioned that it was not--I do not want to put words
in your mouth. Was it unusual for the DNC, somebody at the DNC, to
contact either yourself or Nancy Hernreich or someone at your office
and ask that a particular individual or DNC contributor be given access
or be allowed to attend a presidential radio address?
Mr. McLaughlin. Your question includes the word ``contributor.'' I
do not think Ms. Crawford has stated anything about whether or not
these people were contributors or whether she knew. Why you don't
rephrase your question, sticking to the knowledge and the testimony
that has been established.
EXAMINATION BY MS. SAFAVIAN:
Question. Did you understand my question?
Mr. McLaughlin. I am not asking. I am telling you I object to your
question on the grounds that it misstates her prior testimony.
Ms. Safavian. Your objection is noted for the record.
Mr. McLaughlin. It is sort of a funny exchange that we have here,
because you then ask the witness if she understands the question. I am
making an objection. I would like you to respond to the objection.
Ms. Safavian. Your objection is noted for the record.
You may answer.
The Witness. May I talk to my counsel?
Ms. Safavian. Sure.
[Witness confers with counsel.]
Mr. McLaughlin. If you want your question to go ahead while it
misstates that kind of testimony, that is your choice, counsel, but I
think it is a uniquely ill-considered, poor choice to proceed in that
manner.
The Witness. It was not unique that we would get requests from the
DNC, as we got requests from Cabinet agencies, Members of Congress,
members of the press. But people were never stated as being
contributors to me.
EXAMINATION BY MS. SAFAVIAN:
Question. But the request would come from the DNC. Would it be a
request that the DNC employees or staff members----
Answer. Sometimes, sure.
Question. But not always?
Answer. Not always, no.
Question. Was there any particular procedure that yourself or Ms.
Hernreich would then follow?
Answer. One other thing that I should state is that within the
White House there is also the Office of Political Affairs, so requests
might also come through--there was not a set way that every request
came through a specific channel. So requests could also come from the
Office of Political Affairs, as well.
Question. And the previous question was, was there any particular
manner in which either yourself or Ms. Hernreich would handle such
requests?
Mr. Wilson. You mean requests that came from the DNC directly?
EXAMINATION BY MS. SAFAVIAN:
Question. Correct.
Answer. They would have been handled in the same way that any other
requests were handled which, as I stated before, we compiled the
requests and then would sit down and talk about them. Unless possibly,
as we would with other requests, if a Cabinet official called, we would
let Cabinet Affairs know Secretary Riley from Education had requested
to come in; or if a request from the DNC came, we might let Political
Affairs know that we had this request and check with them. I am not
saying that that was done in every single case, but it would not have
been unusual for that to happen.
Question. Was it your testimony that you believe Ceandra Scott was
the one that contacted you about Johnny Chung and the Chinese
delegation attending the radio address?
Answer. I don't have specific recollection of who exactly in the
chairman's office contacted me about Mr. Chung.
Question. But you do have a specific recollection that it was
someone in the chairman's office of the DNC?
Answer. Yes, I believe that is where the request came from.
Question. Do you recall when the request came to you?
Answer. I believe that the request came late on a Friday, or sort
of not way ahead of time, sometime close to the radio address. I have
some recollection that it was kind of a last minute request.
Question. The day before the radio address?
Answer. Yes.
Question. Do you----
Answer. But I do not specifically recall what time or when.
Question. Do you have any specific recollection as to what was
asked of you?
Answer. I was asked if--I do not have a specific recollection of
what the conversation was. I assume I was asked did we have room in the
radio address for Mr. Chung and his guests.
Question. What would your response have been?
Answer. I don't specifically recall what I did in this case but I
can tell you generally what the practice was, that I would say, ``Let
me check and see. Let me get a phone number and I will call you back.''
As I have said before, I would then check with Ms. Hernreich to see if
we did in fact have room and if in fact this was someone that we should
allow to attend the radio address.
Question. Would you think--you said the request came in late,
perhaps the day before.
Answer. I said I believed that the request--I have some
recollection that the request came in----
Question. Came in late?
Answer. Yes.
Question. Do you have any recollection as to whether at the time
the request came in you already had determined who was going to attend
the radio address for that Saturday?
Mr. Wilson. You mean whether the--whether anybody had been cleared
in to see the radio address?
EXAMINATION BY MS. SAFAVIAN:
Question. Whether you and Ms. Hernreich had already sat down and
discussed who was going to attend the radio address?
Answer. I am not sure that you understand the process. It was not
like we made a decision and--this was sort of if there was room, other
requests would be taken. It would not be unusual that on a Friday we
would learn that someone happened to be in town or that someone
extended their visit and was going to stay.
I do not specifically recall in this case what the standard
procedure was. But I do not remember it as being with a whole--the
whole slew of requests, which makes me, as I indicated earlier, believe
that it came in later.
Question. Okay. You had mentioned that when requests would come in,
generally you would take down the person's name and say, ``I will have
to see and get back with you.'' So in this instance you recall that you
would have said the same thing to this individual in the chairman's
office of the DNC?
Answer. I don't have specific knowledge of what I said to that
person, but that was the general practice. I can't swear that this is
what I said on that occasion, but that would have been what I generally
would have said.
Question. Do you recall then speaking with Ms. Hernreich about this
request?
Answer. I spoke with Ms. Hernreich about hundreds of such requests.
I do not recall having a specific conversation about this request, no.
Question. Do you recall then contacting this individual back at the
DNC, the chairman's office of the DNC, and letting them know that
these--that Mr. Chung and the Chinese delegation were able to attend
the radio address?
Answer. No, I do not remember. I assume that it probably would have
been me that would of called them back but I do not recall.
Question. Do you recall when you would have made that call?
Answer. No.
Question. Do you know how Mr. Chung knew that himself and his
guests were able to attend the radio address?
Mr. Wilson. I object because particularly based on the prior
testimony, I do not see how she can know what was in Johnny Chung's
mind, how he might have found something out. But with that I hope
clarification of the record, if you can answer it, go ahead.
The Witness. I don't know.
EXAMINATION BY MS. SAFAVIAN:
Question. Do you recall being--do you recall being provided with a
list of the individual names of the Chinese delegation, as well as Mr.
Johnny Chung, who would have attended the radio address? Do you recall
getting a list of their names?
Answer. I don't specifically recall getting a list of their names.
I may have been the one that received the list through the DNC and
cleared them in but I do not specifically recall whether I did. And if
I had been the person that Saturday to put together the final list,
then, yes, I would have gotten the names somehow.
Question. The final list is usually put together that day, the
morning of?
Answer. The night before, usually.
Question. And what would you need for every individual who was
going to attend a radio address? What kind of information would you
need?
Answer. To attend or to clear them in?
Question. Both.
Answer. Well, in order to clear someone into the White House, you
needed their name and date of birth and sometimes Social Security
number or passport number. But as I indicated before, I did not clear
in every single person that came to a radio address because other
people at the White House could also clear people in and would often do
so.
Question. Would this list, this final list, as you call it, of
attendees, would that have had on it their date of birth, their Social
Security number, perhaps,?
Answer. No. It was not standard practice that we would put that
information.
Mr. McLaughlin. That information was sent to the Secret Service to
wave them in?
The Witness. Yes, that is what that was used for.
Mr. McLaughlin. You wouldn't give the President the Social Security
numbers of the individuals?
The Witness. No.
EXAMINATION BY MS. SAFAVIAN:
Question. You had mentioned earlier that usually you were present
during the radio addresses, and you would greet the guests and
sometimes introduce them to the President; is that correct?
Answer. Yes.
Question. Do you recall doing that specifically on March 11, 1959?
Answer. No, I do not recall that specific date or specifically what
I did.
Question. Do you recall being present on March 11, 1995?
Answer. I do not recall that specific date. I may have been----
Mr. Wilson. Are you asking her if she recalls being present at the
radio address that Johnny Chung attended?
Ms. Safavian. Yes.
The Witness. Yes. I don't know the date. I assume the date that you
are saying is that address, but there was a radio address that I
attended that Mr. Chung also attended. Yes, I have a vague
recollection, as I stated before, of that radio address, yes.
EXAMINATION BY MS. SAFAVIAN:
Question. Do you recall being introduced by Mr. Johnny Chung to
this Chinese delegation?
Answer. I don't specifically recall.
Mr. McLaughlin. Just so the record is clear, when you say Chinese
delegation----
The Witness. Yeah.
Mr. McLaughlin [continuing]. You mean a group of individuals
accompanying Johnny Chung? Is that the term of art we're going to use
for group of individuals accompanying Johnny Chung?
Ms. Safavian. Yes. That's the way they've been referred to.
The Witness. That's never been referred to me that way. But I
understood Mr. Chung--and I know Mr. Chung came with some other
gentleman to a radio address.
EXAMINATION BY MS. SAFAVIAN:
Question. Let me show you--and I'm not really sure how to explain
what this is. Perhaps you can explain it to me. It is--perhaps, it
says: At the top, Name List of Delegation. And at the very bottom
Johnny Chung's name is listed. And at the top, there are several other
individuals' names on this list.
Answer. Where is Johnny Chung? Oh, down.
Question. At the bottom under AISI representatives.
Answer. Uh-huh.
Question. And at the top of the Name List of Delegation, there's
five gentlemen's names who are listed. And then under the entourage,
there's three, but two are crossed off, so there's only one
individual's name that is listed.
Answer. Yes.
Question. Two are crossed off. And under AISI representative, we
have Johnny Chung's name, and there is one name that is crossed out.
Have you seen this document before?
Answer. I just saw it a minute ago. I may have seen it. Actually, I
must have seen it. That looks like my back-wrote check mark. So I may
have seen this document, yes.
Mr. Wilson. You're referring to the check mark that is under 3/13
at the top.
The Witness. Yes. I think that's my left-handed check mark. I--I
may----
Mr. Wilson. If you can identify a backwards check mark as
definitively being yours, that's fine. But I don't want you to
speculate because there may be other people who make backwards check
marks as well.
The Witness. Okay.
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Crawford, you make backwards check marks on
documents?
Answer. I'm left-handed.
Question. Okay.
Answer. As I have said so many times before, this was a very long
time ago. I don't specifically remember seeing this exact piece of
paper. But I'm not going to say that I never have seen it.
Question. Okay. Just so the record is clear, you say that you just
saw it a moment ago?
Answer. Isn't it----
Question. And it was similar to----
Answer. Oh, okay.
Question [continuing]. It's not identical--the Richard Sullivan--
the letter to Richard Sullivan from Johnny Chung.
Mr. Wilson. Which has been marked as KC-2.
Ms. Safavian. Right. It's DNC 3233327.
EXAMINATION BY MS. SAFAVIAN:
Question. This is what you're referring to?
Answer. That's, yeah, similar.
Question. I was going to say, as you can see, there are differences
between the two documents. Specifically, some of the names are crossed
off.
Answer. Okay.
Question. And specifically number 2, the person listed as number 2
on the Name List of Delegation, that person's name was crossed off and
is replaced by another individual's name which is handwritten on
document EOP 063488. Do you see that?
Answer. Uh-huh. Uh-huh.
Question. Is that a yes?
Answer. Yes.
Question. Can you tell me, do you recognize whose handwriting this
is with what looks like the dates of births by each individuals and
this replaced name of number 2?
Answer. No, I do not recognize that handwriting.
Question. Do you recognize the handwriting that is on the top right
and bottom right corners of this page? It looks like it says: Cc colon,
Nancy Soderberg, someone from DNC asked to let into radio address.
Before photos are----
Mr. McLaughlin. Sent.
EXAMINATION BY MS. SAFAVIAN:
Question [continuing]. Sent out, we need to know if we should not
send them. N.H.
Do you know whose handwriting that is?
Answer. I believe it's Nancy Hernreich's handwriting. N.H. would be
Nancy Hernreich.
Question. Okay. But you don't have any specific recollection of
this document?
Mr. Wilson. I mean, seeing the document in this form?
Ms. Safavian. Either in this form or before it was written on.
The Witness. No, I don't have specific knowledge of seeing this
document before. But I'm not saying that I haven't.
EXAMINATION BY MS. SAFAVIAN:
Question. Okay. Just so the record is clear, when I refer to the
Chinese delegation and Mr. Chung, those who attended the radio address,
we will be referring to the gentlemen who are listed on this document,
EOP 063488. And I will mark that as exhibit KC-3.
Answer. Okay.
Ms. Safavian. And if I could just have your copy for a moment.
[Crawford Deposition Exhibit No. KC-3 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Do you recall on the day of that radio address, the one
that Johnny Chung and this delegation of gentlemen attended, do you
recall any comments by the President to you about Mr. Chung and the
delegations' attendance?
Mr. Wilson. Before the radio address?
Ms. Safavian. It would be during or after most likely. Any time.
Mr. Wilson. But--wait, wait, wait. Let's narrow it down. Before? Do
you want any comments the President made about the delegation at any
time? I thought the question was initially before the radio address,
but then it evolved into any time.
Ms. Safavian. Well, I don't--I don't believe I mentioned--I said
before in my question.
EXAMINATION BY MS. SAFAVIAN:
Question. What I'm interested in is if you recall the President
speaking with you on this day, which is March 11th, 1995 about Mr.
Johnny Chung and this delegation of Chinese businessmen's attendance at
the radio address.
Answer. After the radio address, as was often the case, once all
the guests had left the White House or left the oval office area, you
know, I would be standing out there, as sometimes would Nancy or
others. And I have--I can recall the President asking who this group of
Chinese businessmen were. And I don't specifically recall what he
asked. But I--I have a vague recollection that he asked who they were,
where their request came from, why they were there.
Question. And who was that request directed to from the President?
Answer. I don't specifically recall. Probably Ms. Hernreich or
myself because that was within our scope of responsibility. And, again,
I don't specifically recall the conversation or what specifically was
said. But I believe that the President asked, you know, where--why
these--or who these people were, why they were there and that, while I
don't specifically remember what I answered, I assume that I would have
said where the request had come from, which was they came through the
DNC. It was a request from the Chairman's office. And I believe that
the President asked to, if I knew who they were or someone at the White
House such as someone in maybe the National Security Office knew that
they were there.
And while I don't, again, specifically remember what I said, I
assumed that I probably said I will make sure that they do. And I
believe that he, and as this note indicates, wanted us to ensure that
we knew who these people were before their photographs were sent out
because they, as you know, had been at the radio address and had their
picture made with the President. So I believe that he was concerned
that, before we sent out the photographs, that we knew exactly who
these people were. And at that point, I could not answer that question
for the President.
Question. Is it all that you recall him saying?
Answer. Yes.
Question. Okay. And at that point----
Answer. I said I don't specifically recall exactly what he said. I
think that was the gist of his concern. But I don't specifically recall
the words that he used.
Question. And at the time the President asked you about
this----
Answer. I did not indicate that it was me. I said it must have been
Nancy Hernreich or myself, because we both--this would have fallen into
both of our scopes of responsibility.
Question. Okay. I thought you had testified that you couldn't
respond to the question when he asked whether the--whether anything was
known about these individuals.
Answer. I believe that I did. But I'm not exactly sure.
Question. Okay. At that point, then, the--these individuals on what
has been marked as KC-number 3, the NSC had not been notified that
these individuals were going to attend the radio address.
Mr. Wilson. You mean in advance of the radio address?
Ms. Safavian. In advance of the radio address.
The Witness. I don't believe that they had, but I'm not sure. But I
don't believe that I had notified them.
EXAMINATION BY MS. SAFAVIAN:
Question. Is that something that you would have done?
Mr. Wilson. Wait. Can you just ask that question a different way.
You said you asked if it was something she did. She said she doesn't
think she did. And then you asked if it was something she would have
done. Can you just rephrase that or actually--the important question is
whether Kelly understands what you mean.
The Witness. I don't quite understand what you--what you mean. If
you restate that or clarify.
EXAMINATION BY MS. SAFAVIAN:
Question. Sure. Was it one of your responsibilities or one of your
job responsibilities to have asked the NSC prior to individuals
attending the radio address to look into their backgrounds or----
Answer. No.
Question. That would not have been something that you would have
been responsible for doing?
Answer. We did not look into backgrounds of people who had attended
the radio address. No. I believe that this request--I assume this
request would have been sent to the NSC, because obviously these were
individuals from China from another country.
Question. And when you--if you had other individuals from other
countries attend radio addresses, is that something that somebody in
your office would have notified the NSC prior to their attendance they
radio address?
Answer. I don't specifically recall having other individuals from
foreign countries attend radio addresses, in which case it would have
called upon us to tell someone--I mean the President--I should clarify
that as the President has a couple of friends from--a friend from
Oxford, who's from Germany, but he's a personal friend of the
President's that we would not have told the NSC about.
Question. Are you saying you don't ever recall foreigners being at
radio addresses, or are you saying you don't recall checking out
foreigners with the NSC?
Answer. I don't recall checking out foreigners with the NSC.
Question. Okay. And just to clarify, was there--is there somebody
else besides yourself in the office who--whose responsibility it would
have been to contact the NSC if someone from a foreign country was
going to attend a radio address that you know of.
Answer. I don't know of anyone else.
Question. Okay. Can you tell me what happened after the President
inquired about these individuals? Did you take any action after that?
Answer. Again, I have--I believe that I would have responded to his
inquiry. And I have a vague recollection that maybe I took the list of
names to Ms. Soderberg or to Tony Lake's office to say these people
have been in the radio address. You know, is there a problem with any
of the names? Do you know who these people are. But I don't
specifically recall what I did on that day.
EXAMINATION BY MS. SAFAVIAN:
Question. Do you recall who you would have contacted at the NSC?
Answer. On the morning of the radio address?
Question. No. I am sorry. I thought we determined that you did not
contact the NSC on the morning of the radio address.
The Wilson. I don't think that is what she testified.
The Witness. No.
The Wilson. Is it possible to have the reporter read back her
answer to that question?
Ms. Safavian. I don't think it was a specific question.
The Witness. The prior question that I just responded to.
The Wilson. She was testifying about, in response to your question,
about what Kelly did subsequently with respect to the President's
concern, or some question like that.
The Witness. Uh-huh. What happened that morning.
The Wilson. I am not sure she specified it as being that morning.
But if we could just get the question and answer read back then we will
all be on the same page.
[The reporter read back as requested.]
The Witness. Morning. That's where we were.
EXAMINATION BY MS. SAFAVIAN:
Question. So you did something that morning, or you----
Answer. I said I did not specifically recall, but I think that I
may have responded to the President's inquiry.
Question. The morning----
Answer. At that time.
Question. The morning of that radio address on March 11th, 1995?
Answer. I believe I may have.
Question. Okay. And do you recall who you would have contacted at
the NSC?
Answer. I just.
Mr. McLaughlin. That's a weird question because you are asking it
in the would have form. Why don't you reconsider the way to get a--a
proper way to get the information you are looking for, counsel?
EXAMINATION BY MS. SAFAVIAN:
Question. Do you recall who you contacted at the NSC?
Answer. I just stated that I may have contacted Ms. Soderberg, Mr.
Lake or someone in their office but, no, I do not specifically recall
that morning.
Question. I have just handed you what--a document that is Bates
Stamp EOP005438, that is an e-mail from Melanie B. Darby to Rosanne
Hill, Stanley Roth and Robert Suettinger.
The date of that is April 7th, 1995. Am I reading that correctly?
Answer. Yes.
Question. Why don't you go ahead and read that e-mail.
Mr. McLaughlin. Have you seen this document before?
The Witness. No.
Okay. I have read it.
EXAMINATION BY MS. SAFAVIAN:
Question. Okay. Do you know who Melanie B. Darby is?
Answer. I assume it's Brook Darby, who works at the NSC, but
Melanie I have never heard Melanie B. Darby.
Question. Okay. Do you know a Brook Darby at the NSC?
Answer. Yes.
Question. Is she somebody that you contacted regarding the
President's concern of Johnny Chung and these individuals from China?
Answer. I may have, yes.
Question. Would anybody else in your office have contacted the NSC
besides yourself?
The Wilson. You are asking her to speculate?
Mr. McLaughlin. It's a weird question, counsel. Would have? After
she states that she may have contacted somebody you are asking if there
is anybody else who would have contacted. I don't think you have laid
any kind of a proper predicate or foundation to start going into
questions like that.
Furthermore, you are the one who said the committee is not
interested in speculation so I would think you would want to ask a more
carefully constructed question.
EXAMINATION BY MS. SAFAVIAN:
Question. Can you answer the question?
Answer. People at the White House on a daily basis talked to
every--I mean, it's a very broad, broad question.
Question. If you look at the third full paragraph down, it states,
``It turns out they are various Chinese gurus and the POTUS wasn't sure
we'd want photos of him with these people circulating around. Johnny
Chung, one of the people on the list, is coming in to see Nancy
Hernreich tomorrow and Nancy needs to know urgently whether or not she
can give him the pictures. Could you please review the list ASAP and
give me your advice on whether we want these photos floating around?
(FYI-these people are major DNC contributors and if we can give them
the photos, the President's office would like to do so).''
Did I read that correctly?
Answer. Yes.
Question. You had stated that you believe that you did something,
you contacted the NSC or did something about the President's request
that morning of the radio address.
Answer. I believe so.
Question. Okay. That was March 11th, 1995.
Answer. Uh-huh.
Question. Do you have any knowledge as to why this e-mail
requesting that information is dated April 7th, 1995?
Mr. Wilson. You are asking her why----
The Witness. It is dated that----
The Wilson [continuing]. Brook Darby dated it April 7th or why
there isn't a date earlier? I am having a hard time. You are asking her
to speculate as to why----
The Witness. It is dated----
The Wilson [continuing]. There isn't an earlier date on this?
EXAMINATION BY MS. SAFAVIAN:
Question. Do you recall contacting Brook Darby on April 7th, 1995,
about this?
Answer. I am not saying that I never contacted Brook Darby about
this, but I do not recall calling her on April 7th, 1995.
Question. Do you recall it being earlier than April 7th, 1995?
Answer. No.
Mr. McLaughlin. You keep saying it as if there was testimony that
it happened. She may have, I think was her testimony.
The Witness. It would not have been unusual for me to call Brook
Darby or--if this was a situation to follow up with her. I do not know
when this occurred. I mean, you are asking me to recall something that
was several years ago and to recall dates.
I just--I wish I could do that for you. I wish that I could
remember everything for you.
Mr. McLaughlin. Was Brook Darby a contact person at the NSC?
The Witness. Yes. She--it is my understanding that she worked for
Nancy Soderberg who was like----
Mr. McLaughlin. Can we pause? There is somebody else in the room
here. Can we go off the record?
[Recess.]
Ms. Safavian. Could you read back the last question?
[The reporter read back as requested.]
The Witness. Can I clarify my answer?
EXAMINATION BY MS. SAFAVIAN:
Question. Sure.
Answer. I mean, this is not my e-mail. I did not send this e-mail
so I don't know why the date would or wouldn't have been earlier or
later. Let's start again.
Question. Do you have any recollection of contacting Brook Darby
either on April 7th, 1995, or a day or two before
April 7th, 1995?
The Wilson. Why don't you ask her just if she has a recollection of
talking to Brook Darby on this subject, because you are going to get
hung up if you ask her about specific dates. Would that work for you?
Ms. Safavian. That's fine. I thought we had covered that earlier.
EXAMINATION BY MS. SAFAVIAN:
Question. Do you have any recollection of speaking with Ms. Darby
about these individuals?
Answer. I don't recall a specific conversation, but it would not
have been unusual for me to talk to Ms. Darby, and if I was trying to
figure out what to do with these photographs as the e-mail indicates
Nancy was trying to figure out what to do with these photographs, so it
would not have been unusual for me to have contacted Ms. Darby to check
up on them and see where--what we should do with them.
Question. Okay. And you testified that you have never seen this
document before?
Answer. No, I have never seen it.
Ms. Safavian. Before I forget, let me mark that as Exhibit KC-4.
[Crawford Deposition Exhibit No. KC-4 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Let me hand you now another e-mail. This time it is from
Robert Suettinger. It is also dated April 7th, 1995. And if you would
just go ahead and take a moment to take a look at that.
Answer. Okay.
Ms. Safavian. Just so the record is clear, this document we are
looking at is EOP 005439, which I will mark as Exhibit KC-5.
[Crawford Deposition Exhibit No. KC-5 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Crawford, have you ever seen this document before?
Answer. I don't believe I have ever seen this, no.
Question. Do you recall or have any recollection of Ms. Darby
contacting you in response to the White House's request to look into
the background of these individuals?
Answer. I am sorry. Will you repeat the question again?
Question. Sure. Do you recall Ms. Darby contacting you, in response
to your office or the White House request for the NSC to look into the
backgrounds of these individuals?
Answer. I vaguely recall her--yes, her contacting me and telling me
some of what is in here, but I don't think I have seen this document.
Question. Okay. Do you recall when she would have contacted you?
Answer. No.
Question. Okay. Was it by correspondence or by telephone? Do you
recall how she contacted you?
Answer. I don't remember.
Question. And can you tell me what she said?
Answer. I don't recall specifically, although--although, I mean,
again, in this situation I have heard press accounts of an e-mail
saying that, you know, Johnny Chung was--some of this language that was
in here. So I am not sure if it is from my knowledge of talking with
Brook or from my, you know, hearing other accounts of what this e-mail
said. But some of it sounds familiar.
Question. Do you recall--first of all, do you know--we will just go
forward a little bit. Do you know whether the White House released the
photos of Johnny Chung and the Chinese delegation with the President?
Answer. I don't know for sure whether they were released or not,
no. I don't remember sending them out, but I am not saying that they
were or weren't sent out.
Question. Okay. Do you recall whether or not you would have waited
to hear from the NSC to make the decision whether to send these out, is
that something that your office would have done?
Answer. I would have waited probably.
Question. Okay.
Answer. That would have been my normal practice, if I had made an
inquiry about this, then I would have followed up, as this indicates.
Question. Okay. I know you say you don't recall exactly what Ms.
Darby said to you. You just have a recollection about some of these
items in this e-mail. Do you recall whether her advice to you was to
release the photos or not to release the photos?
Answer. I don't recall. But I assume that----
Mr. Wilson. I caution you not to assume.
The Witness. Okay.
Mr. Wilson. If you want to talk about your normal practices, that's
fine.
The Witness. I don't recall.
Mr. Wilson. I don't want anyone to suggest that something you are
assuming or speculating about is something that actually happened.
Mr. McLaughlin. I am sorry. Could we go off the record?
[Off the record.]
EXAMINATION BY MS. SAFAVIAN:
Question. Back on the record. Do you recall having a conversation
with Ms. Hernreich about whether to release these photos to Johnny
Chung?
Answer. I am not saying that I did or didn't have a conversation,
but I don't recall a specific conversation, but I am not saying whether
one did or didn't occur. I just don't recall.
Question. Okay. Let me show you a memorandum dated March 28th,
1995, from Betty Currie. If you will just take a look at that real
quick.
Answer. I don't quite understand it.
Question. First of all, have you seen this document before, this
memo?
Answer. No.
Question. Do you know who Betty Currie is?
Answer. Yes.
Question. Who is she?
Answer. She is the President's secretary.
Question. Okay. Do you know who this John is that it seems to be
addressed to?
Answer. Huh-uh.
Question. Does John Frieburg mean anything?
Answer. Jonathan Frieburg?
Question. Jonathan Frieburg, does that mean anything to you?
Answer. Yes.
Question. Who was that?
Answer. He was an intern in our office.
Question. Was there anything in particular that he did which he
would get a memo from Betty Currie about?
Answer. I don't understand. I am sorry. I don't quite understand
your question.
Question. You said he was an intern in the President's office?
Answer. In the President's office. He worked for me.
Question. I am sorry? He worked for who?
Answer. He worked with me.
Question. He worked with you?
Answer. Uh-huh.
Question. Was he also involved in assisting to prepare for the
radio addresses of the President?
Answer. I mean, as much as he sat next to me and may have accepted
a phone call or two or worked with the pictures afterwards, but he did
not have a primary role.
Question. Okay.
Answer. But I--I mean, do you--do we know that that is who this was
to?
Question. It doesn't state so--it doesn't say on the memo.
Answer. I mean, pardon, but it could have been the number one--I
mean--no one called it----
Mr. Wilson. It could be anything.
EXAMINATION BY MS. SAFAVIAN:
Question. This is a redacted copy and we can only do the best with
what we have got.
Answer. I won't speculate.
Question. That's fine. Looking at the paragraph, the only
paragraph, that is still on the memo, it states, Ceandra Scott called.
She was concerned about Johnny Chung. She stated that we should have
called them prior to their coming to the radio address. Apparently they
were in Maggie's office when the request came, and Maggie said she
didn't know but to contact DNC.
Answer. But I don't understand the second sentence. Apparently they
were? Who is ``they''?
Question. Well, I was going to ask you, do you know?
Answer. Do I understand this? No.
Question. Do you know what this is in reference to?
Answer. No.
Mr. McLaughlin. Just so we are clear, this reference is to you; it
is not from you; you have never seen it?
The Witness. I have never seen it and I would not comment on it
because it doesn't make any sense. I mean, I am sorry.
I don't understand it. I shouldn't say it doesn't make sense. I
don't understand it.
EXAMINATION BY MS. SAFAVIAN:
Question. Looking at this does not--you are unable to shed any
light?
Answer. Speculate, I am unable to even speculate----
Question. Okay.
Answer [continuing]. What this is.
Ms. Safavian. Since we did discuss it, let me mark that as KC-6.
[Crawford Deposition Exhibit No. KC-6 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Crawford, do you recall receiving any phone calls
from individuals in the First Lady's office or somebody at the DNC
asking about whether or not the White House was going to release these
photos of Johnny Chung and the Chinese delegation?
Mr. Wilson. Are you talking about phone calls from the First Lady's
office?
Ms. Safavian. From the First Lady's office or the DNC.
Mr. McLaughlin. That's a compound question. Why don't you ask her
one at a time?
Mr. Wilson. If you can answer.
The Witness. I don't have specific--I mean, I dealt with maybe 50
to 100 radio addresses and there were 50 to 100 people in every radio
address and there were pictures from all of them. I don't have a
specific recollection. It would not be unusual that people would call
and say, hey, can I pick up so and so's pictures; can I get this? It
would not be unusual. I am not telling you that it never happened but I
don't have a specific recollection of a specific call asking for these
specific pictures.
EXAMINATION BY MS. SAFAVIAN:
Question. Let me show you a letter from Johnny Chung to Maggie
Williams dated April 5, 1995; if you could just go ahead and take a
quick look at that.
Answer. Uh-huh.
Question. Do you recall Maggie Williams ever contacting you or
anybody else in your office about the status of these photographs?
Answer. Again, I just--I think I just answered the question. I do
not have a specific recollection of a contact about these specific
photos, but I cannot sit here today, three years later, and tell you
that a conversation did or did not occur. I dealt with hundreds of
photographs and hundreds of requests to get these photographs.
Mr. McLaughlin. So after viewing this letter, which is neither to
you nor from you nor mentions you, your answer is still the same as it
was before?
The Witness. Yes.
Mr. McLaughlin. This document does not refresh your recollection?
The Witness. No.
Ms. Safavian. Let me mark that as KC No. 7.
[Crawford Deposition Exhibit No. KC-7 was marked for
identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Crawford, I am now handing you a fax cover sheet from
Johnny Chung to Carol Khare. The subject is Photo. In the comments it
says, quote: The White House assures me that you now have the pictures.
Hurray. If you don't, give me a call. Have a good trip.
Does this refresh your recollection at all that the White House
released these photographs to Johnny Chung?
Answer. No, it does not refresh my recollection. I don't know who
Carol Khare is.
Ms. Safavian. Okay. Let me mark that as Exhibit KC No. 8.
[Crawford Deposition Exhibit No. KC-8 was marked for
identification.]
Mr. McLaughlin. Of course the document speaks for itself but it
says that you may have the pictures. It also says, if you don't. So I
don't think that this document provides any indication one way or the
other. It is a uniquely unhelpful refreshing device.
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Crawford, do you recall when in July you left the
President's office? I know you said it was July of 1995.
Answer. I don't. I can get the date for you but I don't
specifically recall what--when it was. I think it was July.
Question. Okay. Let me--because we don't know the exact date, let
me see if you have any knowledge about this next exhibit, which is--
includes several pages. The first page is an AISI fax cover page from
Betty Currie for Irene from Johnny Chung.
If you will just go ahead and take a look at the 5 pages that are
attached to this.
Ms. Crawford, do you recall ever seeing this document before?
Answer. No.
Question. Do you have any knowledge of Johnny Chung making a
request to Betty Currie of the President providing him with a
credential letter?
Answer. I have no knowledge.
Question. Would you have ever written any correspondence on behalf
of the President in your duties as staff assistant?
Answer. No, I did not write correspondence from the President in my
duties.
Question. Who normally would do that, do you know?
Mr. Wilson. Who?
Mr. McLaughlin. Who normally would what?
Mr. Wilson. Who normally wrote any correspondence?
Ms. Safavian. Yes, it is very general.
EXAMINATION BY MS. SAFAVIAN:
Question. Who normally would write correspondence?
Answer. The correspondence department or the personal
correspondence department would normally write correspondence for the
President
Ms. Safavian. Okay. Let me just mark that as Exhibit KC No. 9.
[Crawford Deposition Exhibit No. KC-9 was marked for
identification.]
Ms. Safavian. If you will just give me a minute, we may be about
done.
The Witness. Good.
[Discussion off the record.]
EXAMINATION BY MS. SAFAVIAN:
Question. Back on the record. Ms. Crawford, you had testified
earlier that the President expressed concern about whether to release
these photos to these individuals who were from China. Do----
Answer. Can I just clarify? He expressed concern, did we know who
these people were. I believe part of the concern may have also been
that he had had his picture made with them, but I don't think he
specifically told me what his exact concern was.
Question. Okay. Do you have any recollection of the President ever
expressing concern or questioning any other individual's attendance at
a radio address?
Answer. I don't specifically recall other instances but, like I
said, the radio address was a time for his friends and family and staff
members and their family members. So I don't believe that there was
another instance that I can specifically recall, that there were people
in the radio address that he did not know and that I did not know
exactly who they were, or Nancy did not know exactly who they were.
Ms. Safavian. Okay. That's all I have, I believe. Minority counsel
may have a few questions to ask you.
Mr. McLaughlin. Yes, I do want to go over something.
EXAMINATION BY MR. MCLAUGHLIN:
Question. I am sorry that the prior questioning has been so
confused but I just want to walk through it.
Answer. I would just say it is very confusing.
Question. It has been very confusing. I am sorry about that. I just
want to walk through this sort of sequence of events following the
radio address and what you do and don't recall about them just so it is
clear for the record.
Let me--without turning to any of the documents, can you just state
your understanding of what, just--whatever way you think is
appropriate, of what happened following the radio address that Johnny
Chung attended and what steps you may or may not have taken?
Answer. Sure. As I mentioned, I recollect that the President seemed
concerned that--as I have said, this radio address was a very informal
gathering and that there were--it was an unusual group on this Saturday
in that these businessmen from China were attending the radio address,
and so the President, I believe, voiced his concern to me and/or Nancy,
saying, who are these people? Do we know where they--you know, who
requested their attendance?
And since I didn't have a really good answer, although I believe I
said that the request came from the DNC, I believe he asked me and/or
Nancy to check with Tony Lake or the National Security Council.
And I don't specifically recall what I did that morning, but I am
basing what I am telling you on what I--normal practice if the
President asked me to check something out, I assume I would have done
it in a timely fashion.
Question. So was it a normal practice for you to contact Brook
Darby if you had to have an interaction with the NSC? Would she
normally be the person you would contact?
Answer. Yes. As we actually--when I got up to use the restroom, we
were talking about this. But she is--it is my understanding that she
was the assistant to the staff director, I think is what Nancy titled--
Nancy Soderberg's title was. So she was sort of my counterpart at the
NSC.
Question. And then would it be normal practice for the person that
you contacted at the NSC to also be the person to contact you back and
relay whatever information had to be relayed back from the NSC?
Answer. I am sorry. Can you state that again?
Question. It was a confusing question. I am falling into that trap.
If you contacted Brook Darby with a question, would it be normal
practice for Brook Darby to contact you back with whatever information
had to be passed back?
Answer. Yes. Yes.
Question. Okay. Can I direct your attention to the exhibit that's
been marked KC-4?
Answer. Uh-huh.
Question. If I recall your earlier testimony, you may have
contacted somebody at the NSC the day of the radio address or shortly
thereafter?
Answer. Uh-huh.
Question. Okay. Turning to Exhibit 4, the second sentence of the
third full paragraph states, Johnny Chung, one of the people on the
list, is coming to see Nancy Hernreich tomorrow and Nancy needs to know
urgently whether or not she can give him the pictures.
Is it possible that you might have made a second call to Brook
Darby or somebody else on the NSC staff in light of the fact that
Johnny Chung was coming in in person, or according to this document was
coming in in person?
Answer. Absolutely. That's very likely.
Question. It is entirely possible you made one contact?
Answer. Yes.
Question. You made a second contact later?
Answer. Yes.
Question. You don't recall specifically?
Answer. No.
Question. But it is possible?
Answer. It is very possible.
Mr. Wilson. You need to let him finish the question before you
answer.
The Witness. I am sorry.
Mr. McLaughlin. That's all I have. I want to thank you on behalf of
the Minority members of the committee. We want to thank you for the
time to speak with us.
The Witness. Absolutely.
Ms. Safavian. That's all we have. Thank you.
The Witness. Great. Thank you.
[Whereupon, at 11:55 a.m., the deposition was concluded.]
[The exhibits referred to follow:]
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[The deposition of Carol Khare follows:]
Executive Session
Committee on Government Reform and Oversight,
U.S. House of Representatives,
Washington, DC.
DEPOSITION OF: CAROL KHARE
Monday, November 10, 1997
The deposition in the above matter was held in Room 2247, Rayburn
House Office Building, commencing at 1:15 p.m.
Appearances:
Staff Present for the Government Reform and Oversight Committee:
Jennifer Safavian, Investigative Counsel; Robert A. Rohrbaugh, Senior
Investigative Counsel; Jason Hopfer, Majority Staff; Christopher Lu,
Minority Counsel; and Michael J. Yeager, Minority Counsel.
For MS. KHARE:
W. NEIL EGGLESTON, ESQ.
EVAN J. WERBEL, ESQ.
HOWREY & SIMON
1299 Pennsylvania Ave., N.W.
Washington, D.C. 20004-2402
Ms. Safavian. Good morning. On behalf of the members of the
Committee on Government Reform and Oversight, I appreciate and thank
you for appearing here today. This proceeding is known as a deposition.
The person transcribing this proceeding is a House reporter and notary
public. I will now request the reporter place you under oath.
THEREUPON, CAROL KHARE, a witness, was called for examination by
Counsel, and after having been first duly sworn, was examined and
testified as follows:
Ms. Safavian. I would like to note for the record those present at
the beginning of this deposition. My name is Jennifer Safavian, and I
am the designated Majority counsel for the committee. I am accompanied
today by Jason Hopfer, who is with the Majority staff and also with Bob
Rohrbaugh, who is only going to be with us for a short time, I believe.
Michael Yeager is the designated Minority counsel and he is accompanied
by Christopher Lu.
Ms. Safavian. Ms., is it Khare.
The Witness. Khare.
Ms. Safavian. Ms. Khare is accompanied by Neil Eggleston and Evan
Werbel.
Although this proceeding is being held in a somewhat informal
atmosphere, because you have been placed under oath, your testimony
here today has the same force and effect as if you were testifying
before the committee or in a courtroom.
Mr. Eggleston. I must say, this is one of the most formal
depositions I have ever attended, in a hearing room. Those of us in
private practice think this is impressive.
Ms. Safavian. No comment on my part.
Mr. Eggleston. I'm sorry to interrupt you.
Ms. Safavian. You are interrupting my script.
If I ask you about conversations you have had in the past and you
are unable to recall the exact words used in the conversation, you may
state that you are unable to recall those exact words and give me the
gist or substance of any such conversation, to the best of your
recollection.
If you recall only part of a conversation or only part of an event,
please give me your best recollection of those events or parts of
conversations that you recall. If I ask you whether you have any
information upon a particular subject, and you have overheard other
persons conversing with each other regarding it or have seen
correspondence or documentation regarding it, please tell me that you
do have such information and indicate the source, either a conversation
or documentation or otherwise from which you derived such knowledge.
Before we begin the questioning, I want to give you some background
about the investigation and your appearance here. Pursuant to its
authority under House Rules 10 and 11 of the House of Representatives,
the committee is engaged in a wide-ranging review of possible political
fund-raising improprieties and possible violations of law.
Pages 2 through 4 of House Report 105-139 summarizes the
investigation as of June 19, 1997, and encompasses any new matters
which arise directly or indirectly in the course of the investigation.
Also, pages 4 through 11 of the report explain the background of the
investigation. All questions related either directly or indirectly to
these issues, or questions which have a tendency to make the existence
of any pertinent fact more or less probable than it would be without
the evidence are proper.
The committee has been granted specific authorization to conduct
this deposition, pursuant to House Resolution 167, which passed the
full House on June 20, 1997. Committee rule 20, of which you have
received a copy, outlines the ground rules for the deposition. Majority
and Minority counsel will ask you questions regarding the subject
matter of the investigation. Minority counsel will ask questions after
Majority counsel has finished.
After the Minority counsel has completed questioning you, a new
round of questioning may begin. Members of Congress who wish to ask
questions will be afforded an immediate opportunity to ask their
questions. When they are finished, committee counsel will resume
questioning.
Pursuant to the committees rules, you are allowed to have an
attorney present to advise you of your rights. Any objection raised
during the course of the deposition shall be stated for the record. If
the witness is instructed not to answer a question or otherwise refuses
to answer a question, Majority and Minority counsel will confer to
determine whether the objection is proper. If counsel agree a question
is proper, the witness will be asked to answer the question. If an
objection is not withdrawn, the Chairman or a Member designated by the
Chairman may decide whether the objection is proper.
This deposition is considered as taken in executive session of the
committee, which means that it may not be made public without the
consent of the committee pursuant to clause 2(k)7 of House Rule 11. You
are asked to abide by the Rules of the House and not discuss with
anyone, other than your attorney, this deposition, and the issues and
questions raised during this proceeding.
Finally, no later than 5 days after your testimony is transcribed
and you have been notified that your transcript is available, you may
submit suggested changes to the Chairman. The transcript will be
available for your review at the committee office. Committee staff may
make any typographical and technical changes requested by you.
Substantive changes, modifications, clarifications or amendments to the
deposition transcript, submitted by you, must be accompanied by a
letter requesting the changes, and a statement of your reasons for each
proposed change.
Answer. letter requesting any substantive changes, modifications,
clarifications or amendments must be signed by you. Any substantive
changes, modifications, clarifications or amendments shall be included
as an appendix to the transcript conditioned upon your signing of the
transcript. Do you understand everything we have gone over so far.
The Witness. Yes.
Ms. Safavian. Do you have any questions about anything we have gone
over?
The Witness. No.
Ms. Safavian. I will be asking you questions concerning the subject
matter of this investigation. Do you understand that?
The Witness. Yes.
Ms. Safavian. If you don't understand a question, please say so and
I will repeat it or rephrase it so that you understand the question. Do
you understand that you should tell me if you don't understand one of
my questions?
The Witness. Yes.
Ms. Safavian. The reporter will be taking down everything we say
and will make a written record of the deposition. You must give verbal,
audible answers because the reporter cannot record what a nod of the
head or other gesture means. Do you understand you must give verbal
answers?
The Witness. Yes.
Ms. Safavian. And not an uh-huh or huh-huh.
The Witness. Yes.
Ms. Safavian. If you can't hear me, please say so and I will repeat
the question or have the court reporter read the question back to you.
Do you understand that?
The Witness. Yes.
Ms. Safavian. Please wait until I finish each question before
answering and I will wait until you finish your answer before I ask the
next question. Do you understand this will help the reporter, as she
cannot take down what both of us are saying at the same time?
The Witness. Yes.
Ms. Safavian. Your testimony is being taken under oath as if we
were in court and if you answer a question, it will be assumed that you
understood the question and the answer was intended to be responsive to
it. Do you understand that?
The Witness. Yes.
Ms. Safavian. Are you here voluntarily or are you here as a result
of a subpoena?
The Witness. I am here voluntarily.
EXAMINATION BY MS. SAFAVIAN:
Question. Will you please state your full name and spell it for the
record?
Answer. My name is Carol Fick Khare, K-H-A-R-E.
Question. Have you ever used or been known by any other names?
Answer. No.
Question. Can you tell me what your date of birth and Social
Security number are?
Mr. Yeager. I object to the request for the Social Security number.
I am not quite sure why you need her Social Security number,
particularly in light of the fact that these depositions may be made
public, and in the past, if the past is any indication of future
practice, they may be posted on the Internet and Ms. Khare might have
legitimate privacy concerns about that.
Mr. Eggleston. Well, I mean, I think that is a valid objection. I
don't have any objection to giving it to you, but it is true all these
get posted on the Internet and to have her personal data available to
the committee for some reason, I am happy to give it to you separately,
but I prefer not anybody who looks at the Internet have identifying
characteristics, particularly as you are seeing more and more stories
about people impersonating people using their Social Security number. I
don't want to refuse to answer and withhold information from you, but
I'm not sure why you need it in the deposition, so that any Internet
viewer can see it, as opposed to me giving it to you.
Ms. Safavian. Well, first of all, let me correct something the
Minority counsel has said. It is not customary we release all the
depositions on the Internet. Like I said, this deposition is taken in
executive session and it is not made public until the committee votes
to make it public.
Secondly, we ask for the date of birth and Social Security number
only for identification purposes, for documents we may receive in
response to a subpoena. If it has, perhaps your name on it and we are
not exactly sure it is you, if there happens to be another Carol Khare
out there or the entire name is not there and the Social Security
number is, it just helps us identify if this document, in fact, relates
to you and we don't want you to get mixed up with anybody else.
Mr. Yeager. If we can go off the record, maybe we can get this
information for you. You would have the information, you could use it
for your own internal purposes and you wouldn't have the issue of
public release. It is certainly possible the deposition transcript
could be released.
Mr. Eggleston. In fact, as to her, it's likely, because she has
been notified she is going to be a hearing witness and my understanding
is the committee, as a routine matter, releases the depositions of
hearing witnesses, so I think, in fact, her deposition is going to be
on the Internet by Saturday.
Mr. Yeager. I don't see why you can't get it off the record.
Ms. Safavian. I don't have a problem with that. Is this something
you would be willing to do off the record?
Mr. Eggleston. Sure.
Ms. Safavian. Okay. If we could go off the record.
[Off the record.]
Ms. Safavian. Back on the record.
EXAMINATION BY MS. SAFAVIAN:
Question. Can you please tell us what your current address is?
Answer. Is that all right?
Mr. Eggleston. Yes, that is different.
The Witness. [Redacted].
EXAMINATION BY MS. SAFAVIAN:
Question. And I know there was a time you were residing in
Washington, D.C.?
Answer. Yes.
Question. Do you happen to recall where that was?
Answer. [Redacted].
Question. And for what time period were you living in Washington,
D.C.?
Answer. From February of 1995, until the end of January, 1997.
Question. You said January of '97?
Answer. Yes.
Question. Have you ever lived outside the United States?
Answer. No.
Question. Can you tell me what college you attended and when you
graduated?
Answer. I graduated from Columbia College in Columbia, South
Carolina, in 1965.
Question. And what degree did you receive?
Answer. A B.A. in English.
Question. Did you receive any other degrees after that?
Answer. No.
Question. Have you spoken with anyone other than your counsel about
this deposition today?
Answer. The fact that I was given the deposition or what I was
going to say.
Question. Well----
Answer. I mean, other people know I am giving this deposition
today.
Question. You have mentioned to other people you were going to be
giving a deposition today?
Answer. Yes.
Question. Would those be family and friends?
Answer. Yes.
Question. Okay. Did you discuss with anyone, other than your
counsel, the substance of what this deposition was going to cover
today?
Answer. No.
Question. Did you review any documents in preparation for your
deposition?
Answer. Yes.
Question. Can you generally tell me what it was that you reviewed?
Mr. Eggleston. Well, I don't think you have reviewed anything
except with me.
The Witness. Right.
Mr. Eggleston. And I am not going to let her answer questions about
things she reviewed with me, so you can ask her whether she has
reviewed things independent of me, and I am happy to have her answer,
although I think the answer is, no, but I am not going to let her go
into the method by which we prepared for testimony.
Ms. Safavian. Well I don't want to tread anywhere near attorney-
client privilege.
EXAMINATION BY MS. SAFAVIAN:
Question. Did you review any documents outside the presence of your
counsel?
Answer. No.
Question. Okay. Have you given another deposition, besides the one
that you are here for today?
Answer. No.
Question. Have you been asked by the DNC to help collect documents
in response to either the House subpoena or the Senate subpoena or the
Department of Justice subpoenas?
Answer. Yes.
Question. When were you asked to do that?
Answer. While I was still at the DNC, and since then, I mean, all
my documents stayed there pretty much.
Question. You did not take any documents with you when you left?
Answer. Only personal things.
Question. Do you recall when you were asked to collect these
documents?
Answer. During the time before I left there, whenever subpoenas
were issued, and I don't remember, but I think from maybe November
until January of '96 and '97.
Question. And who asked you to sort of collect these documents?
Answer. Joe Sandler at the DNC council.
Question. And were you just collecting documents that would have
been in your possession?
Answer. Yes.
Question. Did you happen to collect any documents that would have
been in Don Fowler's possession?
Answer. No, I was not the person who did that.
Question. Can you just tell me how it was you came to work at the
DNC?
Answer. I worked in South Carolina for Don Fowler, and so when he
came to the DNC to be Chair, he asked me to come with him.
Question. And how long have you known Don Fowler?
Answer. Since the early seventies.
Question. And how did the two of you meet?
Answer. He was Chair of the South Carolina Democratic Party and I
was working in the headquarters as a volunteer.
Question. So you weren't really working for him, per se?
Answer. Not when I first met him. I began working for him in 1977.
Question. And what were you doing for him in 1977?
Answer. He has an advertising, public relations, community
relations firm and I have done a variety of things in that office,
public relations work for the most part.
Question. And if you can just kind of map that out for me, from
1977, how long--I don't expect you to get into a lot of detail here,
but have you been with Don Fowler from 1977?
Answer. Yes, until now.
Question. Until now?
Answer. Yes.
Question. Are you currently still with him?
Answer. Yes.
Question. You are?
Answer. Yes.
Question. How many different jobs would you say in that time period
did you hold for Mr. Fowler?
Answer. Well, it is a very small firm, 8 or 10 people, and so I
have always been in the same job. I have never been told you are now--
your title is now this, this. Nobody has titles where we are, so I have
done a variety of things, but it was always just me.
Question. So you have worked in this firm with him from 1977
until----
Answer. Until we came to Washington, and then when we went back to
South Carolina and back working at that firm.
Question. And the name of that firm?
Answer. It is Fowler Communications.
Question. And that is located in South Carolina?
Answer. Columbia, South Carolina.
Question. Thank you. What was your initial, I guess, reaction, when
Mr. Fowler asked you to join him at the DNC?
Answer. Oh, I was glad to do it.
Question. Did he tell you what it was he wanted you to help him
with?
Answer. Yes.
Question. What did he tell you?
Answer. He said he wanted me to run the Chairman's office and to do
some of his personal political kinds of things, represent him in some
areas where he couldn't be present.
Question. And when did the two of you move out here and begin
working at the DNC?
Answer. Late January of 1995, and then I actually went back to
South Carolina for a couple weeks in early February and then came back
here again. I just had to go back and finish up things there.
Question. And then you were, from, say, February?
Answer. From February on.
Question. Until----
Answer. Until the end of January of '97.
Question. You have been out here the entire time working at the
DNC?
Answer. Yes.
Question. When did Don Fowler leave the DNC?
Answer. I don't remember the exact date, but it was January 20
something of 1997.
Question. And that was about the time----
Answer. That was when I left.
Question. Okay. And can you tell me, he asked you to pretty much
run the Chairman's office?
Answer. Yes.
Question. How would you describe your job responsibilities or
duties?
Answer. Well, I hired and fired the staff that was within the
Chairman's office, which is ten or so people. I gave them assignments,
I made certain that telephones were answered and calls returned, and
requests filled and letters answered or written. I represented the
Chairman with other staff, outside the Chairman's office, in staff
meetings or just to meet with other members and ask them to do things,
or find out what they were doing, and on some occasions, I have met
with other people outside of the office, a Member of Congress or
somebody like that, and just whatever details came up in the Chairman's
office, I took care of.
Question. Would those other meetings that you just mentioned that
you would have outside the office, would those be meetings that you
would attend because Chairman Fowler was unable to attend those?
Answer. Right, just something he was busy and he wanted somebody in
the meeting, so I would go.
Question. And were you there pretty much just to take notes for him
or was it a more active role?
Answer. Well, it would depend on the meeting, sometimes it would be
just take notes. Other times it would be because we were planning some
event or something that was going to go on and so I would give the DNC
Chairman's point of view.
Question. You said these were meetings a lot with Members of
Congress?
Answer. Well, no, not a lot with Members of Congress, but once or
twice with Members of Congress. I met several times at the DNC with
Members of Congress who came there. Frequently, I met with people just
because he couldn't do it that day, he was busy, but didn't want to
neglect these people so I would meet with them.
Question. You mentioned that you pretty much took care of the
Chairman's office, the hiring and firing of about ten individuals?
Answer. Yes.
Question. Were you the supervisor, then, over those individuals?
Answer. Yes.
Question. And at that time, can you recall who those individuals
were?
Answer. Well, it was not a steady group from beginning to end.
There were some people there when we arrived who gradually were
reassigned to other places or they left for other jobs and other people
came in. They were--I guess every Chairman's office is different from
every other and we had certain things we wanted done that maybe had not
been done before, so we had to bring in the appropriate kinds of people
to do those things.
Question. What types of things would those about ten individuals
do? What were their job responsibilities?
Answer. Scheduling the Chairman's--whatever his schedule was,
handling telephones, correspondence. We had somebody who would do
briefings for him. Several people who just really just were sort of
utility people, if we needed somebody to put together a meeting or
somebody to write a letter, these people could do it, staff assistant I
guess was their title.
Question. Okay.
Answer. And I guess that is all the specific roles people had.
There was a driver, but the driver also did things like memos.
Question. A driver?
Answer. Yes.
Question. And he would also do memos?
Answer. Yes, he would do clerical kinds of things when he wasn't
out driving the car.
Question. Did you have any supervisory role over any other
individuals in the office?
Answer. No.
Mr. Yeager. By office, what do you mean.
The Witness. You mean outside the Chairman's office.
Ms. Safavian. Yes.
The Witness. No.
EXAMINATION BY MS. SAFAVIAN:
Question. Okay. Did you ever prepare any letters or memos on behalf
of the Chairman?
Answer. Yes.
Question. Was there any distinction as to what letters or memos you
would prepare, versus the other staff assistants you just mentioned?
Answer. Not any specific line that was drawn. I would assign people
to answer letters or write memos or whatever, and some things I
assigned to myself, depending sometimes on the subject matter,
sometimes on who the recipient would be.
Question. Do you recall, were there any specific subject matters
that were solely your responsibility, versus somebody else's?
Answer. No, there are just some things I knew more about than
somebody else might. It is not that I don't want somebody else handling
this area. It was I can do this better than somebody else, so I would
do it myself.
Question. Would you pretty much review other correspondence that
were prepared by other staff assistants?
Answer. Yes.
Question. Did you prepare Chairman Fowler's schedule?
Answer. No, I did not prepare a schedule.
Question. You had a copy of his schedule, obviously?
Answer. Yes.
Question. So you were aware of his daily comings and goings.
Answer. Yes.
Question. Did you ever travel with Chairman Fowler?
Answer. Almost never. During the campaign, during the fall of '96,
because his travel was much more--what he did on his trips was much
more intense, there were a lot more activities during the day. We did
have staff traveling with him, and we sort of rotated people on to the
traveling crew, about three people would travel with him, and I did two
or three trips with him. It was all really just to give the others a
break.
Question. Did you attend many meetings with Chairman Fowler?
Answer. A fair number. Not every meeting, by any means.
Question. What types of meetings would those be?
Answer. Meetings with the DNC staff, I almost always attended. If
there was a meeting whose subject I was particularly interested in, I
might sit in on it. If there was a meeting that I might get an
assignment out of, then I would sit in there. But I didn't sit in on
every meeting and sometimes I would ask another staff person to go in
there because I don't have time to be in the meeting, go in and take
notes.
Question. When you generally attended the meetings, did you take
notes at these meetings?
Answer. Frequently. Not intensive notes, not to cover a summary of
the meeting, but of what assignment I might have coming out of the
meeting or might have need to give to somebody else or something that I
might think that Mr. Fowler would want to be reminded of after the
meeting. But, no, I didn't make a summary of the meeting or anything.
Question. With the notes you took, would you generally keep those
notes?
Answer. No. My normal--I don't like paper and so my normal thing is
to write down something that has to be done and when it is done, I
throw away the paper or the legal pad and that is the end of it.
Question. So you never retain those notes?
Answer. Not that kind of thing, no.
Question. Was there anybody assigned to attend these meetings and
actually take notes of what happened at the meetings?
Answer. Not as a routine thing. I suppose that if there were a kind
of meeting where some summary needed to be made, we would put somebody
in there, but that was not the usual thing.
Question. Was there any one person you would normally assign to do
that if and when you did?
Answer. No.
Question. Would the person who took those notes, would they retain
those notes or what would happen to the notes, if you know?
Answer. I am trying to remember a circumstance when we actually did
that, and mostly I think it would have been a planning meeting kind of
thing, and so if we were planning an event or another meeting or a trip
or something, then whoever had responsibility for that would probably
have taken the notes and would then have gone away to put the event or
the trip together and I don't know what would have happened with the
notes.
Question. Okay. Did you ever attend any meetings with Chairman
Fowler that were held at the White House?
Answer. Once or twice.
Question. Do you happen to recall what the subject matter of those
meetings were?
Answer. I think that one meeting that I attended was a planning
meeting for an event that was coming up, that the President was going
to attend, and so several people from the DNC staff went to that. And
if I attended two with him, it would have been both--both probably
would have been planning for events, I can't remember any other kind of
subject that we would have covered.
Question. Did you ever attend any of the Wednesday meetings that
were held at the White House?
Answer. No.
Question. Do you know which meetings I am talking about?
Answer. I do, but I didn't go to those.
Question. And those were the meetings that were discussing the
budget?
Answer. Right.
Question. Okay. Did anyone ever go to those meetings with Chairman
Fowler?
Answer. Yes, the chief financial officer went with him.
Question. And who would that have been?
Answer. His name is Brad Marshall. The Chief of Staff usually went.
Bobby Watson first and then B.J. Thornberry, and frequently, Joe
Sandler, the counsel, would go, and usually one or two people from
finance, Richard Sullivan and maybe Marvin Rosen, if he was in town.
Question. Okay. Did you only report to Chairman Fowler?
Answer. Yes.
Question. Did you do anything for Chairman Dodd?
Answer. If he did asked me to, I would, but I can't think of many
things I ever did for him. But once or twice, he needed something and I
did it, but he had his own staff over there.
Question. So pretty much, you reported to Chairman Fowler?
Answer. Right, right.
Question. Ms. Khare, can you tell me, when was the first time that
you met Johnny Chung?
Answer. I don't remember the first time I met Johnny Chung. I do
remember the first time I talked with Johnny Chung because it was on
the telephone.
Question. Okay.
Answer. And I am sure that soon after that I met him, but I don't
remember when.
Question. So you believe the first contact you had with Mr. Chung
was over the telephone?
Answer. Yes.
Question. And can you tell me a little bit about that?
Answer. It was in early March of 1995, he telephoned the Chairman's
office. I don't think that he asked for me by name, I don't think he
would have known my name, but I got on the telephone with him, somebody
gave me the call. He identified himself as Johnny Chung, a friend of
the First Lady. He said I am in the First Lady's Office, I have met
with the First Lady, and I have some important Chinese businesspeople
with me. We would like for them to go--I would like for them to go to
the President's radio address. I asked Maggie Williams about that and
she said she couldn't----
Mr. Eggleston. I'm sorry to interrupt, but she is still describing,
the ``I'' in that sentence is Johnny Chung talking.
The Witness. Yes, he said that he would like to go to the
President's radio address with these people, and that Maggie Williams
had told him she could not get him into the radio address, but that
possibly somebody in the Chairman's office could, and so he was calling
to ask if somebody in the Chairman's office could get him in.
EXAMINATION BY MS. SAFAVIAN:
Question. Do you happen to recall when in March this was?
Answer. No, but it was within a few days of the radio address. I
don't know if it was the day before or--I'm not even sure whether that
week--sometimes they tape the radio address on Friday and sometimes it
is on Saturday morning live, and I don't know whether that was a week
that they had it on Friday or Saturday, and I don't know whether it was
one day before or 3 days before when he called me.
Question. Just so I understand something that you said, did you say
he said he was calling--he, meaning Johnny Chung, was calling from
Maggie Williams' office?
Answer. He said I am calling from the First Lady's Office, and I
guess you would say, if you were in Maggie Williams' office, you still
might say you were in the First Lady's Office.
Question. Okay. And he told you that he wanted help getting into
the radio address?
Answer. Uh-huh.
Question. I'm sorry, was that a, yes?
Answer. Yes.
Question. And that Maggie Williams could not help him?
Answer. Yes.
Question. Did he tell you that Maggie Williams suggested that he
contact the DNC?
Answer. Yes, he did, he did.
Question. Okay. And this was your first contact with Mr. Chung?
Answer. s, it was.
Question. At that time he called, did you know anything about him?
Answer. I did not know anything about him.
Question. Never heard his name mentioned before?
Answer. I don't think I had heard his name mentioned before. He was
not somebody who was familiar to me at all.
Question. Let me show you--let me start with this memo. It is a
March 1st, 1995, memo to a Kathleen, whose name is crossed off, and it
is written out Katherine?
Answer. That would be Katherine York.
Question. Katherine York?
Answer. Who was the scheduler.
Question. Okay. Why don't you----
Mr. Eggleston. Is this Carol 1 or are you going to make this an
exhibit?
Ms. Safavian. I will eventually, yes.
Mr. Eggleston. I just like to keep track.
Ms. Safavian. Sure, no problem.
If you would just go ahead and take a look at this document. Just
go ahead and read through it.
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Khare, have you ever seen this memo before?
Answer. I don't remember ever seeing this before.
Question. Okay. And I know you just reviewed it, so as you know,
this memo is asking, it is from Richard Sullivan and Ari Swiller, and
it appears they are asking for a scheduling request for Chairman Fowler
from March 8, and it is to meet with Johnny Chung.
Answer. Yes.
Question. Do you recall this meeting taking place?
Answer. I don't. I have since then seen a schedule or something
that had the name on it, but I didn't specifically remember that.
Question. It says the preferred time at the top is Wednesday
afternoon, March 9?
Answer. Yes.
Question. Then there is an ``8th'' underneath it, and at the bottom
there is a ``Thursday, 9:45 to 10 a.m.'' Do you happen to recall when
you were looking at the schedule when this meeting took place?
Answer. No, I don't.
Mr. Yeager. Do you know if the meeting took place.
The Witness. Only because I have seen a schedule recently that had
this meeting on it. I don't have any information. I was not in this
meeting. I don't remember anything about it.
EXAMINATION BY MS. SAFAVIAN:
Question. You don't recall meeting, perhaps, Johnny Chung, and this
delegation of Chinese businessmen at a meeting they would have had with
Chairman Fowler?
Answer. No, I don't.
Mr. Eggleston. In March of '95.
Ms. Safavian. Yes, in March of '95.
The Witness. No, I don't.
Ms. Safavian. For the record, I am going to go ahead and mark this
as Exhibit CK-1.
[Khare Deposition Exhibit No. CK-1 was marked for identification.]
[Note.--All exhibits referred to can be found at end of
deposition.]
Mr. Yeager. Let me just make an observation for the record. Ms.
Khare hasn't really given any testimony of substance with respect to
this document, so I just want the record to be clear that its inclusion
in the record doesn't suggest that she has given substantive testimony.
EXAMINATION BY MS. SAFAVIAN:
Question. Would requests for Chairman Fowler's schedule ever go
through you first?
Answer. Normally, not through me first. Sometimes people would call
me or come by and say can I get on the Chairman's schedule. I always
then went to the scheduler to find out, because Katherine York, the
scheduler, was so good at what she did, that I didn't have to interfere
in the schedule very much.
Sometimes I was the appeal, if somebody was turned down, but she
handled the schedule. Scheduling was a mystery to me when I went to the
DNC, and of course this was very soon after that. But Katherine did it
so well that I didn't have to deal with it very much, unless, if
somebody came to me and asked, I would help them facilitate that or if
somebody appealed it to me, but as a usual thing, I didn't bother with
the schedule.
Ms. Safavian. Okay. Let me show you a February 27, 1995, letter
from Johnny Chung to Richard Sullivan, and if you will just take a
quick look at that.
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Khare, have you ever seen this letter before?
Answer. No, not that I remember.
Question. Okay. Did Richard Sullivan ever speak to you about this
request from Johnny Chung to meet with the President, the Vice
President, tour the White House, and have a meeting with Chairman
Fowler?
Answer. No.
Question. Did Richard Sullivan ever speak with you at all about
Johnny Chung?
Answer. Not in this time period. I am sure that we--I know that we
had conversations about Johnny Chung at times while I was at the DNC,
but not in this time period, he didn't mention it to me.
Question. When you were looking at this document, it lists--it
gives the names, it provides the names of the delegation and provides a
resume of the individuals, the Chinese delegation?
Answer. Yes.
Question. Do any of these names look familiar to you or do you
recall ever having met any of these individuals?
Answer. No, I don't.
Question. It does not help refresh your recollection?
Answer. No.
Ms. Safavian. I am going to go ahead and mark that as CK-2.
[Khare Deposition Exhibit No. CK-2 was marked for identification.]
Mr. Yeager. Again, Ms. Khare said she has never seen the document.
I am a bit curious as to why you are including it in the record.
Ms. Safavian. Because we were discussing it, just so the record is
clear.
The Witness. I have heard of Irene Wu. I think she was Johnny
Chung's secretary. I think she is somebody I later talked to on the
phone. At this time I wouldn't have known who she was if somebody asked
me, but that is a familiar name, so I think she must have worked in his
office.
Ms. Safavian. Okay. Let me mark this as Exhibit CK-2.
EXAMINATION BY MS. SAFAVIAN:
Question. You mentioned you and Richard Sullivan did have
conversations or discussions about Johnny Chung, not with regard to
this letter we just discussed, but you mentioned other discussions the
two of you had?
Answer. I don't know that I would call it discussions, but if
Johnny Chung wanted something from me, I might ask Richard about it. If
Richard knew that Johnny Chung was going to be there, he might mention
it to me. You know, it was not that we sat around and talked about
Johnny Chung.
Question. If Richard Sullivan were to mention that Johnny Chung was
going to be around, was that to see if he could maybe meet with
Chairman Fowler or something like that?
Answer. No, it would probably be so I could go in the office and
close the door.
Question. What do you mean by that?
Answer. Because later, after I knew Johnny Chung, he had a lot of
requests and usually wanted something, and I usually was busy and
didn't want to deal with it, and so if Richard said he was coming to
the DNC, I probably would be unavailable.
Question. Okay. If Chairman Fowler is having meetings with
individuals who come in to meet with them, and I don't mean White House
people or anybody on the DNC staff, but, for instance, if Johnny Chung
and this Chinese delegation of businessmen were to come visit Chairman
Fowler, is that something that usually a photographer would be present
during the meeting and take pictures of?
Answer. No, unless they brought a camera. We didn't have a
photographer who did that.
Question. There wasn't one on staff at the DNC?
Answer. No.
Question. When Johnny Chung came to you asking for help from the
DNC to get into the radio address, what did you do after you spoke with
him? What was your initial response to his request?
Answer. My initial response was pretty much the same, that I would
make to anybody who came up with a request, I don't know, but I will
see and I will call you back, and he gave me a number, and I didn't
know about the radio broadcast at that time. This was the first I knew
that people went to the radio broadcast. But there was a lot that I
didn't know then because I really had not been there very long, so I
went out into the outer office where the staff assistants were and
asked if anybody there knew whether we could get people into the radio
address. And one of the staff assistants said, well, I know somebody at
the White House who handles that, I will call and see.
I explained here is this man and these Chinese businessmen. He is a
friend of the First Lady, and she said I will call over there and see.
And in a short time she came back in the office and said I called the
person I know and they can go to the radio broadcast, and that was
that, so I then called Mr. Chung and told him that they would be able
to go.
Question. Okay. Let's just back up a little bit. You mentioned that
you didn't know anything about attending radio addresses, so you went
out into a general room where the other staff assistants were?
Answer. Yes, there were five or six people having desks in the
area, all of whom had more Washington experience than I did.
Question. So you just phrased the question to everybody?
Answer. Does anybody know if we can get somebody into the radio
address.
Question. And you said one staff assistant mentioned she knew
somebody at the radio address, who was that?
Answer. Ceandra Scott.
Question. And what did she do at the DNC?
Answer. She worked in the Chairman's office. She was there when we
got there. She did some telephone call kinds of things, answered the
telephone in there. She handled--at that time she handled sort of the
traffic going in and out of the Chairman's office, who went in to see
him, the daily schedule, what do they call that, the day of schedule is
what she called it, and if there were schedule changes during the day,
which there always were, she would call and say he is going to be late
for his lunch or we need these two people to come up 15 minutes later.
She dealt with that all day every day.
Question. So she said--what did she say exactly?
Answer. She said I know somebody at the White House who works in
that area or who handles that kind of thing or something, and she said
I will call my friend or I will call the person I know. I don't know
the name of the person she called.
Question. She didn't mention it to you?
Answer. She probably did at this time, but it was not a name I knew
anything about, and so she went ahead and made the call.
Question. Do you recall if it was a man or a woman that she
mentioned?
Answer. I don't know.
Question. Do you recall what office in the White House?
Answer. No.
Question. And you don't recall specifically what day that Johnny
Chung contacted you about this?
Answer. No, I don't.
Question. If I tell you that Johnny Chung and the Chinese
delegation attended the radio address on March 11, 1995, and that that
was a Saturday, does that help you at all determine what day of the
week Johnny Chung contacted you?
Answer. I assume it was 1 or 2 or 3 days before that when he
called, but I don't know which day of the week he would have called, I
mean, I didn't make notes about it at the time or write it on my
calendar or anything.
Question. So as soon as you hung up the phone with him, you
immediately went and asked anybody if they knew anything about this?
Answer. Yes.
Question. And then do you know when Ms. Scott made her phone call?
Answer. Immediately.
Question. It was immediately?
Answer. Yes.
Mr. Eggleston. Can I stop you a second. I want to be clear. You say
you assumed it was 1 or 2 or 3 days. I take it it could have been 4 or
5 or 6.
The Witness. I guess it could have been, but my sense is it was
very close to time, but I don't want to be pinned down on a day because
I really don't know.
Mr. Eggleston. I just want to make sure you weren't pinned down to
1 or 2 or 3 days, even that you are not sure about.
The Witness. Although, actually, now I know they schedule all that
stuff kind of last minute, so it couldn't have been a month ahead of
time.
EXAMINATION BY MS. SAFAVIAN:
Question. And how do you know that they schedule all this at the
last minute?
Answer. Because since that time I have had occasions to call over
there for somebody else to go to the radio address, more than one time,
and subsequent to this experience, I learned a little bit more about
how things work.
Question. You have subsequently called at the last minute; is that
right?
Answer. Yes.
Question. Is that how you know?
Answer. Well, I have subsequently called and they said we won't
know until shortly beforehand which day he is doing it and whether
there is room for anybody to come.
Question. And so you were telling me before that Ms. Scott
immediately called?
Answer. Yes.
Question. The person she knew at the White House?
Answer. Yes.
Question. Were you present when she had that conversation?
Answer. No, I went back into my office.
Question. And do you recall when she came back and told you what
she had learned?
Answer. It was fairly soon after that, that she came and said they
can go.
Question. When you say fairly soon, do you mean the same day.
Answer. Yes.
Question. Do you mean, you know, within a half-an-hour time span?
Answer. Well, I wouldn't want to be pinned down to that, but he was
waiting for our return phone call, and so I know it was not too long.
Question. Okay. Now, you mentioned that you took down a phone
number where you could contact Johnny Chung?
Answer. Yes.
Question. Do you recall him telling you where he could be reached?
Answer. When I called him back, it was at the First Lady's Office.
Question. It was at the First Lady's Office?
Answer. Yes.
Question. And how do you know that?
Answer. Because they answered the phone, Office of the First Lady.
Question. Okay. That would do it. After Ms. Scott told you that
they were able to get into the radio address, did she tell you anything
further or was it just a simple ``they are able to go''?
Answer. I don't recall what else was a part of that, but I know,
because I have dealt with radio addresses after that, that at some
point, the names and passport numbers or Social Security numbers or
whatever had to be collected and given to the White House because you
can't get in if they don't have that, but whether she said to me--I am
sure she told me how that would be handled, but I just don't remember
what it was, whether I was to get that information and get it to the
White House or whether they were--Johnny Chung was supposed to call it
in to somebody, I just don't remember.
Question. She told you that?
Answer. That it was taken care of.
Question. And then when did you contact Johnny Chung?
Answer. I called him back right then and told him, and I am sure I
gave him some instructions about how to go, what gate to go through or
who to talk to about passport numbers. Whatever it was, I am sure I
must have told him, but I do not remember that.
Question. Why do you say you are sure?
Answer. Because he had to be instructed. Everybody that you take to
the White House or send to the White House has to be told certain
information so they can get in.
Question. Do you recall asking or receiving from Johnny Chung a
list of the Chinese delegation and their names?
Answer. No, I don't remember that.
Question. So do you remember forwarding anything to the White
House?
Answer. I do not remember that, whether I did that or not.
Question. Do you recall asking Ms. Scott to follow up and get that
information?
Answer. No.
Question. Did you ask Ms. Scott to do anything else after she had
made that phone call?
Answer. Unless I got her to take care of that information, which I
do not remember. I do not remember anymore conversation with her about
it.
Question. So you contacted Johnny Chung in the First Lady's office
and told him----
Answer. That he could go to the radio address.
Question. Did he ask anything else of you?
Answer. No.
Question. You don't recall if you told him anything else?
Answer. No. No.
Question. Did you tell Chairman Fowler about this conversation that
you had with Johnny Chung about the radio address?
Answer. I doubt it. I do not remember that I told him that.
Question. Did you subsequently ask anybody at the DNC, who is this
Johnny Chung?
Answer. I must have. Later. There was some things came up the next
week about the photos that were taken at the radio address, or I might
have forgotten about the whole thing. They did take photos of Johnny
and his guests and the President. And some--there was a person on DNC
staff who dealt with photos, with people who had gotten their picture
taken with the President. That was not his whole job but he was the
person that you would talk to if you wanted to get a photo. He came to
me and said, the National Security Council is really mad at you, which
was frightening, because these Chinese nationals got their picture
taken with the President. Now they want the pictures and the National
Security Council does not think that is a good idea. And so then that
sort of made me know more about Johnny Chung, be more aware of Johnny
Chung. And after that there was some back and forth about whether he
could have the pictures, would he get the pictures, that kind of thing,
but I do not remember whether in the end he got them or not.
Question. Let me ask you some questions about what you just stated.
You said that there was an individual at the DNC who handled
photographs.
Answer. Yes. That was not his entire job but that was one of the
things that he did.
Question. Who was that individual?
Answer. His name is Eric Sildon.
Question. Mr. Sildon, then, he is the one that approached you about
Johnny Chung?
Answer. Yes.
Question. Do you recall when this was?
Answer. No. A few days or a week or two after the radio address. I
do not remember just when.
Question. Do you know how Mr. Sildon became aware of this whole
situation?
Answer. I think that Johnny Chung had called the DNC saying, I want
the photos. Then when someone at the DNC tried to get the photos, they
were told we do not want him to have them.
Question. Did Johnny Chung ever contact you and ask you for
assistance in getting these photos?
Answer. I don't think he did. I don't remember that he did.
Question. Do you know if he contacted Eric Sildon and that that is
how he got involved?
Answer. I don't know whether he contacted Eric Sildon or whether he
contacted somebody in DNC Finance, which would have been the routine
thing for him to do as a donor. He would have had a contact person in
DNC Finance. He may have contacted that person who then went to Eric
Sildon and said, get me these photos.
Question. Did Richard Sullivan ever mention to you that Johnny
Chung had contacted him about these photos?
Answer. I do not think so.
Question. You just do not----
Answer. I don't remember that he did.
Question. You just do not recall any individual's name with the DNC
that Johnny Chung may have contacted?
Answer. No, I do not.
Question. Do you know how Mr. Sildon knew that the NSC was holding
on to these photographs?
Answer. I think he called over there, as he routinely would, to get
the photographs and was told, no, you can't have them.
Question. Do you know who he would have contacted?
Answer. No.
Question. Did the DNC have a contact person at the White House?
Answer. There is a White House Photo Office and I guess it was
somebody in there. That is who, if I ever needed a photo that I knew
had been taken at the White House or with White House, by White House
photographers, I would say, can you get me this photo, and Eric or
whoever I asked would say, I will call the White House Photo Office.
Question. So you never yourself called the White House Photo
Office?
Answer. No.
Question. So Mr. Sildon mentioned to you that the NSC was upset
with you?
Answer. Yes. And I think part of that he was trying to scare me
that NSC is after you, I mean it was, that was sort of the way he put
it. But then he explained to me that this had happened and that they
did not want him to have the photos.
Question. Did he know or explain to you why the NSC----
Answer. He said these are Chinese nationals and they didn't think
it was a good idea for the President to have had his picture taken with
them.
Question. Did you or anybody else at the DNC ever inquire of Mr.
Johnny Chung who these individuals were that he wanted to get into the
radio address?
Answer. He told me on the telephone when he made the request, these
are important Chinese businessmen. I did not give Ceandra anymore
information than that when she called over to the White House. If she
was asked for more information than that, she didn't come back to me
for it.
Question. And you never inquired to Mr. Chung for any further
information?
Answer. No.
Question. Did the NSC ever contact you?
Answer. No.
Question. Did anyone in the White House ever contact you about this
request?
Answer. I do not think so. I do not remember.
Question. Did anyone in the White House contact you about these
individuals?
Answer. No.
Question. Let me show you a memorandum, dated March 28, 1995, that
is from Betty Currie. If you will just take a look at that. Have you
ever seen this document before?
Answer. No.
Question. Do you happen to know who this, the John who is
referenced at the top would be?
Answer. No.
Question. Did you know a Jonathan Frieberg at the White House?
Answer. No.
Question. Never spoken to a Jonathan Frieberg?
Answer. No.
Question. Taking a look at really the only substance to this
memorandum, it says, ``Ceandra Scott called. She was concerned about
Johnny Chung. She stated that we should have called them prior to their
coming to the radio address. Apparently they were in Maggie's office
when request came and Maggie said she didn't know, but to contact
DNC.''
Do you know what this is referring to?
Answer. I have no idea what that means.
Question. Did you ask Ms. Scott to call Betty Currie?
Answer. I don't know who Betty Currie is.
Question. Okay. She worked in the White House, works in the White
House right now.
Answer. I don't know.
Question. I am just wondering if you had asked Ms. Scott to contact
anyone at the White House at the end of March about Johnny Chung?
Answer. No. Not to my memory I didn't.
Question. Do you know if there is, if there is any reason why Ms.
Scott would have called the White House on her own?
Answer. No, I don't.
Question. As far as you know, after Ms. Scott made the phone call
for you at the White House, she was not involved in this any further?
Answer. As far as I know, as far as I can remember, she was not.
Question. It appears what this is saying is that Ceandra Scott had
stated that the White House should have called them prior to Mr. Chung
and the delegation coming to the radio address. Do you know what that
might be about?
Answer. No.
Ms. Safavian. Let me mark this for the record as Exhibit CK-3.
[Khare Deposition Exhibit No. CK-3 was marked for identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. You mentioned that Eric Sildon spoke with you and it
could have been a couple days or a week after the radio address about
the NSC holding on to these photos.
Mr. Eggleston. I think she said it may have been as far as 2 weeks.
The Witness. I do not remember.
EXAMINATION BY MS. SAFAVIAN:
Question. You didn't know how long after the radio address,
sometime after the radio address?
Answer. Right.
Question. But do you believe it was in March?
Answer. I believe it was, but I do not--I wouldn't swear to that.
Question. Okay. Let me show you an April 5, 1995, letter to Don
Fowler from Johnny Chung. If you would go ahead and take a look at
that.
Have you seen this document before?
Answer. I do not recall this document.
Question. If you will notice----
Answer. I see it has a cc to me.
Question. Do you have any reason to believe that you would not have
gotten a copy of this document?
Answer. No.
Question. This is dated April 5, 1995. Do you believe that Eric
Sildon, that you knew about the problem with the photos from Eric
Sildon prior to----
Answer. Prior to this? Probably, but because I do not remember--it
sounds to me like this came after he had already tried to get the
photos. Probably Eric had already come to me and told me that little
tale. I don't know that for sure.
Question. Okay. Did Don Fowler discuss anything in this letter with
you after he received it?
Answer. I do not remember that he did.
Mr. Yeager. Did Don Fowler know about this? Strike that. Did you
tell Don Fowler about----
The Witness. The whole episode? I do not remember telling him that.
I can't think that I would have. I just do not remember that
conversation with him until just recently.
EXAMINATION BY MS. SAFAVIAN:
Question. Since this is addressed to Don Fowler, would he have read
this letter?
Answer. He would have had it in his office.
Question. If you will notice, the last sentence of the first
paragraph, it reads: ``I have learned from Mr. Richard Sullivan of DNC
that the National Security Council is holding on to those pictures.''
Answer. Yes.
Question. Did Richard Sullivan ever tell you or mention to you that
the NSC was holding on to those photos?
Answer. I don't remember talking with Richard about it. I remember
talking with Eric about it. I don't remember talking with Richard about
it.
Question. And do you remember speaking with Don Fowler about it?
Answer. No.
Question. Do you know if Don Fowler made any phone calls or any
attempts to assist Mr. Chung in getting these photographs?
Answer. I don't know that he did.
Question. Did he ever ask you to make any phone calls or assist in
any way?
Answer. No.
Question. And forgive me if I asked this already, do you recall Mr.
Chung contacting you and asking for your assistance in getting these
photographs?
Answer. No, I do not recall his doing that.
Question. Do you know why he would have cc'd this letter to you?
Answer. Well, because I was probably--I was the one who had set up
the, their attendance at the radio broadcast in the first place. I was
a name that he knew there in the chairman's office.
Mr. Eggleston. Obviously, she doesn't know why he did it. She can
only surmise.
Ms. Safavian. Let me mark this as Exhibit CK-4.
[Khare Deposition Exhibit No. CK-4 was marked for identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Let me now show you an e-mail from Robert Suettinger of
the NSC, dated April 7, 1995. If you will just take a quick look at
that.
Mr. Eggleston. Do these read from the bottom up?
Ms. Safavian. What this is is, the top half of it is what appears
to be a response to the bottom, which was the original e-mail.
Mr. Eggleston. If we are going to read them the way they were
transmitted, we would read the bottom one first and then----
Ms. Safavian. When you respond to an e-mail, it cuts off usually
part of the message and keeps half of it. So the bottom is not a
complete version of that e-mail.
Mr. Yeager. Actually, the times and dates at the top of each
message suggests that----
Mr. Eggleston. The reverse is true. I am sorry.
Mr. Yeager. That the top preceded the bottom.
Ms. Safavian. Let me clarify that by handing you another e-mail.
This is the original, the original request that came out from Darby. It
is addressed to Roseanne Hill, Stanley Roth, and Robert Suettinger. The
time is 10:12 a.m. on April 7, 1995.
Mr. Eggleston. So we think the order is what is going to be marked
Khare 6 is first; top of Khare 5, second; and bottom of Khare 5, third?
Ms. Safavian. Let us not get too confused here. Why don't I go
ahead and mark them as exhibits so that we can refer to them as exhibit
numbers. Why don't I mark as Exhibit CK-5 the first e-mail which is
this one from Darby to Roseanne Hill, Stanley Roth and Robert
Suettinger, EOP 004538, and Exhibit CK-6 will be the e-mail from
Suettinger, which is EOP 005439.
[Khare Deposition Exhibit No. CK-5 was marked for identification.]
[Khare Deposition Exhibit No. CK-6 was marked for identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Have you had a chance to look at both of those?
Answer. Yes.
Mr. Eggleston. Could we just hold up one second because I was so
busy getting organized?
Ms. Safavian. Sure.
Mr. Yeager. The other thing I would like to point out for the
record, looking at CK-5, the message from Brooke Darby, is to Asian
Affairs, Asia-Asian Affairs, and what I think you have characterized as
a response is from Robert Suettinger. It is not at all clear from this
that Suettinger is responding to this e-mail here.
Ms. Safavian. Well, I think if you look at Exhibit CK-5, at the top
it says, to Hill, Roseanne M.; Roth, Stanley O.; Suettinger, Robert L.
If you look at Exhibit CK-6, it shows that the sender is Robert
Suettinger. It is to Melanie B. Darby. The subject on both of these is
photos. Unclassified in parenthetical. And the bottom message from
Brooke Darby is attached or is at the bottom of Suettinger's response.
Mr. Eggleston. Let me say, we are not going to, just ask us the
questions. We cannot adopt a supposition that they are responses or not
responses.
Ms. Safavian. I am not asking you to.
Mr. Eggleston. You can go ahead and ask your questions without us
buying into who said what, when, and whether it was a response or
whatever.
EXAMINATION BY MS. SAFAVIAN:
Question. You have had a chance to look at these?
Answer. Yes.
Question. Have you ever seen these documents before?
Answer. No.
Question. Looking at Exhibit CK-6.
Answer. Yes.
Question. Were you ever told by Eric Sildon or another individual
as to the concerns of the NSC in releasing these photos?
Answer. Just that Eric Sildon said to me, they are concerned
because these were Chinese nationals and they should have the--I mean,
he did not say these are bad guys or anything, just said these are
Chinese nationals and they should not have the President of--the photo
with the President released. That was the concern.
Question. Did Mr. Sildon ever mention to you how it was that the
NSC got involved in this?
Answer. No, he didn't.
Question. Did you ever speak to anybody at the White House about
the NSC holding on to these photographs?
Answer. I don't remember doing that.
Question. Did you become aware at that time that the NSC considered
Johnny Chung to be a hustler, as you can see in the second paragraph?
Answer. No. Nobody said that to me.
Mr. Eggleston. I might say that we don't know that any of these
involved the NSC. If you have that from some independent source, but do
I know that these are NSC--you don't know that these are NSC e-mails;
do you?
The Witness. No.
Mr. Eggleston. I am sure you have it from some external source. I
just want it clear from Ms. Khare's point of view, she doesn't know
that these are NSC people. You can ask her any question you want, but I
do not think she recognizes these names.
The Witness. No, I don't recognize these names, period.
Mr. Eggleston. I don't think it has NSC on here.
Ms. Safavian. No, it does not.
Mr. Eggleston. I just want you to know she has no knowledge even
from reading the e-mail that the NSC said that he was a hustler. She
doesn't know that.
EXAMINATION BY MS. SAFAVIAN:
Question. That was what I wanted to find out, if anyone had, in
fact, told you what the NSC had determined about Johnny Chung and this
Chinese delegation of businessmen?
Answer. No.
Question. You never learned----
Answer. I don't remember being told that at all.
Question. And you, I think you had just mentioned you don't know
these individuals who are listed?
Answer. No.
Question. On these e-mails?
Answer. No.
Question. And had never spoken with them?
Answer. No.
Question. After this, did the White House or anybody ever contact
the DNC and tell the DNC, we are a little concerned about, the NSC is
concerned about Johnny Chung and we just wanted to let you know that?
Did you ever receive any phone call like that?
Answer. No.
Ms. Safavian. I believe that these exhibits are already marked.
Mr. Eggleston. We have been going about an hour and 10 minutes. If
we would break in 5 or so minutes.
Ms. Safavian. Whenever you would like to.
Mr. Eggleston. Whenever is convenient. Just a convenient stopping
point.
Ms. Safavian. Let me go through one other document with you real
quick.
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Khare, let me show you a fax cover sheet that is from
you to Johnny Chung. If you look at the top, the facsimile looks like
the date is April 11, 1995.
Answer. Yes.
Question. Let me just ask you, first of all, do you recall
preparing this document?
Answer. No, but it is my writing so obviously I did.
Question. In the comments section it says: ``The White House
assures me that you now have the pictures. Hooray. If you don't, give
me a call. Have a good trip.''
Do you recall learning that the White House had, in fact, given
Johnny Chung the photographs?
Answer. No, I really don't. Obviously, I did learn it, but I do not
remember that.
Question. You don't recall who you would have contacted at the
White House to find that out?
Answer. No, and I may not have contacted anybody at the White
House. I mean somebody actually on my staff could have told me, on the
DNC staff could have told me.
Question. Do you recall any particular reason why you would have
sent this to Johnny Chung?
Answer. No. Other than--no, I mean, since I didn't remember sending
it, I don't remember any reason.
Question. You don't recall him calling you and----
Answer. I don't remember him calling me about it. This just was not
the highest priority in my life at that time. So things could have
happened that--a lot of things happened that I am sure I do not
remember.
Ms. Safavian. Let me mark this as CK-7.
[Khare Deposition Exhibit No. CK-7 was marked for identification.]
Ms. Safavian. Why don't we go ahead at this time and take that
break.
[Brief Recess.]
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Khare, just one last question on CK-7. You mentioned
``have a good trip.'' Do you recall where Mr. Chung was going?
Answer. No. Although there was a letter here where he said he was
going to China and wanted the pictures to go with him. So obviously I
knew that he was going on that trip.
Question. Would that have been the letter he addressed to Mr.
Fowler?
Answer. I just remembered when you showed me things, seeing that in
here.
Mr. Eggleston. CK-4, I think.
EXAMINATION BY MS. SAFAVIAN
Question. Yes, CK-4, it states, ``I am going to China next week.''
Answer. Yes.
Question. ``I do need to bring those pictures with me.''
Answer. Yes. So I don't know if he had told me that or I had seen
it in a letter, whatever.
Question. Okay. You had mentioned the first time that you had any
contact with Mr. Chung was when he called you about this radio address.
Answer. Yes.
Question. Do you recall from that time period to CK-7, the date
being April 11, 1995, ever actually meeting Mr. Chung in person?
Answer. I don't remember when I ever met him the first time in
person.
Question. You don't recall the first time you actually met him?
Answer. No.
Question. Do you recall what the circumstances were?
Answer. No, I don't.
Question. Do you recall if somebody introduced you to him?
Answer. I don't remember.
Question. If I could just show you a May 8, 1995, letter to Don
Fowler from Johnny Chung. If you will just go ahead and take a moment
to look at that.
Mr. Werbel. Is the number cut off at the bottom?
Ms. Safavian. I am afraid it is. I apologize for that.
Mr. Eggleston. You don't have a better version?
Ms. Safavian. Not with me.
EXAMINATION BY MS. SAFAVIAN:
Question. Have you finished reading that?
Answer. Yes.
Question. Can you tell me, have you ever seen this letter before?
Answer. I do not remember this letter but probably I did.
Question. Once again, it is cc'd to you at the bottom?
Answer. Yes.
Question. Do you have any reason to believe that you would not have
gotten a copy of this?
Answer. No.
Question. In the first paragraph it says: ``It was wonderful to see
you again. I appreciate you and Carol making the time available for us
to talk about the latest update from my recent trip to China.''
Answer. Yes.
Question. Does this help you place in time when you may have met
with, met Mr. Chung?
Answer. I don't even remember this meeting, although I remember
that we had a conversation with him that probably was this meeting
about going to China. He wanted some DNC people to go to China. And
whether prior to that meeting I had met him, I don't know. I don't
know. I mean, obviously, I was in a meeting with him on that subject,
but whether that was the first meeting I had with him or not, I don't
know.
Question. At least we can establish that----
Answer. By that point I had met him.
Question. Okay. And as you can see in the second paragraph, it
appears that Mr. Chung presented Don Fowler with an official invitation
from the Chinese government?
Answer. I vaguely remember that. I do not remember what it looked
like or anything like that. I remember that he was very anxious for us
to go to China.
Question. And when you say ``us,'' who----
Answer. Well, he wanted Chairman Fowler and some DNC staff members,
and he always, when he would talk about it, would say to me, now,
Carol, you will have to come. You will have to come.
Question. Did Don Fowler or any DNC staff members ever take a trip
to China with Johnny Chung?
Answer. No.
Ms. Safavian. Let me mark that as CK-8.
[Khare Deposition Exhibit No. CK-8 was marked for identification.]
EXAMINATION BY MS. SAFAVIAN
Question. Ms. Khare, do you know who Harry Wu is?
Answer. Yes.
Question. And what do you know about him?
Answer. I know what he was a prisoner in China, a political
prisoner in China although he was from the United States. There was in
the summer of 1995, I guess, there was an effort being made
diplomatically to get him out.
Question. Were you involved at all in this effort to free him?
Answer. No.
Question. How do you know anything about this?
Answer. Well, it was in the news, but Johnny Chung wanted to be
involved in the effort to free him or thought that he could be of help
and was going to China and was very anxious to be helpful to the
President and to the United States in getting him out. And he talked
about it.
Question. Did he talk to you about that?
Answer. Yes.
Question. How often?
Answer. Well, more than one time. I mean, I saw him. He came to the
DNC maybe a couple times in that time period and he called me a couple
of times about it, that he really needed to help with this and he, I am
not sure why, except that I would take his phone calls, why he called
me about it.
Question. Would he call you directly or was he trying to get
Chairman Fowler?
Answer. He was calling me directly. Maybe he wanted to go and talk
to the President about it and that kind of thing, but he was just very
interested in the whole subject, and I was somebody in semi official
Washington that he could talk to about it, so he did.
Question. Did he ever ask you for any assistance or for help in any
way with this matter?
Answer. No. I do not think he did. Unless me asked me if I could
get him in to see the President or something, which I don't know that
he did.
Question. He was just calling you?
Answer. He just was--yes. And would I let the White House know that
he was working on this, that kind of thing.
Question. What would you say to him after a conversation like that
took place?
Answer. I would say, sure, if I talk to anybody, I will let them
know that you are working on this. We all know you are trying to help.
Thanks a lot. That kind of thing.
Question. Would you----
Answer. I was not unkind to him, but I really did not think that he
was going to be able to get Harry Wu out of China.
Question. Did you ever pass on his comments that he was trying to
help Harry Wu to anyone at the White House?
Answer. I don't think so.
Question. Did you ever speak to Chairman Fowler about this?
Answer. I probably did. But not in a sense that you really need to
go to call the President and tell him this. More, Johnny Chung says he
is going to get Harry Wu out, that kind of thing.
Mr. Yeager. I take it you were being facetious?
The Witness. I guess that I was. I truly did not take his effort
very seriously.
EXAMINATION BY MS. SAFAVIAN
Question. Let me show you a July 24, 1995, letter from Don Fowler
to Johnny Chung. If you will just take a look at that. Have you seen
this letter before?
Answer. I do not recall this letter.
Question. Would this have been something that you would have
prepared for Don Fowler or would this have been something that a staff
assistant would have done, if you can say?
Answer. I don't know. I think probably a staff assistant did it.
But I could possibly have done it. This was the kind of thing that
whoever happened to be standing there might do. It may even have been
dictated. I mean, it could be that Chairman Fowler did it himself. I
just do not recognize this particular one.
Question. If you look in the second paragraph, starting with the
second sentence, ``I enjoyed meeting your friend who is the wife of the
Chief of Staff of the Chinese Army.''
Do you recall this meeting that Don Fowler had with the wife of the
Chief of Staff of the Chinese Army?
Answer. I do not remember that specific meeting, although he
brought a number of people up there to meet the chairman so I am sure
that was one in a bunch.
Question. You don't specifically recall this meeting, though?
Answer. No.
Question. Would Johnny Chung call ahead of time and try and get
appointments with the chairman or would he just maybe show up?
Answer. Sometimes he called ahead of time. More likely he would
just show up.
Question. And he would show up with guests with him?
Answer. Yes.
Question. Would Chairman Fowler always find time to meet with him?
Answer. He wasn't even always there. In fact, sometimes I met with
some people just because somebody had to go down and meet with these
people and be polite to them because they were guests. But, no, he
obviously couldn't always meet--and sometimes when people dropped by
like that, which was not unusual for people just to drop by to see him,
he would just walk out into the hall or down in the reception area and
say, I am sorry, I am busy, but I am so glad you came by, good-bye.
This could even have been like that.
Question. Okay. If we continue in that second paragraph, quote:
``We all look to you for guidance and help over the coming months.
Please let me know about your efforts to gain the release of Harry
Wu.''
Answer. I think that is good manners.
Question. So Don Fowler obviously knew about Mr. Chung's efforts or
desire to free Harry Wu?
Answer. Yes.
Ms. Safavian. Let me mark this as Exhibit CK-9.
[Khare Deposition Exhibit No. CK-9 was marked for identification.]
EXAMINATION BY MS. SAFAVIAN
Question. I am going to be handing you two documents. They are both
a July 25, 1995, letter to Johnny Chung from Don Fowler. You can take a
look at both of them.
Answer. Looks like the same words on both of them.
Question. I was going to ask you, do you agree that it appears to
be the same letter with the exception of at the bottom of DNC 3233816
there are some Chinese characters.
Answer. Yes.
Question. That does not appear on DNC 3102488.
Answer. Yes.
Mr. Yeager. Do you know if they are Chinese characters?
The Witness. No, as a matter of fact, I don't know if those are
Chinese characters.
Mr. Eggleston. I was going to ask you to read the Chinese to us.
The Witness. You were not going to tell them that is a talent of
mine.
Mr. Eggleston. She is kidding.
The Witness. I was kidding, and I don't know that this is Chinese,
although with Johnny Chung it probably would not be Japanese.
Ms. Safavian. Just so we do not get confused, why don't I go ahead
and mark these two as exhibits. I will mark DNC 3102488 as Exhibit CK-
10, and I will mark Exhibit DNC 3233816 as Exhibit CK-11.
[Khare Deposition Exhibit No. CK-10 was marked for identification.]
[Khare Deposition Exhibit No. CK-11 was marked for identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. First of all, looking at Exhibit 10, do you recall this
letter, preparing this letter or sending this letter out?
Answer. No, I do not.
Question. Let me just read it for the record. Starting with the
second sentence of the first full paragraph: ``You are to be commended
for your efforts to build a bridge between the people of China and the
United States. I want to express my appreciation to you for being a
friend and a great supporter of the DNC.
``Good luck on your trip to China and please keep me informed.
Thank you.''
Did Johnny Chung ask Mr. Fowler to prepare a letter like this?
Answer. I do not think so. We sent letters to almost anybody who
came to the office. I mean, that is something that Don Fowler routinely
does, if he sees somebody, meets them on the street, he sends them a
letter. So this was a very routine kind of thing to send out.
Question. I am sorry, even using language that I just read,
``efforts to build a bridge between the people of China and the United
States,'' did that have anything to do with his trip to China to help
free Harry Wu?
Answer. I don't know, but he talked, in conversations with him he
would talk about wanting to build bridges between our two countries.
That kind of thing. So that is his language. That would be the kind of
thing you would put in a polite note to somebody who had come by. Some
of the conversation in that would have been in his conversation.
Question. So you do not recall Johnny Chung asking for a letter
like this to be drafted?
Answer. No.
Question. Okay. If you look at Exhibit 11----
Mr. Eggleston. CK-8 has got Chung writing about the important
bridge making process.
The Witness. Yes. That is just----
EXAMINATION BY MS. SAFAVIAN:
Question. Were you finished with what you were saying?
Answer. Yes.
Question. If you look at Exhibit 11, first of all, would the DNC
have sent a letter to Johnny Chung including these, what I believe to
be Chinese characters, on the bottom of the letter?
Answer. No. I do not think we had anybody who could, was capable of
doing that at the DNC.
Question. If you look at the top of the document, it looks like it
was faxed on 7/25/95. It says, DNC Chairmen Dodd and Fowler with an
arrow pointing to AISI, which was Johnny Chung's company.
Answer. Right.
Question. Do you know how it is, then, that the DNC had possession
of this letter in this format with the Chinese characters at the
bottom?
Answer. No, I do not. I have no idea. Obviously, I guess this came
from the DNC. But I don't know how that would have gotten on there.
Question. And how the DNC would have gotten the letter back?
Answer. No. I don't know. I mean, this looks like something that
went out of our office. This does not. I assume this got put on it
somewhere else and it came back.
Question. But you don't know why it came back?
Answer. No, I have no idea.
Question. Were you aware through conversations you had with Johnny
Chung that he was asking or wanting from the White House a credential
letter for his trip to China?
Answer. I do not remember that. I am not sure what a credential
letter is. But I do not remember that particular thing.
Question. Let me show you a set of documents that starts with a fax
cover page from AISI to Betty Currie from Irene for Johnny Chung dated
July 25, 1995. If you will just take a quick look at these five pages.
Have you finished looking at that?
Answer. Yes.
Question. Have you seen any of these documents before?
Answer. Other than the, than this one, I do not think that I have.
Question. You are referencing the last document, which is EOP
005057?
Answer. Yes.
Question. Which is the letter to Johnny Chung from Don Fowler that
we were just discussing?
Answer. Yes.
Question. Actually, if you will take a look, looking at that last
page of the document, looking back at Exhibit CK-11, if you will
notice, and maybe you can help me out with this, they are the same
letters with the exception, once again, that CK-11, there is the
Chinese characters at the bottom. On the EOP 005057 version that does
not exist. But at the top of both of those documents we have the same
facsimile message at the top. The typesetting seems to be different
between the two documents. I am just wondering, first of all----
Answer. It does. I agree with you.
Question. Do you have any knowledge as to why that may be or any
explanation for that?
Answer. No.
Mr. Yeager. It could be reduced.
The Witness. I think this one is just reduced because the
letterhead is reduced, too.
EXAMINATION BY MS. SAFAVIAN:
Question. Okay. First of all, as you can see from this document,
and I will mark it as CK-12 so we can refer to that as CK-12, this is
the set of documents which is EOP 005053 through 5057.
[Khare Deposition Exhibit No. CK-12 was marked for identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Do you have any reason to know why Johnny Chung would
have sent a copy of Don Fowler's letter to him to the White House?
Answer. No.
Question. And he did not mention to you at all his desire to get
the White House to send him a credential letter?
Answer. If he did, I don't remember.
Question. Did you ever make any phone calls on his behalf to the
White House to get such a letter for him?
Answer. I don't think so.
Question. Did you ever at any time request from the White House for
them to write any letter for Johnny Chung not limited to a credential
letter?
Answer. I do not remember doing that.
Question. Making any request like that on behalf of him?
Answer. No.
Question. Did there come a time when Johnny Chung contacted you
while he was over in China about Harry Wu?
Answer. Yes.
Question. Can you tell me about that?
Answer. He called me from, he said from Beijing. He said, I guess
you know that Harry Wu is out. I helped get Harry Wu out. And I said,
that is wonderful, that is wonderful that you got him out.
And he--the First Lady was going to Beijing for something, and he
wanted to see her when she came there. And he wanted me to help him. He
had tried calling the White House, I think, but he wanted me to help
him get into whatever event she was going. He wanted to welcome her to
China. He wanted to be there when she arrived. He wanted me to help do
that.
Question. He wanted you to help him with that?
Answer. Yes, he wanted me to contact somebody at the White House
and get permission for him or clearance, whatever, for him to be able
to greet the First Lady when she got to China and be in that group.
Question. Did you assist him in any way in that request?
Answer. No.
Question. You didn't make any phone calls?
Answer. I probably led him to believe that I would but everybody at
the White House at that time was in Montana or something, and I had
tried to get some people at the White House earlier in the week and had
not been able to get them. They would not return my calls. So I sort of
rationalized that I made that call for him but I couldn't really reach
anybody.
EXAMINATION BY MS. SAFAVIAN:
Question. Okay. Do you recall when it was that he made this phone
call to you from Beijing?
Answer. No. I don't remember when it was. It was shortly after
Harry Wu's release.
Question. And do you know why he called you?
Answer. Because he thought that I could help him get in to see the
First Lady.
Question. Oh, that was the purpose of his phone call?
Answer. That was the point of it, yes.
Question. Okay. And he pretty much just told you that he had--that
Harry Wu had been released----
Answer. Uh-huh.
Question. I am sorry. Did you say that he----
Answer. He said, ``I helped get Harry Wu out.'' And I said, ``Well,
that was wonderful.'' I didn't argue with him about it.
Question. Was that pretty much the substance of the conversation?
Answer. That was sort of the gist of it. He is a little difficult
to talk to because he has right much of an accent and to me it is
harder to talk to somebody on the telephone when they have a hard to
understand accent. And when they are calling from Beijing, it is even
harder and it was not a good connection. I think he maybe even called
me a second time to see if I had been able to arrange anything for him
to see the First Lady, and I hadn't been able to.
Question. Did you relay to anybody else that Johnny Chung had
called you from Beijing and he told you that he had helped free Harry
Wu?
Answer. I am sure I did. I am sure I told people that.
Question. Do you recall who you would have told?
Answer. No.
Question. Did he ask you to relay to anybody that he had done this?
Answer. No. No. Unless it was a part of his getting into the First
Lady; maybe said, tell her I got Harry Wu out and now I need to meet
with her, or something like that, but I didn't--no official notices to
the State Department or anything.
Question. Did Mr. Chung, when he was telling you about his efforts
and his assistance in freeing Harry Wu, did he happen to mention to you
at all what he did?
Answer. No. No.
Question. He didn't go into any detail with you?
Answer. No. I don't think so. I mean, he had said, prior to going
over there, that he thought he could help because he knew a lot of
people over there, knew the right people to talk to. He didn't tell me
how he actually achieved it.
Question. Did he happen to mention to you the names of any Chinese
officials that he may have met with about that?
Answer. If he did, I don't remember.
Question. Okay. Let me just show you another letter. This one is
dated January 30th, 1996. Actually, it is a group of letters and it
is--the Bates Stamp is DNC 3263845 through 3263848. If you will just
take a quick look at these for me.
Have you finished looking at them?
Answer. Yes.
Question. Actually, I would like to begin with what is the second
document, because as far as timing goes the second document is a
January 22nd, 1996, letter. This is addressed to Don Fowler from Irene
Wu, who you said you had spoken to?
Answer. Yes. I think she was a secretary or something to Johnny
Chung.
Question. Okay. By reading the letter, it looks like she is asking
for Don Fowler's assistance in arranging a meeting between Vice
President Gore and Professor Qu Geping?
Answer. I don't know.
Question. Okay. Do you recall making any efforts to try and arrange
this meeting?
Answer. No.
Question. Okay. If you notice at the bottom of that document, there
is some handwriting.
Answer. Mine.
Question. That's your handwriting?
Answer. Uh-huh.
Question. I believe it says, ``Don, I am inclined to ignore this.
Johnny promised $100,000 in November and another $100,000 in December.
None came. C.''
Did I read that correctly?
Answer. Uh-huh.
Question. What did you mean by this?
Answer. I think by this point, Johnny was really pestering us a
lot. He wanted something all the time. And he always talked about what
a big donor he was, but he did sort of quit giving money, and DNC
Finance people kept--were complaining about it. I mean, I had been in
meetings with them, that kind of thing. They would say, Johnny Chung,
he keeps promising us money and he always wants something; he always
wants a letter, that kind of thing, and he hasn't given any money. And
so I think that's probably the reason for this.
I mean, I don't remember specifically that he promised $100,000
this time and $100,000 another time, but I do remember that DNC Finance
was complaining because he was always talking and always wanting
something but he wasn't really giving any money.
Question. So you believe that this note that you have down here,
you got that information from these finance meetings?
Answer. Yes. I think I probably just was aware of that. I don't
think I went down there and said, should we do something for Johnny? I
think I just was aware that he had probably had a lot of attention and
we didn't have to put forth a lot of effort for him because he had
gotten a lot of attention.
Question. Oh, okay. You had mentioned, you know, that he was always
calling asking for things, wanting a letter.
Answer. Uh-huh.
Question. I believe that was something that you mentioned. When you
said ``wanting a letter,'' what did you mean by that?
Answer. Well, he would want a letter to somebody welcoming them to
Washington or he would want, you know, a letter to go to China with.
You know, he liked paper and so he would ask you to write him a letter;
I would like a letter from the chairman to this person saying welcome
to the United States or something like that.
So, you know--he was always wanting an appointment and always
wanting to come up and see the chairman and bring people up there.
Question. Before when he made these requests, was that something
that the DNC and Chairman Fowler would usually try to take care of for
him?
Answer. A request that somebody makes that doesn't--isn't real
involved or real difficult, if it is a letter and there is nothing--no
reason not to write that letter, usually we would take care of it for
most anybody who asked.
But he asked so many--so much more often than anybody else that it
was--you know, we became less inclined to jump.
Question. Did you discuss this at all with Chairman Fowler?
Answer. This particular thing?
Question. Yes, about your comments and that.
Answer. I don't remember. I don't remember.
Question. At the top of the letter, there is another handwritten
note. It says--is that Rolf?
Answer. Rolf.
Question. R-O-L-F?
Answer. Uh-huh.
Question. Write a polite letter saying we are referring letter to
Veep's office?
Answer. Yes.
Question. Dash, no commitment. D.
Who is that?
Answer. Don. That's Don Fowler.
Question. Don Fowler's handwriting?
Answer. Uh-huh.
Question. You don't recall have a conversation with him about
whether you were going to help Johnny?
Answer. No. He probably saw my note, saw this letter and that was
the disposition of it.
Question. This didn't come back to you, then?
Answer. No, I don't think so.
Question. It went to Rolf?
Answer. Yes.
Question. Who was Rolf?
Answer. He was a staff assistant in that office. He may have--in
fact, I think he may have been the driver at this time and would do
letters when he was in the office, and I think this is--this is a
letter that he drafted. I can tell from his initials on it.
Question. What was Rolf's last name?
Answer. Olson.
Question. Olson. Okay. So you are talking about the first page of
this, which is DNC 3263845?
Answer. Uh-huh.
Question. Do you know what, if anything, came of this request of
Johnny Chung's?
Answer. No, I don't.
Ms. Safavian. Let me go ahead and mark this as Exhibit CK-13.
Mr. Eggleston. These are all pages?
Ms. Safavian. Yes.
Mr. Eggleston. All four pages, I guess?
Mr. Eggleston. Yes, 3263845 through 3263848.
[Khare Deposition Exhibit No. CK-13 was marked for identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Moving on to another subject, can you tell me, when did
you first meet John Huang?
Answer. I don't know. He had been at the DNC a little while, I
think, when I finally met him, when--or when I first met him.
Question. He had been there prior to you----
Answer. He was there on the staff. I mean, I had sort of seen him
around for awhile before I knew--actually knew who he was.
Question. So when you arrived at the DNC----
Answer. He was not there.
Question. He was not there?
Answer. No, no.
Question. Okay.
Answer. He came to work at the DNC in late '95 or early '96, and I
had already been there awhile but I just happened not to meet him.
Question. Did you know that--did you know the circumstances
surrounding his hiring at the DNC?
Answer. No.
Question. You were not involved in that at all?
Answer. No.
Question. Okay. Do you know whether or not John Huang ever set up
any fund-raising events involving the President?
Answer. I know that he did.
Question. You know that he did?
Answer. Yes.
Question. Was this a usual occurrence for him? Was this one of his
responsibilities?
Answer. Yes. Almost anybody in Finance would have had that
responsibility, to set up events.
Question. Involving the President?
Answer. Yeah, or some involvement in it.
Question. Do you know if there ever came a point in time when he
ceased preparing fund-raising events for the President?
Answer. No, I don't know that.
Mr. Eggleston. I think she said, or some involvement.
The Witness. Yes. I don't know whether he would have been the--in
charge of an event or not, but everybody in Finance worked on events.
So whether he was in charge of particular events, I know that I--I know
now that he was but at the time, when all of this was going on, if you
had said to me he does--he sets up events, I wouldn't have been
surprised. But I don't know if somebody--if I actually knew
specifically what his job was. He was a fund-raiser and that's what
they did.
Question. Did you have much contact with John Huang?
Answer. Not a lot. I talked to him a few times and he would just
stick his head in my office and say hello if he happened to be passing
by. But I never knew him real well, and I didn't work directly with
him.
Question. Were you ever in any of the staff meetings with Don
Fowler where John Huang would have come up and it would have been
discussed whether or not he should continue helping with fund-raising
events or anything like that?
Answer. No.
Question. Would you have had any knowledge whether John Huang
traveled outside the United States for fund-raising?
Answer. No, I don't--I don't have any knowledge that he did. I
don't think I would routinely have been told something like that.
Question. That is not something that you would have been involved
with?
Answer. No.
Question. Okay. Do you recall there came--do you recall when there
came a point in time when John Huang--when he left the DNC?
Answer. Yes, I remember that.
Question. Okay. Do you recall the circumstances surrounding his
leaving the DNC?
Answer. Well, he left after the election, and a lot of--a lot of
fund-raisers left at that time. I mean, obviously he was in the thick
of controversy himself right then, but that was a time when a lot of
staff people left the DNC because the election was over. And I didn't
have any conversation with him about it or with anybody about it.
Question. Did you ever have any conversations with him regarding
reports in the press that he had accepted foreign contributions?
Answer. With him? No.
Question. Did you have any conversations like that with Don Fowler?
Answer. There were meetings over there about that sort of thing,
that I was in. So I wouldn't term them conversations but, you know, as
people were becoming aware of that situation, you know, we had some
senior staff meetings about it.
Question. Was this before or after John Huang left the DNC?
Answer. Probably both.
Question. When it was before he left the DNC, would Mr. Huang have
been involved in those meetings?
Answer. No.
Question. Would he have been present?
Answer. No.
Question. Do you know who Roger Tamraz is?
Answer. Yes.
Question. And can you just tell me who he is?
Answer. Well, most of what I know about Roger Tamraz I have learned
recently from media reports and that kind of thing. While I was at the
DNC, I knew Roger Tamraz as--I didn't know him. I have never met him,
but I knew his name because he was a donor.
Question. But you have never met him?
Answer. No.
Question. Did you ever have a conversation with him on the
telephone?
Answer. No, not--not to my memory.
Question. Do you know if Tamraz--Mr. Tamraz ever met with Don
Fowler?
Answer. I think that he did. I don't remember whether he met with
him at the DNC or not.
Question. Do you know how often he met--the two of them may have
met?
Answer. Not very--a few times, I guess.
Question. Do you know the purpose behind any of those meetings?
Answer. No.
Question. Did Don Fowler ever mention to you that Roger Tamraz was
discussing an oil pipeline deal that he had?
Answer. No.
Question. Do you know whether or not Chairman Fowler ever offered
his assistance to Roger Tamraz in meeting with Federal officials?
Answer. No, huh-uh.
Question. Do you recall a July 11th, 1995, meeting Chairman Fowler
had with Roger Tamraz?
Answer. No.
Question. Let me show you this memorandum, which is to Don Fowler.
It is from Alejandra Castillo dated July 12th, 1995 and it says
regarding a meeting with Roger Tamraz. If you would just go ahead and
look this over before we discuss it.
Ms. Khare, have you finished looking at it?
Answer. Yes.
Question. First of all, do you recall ever receiving this
memorandum or seeing it before?
Answer. Yes.
Question. Would this have been something that you would have gotten
while you were at the DNC or did you see it some other time?
Answer. Yes. And I have seen it recently, but, yes, I would have
gotten it at the DNC.
Question. Okay. Can you tell me, first of all, who is Alejandra
Castillo?
Answer. She was a young woman--is a young woman who at that time
was preparing briefings for Don Fowler.
Question. Briefings? What do you mean by that?
Answer. Well, when he had a meeting with somebody, she would give
him some notes on that person. If he were going on a trip, she would
give him briefings about all the meetings on the trip, who was going to
be in the meeting, what the politics of the--are and the place where he
was going, that sort of thing. And she would research that--those
things and talk to various other people and make him some notes so he
would not go into situations cold; he would know what to expect.
Question. Okay. And the very last page of this, it shows that it
was cc'd to both you and Ari Swiller?
Answer. Uh-huh.
Question. Who is Ari Swiller?
Answer. He was--he is someone who was a fund-raiser at the DNC. He
was on DNC Finance staff.
Question. Okay. Do you know if there was any particular reason why
Ms. Castillo would have prepared a memorandum on Roger Tamraz? I mean,
did--was she asked to do one for this?
Answer. I don't know whether she was asked to do it or not.
Question. Do you know where she would have gotten this information
from to prepare this memorandum?
Answer. No, I don't know. She may have told me at the time where
she got it, but I don't know--I don't remember now if she did.
Question. Okay. And did you--was there a meeting held with Don
Fowler, Ms. Castillo, yourself and Ari Swiller about this or----
Answer. No.
Question [continuing]. Was this memorandum just passed out?
Answer. No. I think it was just passed out.
Question. Do you recall having a conversation with Don Fowler about
this memorandum?
Answer. No, I don't.
Question. Did you ever discuss this memorandum with Ms. Castillo or
Mr. Swiller?
Answer. I am sure I discussed it with her. I am not sure whether I
discussed it with him, with Ari Swiller.
Question. The first sentence, or the first few words of the first
sentence, says, ``Pursuant to your meeting with Roger Tamraz, Capitol
Oil Incorporated, held on Tuesday July 11th,'' do you happen to recall
this meeting that Roger Tamraz had with the Chairman on July 11th?
Answer. No, I don't.
Question. Okay. Would Ms. Castillo have been present at this
meeting with Mr. Fowler and Mr. Tamraz?
Answer. That would be very unusual if she had been in there.
Question. Would Mr. Swiller have been present in this?
Answer. Yes.
Question. Do you know that for sure?
Answer. No, I don't, but that--usually if a donor was in there a
person from DNC Finance would be in there.
Question. So the first paragraph, second sentence, states, quote,
``As a potential managing trustee member, Mr. Tamraz' business dealing
may potentially, if not definite, political and ethical implications on
the DNC fund-raising operations.''
Did Roger Tamraz discuss, do you know, with Chairman Fowler
becoming a managing trustee?
Answer. I don't know whether he did or not.
Question. Did you have any discussions with anyone about Mr. Tamraz
becoming a managing trustee?
Answer. No.
Question. Do you know whether Mr. Tamraz ever became a managing
trustee?
Answer. No, I don't know.
Question. Continuing on in the first paragraph, it says, ``I have
had several conversations with Carol Khare and Ari Swiller regarding
Mr. Tamraz' background.''
Does that refresh your recollection?
Answer. I don't remember several conversations. I remember here is
this memo; we talked about it. But--I remember maybe one conversation
that is mentioned farther back in here prior to her doing this memo,
but I don't remember anything else.
Question. Did you know anything about Mr. Tamraz' background before
reading this memo prepared by Ms. Castillo?
Answer. Only what is mentioned back here about a Commerce
Department friend of mine. That was all I knew about Roger Tamraz.
Question. Why don't we take a look at that. That's back on the last
page, which is DNC 3116353. The first paragraph states, ``Based upon
the above-stated events, it is clear that Mr. Tamraz has several
problems pending before the international business community. Among the
more recent events concerning Mr. Tamraz is his bar from participating
in a Commerce Department trade board. Open parenthesis, unofficial
Carol Khare received warning from a DOC friend, closed parenthesis,''
end of the quote.
Did I read that correctly?
Answer. Yes.
Question. Okay. Who was the DOC friend that you received a warning
from?
Answer. The young man who I knew before I came to Washington who
worked at the Department of Commerce and who had worked at the DNC,
then at the Department of Commerce and then came back to the DNC. His
name is John Ost.
Question. I am sorry. Ost?
Answer. Ost, O-S-T.--had, I believe, seen Roger Tamraz' name on the
Chairman's schedule, which the schedule was on the e-mail. So the staff
knew where he was, who he was meeting with, that kind of thing.
Question. Do you mean he as in Mr. Ost?
Answer. He, Mr. Ost, had seen it on DNC e-mail, I think had seen
the schedule, that Roger Tamraz was meeting with Don Fowler; and said
to me, do you know who Roger Tamraz is? He was supposed to go on a
trade mission with the Commerce Department and then at the last minute
somebody found out something bad about him and he was taken off the
trip.
Obviously, I relayed this to Alejandra before she did this memo. I
don't remember that conversation, but obviously I did. And so that's
what--that was my whole exposure to Roger Tamraz was that from John
Ost. And he didn't know why Tamraz had been taken off the trip.
Question. I am sorry. Maybe I was confused. Were you saying that
Mr. Ost was working at the DNC when----
Answer. He worked at the DNC. Then, after the '92 election, he went
and worked at the Department of Commerce. Then, at some point, he came
back and worked at the DNC. I don't know whether he was back in July or
whether--I saw him occasionally, and he may have just been up there. He
came--he had a lot of friends in the office and he would come up there
sometimes, and so whether my conversation with him about Roger Tamraz
happened while he was an employee of the DNC or an employee of the
Department of Commerce, I don't know.
Question. Oh, okay. Because you had mentioned that he had seen the
schedule of Don Fowler's.
Answer. Yes. He could--there were copies of it lying around so he
might have just seen it or he might have been back on staff at that
point. I just don't know.
Question. You didn't contact him, in fact, about Roger Tamraz?
Answer. No. He brought it up.
Question. Did he tell you anything else besides the fact that he
was not allowed to go on this trip?
Answer. I think he told me that he didn't know why. That's my
recollection, but I am not sure.
Question. Do you recall if you told this information to anybody
else besides Ms. Castillo?
Answer. I don't remember doing that.
Question. Did you speak with Chairman Fowler about this?
Answer. If I did, I don't remember doing that.
Question. If you look at the first sentence of the next paragraph,
under conclusion----
Mr. Eggleston. We are on the last page still?
Ms. Safavian. Yes.
EXAMINATION BY MS. SAFAVIAN:
Question. Quote, ``In a conversation held with Ari Swiller
yesterday, Mr. Tamraz expressed his desire to contribute $300,000 to
the DNC.''
Do you know whether Mr. Tamraz ever contributed this $300,000?
Answer. No. I believe he contributed to the DNC, but how much I
don't know.
Question. You never had a conversation with Mr. Swiller about this
donation?
Answer. If I did, I don't remember it.
Question. The very last paragraph, ``Our association with Mr.
Tamraz should be well defined, a difficult task given his complex
business connections and political associations. His business
background has proved to be full of significant financial and ethical
troubles. Pay attention to these warning signals,'' exclamation point.
Did you have any discussions with Chairman Fowler concerning this
warning from Ms. Castillo?
Answer. I don't remember that I did. I had a conversation with
somebody who sort of reassured me that most of this was not--there was
nothing to most of this and that Roger Tamraz was a fine person and
could--it would be all right for him to donate to the DNC, but I do not
believe that it was with Chairman Fowler.
Question. Do you recall who you had this conversation with?
Answer. No. I just remember not being concerned anymore about this
memo.
Question. Did you think that Ms. Castillo was overreacting to what
she had learned?
Answer. I think so. I think--that was how I felt about it.
Question. Did you inquire of other people--I mean, is that how this
person responded to you and said, there is no need for you to worry
about Mr. Tamraz?
Answer. Yes, I think that's what happened. But whether it was Ari
Swiller or Richard Sullivan or somebody else, I just don't know.
Mr. Yeager. Was Ms. Castillo a pretty junior member of the
Chairman's office?
The Witness. Very junior.
Mr. Yeager. Did she have any expertise in the Middle East or any of
the things she expressed an opinion about in this memorandum?
The Witness. No.
EXAMINATION BY MS. SAFAVIAN:
Question. Are you aware of any meetings or conversations Chairman
Fowler may have had with the National Security Council or the CIA
regarding Roger Tamraz?
Answer. No, I am not.
Question. Do you know whether or not, after this memo----
Mr. Eggleston. Could I interject something? I take it, it is all as
of that time. Since that time, obviously Chairman Fowler has testified.
The Witness. I have heard testimony, that kind of thing.
Ms. Safavian. Of course. I am asking for your knowledge.
Mr. Eggleston. Okay.
Ms. Safavian. Around the time when you received this message.
The Witness. Yes.
Mr. Eggleston. I assumed that. I wanted to make sure the record is
clear you are not asking as of today.
Ms. Safavian. No, that's fine.
EXAMINATION BY MS. SAFAVIAN:
Question. Please let me know if your memory is from a news article
or something like that?
Answer. Right.
Question. Do you know if after this memorandum came to you, if
Chairman Fowler had any further meetings with Roger Tamraz?
Answer. I don't know.
Ms. Safavian. Let me mark this as Exhibit CK-14.
[Khare Deposition Exhibit No. CK-14 was marked for identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. Ms. Khare, did you have any--was there any specific
liaison between your office and somebody at the White House?
Answer. No, not any specific--if I needed something at the White
House, I would usually call somebody in White House Political Affairs,
because those were people that I knew and dealt with. We didn't have
any official, if you want something from the White House you have to
talk to this person--this person has to talk to this person. It was
nothing defined.
Question. There wasn't any one person that you would contact more
often?
Answer. No.
Question. Let me show you a November 20th, 1995, memorandum to
Harold Ickes from Don Fowler, Marvin Rosen, Scott Pastrick and Richard
Sullivan regarding additional DNC fund-raising requests. If you will
just go ahead and take a look at that.
Ms. Khare, have you finished reading that?
Answer. Yes, I have.
Question. First of all, have you ever seen this memo before?
Answer. I think I have seen it recently but I haven't--I don't
think that I saw it at the time.
Question. You don't recall being the one who would have prepared
this memorandum for Mr. Fowler?
Answer. No, no. I am sure that I was not.
Question. Okay. In the fall of 1995, did you ever discuss with
Chairman Fowler the need for the DNC to raise an additional $4 million?
Answer. Everybody discussed that. Everybody at the DNC was aware of
the fund-raising efforts and what we were spending money on, that kind
of thing. It was a huge push at that time.
Question. Is this from the staff meetings that would be held or was
this just common knowledge of everybody?
Answer. Both.
Question. Okay. The top of the memo states that 18 to 20 calls will
have to be made by POTUS, which is the President of the United States.
Answer. Uh-huh.
Question. Do you know who the President was to call to raise these
funds?
Answer. No, I don't. I don't.
Question. There is also 10 calls by the VPOTUS, Vice President. Do
you know who he would have been calling to raise these funds?
Answer. No, I don't.
Question. Were you involved at all in preparing any call sheets for
either the President or the Vice President for fund-raising phone
calls?
Answer. No.
Question. Do you know who would have been involved in preparing a
list?
Answer. Someone in DNC Finance.
Question. Under that, it states that there will be a White House
holiday dinner which will be an accountability event. Do you know what
an ``accountability event'' means?
Answer. No, I don't--I don't know what that term means. I just
noticed it when I was reading this, and I know I have seen this before,
but I don't--I don't know.
Mr. Yeager. I don't want to put this as an objection but I just
want to note that it is not entirely clear that this is a plan.
Would you, Ms. Khare, characterize this as a proposal?
The Witness. Yes, I guess, because you don't send things over to
the White House and tell them what they are going to do.
Mr. Yeager. Thanks.
The Witness. You suggest.
Ms. Safavian. I am going to go ahead and mark this as Exhibit CK-
15.
[Khare Deposition Exhibit No. CK-15 was marked for identification.]
EXAMINATION BY MS. SAFAVIAN:
Question. When you arrived at the DNC, were you aware of the DNC
system for screening contributions or contributors?
Answer. That was something that was done by DNC Finance, and so I
really was not particularly involved with that.
Question. Did you ever have any knowledge of that process?
Answer. I guess in conversations people might say something, you
know, do you know anything about this person? Or we couldn't take money
from this person for this reason. But I don't remember ever having a
specific--being given a specific briefing on what that process was.
Question. And it was not anything that you were ever involved with?
Answer. It was not in my area at all.
Question. Was it any area--was anyone that you were supervising,
any of the staff assistants, ever involved in having to do that?
Answer. No. No.
Question. Are you aware that the President attended a series of
coffees held at the White House during 1995 and 1996?
Answer. Yes.
Question. Were the coffees with the President part of the DNC's
major donor program?
Answer. I don't know if--that you would call them that because
people were invited to those coffees who were not donors, and so--and
people were not required to be donors in order to go to those coffees.
So I don't guess you would call it a part of that.
Question. Were you involved at all in planning or preparing a list
of attendees for any of these coffees?
Answer. No.
Question. Do you know who would be?
Answer. DNC Finance.
Question. Did those lists ever make their way to Chairman Fowler
for his approval?
Answer. They usually--well, always before the event, at some point
before the event, he would have a list of the people who were going to
be there.
Question. Would that be a list of the DNC staff employees or----
Answer. Both, both. The guests, the--everybody who was going to be
there, just because he likes to know who is going to be in the room
before he walks in there.
But I don't think that he participated in--so much in making out
the lists, although he may have suggested names. I don't know. He
didn't do it through me.
Question. Okay. In any of the meetings, I mean, the staff meetings
that were held, were these coffees ever brought up?
Mr. Yeager. What meetings are you referring to again?
Ms. Safavian. I am sorry. The witness----
EXAMINATION BY MS. SAFAVIAN:
Question. You testified earlier that there were staff meetings at
the DNC that you attended?
Answer. I guess they were. I guess they were mentioned but it was
not a thing that we worked on in those meetings or debated in those
meetings or anything.
Question. Okay. Do you happen to know what the purpose of these
coffees were?
Answer. I don't know that I can define that purpose. I don't know
that I was involved enough to define that purpose.
Question. Let me just show you and see if you have seen this
before. This is a--I guess a memorandum or a scheduling memorandum. The
document is Bates Stamped EOP 024249. If you will just take a quick
look at that.
Answer. Uh-huh.
Question. Have you ever seen this document or something like this
before?
Answer. No. I mean, I have seen things like this just because when
there is an event you get something like this, or the chairman would
get something like this, letting him know what--what the sequence of
activities would be, that sort of thing. So I have seen something like
this but I haven't seen this specific one, I don't think.
Question. Let me just state, I just noticed at the bottom of this
document that there seems to be some sticker. It is typed BJT-6. I
don't believe that that was part of the original document. That must
have somehow gotten on it and it was copied. So don't let that distract
you.
This is discussing a Presidential coffee. The date is May 7th,
1996. And the location is the White House. I am just interested in the
purpose. It says, quote, ``The purpose of this coffee is to raise funds
for the Democratic National Committee,'' closed quote.
Would this be a way that the--would this be some way that the DNC
would describe the purpose of these coffees?
Answer. I don't think so. I never heard them described that way. In
fact, it was made pretty clear at the DNC that there was no admission
charged to these coffees, that people were not asked for money in order
to attend these coffees. So that is an unusual phrasing to me.
Question. Do you know who would have prepared this document? Is
this something that the DNC would have prepared or the White House?
Answer. I don't know. I don't know who did this.
Question. Okay. You mentioned that it was made clear at the DNC
that the coffees were not to raise funds?
Answer. Uh-huh.
Question. Is that correct?
Answer. They were--there was no cost of admission to the coffees.
Question. Okay. Who made that clear at the DNC?
Answer. Both the heads of finance and Chairman Fowler. I mean,
the--I just--that was something you heard more than one time, that----
Mr. Yeager. Counsel, I think she has testified, and I don't want to
interfere too much with your questioning, but I think she has testified
that she wasn't involved extensively in the coffees.
The Witness. No, I really was not. I mean, I was not.
EXAMINATION BY MS. SAFAVIAN:
Question. That's fine. Just because you had made that comment, I
wanted to know who--you mentioned the finance Chairs. Who would they
have been?
Answer. Richard Sullivan or Marvin Rosen and people like that.
Ms. Safavian. Okay. Let me, just because we discussed this, let me
mark this as Exhibit CK-16.
[Khare Deposition Exhibit No. CK-16 was marked for identification.]
Mr. Yeager. Could I ask that this--the reference in the lower left-
hand corner be stricken. That appears to be taken from another
deposition.
Ms. Safavian. Yes, absolutely. I would get a cleaner version, but
since this was the version showed to you, I will make this an exhibit.
Mr. Yeager. That's just to protect the identity of someone else who
apparently testified at the deposition.
EXAMINATION BY MS. SAFAVIAN:
Question. Would you have seen any spreadsheets that would list the
coffees and show projected funds that would have been received in
response to the coffees or any in-hand amounts that the coffees
generated?
Answer. I probably wouldn't have--something like that may have been
around our office, but it was not something that I would have paid a
lot of attention to it and studied and looked at. So I may have seen
the document and not looked at it.
Mr. Eggleston. You don't actually remember such a document?
The Witness. No.
Mr. Eggleston. Just to make it clear.
EXAMINATION BY MS. SAFAVIAN:
Question. Would that have been something that you would have had to
look at?
Answer. No, no.
Question. Would it have been something that you would have
discussed with Chairman Fowler?
Answer. No.
Question. Would that have been something you would have prepared
for a meeting?
Answer. Oh, no, I would not have been the one to prepare something
like that.
Mr. Eggleston. Again, just so it is clear, she did not acknowledge
that such a document even existed, I think.
The Witness. I guess--yeah, I don't recall any such document.
Mr. Eggleston. Okay.
EXAMINATION BY MS. SAFAVIAN:
Question. Who would normally, from the DNC, if there was a normal
grouping of individuals, staff employees, would attend these coffees
with Chairman Fowler?
Answer. I think Richard Sullivan went--I know that he went to some.
I don't know if he went to all. Marvin Rosen, who was Finance Chair,
went to some. I don't know if he went to all. And I can't think of
anyone else who would have gone. There may have been some particular
situation where another person went, but those are the ones that I know
went to some of the coffees.
Now, that--but the idea was that they were small and not many staff
people would have gone.
Question. Do you know if Chairman Fowler would follow up with any
of the individuals who would have attended these coffees?
Answer. He probably sent everybody a letter. That would be the
normal thing. Any meeting he was in, he would have sent--followed up
with a letter.
Question. Is that something that you would have been involved in
helping to prepare?
Answer. It would--no, I don't think so. Probably would have
approved the letter, some basic letter.
Question. It would have been a standard letter?
Answer. Yes.
Mr. Yeager. Would there have been a solicitation in that letter for
funds?
The Witness. I doubt it. I doubt it. I just don't remember.
EXAMINATION BY MS. SAFAVIAN:
Question. Do you know if Chairman Fowler would follow up with any
phone calls to these individuals who attended the coffees, after the
coffees?
Answer. I can't say a specific one when he did, but I imagine so. I
imagine that he did.
Question. And why do you say that?
Answer. Just because he always ends up having to deal with people
after he has met with them, because he is just that kind of a person.
But we did not have a routine in that he would go in and sit down and
follow up--make follow-up calls, but I can't say that he didn't do it
because he probably did call some of them.
Question. And you said he would always get the list of the
attendees before he went?
Answer. Yes. Yes.
Ms. Safavian. I think I might be done, if you will just give me a
moment.
Ms. Khare, that's all that I have. Minority counsel may have a few
questions, and I will direct it to him for the moment.
Mr. Yeager. If I could take a few minutes, counsel.
Mr. Lu. Just off the record for a couple of minutes.
[Recess.]
EXAMINATION BY MR. YEAGER:
Question. Let's go back on.
Thank you, Ms. Khare, on behalf of all of the Democratic members of
the committee for coming in today and taking time to give testimony. We
appreciate your coming in voluntarily.
I have one question. I just want to take up where you had testified
before, take you back to March of 1995, when Johnny Chung first called
you from Maggie Williams' office, or the First Lady's office--it is not
clear exactly--you testified that you didn't know who he was at that
time.
Answer. Right.
Question. Isn't that right?
Answer. Uh-huh.
Question. You weren't aware that he had given contributions to the
DNC----
Answer. No.
Question [continuing]. At that time?
Answer. I don't think that I was.
Mr. Yeager. That's it. No further questions.
Ms. Safavian. We are all done. Thank you very much for coming in.
[Whereupon, at 3:55 p.m., the deposition was concluded.]
[The exhibits referred to follow:]
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JOHNNY CHUNG: HIS UNUSUAL ACCESS TO THE WHITE HOUSE, HIS POLITICAL
DONATIONS AND RELATED MATTERS
----------
FRIDAY, NOVEMBER 14, 1997
House of Representatives,
Committee on Government Reform and Oversight,
Washington, DC.
The committee met, pursuant to notice, at 12:25 p.m., in
room 2154, Rayburn House Office Building, Hon. Dan Burton
(chairman of the committee) presiding.
Present: Representatives Burton, McHugh, Horn, Souder,
Pappas, Barr, Waxman, Lantos, Kanjorski, Maloney, Norton,
Fattah, Cummings, Kucinich, and Turner.
Staff present: Kevin Binger, staff director; Richard
Bennett, chief counsel; Dudly Hodson, chief investigator;
Barbara Comstock, chief investigative counsel; Judith McCoy,
chief clerk; William Moschella, deputy counsel and
parliamentarian; Teresa Austin, assistant clerk/calendar clerk;
Will Dwyer, director of communications; Ashley Williams, deputy
director of communications; Dave Bossie, oversight coordinator;
Robert Rohrbaugh, James C. Wilson, and Uttam Dhillon, senior
investigative counsels; Charli Coon, Jennifer Safavian, Kristi
Remington, and Bill Hanka, investigative counsels; Phil Larsen,
investigative consultant; Jim Schumann, investigator; Robin
Butler, office manager; Carolyn Pritts, David Jones, and John
Mastranadi, investigative staff assistants; Phil Schiliro,
minority staff director; Phil Barnett, minority chief counsel;
Kenneth Ballen, minority chief investigative counsel; Agnieszka
Fryszman, Kristin Amerling, Christopher Lu, Andrew McLaughlin,
Michael Raphael, Michael Yang, and Michael Yeager, minority
counsels; Harry Gossett, minority professional staff member;
Ellen Rayner, minority chief clerk; Jean Gosa and Andrew Su,
minority staff assistants; and Sheridan Pauker, minority
research assistant.
Mr. Burton. The committee will come to order. A quorum
being present, we are now in session. Today's session is a
continuation of yesterday's hearing regarding Johnny Chung and
his unusual access to the White House.
Before I welcome our guests this morning, I would like to
say that the questions which will be asked today will not in
any way be taken from the interview we had with Mr. Chung this
morning. We have agreed, Mr. Waxman, myself, our staffs and our
colleagues, to keep the contents of that interview confidential
and we will abide by that agreement.
We will be meeting with Mr. Chung later today to go into it
further, but at this time, with our witnesses today, we will
refrain from raising any issues that were raised in that
confidential interview.
I would like to welcome Brooke Darby, former Executive
Assistant to Nancy Soderberg at the National Security Council,
and Robert Suettinger, former Director of Asian Affairs for the
National Security Council.
We really appreciate your being here, and would you both
stand to be sworn, please?
[Witnesses sworn.]
Mr. Burton. On behalf of the committee, we welcome you here
today. You will each be recognized, if you so desire, to give
an opening statement of 5 minutes. If you have a statement that
is longer than that, we will be happy to insert that into the
record.
So with that, which one of you would like to go first?
Ms. Darby. I have no statement to offer, sir.
Mr. Suettinger. Nor do I, Mr. Chairman.
Mr. Burton. You do not have a statement?
Mr. Suettinger. I do not have a statement.
Mr. Burton. OK. I guess we will start with our
investigative counsel, Mr. Rohrbaugh. I will recognize you--
incidentally, you have counsel with you?
Mr. Suettinger. Yes, we do.
Mr. Burton. Would you like to introduce your counsel?
Mr. Suettinger. This is Mr. John Sparks from the National
Security Council.
Mr. Burton. Mr. Sparks, you are welcome to assist your
clients in any way that you see fit.
Lt. Col. Sparks. Thank you, Mr. Chairman.
Mr. Burton. You are welcome as well.
STATEMENTS OF BROOKE DARBY, FORMER EXECUTIVE ASSISTANT TO NANCY
SODERBERG AT THE NATIONAL SECURITY COUNCIL; AND ROBERT
SUETTINGER, FORMER DIRECTOR OF ASIAN AFFAIRS FOR THE NATIONAL
SECURITY COUNCIL, ACCOMPANIED BY LT. COLONEL JOHN SPARKS,
DEPUTY LEGAL ADVISER, NATIONAL SECURITY COUNCIL
Mr. Burton. Mr. Rohrbaugh.
Mr. Rohrbaugh. Good morning, Ms. Darby, Mr. Suettinger, Mr.
Sparks, we met out in the hall briefly. I introduced myself out
there. My name is Bob Rohrbaugh, and I am just going to ask
some questions of you today. Hopefully, we will try to be brief
so the Members can go back home.
I am going to start with you briefly, Ms. Darby. Could you
briefly tell me your educational background and your work
experience?
Ms. Darby. Yes, I graduated in 1992 from Mount Holyoke
College.
Mr. Burton. Ms. Darby, would you pull the microphone closer
to you so we can hear you clearly? Thank you.
Ms. Darby. Sure. I graduated in 1992 from Mount Holyoke
College. I am currently pursuing a law degree in the evening
division at Georgetown Law School.
My first job after graduating was working for the campaign
in Little Rock, AR, the Clinton/Gore campaign, where I worked
as a foreign policy assistant in the foreign policy office. I
later joined the transition team, where I continued to work for
Nancy Soderberg, who was director of the transition in Little
Rock for foreign policy issues.
Thereafter, I joined the National Security Council staff
working as Nancy Soderberg's special assistant and then later
as her executive assistant.
Mr. Rohrbaugh. Do you still work at the NSC?
Ms. Darby. No, I don't. I currently work at the State
Department in the Bureau of International Narcotics and Law
Enforcement Affairs.
Mr. Rohrbaugh. When you were employed at the NSC to whom
did you report?
Ms. Darby. Nancy Soderberg.
Mr. Rohrbaugh. Who at the NSC would interact with the White
House?
Ms. Darby. Well, both of us interacted with the White
House, and both of us had a number of people who we had worked
with on the campaign who later got jobs in the White House, and
they would frequently call us if they had any issues with
foreign policy implications.
Mr. Rohrbaugh. And you are familiar with an e-mail dated
April 7th, which we are going to display at the present time?
Ms. Darby. Very familiar, sir.
Mr. Rohrbaugh. Very familiar with that. You have been
deposed before; you are very familiar with that e-mail.
First of all, can you tell me what prompted your sending
that e-mail of April 7th that appears in front of you?
Ms. Darby. Yes, I was approached one evening by Kelly
Crawford from the President's staff. She said--she basically
conveyed the information that's in this e-mail, which is that
there had been a radio address, approximately a couple weeks
before. The Friday night before the radio address--the radio
addresses are at 9 a.m. on Saturday mornings--the Friday night
before the President's office had gotten a request from the DNC
that the people on this list in the e-mail be invited to the
radio address and they were invited.
And as a routine part of the radio address, the guests get
their pictures taken with the President afterwards. It usually
takes a couple weeks for those photos to be developed. Those
photos had been developed and Johnny Chung was coming in to see
Nancy Hernreich the following day to pick up the photos. And
she conveyed to me that the President had some concerns about
us perhaps not wanting the photos of him with the individuals
circulating, and asked for our guidance on whether we should--
whether the President's office should give Johnny Chung the
photos when he came to Nancy Hernreich's office the following
day.
Mr. Rohrbaugh. And who asked for your guidance on that?
Ms. Darby. Kelly Crawford.
Mr. Rohrbaugh. In the past--before I get to that, prior to
these individuals having actually come into the White House,
had the NSC been asked to vet or check out these individuals?
Ms. Darby. With respect to the radio address?
Mr. Rohrbaugh. Yes, ma'am.
Ms. Darby. Not that I'm aware of. She indicated to me that
they had not--because of the lateness of the request, coming in
on a Friday night before the radio address on Saturday morning,
that contrary to their normal procedures they hadn't had an
opportunity to check the names with us first.
Mr. Rohrbaugh. OK. So it was the normal procedure that,
especially when foreign nationals would come into the White
House, the NSC would be asked to check or vet these people?
Ms. Darby. Not necessarily. If anyone had a concern about
any of the individuals involved, then they would contact us.
But it was not routine practice for us to vet the names of
people coming to a radio address, for example.
Mr. Rohrbaugh. How often would this vetting be asked of the
NSC by the White House?
Ms. Darby. I don't think I probably handled all of the
vetting, but in terms of my own participation in the vetting
process, I would--it is hard to quantify it, but I would guess
probably four to eight times a month. If I had to guess. But
that really is just an estimate.
Mr. Rohrbaugh. So it would not be unusual for the White
House to actually ask the NSC to vet the people before they
came in?
Ms. Darby. That's right.
Mr. Rohrbaugh. Now, on exhibit No. 196, that is in front of
you, your e-mail.
[Exhibit 196 follows:]
[GRAPHIC] [TIFF OMITTED] T5667.492
Ms. Darby. Yes.
Mr. Rohrbaugh. It starts off by saying ``An odd situation''
developed. Do you see that phrase?
Ms. Darby. Yes, I do.
Mr. Rohrbaugh. What was the odd situation that developed?
Ms. Darby. The odd situation was that the President's
office had some concern about these individuals and they hadn't
come to us in advance to ask for our guidance before these
individuals were invited into the White House.
And usually, if they had a concern about someone, they
would make every effort to contact us first so we would have an
opportunity to comment before the individuals were invited.
Mr. Rohrbaugh. And if I can, in the second paragraph, it
says they, which I believe refers to the President's office,
``Did so, not knowing anything about them except that they were
DNC contributors.''
Did you know anything else about these individuals other
than they were DNC contributors?
Ms. Darby. I didn't know anything about them, sir. I tried
to convey the information that Kelly Crawford had offered to
me. I presume she used the term DNC contributors, because I
would have had no independent basis for knowing whether they
were or were not.
But I don't recall in detail what her words were to me
other than what's written in this e-mail, which may or may not
have reflected her exact words.
Mr. Rohrbaugh. And if I can show you a larger version of
the same exhibit, at the bottom paragraph it says, ``for your
information these people are major DNC contributors,'' and it
goes on, which basically indicates that the President would
like to give the photographs out, if possible.
From whom did you get the information that these
individuals, the people that you listed, the Chinese
delegation, were major DNC contributors?
Ms. Darby. Again, I can only presume that that information
was conveyed to me by Kelly Crawford because, again, I would
have had no independent basis for knowing whether these people
were contributors or not. Again, I'm not sure those were the
exact words she used, but that was the impression that I got
from her.
Mr. Rohrbaugh. You sent this e-mail, I believe, to Mr.
Suettinger, among others?
Ms. Darby. Yes, I did. I sent it to the entire Asia Office,
because it was something that required a prompt response, and I
wanted to make sure that if Bob wasn't around, that someone in
the office got it.
Mr. Rohrbaugh. And I believe you sent it on April 7th at
approximately 10:12 in the morning; is that right?
Ms. Darby. That's what this e-mail would indicate, yes.
Mr. Rohrbaugh. Did Mr. Suettinger respond to you?
Ms. Darby. Yes, he did.
Mr. Rohrbaugh. And how soon after you sent your e-mail did
he respond to you?
Ms. Darby. This e-mail indicates that he responded at
11:24, which would have been, I guess, about an hour and a half
later.
Mr. Rohrbaugh. And you are referring to exhibit No. 198
that shows Mr. Suettinger's response to you; is that correct?
[Exhibit 198 follows:]
[GRAPHIC] [TIFF OMITTED] T5667.493
Ms. Darby. 197.
Mr. Rohrbaugh. OK, 197-198 are the same.
Ms. Darby. Both. Yes. Yes.
Mr. Rohrbaugh. Now, I will get into with Mr. Suettinger
exactly what he responded, but based upon what Mr. Suettinger
responded to you, what did you do?
Ms. Darby. I got back in touch with Kelly Crawford and I
conveyed to her the nature of Bob's response. I believe I
quoted pieces of the response back to her.
She's not--the White House and the NSC are on separate e-
mail systems because our system is classified. So there was no
way for me to directly send a copy of this on to her
electronically. But I believe I conveyed the substance of it to
her and gave her an opportunity to pick up a copy of the text
of the e-mail if she wanted it. And I don't recall whether she
picked it up from me or not.
Mr. Rohrbaugh. In front of you is the larger version,
exhibit C-79, of Mr. Suettinger's response, and it indicates
that he, referring to Johnny Chung, is a hustler. That's Mr.
Suettinger's quotation, I believe, that has now become rather
famous.
Did you relay that information on to Kelly Crawford?
[Exhibit C-79 follows:]
[GRAPHIC] [TIFF OMITTED] T5667.494
Ms. Darby. I believe I did so. That would have been a major
piece of information that she would have needed. So I believe
I--I don't have a specific recollection of passing that on, but
I'm quite sure that I would have.
Mr. Rohrbaugh. Did you make a recommendation to Ms.
Crawford as to whether or not these photographs should be
released?
Ms. Darby. I believe I gave her a personal recommendation
that we probably would not recommend that they release them.
Mr. Rohrbaugh. OK. Now, in Mr. Suettinger's e-mail, he
generally indicated that he didn't think there would be a major
problem. But you took it upon yourself to recommend that the
photographs not be released?
Ms. Darby. It was not a strong recommendation on my part.
Ultimately, there was nothing in Bob's e-mail that conveyed to
me that Johnny Chung or any of the individuals involved
represented a national security risk or that they were
criminals of any kind. But given that, my impression from his
e-mail was that he would perhaps attempt to exploit his
contacts with the President through these photos, that it might
be better to err on the side of caution and not give them to
him.
But it didn't pose a serious security risk, and that is
what she came to us to give a recommendation on.
Mr. Rohrbaugh. Prior to your making that recommendation,
did you contact or talk with your supervisor, Ms. Soderberg?
Ms. Darby. Not that I can recall.
Mr. Rohrbaugh. So it was basically your personal
recommendation that you passed on that the photographs not be
released?
Ms. Darby. Yes.
Mr. Rohrbaugh. Mr. Suettinger, let me just address a few
questions to you. Can you briefly tell me what your background
is and where you're presently employed?
Mr. Suettinger. You want my educational background?
Mr. Rohrbaugh. Yes, please.
Mr. Suettinger. I graduated from Lawrence University in
Wisconsin in 1968. After a stint in the military, I attended
graduate school at Columbia University, where I received a
master's degree.
In 1975, I joined the Central Intelligence Agency as an
analyst, principally on Chinese matters, and had several
different jobs within the agency and at the State Department.
In 1994, Mr. Stanley Roth asked if I would assist him at the
National Security Council, which I did, beginning in 1994, and
continuing until late September 1997.
I am currently employed at the National Intelligence
Council, which is located in Langley.
Mr. Rohrbaugh. So for the period of roughly 1994 through
1997 you were at the NSC?
Mr. Suettinger. That's correct.
Mr. Rohrbaugh. At the White House. And can you tell me when
the first time was that you heard of Johnny Chung?
Mr. Suettinger. I can't give you a specific date, because
my first contact with Mr. Chung, I believe, was via a telephone
call that he made to the National Security Council requesting a
meeting with Mr. Roth.
Again, I cannot remember either the specific context of
that telephone call or whether it was repeated, but I know that
his name was familiar to me when it came up later on.
Mr. Rohrbaugh. Have you ever met Mr. Chung?
Mr. Suettinger. I have not.
Mr. Rohrbaugh. And approximately how many times have you
spoken to Mr. Chung, then?
Mr. Suettinger. I would guess at most two, perhaps three.
He was somewhat persistent, as I recollect, in trying to get a
meeting with Mr. Roth, he and a couple of other people, and I
fended off those requests.
Mr. Rohrbaugh. Let me refer your attention to exhibit No.
250, which is in your book, and it is an e-mail dated February
2, 1995, from Calvin Mitchell. Did you get a copy of that e-
mail?
[Exhibit 250 follows:]
[GRAPHIC] [TIFF OMITTED] T5667.495
Mr. Suettinger. Yes, I do.
Mr. Rohrbaugh. In that particular e-mail it indicates that
there would be, the chairman of the Chamber of International
Commerce might be coming to see the President. Did you know
who--first of all, had you ever heard of that organization, the
Chamber of International Commerce?
Mr. Suettinger. I had not.
Mr. Rohrbaugh. Did you know the individual who was listed
in that particular e-mail?
Mr. Suettinger. His name is vaguely familiar to me.
Mr. Rohrbaugh. And that was through your employment?
Mr. Suettinger. That's correct.
Mr. Rohrbaugh. At that time, which is February 2, 1995, did
you undertake any type of investigation or vetting of this
particular individual who is listed on this e-mail?
Mr. Suettinger. I did not.
Mr. Rohrbaugh. And I won't pronounce the name. I will leave
that to you.
Mr. Suettinger. Zheng Hongye.
Mr. Rohrbaugh. And why was it that you did not do any
investigation or vetting of Mr. Chung at that time?
Mr. Suettinger. First of all, at that time, this was just a
heads-up, rather than a request that this individual would be
vetted. I didn't--and, quite frankly, I had not even remembered
the existence of this e-mail until it was brought to my
attention earlier this week as an FYI. I just basically
disregarded it.
Mr. Rohrbaugh. Are there resources at the NSC which would
permit the NSC to actually vet individuals?
Mr. Suettinger. There are some at the NSC and some
available via other means, phone calls and so forth.
Mr. Rohrbaugh. OK. And without getting into any classified
information, those resources were readily available to you at
the NSC?
Mr. Suettinger. That's correct.
Mr. Rohrbaugh. OK. When did you first become aware that Mr.
Chung intended to bring a Chinese delegation into the White
House?
Mr. Suettinger. I was not aware of that until Ms. Darby
wrote me the e-mail.
Mr. Rohrbaugh. So the first time you heard about that at
all is when Ms. Darby sent you that e-mail?
Mr. Suettinger. That's correct.
Mr. Rohrbaugh. And, again, just for the record, let me show
you exhibit No. 196, and that's the e-mail that you received
from Ms. Darby?
[Note.--Exhibit 196 may be found on p. 715.]
Mr. Suettinger. Yes, it is.
Mr. Rohrbaugh. To your knowledge, had anyone at the NSC or
the White House or anybody else vetted these individuals prior
to their coming into the White House?
Mr. Suettinger. I'm not aware of that having been done.
Mr. Rohrbaugh. And as you know, maybe you don't, the Secret
Service does a criminal background check before individuals
come into the White House. Is that right?
Mr. Suettinger. I don't know whether they do them for
people from foreign countries. Certainly I know they do that
for domestic visitors.
Mr. Rohrbaugh. And, to your knowledge, that's the extent of
the background that the Secret Service does on individuals
coming into the White House?
Mr. Suettinger. I really am not qualified to comment on
that, sir.
Mr. Rohrbaugh. I understand it--well, is one of the
purposes of vetting a person, to use that Washington term,
actually to protect the President and the President's
reputation?
Mr. Suettinger. My understanding of the process is that it
is to make sure that people who have criminal records or who
are intelligence personnel or who are otherwise considered for
whatever reason unsavory characters are not put in the
proximity of the President.
Mr. Rohrbaugh. Let me refer you to your e-mail, which is
exhibit 198. Is that your response to Ms. Darby's e-mail?
Mr. Suettinger. Yes, it is.
Mr. Rohrbaugh. In your response, you indicate that all the
Chinese on the list, with one possible exception, appear to be
bona fide present or former Chinese officials. How did you come
to that conclusion?
Mr. Suettinger. I came to that conclusion, one, by
recognizing some of the names in the list; or by looking them
up in a directory, an unclassified directory of Chinese
officials that I had available to me; or, three, by determining
that the organizations that they worked for were organizations
that I recognized, I had heard the names of before, and seemed
to be bona fide organizations in China.
Mr. Rohrbaugh. And I believe there was one exception in
your e-mail; is that right?
Mr. Suettinger. That's correct.
Mr. Rohrbaugh. And who was that?
Mr. Suettinger. That was Mr. James Sun, who was described
as a self-made millionaire from Xinjiang province. I had no
record of him nor any way of checking on him.
Mr. Rohrbaugh. Was that the reason why you had some
suspicions or some concerns about Mr. Sun?
Mr. Suettinger. Well, the other reason was that there are
relatively few self-made millionaires in the People's Republic
of China. So that term would be--was somewhat jarring and kind
of grabbed my attention.
Mr. Rohrbaugh. Let me show you a portion of a videotape.
[Video tape presentation was shown.]
Mr. Rohrbaugh. The last individual on that tape, I hope
that you heard, Mr. Chung introduced him as being his brother.
Had you ever heard that Mr. Sun was Mr. Chung's brother?
Mr. Suettinger. No, I had not.
Mr. Rohrbaugh. Do you have any information one way or the
other as to whether, in fact, Mr. Chung and Mr. Sun are
brothers?
Mr. Suettinger. I have no information to that effect.
Chinese often refer to close friends as brothers.
Mr. Rohrbaugh. Had you ever seen this videotape prior to
coming in today?
Mr. Suettinger. I had not.
Mr. Rohrbaugh. One of the individuals in the Chinese
delegation was described as the vice president of CITIC; is
that right?
Mr. Suettinger. That's correct.
Mr. Rohrbaugh. And who was that individual?
Mr. Suettinger. That is Mr. Huang Jichun. Or Jichun Huang,
as it's written here.
Mr. Rohrbaugh. Is CITIC an entity that is at least
partially controlled by the State Council of the PRC?
Mr. Suettinger. I believe that's correct.
Mr. Rohrbaugh. And do you know approximately what
percentage is owned supposedly by the State Council of the PRC?
Mr. Suettinger. I do not.
Mr. Rohrbaugh. And what is the State Council of the PRC?
Mr. Suettinger. The State Council is the official governing
organ of the People's Republic of China. It is headed by the
Premier and is in charge of all the Government ministries and
many other organizations within the People's Republic.
Mr. Rohrbaugh. Now, if I can, let me jump ahead to another
incident that occurred in 1996 involving Wang Jun, do you
remember that incident?
Mr. Suettinger. I do.
Mr. Rohrbaugh. OK. Mr. Wang Jun, who was the purported arms
dealer, was also involved in CITIC; is that right?
Mr. Suettinger. I believe he's the chairman of CITIC.
Mr. Rohrbaugh. Back in 1995, after you got the list of
names from Ms. Darby, did the fact that the vice president of
CITIC was seeing the President, did that cause you any concern?
Mr. Suettinger. It did not.
Mr. Rohrbaugh. Let me go back to your e-mail, exhibit No.
198. In your e-mail you indicate, but a word of caution, a
warning of future deja vu, and you indicate that Mr. Chung
should be treated with, quote, a pinch of suspicion, unquote.
What did you mean by that?
Mr. Suettinger. As I spelled out subsequently in the e-
mail, I was concerned that Mr. Chung might have been making use
of his political connections to further his own business
interests. And I was concerned that those business interests
were not known to many people and that they might not be of the
sort that the President would want to be associated.
Mr. Rohrbaugh. Did you ever find out or learn of the
various entities that Mr. Chung was involved in?
Mr. Suettinger. I did not.
Mr. Rohrbaugh. And I believe in that same paragraph you
also used that infamous term, hustler; is that right?
Mr. Suettinger. That's correct, sir.
Mr. Rohrbaugh. And was that for the same reason?
Mr. Suettinger. Basically, yes.
Mr. Rohrbaugh. Now, I just asked you about whether you were
aware of some of the entities that Mr. Chung was involved with.
Were you aware that just prior to Mr. Chung giving the DNC a
$50,000 contribution, he had received through the bank of
China-Beijing $150,000?
Mr. Suettinger. I was not aware of that.
Mr. Rohrbaugh. Let me, if I can, just show you quickly,
exhibit No. 175. Exhibit No. 175 is a wire transfer from the
Bank of Beijing, and at the bottom indicates payment of goods
Haomen Group, Shan Tang. Do you see that?
[Exhibit 175 follows:]
[GRAPHIC] [TIFF OMITTED] T5667.496
Mr. Suettinger. I only see--yes, I see that. Is it Tang
Shan?
Mr. Rohrbaugh. Tang Shan, I'm sorry.
Mr. Suettinger. S-H-A-N? I don't have that on my screen.
Mr. Rohrbaugh. OK. Are you familiar with what the Haomen
Group is?
Mr. Suettinger. No, I'm not.
Mr. Rohrbaugh. Are you familiar with the fact that in
December 1994, Mr. Chung had brought to the White House, I
believe it was the president of the Haomen Group?
Mr. Suettinger. I was not aware of that at the time. I'm
aware of it now. I did not associate the term Haomen with those
individuals.
Mr. Rohrbaugh. Do you presently or at the time in April,
when you wrote your memo, did you know whether Mr. Chung had
actually, and I hate to use the term, sold the Haomen Group any
goods?
Mr. Suettinger. I was not aware of it.
Mr. Rohrbaugh. Let me ask you a couple more questions
about, if I can go back to exhibit No. 198. Your e-mail
continues by stating, the joys of balancing foreign policy
considerations against domestic politics. Did you often have to
do that at the National Security Council?
Mr. Suettinger. No.
Mr. Rohrbaugh. What did you mean by that term?
Mr. Suettinger. The situation was that these individuals
had come in without my being aware of it. We were being asked
as a matter of domestic policy and, in particular, DNC policy,
to make a judgment call as to whether or not photographs should
be given. That was not a task that I relished.
Mr. Rohrbaugh. Why not?
Mr. Suettinger. I simply considered it to be outside the
scope of my own responsibilities.
Mr. Rohrbaugh. How much weight did the DNC carry when it
came to deciding who would meet with the President?
Mr. Suettinger. I can't answer that question.
Mr. Rohrbaugh. After your warning of April 8th, do you know
how often Mr. Chung would then go into the White House?
Mr. Suettinger. I did not know that at the time. I have
obviously learned it subsequently from newspaper accounts.
Mr. Rohrbaugh. So you are aware that it would be
approximately 20 additional times he entered the White House
even after your November 8, 1995, warning?
Mr. Suettinger. I'd have to take your word for that.
Mr. Rohrbaugh. Were you also aware that in July 1995, or
did you become aware in July 1995 that Mr. Chung was attempting
to negotiate the release of Harry Wu?
Mr. Suettinger. I did become aware of that.
Mr. Rohrbaugh. And how did you become aware of that?
Mr. Suettinger. I received, in fact in two separate copies,
some correspondence from the Chief of Staff 's Office, I
believe, I'd have to refer to the documents in particular,
indicating that Mr. Chung had sought some credentials from the
DNC to undertake this kind of mission.
Mr. Rohrbaugh. Let me show you exhibit No. 251. It's a
memorandum from Janice Enright at the Office of the Chief of
Staff of the President, to Anthony Lake. Did you ever see that
document before?
[Exhibit 251 follows:]
[GRAPHIC] [TIFF OMITTED] T5667.497
Mr. Suettinger. Yes, I have.
Mr. Rohrbaugh. And when did you see it?
Mr. Suettinger. It would have been around the time,
probably very shortly before my response. Somewhere between
July 21st and 24th.
Mr. Rohrbaugh. And you made a response to this memo, then;
is that right?
Mr. Suettinger. This memo was sent on to me through the
system, as we call it in the National Security Council, and I
responded to it, and I'm sorry, I had my date wrong, July 31st.
Mr. Rohrbaugh. Let me show you exhibit No. 252. Can you
tell me what that is?
[Exhibit 252 follows:]
[GRAPHIC] [TIFF OMITTED] T5667.498
Mr. Suettinger. That is a memo that I wrote to Mr. Lake in
response to the memorandum from Ms. Enright that was sent on to
me.
Mr. Rohrbaugh. What was your reaction about Mr. Chung
attempting to negotiate the release of Harry Wu?
Mr. Suettinger. I was quite upset.
Mr. Rohrbaugh. Why?
Mr. Suettinger. We had been engaged in a very quiet
persistent and complex set of signals and negotiations with the
Chinese Government trying to ensure that Mr. Wu was released as
soon as possible, and it struck me that Mr. Chung might be
capable of interfering in that process.
I had no idea of what message he thought he was delivering
to the Chinese Government, and thought it could only confuse
the matter; and I was worried that this process might be upset
by the intrusion of somebody who had no knowledge and no
responsibilities for what happened.
Mr. Rohrbaugh. Were you concerned that Mr. Chung was not a
professional diplomat?
Mr. Suettinger. It wasn't so much that he was a
professional diplomat as that he seemed to believe that he had
some sort of a mission, and it was a mission that I didn't
believe that he had; and that I was concerned it would
complicate what we were trying to do in our own appropriate
channels.
Mr. Rohrbaugh. Your memorandum is actually written, I
believe at the very bottom it says, Mr. Chung had already left
for Beijing at the time you had written your memorandum. Is
that right?
Mr. Suettinger. That's correct.
Mr. Rohrbaugh. If that's the case, why did you feel the
need to write that memorandum?
Mr. Suettinger. One, it was sent to me for action and,
generally speaking, when we were given an assignment for action
we tried to respond, to answer the mail, if you will; and I
also thought that I wanted to convey to Mr. Lake my concerns
about this sort of thing because I certainly didn't want a
repetition of it.
Mr. Rohrbaugh. At the bottom you indicate that you had the
concurrence of Alan Kreczko; is that right?
Mr. Suettinger. That's correct.
Mr. Rohrbaugh. Who is Mr. Kreczko?
Mr. Suettinger. Mr. Kreczko was the Senior Director, Legal
Assistant, to the National Security Council.
Mr. Rohrbaugh. Why did you feel that you had to have the
concurrence of Mr. Kreczko?
Mr. Suettinger. It involved an American citizen. Two
American citizens.
Mr. Rohrbaugh. Did you ever find out who Mr. Chung met
while he was in Beijing or what he did?
Mr. Suettinger. I only read one newspaper account, and I
don't know whether it was credible or not.
Mr. Rohrbaugh. Mr. Chairman, I have no other questions.
Thank you.
Mr. Burton. I would like to use some of your time on the
Republican side, if I might.
I want to make sure I understand this. This Mr. Zheng
Hongye.
Mr. Suettinger. Zheng Hongye.
Mr. Rohrbaugh. He was chairman of the China Council for the
Promotion of International Trade, the CCPIT, an organization
set up by the Chinese Communist Party to coordinate lucrative
deals and funnel profits back into the party's leadership. Are
you aware of who he was?
Mr. Suettinger. Your definition of that organization, sir,
is not one that I had heard before. My understanding of the
CCPIT is that it was an organization that was set up to promote
international trade. It sponsored business delegations coming
to the PRC and also Chinese delegations going overseas.
Mr. Rohrbaugh. It was a part of the Communist Government.
Mr. Suettinger. That's correct.
Mr. Burton. I think that says it. He was an adviser to the
PRC State-owned China Ocean Shipping, COSCO, which wanted to
lease the Long Beach Naval Shipyard.
Mr. Suettinger. I was not aware of that, sir.
Mr. Burton. He was vice chairman of the Chinese People's
Political Consultant Conference of the PRC's Communist Party
for the Subcommittee for Taiwan, Hong Kong, Macao Compatriots
and Overseas Chinese. Were you aware of that?
Mr. Suettinger. No, I was not.
Mr. Burton. You were not aware of that either.
Mr. Jichun Huang, he was director and vice president of
China International Trust and Investment Corp., CITIC. You knew
that?
Mr. Suettinger. Yes, sir.
Mr. Burton. And CITIC is the largest state-run business in
the PRC with diversified holdings in banking, energy production
and the United States real estate market, and the president is
the alleged arms smuggler, as was mentioned before, Mr. Wang
Jun. You are familiar with that?
Mr. Suettinger. I'm familiar with the fact Mr. Jun is the
chairman of CITIC.
Mr. Burton. And Mr. Renzhong Wang served as superintendent
of the China Aviation Industry Ministry, part of the Chinese
Communist Government, in Harbin. You are familiar with that?
Mr. Suettinger. Renzhong Wang is a rather common name, and
there are a number of them who have been in different offices.
I will take your word for it.
Mr. Burton. That is what our information shows.
Mr. Suettinger. I will take your word for it.
Mr. Burton. And of course Jianiong Yu oversees the
activities of the COSCO shipping company, the Chinese shipping
company.
The reason I bring all this up is these people have been
alleged to have been part of a beer operation over there, but
they had far-reaching responsibilities in China and ties to the
Chinese party. They are coming in to meet the President. They
meet with the President and he greets them warmly. And then
after pictures are taken, he doesn't want the pictures to be
given to them, and you didn't think the pictures should be
given to them, I guess, as well.
Mr. Suettinger. My e-mail suggests that I didn't think
there would be any lasting damage from providing the
photographs to these individuals.
Mr. Burton. I have no further questions.
Mr. Waxman.
Mr. Waxman. Thank you, Mr. Chairman.
Today's hearing is a continuation of a hearing we held
yesterday, and both days are looking at a man by the name of
Johnny Chung, who seemed to have an extraordinary amount of
access to the White House and gave large amounts of money to
the Democratic party.
Mr. Suettinger and Ms. Darby, you are here--oftentimes
witnesses are invited to come and testify because we think
maybe they did something wrong, but you are here to give us
your professional judgment from the National Security Council
about some matters that took place involving Mr. Chung.
And, Mr. Suettinger, you said in a memo that I think
counsel has already referred to, that when you gave your
impression of Mr. Chung you said, my impression is that he's a
hustler and appears to be involved in setting up some kind of
consulting operation.
Well, I think you are exactly right. Nothing we have
learned or in the materials the committee has received
indicates anything else. I don't believe this is a hearing
about economic espionage or foreign agents or conspiracies to
infiltrate our political system, or any of these more
sensational charges that have been bandied about.
What it appears to me is that we have a man who was out to
try to make a buck; he was a hustler. And the fact of the
matter is, there are a lot of hustlers around, especially in
this city. There is nothing illegal in being a hustler, even if
we might not approve of it.
Now, the two of you are here to testify on one very narrow
issue in particular, and that is the fact that Mr. Chung took a
bunch of people in to listen to the President give a radio
address to the country. And from the testimony yesterday, after
that radio address, the President, after meeting these people,
said that he felt something was inappropriate. And Ms.
Hernreich told somebody, I guess Miss Darby, to find out
whether they should release these photos to this man.
Mr. Suettinger, you were asked your opinion about that, and
I gather you agreed that the photos could go to Mr. Chung and
his colleagues; is that correct?
Mr. Suettinger. That's correct.
Mr. Waxman. Now, Mr. Suettinger, you are here because you
are one of the leading experts on China. You made this your
career. You speak Mandarin, you speak Cantonese; you are, I
think fair to say, you serve as one of the NSC's top experts on
east Asia. Is that an accurate statement?
Mr. Suettinger. It is not for me to say, sir.
Mr. Waxman. Don't be immodest.
In April 1995, you were asked by Brooke Darby to give your
professional opinion as to whether the White House should
release these photos to Johnny Chung. And you concluded in
April 1995, quote, ``I don't see any lasting damage to U.S.
foreign policy from giving Johnny Chung these pictures.'' Is
that right?
Mr. Suettinger. That's correct.
Mr. Waxman. In the second paragraph of your April 7, 1995
e-mail you did state some reservations about Mr. Chung, and you
were concerned he was trying to use his White House contacts to
enhance his business; is that correct?
Mr. Suettinger. That's correct.
Mr. Waxman. But your reservations had nothing to do with
Mr. Chung trying to influence U.S. foreign policy; is that
right?
Mr. Suettinger. That's correct.
Mr. Waxman. Was your e-mail intended to be a general
directive to all White House staff to avoid contacts with
Johnny Chung?
Mr. Suettinger. I'm not sure I'd go that far, sir. I just
wanted to raise some concerns that had been brought to my
attention that I thought others should know about what Mr.
Chung might be up to.
Mr. Waxman. It was a simple response to a request for
advice about the release of these photos?
Mr. Suettinger. That's correct.
Mr. Waxman. Now, was Brooke Darby's request for advice
about the release of photos a matter of high importance to you
as a member of the National Security Council?
Mr. Suettinger. No, it was not.
Mr. Waxman. Every day the NSC has to deal with the most
sensitive and pressing national security matters facing this
country. Isn't that a fair statement?
Mr. Suettinger. I believe that's fair, sir.
Mr. Waxman. So the release of photos is one of the least
important questions you had to grapple with.
Mr. Suettinger. It was not one that I thought was of
burning national interest.
Mr. Waxman. Based on your expertise, were the businessmen
who accompanied Johnny Chung senior members of the Chinese
Government?
Mr. Suettinger. They were senior members--yes, they were
either senior members or former senior members. It's hard to
draw a sharp distinction between what are essentially
government-owned corporations and the Government itself. They
have no governing authority, but they certainly have plenty of
State backing.
Mr. Waxman. Can you give us your views as to the relative
importance of these businessmen within China?
Mr. Suettinger. Relative importance in terms of what, sir?
Mr. Waxman. How important figures were they? We just had a
visit from the President of China. He is obviously the most
important.
Mr. Suettinger. Way below that.
Mr. Waxman. Pardon?
Mr. Suettinger. Far below that.
Mr. Waxman. Far below that. In July 1995, you drafted a
memo concerning a request for Presidential credentials letter
for Johnny Chung. He was interested in a letter from the
President because he wanted to go to China to see if he could
free jailed dissident Harry Wu; isn't that right?
Mr. Suettinger. That's correct.
Mr. Waxman. In your July 31, 1995 memo to Anthony Lake you
referred to Mr. Chung and said, ``No one in the administration
has any idea of what he plans to say on the subject of Harry
Wu, and I doubt the President did more than shake his hand in a
receiving line.'' Did that statement correctly reflect your
views in July 1995?
Mr. Suettinger. That is correct.
Mr. Waxman. In other words, you had no reason to believe
that the President ever encouraged Mr. Chung to go to China. In
fact, you had no reason to believe the President was aware of
anything about Mr. Chung.
Mr. Suettinger. I was--I had no reason to believe that at
the time, no.
Mr. Waxman. Subsequent to July 1995, have you learned of
anything that causes you to believe that the President
encouraged Mr. Chung to go to China?
Mr. Suettinger. As I said, the only information that I have
received about Mr. Chung's travel to China has been what has
been published in the newspapers, and I have no way of
assessing its credibility.
Mr. Waxman. You know Mr. Chung had a letter from DNC
Chairman Don Fowler. Was this letter the kind of credentials
letter that is provided to diplomats?
Mr. Suettinger. No.
Mr. Waxman. In fact, traditional diplomatic credentialed
letters are provided by governments rather than political
parties.
Mr. Suettinger. That is correct.
Mr. Waxman. And you yourself wrote to Mr. Lake and said
that ``Chung's credentials,'' meaning Chairman Fowler's letter,
are ``thin.'' What did you mean by that?
Mr. Suettinger. I thought that they would not be
interpreted by the Chinese Government as representing the views
of the President or the Government of the United States.
Mr. Waxman. Some Republicans have suggested that Johnny
Chung, who is an American citizen, should somehow have been
restrained by the administration from traveling to China on his
own to pursue his own private efforts concerning Harry Wu. In
your experience, does it sometimes happen that American
citizens undertake their own private diplomatic efforts?
Mr. Suettinger. I would say there are probably examples of
that; yes, sir.
Mr. Waxman. Well, you call them free-lancers.
Mr. Suettinger. Yes.
Mr. Waxman. There are a lot of free-lancers around who
promote their view of what diplomacy ought to be, aren't there?
Mr. Suettinger. Yes, there are.
Mr. Waxman. In fact, in your interview, you called these
kinds of individuals free-lancers because you're generally
skeptical about the efforts of these free-lancers. They are not
operating consistent with what U.S. Government policy might be.
Mr. Suettinger. That's correct.
Mr. Waxman. Now, free-lancers are not something unique to
this one case. You have encountered free-lancers from the
American business community. In fact, didn't Ross Perot once
organize a rescue mission to free some of his employees from
captivity in the Middle East? Wasn't that an example of free-
lancing?
Mr. Suettinger. I would not want to characterize that, sir.
Mr. Waxman. OK. When people in the academic community go
off on their own, are they free-lancers as well?
Mr. Suettinger. I think we need to draw a distinction
between going out--I mean, everybody who travels to China is
not a free-lancer. What I'm concerned about is when they're
dealing with or trying to deal with an issue of particular
national importance, such as the release of Mr. Wu. In those
cases, I consider interference or efforts to be influential in
that process to be free-lancing.
Mr. Waxman. It is the same as Amnesty International or
Human Rights Watch or a Member of Congress acting on his own
but not in sync with the American Government, going and doing
what might be called free-lancing.
Mr. Suettinger. The difference between Mr. Chung's case and
those is that Mr. Chung was going out representing himself as
being on a mission that was connected to the White House, at
least via the DNC, and I thought that was of considerable
concern.
Mr. Waxman. I concede that point, and I think it is a valid
one.
I am going to yield to Mr. Lantos to pursue further
questions.
Mr. Lantos. Thank you very much for yielding.
Well, today's episode of Trivial Pursuit deals with
pathological preoccupation with photo opportunities. Now, I
find these particular photo opportunities paling into
insignificance when compared to the photo opportunities that
the President of China just had during the course of his visit
to the United States. As a matter of fact, prior to his visit,
I publicly pointed out that having himself photographed at
Williamsburg or at the Liberty Bell or at the White House or at
Wall Street will do nothing to diminish our outrage at Human
Rights violations in China.
And, of course, in terms of who has himself photographed
with the top man in China, certainly there was a state dinner
at the White House where everybody tried to get himself
photographed with him. He visited here in the Congress, where
the Speaker took him around. He had breakfast with several of
us. And of course when he went to New York, the cream of the
crop of the American business and financial community busted
its gut to get into that dinner and to get themselves
photographed with the top man in China. So, quite frankly, I
sort of fail to get excited over the fact that a group of
third-rate Chinese officials stood by while the President was
reading a prepared 5-minute radio talk.
I do want to spend a minute on the Harry Wu case, because
while I find the rest of this ludicrous, ludicrous beyond
words, I mean it doesn't rise to the level of anything worthy
of any serious discussion, Mr. Chung is a cheap and,
unfortunately for him by this stage, an unsuccessful hustler,
and he was collecting photographs all over the political
landscape, from Presidential Candidate Dole to distinguished
Republican Governors, Speaker Gingrich, the First Lady and
whatnot, and putting them together in a brochure. And that is
what he was selling. He was selling the illusion.
If I were to characterize him, I would call him an illusion
merchant. He was selling an illusion that since Senator Dole
happened to have his picture taken with him, somehow he had
influence with Senator Dole or Newt Gingrich or the First Lady,
which was about as absurd a suggestion as anything that could
be made.
But the Harry Wu thing annoys me, and I tell you why it
annoys me. Harry Wu is one of the heroes of our age. He has
given many, many years of his life because of his commitment to
democracy and freedom. In his attempt to demonstrate the slave
labor system in China, he spent many years of his life in the
most miserable Chinese prison conditions. And the very best
people in this Congress, on both sides of the aisle, in both
the House and the Senate, and many people in the private sector
have busted their guts for years to get Harry Wu out. And the
notion that Johnny Chung, this quintessentially cheap self-
promoter, played the slightest role in the liberation of Harry
Wu is a notion that I find repugnant and obnoxious. This is the
notion of the rooster who claims that the sun rises because he
crows. This does not even rise to the level of absurdity. It is
beyond absurdity.
But, since we need to go on with today's episode of Trivial
Pursuit, I would like to place into the record, Mr. Chairman,
the article of October 30 from the Washington Post entitled
``Business Mixes With Pleasure at the White House Dinner,
China's Jiang Gets a Taste of Corporate America,'' which
describes in detail how diners of our major multinational
corporations were anxious to have their pictures taken with the
President of China, who I think is a more significant figure
than the small entourage that got into the radio studio.
I thank the gentleman for yielding.
Mr. Burton. Without objection.
Mr. Waxman. I yield to Mrs. Maloney, the next senior
member, for questioning.
Mrs. Maloney. Thank you for yielding to me.
I would like to ask Mr. Suettinger, earlier we were talking
about the gentlemen that were with Mr. Chung, and many of them
were associated, you said, with the Chinese Government, but it
is a Communist country, and the Communist country owns all if
not or most of the businesses there. And are most of the people
in business in China associated with the Chinese Government? Is
that a fair statement, would you say?
Mr. Suettinger. I don't think so.
Mrs. Maloney. So there are a lot of private businesses?
Mr. Suettinger. There is a growing amount of private
enterprise in China; that is correct.
Mrs. Maloney. I would like to ask both of you the same
question, first Ms. Darby and then Mr. Suettinger.
Do you have any reason to believe that Johnny Chung was an
agent of the Chinese Government, Ms. Darby?
Ms. Darby. No, I do not.
Mrs. Maloney. Mr. Suettinger.
Mr. Suettinger. I do not.
Mrs. Maloney. Do you believe that he tried to seek any
favors for China, Ms. Darby?
Ms. Darby. I really have no basis for knowing. I have no
idea.
Mr. Suettinger. Not having been present at any of Mr.
Chung's meetings, I can't answer the question.
Mrs. Maloney. Do you believe that it was unusual for Johnny
Chung to seek to have his picture taken with the President, the
First Lady or other members of the administration? And do you
believe that Johnny Chung was unique in seeking to obtain those
photographs?
Ms. Darby. From what I understand in press accounts
recently, it doesn't sound like this was an unusual situation.
Mr. Suettinger. Again, I have no basis on which to make a
judgment on that.
Mrs. Maloney. Do you think it is unusual for a businessman
to display a photograph of himself with the President, the
First Lady or Members of Congress or leaders in the
administration?
Ms. Darby. No, I do not think it's unusual.
Mr. Suettinger. I would think not.
Mrs. Maloney. Is there anything illegal or unethical in
seeking to obtain such a picture or to display it?
Ms. Darby. I don't believe so.
Mr. Suettinger. Not to my knowledge.
Mrs. Maloney. Do you believe that the White House typically
asked for guidance with respect to people granted access to the
President?
Ms. Darby. They sought access on some--they sought our
opinion on some occasions, whenever they had a concern.
Mr. Suettinger. I would have to defer to Ms. Darby on that.
Mrs. Maloney. Do you think that it was common for people to
gain access to the President without being screened by the
National Security Council?
Ms. Darby. That I really wouldn't know. I'm sure there are
many people who are not screened by the National Security
Council, but in terms of foreign nationals or others, I really
wouldn't know.
Mr. Suettinger. Nor do I.
Mrs. Maloney. And what do you think the White House should
do to make the vetting process more effective? Do you have any
ideas in that direction?
Ms. Darby. I understand that Sandy Berger, the current
National Security Adviser, has instituted some new vetting
policies. I'm not sure what those are. I believe it's to make
more routine inquiries into people who are coming in to see the
President, who have a foreign connection of some kind.
Mrs. Maloney. Could you forward those recommendations to
the committee so we could look at them or get them for us?
Ms. Darby. I believe they are recommendations that have
already been made by Sandy Berger, so.
Mrs. Maloney. So they have already been made. I would just
like to see them, that's all. I guess we can get them from him.
Ms. Darby. Yes. I don't work for the National Security
Council any longer.
Mr. Suettinger. Nor do I.
Mrs. Maloney. Do you have any ideas of how we should
improve their vetting process or do you think it needs to be
improved? I am talking to Mr. Suettinger.
Mr. Suettinger. Oh, I'm sorry. I would have no
recommendations on that score.
Mrs. Maloney. You have no recommendations.
I would like to ask Ms. Darby, when you worked at the
National Security Council, could you describe your duties and
exactly what you did there?
Ms. Darby. Sure. I handled Nancy Soderberg's schedule, at
least part of the time; would make sure that she had briefing
papers for her meetings. I generally did not prepare those.
Those were prepared by the professional staff members with the
policy expertise. I was not a policy adviser of any kind. I
would prioritize paperwork for her. I would help screen
requests from the staff who wanted her advice on something and
prioritize things for her.
I was also occasionally a liaison between other parts of
the White House with Nancy Soderberg and members of the
National Security Council staff, based primarily on the
connections I had made on my days on the campaign and on the
transition.
Mrs. Maloney. Did you serve as a contact person for White
House staff who needed to direct requests for guidance to the
National Security Council?
Ms. Darby. Sometimes. It was not an official responsibility
that I would say I had. But, more informally, I think that I
often became a conduit for those kinds of requests.
Mrs. Maloney. And when you received those requests, how did
you handle them?
Ms. Darby. I would staff them out to the relevant policy
office. In the National Security Council there are both
regional offices that handle, obviously, regions, and
functional offices that handle things like defense issues,
nonproliferation issues. And on the basis of the request that I
received, I would make a determination about which office
needed to handle that request and I would farm the request out
to that relevant office.
Mrs. Maloney. How often did the President's office ask for
guidance from the National Security Council with respect to a
visitor or a letter?
Ms. Darby. I really don't recall any specific--it is hard
to put a number on it. If I had to guess, I would say maybe
four to eight times a month.
Mrs. Maloney. Did you usually receive a request for
guidance before the event?
Ms. Darby. Yes. We generally did. I mean that was the
purpose of us providing guidance. Providing guidance after the
fact isn't exceedingly helpful, so.
Mrs. Maloney. And under what circumstance would a request
for guidance typically be made?
Ms. Darby. It's hard to say. I mean, for someone with a
foreign tie, who wanted to come in and see the President, and
it came through another office in the White House and they just
wanted to check with us to make sure that there was nothing
about the person's background that would lead us to have any
concerns about the President meeting with somebody, or other
senior people within the White House.
Mrs. Maloney. Mr. Suettinger saw no lasting damage to U.S.
foreign policy from giving Johnny Chung the photos. Why did you
consider that a negative recommendation?
Ms. Darby. I think his using the term hustler; the fact
that this person was probably going to exploit the photographs
for his own personal business interests. Again, it was really
my own personal recommendation to Kelly Crawford that if I were
in her situation, I wouldn't want this person continually
harassing me for photographs of himself with the President.
So better to err on the side of caution from my own
personal benefit, if I were Kelly Crawford.
Mrs. Maloney. In your own experience, was a request for
guidance about the release of a Presidential photograph one of
the most important matters confronting the National Security
Council in April 1995?
Ms. Darby. No, it certainly was not, and I didn't
independently recall this incident at all until I saw the text
of my e-mail published in the New York Times.
Mrs. Maloney. Well, getting back to your e-mail, you wrote
in your e-mail message that these people, referring to Johnny
Chung and his group, were major DNC contributors; is that
correct?
Ms. Darby. That's what I wrote, yes.
Mrs. Maloney. How did you know that? Did you have actual
knowledge that this fact was correct?
Ms. Darby. No, I did not. I have no idea who contributes to
the DNC. And I believe the only way I would have known this was
if Kelly Crawford conveyed it to me. If not in those specific
terms in more general terms that I took to mean that they were
DNC contributors.
Mrs. Maloney. Because of--so, in other words, she conveyed
that information?
Ms. Darby. I presume so. I don't have an independent
recollection, but the fact it is in the e-mail and I would have
no other way of knowing they were contributors or not.
Mr. Waxman. Mrs. Maloney, I wonder if I could yield to Mr.
Fattah in the time that we have allotted on this 5-minute
round.
But in doing so, I just want to make a comment so that no
one misunderstands. There are a lot of people who use photos
for their own promotional activities. Lobbyists do it all the
time. The reason people go to political fund-raisers is often
just so they can get a picture of the President, Senator Dole,
Newt Gingrich, and then they hustle it to see how far they can
go with it just to promote themselves.
Mr. Fattah.
Mr. Fattah. Thank you very much. Let me welcome you both
here today. It is interesting, as times change, I guess Ms.
Darby, you, unfortunately, have been consorting with known
Democratic sympathizers. The Congress at another point in its
history was interested in those who were sympathetic to the
causes of another political party.
And I want to focus in on this, the Communist Government of
China, because it is of interest to me, given the context of
our relationship since President Nixon opened up our
relationships with this country, there have been a succession
of Presidents who have moved, continued to move in that
direction. And of interest is this discussion about this
supposed arms dealer, Wang Jun.
Mr. Suettinger. Wang Jun.
Mr. Fattah. Of this CITIC.
Mr. Suettinger. CITIC.
Mr. Fattah. I want to enter into the record, Mr. Chairman,
a number of newspaper articles which I am going to refer to;
one from the Chicago Tribune, another from the Portland
Oregonian, and they outline, first of all, that George Bush had
dinner with this gentleman who we are now wanting to raise a
lot of concerns about him having a picture taken with President
Clinton.
In fact, he says that Henry Kissinger is a good friend of
his. There are a number of important political figures in our
country who are on the advisory council for this corporation,
like former Secretary of State George Shultz, former Secretary
of State Alexander Hague. There are a number of other people
who have close ties to the Republican party, like a gentleman
by the name of Mr. Greenberg, who is the head of AIG, who is a
well-known and very substantial contributor to the Republican
party, who is also on the board.
And I want to enter these into the record, because first
and foremost there was never a meeting--let me ask for
permission they be entered into the record.
Mr. Burton. Without objection.
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Mr. Fattah. Thank you. First and foremost, contrary to all
of these statements that the President had a meeting with these
people, there is nothing anywhere in the record to suggest that
there was a meeting. They were in the audience when there was a
radio address. They got a picture taken and they left.
The President then said to his closest aide that he had
some concerns about the appropriateness of their visit, which,
therefore, got the two of you involved in an after-the-fact
request as to whether or not the picture should be released.
But I do want to note, since there seems to be such an
interest in our interrelationships between the People's
Republic and particularly these group of businesspeople, that
if the committee is interested, maybe there are some other
people who we could call in and ask, because they seem to have
a lot of knowledge about how this corporation functions and
particularly this gentleman.
This is not something we dug up anywhere. These are
articles that appeared and are available. I know the committee
has a large staff, so I am sure that the majority has knowledge
of these contacts, even as it attempts to infer some
inappropriate behavior on behalf of the President, when
everything suggests to the contrary, as based on this record,
that this gentleman did nothing more than get his picture
taken. But he is someone who has had extensive contacts and
business relationships with major leaders in the majority's
party.
So I think that we would want to have a chance--he also
had, at this dinner, the former National Security Adviser;
Brent Scowcroft was also present, as reported in this Chicago
Tribune article that was dated March 23, 1997.
The other article from the Portland newspaper is dated
March 16. I want to ask you, because you are, to the best of my
knowledge, the first person that has appeared before us who
really has any knowledge about China to answer some questions
about this Nation's relationship, even though we continue to
talk about the government as if it is a government that we have
no ongoing relationship with.
Isn't it true that for the last few decades we have had the
policy--the foreign policy of our Nation has been to reach out
and to be involved in constructive engagement with the People's
Republic of China?
Mr. Suettinger. That is correct.
Mr. Fattah. And isn't it true that we allow free travel
between citizens of our country, particularly American
businessmen who, by the thousands, go to China, seeking and, in
many cases, winning business over there?
Mr. Suettinger. That also is correct.
Mr. Fattah. Because when the President of China came here
and he came to my district. He signed a contract with Boeing
for a few billion dollars. I didn't notice anybody in the
majority party jumping up and down about this relationship with
the Communist Government of China. They were clapping and being
pleased that there was going to be this business deal with the
Boeing Corp.
So the inference that is being drawn here, that any
association, anything having to do with the People's Republic
of China having to do with the Clinton White House is somehow
inappropriate, isn't that contrary to everything that has been
done since President Nixon went to China and President Ford
continued that relationship and President Carter, President
Reagan and President Bush? Didn't we continue to encourage, at
almost every level, interactions with the People's Republic of
China, their Government, their citizens and their various
institutions?
Mr. Suettinger. The policy of engagement with China has
been consistent over the last several administrations, sir.
Mr. Fattah. Can you help me then understand, even as the
Congress voted to continue most-favored-nation status, and it
is clear that these persons who were here and who got their
picture taken with the President--and as you have indicated,
you don't have any reason to believe that the person who
arranged this, Johnny Chung, was an agent of the Government in
any way, is it the practice of the People's Republic of China,
based on all of your studies and knowledge, that they would
attempt to, as part of their activities, interfere in the
internal political workings of the United States?
Mr. Suettinger. I don't really think I am in any way able
to answer that question in the way that you would like it to be
answered.
Mr. Fattah. Just answer it truthfully. That is fine with
me.
Mr. Suettinger. I am trying to be truthful, sir. It calls
for a judgment that involves information that is classified. It
calls for a judgment that requires study way beyond what I can
do.
Mr. Waxman. If the gentleman will yield, there were press
reports that there might have been Chinese intelligence people
or Government officials of some sort trying to look at how to
influence Congress. There was never any report, that I saw in
the press, that said they were trying to do something to
influence the Presidential elections.
Mr. Fattah. That is correct. But we won't press in
relationship to any classified information. Let's just deal
with what is obvious.
Johnny Chung has been accused of essentially trying to use
his relationship with important, powerful political figures to
make money. Do you think that there may be a few other thousand
people who come into this city who have relationships with
political figures who, from time to time, are then known to try
to make a buck?
Mr. Suettinger. I have to defer to others' judgment on
that, sir.
Mr. Fattah. I want to thank you for your testimony. I thank
the ranking member for yielding.
Mr. Burton. The gentleman's time has expired.
Mr. Barr.
Mr. Barr. During the time period that we are talking about
here, that is, during 1995, what security clearances did each
of you possess?
Ms. Darby. I had a Top Secret SCI clearance.
Mr. Barr. That means Top Secret Codeword?
Ms. Darby. Yes.
Mr. Barr. Mr. Suettinger.
Mr. Suettinger. I have full clearances, sir.
Mr. Barr. Top Secret Codeword?
Mr. Suettinger. Yes.
Mr. Barr. And that entitles you to see a fairly wide range
of classified materials maintained by our Government?
Mr. Suettinger. That is correct.
Ms. Darby. Yes.
Mr. Barr. Mr. Suettinger, would you please enumerate for me
the number of countries in the world whose national security
concerns and whose economic, political, diplomatic and military
interests coincide 100 percent with those of the United States
at all times?
Mr. Suettinger. Zero.
Mr. Barr. Could you please enumerate for me the number of
countries in the world that would have absolutely no interest
whatsoever at any time in making policies of this country more
favorable toward theirs?
Mr. Suettinger. I am not sure I understand your use of the
term making them ``more favorable.''
Mr. Barr. You can interpret it any way you like. What I am
trying--my point is, and I would presume you--and tell me if
you don't. My point is, and I presume you would agree with me,
that at some point in time every country with which we deal, or
virtually every other country in the world, at some point in
time has policy matters and interests that may differ from ours
and for which they would like to see our policies change and
become more favorable to what they would like to see and to
coincide with their interests. Would that be fair to say?
Mr. Suettinger. Yes, sir.
Mr. Barr. It is essentially the nature of politics, Hans
Morgenthau wrote about it two generations ago, and it is the
nature of national sovereignty.
In exhibit 198, if we could have that up again, please, you
posed the question, ``Who am I to complain?'' I think you are a
very appropriate person to complain, to be very honest with
you. You have a very substantial background and understanding
of foreign relations. You have access to very important
classified information of our Government that bears on the
highest levels of international security. You have people, such
as Ms. Brooke, who turn to you for guidance; and I think you
have a very clear responsibility to the President, whoever that
President is. And I know from your background also that your
interest in national security and in providing the unvarnished
information and advice to the administration, the President, is
not motivated by political concerns for one party or another;
is that correct?
Mr. Suettinger. That is correct.
Mr. Barr. Therefore, I think that the answer to your
question posed in that e-mail, ``Who am I to complain?'', I
think you are a very appropriate person to have complained.
It isn't so much that the other side indicates that all
sorts of people want to have their picture taken with the
President. We all know that. I apologize for your having to sit
there and hear them endlessly go on and on about that. We also
know that there are all sorts of people who try and get access
to the President, and a number of those succeed. That is not
the point here either.
My concern right at the moment does not really have
anything to do with Mr. Johnny Chung either. It has to do with
what seems to be a complete lack of process and lack of
safeguards in protecting the President. And I may disagree with
this President rather strenuously in a lot of areas, but I do
think, as the leader of this country, he needs to be protected.
He needs to have people like you complaining when it is
appropriate.
We have people who had gotten in to see the President,
apparently without any background check whatsoever. Apparently.
From Ms. Brooke's testimony earlier, we may provide a
slightly--we may provide a higher level of protection for
people improperly getting in to the President for our citizens
and foreign citizens, which strikes me as very, very odd.
My point is, you say that who are you to concern, and then
you go on to say, they seem to be bona fide Chinese officials.
How were you able to reach that conclusion? It is my
understanding that no checks were made on these people.
Mr. Suettinger. Well, let me say two things.
One, I had at my--in my office a handbook, unclassified
handbook of Chinese officials. I found some but not all of the
individuals on this list, as I explained before, in that book
and was able to verify that either through that resource or
from my own memory of the Chinese Government and its
organizations that the individuals, or the organizations that
they represented, were in fact bona fide organizations,
noncriminal, not intelligence-related so far as I could
determine. That is the basis of my judgment.
If I may just say that my question in there which you
referred to, the ``Who am I to complain?'' was entirely meant
in sarcasm.
Mr. Barr. Well, but then you didn't complain really. I
mean, I just think that the process that seems to have been in
place at that time really ill served the President where people
could get in to see him; and again, it is not a matter of
everybody likes to get in to see the President and then may be
doing something with those pictures.
These were officials of a Communist Government whose
national policy interests frequently don't coincide with ours,
and yet there seems to have been virtually no effort made.
This isn't necessarily your fault, Mr. Suettinger. I am
talking about the process that seems to have been in place at
that time, very similar to what Mr. Aldrich wrote about in
Unlimited Access, that I think raises some very serious
concerns. That is the reason that we are looking into this.
It is not trivial. I think it goes to the heart of national
security concerns of our country.
Mr. Burton. Mr. Cummings.
Mr. Cummings. I, too, want to thank you all for being here
today.
Mr. Suettinger, I just want to ask you, you said a little
bit earlier something that was very interesting. You said that
when you looked at these folks who took the pictures with the
President, you said--in answer to another question as to how
high-ranking they may have been with regard to the Government
of China, you said they were far below that. Those were your
words. In other words, far below the President.
Can you elaborate on that a little bit, please?
Mr. Suettinger. The power structure----
Mr. Cummings. Do you recall?
Mr. Suettinger. Yes, I do recall my answer.
The power structure in China is one that places the party
obviously at the peak of the government structure. Also there
is a separate but related structure of government, i.e.,
administrative offices, that take place. Since the beginning of
what is called the reform period of China, which is about 1980,
there has been an effort to split off and to sort of, the
proper term is not privatize, but at least separate the
operations of organizations such as business organizations or
even, in some cases, ministries from the direct control of the
party, because it was found that that was not a particularly
efficient way to do business. So some of these organizations
that were formally established--CITIC grew out of that kind of
a process, to allow enough leeway for these individuals and
organizations to make decisions that made sense in a business
context and separate them from a political context.
These individuals were--I would say the equivalent of
people perhaps at the deputy assistant secretary level would be
comparable here, or perhaps even, in some cases, below that.
They were not--they are not individuals who have significant
political power or influence within the Chinese Government.
They are people who are responsible for attracting business to
China and for making sure that China receives investment from
outside the country.
Mr. Cummings. I think Mr. Fattah was mentioning a little
bit earlier about when the President of China came here and how
a lot of people were--elected officials, and many of them in
this Congress--very happy to see him because he was bringing
business opportunities to the United States. And I think Mr.
Fattah mentioned Boeing in his district.
I wonder, is this something very unusual, in other words,
for foreign governments to want to try to do business with the
United States of America and its companies here? I am just
curious.
Mr. Suettinger. My sense is, it is not unusual at all.
Mr. Cummings. So I take it, when you went through the book,
that you said you had some kind of document, a book in your
office that basically gave you certain information about who
some of these people may have been. Did you--looking at that
book, did you get the impression that some of these folks were
business people?
Mr. Suettinger. Yes, in the particular context of China's
business operation.
Mr. Cummings. And so it didn't strike you as odd that maybe
these people, while going through Mr. Chung, this fellow who
you called ``The Hustler,'' were perhaps looking for some
possible business opportunities; is that correct?
Mr. Suettinger. That is correct.
Mr. Cummings. And now, was that a concern of yours, the
fact that maybe they may have been looking for some business
opportunities?
Mr. Suettinger. Not particularly a concern except insofar
as it was involving the President.
Mr. Cummings. Let me ask you this. You used the word
``hustler,'' and it is a really interesting word. And I take it
that you felt that this was someone who was trying to, I think,
make himself out to be--talking about Mr. Chung now--a lot more
than what he was; is that right?
Mr. Suettinger. I used the term in the pool hall sense,
sir.
Mr. Cummings. I don't know what you mean by that.
Mr. Suettinger. Somebody who may be doing something
different than what he appears to be doing at the outset and
may have a private agenda that is not immediately evident.
Mr. Cummings. So when you saw this, you wanted to make sure
that your opinion was stated; is that correct?
Mr. Suettinger. That is correct.
Mr. Cummings. And do you know whether anybody listened to
your opinion or acted on your opinion?
Mr. Suettinger. Ms. Darby suggested that she had.
Mr. Cummings. Ms. Darby, your job was basically to kind of
do some screening; is that correct? Is that part of your job?
Ms. Darby. Screening in terms of paperwork, yes.
Mr. Cummings. And so when you were dealing with this issue,
was there anything to cause you to feel that perhaps these were
some fellows that were just looking for some business
opportunities?
Ms. Darby. The impression I got from Bob's response to my
e-mail was that these were people who--or Johnny Chung, in
particular, might try to use the photograph to put up on his
wall to show that he had access to the White House and is
friends with the President. But that is something that a lot of
people do, and so only in that context.
Mr. Cummings. So you didn't--so what you just said, that
thought process that you just told us about, you didn't find
that to be anything unusual, in other words, that people would
want to try to use a picture of the President to make
themselves look good and perhaps have certain influence in
certain circles that they might not normally have; is that
correct?
Ms. Darby. That is correct, sir.
Mr. Cummings. Thank you very much.
Mr. Burton. The gentleman's time has expired.
Mr. Horn.
Mr. Horn. Thank you very much, Mr. Chairman. I am going to
pursue some questions that concern Harry Wu.
As I recall, Mr. Suettinger--and we have gone over this
memo of April 7, 1995 quite a bit--you had some suspicions
about Mr. Chung. I assume that you might recall that Irene Wu,
who is a staff member of Mr. Chung's firm, wrote a letter to
Betty Currie, who is the secretary to the President, saying,
``Please have President Clinton write me,'' this is write
Johnny Chung, ``a credential letter for my trip to China. I
have enclosed a letter dated October 3, 1994, which I cannot
use for this trip because it is for Taiwan. Thank you very much
for your help.''
Do you recall that you were consulted at all when the Wu
situation of Harry Wu came up in relation to Mr. Chung?
Mr. Suettinger. I was not.
Mr. Horn. You don't recall anything on that?
Did you ever see the fax I just mentioned, which is exhibit
204? And 205 is a letter. That could have well come with the
one from Irene that would give Mr. Chung a glowing letter when
he goes to China.
And if you look at 206, we have on stationery, Bill
Clinton, October 3, 1994, to Mr. Chung, signed Bill, ``Please
let me extend my appreciation to you for your participation in
my birthday celebration with your family on August 2nd. Your
outstanding support and dedication to this administration is
benefiting Americans across the Nation. I also want to express
to you how essential your role has been in helping to bridge
our countries' diverse communities. Your efforts to open lines
of communication between our administration and the Taiwanese-
American community are very much appreciated. Again, thank you
for your support, for a job well done.''
Then we get to 207 in the exhibit list, which is Johnny
Chung to Betty Currie, secretary to the President, reference
letter from the Democratic National Committee, thank you.
Now, here is the Democratic National Committee one: Dear--
Mr. Johnny Chung, Chairman, CEO, Automated Intelligence
Systems, so forth. ``Dear Johnny, thank you for stopping by my
office. I really enjoyed meeting your guests. You are to be
commended for your efforts to build a bridge between the people
of China and the United States. I want to express my
appreciation to you for being a friend and great supporter of
the Democratic National Committee. Good luck on your trip to
China. Keep me informed.''
Then we get to the White House memorandum of Janice
Enright, Office of Chief of Staff, Mr. Panetta, to Anthony
Lake, the National Security Advisor. That is exhibit No. 251,
dated July 24, 1995.
I received a telephone call this morning, says Janice
Enright, from Bobby Watson, Chief of Staff, Democratic National
Committee, concerning the release of Harry Wu. Apparently
Johnny Chung, a DNC trustee, is traveling with a group of
people to China, meeting with the President of China this week.
His mission is to negotiate the release of Harry Wu.
Now, was the National Security Council and you, as an agent
expert there and a China expert, were they ever consulted that
Johnny Chung was interested in a mission to China to help Harry
Wu?
[Exhibits 204, 205, 206, 207, 208, and 215 follow:]
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[GRAPHIC] [TIFF OMITTED] T5667.514
[GRAPHIC] [TIFF OMITTED] T5667.515
Mr. Suettinger. The ``they'' being? I am sorry.
Mr. Horn. Was the NSC staff----
Mr. Suettinger. No, it was not.
Mr. Horn. You don't recall this then.
Now, what it says here is, Mr. Watson wanted to alert us
that Mr. Chung plans to represent to the President of China
that he is sanctioned by President Clinton in his efforts to
get Mr. Wu released. He bases this representation on the fact
that he recently saw the President during his trip to
California, mentioned it to him, I believe, in a photo line,
what he was doing in this regard. Apparently the President was
supportive. To that extent, it is unclear, but nevertheless it
is being construed as a validation that he will be the
representative that way to the President of China.
Then we have a July 31, 1995, memorandum from you to
Anthony Lake. That is exhibit 252. And you say, re the
Democratic National Committee trustee, Johnny Chung, and the
Harry Wu case, this memorandum also covers a response to
package 5908 request for Presidential credentials letter for
Johnny Chung. Memo from Leon Panetta's office--and then you
give a tab A there on Chung--and his intent to try to get Harry
Wu released is very troubling, in part because I was not able
to contact the Democratic National Committee in time to get
them to discourage Chung from involving himself in this
diplomatically difficult, high-stakes issue.
Does that ring any memories----
Mr. Suettinger. Of course.
Mr. Horn [continuing]. With you at all?
How did you feel about that? Were you happy? Were you
displeased, et cetera?
Mr. Suettinger. I was quite concerned.
Mr. Horn. And what were your reasons for concern?
Mr. Suettinger. My reasons were, as I indicated before,
that I was concerned that an effort that had been ongoing since
Mr. Wu's arrest, to get him released in the quickest and most
appropriate way, might have been compromised or might have
confused the Chinese Government by the intervention of Mr.
Chung. And I thought that the DNC credentials letter was even
more than I would have liked him to have in terms of his own
travel to China.
Mr. Horn. Well, when they had that letter that just has
``Bill Clinton'' at the top of the stationery, was that ever
discussed by the staff of the NSC, that is October 3, 1994, and
that's just really, thanks; I assume that came out of the
Democratic National Committee, but I am not positive.
Mr. Suettinger. I don't know the origin of the document,
sir.
Mr. Horn. Really a political letter. Anyhow, you say here
in this July 31st memo, I believe Chung means well, something
of a self-appointed Ambassador of goodwill.
Now, what did Mr. Lake do about that?
Mr. Burton. The gentleman's time has expired. We will let
him answer the question.
Mr. Suettinger. Mr. Lake called me later on in the evening
after he received that package, that memorandum from the--and
asked if it was my view that we should try to contact either
Mr. Chung or the United States Embassy in Beijing to try and
forestall or prevent Mr. Chung from engaging in any efforts on
that supposed mission.
I replied that I didn't know where he was, I didn't know
when he was going to arrive. I indicated that I doubted that he
would see the President of China, and that it would be very
difficult and might even further complicate efforts if we made
strong efforts to try and prevent him from seeing anybody. So I
thought there was probably little we could do.
Mr. Horn. I thank you. We might pursue some more of this
later, Mr. Chairman.
Mr. Burton. Mr. Kanjorski.
Mr. Kanjorski. Thank you very much, Mr. Chairman.
I just listened, Mr. Suettinger, to your comments. And it
strikes me that you seem to be a man who believes in doing
everything through the normal order of things. There is a book
of procedure and you follow the process; is that correct?
Mr. Suettinger. I try to be.
Mr. Kanjorski. Have you dealt in political life as a
nonprofessional? What did you do before you were at the NSC?
Mr. Suettinger. Before I went to the NSC, I worked at the
National Intelligence Council, and prior to that, the Central
Intelligence Agency.
Mr. Kanjorski. But you haven't really been in politics,
have you?
Mr. Suettinger. No, sir.
Mr. Kanjorski. Would you be surprised to know that Members
of Congress occasionally will arrange visits, private visits
with heads of state from around the world through their own
communications without having any contact through the State
Department or the embassy in the area or anybody but private-
sector individuals?
Mr. Suettinger. I am aware that that has happened.
Mr. Kanjorski. Why would you assume that an American of
Taiwanese ancestry, doing business and having quite a
promotion--I am impressed with Mr. Chung's promotion--may not
just convince some high-ranking officials and political
operatives in China that if this would affect business in some
way, this is something that should be handled?
Why would you conclude that that would not be strong or a
possibility?
Mr. Suettinger. I am not sure I understand the thrust of
your question, sir.
Mr. Kanjorski. Well, I know that some members of the
committee are shocked and think that it is impossible, what Mr.
Chung may have done or could have done to have an impact. But I
have seen that type of impact occur between private individuals
and political individuals of other countries in dealing with
very touchy questions. I could give you a perfect example
myself.
Mr. Suettinger. Are you speaking of the Harry Wu case?
Mr. Kanjorski. Yes, I am talking of the Harry Wu case.
It wouldn't seem unreasonable to me that if a well-
connected, active American-Chinese businessman sat down with
someone in the hierarchy of the Chinese Government or the
business community and said you are really making it very
difficult for us to try and develop business relationships here
because you have this political prisoner and the people in the
bureaucracy don't seem to be paying attention or sensitive to
the problem; and I am telling you as a businessman that this
is--we don't know what your political problems are, but as a
businessman, you are causing us a disconnect here.
Wouldn't that be a reasonable thing to happen?
Mr. Suettinger. Certainly there are circumstances in which
that might be true.
My concern in this particular case was, one, that Mr. Chung
seemed to have indicated that he was going to represent himself
as somebody on a mission from the President, which was
certainly not the case. It was also the case that Mr. Chung did
not know what the administration had been doing to try to gain
Mr. Wu's release, and his idea of what was appropriate might
not be at all consistent with ours.
Mr. Kanjorski. What if in fact he wasn't trying to really
represent himself as an emissary from the President, but merely
that he knew the President, or was a friend of President,
quote, ``friend of the President''? Would you still try to stop
him, or do you think he would have no impact?
Let me give you an example. I referred to it earlier. Right
after the Polish situation I was on a CODEL, an official
congressional trip to Eastern Europe. The Members of that CODEL
wanted to have an opportunity to meet with the political
leadership, the head of Solidarity, Lech Walesa. At that time
he was an unofficial, unelected individual in Poland and
attempting to consolidate political influence. And regardless
of how they tried, they couldn't get an audience with him.
I happened to know a friend. There was a businessman who
has since become an American citizen, and he knew Lech Walesa,
or anyway he purported to know him to me. And so since I was
going to be over there, I said, I would like to try and have a
meeting with him. This is the same individual who said, look,
if you ever go to Rome, I would like to take you to meet the
Pope. I didn't go to Rome and I didn't think I would get in to
see the Pope that easily.
But I happened to call this fellow just by chance, and I
said, look, I am going to be in Europe and let's break away
from this trip for a day. I would like to fly up to Gdansk and
have a meeting.
He called me back in 25 minutes and he said, you arrive at
the airport, the car will pick you up, they will take you to
Solidarity headquarters, and the leader will be at your
disposal for any number of hours. You can select a group of
four people, which I did, another Member of Congress and
myself. We flew into Gdansk and we spent a very enlightened 4
hours with Lech Walesa.
The Ambassador to Poland couldn't get us there. The State
Department, Secretary of State, couldn't get us there, and no
one in the Congress of the United States could get us there.
Now, that is a personal experience I have had. I told the
story about the Pope--since that time, many of my friends have
taken up this friend and, by golly, they do go and spend time
with the Pope.
So people in private life do sometimes have connections or
appearances of being able to still the waters. There is a
sequence here that you can say is coincidental, could be a
seizure of opportunity, someone trying to get in on a good
thing, taking advantage, because we are dealing with someone
here that, quote, is ``a promoter,'' but there is also an
outside possibility that the Chinese Government and Chinese
business community would take more stock in something a
Chinese-American businessman would be telling them than all
officialdom, who they are dealing with on a regular basis and
may not be impressed with.
Haven't you had those experiences down there?
Mr. Suettinger. I readily concede the point that unofficial
and informal communications can sometimes have a very
beneficial effect on the development of relations. In this
particular instance, I was not persuaded that Mr. Chung was
operating on the same wavelength as the rest of us, that he
fully understood the complexity and nuance of American policy
or that, indeed, he had been given such a mission by the
President. And so I thought it was appropriate for me to raise
a warning flag for Mr. Lake, and that is what I did.
Mr. Burton. The time of the gentleman has expired.
Mr. Kanjorski. Thank you, Mr. Chairman.
Mr. Burton. Mr. McHugh.
Mr. McHugh. Thank you, Mr. Chairman.
I just wanted to followup on a couple of comments you made
earlier. In response to some of the questions, you said that
you did not know that Johnny Chung was an agent of the
Communist Government, true? Both of you, I believe, said that.
Mr. Suettinger. I have no basis on which to make such a
judgment.
Mr. McHugh. Ms. Darby, you said that as well. Do you have
any basis on which to say he is not an agent?
Mr. Suettinger. Similarly, no.
Ms. Darby. Nothing.
Mr. McHugh. Mr. Suettinger, you defined a ``hustler,'' I
think, very appropriately, someone who has an agenda that may
not be readily apparent. Did I hear you correctly?
Mr. Suettinger. Yes, sir.
Mr. McHugh. Did you have an opportunity or cause to
speculate as to what Mr. Chung's hidden agenda might be?
Mr. Suettinger. I did not have any specific indications of
his agenda other than, as I outlined it in the e-mail, which
was based on an earlier conversation.
Mr. McHugh. In that e-mail, you made the comment that you
felt that the President might not wish to be associated with
some of these business undertakings; do you recall that
statement?
Mr. Suettinger. Yes, I do.
Mr. McHugh. What speculation were you assessing there? How
did you come to that judgment and what kinds of business
undertakings were you concerned might not be appropriate for
the President to be associated with?
Mr. Suettinger. It was really a generic kind of comment on
my part. As I indicated earlier in the e-mail, I was concerned
that Mr. Chung would do this repeatedly and would bring a
series, a sequence of individuals in to see the President. And
I certainly had no confidence that we would be able to verify
that all of them were bona fide officials or engaged in
legitimate business operations.
I was just concerned with protecting the President from
future problems that might exist because of the association
with Mr. Chung.
Mr. McHugh. So you were concerned where the situation might
lead rather than where you could definitively say it was at
that moment?
Mr. Suettinger. That is correct.
Mr. McHugh. OK. Earlier you talked about the recent
separation in mainland China, the PRC, between the structure of
the political party and the business side of the society,
trying to provide the business undertakings with a certain
freedom from the political apparatus; is that correct?
Mr. Suettinger. Yes.
Mr. McHugh. Is my understanding correct, however, that
ultimately it all does come back to the party, that indeed any
indigenous Chinese business undertaking not only is concerned
but ultimately responsible to the political structure?
Mr. Suettinger. I think, as a general statement, yes, that
is correct.
Mr. McHugh. Thank you.
Ms. Darby, how long were you at NSC?
Ms. Darby. From February 1993 until August 1995.
Mr. McHugh. During your time there, how many opportunities
did you have to do a vet such as this, where you were asked to
look over a particular--appropriate individuals and make a
recommendation as to whether or not the President should be
associated in this instance with the pictures?
Ms. Darby. This situation, I don't recall ever having a
similar counterpart during my tenure at the NSC. Again, this
was an after-the-fact request for guidance and the standard
practice was that we were consulted prior to any events like
this taking place. As I said earlier, my contacts with the
President's office where senior White House staff would have
been maybe four to eight times a month maybe. It is really hard
to say. It varied a lot.
Mr. McHugh. Were your recommendations generally accepted?
Ms. Darby. I wouldn't say in particular that they were my
recommendations. I was not a policy specialist at the NSC. I
relied on the guidance of the policy staff of the NSC, and if
something required a real policy decision, I would refer it to
Nancy Soderberg or another senior person on the staff.
Mr. McHugh. You made a recommendation in this case?
Ms. Darby. It was more of a personal recommendation rather
than--there were no real foreign policy concerns that I could
see. Johnny Chung did not appear, from Bob Suettinger's e-mail,
to pose a national security risk, so it really wasn't so much a
question of whether, for foreign policy reasons, they should
not be delivered.
Mr. McHugh. Was this the first time you had to make a
personal recommendation during your time there?
Ms. Darby. I really don't recall.
Mr. McHugh. Do you have any observations about this case
where your personal recommendation was not apparently observed?
Ms. Darby. About this case?
Mr. McHugh. Yes.
Ms. Darby. I do not know what the disposition of the photos
was, so I really couldn't comment.
Mr. McHugh. I see.
I have a very brief amount of time left. Mr. Suettinger,
let me return to you very briefly. There seems to be a lot of
concern about the situation where people you described as free-
lancers go out and undertake certain missions unto themselves.
I think we would all agree that that does happen very
frequently, whether they are officials of Government or whether
they are private business people. But I believe I am hearing
you say, at least from your perspective, this one was of
particular concern and somewhat unusual in that it was a
national political party providing a letter of introduction or
at least some form of credential.
Did I hear you correctly, listing that as an unusual
concern on your part?
Mr. Suettinger. I was concerned that there was a credential
in the form of a letter from the DNC.
Mr. McHugh. I see my time has expired. Thank you, Mr.
Chairman.
Mr. Burton. Mr. Fattah.
Mr. Fattah. Mr. Chairman, I think we have exhausted our 5
minutes on the first round. You still have a Member who has not
yet used their first round.
Mr. Burton. You also have 5 minutes, even though you spoke
during the 30 minute round.
Mr. Fattah. Thank you, Mr. Chairman, if you insist.
Let me proceed forward on this. I do want to say that,
notwithstanding our legitimate interactions, I think that--
there is one issue that I think that we could share in and that
is that this committee, even though it has spent a few million
dollars in the beginning of its investigation, we have a number
of intelligence agencies and law enforcement agencies that have
multibillion dollar budgets. And if there is information that
the FBI or the CIA or the National Security Agency or anyone
has that could be useful to the purposes that the chairman has
outlined in terms of trying to filter out whether or not there
was foreign--illegal foreign activities vis-a-vis our election,
that information should be brought forward.
Plus it might help us that if, with all of their ability,
they haven't found anything, then maybe we could put this to
rest sooner rather than later. So either way, it may be of some
use.
I do want to get to the point that was raised, and that is
that under questioning from the gentleman from Georgia, he got
you to admit that at all times there are foreign governments
who from time to time might have or may want us to have a
different viewpoint about a certain matter; and they have very
legitimate and appropriate ways in which they can communicate
their viewpoints to our Government.
I guess the question really is, under this investigation,
we are trying to determine, since there have been allegations
made that the Chinese Government wanted to influence Members of
Congress, they were concerned about these votes on the most-
favored-nation, or whatever the case may be, or their
relationships generally with the Congress that they wanted to
have an impact.
In terms of this matter with the photos and with Johnny
Chung, is there any information that somehow this had something
to do with the People's Republic of China, either legally or
illegally or inappropriately trying to influence the Congress
of the United States?
Mr. Suettinger. With all due respect, Congressman, your
question takes me somewhat beyond the scope of what I have been
asked to testify about.
The simple answer to your last question is, I have no way
of knowing.
Mr. Fattah. OK. Well, I have no way of knowing either,
because we are really hung up on the fact that these gentlemen
got into this radio address and that they got in through Johnny
Chung's entre, through the DNC, and that they got a picture
taken.
And then there is a lot of question what happened to the
picture--whether they got the picture, whether they didn't--and
we have been going back over this for at least 2 days now. We
are not even clear whether or not the pictures were ever
released to the gentlemen involved. But it doesn't seem to me
to have anything to do with the central question of our
investigation.
So I realize that you may be at a loss, but I am also at a
loss. It may be useful, I guess, to just run through it one
more time.
You had nothing to do, Ms. Darby, with approving these
gentlemen to go into the radio address?
Ms. Darby. No, I did not.
Mr. Fattah. You were not present at the radio address?
Ms. Darby. No, I was not.
Mr. Fattah. Your only responsibility in this matter was
that you were asked by Ms. Crawford whether or not since the
President had raised a concern whether or not these photos
should actually be released, and you said, look, we have a lot
of other important things to do around here. Why don't you err
on the side of caution and not release the photos? And you sent
a memo that said, look, you don't see any lasting harm in the
photos being released and neither one of you have any idea what
the actual disposition of the photos is at this time; is that
correct?
Mr. Suettinger. That is correct.
Ms. Darby. That's correct.
Mr. Fattah. I want to thank you for your presence here
today. I want to thank the chairman for yielding me our due 5
minutes. We will not even use it all. We yield it back.
Mr. Burton. Thank you, Mr. Fattah.
Mr. Souder.
Mr. Souder. Yesterday in the testimony we heard from Nancy
Hernreich that apparently at least one of the photos was
released. Does that bother you, Ms. Darby?
Ms. Darby. I was not aware that there was more than one
photo. It doesn't bother me. As I say, I don't think there were
foreign policy implications that Bob made me aware of in this
e-mail about the photos being released.
Mr. Souder. Is it typical that when you would express
caution and suggest that it might not be wise to release them
that the White House would release them anyway?
Ms. Darby. I really have no idea. I didn't usually, I
didn't get followup information on whether they took my advice
or not, but again generally it was not my advice as an NSC
foreign policy specialist.
Mr. Souder. Well, it was certainly Mr. Suettinger's e-mail,
as well, expressing concerns. Do you know very many other times
that you may have expressed concerns regarding certain photos
at the White House?
Ms. Darby. I don't recall any other specific incident, sir.
Mr. Souder. So this may be in-fact the only case where you
expressed concern to the White House about a photo and they
didn't listen?
Ms. Darby. I am not sure that they didn't listen.
Mr. Souder. If indeed the testimony yesterday was accurate
that at least one photo has been released, then they didn't
follow your caution at least. Would that not be a fair
statement?
Ms. Darby. Again, it was my personal caution. It was not
based on any foreign policy implications I saw in turning the
photograph over.
Mr. Souder. I wanted to ask you one other question as well.
Clearly, there was a kind of a flurry of activity here around
April 7 because Mr. Chung was coming in. Had they requested
this earlier, an opinion from your office? Was it sitting on a
desk among other requests, or why was this almost a month
later?
Ms. Darby. I am not aware of any other request relating to
this other than the one that we have been discussing and is
reflected in this e-mail. But I think the sense of urgency was
probably because the photographs take several weeks to be
developed and they probably had just been developed and Johnny
Chung was coming in the following day to pick them up.
Mr. Souder. So you are saying it isn't correct that the
White House contacted you right after the photo to do a
background check about releasing it? There was certainly the
implication under testimony here that there was an immediate
contact to your office rather than a delay of almost a month.
Ms. Darby. There wasn't a contact that I am aware of, no.
Mr. Souder. Thank you.
Mr. Suettinger, I think your e-mail was, which is exhibit
198, was very informative. In other words, you said you didn't
have any direct evidence, but you expressed future concerns,
which I would hope that any White House would take seriously,
coming from the National Security Council.
One of the statements that you made to Mr. McHugh is that
while you didn't have any evidence that these people were
agents, you didn't have any evidence that necessarily they
weren't. I heard you say earlier, too, that you felt they were
relatively low level or less powerful. Wouldn't it be true that
if somebody wanted to try to start to influence a system that
in fact if they would have sent more powerful people or people
who had more of a history that, in fact, you would have caught
them, and wouldn't that argue not that they are but that this
is one way you could do it? In other words, it would have
flagged your system, had they been higher up. Why would that
argument not be a concern as well?
Mr. Suettinger. I am really not in a position to speculate
about whether there was a conspiracy afoot in this case to
utilize a photo opportunity toward broader purposes. My
understanding is, I answered the e-mail, was that there was no
national security concern with regard to the individuals
involved and that remains my view.
Mr. Souder. My point, however, is that had they had a
record or been more influential, you might have said
definitely, no, to the photos?
Mr. Suettinger. I was not in a position--I see, I am sorry.
I misunderstood you. It is very difficult for me to speculate
on what might have taken place had circumstances been
different. I responded to the circumstances as I understood
them at the time.
Mr. Souder. Isn't that what your e-mail does? It is
speculation. You say that there could be other individuals,
there may be times, would be ones the President would support.
You were concerned about how this could not only go long-term
with Johnny Chung, but how this process could be misused.
Mr. Suettinger. My concern was really in making sure that
the President was protected more from kind of perhaps shady
business deals than from an effort to influence his opinion in
any way, shape or form.
Mr. Souder. Don't you think that when they contacted your
office they were concerned about national security things, not
just whether or not they were----
Mr. Suettinger. You mean when Mr. Chung contacted my
office?
Mr. Souder. When the White House asked about using these
pictures, do you think they were asking you whether or not
you--they wanted your advice on how business deals were going,
or do you think they were asking your advice on national
security matters?
Mr. Suettinger. I really can't speculate on what prompted
them to raise the concern or in what context. I responded to
the question again, as I indicated earlier, from a national
security perspective. But in my comments vis-a-vis Mr. Chung, I
was really thinking more of repeat performances that might have
a different cast of characters.
Mr. Souder. Do you get questions about businessmen on a
routine basis on most of the requests that come to you related
to national security?
Mr. Suettinger. There have not been that many. You are
referring to requests for vetting?
Mr. Souder. Yes.
Mr. Suettinger. Most of them involve individuals who are
not known to be Government officials. In other words, they
would be more businessmen and private individuals, academics
and so forth.
Mr. Souder. But you are vetting for national security, not
for hustling?
Mr. Suettinger. That is correct.
Mr. Souder. Because, and it is not--it is hard to be in the
position of not wanting to question an individual's integrity,
yet based on what we saw this morning that, in fact, we do have
agents of influence trying to influence things and that some of
that information was withheld. We need to be as aggressive as
possible in asking some of these questions and laying this out
as this hearing goes through.
I yield back.
Mr. Burton. The time of the gentleman has expired. Mr.
Waxman is the next.
Mr. Fattah. If the gentleman will yield, I just wanted to
correct the record. I think the gentleman mistakenly misspoke
in that the testimony yesterday from Mrs. Hernreich was not
that the photos had been released. In fact, her testimony
several times yesterday was that she was not at all, it was not
at all her belief that the photos were ever released. She did
not even acknowledge that they had been released. I just wanted
to correct the record as to whether or not these photos were
ever released and we are going to continue to search for the
truth in this regard.
Mr. Souder. My understanding was one photo. If I said
photos, it was a mistake. One photo.
Mr. Waxman. Reclaiming my time, just also for the record,
the only thing that we had in the newspaper today was that the
FBI didn't give some information to this committee, and I think
it is a big leap from that to say that we learned about spying
because we didn't learn about that. We may, but no one knows
that at this point. So we don't know whether the photos were
ever released. We do know Mr. Suettinger was asked whether they
should be released and he said he didn't think any lasting
damage would be done to U.S. foreign policy if they were
released to Johnny Chung. I want to yield the balance of my
time to Mr. Cummings.
Mr. Cummings. Thank you very much, Mr. Waxman.
First of all, let me take a moment. This hearing, I think,
will be winding down very shortly, but I want to thank you both
for your service to the United States of America. I know that
this is not the most pleasant situation for you. But I think
you symbolize the very best that America has to offer. I do
mean that. It was just, someone just said a few minutes ago,
Mr. Suettinger, that you were a person, I think it was Mr.
Kanjorski who said that you were a person that went by the
books. And I think the same thing can be said of you, Ms.
Darby. I just want to thank you on behalf of all of us. I am
sorry that you have to go through this, but this is, I guess, a
part of the process.
Mr. Suettinger, I want to also say to you that I really
admire you for your ability to kind of figure out who is a
hustler and who is not. It is interesting that Mr. Chung is an
equal opportunity hustler. Because he has a book, I don't know
if you have seen this document. But it is automated, it is
called Automated Intelligence Systems, Inc. I think this was
his corporation. Have you seen this? It is a brochure.
Mr. Suettinger. I have not, sir.
Mr. Cummings. I think your worst fears about what a hustler
does is epitomized in this document because he not only has
pictures of him, it is full of pictures, by the way, and he not
only has pictures of him and the President, but he has a
picture of him and our illustrious Speaker of the House, Newt
Gingrich. He has a picture of him and the Governor of
California, Pete Wilson. He has a picture here of he and the
majority leader, former majority leader and former Presidential
Republican Candidate Bob Dole. So he really made sure that he
did exactly--and I admire you for figuring this out, that this
guy was a hustler, equal opportunity. It is very interesting.
I also want to note something else. I was wondering,
exhibit 215, are you familiar with this? This is a document
which is apparently from, it is dated November 22, 1995. It is
apparently to a Lori Weiner from a Kathleen Hennessey. I take
it that this is from the photography shop in the White House.
Are you familiar with that document?
Mr. Suettinger. I have not seen this document before, sir.
Mr. Cummings. Let me just read it. It says, ``as of 11/22/
95, per Bob McNeely,'' do you know who that is?
Mr. Suettinger. I do not.
Mr. Cummings. ``We will not honor requests from Johnny
Chung. He has been CEO of this corporation. He has been
improperly using the photo of the business people and the
President. Bob suggests telling him the photos were ordered and
sent out and cannot be reordered. He has been asking through
the west wing office, but he might find our office at some
point. Thanks, Kathleen.''
So again, I go back to your fears and your concerns. It
appears that the photo office in the White House, again, later
on, found a way to kind of block this hustler that you talked
about. Yesterday it was brought up, I don't know whether you
reviewed the testimony yesterday on C-SPAN, but it is also
interesting to go back to this whole question of the equal
opportunity hustler.
In a letter dated April 6, 1994, but from all people, the
Governor of the State of California, Pete Wilson. I just want
to reiterate it so that the record will be clear that he not
only was trying to pimp the President, but he was trying to
also do the same thing with Mr. Wilson, Governor Wilson. I just
want this, again, to be reiterated.
It is addressed to Mr. Chung. It says,
Dear Mr. Chung: It is my understanding that you have been
nominated as entrepreneur of the year. Congratulations. It is a
well-deserved recognition. My communications and press offices
inform me that you and your team have performed in an
outstanding manner. Your good work in turn has enabled my
office to serve the people of California effectively and
efficiently, especially during California's recent disasters.
Again, you have my appreciation for a job well done.
And that is signed by the Governor of the great State of
California, Pete Wilson. So again, I know that it may sound
like there was a little bit of sarcasm, but I do admire both of
you for what you have done. I thank you for being the good
employees that you have been for the United States of America
and, again, on behalf of all of us, I thank you for your
testimony today. I yield back to the ranking member.
Mr. Waxman. I yield back the balance of my time.
Mr. Burton. The gentleman yields back the balance of his
time. I have the last 5 minutes and I will yield my time to Mr.
Barr.
Mr. Barr. Thank you, Mr. Chairman. There is a major
difference, just for the record, between what was just stated
with regard to the Governor, former Governor, whatever, of
California. He was not the recipient of $3 or $400,000 in Mr.
Chung's largess. That makes a big difference.
Going back to SINOPEC, this is not a small corporation, is
it, Mr. Suettinger? Is it not the fourth largest petrochemical
company in the world?
Mr. Suettinger. If that is information that you have
derived from other sources, I have no means--I mean it is a
large--it is a large state entity.
Mr. Barr. Commercial entity, dealing in the billions of
dollars? Dealing in the billions of dollars?
Mr. Suettinger. I would assume so. The oil business does
make lots of money.
Mr. Barr. You can assume that since particularly in October
1997 SINOPEC announced an agreement with Exxon and ARAMCO for a
joint feasibility study for a refinery and petrochemical
complex in east China's coastal Province of Fukien, which will
involve a total investment of $3 billion. So somewhere along
the line SINOPEC has done real well.
SINOPEC was, as you all may or may not know, the
corporation that wanted the meeting with Energy Secretary
O'Leary at which time Mr. Chung was directed to contribute
$25,000 so that that meeting could take place, that $25,000 was
given to Africare, Ms. O'Leary's favorite charity, at her
direction, picked up by an employee of the Energy Department.
So there is a lot more at stake here than just a two bit
hustler and a few photographs. There are billions of dollars at
stake here and the national security interests of at least two
of the major powers of the world, the United States and China,
and also Saudi Arabia. That was also part of what SINOPEC was
after.
So it still leads me to scratch my head and figure out why
no red lights went off. I know that the e-mails we have been
talking about here postdate by a month the meeting at the White
House, but we now know that there was an awful lot that took
place subsequent to that such as the payment at the direction
of Ms. O'Leary, a number of other efforts by SINOPEC and by Mr.
Chung involving perhaps Ron Brown and others, according to
letters that are in exhibits here. And I would ask Mr.
Suettinger, if you had before you all of the information that
we now have and if you had this information not on April 7,
1995, but on March 7, 1995, would the attitude have been the
same in responding to Ms. Darby's e-mail.
Mr. Suettinger. With all due respect, Congressman, you are
asking me again to speculate on what I would do in different
circumstances. It is very difficult for me to do that,
certainly, given the way the information has been, the way that
you have characterized the information.
Mr. Barr. You can characterize it anyway you would like.
All I am saying is, is there anything that you have become
aware of or just based on your review of who these gentlemen
were, do you still believe them to be essentially two bit
players that have no real interest beyond just getting a
picture with the President that would cause you to have given a
different recommendation if you had had that information before
you on March 7? Yes, I am asking you to speculate.
Mr. Suettinger. Again, my remarks at the time were based
upon my understanding of what constitutes a photo opportunity:
a handshake, a friendly word and then head for the door. So it
is not my belief that there was anything politically
significant likely to transpire during the period of a photo
opportunity. So even had I been asked in advance, I don't think
I would have changed my view.
Mr. Barr. Then I take back some of the nice things I said
earlier. I think that your work and your statements indicate
that there is not an effort to really serve the national
interest of this country well. You understand even in your e-
mail that there was a political effort here by contributors to
seek access to the President. We know now that some of those
contributors were, wanted things involving billions of dollars
from this country that would benefit the Communist Chinese
Government at a minimum in a major economic way, and you are
still saying that that would not cause you to recommend that
they not have access to the President. I must admit, I am just
flabbergasted. I yield back.
Mr. Suettinger. I would certainly----
Mr. Fattah. Mr. Chairman, would you yield some of your
available time?
Mr. Burton. Mr. Horn needs some time. I will yield to Mr.
Horn. If I have any left of course, I will yield to you.
Mr. Horn. Thank you, Mr. Chairman. Just one question
because I am curious as to the relationship with Mr. Chung that
crossed your desk before the April 7th memorandum in which you
say, having recently counseled a young intern from the First
Lady's office who had been offered a dream job by Johnny Chung,
I think he should be treated with a pinch of suspicion.
Now, we read into the record earlier the memorandum you
wrote to the President's National Security Advisor, Anthony
Lake, on July 31, 1995. I am curious what came before April 7
that you remember, what came after July 31, 1995, that involved
Mr. Chung that you remember? Is this all that you were involved
in? Obviously, you counseled this intern before April 7. That
helped lead you to a conclusion about Mr. Chung. What happened,
anything else before April 7? Anything else after July 31st?
Anything in between?
Mr. Suettinger. As I indicated, I had some phone calls from
Mr. Chung that caused me to be concerned about his own agenda.
Again, I can't--I did not put them on the record at the time
and they are not available either to my recollection or to any
other record.
The meeting with the intern from the First Lady's office is
likewise not on record. She called me in the morning, said that
somebody had suggested she come to talk to me, and I did so.
She described a position that she was being offered by Mr.
Chung that caused me some concern, that appeared she was going
to be hired as someone whose principal responsibilities would
be to provide some sort of escort for some of these individuals
coming into town, and that her service, at that point, former
service, with the First Lady's office would also be used as an
entre to get some of these individuals to see people in the
First Lady's office.
I found that to be something that aroused my suspicion. She
was about my daughter's age and so I counseled her that the
jobs that seem to be too good to be true usually are not true,
and that she ought to find out as much information as she could
about what was being offered and what was going to be expected
of her before she accepted any kind of a dream job. As I say,
that sort of colored my perception of what Mr. Chung was up to,
to a significant degree. And after July 31st, according to your
question, I have had no contact with anything to do with Mr.
Chung, other than what I have been able to read in the
newspapers.
Mr. Horn. Thank you very much.
Mr. Burton. All time has expired. I want to thank both of
you for being with us today. We appreciate your candor, and
hopefully we won't have to bother you again, but if we do, we
will try to make sure we accommodate your schedules.
Per our agreement with the minority, I ask unanimous
consent that the depositions of Ari Swiller, Dick Morris, and
Eric Sildon be made public. Without objection, so ordered.
The continuation of the meeting with Johnny Chung will be
in the lounge of the committee, so those who want to attend and
participate in that discussion will go there immediately upon
adjournment. This committee stands adjourned.
[Whereupon, at 2:29 p.m., the committee was adjourned.]
[The depositions of Ari Swiller, Dick Morris, and Eric
Sildon follow:]
Executive Session
Committee on Government Reform and Oversight,
U.S. House of Representatives,
Washington, DC.
DEPOSITION OF: JACOB ARIEH SWILLER
Friday, August 22, 1997
The deposition in the above matter was held in Room 2203, Rayburn
House Office Building, commencing at 10:00 a.m..
Appearances:
Staff Present for the Government Reform and Oversight Committee:
James C. Wilson, Senior Investigative Counsel; Miki White,
Investigative Counsel; Christopher Lu, Minority Counsel; and Michael J.
Yeager, Minority Counsel.
For MR. SWILLER:
STUART F. PIERSON, ESQ.
Levine Pierson Sullivan & Koch, L.L.P.
1155 Connecticut Avenue, N.W., Suite 700
Washington, D.C. 20036
Mr. Wilson. Good morning. On behalf of the members of the Committee
on Government Reform and Oversight, I appreciate and thank you for
appearing here today.
This proceeding is known as a deposition. The person transcribing
this proceeding is a House reporter and notary public. I will now
request that the reporter place you under oath.
THEREUPON, JACOB ARIEH SWILLER, a witness, was called for examination
by Counsel, and after having been first duly sworn, was examined and
testified as follows:
Mr. Wilson. I would like to note for the record those who are
present at the beginning of this deposition. My name is James Wilson.
I'm the designated Majority counsel for the committee. I'm accompanied
today by Mickey White, who is also with the Majority staff. Mr.----
Mr. Lu. Lu.
Mr. Wilson. Christopher Lu and Michael Yeager are with the Minority
staff. And Mr. Ari Swiller is accompanied by Mr. Stewart Pierson.
Although this proceeding is being held in a somewhat informal
atmosphere, because you have been placed under oath, your testimony
here today has the same force and effect as if you were testifying
before the committee or in a courtroom. If I ask you about
conversations you have had in the past and you're unable to recall the
exact words used in the conversation, you may state that you are unable
to recall those exact words and then you may give me the gist or
substance of any such conversation to the best of your recollection.
If you recall only part of a conversation or only part of an event,
please give me your best recollection of that conversation or that
event or the parts of the event or conversation that you do recall.
If I ask you whether you have any information about a particular
subject and if you have overheard other persons conversing with each
other regarding that subject or have seen correspondence or
documentation regarding that subject, please tell me that you do have
such information and indicate the source, either a conversation,
documentation or otherwise from which you derive such knowledge.
Before we begin questioning, I would like to give you some
background about the investigation and your appearance here. Pursuant
to its authority under House rules 10 and 11 of the House of
Representatives, the committee is engaged in a wide-ranging review of
possible political fund-raising improprieties and possible violations
of law.
Pages 2 through 4 of House Report 105-139, summarizes the
investigation as of June 19, 1997, and encompasses any new matters
which arise directly or indirectly in the course of the investigation.
Also, pages 4 through 11 of the report explain the background of the
investigation.
All questions related either directly or indirectly to those issues
or questions which have the tendency to make the existence of any
pertinent fact more or less probable than it would be without such
evidence are proper.
The committee has been granted specific authorization to conduct
this deposition pursuant to House Resolution 167, which passed the full
House on June 20, 1997. Committee Rule 20 outlines the ground rules of
this deposition.
Majority and Minority counsel will ask you questions regarding the
subject matter of the investigation. Minority counsel will ask
questions after Majority counsel has finished. After the Minority
counsel has completed questioning, a new round of questions may begin.
Members of Congress that wish to ask questions will be afforded an
immediate opportunity to ask their questions. When they are finished,
committee counsel will resume questioning.
Pursuant to the committee's rules, you are allowed to have an
opportunity present to advise you of your rights. Any objection raised
during the course of the deposition shall be stated for the record. If
the witness is instructed not to answer a question or otherwise refuses
to answer a question, Majority and Minority counsel will confer to
determine whether the objection is proper. If Majority and Minority
counsel agree that the question is proper, the witness will be asked to
answer the question. If an objection is not withdrawn, the Chairman or
a Member designated by the Chairman will decide whether the objection
is proper.
This deposition is considered as taken in executive session of the
committee, which means that it may not be made public without the
consent of the committee. Pursuant to clause 2(k)(7) of House Rule 11,
you are asked to abide by the rules of the House and not discuss with
anyone other than your attorney or attorneys this deposition and the
issues and questions raised during this proceeding.
Finally, no later than 5 days after your testimony is transcribed
and you have been notified that your transcript is available, you may
submit suggested changes to the Chairman. The transcript will be
available for your review at the committee office. Committee staff may
make any typographical or technical changes requested by you.
Substantive changes, modifications, clarifications or amendments to the
deposition transcript submitted by you must be accompanied by a letter
requesting the changes and a statement of your reasons for each
proposed change.
A letter requesting any substantive changes must be signed by you.
Any substantive changes made shall be included as an appendix to the
transcript, conditioned upon your signing of the transcript. It's my
understanding that you've come from a long distance, and at the
conclusion of these proceedings we'll make arrangements for you to
review your deposition transcript in a way that's convenient for both
yourself and your attorney.
Do you understand everything that we've gone over so far?
The Witness. I do.
Mr. Wilson. Do you have any questions about anything I've discussed
so far?
The Witness. No.
Mr. Wilson. I've got a few preliminary questions to ask of the
witness. Does anybody else have any statement or comment at this time?
Mr. Lu. Not at this time.
Mr. Pierson. I do. First of all, your preliminary instructions to
the witness about what you would like him to say if he should answer a
particular way are general questions that typically you find at the
beginning of written interrogatories and are easy for a respondent to
attend to since they'll be right there before him in writing.
I would expect that if Mr. Swiller gives you an answer that he
either doesn't recall or doesn't know or is not sure, that you will be
appropriately following up with questions about what he does know or
what he may remember so that he will not have to remember specifically
every item of your preliminary instructions.
With respect to the transcript, I appreciate your indication that
you'll make it available to him since he's in California currently. He
lives there now and has a residence there. He is also getting married
at the end of this month and will also not be accessible for a while
afterward, as you expect. We appreciate you making appropriate
accommodations for reading the transcript.
Finally, I refer to my letter, July 3, 1997, to the committee in
which I responded to dates of Mr. Swiller's deposition. Among other
things, I have advised the Chairman that he should be advised Mr.
Swiller testified extensively recently in depositions taken by the
Senate committee inquiring into this.
We would be pleased to give you permission to read the transcript
of that deposition and thereby to avoid the inevitable repetition that
would result as you pursue the same lines of inquiry. I take it,
counsel, that you have not undertaken to read the transcript of Mr.
Swiller's deposition in the Senate.
Mr. Wilson. We have not been given a copy of Mr. Swiller's
deposition transcript from the Senate. And I appreciate your initial
offer. And we would certainly have taken up your suggestions. But we
have not been permitted to see or review a copy of that deposition.
Mr. Pierson. Can you tell me whether the Senate committee has been
advised whether we would be given permission to do so?
Mr. Wilson. I honestly don't know specifically in your case. But
there have been a number of witnesses who have made similar offers, and
we have advised the Senate in each instance that there have been no
objections and my understanding is that there's a matter of Senate
protocol and the particular rules under which they are functioning and
that specific investigation in which Mr. Swiller gave his deposition.
At this point, we do not have access to most of the depositions taken.
Some have been released. And those have involved individuals who have
testified publicly. Unfortunately, Mr. Swiller's is not one of them.
Mr. Pierson. Finally, I understand that under the rules, this
deposition is being taken in executive session. I appreciate that. And
I appreciate the instructions. Of course, Mr. Swiller is entirely at
liberty to talk to anybody about what he has said here today at any
time. Moreover, if any report of his testimony should be leaked from
the committee or from its staff, we will consider that executive
session instruction to be devoid.
Mr. Lu. If I may, I would just like to second Mr. Pierson's
concerns about Mr. Swiller's deposition in light of the Senate
deposition. The Democratic staff has always believed that these
depositions should be put off until after the release of their Senate
depositions. Obviously, we have not had our way. So I would simply just
second that. We appreciate you coming in. We realize this has been a
burden for you, especially since a lot of the testimony you'll be
giving today will be duplicative testimony to the Senate.
Mr. Pierson. That's all I have.
EXAMINATION BY MR. WILSON:
Question. Mr. Swiller, I'll be asking you questions concerning the
subject matter of this investigation. Do you understand?
Answer. Yes.
Question. If you don't understand a question, please say so, and
I'll repeat it or rephrase it so that you are able to understand the
question. Do you understand that you should tell me if you do not
understand my question?
Answer. Yes.
Question. The reporter will be taking down everything we say and
will make a written record of the deposition. You are asked to give
verbal, audible answers because the reporter cannot record a gesture or
nonspecific answer. Do you understand that you should not answer uh-huh
or provide a gesture to answer one of my questions?
Answer. Yes.
Question. If you can't hear me, please say so and I'll repeat the
question or have the court reporter read the question to you. Do you
understand that?
Answer. Yes.
Question. Please wait until I finish each question before answering
it, and I will wait until you finish your answer before I ask the next
question. Do you understand that this will help the reporter to make a
clear record because she cannot record what we are both stating at the
same time?
Answer. Yes.
Question. Your testimony is being taken under oath as if we were in
court, and if you answer a question, it will be assumed that you
understood the question and the answer was intended to be responsive to
it. Do you understand that?
Answer. Yes.
Question. Are you here voluntarily or are you here as a result of a
subpoena?
Answer. Voluntarily.
Question. Do you have any questions about this deposition before we
begin the substantive portion of the proceeding?
Answer. No.
Question. Please state your name and spell it for the record?
Answer. It's Jacob Arieh, A-R-I-E-H, Swiller, S-W-I-L-L-E-R.
Question. Have you in the past used any other name or gone by any
other name?
Answer. Ari Swiller is what I generally go by. It's A-R-I, same
last name.
Question. What is your date of birth?
Answer. [Redacted].
Question. What is your current address?
Answer. [Redacted].
Question. What was your last address in Washington, D.C.?
Answer. [Redacted].
Question. Have--have you lived for a period of more than 6 months
out of the United States?
Answer. I have not.
Question. Did you attend college?
Answer. I did.
Question. Where did you attend college?
Answer. [Redacted].
Question. And when did you graduate?
Answer. [Redacted].
Question. Have you received any other degrees?
Answer. I have not.
Question. Please briefly describe your employment history after
college?
Answer. My first--after college, I traveled for a few months and
moved to Washington in early 1992. I was an intern for the office of
Matt McHugh, a Member of Congress from the State of New York. At the
same time I began to volunteer at the Clinton for President Campaign.
In approximately April or May of 1992, I became a full-time staffer
in the Clinton for President Campaign in the Finance Department. We
transferred to the Democratic National Committee following the 1992
convention in New York. After the November election, I worked for the
Presidential inaugural committee. Following the inaugural, I stayed on
the staff of the inaugural until approximately April again.
In April of 1993, I started work for Steny Hoyer, a Member of
Congress from Maryland. At the time, he was chair of the Democratic
caucus and I served on his caucus staff. I worked there until December
of 1993, at which time I joined the Democratic National Committee. I
worked there until March of 1997 at which time I joined the Rouse
Grocery Company as Vice President of External Affairs. That's my
current position.
Question. Have you spoken with anyone other than your counsel about
this deposition?
Answer. No.
Question. Have you reviewed any documents in preparation for this
deposition?
Mr. Pierson. I will tell you that yesterday he had an interview
with the FBI at which time he was asked to examine documents which you
may be interested in.
EXAMINATION BY MR. WILSON:
Question. Do you have any documents that are--DNC documents
currently in your possession?
Answer. I do not.
Question. Did you leave all of your work-related materials in
your--with your former place of employment?
Answer. I did.
Question. What documents did you review with the FBI?
Mr. Pierson. He may not remember. I can perhaps help him. There was
a memorandum in July 1995 by a Landroca Steel to Donald Fowler. There
was a memorandum he wrote to a counsel at the DNC concerning Pauline
Kanchanalak following 1996 election. Was there anything else?
The Witness. Staff list.
Mr. Pierson. Oh, yes, they showed him a staff list of the DNC and
asked him to indicate which ones were fund-raisers and which were not.
EXAMINATION BY MR. WILSON:
Question. How did you come to work at the DNC?
Answer. At which time period?
Question. In your final--your final stint at the DNC as a paid
employee?
Answer. I had worked with a few of the staff members of the DNC
during the '92 campaign. When I went to work with Mr. Hoyer, I stayed
in touch with them. Around December of 1993, a little bit earlier, a
friend of mine, Laura Hartigan, became finance director and at that
time asked me to rejoin with her at the staff of the DNC. I accepted
her offer in the beginning of December of 1993.
Question. Did you interview with anybody for that position?
Answer. I interviewed with Laura Hartigan and David Wilhelm who at
that time was Chairman of the Democratic National Committee.
Question. And referring, and I'll try and be specific, but I'm
referring to your final employment at the DNC, what was your title?
Answer. For most of the time, I was director of the Trustee
Program. Or director of large donor efforts.
Question. Did you have any other titles?
Answer. No.
Question. Who did you report to?
Answer. When I first started at the DNC, I reported to Laura
Hartigan. Following the spring of 1995, there was a transition, and the
new finance director was Richard Sullivan, who I reported to until I
left.
Question. Could you provide a general description of your office?
And by that I mean were there other individuals who worked with you in
your capacity as----
Answer. There were two people under my direction. When I first
started, they were Jennifer Scully and Jay Webber. The following time,
Mr. Webber left, and a gentleman named Mack Gobush, G-O-B-U-S-H, joined
the staff. Following some time, there was another transition in the
spring of '95, an Anne Braziel and Nancy Burk joined the staff with me.
Question. In a spatial sense, where were they located in relation
to where you worked? Were you all in the same office?
Answer. I'll refer to the last part of my year and a half.
Question. Okay.
Answer. Ms. Braziel and I shared an office. And Ms. Burk was
stationed at a cubicle within approximately 12 feet of our office.
Question. Did you type your own letters and memoranda?
Answer. For the most part, I did. However, at times, I was assisted
by both Ms. Braziel and Ms. Burk in some of the memoranda and letters
that were sent under my name.
Question. Did you fax your own fax transmissions to other people?
Answer. Same, the previous answer. I did most of it. But they also
assisted.
Question. Did you have someone who would take messages for you from
the telephone?
Answer. I did not. We had a voice mail system.
Question. Did you use an e-mail system at the DNC?
Answer. It was available. I was not a frequent user of it.
Question. Did you have any--and, again, I'll just refer to the
period during which you were the--the director of the Trustee Program.
Did you have any official contact with White House employees?
Answer. What do you mean by official?
Question. Business-related contacts, where you would discuss
matters with them or they would discuss matters with you?
Answer. Yes, I did.
Question. Was there a specific liaison in the White House to deal
with you in your office?
Answer. There was not.
Question. Were there--was there any one person or were there any
select number of people that you would deal with regularly?
Answer. I dealt for some time with Brian Bailey, with a woman named
Tracy LeBreque, with a gentleman named Donald Dunn. Those were my
primary contacts.
Question. Do you recall any dealings with other employees at the
White House?
Answer. I mean,--I mean, for instance----
Mr. Pierson. Are you asking about any contact or regular contact?
Mr. Wilson. Regular contacts.
The Witness. I mean I was friendly with a number of people through
my work on the campaign. As far as business-related matters, the
majority of my contacts are with the people I stated already.
EXAMINATION BY MR. WILSON:
Question. Did you ever attend regularly scheduled events at the
White House?
Answer. Events meaning meetings or----
Question. Well, I'm trying to eliminate a random event that might
be a Christmas party or a single type event, but a weekly scheduled
event or a monthly type scheduled event, something that would occur on
a regular basis?
Answer. For a time, Mr. Bailey arranged for meetings that included
and arranged political staff representatives, congressional liaison
staff representatives. The point of the meeting was to gather lists of
names for upcoming social events that may take place at the White
House.
Question. How frequently did such meetings occur?
Answer. They were scheduled, I believe, to take place every other
week. Invariably, my meetings were canceled pretty often, and they did
not run--I believe this program did not run more than 6 months.
Question. Did you have a pass to allow you access to the White
House?
Answer. Never did.
Question. How did you gain access to the White House?
Answer. I was usually cleared through Mr. Bailey's office.
Question. And how would that process work?
Answer. After I was notified of a meeting, someone from his office
would call and request my date of birth and Social Security number.
They would tell me the time to enter and which gate of the White House
to enter. I would present ID when I'd enter and be directed to the room
where the meeting would take place.
Question. Please provide an overview of the Trustee Program at the
DNC.
Answer. Trustee Program was a group of the highest donors to the
Democratic Party or highest fund-raisers. The--there were two levels
within the Trustee Program. There were trustees who contributed $50,000
or raised over 100,000. And managing trustees who contributed 100,000
and raised over 250,000. The program consisted of, by the time the '96
election, approximately 800 people from across the country.
Question. Did individuals who were members of the Trustee Program
receive regular materials from the DNC? By that, I mean mailings and
the sort?
Answer. We had a tally or sometimes every other day fax service
with talking points regarding pertinent political issues. When we knew
of--ahead of time of scheduled events such as the national galla in
Washington, they received the date of that event as far ahead of time
as we could provide it so that they knew of an invitation to that
event.
Question. The daily faxes that you just referenced, who was
responsible for sending the fax transmissions?
Answer. I believe they were written in the Research Department. And
I don't know the process by which they were then faxed. But it was on a
massive scale to not just trustees, but all financial supporters as
well as political supporters and constituents.
Question. Who was the individual or who were the individuals who
composed the fax transmissions?
Answer. I would be speculating. I'm not sure who in the Research
Department.
Question. Did you ever have occasion to discuss entries in the fax
transmissions with people who would be authors of the fax
transmissions?
Answer. I did not.
Question. Do you know who did?
Answer. I don't.
Question. Did you receive regular copies of the fax transmissions?
Answer. They were supposed to be provided regularly. I don't think
I saw--I probably saw half of the transmissions that were sent.
Question. Do you recall whether you retained any of the faxes that
went out to the trustees for your records?
Answer. No. I did not.
Question. No, you don't recall?
Answer. I did not retain them.
Question. While you were at the DNC in your position as Director of
the Trustee Program, did you have any responsibility for any other
programs or initiatives at the DNC?
Answer. The one other program I was involved with was an effort to
raise money from the Jewish constituency. It had varying titles. One we
used most frequently was Jewish Leadership Forum. It was not a
scheduled or defined job description. It just was a general--part of a
general effort to raise money within the Jewish community?
Question. Did you regularly receive requests from members of the
Trustee Program to obtain assistance with various types of things that
they would like to do with the White House? And I realize that's about
as unspecific as you can possibly make a question. So I'm just trying
to gather whether there was a type of system that you used when people
would call you up and ask you to do something for them, if they did ask
you to do something for them. And that could be a tour of the White
House or something like that or--just starting with that, if people
called you up and asked you for a tour or perhaps an opportunity to get
a photograph. Did you have a regular procedure that you would follow to
respond to that request?
Mr. Pierson. Are you talking about trustees calling.
Mr. Wilson. Yes.
The Witness. Well, let's take them--as far as tours, we tried to
accommodate. Nancy Burk, Ms. Burk was the woman in my office who
handled, who contacted the White House, receiving an allotment of some
of the tickets which the White House provided the DNC to our trustees
to have ticketed tours of the White House. Ms.--If--when you say
photograph, you mean just a still photo of the President?
EXAMINATION BY MR. WILSON:
Question. Yes.
Answer. If it's just a still picture, again, I would probably ask
Ms. Burk to retrieve one from the file and address a letter, an
envelope to the requester.
Question. Did you--did you have a system to handle requests? And by
that, I mean, did you use forms to track a request that would come in,
a form would go out to a particular individual, or would it be fair to
say that you responded to requests of you on an ad hoc basis?
Answer. Ad hoc basis.
Question. Did you have a system in place to determine whether it
was appropriate to help an individual with a request that might be made
of you?
Mr. Lu. I'm not sure I understand the word, ``appropriate.'' But if
you do, please answer it.
Mr. Pierson. I also have an objection. Is the ``you'' directed to
him or is it directed to the entire DNC?
Mr. Wilson. To Mr. Swiller.
Mr. Pierson. Did he personally have a system?
Mr. Wilson. Personally. Just was there a fail-safe mechanism system
that you had in place to screen and determine whether it was
appropriate to assist somebody with a request that they might make of
you.
Mr. Pierson. He's asking about you personally.
The Witness. No.
EXAMINATION BY MR. WILSON:
Question. Was there a DNC system that you would follow to determine
whether it was appropriate to assist anybody with the request?
Answer. No.
Question. Were there ever occasions in which an individual might
call you and ask--asking for you to help with something, and you were
uncomfortable with providing assistance to them?
Answer. Yes.
Question. If you could, please describe those situations.
Mr. Pierson. Try and give some examples.
The Witness. Frequently,--not frequently. That's overstating it. A
few times, people would request to speak directly with the President,
the Vice President, even members--most senior staff members at the
White House, and ask for my assistance in providing those meetings. I
always felt those requests were inappropriate and do not recall ever
acting on one of them.
EXAMINATION BY MR. WILSON:
Question. Do you have any examples or do you recall any situations
where an individual made a request of you and you were concerned about
following up on that request because of something you knew about that
person?
Answer. I don't know if I understand the second part of your
question. You mean something I knew in their past?
Question. Yes, pre-existing knowledge of something that they had
done or place that they had been or position that they had held which
made you uncomfortable with continuing to assist them or assisting them
in the first place.
Answer. I generally acted that if I felt uncomfortable with a
request, I didn't do it, regardless of whether it was something in
their background or if their request was, I felt, inappropriate, I
didn't act on that.
Question. Trying to move away from situations where people were
asking you things that you found to simply not be possible or request
that you felt was just not something that could be realized, do you
recall any situations where an individual made a request of you and you
thought that you or the DNC did not want to be involved with helping
that individual?
Mr. Lu. Because of their past?
Mr. Wilson. Because of anything.
Mr. Lu. Because of anything.
Mr. Wilson. Anything that you knew or have knowledge of.
The Witness. Could you restate the question? I'm sorry.
Mr. Wilson. I'll ask the reporter to read it, if I may.
[The reporter read back as requested.]
The Witness. Could you possibly restate that?
Mr. Wilson. Well, I'm not trying to be hard here. If you thought
simply this is a person I don't think we should be involved with, and
either you decided not to help or you discussed with somebody else
whether that person should be assisted.
The Witness. I don't recall anyone that I flatly denied assistance.
EXAMINATION BY MR. WILSON:
Question. Did you ever talk to any colleague at the DNC about an
individual and about whether it was appropriate to provide assistance
to them?
Answer. I don't recall any specific conversations.
Question. Did you ever personally do any background checks on
individuals who you came in contact with in your position as the
director of the Trustee Program?
Answer. I do not personally, no.
Question. Did you ever request that anybody at the DNC to provide
background information on the people that you came into contact with at
the DNC?
Answer. Yes.
Question. Who would you make such requests of?
Answer. I tended to work with the Research Department at the DNC,
different individuals who had access to Nexis-Lexis within their
department.
Question. Do you recall the names of individuals you worked with?
Answer. I don't. Oh, that I worked with?
Question. At the DNC. On this matter of getting background
information?
Answer. A name that I recall is Tom Janenda was the Deputy Research
Director.
Question. Do you recall any other individuals that you might have
made background requests for background information?
Answer. He was my primary contact. That I recall.
Question. Did you ever have anybody in your immediate office, the
individuals you described previously as working with you, did you ever
ask them to do any background checks on individuals?
Answer. I did not.
Question. Did you keep files of biographical information on
individuals who were members of the Trustee Program?
Answer. I did.
Question. And--and what form did you keep that information in?
Answer. It was in a file cabinet, each donor member of the Trustee
Program had a file with their name. And as many cases as we had a bio,
a bio accompanied the file.
Question. So is it fair to say that if there were approximately 800
individuals who participated in the Trustee Program, that there were
approximately 800 files on the individuals?
Answer. Approximately, yeah. But not all of them had bios. We may
have had an empty file.
Question. What types of information would you keep in the file?
Answer. Bio information. If they had been sent a photograph or some
other letter inviting them to an event, we may keep a copy on file. And
in some cases, not in all, we--if they were trustees because of a
donation, we kept a copy of the check and the check-tracking form in
the file.
Question. Do you recall any other types of information that was
kept in the files?
Answer. That was primarily it.
Question. How would you obtain the biographical information?
Answer. We would request it directly from the office or from--from
the office of the individual for the--from the individual, him or
herself.
Question. Did you have a standard form that you would send to them
to fill out?
Answer. I believe Ms. Braziel designed a form that also requested
that they provide us with their date of birth, Social Security number,
as well as their address, home address, business address, telephone
numbers, spouse's name, et cetera.
Question. How did you keep track of the individuals who were
participants in the Trustee Program?
Answer. We had a computer data base system?
Question. What--did this data base produce an aggregate list of
trustees that was--that you had access to?
Answer. It could, uh-huh. Yes.
Question. Did you keep such lists?
Answer. I did.
Question. Were these lists updated on a regular basis or were they
just lists that if you had a need for them, you would request a new
list to be generated?
Answer. Generally, I received a list when I requested it. There was
not a scheduled updating.
Question. Were there any lists generated by the data base you
described or in any other way that described the aggregate amount of
contributions that come, that had come from the Trustee Program?
Answer. I'm not sure if I understand.
Question. Just whether at any particular time during the year,
could you get a printout or a list that said--that told you this year,
X amount of dollars have been raised through the Trustee Program?
Answer. No, I did not.
Question. Did you ever create such a list yourself based on numbers
of participating trustees?
Answer. I may have tried to create lists broken down by
contribution and then the sum of their contribution. But contributions
were not made directly to the program in many cases. They were made in
conjunction with an event, a fund-raising event anywhere in the
country. But if someone had raised the necessary funds to become a
member or contributed the necessary funds, they became a member,
whether or not it was a direct to joining the program.
Question. Is it fair to say, then, that if somebody that made a
contribution, that it was of the requisite amount, $50,000, for
example, for the Trustee Program to attend a dinner, a fund-raiser,
that they would then become a member of the Trustee Program?
Answer. Uh-huh. That's correct.
Question. And how did--how did you keep track of those types of
transactions? How did you know whether people would become eligible to
be a member of the Trustee Program or not?
Answer. I mean, it varied case to case. Some individuals sent their
contributions directly to me or a list of what contributions they had
raised. And I had direct contact. In cases where events were held
around the country, individual fund-raisers were responsible for that
event. Following the event would provide me a list of new members or
people who had renewed their membership through the event which they
had just coordinated. Those are the primary ones.
Question. Did you circulate among other offices at the DNC the list
of trustees?
Answer. On occasion, the chairman's office would request a list.
Other than that, the lists were in the Finance Department. No one else
requested them.
Question. Did you ever send a trustee list to the White House?
Answer. No.
Question. There's a term of art that I've seen on documents, and
it's the fund-raiser account. Do you know what that refers to?
Answer. I don't.
Question. You mentioned earlier that there was a computer system
that kept track of the managing trustee lists. Was that the AS-400
system?
Answer. The AS-400 system was a system at the DNC. Within the
Trustee Department, we had a separate data base that was more flexible
to our needs of generating labels and quick lists that we used. It was
a Paradox-based data system.
Question. Did you receive regular information from the AS-400
system?
Answer. I used it to reference--it was a good reference for when
contributions were put in, because all contributions were posted in the
AS-400. So I had access to it from the main frame at my desk. So
frequently, I would access information off it.
Question. Were printouts of contributions generated by the AS-400
system the source of information that you used to determine who had
contributed money and who would be eligible to be in the Trustee
Program?
Answer. At times, yes. It was a source of information for that,
yes.
Question. If you could, just describe what would happen if you had
dealt directly with somebody and discussed making a contribution, and
they hadn't made a contribution, sent you a contribution----
Answer. And they hadn't----
Question. And they had sent you a contribution. What would you do
to ensure that that was entered into the AS-400 system?
Answer. I actually had no direct connection to the entries into the
AS-400. My only assurance was I'd give approximately a week's time from
when I had received the check--from the time from when I submitted the
check, and checking the AS-400 was my only safety net in making sure.
And I don't recall situations where checks did not appear after a week
or maybe in some cases 2 weeks, but----
Question. When a check, and this is assuming first of all, did you
receive checks directly from donors?
Answer. I did.
Question. When you did receive such a check, what was the
mechanical process of handling that check? What would you do with that?
Answer. We--I would attach a donor information sheet check tracking
form and add with it their name, company, phone number, which event the
contribution related to, or was it part of their membership to the
Trustee Program as indicated on the sheet. Then photocopied batch
checks if I had more than one, and submit them to--I don't know the
title, but the person within our--the Finance Department who maintained
the list of what checks had come in.
Question. Who was that person?
Answer. The last person serving that was a woman named Theresa
Stirk.
Question. And do you recall who was in a similar position before
that?
Answer. During my time there were two other people that held it.
First, it was a gentleman, Jeff King. And Susan Ochs, O-C-H-S.
Question. Did you ever receive lists of individuals generated in or
by the White House?
Mr. Pierson. Any kind of lists? Just a list that came from the
White House.
Mr. Wilson. [Indicating in the affirmative.]
The Witness. Yes.
EXAMINATION BY MR. WILSON:
Question. What types of lists did you receive?
Answer. On occasion, they would submit to us a list of individuals
who might be attending an upcoming White House event.
Question. And why would you receive such information?
Mr. Pierson. If you know.
The Witness. In some occasions, we provided some names to be
included in events they submitted since they were responsible for
invitations and receiving regrets. They would provide a list
identifying who was coming.
EXAMINATION BY MR. WILSON:
Question. Do you recall receiving any other types of lists from the
White House?
Answer. I do not.
Question. Did you ever receive any lists of individuals who were
suggested individuals to approach to ask for donations----
Mr. Pierson. From the White House.
Mr. Wilson. From the White House.
The Witness. No, I did not.
EXAMINATION BY MR. WILSON:
Question. Do you know what the system at the DNC is now for
screening campaign contributors, people who have contributed----
Answer. Today, I do not.
Question. Okay. Prior to November of 1996, did--do you know at the
time what the system was for screening contributions?
Mr. Pierson. Are you talking appropriateness or legality?
Mr. Wilson. Well either, actually.
Mr. Pierson. Well, you probably ought to take them one by one.
Mr. Wilson. Well, we will then.
EXAMINATION BY MR. WILSON:
Question. Appropriateness screening for appropriateness?
Answer. Extended to our own discretion to decide on whether we're
comfortable with a person's contribution. When I say our, I mean the
individual fund-raiser dealing with that contribution.
Question. And staying on the issue of appropriateness in terms of
screening contributions, do you recall examples or situations where it
was determined--where you had discussions with people about the
appropriateness of a--of a contribution?
Answer. I may have at times conferred with the--Mr. Sullivan or
Marvin Rosen, the finance chair. But it was very infrequent.
Question. And do you remember the subjects of those inquiries?
Answer. Sometimes, there--if individuals were making a contribution
that we needed--I'm trying to think. We needed more information on the
individual or the corporation giving the contribution to make sure that
it was a U.S. subsidiary.
Mr. Wilson. Excuse me, this is a reinforcement reporter.
The Witness. Oh.
EXAMINATION BY MR. WILSON:
Question. Do you recall any individual contributors that were
discussed during these meetings with Mr. Sullivan?
Mr. Pierson. Are you talking about natural persons or just specific
instances.
Mr. Wilson. Natural persons, yes.
The Witness. I don't recall specific conversations about
individuals or any individuals.
EXAMINATION BY MR. WILSON:
Question. Turning to legality, what was the system for screening
contributions for legality of contribution?
Answer. I'm not sure what it was. I'm not an attorney. I don't know
what the process was.
Question. Did you ever have any training during which legality of
contributions was discussed?
Answer. I did.
Question. And with whom? Who conducted this training?
Answer. The general counsel and the deputy counsel, Joseph Sandler
and Neal Rieff.
Question. Do you recall any instances where a Lexis-Nexis search
was done to determine background information to assess either the
legality or appropriateness of the contribution?
Mr. Lu. By anyone--I'm sorry.
Mr. Pierson. Let's break it down. Ask about Lexis-Nexis.
Mr. Wilson. Stay with one.
Mr. Pierson. Search before you ask other purpose. Because you'll
get a complicated or nonresponsive answer.
Mr. Wilson. Okay.
EXAMINATION BY MR. WILSON:
Question. I know you did mention before that there had been Lexis-
Nexis searches. Did you ever request any Lexis-Nexis searches to be
performed to supplement information that would be transmitted on the
check-tracking forms that you filled out?
Answer. Not that I recall.
Question. Did you request Lexis-Nexis searches for any other
purposes?
Answer. I remember a few occasions requesting the context being a
person was going to be attending an event at the White House. And
required more biographical information on the individual.
Question. Do you remember the individuals that you requested
searches about?
Answer. I don't.
Question. Do you know whether at any time the DNC stopped
performing Lexis-Nexis searches to determine the legality of campaign
contributions?
Answer. I don't recall starting points. I don't recall an ending
point. I don't recall there being a program of it.
Question. But do you know whether at any time such searches were
stopped?
Answer. I do not.
Question. I provide the witness with a document that was a single
page of handwritten notes, and it is marked DNC 3049787.
Just requiring you to read the whole thing, do you recognize the
handwriting on this document?
Answer. I do not.
Mr. Pierson. Are we going to mark this for the records?
Mr. Wilson. No, actually we will not. What I can do is two things,
actually. I will defer to what is convenient for you. Documents that I
show the witness that become immediately apparent have no relevance to
his testimony, I can simply move on from, or else I can include them in
the record if it is a convenience to you when you go back and review
the record.
Mr. Pierson. I don't think the record will be complete unless you
do include it, because you have testimony about it. If the record says,
there is a question, do you recognize the handwriting, there won't be
any indication of what handwriting he was looking at, unless you
include it. So you should.
Mr. Wilson. I am perfectly willing to do that. I will mark this
document Exhibit AS-1 for inclusion in the record.
[Swiller Deposition Exhibit No. AS-1 was marked for
identification.]
[Note.--All exhibits referred to can be found at end of
deposition.]
Mr. Wilson. Just by way of background, we actually keep the
documents. We don't let you take them.
Mr. Pierson. The Senate lets us have them.
Mr. Wilson. Sorry. We are less accommodating on that front.
Mr. Pierson. So am I.
EXAMINATION BY MR. WILSON:
Question. Are you familiar with FEC reporting requirements that
apply to the DNC?
Answer. I am familiar with general requirements, yes.
Question. What reporting requirements applied to you in what you
were doing as director of the Trustee Program?
Answer. I don't recall direct requirements. What I recall is that
information such as occupation, employer of an individual, their
address, the phone number and fax number, were required information for
all contributions made, or if it was a corporation, the corporation's
address, and that that was required for every individual that would
then be submitted by the DNC to the FEC. So my requirement in relation
to the FEC, as I recall it, was providing complete information on
contributions.
Question. Apart from filling out check tracking forms, as you have
described it previously, did you have to do anything else to ensure
compliance with FEC provisions?
Mr. Pierson. You are asking him----
Mr. Wilson. That you know of, that had been communicated to him.
Mr. Pierson. As his responsibility? Witness will correct.
The Witness. Not that I recall, no.
EXAMINATION BY MR. WILSON:
Question. Did you have to produce any reports that you knew were
going to be used for the purposes of FEC filing?
Answer. Other than the tracking form, nothing else was required
that I recall.
Question. Are you aware that the accounting firm of Ernst & Young
prepared materials that discussed contributions by individuals during
the 1996 election cycle?
Answer. My only--and this is very second and thirdhand knowledge of
Ernst & Young's connection with the DNC, is that they, after there were
concerns about some donations, they reviewed those as an accounting
firm following the '96 election. That is the only knowledge I have of
any work they did with the Democratic National Committee.
Question. Did you ever meet with any Ernst & Young personnel while
you were an employee at the DNC?
Answer. I had a contact there who was a contributor, but not in the
context of your earlier stated question.
Question. Not in the context of the report or the materials
prepared by Ernst & Young?
Answer. Correct.
Question. Were you ever contacted by any Ernst & Young employee in
regard to the work that they were doing vis-a-vis the '96 campaign
contributions?
Answer. Never.
Question. Were you ever--did you ever discuss with any of your
colleagues the work that Ernst & Young was doing?
Answer. Yes.
Question. Were you ever asked to provide anything for the Ernst &
Young report?
Answer. Never.
Question. Can you just generally recount the discussions you had
with colleagues about the Ernst & Young process?
Answer. We, the colleagues I tended to discuss it with were within
the finance department that I worked with. My discussion, the context,
we were discouraged at how they were proceeding with their report. We
felt that it was detrimental to the DNC, it was offending donors who
were contacted, and I believe at the time some of our Asian American
donors felt that they were being harassed by some of the Ernst & Young
employees who were proceeding with that, and it was, you know, to our
dismay.
Question. Was this your belief?
Answer. Being I had no direct contact, I had no notion, but, you
know, after hearing that there were donors who were upset, then became
my belief, sure. Yes.
Question. Do you know if individuals communicated that to Ernst &
Young personnel?
Mr. Lu. You mean donors themselves, or do you mean people at the
DNC?
Mr. Wilson. People at the DNC.
Mr. Pierson. Time out. What is the ``that'' we are talking about?
The last thing we testified to is his feeling.
Mr. Wilson. That is quite right.
EXAMINATION BY MR. WILSON:
Question. Do you know if DNC personnel communicated to Ernst &
Young personnel that there was a sense of dissatisfaction with the way
the process was proceeding?
Answer. I have no knowledge of that.
Question. Did you ever participate in any discussions during which
it was discussed the threshold of contribution that Ernst & Young
reviewed during their review process?
Mr. Lu. First of all, do you mean a monetary threshold?
Mr. Wilson. Dollar amount.
The Witness. I was not in formal discussions. I think informally,
again, all the information we received was secondhand on their
inquiries, and I believe we thought it was somewhere either over 5,000
or over 10,000. But I don't ever remember having direct knowledge of
what the threshold was. But there was discussion of how they were
proceeding.
EXAMINATION BY MR. WILSON:
Question. Do you know who set the level of monetary contribution
that would be examined?
Answer. I don't.
Question. Aside from what you might have learned subsequently in
media accounts, at the time did you know that--at the time, I am
speaking of any time you were employed at the DNC, sort of in your
knowledge of what people were telling you among your colleagues, did
you know that checks were recommended to be returned?
Answer. Yes.
Question. Do you know whether the DNC returned all checks that
Ernst & Young had recommended be returned?
Answer. I am not privy to that. No, I don't know that information.
Question. Did you have any discussions with your colleagues about
whether Ernst & Young was distinguishing between illegal contributions
and contributions that were deemed inappropriate?
Answer. I don't recall that discussion, no.
Question. What was Scott Pastrick's position at the DNC?
Answer. He had an unpaid volunteer position of treasurer of the
Democratic National Committee, which I believe began in the spring of
'95.
Question. Do you know whether he signed FEC reports?
Answer. I have no knowledge of that.
Question. Were you aware of any discussions that----
Answer. May I go back to that?
Question. Certainly.
Answer. Scott at one point in a conversation with me made light of
the fact that he was supposed to sign FEC reports, but I think there
were reports that were passed on that he did not sign.
Question. Did he tell you why that was?
Answer. I don't remember that, the context of why it was.
Question. Did you have any conversations with other colleagues
about whether Mr. Pastrick was signing or not signing FEC reports?
Answer. No.
Mr. Pierson. Off the record.
[Discussion off the record.]
EXAMINATION BY MR. WILSON:
Question. Back on the record.
Have you ever met Mark Middleton?
Answer. I have.
Question. When did you first meet Mr. Middleton?
Answer. I first met Mr. Middleton in the course of the 1992
Presidential campaign. We both served on the fund-raising staff for the
Clinton for President. My position was in the mid-Atlantic region. Mark
was the director of fund-raising in the State of Arkansas. We probably
first met either at a national event we did for fund-raisers here in
Washington or June or at the convention in July.
Question. Do you know whether Mr. Middleton was affiliated with the
DNC in 1996?
Answer. I believe he was not.
Question. Did Mr. Middleton, do you know whether he was asked to
serve on the 1996 finance board of directors?
Answer. I believe he may have been.
Question. Do you know whether he actually did serve on the finance
board of directors?
Answer. I don't believe so.
Question. Did you have any discussions with him about whether he
would or would not serve on the '96 finance board of directors?
Answer. Not that I recall.
Question. Do you recall whether Mr. Middleton did any fund-raising
for the DNC in the 1996 election cycle?
Answer. I recall that he was--when Truman Arnold served as finance
chair, he and Mark, he and Mr. Middleton had a close association from
Arkansas. Mr. Arnold asked Mr. Middleton to assist in some fund-raising
efforts when Mr. Arnold was chairman. But I don't recall--what was the
last part of the question?
Question. I think that is pretty responsive right there. Did Mr.
Middleton assist in organizing any fund-raising events in the '96
election cycle?
Answer. Not that I know of.
Question. After Mr. Middleton left the White House, he formed a
business called CommerceCorp. Did you ever visit Mr. Middleton in his
business place?
Answer. I did not.
Question. Did Mr. Middleton ever contact you to request assistance
on behalf of clients or associates of his?
Answer. No.
Question. Did anybody else from Mr. Middleton's office ever contact
you to request assistance?
Answer. No.
Question. When Mr. Middleton worked at the White House, did Yusuf
Khapra ever contact you to arrange for assistance on behalf of any
matter brought to your attention?
Answer. Not that I recall.
Question. Do you know Yusuf Khapra?
Answer. Not well, but I know him, yes.
Question. When did you first meet him?
Answer. Sometime during my service at the DNC, I believe in 1994,
during that year.
Question. Did he ever contact you for any reason?
Answer. My recollection is that he worked with Brian Bailey in
setting up the meetings regarding--that I described earlier, and that
was the context of our contact, was to invite me to the meetings and
make me aware of them.
Question. Did you ever receive any contacts in 1995 to provide
assistance to the Widjaja family?
Answer. The what?
Question. The Widjaja family. Did anybody ever contact you and
mention the Widjaja family that you know of?
Answer. Not that I recall.
Question. I provide the witness with a document, a memorandum to
Richard Sullivan and Mr. Swiller from Anne Braziel, marked DNC 1809003.
Take just a moment to look through those.
This memorandum is undated, and it is the only copy that has been
provided to us. Do you recall ever having received this memorandum?
Answer. It does not look familiar.
Question. Are you able to tell me the year, date of the memo?
Answer. I am not.
Question. The first sentence of the memorandum is that Mark
Middleton spent some time with me and pledged to help in raising money.
Assuming that that is Anne Braziel he spent some time with, do you
recall having any conversations with Anne Braziel about Middleton
pledging to help raise money?
Answer. It sounds familiar.
Question. Do you recall whether he ever did provide any assistance
in giving you names of potential donors to the DNC?
Answer. Not that I had direct contact on. But Mark, having
previously assisted in fund-raising, we were, you know, requesting of
him to help--I requested him to help from time to time on some
additional efforts. Like when I described earlier, Mr. Arnold brought
him in to assist.
Question. Do you recall having conversations with any DNC
colleagues about Mr. Middleton providing names for telephone
solicitations?
Answer. I don't remember those conversations, no.
Mr. Wilson. I will mark this document Exhibit AS-2 for the record.
[Swiller Deposition Exhibit No. AS-2 was marked for
identification.]
EXAMINATION BY MR. WILSON:
Question. Did you ever have any conversations that involved the
Sinar Mas delegation or Sinar Mas entity?
Answer. No.
Question. Do you know what Sinar Mas is?
Answer. No.
Question. Do you know whether Mark Middleton ever raised funds for
the DNC or any political party outside of the United States?
Answer. This will help, maybe. I don't recall Mark ever raising
money in the last 2 years I worked with him, meaning from when Mr.
Arnold brought him. So globally I have no knowledge of him ever raising
money.
Question. That does help. I can't take away quite as many as the
last time, but that does help.
When did you first meet Charlie Trie?
Answer. Sometime after I rejoined the DNC in 1993. Sometime in
1994. I don't recall the first meeting.
Question. Do you remember who introduced you?
Answer. I don't. I very well may have introduced myself, being that
I was the director of the trustee program. Mr. Trie was a member of the
program, and I had not met him yet. I may have introduced myself or
been introduced by someone. I don't remember the context.
Question. Do you remember when you first solicited a contribution
from Mr. Trie?
Answer. I don't recall ever soliciting contributions from Mr. Trie.
Question. I show the witness a document which is marked Bates
Number DNC 3078818, and the title is ``DNC Finance Executive Summary.''
Mr. Pierson. For the record, Counsel, it shows an apparent date in
the upper left-hand corner of 12-3-96.
EXAMINATION BY MR. WILSON:
Question. If you could, explain what the terms ``solicitor'' and
``fund-raiser'' mean in this, in the context of this document?
Answer. One of the areas we filled out in our AS400 sheet for
assistance in tracking was a solicitor. If someone made the request of
a donor to make a contribution that was in the context of trustee,
membership could be allocated by money raised. So this was an area that
tracked that.
Fund-raiser was the contact or the individual person who received
the check, filled out the form, and submitted it.
Question. Is it fair to say that if you received--if somebody
transmitted a check to you and you filled out the tracking form, that
you would generally be listed as the fund-raiser for that event?
Answer. For that event?
Question. The event being the filling out of the tracking form for
the particular receipt of that check.
Answer. If I filled out a form, I put my name as the fund-raiser.
Question. Do you recall any conversations with Mr. Mays on the
contributions given by Mr. Trie in 1994?
Answer. I don't.
Question. Do you know Richard Mays?
Answer. I do.
Question. When did you first meet Mr. Mays?
Answer. I believe I met him during the 1992 campaign cycle.
Question. The entry on this document indicates that--actually it
doesn't indicate anything. It states, health care campaign.
Could you provide a little bit of explanation of what the health
care campaign entry on this document means?
Mr. Pierson. Counsel, for the record, it says 1994 health care
campaign.
Mr. Wilson. Correct.
The Witness. We had different efforts constantly going for raising
money. It could be a gala event that was upcoming, it would be, as this
indicates, the health care campaign effort. If it was a topical effort
at the time and the contribution wasn't made in direct correlation to
an event, they would attribute it to the issue that we were raising
money for at that time.
EXAMINATION BY MR. WILSON:
Question. Who would make the decision to allocate it to one area or
another area?
Answer. It tended to be made either by the fund-raiser or the
finance director.
Question. Do you recall in this example why the money contributed
by Mr. Trie was allocated to the health care campaign in 1994?
Answer. I don't recall.
Question. Do you recall whether all funds that you received that
were not designated to go to a particular source were allocated to the
health care campaign in 1994?
Mr. Pierson. Could you repeat the question again? I am sorry, I
think there was a double part. Could you ask it again, please?
EXAMINATION BY MR. WILSON:
Question. Sure. Was all money that was not allocated to a certain--
was not designated by the contributor to go to a certain account
allocated to the health care campaign in 1994?
Answer. I don't know. I don't know that it was or was not.
Question. Do you recall the dates that contributions were accepted
for the 1994 health care campaign account? Maybe instead of just being
quite so obtuse, if you could just explain what the 1994 health care
campaign was. Was that literally a separate account into which money
would go?
Answer. I don't believe it was a separate account. I believe it was
separate internal accounting, but I believe all the contributions were
to the Democratic National Committee campaign--I mean Democratic
National Committee bank accounts. I don't think there were separate
accounts. I think internally, just for our accounting, we had separate
designations.
Question. Is it fair to say the money wasn't segregated into one
particular place? The check would be deposited into a general account?
Answer. That would be my understanding of it.
Question. Do you recall whether there ever were any separate
designated accounts into which checks were deposited? And I am asking
for at any time during your working at the DNC.
Answer. My knowledge of accounts were there was a DNC Federal
account, DNC non-Federal account, corporate account, there may have
been a PAC non-Federal account. But those are the different accounts I
recall.
Question. Do you recall any specific issue accounts, for example,
health care campaign or media fund purchases or anything?
Mr. Pierson. You are talking about bank accounts or internal
accounts?
Mr. Wilson. I am talking about bank accounts.
The Witness. As I stated earlier, my knowledge of accounts is what
I laid out. This designation is not referring to a separate bank
account, I don't think. My knowledge of seeing this is it was a
separate internal account within the finance department for internal
tracking. That would be my understanding of reading it today.
EXAMINATION BY MR. WILSON:
Question. On this format, the end of the lines, indicating
contributions to the health care campaign, there are what appear to be
codes. One is F-01 and the other is N-03. Do you know what those mean?
Answer. I don't know for certain, but my understanding would be
that these were probably personal, as it says in the top right corner,
individual contributions. So there is a $20,000 limit that an
individual can give to a party in a year. So that was probably, then
the ``F'' would mean the Federal account, and then the remaining money
would be designated, I assume, non-Federal and would be put into a non-
Federal account. That would be my read of it.
Question. Do you know what the numerals mean after the letters?
Answer. No.
Question. Do you know whether there was a system for providing
codes of this sort with a meaning?
Answer. I know that you needed to designate Federal from non-
Federal money. Other than that, I am not familiar with how accounting
is done.
Question. Is this a number that you would have entered on the check
tracking form?
Answer. No. It may have been required to enter in certain cases if
it was a Federal or non-Federal contribution, but I never made these
designations.
Mr. Wilson. I will mark this document Exhibit AS-3 for the record.
[Swiller Deposition Exhibit No. AS-3 was marked for
identification.]
EXAMINATION BY MR. WILSON:
Question. What was the health care campaign?
Answer. As you may recall, the President had an initiative to
reform health care. Internally, we thought that we may be able to, for
lack of a better word, like spice up our fund-raising if we talked
about a certain initiative that was going on that the committee was
supporting. So the campaign fund then became sort of a reaction to
that.
Mr. Wilson. If we could go off the record for just a moment.
[Brief Recess.]
EXAMINATION BY MR. WILSON:
Question. Back on the record.
I will show the witness a document which is marked DNC 3078820. The
heading is DNC Finance Executive Summary, date 12-3-96.
Have you ever met Mr. Trie's wife, Mrs. Wang Mei Trie?
Answer. Not that I recall.
Question. Again, you are listed on this document as the fund-raiser
for a contribution of $20,000 from Mrs. Trie. Did you have any contacts
with her about this contribution?
Answer. Not that I recall.
Question. Do you know who the solicitor of this contribution was?
Answer. It is not listed here, and I don't recall the contribution
or the transaction of it.
Mr. Wilson. I will mark this document Exhibit AS-4.
[Swiller Deposition Exhibit No. AS-4 was marked for
identification.]
EXAMINATION BY MR. WILSON:
Question. Did you attend the June 22nd, 1994, Presidential gala,
DNC gala?
Answer. Yes, I did.
Question. Did you contact Mr. Trie regarding a $100,000
contribution that he gave to the DNC in May of 1994?
Answer. I don't recall that contact, no.
Question. Do you recall discussing Mr. Trie's attendance at the
1994 gala?
Answer. No, I don't. Discussing----
Question. With Mr. Trie.
Answer. No, I don't.
Question. Do you recall having discussions with any of your
colleagues about Mr. Trie's attendance at the gala in 1994?
Answer. I don't.
Question. Were you ever asked to provide a recommendation for Mr.
Trie for an apartment that he was attempting to be the renter of at the
Watergate?
Answer. I did not. I don't recall that. It doesn't sound familiar.
Question. Did you know that David Mercer and Susan Levine had been
asked to provide a recommendation for Mr. Trie?
Answer. Not that I recall.
Question. Did you ever attend any events at Mr. Trie's apartment in
the Watergate?
Answer. Never.
Question. Did you ever speak with Martha Shoffner regarding Mr.
Trie's move to Washington?
Answer. I am not familiar with that individual.
Question. Have you ever met Martha Shoffner?
Answer. Not that I recall.
Question. Do you recall having any contacts with Mr. Trie in
relation to the August 1994 Presidential birthday fund-raiser?
Answer. No, I do not.
Question. I would like to provide a document for the witness. It is
marked DNC 1275756. It is a memorandum to Martha Shoffner from David
Mercer. It does not have the witness' name on it. I would ask you to
just take a moment to look through the content of this memo.
The memo discusses a meeting between Mr. Mercer and Mr. Trie in
1994. Did you attend this meeting?
Answer. Not that I recall, no.
Question. Did you ever attend any meetings with Mr. Trie in the
accompaniment of Mr. Mercer?
Answer. Not that I recall.
Question. The memo refers to a number of events or subjects, and I
just want to very quickly ask you a few questions about some of the
referenced issues.
In the first paragraph, there is a reference to a meeting before
Mr. Trie left for Beijing. Did you ever discuss with Mr. Trie any
travels that he took?
Answer. Not that I recall.
Question. Were you aware in 1994 that Mr. Trie was planning to
travel to Beijing?
Answer. Not that I recall, no.
Question. And the fourth paragraph of this memorandum discusses a
request for a letter inviting Mr. Trie to serve on the finance board.
Were you ever a participant in any discussions about Mr. Trie becoming
a member of the finance board at the DNC?
Answer. I was in discussions on the finance board as it relates to
Mr. Trie. Individually, I don't have a specific recollection of
specific conversations regarding it.
Question. Who was in charge of determining who would be on the
finance board of directors?
Answer. It was a collective effort of DNC staff.
Question. And who were the staff?
Answer. It would be Ms. Hardigan, Richard Sullivan, David Mercer,
Erica Payne, Peter O'Keefe. Any of the fund-raising staff, up to 20
individuals.
Question. Were you involved in that process?
Answer. Yes, I was.
Question. Were there any prerequisites for becoming a member of the
finance board of directors?
Answer. There weren't prerequisites, but we were going to ask
members to see if they could raise above the limit--not limit, above
the threshold for the trustee program; we were going to ask them to
raise I believe it was $350,000 in a year.
Question. Do you know whether Mr. Trie made a request to be put on
the finance board of directors?
Answer. I don't recall that. It was not made to me, but there was a
request made.
Question. The fifth paragraph of this memorandum discusses a
mission to China, and it refers to a Commerce Department mission to
China which was to commence on August 27th, 1994.
Did you have any discussions with Mr. Trie about his participating
in this Commerce Department mission to China?
Answer. Not that I recall, no.
Question. Did you know at the time that there was going to be a
Commerce Department mission to China?
Answer. I know there has been one. I don't recall when I became
aware of it.
Question. Do you recall any conversations or discussions about this
particular Commerce Department mission to China?
Answer. No, I don't.
Question. Do you recall whether you made any telephone
conversations on behalf of Mr. Trie about this trade mission to China?
Answer. Not that I----
Mr. Pierson. Made or had?
Mr. Wilson. Made.
Mr. Pierson. Telephone calls on behalf of Mr. Trie?
Mr. Wilson. Yes.
The Witness. Not that I recall, no.
EXAMINATION BY MR. WILSON:
Question. Were you involved in any conversations by telephone or in
person during which Mr. Trie's interest in any type of trade mission or
foreign trip with American governmental employees was discussed?
Answer. Not that I recall.
Question. Did you ever discuss Mr. Trie's financial contributions
with anybody at the White House?
Answer. Not that I recall, no.
Mr. Wilson. Just to back up for a moment, I will mark the document
we are discussing, Exhibit AS-5, for inclusion in the record.
[Swiller Deposition Exhibit No. AS-5 was marked for
identification.]
EXAMINATION BY MR. WILSON:
Question. Have you ever met an individual named Ng Lap Seng, also
known as Mr. Wu?
Answer. No, not that I recall.
Question. Have you ever had any telephone conversations with Mr. Ng
Lap Seng?
Answer. No, I have not.
Question. Do you recall whether Mr. Trie was ever invited to become
a member of the finance board of directors?
Answer. I believe he was. My recollection is he was.
Question. Do you know an individual named Ernest Green?
Answer. I do.
Question. When did you meet him first?
Answer. I believe I met him upon my return to the DNC, subsequent
to that, sometime in 1994.
Question. Do you know Jude Kearney?
Answer. I am sorry?
Question. Do you know Jude Kearney, K-E-A-R-N-E-Y?
Answer. I know him, yes.
Question. Have you met Mr. Kearney in person?
Answer. Yes, I have.
Question. And where have you met him?
Answer. In the '92 cycle, as I stated earlier, I was a fund-raiser
in the mid-Atlantic region. At that time Mr. Kearney was based in D.C.,
and I believe I met him in events and he assisted in some fund-raising
efforts.
Question. Did Mr. Kearney, after you first met him in, I believe
you said 1992, did he obtain a job with the government in Washington?
Answer. That is my recollection, that he did.
Question. Do you know where he was working after 1992?
Answer. I believe it was either the Commerce Department or at the
Treasury Department.
Question. Did you attend a breakfast with Mr. Green, Mr. Kearney,
Mr. Trie, and Mr. Ng Lap Seng in October of 1994 at the Hay-Adams
Hotel?
Answer. Not that I recall, no.
Question. Do you know Allen Weinstein?
Answer. The name is not familiar.
Mr. Lu. Was that Allen or Ellen?
Mr. Wilson. Allen.
EXAMINATION BY MR. WILSON:
Question. Do you know Nancy Jacobson?
Answer. Yes, I do.
Question. Who is Ms. Jacobson?
Answer. She was my supervisor in 1992 when I worked on the Clinton
campaign. She was again the finance director of the Inaugural Committee
when I served as the deputy finance committee. We stayed friendly while
I lived in Washington, but I have not spoken to her since approximately
6 months or longer.
EXAMINATION BY MR. WILSON:
Question. Do you know where she works?
Answer. My last knowledge of her employment was that she was
employed individually, working for herself on a contract basis.
Question. Does she have a connection with an organization called
Center for Democracy?
Answer. Not that I'm aware of. Not that I know of.
Question. Do you know of an organization called Center for
Democracy?
Answer. It's a familiar name, yes.
Question. Do you know what it does?
Answer. I do not.
Question. Have you ever discussed the activities of Center for
Democracy with Mr. Trie?
Answer. Not that I recall.
Mr. Pierson. Have you ever discussed contributions that Mr. Trie
might or--might have made or might have been considering making to the
Center for Democracy?
Answer. Not that I recall.
Question. Did you participate in setting up a meeting between Mr.
Trie, Winston Bank and Chairman Fowler in 1995?
Answer. Not that I recall.
Question. Did you ever participate in any discussions with Mr. Trie
about setting up a chapter of an organization called Democrats Abroad
in Taiwan?
Answer. Not that I recall.
Question. Do you know of an organization called Democrats Abroad,
based in Taiwan?
Answer. I know of an organization called Democrats Abroad, but not
one based in Taiwan, no.
Question. What is Democrats Abroad?
Answer. Just that. It's registered Democrats who are abroad for
work in countries throughout the world.
Question. Is it an organization that's independent of the DNC?
Answer. That's my understanding, yes.
Question. Did you assist with organizing a fund-raiser in November
of 1995 at the Car Barn in Washington, D.C.?
Answer. What was it?
Mr. Pierson. November of 1995. November 8, 1995.
The Witness. Not that I recall.
EXAMINATION BY MR. WILSON:
Question. Did you ever have any discussions with Mr. Trie about an
individual named Wang Jun, W A-N-G, J-U-N, attending a Presidential
coffee?
Answer. Not that I recall, no.
Question. Have you ever had--have you ever met a Wang Jun?
Answer. I have not.
Question. Have you had any conversations with him?
Answer. I have not.
Question. Do you know who he is?
Answer. I don't.
Question. How many times do you recall being contacted by Mr. Trie
or one of his representatives in 1995 and 1996?
Answer. I don't recall one contact.
Question. You don't recall any contacts at all?
Answer. That's correct, I don't recall any.
Question. Have you ever met an individual named Antonio Pan?
Answer. Not that I recall, no, the name is not familiar.
Question. Do you know whether Mr. Trie was ever invited to use the
President's box at the Kennedy Center?
Answer. Not that I know.
Question. Just generally speaking, was Mr. Trie considered a member
of the Trustee Program?
Answer. Yes. The time I was there, he was.
Question. And covering the entire time you were employed by the
DNC, do you recollect, and this is personally, any interaction with Mr.
Trie at all?
Answer. I saw Mr. Trie at some of our events. I think that was the
limit of our interaction. He may have stopped by the DNC--he did stop
by the DNC a few times where I would say hello, chat with him for a few
minutes. But I was primarily not a major contact of his at the DNC, so
I didn't have many conversations with him.
Question. Who did Mr. Trie contact at the DNC?
Answer. My recollection is that the majority of his contacts were,
I believe, with Mr. Mercer.
Question. Do you know whether he had contacts with Mr. John Huang?
Answer. Whether who did?
Question. Mr. Trie.
Answer. I have no knowledge if he had contacts or not.
Question. Do you know of any situations in which Mr. Trie contacted
any members of your staff?
Answer. Meaning Ms. Braziel, Ms. Burke?
Question. Correct.
Answer. Not that I recall, no.
Mr. Wilson. I'm providing the witness with a document which is
marked F 0015575. It's dated, or at least there is a number at the top,
7-21. It says, ``Notes for Ari.''
EXAMINATION BY MR. WILSON:
Question. And if you would, there's an arrow pointing to an entry
about halfway down the page?
Answer. Uh-huh.
Question. It's an arrow that was on the document as produced to us,
and it says, ``Charlie Trie has 4 SP and 2 WH,'' dash, dash, ``is this
right? I''--question mark. ``I thought it was 4 total,'' question mark.
Do you know what this means?
Answer. My understanding what this document looks like is--it was
regarding the events at the convention. Anne Braziel, myself, Nancy
Burke worked in coordinating some of the hotel accommodations for
trustees at the convention. Two of the hotels that we worked with were
Sutton Place and the Whitehall Hotel in Chicago. So my read of this
would be that, as it says, Charlie Trie has four Sutton Place rooms and
two Whitehall rooms. Is that right? I thought he only had four rooms.
That was her--this looks like a document that would have been put
together by Ms. Braziel. She was sort of coordinating the hotel efforts
hand on.
Question. Do you recall providing any assistance for Mr. Trie at
the convention?
Answer. Not as an individual; provided assistance to trustees
collectively. I don't recall specific assistance to Mr. Trie.
Question. Do you know whether he made any requests of you--of you?
Answer. Not that I have knowledge of that I recall, no.
Question. Did he make any requests of any of the people that you
were working with at the convention?
Answer. Well, it looked, from this document, it looks like he made
hotel requests, which we probably assisted him with. Other requests are
not familiar to me.
Mr. Wilson. This document is marked Exhibit AS-6.
[Swiller Deposition Exhibit No. AS-6 was marked for
identification.]
EXAMINATION BY MR. WILSON:
Question. Did Mr. Trie ever discuss his desire for appointment to a
commission or board, a Federal commission or board, with you?
Answer. I don't recall any discussion about this.
Question. Do you know of any conversations in which Mr. Trie's name
was brought up in conjunction to possible appointment in a commission
or a board?
Answer. Not that I recall, no.
Question. Did you know that Mr. Trie was interested in being
appointed to a Federal commission or board?
Answer. I think I've learned that information subsequent to the
campaign in some of the news accounts of it, but not that I recall.
Question. Did you ever have any discussions about Mr. Trie with the
White House Office of Presidential Personnel?
Answer. Not that I recall, no.
Question. Do you know whether either yourself or any individuals in
your office were contacted by the White House Office of Presidential
Personnel about Mr. Trie?
Answer. I don't recall any contacts, no.
Question. Do you know of anybody else at the DNC who was contacted
about Mr. Trie by the White House Office of Presidential Personnel?
Answer. Not that I recall or have any knowledge of, no.
Question. Do you know of Mr. Trie ever making a contribution to the
DNC before 1994? And I'm just asking you, when--I mean, the question
really should be, do you recall when Mr. Trie first made a contribution
to the DNC?
Answer. My recollection is that Mr. Trie was a member of the
Trustee Program and returned to the DNC. Whether that was through
contributions or funds raised, I don't recall.
Question. Have you ever met an individual named Tony Shsu, S-H-S-U?
Answer. Not that I recall, no.
Question. Have you ever heard of an organization called the Chy
Corporation, C-H-Y Corporation?
Answer. No.
Question. Do you know Pauline Kanchanalak?
Answer. Yes, I do.
Question. When did you first meet Ms. Kanchanalak?
Answer. I believe I met her in the '92 campaign, somewhere when I
was serving as a fund-raiser in the Mid-Atlantic region.
Question. Do you recall where you met her?
Answer. I don't recall the circumstances of meeting her. I know
that she was involved with some of the events in some of the fund-
raising we did in the D.C. metro area.
Question. Do you recall whether she was a contributor, a financial
contributor, in 1992?
Answer. That would be my, in retrospect, reflection now, my
understanding why I would have met her, because she was a contributor.
Question. Did Ms. Kanchanalak or her sister-in-law Mrs. Kronenberg
or any of her employees ever contact you or anyone in your office while
you were an employee at the DNC?
Answer. The second time or any time?
Question. Actually, let's--we'll break that down. The first time
you were at the DNC, and I'll ask you----
Answer. I believe I had some contacts with her during the time. I
don't recall the context of them. But she was an individual who we may
have asked her to participate. I can't remember the contacts because I
didn't do that year, but I don't know.
Question. And turning to the second stint, your second stint at the
DNC, do you recall whether she or her sister-in-law or any of her
employees contacted you?
Answer. I did have some contact with Pauline and with Ms.
Kronenberg.
Question. And do you remember the context of any of those contacts?
Answer. I remember few. One was a request by Ms. Kanchanalak to
attend a luncheon that the White House was hosting with the Queen of
Thailand. She wanted to be--she requested me to assist her in being
included in that event. I recall discussing with her an upcoming White
House event which she was going to receive an invitation to. And I had
a--my final contact with her was subsequent to the '96 election. She--
we had a discussion about her contributions to the DNC at which time
she inferred that they were not her contributions, but her mother-in-
law's contributions.
Question. Do you recall whether you ever arranged for Ms.
Kanchanalak to meet with administration officials?
Answer. Not that I recall, no.
Question. Was it ever brought to your attention that Ms.
Kanchanalak had an interest in the Bureau of Labor Statistics and
becoming somehow involved with the Bureau of Labor Statistics?
Answer. I don't recall that at all.
Question. Did you ever organize lunches for any DNC contributors at
the White House Mess?
Answer. I was aware that some lunches were attended by donors, but
I'm trying to recall when I participated in setting them up, and I
don't.
Question. Do you have any recollection of--of Ms. Kanchanalak or
Ms. Kronenberg attending a White House Mess luncheon?
Answer. Not that I recall, no.
Mr. Wilson. I provide the witness with a document which is marked F
0040590. It's a memorandum to Mr. Swiller from Georgie Kronenberg,
dated May 11, 1995.
Mr. Pierson. My I make a suggestion that we mark the exhibit when
you first identify the document. That way we will have a number we can
refer to.
Mr. Wilson. Certainly. I'll mark this exhibit as AS-7.
Mr. Pierson. Thank you.
[Swiller Deposition Exhibit No. AS-7 was marked for
identification.]
EXAMINATION BY MR. WILSON:
Question. The part that I'm particularly interested in is the
postscript at the very end of the memoranda which states, ``On a
different matter, please let me know the amount to reimburse you for
the luncheon at the White House Mess which Susan Lavine has kindly
organized for us.''
Mr. Pierson. Have we established whether or not he's seen this
before?
Mr. Wilson. I was just about to ask.
EXAMINATION BY MR. WILSON:
Question. Are you familiar with this document, that exhibit?
Answer. It's not familiar to me. But----
Question. Do you recognize there's a handwritten notation on the--
towards the top of the first page that says, ``File,'' and that's
underlined?
Answer. Yes.
Question. Is that your handwriting?
Answer. It looks like it is, yes.
Question. Do you have any recollection of any discussions about Ms.
Kronenberg providing reimbursement for a White House Mess lunch?
Answer. It--it's not familiar, no.
Question. Do you know how--how you would have resolved the request
that is made in the postscript? Do you recall passing this along to
somebody else's attention?
Answer. No, I don't.
Question. Did you ever have any involvement with people's
reimbursements for White House mess lunches that you remember?
Answer. No, I don't.
Mr. Wilson. I have a document which is marked Exhibit AS-8, which
is provided to the witness. It's a memorandum to the file. It's been
premarked F 0018925. It's from Mr. Swiller, and it's regarding a
conversation with Ms. Kanchanalak.
[Swiller Deposition Exhibit No. AS-8 was marked for
identification.]
Mr. Pierson. Can I see the last document, please, just for a
moment?
Thank you. Sorry.
Mr. Wilson. Sure.
EXAMINATION BY MR. WILSON:
Question. The memo refers to a telephone conversation that you had
with Ms. Kanchanalak on November 14, 1996. Do you know--assuming that
the--the information contained is correct, did you, in fact, call Ms.
Kanchanalak?
Answer. My recollection is she called me.
Question. And do you know why she called you?
Answer. Yeah. The context of this memo, she had received some calls
about contributions that were being indicated that she had made to the
Party. She indicated to a reporter that they were, indeed, not her
contributions, but that of her mother-in-law. I guess that became an
issue because in our FEC reports or in our internal reporting, it was
reflected that the contributions were under Pauline's name and not
Praitun's name, which I believe is the name of her mother-in-law. So
this was then a conflict which was brought to the attention of our
press department, brought to the attention of our counsel, and my
conversation clearly states, you know, the context of it--this document
states the context of the conversation.
Question. Do you know whether Ms. Kanchanalak called anybody else
at the DNC before you to impart the information contained in this memo?
Answer. Not that I have knowledge of, no.
Question. Okay. Do you know whether she had any subsequent
conversations with other DNC employees about the issues discussed in
this memorandum?
Answer. Not that I know of, no.
Question. Do you know why she called you?
Answer. I believe she had tried to call a few people at the DNC,
and some others may not have been available. And I doubt if I was
available. And the fact that I had been one of the many contacts of the
DNC, she called me as well.
Question. Prior to your telephone conversation on November 14th
with Ms. Kanchanalak, were you under the impression that contributions
that she had conveyed to you were made by her?
Answer. That was very clearly my understanding, yes, that the
contributions she made were her contributions.
Question. Had she ever told you that the contributions were made by
her?
Answer. I don't recall that as a topic of discussion in specific,
no.
Question. Did Ms. Kanchanalak, during the discussion on November
14, make any reference to Ms. Kronenberg's contributions and the source
of Ms. Kronenberg's contributions?
Answer. Not that I recall, no.
Question. Do you know whether the memo that we're reviewing now
embodies all of the things that Ms. Kanchanalak and you discussed, or
were there other matters that you discussed during the telephone
conversation?
Answer. No, I believe this covers--the memorandum pretty well
covers the conversation, yes.
Question. Did you ever, subsequent to your telephone conversation
with Ms. Kanchanalak on November 14, '96, did you review her past
contributions to the DNC?
Answer. Yes.
Question. Did you prepare a memorandum or any written work product
that came from that review?
Answer. I don't recall written work product, no.
Question. Did you discuss this conversation with anybody else at
the DNC?
Answer. Yes.
Question. And who did you talk with at the DNC about your November
14 conversation?
Mr. Pierson. Counsel, the DNC is not represented here. You may be
inquiring into frivolous conversations, and the privilege may be
waived, but we're in a position where, if this--if you're asking about
conversations with counsel for the DNC, I'm going to have to instruct
the witness that he's going to have to decline to describe the content
in order to reserve the privilege. It's not ours, but it's also not
ours to waive.
Mr. Wilson. I understand.
Mr. Pierson. So any conversations you had with any lawyer for the
DNC about this subject, you can describe who you talked to and that
this was the subject, but beyond that, we'll assert the privilege.
Okay. Can you answer the question?
The Witness. I had a conversation with the counsel.
EXAMINATION BY MR. WILSON:
Question. And the counsel is?
Answer. Joseph Sandler.
Question. Did you have any conversations with anybody else at the
DNC about your conversation with Ms. Kanchanalak?
Answer. As I recall, I had conversation with Mr. Sullivan and Ms.
Supina, S-U-P-I-N-A.
Question. In your conversations with Mr. Sullivan and Ms. Supina,
did they indicate to you whether they were under the expression that
Ms. Kanchanalak was making the contributions personally?
Answer. Yes, they were under the same impression I was, that her
contributions were made personally.
Question. Now, subsequent to the conversation, you indicated that
you did check into Ms. Kanchanalak's previous contribution history. Did
you accumulate any materials at this time?
Answer. I recall reviewing some of the past check tracking forms
that were attached to contributions she had made, yes.
Question. Did you create a file and put the information into a--
into an individual file?
Answer. I don't recall the creation of a file. I recall reviewing
the documents.
Question. The document we're reviewing now is--has a title which is
``Memorandum to the File.'' Do you recall where it--where you put this
document after you had drafted it?
Answer. I--my recollection is that I submitted it to our legal
counsel.
Question. Did you keep a copy of this document for your own files?
Answer. I believe I may have, yes, as I said earlier, and it would
have been in the files under ``trustee donor,'' so I probably put it in
the Kanchanalak file.
Question. Did you provide a copy of this document to anybody else
at the DNC, apart from Mr. Sandler?
Answer. I may have--as I recall, I reviewed the document with Mr.
Sullivan, but I don't recall providing him an individual copy.
Question. Did you transmit this document to anybody outside of the
DNC, give it to anybody outside of the DNC?
Mr. Pierson. Other than counsel?
The Witness. No.
EXAMINATION BY MR. WILSON:
Question. When you looked back over Ms. Kanchanalak's previous
contribution history, did you come across any indication of the
material that she communicated to you during your conversation on
November 14th, any indication that she had communicated to anybody that
she would not be making the contributions in her own name?
Answer. No, I did not.
Question. When--when Ms. Kanchanalak mentioned to you that she had
made an arrangement with Mr. Riser during----
Mr. Pierson. Raiser.
Mr. Wilson. Raiser. Thank you.
EXAMINATION BY MR. WILSON:
Question [continuing]. During the 1992 campaign, did she tell you
whether this was communicated to anybody else at the time?
Answer. My recollection is that she indicated it was just a
discussion between the two of them, and that was the limit of the
communication.
Question. And do you know what position Mr. Raiser had in 1992?
Answer. Mr. Raiser was one of the two finance cochair's for the
Clinton for President campaign. He was based in Washington, D.C.
Question. Now, you've indicated that you had discussions with Mr.
Sandler about your telephone conversation from November 14th. What did
you tell Mr. Sandler?
Mr. Pierson. We have to assert the privilege. And it's--it's only
because we're preserving it for the DNC. It's not our privilege to
waive.
Mr. Wilson. So it's fair to assume that anything related to the
context of Mr. Sandler will be covered by--you will assert privilege
over it at this time?
Mr. Pierson. Yes, on this topic.
Mr. Wilson. Sure.
Mr. Pierson. And I should tell you that there are circumstances on
the Senate side in which the DNC has waived the attorney/client
privilege, but since I don't know what those are, and I don't know what
the attitude towards the House side is----
Mr. Wilson. Right.
Mr. Pierson.--I just have to preserve the privilege.
Mr. Wilson. Certainly.
EXAMINATION BY MR. WILSON:
Question. Have you had any subsequent conversations or
conversations subsequent to November 14 of 1996 with Ms. Kanchanalak?
Answer. No, I have not.
Question. Do you know where she called from? The memo says
Thailand, but do you know where in Thailand she called from?
Answer. No I don't.
Question. Did she indicate to you whether she intended to return to
the United States at any time?
Answer. I don't recall that being part of the discussion.
Question. Did she discuss with you why she was in Thailand?
Answer. I don't recall that either.
Question. After the November 14 conversation, did you communicate
the contents of the telephone conversation to Ernst & Young, the
accounting firm conducting the background review of campaign
contributions?
Answer. As I stated earlier, I don't recall having any contact
whatsoever with any member of Ernst & Young.
Question. Do you know whether anybody else at the DNC communicated
the contents of your telephone conversation with Ms. Kanchanalak to
Ernst & Young?
Answer. Not that I have knowledge of.
Question. Did you discuss with Mr. Sullivan or Ms. Supina whether
anybody should communicate the contents of your telephone conversation
with Ms. Kanchanalak to Ernst & Young?
Answer. That was never part of a discussion as I recall.
Mr. Pierson. Can I have just 2 minutes to talk to Minority counsel
just outside in the hallway? It will take 2 minutes.
Mr. Wilson. Yes, if we can go off the record.
[Discussion off the record.]
[Brief recess.]
Mr. Wilson. Back on the record, please.
EXAMINATION BY MR. WILSON:
Question. Do you know John Huang?
Answer. Yes.
Question. When did you first meet Mr. Huang?
Answer. I believe I first met Mr. Huang during the 1992/93
Inaugural Committee, my service there.
Question. When did you first hear about Mr. Huang?
Answer. Probably prior to that, part of my responsibility is we're
coordinating lists of the top fund-raisers and contributors for--across
the country, for the finance department of the Inaugural Committee. I
believe that's when I probably first ran across the name.
Question. Did you ever have any contacts with Mr. Huang while he
was employed by LippoBank in California?
Answer. Not that I recall, no. Let me restate. I believe that my
contacts with him during the Inaugural, my understanding is that he may
still at that time have been an employee of the bank.
Question. Were--were those social contacts, or did you have any
fund-raising contacts with him?
Answer. He assisted in a contribution that I believe came from the
LippoBank or from him for part of the events going on during the
Inaugural Committee, so--as far as fund-raising, that was the context
of it.
Question. Did you speak with anybody regarding Mr. Huang's
appointment to the--his position at the Commerce Department?
Answer. Not that I recall, no.
Question. Did you have any contacts with Mr. Huang while he was at
the Commerce Department?
Answer. I don't recall the specific conversations, but I believe I
did have a contact with him.
Question. Did he contact you this period?
Answer. I believe I made the initial outreach to Mr. Huang in the
context of my returning to the DNC in '93, '94.
Question. And if you could describe in more detail the reason for
your contacting him?
Answer. Mr.--My--there are two contacts. My recollection is that
Mr. Huang had been a fund-raiser for the '92 campaign effort. I called
him, I believe, to secure from him any names that I may then reach out
to in the context of my position at the DNC, and also his wife was a
contributor to the party at that time, but lived in California. So I
may have made contacts to him in reference to his wife's participation
with the party.
Question. Did you--have you ever communicated directly with Mr.
Huang's wife?
Answer. I have met her. I've talked to her.
Question. Where have you met her?
Answer. I met her at functions in Washington, galas.
Question. Did you ever seek Mr. Huang's assistance in setting up
meetings while he was at the Department of Commerce?
Answer. Not that I recall.
Question. Did you ever contact Mr. Huang about arranging for
individuals' participation in trade missions while he was at the
Department of Commerce?
Answer. Not that I recall.
Question. How did Mr. Huang come to be hired as a fund-raiser at
the DNC?
Answer. I only know what I've learned in the last few months. I
don't--didn't know the context then. So if you want me to reflect upon
what I----
Question. If you would. What do you know now about Mr. Huang's
coming to be hired as a fund-raiser at the DNC?
Mr. Lu. And you want his recollection even if it's from news
accounts?
Mr. Wilson. Well, I would like to know what he knows now, yeah.
Mr. Lu. Okay.
The Witness. As I said, my recollection is what I've heard in the
news, that Mr. Huang was brought to the attention of Mr. Sullivan by I
believe it was Mr. Ickes or someone else that he was someone interested
in assisting in fund-raising.
EXAMINATION BY MR. WILSON:
Question. Were you aware of--of Mr. Huang meeting with individuals
at the DNC just prior to his being hired at the DNC as a fund-raiser?
Answer. No. I--not that I recall.
Question. Did you ever see him over at the DNC prior to his being
offered the position as a fund-raiser of the DNC?
Answer. Not that I recall, no.
Question. Did Mr. Huang ever visit you at the DNC?
Answer. Prior----
Question. Prior to his becoming a member of the fund-raising staff?
Answer. Not that I recall, no.
Question. Did you ever visit Mr. Huang at the Department of
Commerce?
Answer. No I did not.
Question. Did Mr. Huang ever speak with you about his becoming a
member of the fund-raising staff at the DNC prior to his becoming a
member of the fund-raising staff?
Answer. Not that I recall.
Question. When Mr. Huang was hired by the DNC, did you ever have
discussions with him about fund-raising staff training?
Answer. He and I individually?
Question. Yes.
Answer. Not that I recall, no.
Question. Did you ever have any discussions with Mr. Huang about
the law as it applies to fund-raising in political campaigns?
Answer. Not that I recall.
Question. Do you know whether he was given instructions on the law
as it pertains to fund-raising and political campaigns?
Answer. I don't recall his specific tutoring of those laws. We, on
a--maybe once a year, as a finance staff got together and briefed in a
group. But I don't know of John receiving any specific individual
instruction on the law.
Question. Do you recall ever--do you recall ever attending any
seminars or instructional meetings about the law and campaign financing
with Mr. Huang?
Answer. I don't recall if Mr. Huang was at any of them. My
recollection would be that he would be, because the whole staff was
invited to them. But Mr. Huang traveled a bit, so I don't know if he
was at the ones which I attended.
Question. Did Mr. Huang ever seek your advice or counsel on any
campaign contributions that he was soliciting?
Answer. No, he did not.
Question. Did he--did he ever discuss with you--did he ever discuss
with you your fund-raising activities?
Answer. Not that I recall, no. He--but--I was being the director of
the Trustee Program, he may have had individuals who he solicited
contributions that made them trustees, then he would then provide
myself with those names. That would sort of be the context.
Question. Aside from the transmission of the name and the check and
basic information about the contributor, did you have any discussions
with Mr. Huang about any individuals who were being solicited for
campaign contributions?
Answer. No, not that I recall.
Question. Do you remember whether he ever sat down with you and had
a conversation about what he was doing as a fund-raiser at the DNC?
Answer. I don't recall it.
Question. Do you recall whether you called him and asked him things
about--how his job was going or what he was doing as fund-raiser for
the DNC?
Answer. I don't recall that type of conversation.
Question. Is it--is it fair to characterize, then, your
recollection is not having any contacts with Mr. Huang at all on any
substantive issues while he was employed at the DNC?
Answer. We had social contacts, but substantive, that's correct.
Question. Do you know anything about Mr. Huang's compensation at
the DNC?
Answer. Only what I've read subsequent to the campaign in the news.
Question. Prior to November of 1996, did you know anything about
Mr. Huang's compensation?
Answer. I remember knowing that he was a compensated employee and
wasn't in the position as a volunteer, but I didn't know the sum that
he was being compensated.
Question. Did you know--did you know whether there was an agreement
to supplement his compensation, depending on how much--how many
contributions he raised?
Answer. I had no knowledge of that. If I had, I would have asked
for it for myself.
Question. Were you ever involved with Mr. Huang in setting up fund-
raising events?
Answer. The only context I can think of was when we worked--when
the finance staff as a team worked on the large gala. He and I directly
on one specific event, no, there was never an occasion with just the
one of us.
Question. And that was the 1996 gala that you're referring to?
Answer. Yes.
Question. Were you aware of any controversy within the DNC
regarding Mr. Huang's being involved in setting up events that included
the President?
Answer. Not prior to November of '96.
Question. Did any of your DNC colleagues have discussions with you
about Mr. Huang's job performance while he was a fund-raiser at the
DNC?
Answer. Not that I recall, no.
Question. Did you ever have any communications with White House
employees during which you discussed Mr. Huang's performance as a DNC
fund-raiser?
Answer. No, I don't recall any.
Question. Did you have any conversations with any employees of
other executive branch agencies during which you discussed Mr. Huang's
fund-raising responsibilities?
Answer. No, not that I recall.
Question. Did Mr. Huang ever request you to provide him with lists
of contacts in order for him to approach people to solicit donations?
Answer. I believe it--we may have discussed a list of California
contributors, but I don't recall him requesting contacts from me to
provide them.
Question. Did you ever provide him with any information?
Answer. I believe we had a discussion on who were active trustee
participants from California, since he had participated in that region.
Question. Did you send him anything written following this
discussion?
Answer. I may have provided him a copy of the State lists for
California of trustees.
Question. Did Mr. Huang specifically request information about
California?
Answer. I can recall that being a--a discussion in the context that
he had been active in California fund-raising prior.
Question. Did you ever send Mr. Huang a list of all of the trustees
or managing trustees at any time when he was a fund-raiser at the DNC?
Answer. No, not that I recall.
Question. Do you know whether he ever requested such a list?
Answer. I have no recollection of such request.
Question. Did--are you aware of any contacts between Mr. Huang and
any of the individuals that you have named as being part of your office
staff?
Answer. No, I'm not aware of contacts.
Question. Did Mr. Huang ever share any information with you? Did he
ever provide you with a list of individuals or names?
Answer. I don't recall ever getting names from him.
Question. Do you recall ever receiving any information from Mr.
Huang?
Answer. As I mentioned earlier, in the context of being a trustee
director and providing people that made the requisite contribution,
that was the context, I believe, the information he provided me.
Question. Did he ever provide anything other than a check and a
check tracking form, if indeed he provided you that? I mean, did you
receive checks and check tracking forms from Mr. Huang?
Answer. No. I never received checks from Mr. Huang. I don't
remember the format he used to provide the names and addresses. They
may have been photocopies of check tracking forms, or he may have typed
out a list, but I don't recall.
Question. Now, why would Mr. Huang have occasion to provide any
information to you?
Answer. All fund-raisers provided the trustee department with
information of, you know, as I stated earlier, people who had raised
the requisite amount of money or contributed, so that they were
correctly listed, properly listed on our trustee list. So in that
context, he would have had provided that information.
Question. Did he send you the check tracking forms of all of the
people that he solicited contributions from?
Answer. No, he did not.
Question. Did he--did he send you check tracking forms from a
number of individuals from whom he solicited contributions?
Answer. As I stated earlier, I don't recall how he provided the
information for the trustee lists, whether it was photocopies of
tracking forms or if it was a typed list. People provided that
information to my department both ways. Some just gave us an additional
photocopy, others would do a more thorough-type list, and I don't
remember how John, Mr. Huang provided that information.
Question. Do you recall whether he ever provided for you additional
biographical information on any individuals?
Answer. I don't recall that.
Question. Did you ever participate in any discussions with DNC
colleagues about whether Mr. Huang was providing information sufficient
to provide the FEC with the required information on campaign donors?
Answer. I don't recall such discussion. I don't recall.
Question. Do you know whether Mr. Huang traveled out of the United
States while he was employed as a fund-raiser at the DNC?
Answer. I have since read about that since the November election,
but prior to that I did not know that.
Question. Do you recall any discussion about Mr. Huang traveling
prior to--and this--this I'm asking for your recollection. Prior to
November 1996, do you recall any discussions relating to Mr. Huang and
his travel schedule?
Answer. No, I don't recall any.
Question. Do you know who would have approved Mr. Huang's travel
requests?
Mr. Pierson. Any travel requests?
Mr. Wilson. Correct.
The Witness. No, I--in the context of how I would do it, it would
be the finance chairman or the finance director. I don't know if it was
the same for John, but I--I don't know how he had his travel approved.
EXAMINATION BY MR. WILSON:
Question. And does your answer indicate that that's the process
that you would follow----
Answer. Un-huh.
Question [continuing]. When you were seeking----
Answer. Correct.
Question [continuing]. Travel approval?
Answer. Correct. The process I assume most finance staff proceeded
with.
Question. What did you have to do to obtain approval for travel?
Answer. Generally, you didn't have to obtain it, you were told that
you were going somewhere, so you needed to just fill out a form that
was then submitted to the person who had purchased the tickets with
your times and dates of departure.
Question. Do you know whether Mr. Huang ever solicited
contributions--strike that question, please. was there a system at the
DNC to keep track of how much individual fund-raisers raised?
Answer. I don't know if there was a system set up for that, but you
could run that, my understanding, through the AS400. And as we looked
at documents earlier, where it said ``fund-raiser,'' you could, I
believe, sort by that field and get a list run of who was involved in
raising what funds.
Question. Do you recall ever seeing a list of the aggregate
contributions raised by Mr. Huang?
Answer. No, I don't recall ever seeing that.
Question. Did you ever print up for yourself a list of the
aggregate contributions for which you were named as the fund-raiser?
Answer. I would have to request that, because I wasn't familiar
with running the lists on the AS400 system.
Question. Did you ever request that for yourself? And I'm speaking
about for yourself as the fund-raiser, not Mr. Huang at all. But did
you ever request that you run a list of all of the contributions that
you were listed as the fund-raiser of?
Answer. I never requested it. I recall seeing one, but it was not
at my request.
Question. Where did you see the one that you recall seeing?
Answer. I believe Ms. Stirk may have had a copy of it.
Question. Do you know if she--why she would have had a copy of it
such a list?
Answer. I don't recall. No.
Question. Do you know whether spreadsheets indicating aggregate
contributions produced by individual fund-raisers were printed up for
everybody?
Answer. I have no knowledge of that.
Question. The printout that you just mentioned with aggregate
contributions wherein you were listed as the fund-raiser, did that
include all of the years for your employment as a fund-raiser at the
DNC?
Answer. I believe it was--as I recall, it was in--sometime in '95,
so it included the year and a half prior to it.
Question. Did anybody at the DNC ever tell you that Mr. Huang might
be accepting contributions from non-U.S. citizens?
Answer. No. I don't recall ever having such a discussion.
Question. Did anybody from outside the DNC ever tell you that Mr.
Huang might be accepting contributions from non-U.S. citizens?
Answer. Not that I recall, no.
Question. Do you recall any discussions during which it was
suggested that Mr. Huang might be accepting contributions from non-U.S.
citizens?
Answer. No. I don't recall it.
Question. Do you recall when you last had personal contact with Mr.
Huang?
Answer. I believe it was sometime during the summer of '96.
Question. Did you ever visit him in his offices when he was a DNC
fund-raiser?
Answer. As I recall, he did not have an office. It was sort of in a
cubicle area. And I may have visited him and seen other people or--but
I don't recall him having a physical office space.
Question. Where was the cubicle located?
Answer. My recollection is it's in the basement level of the DNC.
Question. And where was your office?
Answer. On the third floor.
Question. And the cubicle that Mr. Huang used, what office was it
attached to? Or who was--who had the other cubicles around that
cubicle?
Answer. The--what we call like the road staff, the road fund-
raisers, people who travel in and out from events around the country.
There was an area where they had a desk for a little while while they
were in town .
Question. Were you aware if Mr. Huang had an office at another
location in Washington?
Answer. I was not aware of that.
Question. Do you know if anybody at the DNC has been in contact
with Mr. Huang subsequent to November of 1996?
Answer. I don't know of any contacts.
Question. Have you had any contacts with Mr. Huang since November
of 1996?
Answer. I have not.
Question. Did you ever have any discussions with Mr. Huang as to
why he left the Department of Commerce?
Answer. I don't recall such a discussion.
Question. Did you ever express any concern to either Mr. Huang or
DNC colleagues about a fund-raiser at the Sheraton Carlton Hotel in
Washington, D.C., that Mr. Huang was an organizer of?
Answer. I don't recall the event.
Question. Did you know of the event at the time?
Answer. It does not sound familiar.
Question. Were you aware of Mr. Huang's participation in organizing
a fund-raiser at the Shilla temple in California? Were you aware prior
to 19--to November of 1996 about this particular fund-raising event?
Answer. I was not.
Mr. Wilson. I've provided the witness with a document which has
been marked exhibit AS-9. It was premarked with a Bates number that was
cut off in the copying process, not cut off by us, but cut off by the
people that copied it before it was transmitted to us. Its Bates Number
begins DNC 312837, and then the other numbers are obscure. It's titled
``DNC Finance Executive Summary,'' and there's a handwritten notation
on the bottom.
[Swiller Deposition Exhibit No. AS-9 was marked for
identification.]
EXAMINATION BY MR. WILSON:
Question. Do you recognize the handwriting on this?
Answer. I do.
Question. You do.
Answer. Uh-huh.
Question. And whose handwriting is that?
Answer. To me it looks like the handwriting of mat Gobush Matt
Gobush.
Question. And who is Mr. Gobush?
Answer. He had served at some--for some time as the staff assistant
for the trustee program.
Question. What is the TRULIST?
Answer. It would it would be trustee list. My recollection would be
an abbreviation for trustee list.
Question. And do you know why this notation has been written on
this document?
Answer. No, I don't recall.
Question. Was--was Mr. Huang a member of the Trustee Program prior
to his going to the Department of Commerce?
Answer. My recollection was that he was on the trustee list when I
returned to the DNC in November of--in December of '93.
Question. And do you recall whether his name was taken off the
trustee list?
Answer. I recall that he may have--in looking at this, he may have
lapsed as a trustee, because he did not maintain the level of
contribution or fund-raising necessary to be a trustee. So, you know,
it would lead me to think that this was then--he was then deleted from
the trustee list, because he was no longer an active participant at the
requisite level.
Question. Do you know if anybody contacted him to attempt to obtain
from him requisite contributions to get him back on the trustee roster?
Answer. Not that I recall.
Question. When--when Mr. Huang was an employee of the DNC, were you
aware of whether he had any relationship with Charlie Trie?
Answer. I did not know if they had or did not have a relationship.
Question. Do you know whether they ever had worked together on a
fund-raising issues?
Answer. Not that I'm--not that I have specific knowledge of, no.
Question. Did Mr. Trie in any of his conversations with you ever
mention Mr. Huang to you?
Answer. Not that I recall, no.
Question. Did Mr. Huang in any conversations with you mention Mr.
Trie?
Answer. No, not that I recall.
Question. I would like to go off the record if we could.
[Discussion off the record.]
[Lunch recess, 1:00 p.m.]
EXAMINATION BY MR. WILSON:
Question. If we could go back on the record, please.
Have you ever met Johnny Chung?
Answer. I have.
Question. And where have you met Mr. Chung?
Answer. I met him at a few events we did while I was at the DNC,
and I also met him when he came to the DNC. I visited with him there. I
also paid a visit to his office in California.
Question. When did you visit his office in California?
Answer. It was while I was working on an event in California in
spring, I think either late March-April of 1995.
Question. And why did you visit his office?
Answer. I was responsible for a fund-raiser that we were working on
in California, in Los Angeles, so I was contacting all of the trustees
who had been supportive in the past, trying to get their support for
that event, or to identify other individuals who may also want to be
supportive.
So in that context, I contacted all the trustees on the list, and
Johnny was one of many who I visited with.
Question. What was the fund-raiser that you were working on?
Answer. We did a high dollar couples events at the home of Steven
Spielberg that the President attended. The contributions were made to
the DNC for those who attended.
Question. And when you visited Mr. Chung, what did you discuss at
his office?
Answer. I remember discussing a few things. I remember he had an
office that had pictures of Mr. Chung and every elected official I
think since Lincoln on the walls, Republican and Democrat, and I mean
we discussed the fund-raiser. I remember he was bringing additional
couples and I told him that that would require additional contributions
for the event.
Question. Do you recall how much Mr. Chung contributed to that
event?
Answer. My recollection is he made one individual check
contribution of $125,000.
Question. And how many individuals did he take as guests to that
fund-raiser?
Answer. I believe total there were three couples, he and his wife
included.
Question. When you visited him at his office, was it a few days
before the fund-raiser you are speaking of, or was it well in advance
of the fund-raiser you are speaking of?
Answer. I was only in California about two weeks prior to the
event, and it was in that time frame, so in the two weeks prior.
Question. Did Mr. Chung ever visit you in your office at the DNC?
Answer. Yes, he did.
Question. And approximately how many occasions did Mr. Chung visit
you in your office?
Answer. We had--no visits were necessarily scheduled for me. He
would come to the DNC on occasion by himself or with a few individuals
and would stop by. So I would say maybe three or four times that he
stopped by my office to say hello while he was visiting the DNC.
Question. On these occasions, did he ever bring other individuals
with him?
Answer. On a couple I recall he did.
Question. Who did he bring with him on the visits he made to your
office?
Answer. I remember him--I don't remember the individuals, but I
remember him identifying them as being partners of his or business
associates.
Question. And did he discuss what their businesses were?
Answer. Not that I recall, no.
Question. Do you have any general recollection of what the
individuals that came with him to your office did for a living?
Answer. I don't.
Question. Approximately how many contributions--actually, if you
could, just describe the various contributions that you solicited from
Mr. Chung?
Answer. I don't recall other contributions that I solicited
directly from him. That was the major contribution that I was involved
with. There are other people who worked with Mr. Chung. I am trying to
think--I don't remember dates and other contributions, that is one that
sticks out, the one I described earlier.
Question. Who else at the DNC worked with Mr. Chung?
Answer. Mr. Sullivan, Mr. Fowler, Mr. Fowler's executive assistant,
Carol Khare. Those were the primary contacts.
Question. Do you know whether Mr. Chung ever contacted members of
the staff in your office?
Answer. No, I believe he dealt with me in my department.
Question. Did you keep a trustee file for Mr. Chung?
Answer. I am sure it was included with the other members of the
trustees, yes.
Question. Do you recall the contents of this file?
Answer. I assume like other files, it would have, as I discussed
earlier, copies of checks, tracking forms, a bio. If we sent letters or
correspondence to him, we may have kept a record of those.
Question. Do you recall whether you kept any photographs of Mr.
Chung with other dignitaries?
Answer. I don't recall keeping any photographs at all of any
individuals, so I don't think I would have any.
Question. Did you, prior to November of 1996, have any misgivings
about Mr. Chung as a contributor?
Answer. No, I did not.
Question. Had you ever asked anybody to perform any background
research on Mr. Chung?
Answer. Not that I recall, no.
Question. Did you ever receive any background research about Mr.
Chung?
Answer. I don't recall that.
Question. From other offices?
Answer. No, I don't recall ever receiving any.
Question. How frequently would you communicate with Mr. Chung?
Answer. It was sporadic. I tended to communicate with him closer to
an event that may be in California that he would be interested in
participating in, and at that time I could contact him maybe two or
three times in the weeks prior. Other than that, it was infrequent.
Once every other month would be a high number, I think.
Question. I have a document which I will mark Exhibit AS-10.
[Swiller Deposition Exhibit No. AS-10 was marked for
identification.]
EXAMINATION BY MR. WILSON:
Question. I will provide that for the witness. It is a memorandum
to Richard Sullivan from David Mercer, and it is a list that had been
requested purportedly by Mr. Sullivan for a Vice Presidential luncheon
on 9-21, which is presumably 1994. The document is dated September 14,
1994.
It mentions that this is a pool of some of the best raisers and
writers to draw from.
Do you recall ever having seen this document?
Answer. I do not.
Question. Was there a list kept of the more significant
contributors or the best campaign solicitors from outside of the DNC
staff that you were aware of in the DNC?
Answer. Not to my knowledge, no.
Question. Did colleagues of yours at the DNC have any discussions
with you about Mr. Chung and mention to you that he was one of the
better or best fund-raisers from amongst contributors to the DNC?
Answer. We discussed that he made large contributions. I don't
recall him being much of a fund-raiser.
Question. Are you aware of Mr. Chung ever soliciting contributions
from anybody else?
Answer. Not that I can recall, no.
Question. Is it fair to say then that your interactions with him
led you to believe that he was contributing money merely himself and
not soliciting funds from anybody else?
Answer. Correct.
Question. Did you ever have any concerns that funds contributed by
Mr. Chung might not be his own funds?
Answer. No, I did not.
Question. Did you ever have any conversations where anybody else at
the DNC expressed concerns that funds contributed by Mr. Chung might
not be his own funds?
Answer. No, not that I can recall.
Question. Did you ever have any conversations with anybody outside
of the DNC about Mr. Chung's fund-raising contributions?
Answer. Not that I can recall, no.
Question. Do you have any recollections of whether anybody at the
White House ever contacted you to ask you any questions about Mr.
Chung?
Answer. No, not that I can recall.
Question. Do you know whether anybody from any of the Executive
Branch agencies contacted you and asked questions about Mr. Chung?
Answer. I don't recall that.
Question. Do you recall any instances where Mr. Chung asked you to
do anything for him?
Answer. No, I don't recall specific instances. I recall--Johnny--
Mr. Chung was always concerned with receiving photographs of events, so
he was always calling after events to get--to expedite sort of getting
him photographs of himself with the dignitary at the event. But those
were the events that come to mind.
Question. Did you ever help to arrange for Mr. Chung to meet with
any administration employees?
Answer. No, not that I recall.
Question. Did you ever receive any requests from Mr. Chung about
government trade missions?
Answer. No, I did not.
Question. Did Mr. Chung ever mention John Huang to you?
Answer. I don't recall that in any conversation, no.
Question. Do you recall whether you ever made any requests of any
White House employees on behalf of Mr. Chung?
Answer. No, not that I recall.
Question. Were you aware in 1995 that Mr. Chung and a number of
Chinese businessmen attended a Presidential radio address?
Answer. I have subsequently found out about it, but at the time I
didn't. I don't have a recollection of knowing about it.
Question. Do you recollect any conversations wherein somebody else
might have mentioned Mr. Chung's attendance at a radio address with the
President?
Answer. No, I don't.
Question. In the subsequent knowledge that you have gained about
this particular event, did you know--do you know any of the individuals
that Mr. Chung attended the radio address with?
Answer. No, I don't.
Question. Had you ever met any of those individuals?
Answer. I may have, but none of the names are familiar to me.
Question. Were you aware of any requests being made by anybody at
the DNC of the National Security Council about Mr. Chung?
Answer. No, I was not.
Question. Did anybody ever mention to you prior to November of 1996
that Mr. Robert Suettinger had once described Mr. Chung as a hustler?
Answer. No.
Question. Were you ever aware that--did anybody ever suggest to you
that Mr. Chung had ever been approached by either White House or DNC
employees in conjunction with contributions to retire debts from the
White House Christmas party?
Answer. That is not something I am familiar with, no.
Question. I am providing the witness with a document marked Exhibit
AS-11.
[Swiller Deposition Exhibit No. AS-11 was marked for
identification.]
EXAMINATION BY MR. WILSON:
Question. This is addressed to Mr. Johnny Chung. It is dated August
21, 1995, and the signature blocks are those of Richard Sullivan and
Mr. Swiller, and the text of the letter is one sentence: ``Thought you
would be interested in the enclosed.'' Do you have any recollection of
signing this letter?
Answer. I don't.
Question. Do you have any recollection of this letter at all?
Answer. No.
Question. This takes me away from Mr. Chung for a moment, but did
you keep copies of signed letters in your files?
Answer. On occasion. As I referred to earlier, and this may be a
case of it, we would send letters accompanying photographs from events
that were DNC-sponsored events in which donors would attend the event
with the President. This may be such a case where enclosed items were
photographs.
Question. Did you personally keep a correspondence file of all the
correspondence that you sent out to individuals?
Answer. I didn't, because the scale was so high, and, you know, it
was letters like these which really were one sentence, two sentence
letters. It would have been, I think, a wasteful exercise.
Question. What types of signed correspondence would you keep?
Answer. I would once in awhile keep similar correspondence like
these or letters of invitation to an event. I would sometimes keep
those on file because people would sometimes say they never received
them and I could refer back to the reference point.
Mr. Lu. Before we move away from this document, I think all of us
concede the document is unsigned. I just want the record to be clear
that is an unsigned letter and there has been no testimony it was even
sent out.
EXAMINATION BY MR. WILSON:
Question. Were you aware or have you ever been aware that Mr. Chung
spoke with Richard Sullivan about going on a trade mission to China
with Commerce Secretary Ron Brown?
Answer. That is not something that is familiar to me, no.
Question. I am providing the witness with a document marked Exhibit
AS-12, which is a March 1, 1995 dated document to Kathleen from Richard
Sullivan/Ari Swiller.
[Swiller Deposition Exhibit No. AS-12 was marked for
identification.]
EXAMINATION BY MR. WILSON:
Question. Do you recall ever having seen this document before?
Answer. I don't recall it.
Question. The memo refers to a planned meeting between--or a
meeting requested by Mr. Chung. Do you know whether this meeting ever
took place?
Answer. I can't say for certain.
Question. Did you typically prepare briefing materials for Chairman
Fowler or any other DNC employees involving meetings with individuals
who were trustee members?
Answer. Yes.
Question. Do you recall ever participating in any meetings with Mr.
Chung and Chairman Fowler?
Answer. I can--there is one that comes to mind, yes.
Question. Do you remember when that meeting was?
Answer. I believe it was sometime in 1995. I don't remember the
exact date.
Question. And what was discussed at that meeting?
Answer. The reason why it comes to mind, I remember Mr. Chung
informing Mr. Fowler that he was going to make a personal effort to try
to win the freedom of a gentleman named Harry Wu, I believe--Henry Wu
or Harry Wu. At the time he had become imprisoned and it was a
highlighted case by the Chinese government.
Question. And do you recall what Mr. Fowler said in this meeting?
Answer. I don't recall what he said to Mr. Chung. I recall
afterwards we were sort of in disbelief at Mr. Chung's idea that he
could play a role. But I am sure, you know, Mr. Fowler was pleasant in
his conversation with him.
Question. Do you have a recollection of the sense of what was
communicated to Mr. Chung?
Answer. I am sure Mr. Fowler thanked him for his support of the DNC
and wished him luck in his endeavors, but I don't recall any offer of
support from the DNC, because we never got involved in those sorts of
affairs.
Question. Do you know whether Mr. Fowler told Mr. Chung that the
DNC would not be supportive of Mr. Chung's endeavors?
Answer. I think it was understood. I don't remember him directly
saying that.
Question. Do you know if Mr. Chung met with Richard Sullivan and
Chairman Fowler at any time in 1995 at the White House mess?
Answer. I don't have recollection of such a meeting, no.
Question. You had mentioned earlier that Mr. Chung had made--I
should ask you this, because I don't recall exactly what you said. But
did Mr. Chung ever contact you specifically about obtaining photographs
that had been taken with himself and other individuals?
Answer. Yes, he did.
Question. Did he ever contact you in regard to photographs that
were taken of himself and business associates at the Presidential radio
address?
Answer. No, he did not, that I recall.
Question. Do you recall which photographs he did contact you about?
Answer. The photographs I recall being requested were ones in
connection to the event where I solicited the contribution from Mr.
Chung at the home of Mr. Spielberg.
Question. Do you recall any other requests from Mr. Chung about
photographs?
Answer. No, that is the one that comes to mind.
Question. Did Chairman Fowler or Richard Sullivan ever request that
you find photographs involving Mr. Chung?
Answer. Not that I can recall, no.
Question. Did you ever provide photographs for Mr. Fowler or
Chairman Dodd or Mr. Sullivan for their review prior to their being
sent out to individuals?
Answer. Not as far as Mr. Fowler or Mr. Dodd. On occasion if I
couldn't identify certain people in a group of photos I was given, I
would ask Mr. Sullivan for his input on who they might be. But I don't
recall ever being requested to provide them with photos, no.
Question. I will ask the same question for after photographs have
been sent out. Did anybody after the fact ask you to find a photograph
or track down a photograph that had been sent out previously to an
individual for purpose of reviewing the photograph?
Answer. ``Anyone'' meaning?
Question. I apologize, ``anyone'' meaning Chairmen Dodd, Fowler, or
Mr. Sullivan?
Answer. Mr. Sullivan may have. I don't recall requests like that
ever coming from Mr. Fowler or Mr. Dodd.
Question. Do you know an individual whose name is Sheng Huaren, S-
H-E-N-G H-U-A-R-E-N?
Answer. The name is not familiar to me, no.
Question. Are you familiar with the China Everbright Group?
Answer. I am not.
Question. Do you recall whether you have ever heard that name
before?
Answer. I don't recall hearing it before, no.
Question. Do you recall ever having heard the name of a Mr. Qiu
Qing, which is spelled Q-I-U Q-I-N-G?
Answer. No, I don't recall that name.
Question. Have you ever met Roger Tamraz?
Answer. Yes, I have.
Question. Where have you met Mr. Tamraz?
Answer. I met Mr. Tamraz for the first time at the Democratic
National Committee.
Question. Was this the convention or a meeting?
Answer. At the committee. At the headquarters.
Question. Okay. And what was the occasion of meeting Mr. Tamraz?
Answer. I had, as my department often did, sent solicitations to
businesses across the country informing individuals and corporations
about the program and encouraging them to support it. In response to
that, I received a call from a partner of Mr. Tamraz who indicated to
me that he or his partner were interested in participating at the
trustee or possibly the managing trustee level and wanted to come to
Washington to discuss that.
Since the level is high, they had offered to come to Washington, I
asked to set up a meeting with Mr. Fowler at the DNC. The person who
came representing the company was Mr. Tamraz, and that is the first
time I met or spoke to him, was when he came to the DNC.
Question. The initial contact from Mr. Tamraz or his associate,
what was the form of that contact?
Answer. They phoned me.
Question. And do you recall when Mr. Tamraz came and met with you?
Answer. It was in July of 1995.
Question. How long was the meeting after the telephone call took
place?
Mr. Pierson. Are you talking about the meeting in Chairman Fowler's
office?
EXAMINATION BY MR. WILSON:
Question. No, let me clarify this, because I don't want to muddy
this issue. Is it correct to say that you met with Mr. Tamraz, just the
two of you the first time?
Answer. That is not correct.
Question. Okay. Just if you could, just explain. Mr. Tamraz came in
and met with yourself and other individuals. Who were the other
individuals?
Answer. His initial meeting was with myself and Chairman Fowler,
and after that meeting, there was immediately following a follow-up
meet with myself and Mr. Tamraz which Mr. Pastrick attended part of.
Question. And the first meeting, where did that occur?
Answer. In Mr. Fowler's office at the Democratic National
Committee.
Question. And where did the second meeting occur?
Answer. It occurred in an office adjacent to mine that was used--
that was set aside for the finance chairman.
Question. Did you ever prepare any memoranda about the initial
meeting with Mr. Tamraz?
Answer. I don't recall in this case the memoranda I proposed for
this meeting, but it was customary that I did provide a little bit of
information.
Question. I will provide the witness with a document which was
marked Exhibit AS-13. If you could take a minute just to look at this.
[Swiller Deposition Exhibit No. AS-13 was marked for
identification.]
Mr. Pierson. For the record, counsel, this is several documents.
The first one is DNC 3116350. The last one is DNC 3116355. They appear
to be sequential.
Mr. Wilson. Just to clarify, it appears the last two pages of the
document may be out of sequence, 55 followed by 54. I just want to
check that you have the same.
Mr. Pierson. Mine are in sequence.
Mr. Wilson. Okay.
[Discussion off the record.]
EXAMINATION BY MR. WILSON:
Question. The first page of that which I provided you has just the
handwritten notation ``Roger Tamraz'' on it. Do you recognize this
writing?
Answer. I do not.
Question. Turning your attention to the document marked DNC
3116354, which is a memo from Mr. Sullivan, Mr. Swiller, to Roger
Tamraz, it discusses contributions and the date is March 28th, 1996. Do
you recall preparing this memorandum?
Answer. I recall being asked for the information on this
memorandum, correct.
Mr. Pierson. That wasn't what he asked you. He asked you whether
you prepared it.
The Witness. I don't believe I prepared this memorandum.
EXAMINATION BY MR. WILSON:
Question. Did you supply the information that is in this
memorandum?
Answer. Yes.
Question. Who asked you for that information?
Answer. My recollection is that Mr. Sullivan did.
Question. Did you keep records of contributions that Mr. Tamraz
made to organizations other than the DNC?
Answer. Yes, I did.
Question. And for what purpose did you keep such records?
Answer. To keep a sum of contributions Mr. Tamraz made to
Democratic affiliated campaigns.
Question. Who provided you with this information?
Answer. In the case of a lot of these contributions, Mr. Tamraz
forwarded them to the DNC office.
Question. What did Mr. Tamraz forward to the DNC office?
Answer. The contributions.
Question. And by that do you mean he actually forwarded a check
directly to the DNC office?
Answer. Correct.
Question. And in situations like that, what would the DNC do with
those things?
Answer. They tended to be sent to the entity that they were
directed to with an accompanying letter.
Question. Were records of those contributions kept by the DNC?
Answer. I believe in some cases they were, yes.
Question. And how were the records kept?
Answer. My recollection is that there was a list comprised by a
woman named Theresa Stark of contributions sent to DNC that were for
entities that weren't the DNC.
Question. Do you know whether this information was entered in the
AS 400 computer database?
Answer. I don't know for certain, no.
Question. Did Mr. Tamraz ever discuss with you campaign
contributions?
Answer. Yes, he did.
Question. Did you have discussions about campaign contributions to
entities other than the DNC?
Answer. Yes, I did.
Question. Did you provide any recommendations as to whom he should
make campaign contributions?
Answer. Yes, I did.
Question. Why did you--the campaign contributions, just referring
to the ones on the memorandum we are examining, the March 28, 1996
memorandum, why did you suggest that Mr. Tamraz contribute to the
entities listed on this memo?
Answer. I don't recall the exact conversation on the ones that sit
on this memo.
Question. Had you ever received instructions from any other DNC
employees as to where campaign contributions might be made?
Answer. From Mr. Tamraz?
Question. From anybody, other than the DNC.
Answer. Yes, I did.
Question. Who would give those instructions?
Answer. The ones I recall were either Mr. Fowler or Mr. Sullivan.
Question. Did you ever receive any memoranda that outlined these
types of instructions?
Answer. Not that I can recall, no.
Question. Is your recollection that the communications you had were
solely verbal?
Answer. Yes, that is correct.
Question. Did you discuss these particular contributions with Mr.
Tamraz?
Answer. The ones listed on the memorandum?
Question. Yes.
Answer. I don't recall a specific discussion of these.
Question. Did you forward this memorandum to Mr. Tamraz?
Answer. I did not forward it to him.
Question. Do you know whether Mr. Sullivan is responsible for
forwarding this to Mr. Tamraz?
Answer. My only recollection is he requested some of the
information. I don't know if it was then forwarded.
Question. Do you know why it was suggested that he provide a
contribution to the Virginia Democratic Party?
Answer. I recall there being a request that he provide it to the
Virginia Legislative Campaign Committee in connection with the '95
election cycle, but I don't recall that specific to the Democratic
Party contribution.
Question. And was that information communicated to you or the
suggestion that Mr. Tamraz--if you could just state again, who was it
that suggested to you that Mr. Tamraz might make a contribution to the
Virginia Democratic Party?
Answer. My recollection is that direction came from Mr. Fowler.
Question. Do you recall whether you had a meeting with Mr. Fowler
to discuss where campaign contributions should be directed?
Answer. I don't recall a formal meeting. I recall sort of a meeting
in passing.
Question. Do you know if Ms. Khare, Carol Khare, was in contact
with Mr. Tamraz at any time in 1996?
Answer. I don't know for certain, no.
Question. Did you ever discuss Mr. Tamraz with anybody at the DNC
except for Mr. Sullivan and Mr. Fowler?
Answer. I discussed with Mr. Pastrick and Marvin Rosen.
Question. The meeting that you earlier described between Mr.
Fowler, Mr. Tamraz and yourself, do you recall the date of that
meeting?
Answer. I don't recall an exact date. I believe it was in July of
1996.
Question. Do you recall how long the meeting lasted?
Answer. I believe it was a half-hour to 45 minutes.
Question. And what was discussed at that meeting?
Answer. I remember that Mr. Tamraz stated that he was very
interested in being supportive of the President and of the party, that
he was encouraged by the President's policies. He went on to describe
how he wanted to be financially supportive.
Mr. Fowler thanked him for that. Mr. Tamraz went on to discuss and
provided a copy of a Newsweek article, I believe he had the magazine
with him, which talked about a pipeline construction that his company
was undertaking in Russia, and I remember him describing that the
project hadn't physically started, but that the steps to get it were
well on their way, and that he had many corporate clients who were
supporting his effort. He was just informing us of sort of who he was
and what his business was.
Question. Do you know how many times Mr. Fowler met with Mr.
Tamraz?
Answer. I don't.
Question. If you could just--the document I provided you earlier,
which was provided because I believe it came from a file of some sort,
you have indicated that you don't recognize the handwriting on the
first page of it, but the second page, the third page and the fourth
page have what appear to be a memorandum to Mr. Fowler from Alejandra
Castillo. If you could take just a moment to review that memorandum.
Mr. Pierson. For the record, these are pages DNC 3116351 through
6353.
EXAMINATION BY MR. WILSON:
Question. Did you receive a copy of this memorandum?
Mr. Pierson. At any time before----
EXAMINATION BY MR. WILSON:
Question. At--well, I must be clear on this. Did you receive a copy
of this memorandum at any time in 1995?
Answer. I don't recall specifically receiving it.
Question. Do you recall receiving a copy of this memorandum at any
time before November of 1996?
Answer. I don't recall a specific time of receiving it.
Question. But do you recall whether you did receive this
memorandum?
Mr. Pierson. Before the election?
Mr. Wilson. Before the election.
The Witness. I don't recall a certain time of receiving it, no--or
receiving it.
EXAMINATION BY MR. WILSON:
Question. The third page of this memorandum, in the second
paragraph, in the conclusions section, states that, in a conversation
held with Ari Swiller yesterday, Mr. Tamraz has expressed his desire to
contribute $300,000 to the DNC. Did you speak with Ms. Castillo about
your meeting with Mr. Tamraz?
Answer. I recall having discussions with Ms. Castillo about Mr.
Tamraz. I don't recall the specific discussions.
Question. Do you recall what she asked you?
Answer. I think she was inquiring whether I knew some of the
information that has been provided in this document, and I believe it
may have been the context of my discussion with Mr. Tamraz.
Question. The first paragraph of this conclusion section on the
third page of the memorandum indicates that it is clear that Mr. Tamraz
has several problems pending before the international business
community. Did Ms. Castillo discuss with you any of the specifics of
what she knew about Mr. Tamraz?
Answer. I remember either seeing in news articles or hearing from
her some of the items that are brought up in this document that refer
to business problems or problems pending in the international business
community.
Question. In the first paragraph of the memorandum, in what is the
second sentence, it states, as a potential managing trustee member, Mr.
Tamraz' business dealing may have potential, if not definite--if not
definite political and ethical implications on the DNC fund-raising
operations.
Did you have any discussions with anybody at the DNC prior to
November of 1996 about the implications Mr. Tamraz' business dealings
might have for the DNC?
Answer. I believe I did, yes.
Question. And who did you talk to?
Answer. I believe I talked to Ms. Castillo and possibly--my
recollection would be Mr. Sullivan or Mr. Pastrick.
Question. And what was discussed when you spoke with Ms. Castillo?
Answer. As I stated earlier, some of the concerns that she
highlights in this memo I think are part of that discussion.
Question. Now, had she communicated these concerns to you for the
first time? You had not heard of these concerns before she spoke to
you; is that correct?
Answer. As I recollected--in reflecting, that's correct. I may have
seen articles. I don't know the timing--if I saw the articles, we had
the discussion, she brought them up with the articles. I don't remember
the sequence, but--I didn't have a long-standing prior knowledge, no.
Mr. Pierson. May I have a moment, please?
[Witness conferring with counsel.]
Mr. Pierson. If you would like to add to your answer please.
The Witness. Yes. Mr. Tamraz, during our discussion, mentioned--I'm
sorry, during my meeting with Mr. Fowler and Mr. Tamraz, he mentioned
sort of in passing that he had a controversial background, which is
something that I think came up in discussions following with Ms.
Castillo--in the following conversations that I may have had with other
DNC folks, that we mentioned that as well.
EXAMINATION BY MR. WILSON:
Question. Prior to your meeting with--the first meeting with Mr.
Tamraz, a meeting that Mr. Fowler attended, did you yourself do or did
you request anybody else to do any background research on Mr. Tamraz?
Answer. Not that I recall, no.
Question. Did you communicate to anybody the nature of the
controversial background that you just mentioned Mr. Tamraz brought to
everybody's attention?
Answer. I don't remember him--sorry. Restate the question.
Question. My understanding from what you just said was that Mr.
Tamraz himself brought up controversial background in your meeting with
yourself and Mr. Fowler. Once you learned of that during that meeting,
did you bring that to anybody else's attention?
Answer. I don't recall specifically doing that. I may have brought
it to the attention of Ms. Castillo as she was preparing this memo. In
follow-up, I may have also mentioned it to Mr. Pastrick following our
meeting with Mr. Tamraz, that he had mentioned something about this.
Question. Did Ms. Castillo tell you or mention to you that she was
preparing a memorandum about Mr. Tamraz?
Answer. I don't remember her telling me before preparing it or
providing it and saying, I have a memorandum. I don't remember there
being a sequence where she first informed me and then provided it.
Question. Did you provide her with any information prior to the
drafting of this memorandum?
Answer. In my conversation, I may have referenced the article in
NewsWeek which Mr. Tamraz had referenced in his discussion with Mr.
Fowler and I, and I may have had some discussion with her about the
context of our conversation with Mr. Fowler.
Question. Had you seen the NewsWeek article?
Answer. Not prior to my meeting with Mr. Tamraz.
Question. After you met with Mr. Tamraz, did you see that NewsWeek
article that you just discussed?
Answer. He had it in the meeting.
Question. Did he provide a copy of the article to you?
Answer. I believe he left a copy, yes.
Question. Do you recall whether he left any other material or
information?
Answer. Not that I remember, no.
Question. Did you have any discussions with Ms. Khare about Mr.
Tamraz' background?
Answer. I don't recall any discussions with Ms. Khare, no.
Question. Do you know whether Ms. Khare made any inquiry's about
Mr. Tamraz' background of anybody else other than yourself?
Answer. Not that I'm aware of, no.
Question. Do you know--do you have any knowledge of whether this
memorandum was circulated to anybody other than the addressee of the
memorandum, other than to Mr. Fowler?
Answer. Not that I recall, no.
Question. Do you know if Mr. Tamraz had subsequent discussions with
either yourself or Chairman Fowler about his oil pipeline proposal?
Answer. I don't know of his discussions with others. I do not
recall any discussion with me about the pipeline following that initial
conversation.
Question. Do you know if Chairman Fowler ever offered any
assistance to Mr. Tamraz in meetings with the Federal officials? And I
ask that in terms of did you know that before November of 1996?
Answer. No, I did not.
Question. Did Chairman Fowler tell Mr. Tamraz or discuss with Mr.
Tamraz contributions to the DNC at the meeting you attended with the--
the first meeting you attended with Chairman Fowler and Mr. Tamraz?
Answer. Did Mr. Fowler discuss it?
I think Mr. Fowler thanked him for Mr. Tamraz' willingness to be
supportive. I recall that during--the figures and how contributions
were made were not discussed at that time.
Question. Is it correct to say that, at that point, Mr. Tamraz had
not made a contribution to the----
Answer. That's correct.
Question [continuing]. To the DNC?
Did you have--ever have any discussions with anybody at the DNC
prior to November 1996 of whether the--anybody in the Clinton
administration was being supportive of Mr. Tamraz' oil pipeline
project?
Answer. I don't--no, I do not.
Question. Did you ever talk to anybody in the administration--and
by that I mean any executive branch or agency officials, nonDNC
employees--about the Tamraz oil pipeline proposal?
Answer. Not that I recall.
Question. Did you ever get any requests from anybody else outside
of the DNC prior to November of 1996 about the Tamraz oil pipeline
project?
Answer. Not that I recall.
Question. Did you ever have any discussions about Mr. Tamraz being
banned from a commerce trade board?
Answer. I'm not familiar with that. No.
Question. Do you know if Ms. Khare had any discussions with
Department of Commerce Employees about Mr. Tamraz?
Answer. Not that I'm familiar with.
Question. Just referring back to the meeting between yourself and
Mr. Fowler and Mr. Tamraz, what did Mr. Tamraz indicate that he was
willing to contribute?
Answer. During my meeting with he and Mr. Fowler, there was--no
indication was made.
Question. Was there any discussion at that meeting of contributions
to entities other than the DNC?
Answer. There was not.
Question. Do you know why Mr. Fowler later communicated that some
of Mr. Tamraz' contributions would be--it would be appropriate to have
them routed to other entities than the DNC?
Answer. My understanding in the case of the Virginia legislative
campaign committee - or council--it was designated there because their
election was--they had a '95, an off-year election. So there was a
certain urgency to support their campaign effort.
Question. And what about the Louisiana contribution? Was there a
reason for that?
Answer. I don't recall.
Question. Do you know if anybody other than Ms. Castillo in the
format of the memorandum that we've just been discussing brought any
concerns about Mr. Tamraz to Mr. Fowler's attention?
Answer. Not that I'm aware of, no.
Question. Did anybody communicate concerns about Mr. Tamraz to you
directly?
Answer. Other than in conversations with Ms. Castillo I'm not
aware--I don't recall anyone else communicating concerns.
Question. Once--once Mr. Tamraz did make his contributions, is
there any one person that was designated the primary contact between
the DNC and Mr. Tamraz?
Answer. Initially, I was his contact. But subsequent to my first
few contacts with him, I think he began to work more exclusively with
Marvin Rosen.
Question. And in light of the concerns that Ms. Castillo outlined
in her memorandum to Chairman Fowler, did you think it was appropriate
for the DNC to accept contributions from Mr. Tamraz?
Mr. Pierson. Can I just interpose an objection?
Mr. Wilson. Sure.
Mr. Pierson. We've got a temporal disconnect. He was--he can tell
you that he saw the Castillo memorandum. So he can't tell you that, in
light of what's in the memorandum, he thought anything. But I know he
has some substantive testimony to give to you on the subject, so I
don't want to interrupt your line of questioning here.
Mr. Wilson. Right.
Mr. Pierson. I just think the two don't connect.
Mr. Wilson. I understand.
EXAMINATION BY MR. WILSON:
Question. Given your communications with Ms. Castillo about Mr.
Tamraz, did you have any concerns about Mr. Tamraz contributing to the
DNC?
Answer. I recall having some reservations, yes.
Question. Did you communicate those to anybody?
Answer. I believe I communicated them to Ms. Castillo. I may have
communicated them to Mr. Sullivan.
Question. And did you tell anybody else about your concerns?
Answer. Maybe Mr. Pastrick. But I'm not even sure there. But those
would be the people, I think.
Question. Did you ever speak with Sheila Heslin or anybody else at
the National Security Council about Mr. Tamraz?
Answer. I'm not familiar with her. I don't recall any conversations
that I had with people at the National Security Council, no.
Question. Prior to 19--November of 1996, do you recall anybody
contacting you about Mr. Tamraz?
Answer. Anyone?
Question. And--I'm puposefully being very broad. Anybody from----
Mr. Pierson. Outside the DNC?
Mr. Wilson. Yeah. Outside the Democratic National Committee.
The Witness. Outside--I don't recall, outside of the people we've
discussed, anyone making inquiries of me of Mr. Tamraz.
EXAMINATION BY MR. WILSON:
Question. Apart from the--the communications that we've just
discussed with Ms. Castillo, did you ever hear anything about Mr.
Tamraz seeking political leverage to advance his oil pipeline proposal?
Mr. Pierson. Up to the election?
Mr. Wilson. Prior to November, 1996.
The Witness. No, I don't recall asking for a leverage.
EXAMINATION BY MR. WILSON:
Question. Were you in contact with Mr. Tamraz after the--after the
meeting with Chairman Fowler and Mr. Tamraz and yourself?
Answer. Yeah, immediately following the--that meeting, Mr. Tamraz--
as I stated earlier, Mr. Tamraz, Mr. Pastrick and myself had a separate
meeting where we discussed contributions more directly.
Question. Do you know if Mr. Tamraz attended DNC events at any time
after your initial contact with him?
Answer. Yes, I believe he did.
Question. Do you know what events he did attend?
Answer. I can't recall the specific events, but I do recall seeing
him at events. I don't know which ones exactly.
Question. What type of events do you recall seeing him at?
Answer. Fund raisers. Fund-raising galas with dinners.
Question. Do you know--did you know, prior to November, 1996,
whether Mr. Tamraz met with nonDNC officials or government employees
after the time that you first met him and before November of 1996?
Answer. No, I was not aware of it.
Question. Did you ever have any discussions with Chairman Fowler
about Mr. Tamraz visiting the White House?
Answer. I don't recall specific discussion regarding that, no.
Question. Just very generally, do you have any recollection of--of
Mr. Fowler discussing Mr. Tamraz and attempts to meet with people in
the White House?
Answer. No, I don't have any recollection of that.
Question. Were you aware at any time before November, 1996, that
the White House did have objections to Mr. Tamraz attending events in
the White House?
Answer. No, I was not aware of that.
Question. Do you have any knowledge of meetings involving Mr.
Tamraz and Mr. Sullivan and Marvin Rosen in October of 1995?
Answer. I'm not aware of those specific--that specific time or
meeting.
Question. Do you have any knowledge, just in a general sense, of
Tamraz meeting with Richard Sullivan and Marvin Rosen?
Answer. As I stated earlier, I was initially his contact at the
DNC. But, soon after, his primary contact became Mr. Rosen; and I know
that they he met or spoke on the phone on occasion. I don't know the
specific times or--or who else was in attendance, but I know that his
primary contact became Mr. Rosen.
Question. Are you aware of any telephone calls made by Mr. Fowler
to employees of the National Security Council?
Answer. Not prior to recent revelations of it, no.
Question. Did--did Chairman Fowler ever ask for information about
Mr. Tamraz--ask you for information about Mr. Tamraz after that initial
meeting that you attended with Mr. Tamraz and Mr. Fowler?
Answer. I don't recall any requests, no.
Question. Did Chairman Fowler ever communicate any concerns to you
about Mr. Tamraz at any time after the initial meeting that you--that
the three of you had?
Answer. Not that I can recall, no.
Question. Do you recall any discussions with Mr. Fowler about Mr.
Tamraz or that involved Mr. Tamraz after your initial discussion or
after your initial meeting?
Answer. As I stated earlier, Mr. Fowler at some point had indicated
to me that a--that I make a request of Mr. Tamraz to designate some of
his contributions to Virginia legislative campaign. That's a
conversation that sticks to mind. Other conversations, I don't recall.
Question. Do you recall whether there were any conversations?
Answer. I don't.
Are you finished with this?
Question. I think we are. Let me just have a quick review of it.
Do you--do you recall whether you kept a file for Mr. Tamraz among
your trustee files?
Answer. I don't--I--I'm sure I did. I don't recall specifically,
but he was a trustee, and we had files on all of them. Yes.
Question. Do you know Eric Hotung?
Answer. I know who he is.
Question. Have you ever met him?
Answer. No, I've not.
Mr. Pierson. Counsel, when you come to a convenient stopping place,
can we have several minutes, please?
Mr. Wilson. Let's go off the record.
[Recess.]
Mr. Wilson. If we can go back on the record, please.
EXAMINATION BY MR. WILSON:
Question. Just one follow-up question on the materials we were
discussing about Mr. Tamraz and Exhibit 13. If I could provide again
the memorandum from Ms. Castillo to Chairman Fowler, the cc is to
yourself and to Carol Khare. Why would Ms. Khare have received this
memorandum?
Mr. Pierson. If you know.
Mr. Wilson. To the extent you know.
The Witness. To the extent I know, she was Mr. Fowler's executive
assistant and sort of like an alter ego. She received some of the
information Mr. Fowler received.
EXAMINATION BY MR. WILSON:
Question. Do you know whether in Mr. Tamraz' case she did any
follow-up investigation about Mr. Tamraz for Chairman Fowler?
Answer. Ms. Khare?
Question. Yes.
Answer. Not to my knowledge.
Question. Did you ever speak with Mr. Hotung?
Answer. No, I had never done that.
Question. Had you ever received any contacts from Pat O'Connor
about Mr. Hotung?
Answer. No I have not.
Question. Do you know Pat O'Connor?
Answer. I do.
Question. And do you know what he does for a living?
Answer. My understanding is he is an attorney and a lobbyist.
Question. And how do you know Mr. O'Connor?
Answer. He's been a long-time Democratic fund-raiser and supporter.
I've met him through DNC events and his support of the DNC and fund-
raising efforts.
Question. Has Mr. O'Connor ever had any official discussions with
you outside of the social context because he--had you ever worked with
Mr. O'Connor in an official capacity?
Answer. I don't believe I have, no.
Question. Do you recall whether you helped to arrange any meetings
for Mr. Hotung?
Answer. No, I don't recall that.
Question. Have you had any interaction at all with Mr. Hotung?
Answer. I have not.
Question. Do you know either James or Mochtar Riady?
Answer. I know who they are.
Question. Have you ever met either James Riady or Mochtar Riady?
Answer. I have not.
Question. Have you ever spoken with either of them?
Answer. I have not.
Question. Have you ever been asked to arrange introductions for
them to administration officials?
Answer. I have not.
Question. Do you recall ever having assisted them in any way?
Answer. No, I do not recall that.
Question. Do you know either Arief or Soraya Wiriadinata?
Answer. I do not know them. They at some point became trustees, but
I've never met with them or spoken with them.
Question. Did you solicit contributions from them?
Answer. Never.
Question. Do you know who did?
Answer. My recollection is that John Huang did.
Question. Do you recall whether you've ever had requests to do
anything for Mr. or Mrs. Wiriadinata?
Answer. I don't recall that at all.
Question. Do you know Yogesh Gandhi?
Answer. Only what I've read. I've never met him, and I've never
been involved with him.
Question. Have you ever been asked to assist him in any way?
Answer. No, I've not.
Mr. Wilson. I've given the witness a document that's marked Exhibit
AS-14. It is a letter to President Clinton from an individual named
Richard Agins. It does not have Mr. Swiller's name on it anywhere. If
you could take just a moment to review this.
[Swiller Deposition Exhibit No. AS-14 was marked for
identification.]
Mr. Pierson. For the record, it is dated August 14, 1996; and it
bears number EOP 05587. There may be another number, but that's all
that appears.
EXAMINATION BY MR. WILSON:
Question. This is a letter from an attorney in New York to
President Clinton, and it discusses a purported arrangement between
Chairman Fowler and an organization wherein Chairman Fowler was
purportedly promised two videotaped addresses in exchange for a
campaign contribution. Do you have any familiarity with the Hermes
Enterprises, Limited, organization?
Answer. I do not.
Question. Have you ever heard or seen the name Richard Agins, A-G-
I-N-S?
Answer. I have not.
Question. Do you have any familiarity with a dispute involving a
Greek-American group and either the President or the DNC?
Answer. No.
Question. Do you know an individual named Ramesh Kapur?
Answer. Yes I do.
Question. Have you met Mr. Kapur?
Answer. Yes, I have.
Question. Where did you meet Mr. Kapur?
Answer. I don't know the first time, but he was a trustee who I saw
often at events. He visited the DNC a few times where I would see him.
He also attended events around the country where I saw him.
Mr. Wilson. I have provided the witness with a document which is
marked Exhibit AS-15. It's a fax cover sheet dated 7/18/95, marked with
the Bates Number DNC 3235705.
[Swiller Deposition Exhibit No. AS-15 was marked for
identification.]
Mr. Wilson. It--the fax transmission----
Mr. Pierson. 5707.
Mr. Wilson. Oh, pardon. Correct. Pardon.
Mr. Wilson. The fax transmission indicates that there are five
pages included with this sheet, and it's my understanding that all we
have received is a single page of a fax transmission cover. If you
could take just a moment to look at that.
EXAMINATION BY MR. WILSON:
Question. The fax cover sheet indicates that there are two topics
of discussion with Mr. Roger Johnson. Do you recall discussing with Mr.
Kapur the contents of this fax cover sheet?
Answer. No, I do not.
Question. Do you recall--do you know whether you ever approached
Roger Johnson about arranging a meeting between himself and Mr. Kapur?
Answer. I do not recall that at all.
Question. Did Mr. Kapur discuss with you getting more Indian-
Americans into high-level positions at the GSA?
Answer. Not that I recall, no.
Question. The second topic mentioned in this fax cover sheet is
about preventing Indian-American businesses from being pigeonholed into
smaller contracts when they are capable of handling larger contracts.
Did Mr. Kapur have any discussions with you about this subject?
Answer. No. Not that I recall, no.
Question. Do you recall receiving this fax transmission?
Answer. I don't recall.
Question. Do you have any recollection of receiving a resume? This
fax cover sheet indicates that a copy of a resume is attached to the
fax. Do you recall receiving a resume from Mr. Kapur?
Answer. I don't.
Question. Did----
Mr. Pierson. Excuse me just a minute.
EXAMINATION BY MR. WILSON:
Question. Did you have any discussions with Mr. Kapur about
meetings that he had with administration officials?
Answer. No, I don't recall it.
Question. Do you recall ever assisting Mr. Kapur in setting up a
meeting with any Clinton administration employee?
Answer. No, I don't recall it.
Question. Do you recall receiving any requests from Mr. Kapur for
assistance on any matter?
Answer. Mr. Kapur would request special preferential seating at
events we would do around the country. He would request--he was another
person who requested photos and multiple copies of photos. That was
probably the extent of the requests that I dealt with.
Question. Do you recall whether you helped him with those requests?
Answer. If those sort of requests--I probably would have helped,
maybe not with the seat--giving him preferential seating, but I
probably would have heard him out.
Question. Do you recognize the handwriting on the document in front
of you?
Answer. I believe I do, yes.
Question. And there is a note at the middle, in the middle on the
right-hand side of the document; and I believe it says Ramesh requested
trustee as well. Do you recognize that handwriting?
Answer. No. I--if they're the same handwriting, this one is more
familiar to me.
Question. And do you know whose handwriting is on the bottom right-
hand section of the fax cover sheet?
Answer. It looks to me like the handwriting of Anne Braziel.
Question. Do you know whether Ms. Braziel ever scheduled meetings
with administer--between Mr. Kapur and any Clinton administration
officials?
Answer. Not that I can recall, no.
Question. Do you know an individual named Mansoor Ijaz? That's I-J-
A-Z?
Answer. Yes, sir, I know him.
Mr. Pierson. Ijaz.
Mr. Wilson. I was going to help with the pronunciation of his name
because I'm always sensitive to that.
EXAMINATION BY MR. WILSON:
Question. Have you met with Mr. Ijaz?
Answer. Yes, sir, I have.
Question. Where did you first meet Mr. Ijaz?
Answer. I believe I first met him with at a joint DNC-DCCC--D
triple C--event in Washington.
Question. And have you met with him on subsequent occasions?
Answer. Yes, I have.
Question. Where have you met him?
Answer. I met with him in my office at the DNC. I met with him on
occasion when I was working in New York in his office in New York, and
he hosted a fund-raiser at his home with the Vice President. So I met
with him at his home prior to the event.
Question. Do you know if Mr. Ijaz ever met with Nancy Soderberg?
Answer. Yes, he did. I believe he did.
Question. Did you know that prior to November of 1996?
Answer. Yes, I did.
Question. Did you assist Mr. Ijaz in meeting with Ms. Soderberg?
Answer. Yes, I did.
Question. Did he request that you provide assistance in setting up
a meeting?
Answer. Yes, he did.
Question. Why did he ask you to set up the meeting with Ms.
Soderberg?
Answer. Mr. Ijaz believed that he had some concerns that--about
nuclear technology development in Pakistan that he thought should be
brought to someone's attention. He was working international affairs
there.
Question. What is Mr. Ijaz's business?
Answer. My understanding is that he directs a large fund. He's a
fund manager. He raises large sums of capital and invests it.
Question. Do you know if Mr. Ijaz has any business and trusts in
Pakistan?
Answer. Not that I'm aware of, no.
Question. Did Mr. Ijaz ever discuss South Africa with you?
Answer. I know that he had business trips there. That was the
extent of the discussion.
Question. Do you know if he ever traveled to South Africa with a
Commerce Department delegation?
Answer. I don't recall that.
Question. Did Mr. Ijaz ever request your assistance in obtaining a
space on any Commerce Department travel events?
Answer. No, he did not.
Question. Do you know whether Mr. Ijaz ever attended--well, do you
know whether he attended a Washington lunch with the Vice President and
South African Vice President Mbeki?
Answer. I believe he did attend that event, yes.
Question. Did he discuss this event with you?
Answer. I believe so, yes.
Question. Did he ask for your assistance in obtaining an invitation
to this lunch?
Answer. Yes, he did.
Question. Did you help him with this request?
Answer. I believe I did, yes.
Question. Who did you contact on his behalf, if anybody?
Answer. I believe I contacted staff. I don't remember the person--
well, staff in the Vice President's office.
Question. Do you know whether you were--provided any indication of
Mr. Ijaz's request to any of your DNC colleagues?
Answer. I may have mentioned it to Mr. Sullivan.
Question. Did Mr. Ijaz speak with you about the Vice-Presidential
lunch after the event?
Answer. I believe he did speak with me, yes.
Question. And what did he tell you?
Answer. He was encouraged, thought it was a historic moment and was
happy that he had the opportunity to be there.
Question. Do you know if Mr. Ijaz ever met with Chief of Staff Leon
Panetta?
Answer. Not that I'm aware of.
Question. Do you know an individual named George Chu, C-H-U?
Answer. I know he was a trustee. I know--I do not know him.
Question. Have you ever spoken with him?
Answer. I have not.
Question. Do you--do you know who, in the DNC, was responsible for
contacting Mr. Chu initially?
Answer. My recollection--Mr. Chu, I think, lives in south San
Francisco; and his contact was our fund-raiser for that area, a
gentleman named Mark Thomann.
Question. Have you had any correspondence with Mr. Chu?
Answer. Correspondence similar that I would have with general
correspondence to all trustees.
Question. Did Mr. Chu ever make a request of you or your office?
Answer. Not that I'm aware of, no. Not that I recall.
Question. Do you know an individual named George Gruggiero?
Answer. You can see that--I believe you may be referring to a
gentleman named Joseph Ruggiero. If it's an individual at the IMPAC
Group.
Question. It's an individual at the IMPAC, yes.
Answer. My contact there was a man named Joseph Ruggiero.
Question. When did you believe you first met him?
Answer. I believe I first met Mr. Ruggiero during the '93
inaugural.
Question. And did you have subsequent contacts with Mr. Ruggiero?
Answer. Yes, I did.
Mr. Wilson. I would like to provide the witness with a document.
It's marked Exhibit AS-16 and indicates very clearly that it's Joe
Ruggiero and certainly not George. The date of the document is April 3,
1996. It's Bates Number DNC 3063532.
Mr. Pierson. Through 34.
Mr. Wilson. And subsequent pages, correct, through 34.
[Swiller Deposition Exhibit No. AS-16 was marked for
identification.]
Mr. Wilson. The first of the three pages that I've provided to
you--actually, I'll give you longer to look at it.
The Witness. Okay.
EXAMINATION BY MR. WILSON:
Question. The first of the three pages I've given to you indicates
that when you met with Mr. Ruggiero the previous year, which would have
been 1995, Mr. Ruggiero had complained about his treatment from the DNC
during the previous 2 years. Do you have--do you know what this refers
to?
Answer. As I recall, Mr. Ruggiero was very insistent that the--that
his participation with the RNC, he received much greater access to
President Bush and to administration officials, to Senators, to Members
of Congress than he did with his contributions with the DNC.
I remember him indicating that he was a member for what was called
Team 100, which I believe was a top-level RNC contributor group, and
that through his support of it had opportunities to have photos in the
Oval Office with the President, was often included in small meetings
with the administration officials, and that he felt that his support of
the DNC, he did not receive the same response or access; and it was
very discouraging for him.
Question. Did you discuss Mr. Ruggiero's complaints with Chairman
Fowler?
Answer. I believe I had conversations that sort of indicated things
similar to these lines in the document.
Question. The third page, the three documents I--the three pages I
provided to you is what appears to be a letter dated March 8, 1996,
from Chairman Fowler to Ambassador Shearer in Finland?
Answer. Uh-huh.
Question. Were you aware at the time that Chairman Fowler wrote to
Ambassador Shearer?
Answer. I was aware that a request was made for Mr. Fowler to write
such a letter. I was not aware that a letter was sent or that it was
ever completed.
Question. Do you--do you have any knowledge of that which is
referred to in this letter, which is a libel case involving the
company, Integrated Control Systems, Incorporated?
Answer. I recall there being a concern that his company was falsely
being accused in Finland. But I don't recall the greater details of it.
Question. So it's your recollection that this involved a legal
lawsuit in Finland?
Answer. That's my recollection, yeah.
Question. Do you recall whether you had any subsequent
conversations with Mr. Ruggiero or the other individual referred to in
this letter, Mr. Erwin, or any other members of IMPAC Group about the
libel case in Finland?
Answer. No, I don't recall that.
Question. Did you make any contacts to Ambassador Shearer in
Finland?
Answer. No, I did not.
Question. Do you know whether anybody else in the DNC made contact
with Ambassador Shearer?
Answer. No. I don't recall that.
Question. One--just a question, a general question, about this
particular letter. It is unsigned. Was it--was it a practice of--to the
extent you have any knowledge at all, was it a practice of the DNC to
retain unsigned correspondence in people's personal files?
Answer. It wasn't a practice.
Question. It wasn't a practice.
Mr. Pierson. Counsel, I do not want the assumption to remain in the
record that this came from a file. It could well have come off a
database.
Mr. Wilson. It could, and I was actually going to follow up and ask
that. It's entirely possible that this is printed off of a computer
database.
EXAMINATION BY MR. WILSON:
Question. And I'm just trying to get any elucidation on whether--in
your case, I asked you earlier whether you kept signed correspondence;
and you provided the answer for that. Do you know whether database
files were purged in your computer system on a regular basis or whether
they were retained just as a default mechanism in the computer system?
Mr. Lu. Are you asking him whether he purged them or whether the
system----
Mr. Wilson. No, no. Whether they were purged as a default mechanism
of the computer system. Not whether Mr. Swiller had any part in doing
any purging of any memorandum.
Mr. Pierson. Do you understand that the question is asking whether
it was done as part of a default mechanism? Not whether somebody came
in and sat down and did it but whether the system had a purging
mechanism within it?
The Witness. Not that I'm aware of.
EXAMINATION BY MR. WILSON:
Question. Do you have any knowledge of a meeting between
Ambassador--between Chairman Fowler, John Huang and Ambassador March
Fong Eu in April of 1996?
Answer. No, I don't.
Question. Did you ever receive any requests from Ambassador March
Fong Eu?
Answer. No, I did not.
Question. Did you have any contacts with Ambassador March Fong Eu?
Answer. I met her in 1992 during the campaign; but, following, I
don't think I ever saw or spoke to her again following the '93
Inaugural.
Question. Did you ever have any contacts with an individual named
David Lai, L-A-I?
Answer. No.
Question. Do you know Joe Giroir?
Answer. I know who he is.
Mr. Pierson. Have you met him?
The Witness. I believe I have met him.
EXAMINATION BY MR. WILSON:
Question. Did Mr. Giroir ever contact you at the DNC?
Answer. Never.
Question. Have you ever met either Nora or Gene Lum?
Answer. I have not.
Question. Have you ever had any contacts with Nora or Gene Lum?
Answer. I have not.
Question. Are you----
Answer. Let me correct--may I?
Question. Certainly.
Answer. I may have--I knew their names because they had at some
point before my return to the DNC--being trustees of the party, as I
did with a lot of people who had stopped contributing, I frequently
sent them requests to renew their contributions to the DNC. So I may--
at some point, they would have been included in that correspondence.
But I had no conversations with them, no follow-up conversations, and
never spoke with them directly.
Question. Do you know an individual named Al Wong, W-O-N-G?
Answer. I do not.
Question. Do you know an individual named Ray McClendon? That's M-
C, capital C, L-E-N-D-O-N?
Answer. The name is familiar. I believe he's a member of a firm
that was supportive of our efforts, but I don't know him.
Question. Do you recall any specific contacts between yourself and
Mr. McClendon?
Answer. No, I do not.
Question. Do you know James Staffors, who is with the company,
American Home Products?
Answer. I don't know him. I know that they were trustee-level
contributors. I don't recall ever meeting him or ever having any
conversations with him.
Question. Do you recall any requests that came from either Mr.
Staffors or any other employee of American Home Products of you or your
office?
Answer. No, I do not.
Question. Have you ever met James Belcher?
Answer. I have never met him.
Question. Mr. Belcher is with a number of companies. One is called
Peat Rubber Company. Another is called N. R. Latex. Do you know of any
contacts between Mr. Belcher and either yourself or your office?
Answer. He became a trustee level contributor while I was at the
DNC, so I assumed he received the similar correspondence that other
trustees received after he became a trustee.
Question. Did either Mr. Belcher or any other member of his--any of
his firms contact you with any manner of requests in either 1995 or
1996?
Answer. No.
Let me correct that. A gentleman named Chris Martin, I was
introduced to by an attorney of his, and he requested of me information
about the trustee program, which I discussed with him, with Mr. Martin.
Question. Did Mr. Martin contact you?
Answer. A trustee in Connecticut introduced us. She introduced me
to Mr. Martin under the pretense that he was interested or had a client
that was interested in becoming a DNC supporter.
Question. Where were you introduced to Mr. Martin?
Answer. At the home of Sandra Murphey and Bill Bryant in
Connecticut.
Question. What was the circumstance of this meeting?
Answer. They were hosting a fund-raiser for Senator Kennedy. They
invited me to come so that--I had known Mrs. Murphey for a few years
and her husband. She was--they were active contributors as well as
fund-raisers. They invited me there because they thought that Mr.
Martin had a client who would be interested in participating as a
trustee and being that I was their trustee liaison, they thought it
would be proper to make that introduction.
Question. Did Mr. Belcher or one of his companies ultimately become
a trustee participant?
Answer. Yes.
Question. Did you receive any communications about any of Mr.
Belcher's enterprises subsequent to Mr. Belcher becoming a trustee
participant?
Answer. Not that I recall specifically, no.
Question. Did you receive any requests regarding Mr. Belcher from
any Congressional staff?
Answer. Can you restate the question?
Question. Did you have any contacts regarding Mr. Belcher or Mr.
Belcher's enterprises with Congressional staff?
Answer. Following the election, I was contacted by members of
Senator Dodd's staff, because there had been some concerns raised that
Senator Dodd was involved in soliciting contributions from Mr. Belcher,
and they were asking me sort of what I knew about Mr. Belcher and the
history. That was the only Congressional contacts I think I had
regarding that.
Question. What did you tell them?
Answer. As I recall, I had this first introduction with Mr. Martin,
followed up with a phone call, maybe more than one phone call, which
were not returned. And subsequently, not through any contacts of mine,
Mr. Belcher became a trustee, and I never spoke to Mr. Martin or Mr.
Belcher again.
Question. Did you make any telephone calls or write any letters or
make any communications whatsoever on any matter that pertained to any
of Mr. Belcher's enterprises?
Answer. No, not that I recall.
Question. Do you know who solicited the contributions from Mr.
Belcher?
Answer. My recollection is that Mr. Huang did.
Question. And do you know anything about Mr. Huang's solicitation
of this contribution?
Answer. No.
Question. Do you know whether Mr. Huang traveled to Connecticut to
speak with Mr. Belcher?
Answer. I did not know it at the time, but as I just stated, I had
some conversations about sort of how Mr. Belcher became involved. In
that I found out Mr. Huang made that travel to Connecticut to meet with
Mr. Belcher.
Question. Did you have discussions with Mr. Huang about the
solicitation of a contribution from Mr. Belcher?
Answer. The only conversation I can recall is subsequent to an
initial contribution from Mr. Belcher, I remember just acknowledging to
Mr. Huang that I had met and associated with Mr. Belcher and Mr.
Martin, and that that was the extent of my contact, serving knowledge
that I guess I was encouraged that he finally made a contribution.
Question. Did anybody--you mentioned one Congressional contact.
Prior to your leaving the DNC in March of 1997, had anybody else
contacted you about Mr. Belcher or Mr. Belcher's companies?
Answer. No, not that I recall. No.
Question. Have you heard of the Ellicott Machine Corporation?
Answer. That is not familiar to me, no.
Question. Or the principal of the Ellicott Machine Corporation, the
CEO is a person named Peter Bowe, B-O-W-E. Do you know Mr. Bowe?
Answer. No, I don't.
Question. Do you know Mark Nichols?
Answer. Yes, I do.
Question. And when have you met Mr. Nichols?
Answer. I have.
Question. Where did you first meet Mr. Nichols?
Answer. At a DNC gala, I believe.
Question. Do you remember when that was?
Answer. I don't.
Question. Have you ever met with Mr. Nichols at the DNC?
Answer. No, I have not.
Question. Have you ever met with Mr. Nichols outside of social
circumstances such as the DNC gala or fund-raising event?
Answer. I have not.
Question. Do you recall ever having helped Mr. Nichols set up
meetings with any Clinton Administration employees?
Answer. No, I do not.
Question. Have you had any contacts with Mr. Nichols outside of the
social meeting you described at the very beginning of this line of
questions?
Answer. I happened to have run into him at a DSCC event recently
while I was in California, where it was a social visit. But I barely--I
don't recall it.
Question. Did you have any discussion with him at that time?
Answer. Yes, I did.
Question. And what did you discuss?
Answer. He--actually I recall now he requested of me if I could
assist him in getting a photo of himself from an event with the
President that took place in Los Angeles that I had actually worked on,
which would be another event where I saw him, a fund-raiser in the fall
of '96, and he had remembered that--he remembered that he hadn't
received a photo, that I was at the event, and he asked if I could
assist in getting him a photo.
Question. Did you attend any meetings with Mr. Nichols and Chairman
Fowler?
Answer. Not that I recall, no.
Question. Are you aware of meetings between Mr. Nichols and Mr.
Fowler?
Answer. I can recall that he, Mr. Nichols, came to the DNC, but who
he met with, I don't recall if it was Mr. Fowler or not.
Question. Earlier I asked you if you knew Mr. Patrick O'Connor, and
you indicated that you did. Did Mr. O'Connor ever have any
conversations with you about tribal, Indian tribal gaming concerns in
Wisconsin and Minnesota?
Answer. He did not.
Question. Did you ever have any discussions with Mr. O'Connor about
any Indian tribal concerns?
Answer. No.
Question. Did Mr. O'Connor ever ask for your assistance on any
matter?
Answer. No, he did not.
Question. Prior to November of 1996, were you aware of any
litigation involving a Chippewa Indian tribe in Wisconsin and
Minnesota?
Answer. I was not.
Question. Were you aware, and again prior to November of 1996, that
Chairman Fowler had been threatened with a subpoena and a lawsuit
involving Indian tribal issues in Wisconsin and Minnesota?
Answer. No, I was not aware of that.
Question. Was there anybody at the DNC who was the principal
contact between the DNC and Native American campaign contributors?
Answer. No, not that I recall.
Question. Do you remember any DNC fund-raisers being in contact
with Native American fund-raisers, or Native American contributors?
Answer. I had some contact with some, and I don't--I think other
staff fund-raisers in the field did, yes.
Question. Did any Native American tribal representatives become
trustees or managing trustees?
Answer. Yes.
Question. Do you recall who they were?
Answer. Well, I think Mr. Nichols or his tribe contributed. Skip
Hayward, who represented the Mashantucket Pequot tribe. The Sioux, the
Saint Sioux tribe in Minnesota. I don't recall at this time other
tribes, but there may have been a few others that contributed at the
trustee level.
Question. Did you ever receive any requests from any of the
individuals that you have just mentioned?
Mr. Pierson. Of any kind?
EXAMINATION BY MR. WILSON:
Question. Of any kind.
Answer. Yes. Mr. Hayward had a representative, or his tribe had a
representative named Chris McNeil in Washington, who I remember
requested a meeting with chairman--through me with Chairman Wilhelm,
and I can remember I attended, and with Chairman Fowler.
Question. Do you remember what the meeting was about?
Answer. The first meeting with Wilhelm?
Question. Yes.
Answer. I remember they described the success of their casino, how
they had--I remember what sticks out in my mind is that they referenced
a number of like $140 million they had written to the State of
Connecticut because they are a tribe. I remember their concern that
they felt that they did not have a contact in the White House who was
well versed on Indian, Native American, Indian concerns and issues.
Question. And referring to the second meeting that you mentioned,
what was discussed at that meeting?
Answer. I remember there being some follow-up to the original
meeting, feeling that they had been supporters, but that these concerns
that they laid out earlier had still not been addressed, that there
were not people who understood their concerns.
Question. Did you ever have any contacts with Tom Collier, either
when he was Secretary Abbott's chief of staff or when he was in private
practice in a law firm in Washington?
Answer. The name is familiar, but I don't recall contacts with him.
Question. Have you ever had any contacts with a woman named
Gretchen Lerach, L-E-R-A-C-H?
Answer. She was an employee at the DNC part of the time that I was
at the DNC, yes.
Question. Who did Ms. Lerach work for?
Answer. My recollection is that she served as an assistant to the
chief of staff, B.J. Thornberry, when she was employed at the DNC.
Question. Do you know whether she was still employed at the DNC
when you left in March of 1997?
Answer. No, I believe she left previous to my departure.
Question. Did you have any knowledge prior to November of 1996 that
Indian tribes were considering forming a PAC to advance tribal issues?
Answer. No, not that I recall.
Question. Do you know an individual named Richard B-E-R-T-S-C-H,
Bertsch?
Answer. Yes, I do.
Question. Who is Mr. Bertsch?
Answer. He was someone who was involved in politics and some fund-
raising in Los Angeles.
Question. Have you met him personally?
Answer. Yes, I have.
Question. When did you first meet Mr. Bertsch?
Answer. I believe I recall him screaming at me at a fund-raising
gala at the Washington Hilton, and I think that gala was in the spring
of '94. That was my first introduction.
Question. And what facilitated the manner of introduction?
Answer. I believe he didn't like his seating and felt I was
responsible or I was the closest staff person to him at the time.
Question. Did you ever--have you ever solicited contributions from
Mr. Bertsch?
Answer. No, not that I recall. No.
Question. Have you ever either yourself or have any of your staff
conducted background research on Mr. Bertsch?
Answer. No, not that I can recall.
Question. Did Mr. Bertsch ever request that you provide assistance
in setting up a meeting between himself and any member of the Clinton
Administration?
Answer. No, not that I can recall.
Question. Do you know Richard Park?
Answer. Yes, I do.
Question. When did you first meet Mr. Park?
Answer. I believe he was accompanying Mr. Bertsch at that first
fund-raiser that I described earlier.
Question. Have you ever solicited contributions from Mr. Park?
Answer. Yes, I have.
Question. Have you ever conducted any background research or any of
your staff members conducted background research on Mr. Park?
Answer. No, not that I can recall.
Question. Has Mr. Park ever contacted you to request your
assistance?
Answer. When I was at the DNC?
Question. When you were at the DNC, right.
Answer. No, not that I can recall.
Question. Do you recall ever helping to arrange meetings for Mr.
Park with any Clinton Administration officials?
Answer. No, I don't.
Question. Are you aware that the President attended a series of
coffees held at the White House during 1995 and 1996?
Answer. Yes, I am.
Question. Do you know whether the coffees were a part of the DNC's
major donor program?
Answer. No, they were not.
Question. They were not. Did you ever send out any correspondence
or information to any of the managing trustees or trustees about
presidential coffees?
Answer. We had--regarding coffees? No, not that I recall.
Question. Did you ever have any contacts with any of the trustees
or managing trustees about presidential coffees?
Answer. Yes.
Question. And what were the circumstances of those contacts?
Answer. As I stated earlier, the President attended a number of
coffees. From time to time, I had the opportunity to include long-
standing supporters or people that I thought would be potential
supporters in those coffees. So I would invite them to attend a certain
coffee.
Question. And mechanically speaking, how would you go about
inviting the individual?
Answer. Over the phone, through a phone conversation.
Question. Would you follow up that telephone conversation with a
letter?
Answer. We would sometimes follow up with a fax explaining where to
enter the White House and also requesting them to fax back social and
date of birth information for them to be waved into the White House.
Question. Did you discuss your intention to contact people about
coffees in advance of your contacting them with anybody else at the
DNC?
Answer. Yes.
Question. Who would you discuss those people with?
Answer. Frequently with Mr. Rosen, Mr. Sullivan, Ms. Braziel. Those
are probably the majority of the contacts.
Question. Did you ever provide anybody else in the DNC with a list
of suggested attendees for coffees?
Answer. Others than I mentioned?
Question. Well, actually, no, I am including those people. Did you
provide them with a list----
Answer. Of prospective invitees?
Question. Exactly.
Answer. Yes. I would provide on occasion a list to Mr. Rosen or Mr.
Sullivan about some people that I would want to include.
Question. And this would be in the form of a written memorandum?
Answer. Yes.
Question. Did you keep copies of such memoranda in your files?
Answer. No, I don't think I kept printed copies. As I talked about
earlier, they were saved automatically on the computer.
Question. Do you recall whether your suggestions were generally
accepted?
Answer. I think generally they were, yes.
Question. Did you attend any of the White House coffees?
Answer. Yes, I did.
Question. Do you recall the occasions that you attended coffees?
Answer. I believe I attended one coffee that was attended by the
President and Vice President in August of 1995.
Mr. Pierson. You are talking about White House coffees now, right?
Mr. Wilson. Yes.
EXAMINATION BY MR. WILSON:
Question. And do you recall any of the other attendees at that
coffee?
Answer. Mr. Fowler was there. Truman Arnold, who at the time was
the finance chairman, was there. I remember Gail Zappa was in
attendance, Carol Penskey, Bill Doctor. I believe Rich Keating. Those
are the names I remember. There would be I think about a dozen people
all together.
Question. When you compiled lists of suggestions for coffee
attendees, did you have any criteria that you went by to assist you in
putting a name on the prospective list?
Answer. I tended to put people on who had been long-standing
supporters. I viewed it as quite an awesome event to go to, so I would
allow people who had been with the DNC and trustees for a long period
of time. Those were the names I tended--my personal criteria for
putting them on the list.
Question. Did you ever suggest to any individuals that were
ultimately invited, and that you had suggested, that they should make a
campaign contribution in association with attending the coffee?
Answer. No, I did not.
Question. Do you know whether the individuals that you suggested as
attendees of the coffees ever received formal invitations from either
the DNC or the White House to attend the coffee?
Answer. My recollection is they did not receive formal invitations.
Question. I provide for the witness a document marked Exhibit AS-
17, which is marked EOP 035478, dated September 28, 1995, and it
appears to be a list from a computer database that is not addressed to
anybody in particular.
Answer. I don't think it is a list.
Question. I mean it provides fields, entry of data, for an
addressee. It is not an actual letter that went out to anyone.
[Swiller Deposition Exhibit No. AS-17 was marked for
identification.]
EXAMINATION BY MR. WILSON:
Question. I show you this to ask you if you have seen letters like
this that have gone out to coffee invitees?
Answer. Not like this, no. As I stated earlier, the letters we
would send were in the form of a memorandum indicating where they
should enter. I don't recall sending a formal letter like this.
Question. Was there anybody at the DNC that was responsible for
issuing the invitations or collecting information from the individual
invitees?
Answer. At the DNC?
Question. Yes.
Answer. It tended to be myself and Ann Braziel.
Question. Did you have any--do you have any knowledge that any
individuals at the DNC were linking attendance at a coffee with a
contribution of any sort?
Answer. No, I don't.
Question. I provide the witness with an exhibit marked AS-18.
[Swiller Deposition Exhibit No. AS-18 was marked for
identification.]
EXAMINATION BY MR. WILSON:
Question. This is premarked with a Bates Number DNC 3098456. If you
would take just a moment to look at that. This appears to be a call
sheet. It is not specifically addressed to an individual. It is
prepared by Ann Braziel.
Do you recall call sheets of this nature being prepared?
Answer. Yes, I do.
Question. Did you discuss with Mr. Braziel--with Ms. Braziel call
sheets of this nature?
Answer. Yes, I did.
Question. And did you discuss with her language that is set out at
the bottom, the reasons for call. Here it indicates that an individual
is interested in participating in convention but is not sure about
membership. Ask them to begin renewal of his trustee membership at 25 K
and attend the coffee with the President on, and three dates are
listed.
Were you aware of any situations where when calls were made,
attendance at coffee was linked with renewal of trustee membership?
Answer. I don't have knowledge of that.
Question. Did you ever discuss with Chairman Fowler the
relationship between membership or being included in the trustee
program and attending coffees?
Answer. He knew that in my role I included trustees in those
coffees, so the participation of trustees was sort of a natural thing
for us to discuss, because they were the donors I worked with.
Question. You mentioned before that you tended to include long-
standing trustees as possible invitees to coffees. How would you
determine what would qualify as a long-standing trustee contributor to
be included in your list of invitations?
Answer. Their length of time for when they contributed. If they had
been a contributor for two years, a year. People that got involved more
close to the date of a coffee, I would move them sort of towards a
later date. People who had been continual contributors, renewing every
year, were my first priority.
Question. And did you have a cutoff in your own mind as to years of
participation for inclusion in the list of potential attendees that you
submitted?
Answer. No.
Question. Did you ever receive information, financial information,
that projected income for coffees that the President attended?
Answer. No, I did not.
Question. Did you ever receive any spreadsheets or financial data
that listed coffees?
Answer. Not that I recall, no.
Question. Do you have any recollection of receiving any types of
financial data or spreadsheets, apart from that which we have already
discussed, which were the lists of trustees that could be generated at
your request?
Answer. No.
Question. No.
Answer. Not that I recall, no.
Question. Did you ever have any discussions with your colleagues
about financial projections for coffees or indications of money
received from coffees? And I refer exclusively to before November of
1996.
Answer. No, not that I recall.
Question. Are you aware of whether the Vice President hosted
coffees for DNC supporters?
Answer. Yes, he did.
Question. Did you ever submit any lists of suggested attendees for
those coffees?
Answer. I did.
Question. And what criteria did you use to determine who you would
put on the list?
Answer. Similar criteria. I tended to defer to, in the case of
coffees with the Vice President, contributions that were not made by
the individual, but if there was like a Washington representative of a
company that had been a long-standing contributor, that is where I
tended to include them on the list.
Question. Have you ever heard of the term of art ``servicing'' used
in conjunction with either presidential or vice presidential coffees?
And, if so, do you know what it means?
Answer. I have heard the term ``servicing.''
Mr. Pierson. Have you heard it applied though to coffees?
The Witness. Yes.
EXAMINATION BY MR. WILSON:
Question. And do you have an understanding of what the term
``servicing'' means?
Mr. Pierson. As applied to coffees?
EXAMINATION BY MR. WILSON:
Question. As applied to coffees.
Answer. It would mean an opportunity to include donors at an event
where the President would be attending and it would not be a fund-
raiser.
Question. Have you ever seen any lists of coffees where the term
``servicing'' is applied to one of the presidential or vice
presidential coffees?
Answer. I don't recall such a list.
Question. Do you recall ever having discussions with any of your
colleagues as to whether either a presidential or vice-presidential
coffee would be designated as a servicing event?
Answer. No.
Question. There was a coffee on May 13, 1996, that included a
number of prominent bankers. Did you submit any suggestions or names
for that particular coffee?
Answer. I did not.
Mr. Pierson. Counsel, it is now about 4 o'clock. I would like to
ask on the record counsel for the Minority whether they will have any
examination based on how the testimony is going so far?
Mr. Lu. I think we will, yes.
Mr. Pierson. Can you give me an estimate of how long?
Mr. Lu. At this point, 15 to 20 minutes maybe, possibly a little
bit more, a little bit less.
Mr. Pierson. Okay. I haven't talked to Mr. Swiller about how he is
feeling, but I am getting weary. I am just writing notes. What I would
like to do is take about a 2 or 3-minute break and go until 5 o'clock,
and whatever line of questioning you have at that time we would be
happy to let you finish, and let the Minority do some questioning.
Unless it opens some area that is legitimate for you to pursue, I would
like to end.
Mr. Wilson. I am in agreement to continue on after a short break. I
hope I can wrap up within the next hour. I can't make any
representations to that.
Mr. Pierson. Fair enough.
[Brief recess.]
EXAMINATION BY MR. WILSON:
Question. Back on the record, please.
Did you ever have any interaction with Harold Ickes?
Answer. No, I did not.
Question. Did you ever place any calls or make any contacts with
Mr. Ickes' office?
Answer. Yes, I did.
Question. And what were the circumstances?
Answer. I believe I spoke with an assistant to him, John Sutton. I
think it was regarding a tour request that he was going to do for some
contributors, supporters.
Question. That Mr. Sutton was going to----
Answer. Yes.
Question [continuing]. Organize for contributors? Did you ever----
Mr. Pierson. You have to speak audibly.
EXAMINATION BY MR. WILSON:
Question. Did you ever have any contacts with Janice Enright?
Answer. Socially, but not that I recall in her office, work.
Question. Did you make any requests of her?
Answer. No, not that I recall.
Question. Do you recall whether she made any requests of you?
Answer. No, I do not recall any.
Question. Did you ever prepare call sheets for the President, Vice
President, First Lady or Vice President's wife?
Answer. I believe I prepared call sheets for the President and Vice
President, yes.
Question. And----
Answer. I did.
Question. And how did you determine who would be put on call
sheets?
Answer. In discussions with Mr. Sullivan and Mr. Rosen.
Question. Did you keep track of the results of what happened after
call sheets were sent out?
Answer. Yes, I did.
Question. How did you do that?
Answer. We had a binder in the office that had copies of call
sheets, and at the front of it was a spreadsheet that indicated if a
call was made and what the response was.
Question. And was the binder divided into sections depending on
President and Vice President, First Lady, or who the person to make the
call was?
Answer. Since there were only calls to my knowledge made by the
Vice President, it was all calls referring to him.
Question. And who generated the spreadsheet that you refer to as
being at the front of the binder?
Answer. Ms. Braziel.
Question. When you provided call sheets through the Vice President,
did you provide any additional instructions or materials in addition to
the one-page call sheet?
Answer. Not that I recall, no.
Question. I provide for Mr. Swiller a document marked Exhibit AS-
19, which is marked as a DNC call sheet for Vice President Gore.
[Swiller Deposition Exhibit No. AS-19 was marked for
identification.]
EXAMINATION BY MR. WILSON:
Question. It has been premarked with the Bates number EOP 049239.
It is dated December 1, 1995.
Do you recognize the handwriting at the bottom of the page?
Answer. It looks like it could be the handwriting of Anne Braziel.
Question. And if you could, please tell me how the call sheets were
treated once they were sent out? Did you request the calls be made by a
certain time?
Answer. No, I did not.
Question. How would information as to whether the calls had been
made or not made be transmitted back to your office?
Answer. It generally tended that a gentleman named Peter Knight
would assist in that. He would provide information if calls were made
or not.
Question. Did you ever discuss with Peter Knight the call sheets
and fund-raising efforts made pursuant to the call sheets?
Answer. Yes, I did.
Question. What did you discuss?
Answer. In regards to the call sheets?
Question. Yes.
Answer. He would inform me if a call was made, if the Vice
President connected with the individual who the outreach was made to,
what the result of that call was, if it was favorable or not favorable.
Question. And do you recall whether he contacted you exclusively,
or did he sometimes contact Ms. Braziel?
Answer. I think he sometimes contacted Mr. Sullivan, but I think he
generally contacted myself and talked to me.
Question. This particular call sheet lists as a reason for the call
to ask an individual to contribute an additional $50,000 to the DNC
Media Fund.
What was the Media Fund?
Answer. It was a similar internal campaign line of funds we were
trying to raise. I don't think there was a separate account for it, and
I think it was just internally attracting that we were doing.
Question. Did you receive copies of separate accounting for funds
that had been raised in the Media Fund?
Answer. Not that I recall, no.
Question. Did you ever suggest to any individuals that they make
contributions to not-for-profit organizations?
Answer. If individuals were interested in organizations that were
not-for-profit, there were times when I would offer them names of such
organizations.
Question. Did you keep a list of names of organizations that were
not for profits that you suggested people to contribute to?
Answer. I did not.
Question. Did you have a memoranda that you could provide for
people with names and addresses?
Answer. Not that I recall, no.
Question. When you made suggestions to individuals about a
particular not for profit to which they might contribute, did you
verbally tell them what the organization was and other information
about the organization?
Answer. That is correct.
Question. Did you ever keep any records of whether people you
discussed not-for-profit contributions with actually did contribute to
the not-for-profit group?
Answer. I don't recall a separate recording for that, no.
Question. Do you recall whether there was an accounting of any sort
within the DNC that kept track of contributions made to not-for-profit
organizations?
Answer. Not that I am aware of.
Question. Did you ever see any spreadsheets that listed not-for-
profit contributions?
Answer. No, I did not.
Question. Did you keep any information in the trustee files about
whether individuals made contributions to not-for-profit organizations?
Answer. I may have, but I don't recall any specific.
Question. You suggested earlier you would provide the names of
organizations to which contributions could be made. What are the names
of those organizations?
Answer. The ones I recall are the William Randolph Black Coalition
for Black Voter Participation, the A. William Randolph Coalition for
Black Voter Participation, and I think there was another organization
called Vote '96.
Question. Did you ever suggest individuals make contributions to an
organization called Defeat 209?
Answer. No, not that I recall.
Question. Did you ever suggest individuals make contributions to an
organization called Participation 2000?
Answer. No, not that I recall.
Question. Why did you ask individuals or corporations to give gifts
to not-for-profit organizations?
Answer. I never asked them to.
Question. Is it fair to characterize what you said earlier that you
merely responded to their questions of who might I contribute to for a
not-for-profit contribution?
Answer. That is correct.
Question. Have you ever met an individual named Warren Meddoff?
Answer. No, I have not.
Question. Have you been contacted about a possible contribution
from Mr. Meddoff prior to November 1996?
Answer. By whom?
Question. By anybody. Prior to November of 1996?
Answer. Mr. Fowler contacted me about it.
Question. And what did he ask you or tell you?
Answer. He asked if I had heard the name Meddoff, or I believe
there was another individual working with him who had indicated that
they may make a large contribution to the DNC. Mr. Fowler was concerned
because of the size of the contribution and the timing of the
contribution and the fact that Mr. Meddoff was not known to myself and
other individual fund-raisers at the DNC. He had some suspicions about
their motives, their sincerity, and whether they were for real or not.
Question. What did you tell Mr. Fowler?
Answer. I told him that I did not know Mr. Meddoff. I don't recall
the company he represented himself aligned with, but I didn't know that
either. As I said earlier, there was another gentleman involved, and I
did not know that gentleman either.
Question. Did Mr. Fowler ask you to do any research on Mr. Meddoff
or Mr. Meddoff's associate?
Answer. Yes. They sort of I guess indicated that they were in the
financial field, so he asked that I call, if I could request of donors
who were also in the finance field if they knew of these individuals.
Question. And did you make calls to----
Answer. I recall two calls that I made, yes.
Question. Who did you call?
Answer. A gentleman named Steven Rattner, and a gentleman named
Elliott Wolk.
Question. The spelling of the second gentleman's name is?
Answer. W-O-L-K.
Question. And what did they tell you about Mr. Meddoff?
Answer. Neither of them had heard of him or the company which they
represented.
Question. Did you communicate this to Mr. Fowler?
Answer. I did.
Question. And did he ask you to do anything else?
Answer. He did not.
Question. Did you have any--did you receive any requests from
anybody outside of the DNC about information pertaining to Mr. Meddoff
prior to November of 1996?
Answer. No, I--no.
Question. Do you know whether the DNC ever provided a list of
Chinese American trustees to anyone at the Taiwan Economic and Cultural
Representative Office in the United States?
Answer. Not to my knowledge.
Question. Do you know an individual named Andrew Hsi, spelled H-S-
I?
Answer. I do not.
Question. Have you ever had any contacts with Andrew Hsi?
Answer. No, I have not.
Question. Do you know an individual named Steve Boyd?
Answer. Yes.
Question. Has Mr. Boyd ever asked you to provide a list of trustees
to him?
Answer. Not that I recall, no.
Question. Do you know whether Mr. Boyd asked you to provide a list
of trustees to anyone else?
Answer. Not that I have any recollection of.
Question. I provide the witness with a document which has been
marked Exhibit AS-20.
[Swiller Deposition Exhibit No. AS-20 was marked for
identification.]
EXAMINATION BY MR. WILSON:
Question. It has been Bates marked DNC 1761511. It is a memorandum
to Ari Swiller from Matt, dated April 21, subject, loose ends. If you
can take just a moment to review this document.
Answer. Okay.
Question. Do you know who the individual was, ``Matt,'' at the top
of the memo is?
Answer. Yeah. It's Matt Gobush.
Question. Do you recall ever having seen this memo?
Answer. Yes, I do.
Question. Referring to the last bullet mark paragraph of the
memorandum, it states that ``Steve Boyd has requested a list of
Chinese-American Trustees for Andrew Hsi of the Secretariat of Taiwan
per the request of Jim Brady, DNC Vice Chair.''
Do you recall having any conversations about Mr. Boyd requesting a
list of Chinese-American trustees?
Answer. I don't.
Question. Do you remember having seen this at the time that the
memorandum was given to you?
Answer. I----
Question. This statement.
Answer. This statement. I don't have a recollection of it, but I
remember seeing a memorandum.
Question. Did you ask Mr. Gobush for further information about
this, the request about a list of Chinese-American trustees for the
Secretariat of Taiwan?
Answer. Not that I recall.
Question. Did Mr. Gobush provide any additional information to that
which is in this memorandum?
Answer. Not that I can recall.
Question. Do you recall having any conversations with anybody or
contacts with anybody about providing lists of trustees for somebody in
the Secretariat of Taiwan?
Answer. No, I do not recall any.
Question. Do you know whether Mr. Gobush sent over such a list to
the Secretariat of Taiwan?
Answer. Not to my knowledge.
Question. Do you recall whether at the time that this struck you as
being an unusual request?
Answer. It strikes me now as one. I don't recall my reaction to it
at that time.
Question. Have you ever provided a list of trustees to any
organization outside of the DNC?
Answer. Not to my knowledge. I was very protective of the list.
Mr. Wilson. I've given the witness a memorandum which has been
marked AS-21. It's premarked DNC 1781772. It's a memorandum dated April
24, 1995, to Steve Boyd from Mr. Swiller and Nancy Burke. It's re:
Chinese-American trustees. This memorandum lists three--actually five
individuals: Mr. Johnny Chung, Mr. Charlie Trie, Mrs. Wang Mei Trie,
Dr. C.J. Wang and Dr. Mildred Wang.
[Swiller Deposition Exhibit No. AS-21 was marked for
identification.]
EXAMINATION BY MR. WILSON:
Question. Do you recall ever having seen this memorandum?
Answer. No, I don't recall seeing it.
Question. Who is Nancy Burke?
Answer. She was my assistant on the trustee program after Mr.
Gobush left. She worked at my direction.
Question. Did Ms. Burke and Mr. Gobush overlap in their terms of
employment?
Answer. Maybe by a week as a transition period.
Question. Do you recall whether Ms. Burke ever discussed with you
sending names of Chinese-American trustees to Mr. Boyd?
Answer. I don't recall the conversation, no.
Question. Referring back to the previous document, the date is not
specific. It says April 21st, and a year is not included in the first
document. The second document is dated April 24 of 1995. I believe
April 21st is a Friday and April 24 is a Monday. Is there--.
The Witness. Excuse me one second.
[Witness and counsel confer.]
The Witness. Sorry.
Mr. Pierson. Perhaps, counsel, it might be more useful if you're
trying to fix the year to ask the witness if he recalls when Mr. Gobush
was employed at the DNC.
EXAMINATION BY MR. WILSON:
Question. When was Mr. Gobush employed at the DNC?
Answer. He was employed at the DNC through--through the end of
April, I believe, in 1995.
Mr. Pierson. And he began at what time?
The Witness. He began in--about a year prior.
EXAMINATION BY MR. WILSON:
Question. Do you have a recollection of the month that he began his
employment?
Answer. I don't.
Question. Okay. Who is Steve Boyd?
Answer. I believe he worked in the Office of the Secretary of the
DNC.
Question. And what is the Office of the Secretary in the DNC
responsible for doing?
Answer. I don't know. They are responsible for making sure that the
Secretary of the DNC is well seated at all DNC events. Other than that,
I think they maintain the bylaws of the party, but I'm not sure what
their day-to-day responsibilities are.
Question. Did you receive other requests from Mr. Boyd--well I
shouldn't say other requests. Did you receive any requests that you
recollect from Mr. Boyd during your employment at the DNC?
Answer. Not that I recall.
Question. Do you know Anne Lewis?
Answer. I know who she is.
Question. Have you ever met her?
Answer. I believe I have, yes.
Question. Do you know Lynn Cutler?
Answer. Yes, I do.
Question. And do you know her personally?
Answer. Yes I do.
Question. Do you know of any donations--did you ever recommend
donations be made to the Back to Business group.
Answer. No I did not.
Question. Were you ever part of any--of discussions wherein it was
suggested the DNC donors made contributions to the Back to Business
organization?
Answer. Yes, I believe I was--yes.
Question. And if you could, please describe those discussions.
Answer. I believe Ms. Cutler at some point made a request for some
names that may be outreached to for that organization.
Question. Did Ms. Cutler make the request directly of you?
Answer. As I recall, yes.
Question. And how did you respond?
Answer. I did not respond.
Question. Did you send her any names?
Answer. Not that I recall.
Question. Did you suggest any names that she might contact?
Answer. Not that I recall.
Question. Do you recall in a general sense what you told her?
Answer. I think it--when she asked, I said I would look into it.
But I remember feeling that it would be counterproductive to my efforts
to raise money, so I--I don't recall her ever following up, so I didn't
do any proactive follow up.
Question. When you left the DNC in March of 1997, or at any time
previous to your leaving the DNC, did you sign a memorandum about the
retention or nondestruction of documents?
Answer. Yes, I believe so.
Question. Do you know when you might have signed such a document?
Answer. Prior to leaving the DNC.
Question. Do you remember when--when the document was circulated
for you to be signed?
Answer. Around the new year, December, January; maybe earlier.
Question. And do you recall signing this document?
Answer. I believe I did, yes.
Question. When you--in 1995, were you aware of a suggestion by
campaign consultant Dick Morris about a large-scale media purchase for
the end of 1995?
Answer. At that time, no.
Question. And I'm speaking specifically about that time.
Answer. No, I'm not.
Question. Did you become aware of such a suggestion at any time
before November of 1996?
Answer. I became aware that the DNC was making large purchases of
TV time. I don't know at what point that I became aware it was at his
suggestion. I knew we were doing it, and when I became aware of that
Mr. Morris was involved in that discussion, I can't recollect exactly
when that was.
Question. Did you contact any of the trustee donors to provide
additional contributions for media purchases at the end of 1995?
Answer. As I recall, no, there was no direct contributions made to
direct media purchases. There was general fund-raising that was always
at an increase because we always needed more money. As we started to,
as I recall, buy more media time, our expenditures grew, so we were
required to raise more money. I don't know that that--I can't recall
directing anyone that their funds would go to media purchase, because I
don't believe that that was ever the case.
Question. Do you know whether anybody at the DNC was involved in
keeping track of funds or monies to be directed towards media purchases
at the end of 1995?
Answer. Not that I have knowledge of, no.
Question. Do you recall whether there were any specific accounting
systems set up to keep track of funds that might be expended in media
buys at the end of 1995?
Answer. No.
Question. Did you have any involvement with funds being wired to
State parties to implement media buys at the end of 1995?
Answer. I don't recall that.
Question. Did you have any direct contact with any State party
officials in terms of providing contributions to the State parties from
the DNC?
Answer. No. I don't recall speaking to State party officials.
Question. Were you involved in any discussions of sending DNC
monies to State parties?
Answer. No, not that I recall.
Mr. Pierson. May I hear the last question and answer, please?
[The reporter read back as requested.]
Mr. Pierson. Excuse me just a moment.
[Witness and counsel confer.]
Mr. Pierson. Are you asking for his discussion with anybody inside
the DNC, any contributors, anybody in the world?
Mr. Wilson. Any----
Mr. Pierson. Because he's already testified about the Tamraz
situation.
Mr. Wilson. Correct. Any of the DNC colleagues.
[Witness and counsel confer.]
Mr. Pierson. Start your question again, because I think he's
thinking about something different than you're asking. So ask again if
you would, please.
EXAMINATION BY MR. WILSON:
Question. Were you involved in any meetings or discussions with DNC
colleagues about--about forwarding DNC monies to State parties?
Mr. Pierson. What you're talking about is money that has gone into
DNC accounts and thereafter would go to State parties?
Mr. Wilson. Correct.
The Witness. No.
Mr. Pierson. Okay.
EXAMINATION BY MR. WILSON:
Question. Unfortunately, this is depressing for me to go back and
look at the pile that I went passed earlier, but a couple of quick
questions on a few more issues.
Mr. Pierson. Far more depressing to us.
Mr. Wilson. I'm hoping to come within the last 4 or 5 minutes of my
questioning.
Mr. Pierson. Good.
Mr. Wilson. Maybe a little longer.
Mr. Pierson. Good.
EXAMINATION BY MR. WILSON:
Question. Did you ever draft, suggest a list of DNC contributors to
stay as overnight guests in the White House?
Mr. Pierson. Do you mean did he ever propose names for overnight
stays in the White House?
EXAMINATION BY MR. WILSON:
Question. Well, the first question is did you ever send the list or
draft lists of suggested overnight guests at the White House?
Answer. I don't recall drafting it, no.
Question. Did you ever make suggestions of individuals to be
overnight guests at the White House?
Answer. On occasion, yes.
Question. Do you recall specifically who you suggested as an
overnight guest?
Answer. No. My recollection would be that there had been long-
standing fund-raisers and trustees who have been significantly
supportive throughout the years.
Question. And to whom would you communicate your suggestions?
Answer. I think initially I communicated suggestions to Ms.
Hartigan and Mr. McAuliffe; subsequent to the transition, to Mr.
Sullivan and Mr. Rosen.
Question. Did you ever communicate directly with the White House
with suggestions of potential overnight guests?
Answer. No, not that I recall.
Question. Did you ever receive telephone calls or contact from the
White House about suggested overnight guests?
Answer. No.
Question. Did you ever travel on Air Force One or Air Force Two?
Answer. No.
Question. Did you ever suggest individuals to travel on Air Force
One or Air Force Two?
Answer. Yes, I did.
Question. And what criteria would you use to make such a
suggestion?
Answer. Same criteria as I stated earlier: People who had been
long-standing supporters or longtime fund-raisers of the party.
Question. And who would you communicate your suggestions to?
Answer. As I stated earlier, at first I--I would to Mr. McAuliffe
and Ms. Hartigan; following the transition, to Mr. Sullivan and Mr.
Rosen.
Question. Did you ever discuss requests for positions on boards or
commissions with DNC donors?
Answer. Yes, I did.
Question. And who did--who did you discuss board or commission
positions with?
Answer. I can't recall all the donors. I remember Ms. Betsy Cohen
made a request about an inquiry. I think Elaine Shuster.
Question. Do you remember any other names?
Answer. I believe there may have been others that I spoke with
about it but not coming to mind.
Mr. Wilson. I've given the witness a document which is marked
Exhibit AS-22. It's been Bates marked DNC 3052822, memorandum to Mr.
Swiller and Richard Sullivan from Eric Sildon and Jay Dunn, dated
January 24, 1994.
[Swiller Deposition Exhibit No. AS-22 was marked for
identification.]
EXAMINATION BY MR. WILSON:
Question. Do you recall ever receiving requests from the Commerce
Department for potential board members?
Answer. No, I don't.
Question. Do you recall having seen this memorandum?
Answer. I do not recall it.
Question. Do you remember whether you ever submitted names of
individuals as recommendees for the President's Export Council?
Answer. I don't recall it.
Question. Do you remember any--anybody following up on this
request--any request for names to be submitted for the President's
Export Council?
Answer. I don't recall it.
Question. Did you ever suggest that DNC donors attend White House
movies?
Answer. No.
Question. Are you familiar with the term of art ``White House
database''?
Answer. Yes.
Question. Did you ever have access to any materials produced by the
White House database?
Answer. Yes.
Question. And what materials did you have access to?
Answer. I remember--I didn't have physical access, but requesting
of someone who had access to see whether certain people had been
invited to certain events at the White House.
Question. And did you make a request to obtain this information?
Answer. Yes I did.
Question. And who did you make the request of?
Answer. A gentleman named Donald Dunn.
Question. And who is Mr. Dunn?
Answer. At that time he worked in the Office of Political Affairs
at the White House.
Question. And did you make requests on more than one occasion of
Mr. Dunn to provide this information?
Answer. Yes.
Question. What was the format of the information that he provided?
Answer. There was no format. He would--it was voice conversation.
Question. Is it fair to say that you provided him with a name, and
he provided you an answer as to----
Answer. Correct.
Question [continuing]. Whether the person had or had not been
invited?
Answer. Correct.
Question. Did you ever provide information to be included in the
White House database?
Answer. Not that I recall.
Question. Did Mr. Dunn ever make requests of either yourself or
staff in your office to provide any information?
Answer. Not that I recall.
Question. Do you recall speaking with Mr. Dunn on more than the one
occasion that you just discussed?
Answer. I spoke to Mr. Dunn probably half a dozen times.
Question. And was it always for the same reason?
Answer. Some--no, at certain times I made a request of Mr. Dunn to
provide a White House tour for family or individual donors.
Question. Did you ever receive any lists of names or information
that was generated by the White House database?
Answer. I don't know if it was generated by the database, but I
received a list of names from the Office of the Social Secretary.
Question. And what were these lists of names for?
Answer. On occasion they would request of us lists of possible
invitees to events that the White House would be hosting. They would
send back a response list.
Question. Do you know whether the DNC had an autopen for the
President's signature?
Answer. My recollection is that we did not have one.
Question. Regarding materials that had the President's signature,
and I'll ask you specifically about photographs that were signed by the
President, when you were attempting to obtain photographs for people,
who would you make your requests of?
Answer. For the photographs?
Question. Yeah.
Answer. Sometimes Mr. Dunn. There was a woman at the DNC that I
worked with, a woman named Brooke Stroud, who would assist in obtaining
photographs from the White House.
Question. Just a--I think my last question on this go-around, you
mentioned at the very beginning when we were discussing Ernst & Young
and the materials Ernst & Young prepared that you knew of an Ernst &
Young individual who was a trustee. Who was that individual?
Answer. His name was Jeffrey Hershberg.
Question. And when did you meet him, or have you ever met him?
Answer. I have met him. I believe I didn't meet him until I
returned to the DNC. He was already a trustee at that time. So
subsequent to my return, beginning of 19--end of 1993, beginning of
1994.
Question. What was his job at Ernst & Young?
Answer. He was vice president--vice chairman was his title. I
believe he directed the Washington office, lobbying office, for the
company.
Question. Do you know if he is still an Ernst & Young employee?
Answer. When I left here 5 months ago, he was. I have not had
contact with him in 5 months since I left, so today I do not know.
Question. How did you obtain your current job in California?
Answer. I knew an individual who was working with the same company
who had the position basically as I have it now. And he was leaving the
position to assume a different role and approached me about filling the
position.
Question. And who was this individual?
[Witness confers with counsel.]
Mr. Lu. Counsel, I don't know how much you're going to----
Mr. Pierson. Just let him answer this question.
The Witness. The gentleman's name is Darius Anderson.
Mr. Wilson. Thank you very much. That concludes my round of
questioning.
Mr. Lu. Can we take just a quick 5-minute break while I confer with
counsel?
Mr. Wilson. Can we go off the record for a second?
[Discussion off the record.]
[Brief recess.]
Mr. Lu. Let's go back on the record.
Mr. Wilson, I--you're done with your questioning?
Mr. Wilson. Yes, I am.
Mr. Lu. Okay.
EXAMINATION BY MR. LU:
Question. Mr. Swiller, on behalf of the Democratic Members of the
committee, I want to thank you for coming in today. I realize this must
have been a great burden on you coming from the west coast, but we
appreciate your time.
Just a couple clarifying questions I want to ask you. Can you tell
me again how many trustees or managing trustees there were at the DNC
during the time you worked there?
Answer. It grew during the time I was there. By the time I was
finished, or by the time in the '96 election, it was approximately
around 800.
Question. About 800.
Mr. Wilson has asked you about a number of them today and a couple
of more newsworthy ones. At the time that you worked at the DNC prior
to November of 1996, had there been any news accounts about Johnny
Chung, Pauline Kanchanalak, Charlie Trie?
Answer. Not that I recall, no.
Question. So at that time, you, prior to November 1996, you had no
particular reason to pay special attention to correspondence that you
received from them or requests that you received from them any more
than from any other trustee?
Answer. That's correct.
Question. I would like to ask you to clarify the terms ``trustee''
and ``managing trustee.'' When I think about a university having a
board of trustees or a company having a board of directors, I have a
sense that these people play a role in the day-to-day operations of a
university, a corporation, what have you, and especially when I think
about the terms ``managing trustee'' or ``managing director.'' My
understanding, however, is that with regard to the DNC, the use of the
term ``trustee'' and ``managing trustee'' is more of an honorary term.
Is that consistent with your understanding?
Answer. No. My understanding is they are--the names were consistent
with the level of contribution or level of funds raised for the party.
Question. Well, no, I think what my question was really getting at
is whether those people had a role in the day-to-day operation of the
DNC?
Answer. Absolutely not.
Question. With regard to Pauline Kanchanalak, I gather that she was
a trustee at the time that you joined--you rejoined the DNC in December
of 1993?
Answer. That's my recollection, correct.
Question. So from there on out, when you received checks from her
that were P. Kanchanalak, you had no reason to believe that they were
anything other than checks from Pauline Kanchanalak?
Answer. That's correct.
Question. I believe you also testified that you attempted to
contact Mr. John Huang when he worked at the Department of Commerce;
isn't that correct?
Answer. That's correct.
Question. Did you actually getting ahold of Mr. Huang that one time
you tried to call him?
Answer. I never did.
Question. With regard to Johnny Chung, I believe you said when you
visited him at his office in California in spring of 1995, you chuckled
because you saw a whole wall full of photos that he had taken. You
mentioned that there were some of Republican leaders. Did he tell you
or did you ask him how he obtained those photos?
Answer. No, I don't recall that conversation.
Question. Did you have any understanding as to whether he had given
money to the Republican Party or attended Republican fund-raising
events?
Answer. Judging from the pictures, they were very similar to DNC-
type staged pictures, so I assumed that--it was just an assumption on
my own, but not a discussion--that they were--you know, that he
received pictures like that at fund-raising events.
Question. When we spoke about Mr. Ruggiero, Mr. Joseph Ruggiero,
you explained that had he complained that he had received much better
treatment by the RNC in getting access to the Bush White House. And
you--I believe you had mentioned some of the perks that he had received
as a result of giving money to the RNC.
Other than your conversation, that conversation with Mr. Ruggiero
or that understanding as a result of Mr. Ruggiero, do you have any
understanding of the types of perks that the Republican National
Committee offered to its large donors?
Answer. My understanding was that they included many more of their
financial supporters at events at the White House, at small delegation
meetings, meetings with Members of Congress much more frequently as a
system of their fund-raising apparatus.
I also recall, when we were discussing the possibility of putting
together a brochure for our trustees, we referenced the RNC Team 100
brochure, which, as I recall, had a picture of what they called a trade
mission. It was a picture at the wall of China of approximately 50
people standing at the wall and indicated that, you know, their--
through the RNC's efforts, these donors met with the highest-level
officials in other countries.
Question. And did you gather from that photo that that RNC trade
mission included officials of whether it be the Reagan administration
or the Bush administration?
Answer. I couldn't draw that conclusion, no.
Question. Were you aware of any perks that the RNC offered to its
large donors that the DNC did not offer to its large donors?
Answer. I don't recall ever having the opportunity to bring
individual donors to the Oval Office to provide photos there. It was
always joked about, and I don't know the truth of this, that the
Republicans were much better at giving large contracts to their
supporters than we, and we couldn't figure out how to do that, which I
just took it as that and never looked into it or did anything to follow
up if that was true.
Question. With regard to these--I think you said these meetings
that--your ability to bring people to the Oval Office to meet with the
President, I believe you had earlier testified that some contributors
had asked you for--to set up meetings with the President and the Vice
President, and you had declined those requests because you thought that
was inappropriate?
Answer. That's correct.
Question. Okay. With regards to government boards and commissions,
the fact that you or someone at the DNC submitted a name for a
government board did not necessarily mean that the White House would
accept that name; isn't that correct?
Answer. More often than not there was no response to my request, or
the name was not accepted.
Question. In fact, when there's--typically when there's an opening
on a government board or commission, many people both inside and
outside the administration submit names for boards and commissions;
isn't that correct?
Answer. That's my understanding correct.
Question. Mr. Swiller, the last set of questions I have for you are
requested by Congressman Condit. He's asked us to ask these of all the
witnesses that are testifying before us.
I believe you've told us that you've provided deposition testimony
to the Senate; isn't that correct?
Answer. That's correct.
Question. And I'm curious, when you first learned that this
committee wanted to take this deposition, did you wonder why you needed
to be deposed again after you had already been deposed by the Senate?
Answer. Yes, I did.
Question. Can you estimate for me just very roughly what percentage
of the questions you were asked today were also asked by the Senate?
Answer. 80 percent.
Question. 80 percent. And I also understand you've been interviewed
by the FBI?
Answer. That's correct.
Question. And I gather a lot of the questions that the FBI asked
were the same ones that have been asked today?
Answer. That's correct.
Question. Have you been notified of any other testimony that you're
scheduled to give in the future?
Answer. Not yet.
Question. And I believe that when--I believe that you were at the
DNC when some of the first congressional document requests were served
upon the DNC; is that correct?
Answer. That's correct.
Question. Do you recall how much time you spent searching for
documents at the DNC responsive to those requests?
Answer. Probably each request required half a day of work.
Question. Can you estimate a total of----
Answer. Four hours. I think there were three requests.
Question. Four hours for each request?
Answer. Right.
Question. Okay. And since you have left the DNC, have you spent any
time searching for documents responsive to document requests?
Answer. I no longer have any documents.
Question. Other than the time that you've spent in this deposition,
how much other time--well, actually let me stop that question.
In connection with this entire investigation, can you give me an
estimate of how much time you have spent? And that would include the
Senate testimony, the FBI testimony, your testimony here, all the
preparation time, all the travel time, conversations. We'll leave it at
that.
Answer. Probably 2 weeks of time.
Question. And I assume this is the time that you have not been able
to spend at your job?
Answer. That's correct.
Question. Other than your time, this 2 weeks that you've said, have
you--I've assumed you've incurred other expenses to come here, travel
expenses, hotel expenses, things like that?
Answer. Most of the travel expenses have been incurred by the
committees that have requested my presence, and the majority of the
burden of my expenses has been placed on the DNC.
Question. And obviously there's the time off from work I gather?
Answer. Oh, yeah. I mean, that's probably the greatest expense, my
lost time.
Question. And if it is available, will you seek reimbursement from
this committee for your time?
Answer. Yes.
Mr. Wilson. I have nothing further. Thank you again for coming
today.
The Witness. Sure.
Mr. Pierson. Sorry for coaching.
Mr. Wilson. Thank you very much, Mr. Swiller.
Mr. Pierson. Thank you, gentlemen.
[Whereupon, at 5:12 p.m., the deposition concluded.]
[The exhibits referred to follow:]
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[The deposition of Dick Morris follows:]
Executive Session
Committee on Government Reform and Oversight,
U.S. House of Representatives,
Washington, DC.
DEPOSITION OF: RICHARD S. MORRIS
Thursday, August 21, 1997
The deposition in the above matter was held in Room 2247, Rayburn
House Office Building, commencing at 9:15 a.m.
Appearances:
Staff Present for the Government Reform and Oversight Committee:
Barbara Comstock, Chief Investigative Counsel; Kristi Remington,
Investigative Counsel; Michelle E. White, Investigative Attorney; Greg
Zoeller, Majority counsel; Elliot Berke, Majority staff; Kenneth
Ballen, Minority Chief Investigative Counsel; Andrew J. McLaughlin,
Minority Counsel; Phil Schiliro, Minority staff director; David Sadkin,
Minority counsel; and Kristin Amerling, Minority counsel.
Also present: Representative Cummings.
For MR. MORRIS:
DAVID LENEFSKY, ESQ.
Attorney & Counselor at Law
18 East 48th Street
New York, N.Y. 10017
Ms. Comstock. On the record. Good morning, Mr. Morris. I would like
to begin by thanking you on behalf of the members of the Committee on
Government Reform and Oversight for appearing here today. I am going
through an opening statement here we read to all our witnesses.
This proceeding is known as a deposition. The person transcribing
this proceeding is a House reporter and notary public. I will now
request that the reporter place you under oath.
THEREUPON, RICHARD S. MORRIS, a witness, was called for examination by
Counsel, and after having been first duly sworn, was examined and
testified as follows:
Ms. Comstock. I would like to note for the record those who are
present at the beginning of the deposition. My name is Barbara
Comstock. I am the chief investigative counsel on the committee. I am
accompanied today by Kristi Remington as Majority counsel and Michelle
White, who is also Majority counsel.
Ken Ballen is the designated Minority counsel for the committee
this morning, and he is accompanied by Andy McLaughlin.
Mr. McLaughlin. Andrew, actually.
Ms. Comstock. With the Minority staff.
The deponent is represented by Mr. Lenefsky.
Although this proceeding is being held in a somewhat informal
atmosphere, your testimony here today has the same force and effect as
if you were testifying before the committee or in a courtroom.
If I ask you about conversations you have had in the past and you
are unable to recall the exact words used in the conversation, you may
state that you are unable to recall those exact words and then you may
give me the gist or substance of any such conversation to the best of
your recollection.
If you recall only part of a conversation or only part of an event,
please give me your best recollection of those events or parts of
conversations that you do recall.
If I ask you whether you have any information upon a particular
subject----
Mr. Lenefsky. Can you identify the gentleman who just walked in?
Ms. Comstock. It is another Majority member of the committee.
The Witness. What is your name?
Mr. Berke. Elliot Berke.
The Witness. Member or counsel?
Ms. Comstock. Staff member of the committee, on the Majority staff.
If I ask you if you have any information upon a particular subject
and you have overheard other persons conversing with each other
regarding it or seen correspondence or documentation regarding it,
please tell me that you do have such information and indicate the
source, either a conversation or documentation or otherwise, from which
you have derived such knowledge.
Before we begin the questioning, I would like to give you some
background about the investigation and your appearance here.
We have another staff member.
Mr. Ballen. David Sadkin.
Ms. Comstock. He is with the Minority staff.
Pursuant to its authority under House Rules X and XI of the House
of Representatives, the committee is engaged in a wide-ranging review
of possible political fund-raising improprieties and possible
violations of law within the committee's jurisdiction.
Pages 2 through 4 of House Report 105-139 summarizes the
investigation as of June 19, 1997, and encompasses any new matters
which arise directly or indirectly in the course of the investigation.
Also, pages 4 through 11 of the report explain the background of the
investigation.
All questions related either directly or indirectly to these
issues, or questions which have a tendency to make the existence of any
pertinent fact more or less probable than it would be without the
evidence, are proper.
The committee has been granted specific authorization to conduct
this deposition pursuant to House Resolution 167, which passed the full
House on June 20, 1997. Committee rule 20, of which you have received a
copy, outlines the ground rules for the deposition.
Majority and Minority committee counsel will ask you questions
regarding the subject matter of the investigation. Minority counsel
will ask questions after Majority counsel has finished. After the
Minority counsel has completed questioning you, a new round of
questioning may begin.
Members of Congress who wish to ask questions will be afforded an
immediate opportunity to ask their questions at any time when they may
be present. When they are finished, committee counsel will resume
questioning.
Pursuant to the committee's rules, you are allowed to have an
attorney present to advise you of your rights. Any objection raised by
your attorney during the course of the deposition shall be stated for
the record.
If the witness is instructed by his attorney not to answer a
question or otherwise refuses to answer a question, Majority and
Minority counsel will confer to determine whether the objection is
proper. If Majority and Minority counsel agree that a question is
proper, the witness will be asked to answer the question.
If an objection is not withdrawn by the witness' attorney, the
chairman or member designated by the chairman may decide whether the
objection is proper.
This deposition is considered as taken in executive session of the
committee, which means it may not be made public without the consent of
the committee, pursuant to clause 2(k)(7) of House Rule 11. You are
asked to abide by the rules of the House and not discuss with anyone,
other than your attorney, this deposition and the issues and questions
raised during this proceeding.
Finally, no later than 5 days after----
Mr. Lenefsky. Excuse me.
The Witness. Just one second.
[Discussion off the record.]
Mr. Lenefsky. Please continue.
Ms. Comstock. Finally, no later than 5 days after your testimony is
transcribed and you have been notified that your transcript is
available, you may submit suggested changes to the chairman.
I would just like to let you know, with agreement of counsel, we
have been waiving that 5 days, if you need additional time. Also, we
can make arrangements to mail the transcript to you so you can have an
easier time reviewing it.
We do ask, however, that you sign a form, that Majority and
Minority counsel have agreed upon, that asks both you and the client to
sign a form saying you haven't shared the deposition with anybody when
we let it out of the committee offices.
The transcript will be available for your review at the committee
office.
Also, committee staff may make any typographical and technical
changes requested by you. Substantive changes, modifications,
clarifications, or amendments to the deposition transcript submitted by
you must be accompanied by a letter requesting the changes and a
statement of your reasons for each proposed change.
A letter requesting any substantive changes, modifications,
clarifications, or amendments must be signed by you. Any substantive
changes, modifications, clarifications, or amendments shall be included
as an appendix to the transcript, conditioned upon your signing the
transcript.
Do you have any questions about anything we have gone over so far?
The Witness. No.
Ms. Comstock. I just want to go through a few ground rules. I just
want to indicate for the record that the House committee may regard
this as an informal setting, but it seems pretty formal to me.
Mr. Ballen. I just want to add to the remarks, so that you and your
counsel are aware, that under House Rule 11(2)(K)(8), any objections as
to relevancy or pertinency are a matter for the committee to decide and
rule on.
Mr. Lenefsky. I understand, reading the rules, it would first go to
the chairman.
Mr. Ballen. First goes to the chairman and then is appealed to the
committee. Some issues are for the chairman. But objections as to
relevancy or pertinency do go to the committee ultimately.
Ms. Comstock. I will be asking you questions concerning the subject
matter of this investigation. I would ask, if you don't understand a
question, you please say so, and I will repeat it or rephrase it so you
do understand the question.
The reporter will be taking down everything we say and will make a
written record of the deposition. You must give verbal, audible answers
because the reporter cannot record what a nod of the head or other
gesture may mean.
Do you understand that you must give audible answers?
The Witness. Yes.
Ms. Comstock. If you can't hear me, please say so, and I will
repeat the question or have the court reporter read the question to
you.
I would ask that you wait until I finish each question before
answering. I will wait until you finish your answer before I ask the
next question. Do you understand that this will help the reporter make
a clear record because he cannot take down what we are both saying at
the same time?
The Witness. Yes.
Ms. Comstock. Okay.
Mr. Ballen. Kristin Amerling with the Minority staff.
Ms. Comstock. We have another Minority staff member arrive.
Your testimony is being taken under oath today as if we were in
court, and do you understand that your answers will be assumed to be
responsive to the questions?
The Witness. Yes.
Ms. Comstock. Are you here voluntarily or as a result of a
subpoena?
The Witness. Voluntarily.
Ms. Comstock. Do you have any questions about the deposition before
we begin?
Mr. Lenefsky. No.
examination by ms. comstock
Question. Could you please state your full name and address for the
record?
Answer. Richard S. Morris, M-O-R-R-I-S.
Question. And do you have any other addresses?
Answer. Yes.
Question. Could you provide those for the record?
Answer. [Redacted.]
Question. Can you provide your phone numbers for each of those
addresses, please?
Answer. [Redacted.]
Question. Has that been the same from approximately 1994 to the
present?
Answer. Yes.
Question. Okay.
Answer. [Redacted.]
Mr. Ballen. Excuse me, Counsel. I want to add something for the
record here. I assume that before--if these depositions are ever voted
on to be publicly released by the committee--last time they were placed
on the Internet--that Mr. Morris, in the interests of privacy, his home
numbers be removed from any such public release.
Mr. Lenefsky. Thank you for that information. I didn't realize
there is a possibility this would be on the Internet or, in fact,
released to the public.
Mr. Ballen. There certainly is. If the committee votes to do that,
these depositions could be publicly released.
The Witness. Particularly if it is in the section on cybersex, I
would like it deleted.
Ms. Comstock. I would say for the record, last year that was by
agreement of the Majority and Minority Counsel that all of the
depositions be made public, and no questions had been raised at that
time. But we will be happy to entertain any concerns in that matter.
The Witness. I would request the phone numbers be deleted. Yes, go
ahead.
EXAMINATION BY MS. COMSTOCK:
Question. Could you provide for us any cellular phone or other
phones you may have had between 1994 to the present?
Answer. Oh, I had one during the campaign, but I don't recall the
phone number and I don't have it any more.
Question. Do you know who paid for that cellular phone?
Answer. Yes; Clinton/Gore.
Question. Was that one number that you had throughout the----
Answer. Yes.
Question. Do you know approximately when you got that phone number?
Answer. Early '95.
Question. And do you know how long you kept it?
Answer. Until August 26th, '96.
Question. Those phone bills were all paid for by Clinton/Gore?
Answer. Yes.
Question. And to your knowledge, did Clinton/Gore maintain all of
those?
Answer. Yes. I also have a car telephone, and the phone number in
the car is [redacted], and I have had that continuously since '94.
Question. All right. Have you discussed this deposition this
morning with anyone other than your attorney?
Answer. No.
Question. Have you----
Answer. With my wife, but no one else--no, no, I am sorry; yes, I
did. I was interviewed by the Washington--somehow, the Washington Times
and the New York Post and USA Today all learned of the deposition and
they all called me for comment, and I did interview them about this
deposition.
Question. About this deposition or yesterday's deposition?
Answer. They actually called knowing about today's, not
yesterday's, and I told them about yesterday's.
But this was before yesterday. Is that clear?
Mr. Ballen. For the record, yesterday being the Senate?
The Witness. Yes. In other words, they had information about the
House deposition, not about the Senate.
EXAMINATION BY MS. COMSTOCK:
Question. Okay. Could you please describe your employment history
from college forward?
Answer. After college, I worked as a research analyst at the New
York City Citizens Budget Commission, a civic watchdog group. After
that, I was employed by--I was basically self-employed, and my company
was called Public Affairs Research Organization.
In 1977, I joined another firm that I owned called Dresner, D-R-E-
S-N-E-R, Morris, Tortorello, T-O-R-T-O-R-E-L-L-O. I worked for them
through the end of 1982.
From 1983 on, I have been self-employed either through my own name
or Dick Morris Consulting or Message Advisers. And in 1995, in July of
1995, I became an employee of the Clinton/Gore campaign and remained in
their employ until August 1996, and I have been either self-employed or
unemployed, as you wish, since then.
Question. When was the first time you met President Clinton?
Answer. In November--roughly November 1977.
Question. And were you working for him on a campaign at that time?
Answer. I was asking to be hired by a campaign at that time, and
shortly thereafter I was.
Question. And could you describe in your history working with Mr.
Clinton from that time forward?
Answer. He engaged me about December of 1977 to advise him on his
gubernatorial race in 1978 in Arkansas. I did so. He dismissed me
sometime in 1979; I don't recall exactly what month. Then he hired----
Question. The circumstances, you just stopped working?
Answer. No; he fired me.
Question. And is there any reason?
Answer. He didn't--he felt that he wanted to hire someone else who
had more of a national reputation, and he disagreed with one of the
recommendations I gave him, which is that he should not raise taxes,
and he felt that it was unduly intrusive of me to make recommendations
of that sort.
He rehired me the day after Election Day in 1980, after his defeat,
and I was in his employ as a consultant more or less continuously
between then and January 1991.
I say more or less because there were times during that period when
I was paid a monthly retainer, and there were times when I was not, I
was just paid on a poll-by-poll basis.
I stopped work for him professionally in January of 1991. I had no
professional involvement with him between January of 1991 and November
1994--I am sorry, October 1994, and--although I did chat with him and
advise him over the phone just as a friend.
Then I worked for him part-time between November '94 and June '95
and full-time from July '95 until August '96.
Since August '96, I have no professional relationship with him. As
before, we continue to talk, to chat.
Question. Okay. You said throughout the eighties, essentially, you
were either on a monthly retainer or paid on a poll-by-poll basis.
Answer. Correct.
Question. Were you paid by Mr. Clinton's campaign operation?
Answer. I don't recall. Generally speaking, yes, and I was never
paid by the State of Arkansas, never paid by tax money. I cannot recall
the names of the different campaign committees that paid me though, but
it was always by some committee that he controlled, whether it was a
campaign committee or committee for education in Arkansas or something
like that.
Question. Okay. Do you know if you were ever paid by any
independent sources or independent expenditure-type money?
Answer. I can't be completely certain, but I have no recollection
of ever having been paid by any such entity. I don't believe that I
was. But I did receive probably 1,000 checks from him over the course
of the eighties, and it is conceivable that one of them might have been
something like that, but I have no recollection of it.
Question. When you said you thought you may have been paid by an
education committee, was that something separate from a campaign
committee?
Answer. Yes. I don't recall how he paid me, but in 1983 I worked
with him on ads, very similar to the ones we ran in '95, which were
issue advocacy ads in connection with his desire to increase the sales
tax in Arkansas and test teachers. And there was a committee that was
separate from the campaign that raised money for that effort. And he
might have paid me through that, or I might have been paid through his
campaign; I don't recall.
Question. Do you have any knowledge of who contributed to those
committees?
Answer. No.
Question. In any of the work you did for Governor Clinton, did you
ever work with an individual named David Watkins?
Answer. Yes.
Question. On what occasions did you work with Mr. Watkins?
Answer. Constantly, throughout the whole period. He was the person
who produced the advertisements for Clinton, and in virtually--in any
of the campaigns, except for the 1978 campaign, which is to say in the
'82, '84, '86, and '90 campaigns, he would be in virtually all of the
meetings that we had in the 2 or 3 months before Election Day, and he
and I would work together to produce the ads for Clinton.
Question. And were you aware of him working in the '92 campaign?
Answer. Yes. I had one occasion to be aware. He called me--he had
occasion to call me at one point in roughly February of 1993--1992.
Question. And----
Answer. It was right before the New Hampshire primary, and he was
seeking advice and basically asked me if I would receive a call from
Governor Clinton, and I said I would. And the next--I was in France, so
I remember it. The next day, the Governor called and we talked for
about 40 minutes or an hour or so on this campaign, and I gave him
political advice at that time.
But other than that, I had no contact with Watkins during the '92
campaign.
Question. All right. Have you been in touch with Mr. Watkins
recently at all?
Answer. No. I called him after--a couple of months after he had to
resign. I forget when that was, I think it was in '94.
Question. May of '94, he left the White House.
Answer. So I called him at one point toward the end of '94 just to
tell him I still liked him and cheer him on, and I had--I think I may
have called him back a few weeks later in the same vein. But since
that, I have had no contact with him.
Question. Did you ever talk with him about any investigations at
the White House?
Answer. No, except to tell him that I thought that the President
acted precipitously in discharging him.
Question. Regarding the helicopter incident?
Answer. Yes.
Question. Did you have any knowledge of that incident----
Answer. Just what I read in the paper.
Mr. Ballen. I object to that line of questioning. I didn't know
this committee's charge was to reopen that, the Watkins matter.
You can proceed, Counsel.
EXAMINATION BY MS. COMSTOCK:
Question. Other than this call that you said in 1992, did you have
any other role in the 1992 campaign?
Answer. Yes. I spoke with the President five or six times during
the '92 campaign, and with the now First Lady probably a dozen times,
just on the basis where I was just offering advice and counsel. It was
not a paid relationship or a formal one.
I didn't meet with either of them during 1992, but I did have those
occasions to speak to them, to give them political advice.
Question. All right. And in 1992 or any time you worked during the
1980s on Clinton campaigns, did you ever have an opportunity to meet
with someone named John Huang?
Answer. No.
Question. You have never met Mr. Huang?
Answer. No.
Question. Do you have any knowledge about Mr. Huang's fund-raising?
Answer. Just what I read in the paper.
Question. Did you ever have any occasion to meet any member of the
Riady family?
Answer. No.
Question. Do you have any knowledge about any fund-raising by the
Riadys?
Answer. No. The only person vaguely in that ilk who I have ever met
was, I may have met Mr. Trie, because I ate at his restaurant and I may
have seen him then, but I didn't know it was him until--I still don't
know if I have ever seen him. He is a smiling guy that greeted you as
you walked in. I didn't know if it was him.
When you are in----
Question. He also has restaurants in Beijing.
Answer. When you are in Arkansas, you eat Chinese food.
Question. Do you have any knowledge of any particular people or
groups of people who are involved in fund-raising throughout the
eighties, any core group of people in Arkansas that you knew of?
Answer. Well, I knew that Betsy Wright was heavily involved in the
fund-raising. I knew that Maurice Stans was involved--is that the Nixon
person? No, Maurice somebody or other.
Question. Maurice Stans was a Nixon fund-raiser.
Answer. It was an old codger named Maurice something or other, who
hung around, who was supposed to have access to money. I just vaguely
knew that the two of them were doing something in raising money.
I knew that Clinton required constant badgering to make fund-
raising phone calls, and I would just periodically tell him, you know,
I hope you are raising money. A couple of times I would be recommending
media expenditures, and he would be saying, I don't have the money for
those, and then I would say something like, you better go out and
borrow the money for those, because we got to put those ads on, because
we will lose if we don't.
But other than demand for money on the expenditure end, I had no
knowledge at any time of where any of the money came from in terms of
donors, fund-raisers, parties, or anything like that.
Question. And when you made recommendations such as you just
relayed about that the President better, or at that time the Governor,
needed to spend the money or borrow it, that this was essential, did
the President usually--did Mr. Clinton usually take your advice?
Answer. The Governor did, almost all the time.
Question. He had trust in your judgment on those types of matters?
Answer. Yes. See, unlike you, I am used to calling him Governor.
Question. Get the names and time sequences correct.
Okay, could we move a little, going to when you first started to
work for Mr. Clinton as President Clinton.
Answer. Yes.
Question. Can you describe how that came about?
Answer. During--shortly after the '92 election, I met with the
President-elect and the First Lady-elect in Arkansas, and we had a
meeting of an hour or two hours, and the President-elect asked me if I
would occasionally call him with ideas and advice and meet with him
from time to time and keep a more regular contact with the First Lady
to provide a channel of advice for him.
During 1993 and 1994, through October--through the last week of
September 1994 would be the end of this period--I had occasion to meet
with the President probably 8 to 10 times, meet with the First Lady
three or four times, speak to the President by phone three or four
times, and speak to the First Lady by telephone 30 to 50 times. None of
that was paid, and in all of the conversations I was just offering
advice on matters that had occurred to me and things that I had thought
of. Virtually all of the contacts were initiated by me.
So I think that describes our relationship during that period.
Shall I pause?
Question. Did you have a particular phone line that you called them
on?
Answer. No.
Question. You just called the main switchboard and would--who did
you usually contact to try to get through?
Answer. To speak to the First Lady, I would call Pam Sipareti, I
think, or something like that, who works for the First Lady. [Redacted]
was the number I would use. And when I was calling the President, I
would call, the switchboard, and get connected through that way.
Question. You would usually go through Ms. Hernreich or his main
office?
Answer. Usually Ms. Hernreich or Ms. Currie.
Question. Okay. Why don't you continue on?
Answer. Okay. In the last few days of September or the first few
days of October of 1994, the President called me and asked me to do a
survey for him, the first professional engagement I had had with him
since January of 1991. And I did the survey concerned the positioning
that he and the Democratic Party should assume in the '94 bi-year
elections.
I did the survey. I briefed he and the First Lady on the results
and was paid for the survey.
Question. And who paid you for that?
Answer. I am afraid I recall neither end of that transaction. I
don't recall who paid me, and I don't recall who they paid. I don't
recall whether the check was--I only charged him the actual cost of the
interviews, and I may have told them to send the check to the
interviewing house I used to do the survey, which was called Action
Research in Melbourne, Florida, which is the interviewing house I
usually use.
Or I may have asked him to send the check to me, and I may have
then paid the interviewing house. I don't recall which one it was. And
I don't recall which entity paid for the survey, whether it was DNC or
Clinton campaign or anything of that sort. I have no recollection of
that.
I think that, but I am not sure, the check was probably paid
directly to the interviewing house rather than to me, since I do recall
that I decided not to make a profit on it, because I felt that by
holding the price down, I would encourage him to seek my services more
frequently in the future.
Question. At that time, was there any concern about paying you
directly, going to the DNC or Clinton/Gore and putting you on the
payroll?
Answer. Yes, I think probably one of my motivations, if I did have
them pay the interviewing house--in fact, as I recall, I think I did,
now that you mention that.
I was concerned that I didn't want to be publicly identified as
working for Clinton at that point, so I may have had them pay the
interviewing house directly. To make sure that it was honest, I then
didn't take any money for it, so it was not like a subterfuge. I was
just doing my polls for free, and he was paying me, the vendor,
directly.
Question. And you briefed the President and the First Lady on this
poll?
Answer. As I said, yes.
Mr. Lenefsky. Can you identify that person?
Mr. Ballen. Phil Schiliro with the Minority staff.
Mr. Lenefsky. Now the Majority is the minority.
EXAMINATION BY MS. COMSTOCK:
Question. Now I am the minority.
Okay. Can you continue what the professional relationship was here?
Answer. After the election, I met with the President and the First
Lady during November and early December to explore working together on
his 1996 campaign.
My next professional involvement with him--that is, next paid
involvement--came in early December of '94 when he asked me to conduct
a survey in connection with the middle class tax cut speech that he
gave to the Nation in the middle of December, to advise him on the
content of that speech. I did, and I was paid for that.
And I am unsure whether I did the polling through the Melbourne,
Florida, interviewing house or through Penn & Schoen, the polling
company I subsequently used. I know that the third poll I did for him,
which was in January, was through Penn & Schoen, but I am unsure of who
was the vendor on the second poll. And I believe that the way I was
paid for that poll, again, was that the interviewer was paid directly
for that survey.
No, as a matter of fact, as I think about it, no, something
reminded me which I had forgotten yesterday; it was Penn & Schoen for
that poll. So that I went to Penn & Schoen, the interviewing firm,
polling firm, and asked them to conduct the survey, and I would write
the questionnaire, they would field it; they received the money from
Clinton; I don't know what entity paid him; and they then paid me as a
consultant to them on this polling project.
Question. And Penn & Schoen is based in----
Answer. New York.
Question. New York.
Answer. Two N's.
Question. Did you advise Mrs. Clinton at all on her health care
reform policies?
Answer. Yes. A lot of our phone conversations in '93 and '94
related to that.
Question. And were you aware of any particular media efforts or
fund-raising efforts directed towards media for health care?
Answer. Paid media.
Mr. Ballen. Excuse me, Mr. Morris. I am going to object to this
line of questioning on relevancy and pertinency. There is nothing in
the committee's resolution authorizing the taking of depositions or in
the report that remotely touches upon health care policy and any advice
Mr. Morris might have given with regard to that in 1994.
We are very far afield here. We have had about 40 minutes of
questioning, and Mr. Morris has already said he didn't know Mr. Huang,
Mr. Trie, or the Riadys, which are the subject matter of this
investigation. I haven't objected until now because I allowed counsel,
except for the Watkins matter, some latitude to get into background.
At this point, discussing health care campaigning and any advice
Mr. Morris gave on that, we will object as to relevancy and pertinency
to this deposition.
Ms. Comstock. We were talking about health care fund-raising being
done as well as Mr. Morris' knowledge of any efforts to raise money for
health care media campaign.
The Witness. Shall I answer the question?
Mr. Lenefsky. Yes.
The Witness. I am not aware of any efforts to raise money for the
health care media campaign. I did have occasion to speak to Mandy
Grunwald, who was producing the health care ads. I wrote one or two
commercials that I sent to her which she then did not use.
EXAMINATION BY MS. COMSTOCK:
Question. Were you paid at all for those?
Answer. No.
Question. Do you know--do you have any knowledge about Charlie Trie
providing money for the health care funding, health care media
campaign?
Answer. No. As I testified before, I know absolutely nothing about
Charlie Trie except he makes good lo mein at his restaurant.
Question. In the summer of--can you recall when you worked with
Mandy Grunwald on this media effort?
Answer. Sometime--I am not sure, but I think it was probably
sometime in early '94.
Question. Why don't we pick up from the December '94 middle class
tax cut speech and the assistance you provided there.
It is another court reporter. They just keep going out.
Answer. Okay. I then--in early December, the President asked me to
become involved as a consultant in his re-election campaign, and we
agreed that the relationship between us would be a private one, which
is to say secret one, because neither of us were really prepared for it
to be public at that point.
I wasn't prepared for it to be public at that point because most of
my clients were Republicans, and I knew that if I crossed the divide to
go to work for the President, that that would end my ability to work in
the Republican Party, and I wanted to be sure that it would be possible
for me to give him meaningful advice and that I wouldn't just be chewed
up and spit up, as previous advisers had been.
He, from his point of view, I think, didn't know if I could handle
play at this level, because I had only worked with him in one State,
and I think he wanted to take his time before he formally committed to
me, both because any involvement with the President usually is blown up
by the media, and if he brought me in and then cut off the
relationship, it would appear like vacillation on his part, and
bringing me in would cause him no end of grief with the liberal
Democrats on his staff because of my previous Republican affiliations
and my moderate political views.
I think he was unwilling to incur that political harm until it was
clear that I was important to him in the campaign and would work out.
So by mutual agreement, we did not publicly reveal the relationship.
We agreed that I would be paid on a poll-by-poll basis, and that
the polling would be conducted by Penn & Schoen, and that I would be
paid as a contractor to Penn & Schoen. That was both how I often was
paid and it was a convenience so that my name would be disclosed at the
time that the Federal filings took place, but not before.
To my knowledge, Penn & Schoen, when they filed, indicated that
they had paid me in their filing, or at least we submitted that
information to the campaign to be filed.
But had the campaign issued checks directly to me, I think the
President and I were both concerned that somebody would leak that that
was taking place.
Question. And you had discussions with the President about this?
Answer. Yes.
Question. What concerns did he express?
Answer. He said that he wanted--he said that he was concerned that
he did not want his staff to know at that point that I was working for
him, and that he wanted the relationship to be secret between us, and
that was the nature of what he said. And then I said, I suggest that
this is the way that you pay me so that it is not--so that we don't
release the story simply by the act of somebody writing a check.
I did a survey for him in January of 1995, under this arrangement,
with the survey conducted by Penn & Schoen, and then throughout the
rest of '95 until the end of June, I conducted with Penn & Schoen
probably five or six surveys for him, and Penn & Schoen received the
payments for those.
Question. Was that on a flat fee basis then?
Answer. No. It was a cost per poll, and some polls were more
expensive than others because some were longer than others.
Question. Who worked out the cost arrangements on those polls?
Answer. I worked out the charges with the President, and pursuant
to that, Shoen then would bill the President for the amount we had
negotiated together.
Question. So you personally discussed the payment levels with the
President?
Answer. Yes.
Question. And agreed upon them solely with the President?
Answer. Yes.
Question. And then you relayed that back to Penn & Schoen, who
would then bill the Clinton/Gore campaign or the DNC?
Answer. They sent the bills, as I understand it--this is second
hand--to Nancy Hernreich, and I do not know what happened to them then.
I don't know who paid them, when they were paid, or how they were paid.
I just gathered that they were paid.
Mr. Lenefsky. Excuse me for a minute.
[Brief recess.]
The Witness. My counsel reminds me that this arrangement continued
until the end of March 1995. At the end of March, the President
revealed to Harold Ickes that I was working for him and at that point
all billings were handled directly to Harold and Penn & Schoen would
send their bills to Harold.
EXAMINATION BY MS. COMSTOCK:
Question. At the White House?
Answer. I don't know where they sent it.
Question. Do you have copies of any of these bills yourself?
Answer. No.
Question. All of the billings then would have been maintained by
Penn & Schoen?
Answer. Yes.
Question. And then Penn & Schoen would send them to initially Nancy
Hernreich and then following that, directly to Harold Ickes?
Answer. Yes.
Question. Okay. And then you would be paid directly by Penn &
Schoen after they had been paid by whoever paid them?
Answer. Yes.
Question. And your testimony is that you do not know who paid Penn
& Schoen, whether it was DNC or Clinton/Gore?
Answer. That is correct.
Question. So all of the checks that you would have been getting for
these surveys were all checks that came from Penn & Schoen?
Answer. Correct.
Question. And then during the time, through March of 1995 when the
bills were being sent through Nancy Hernreich, did you ever discuss any
aspects of the bills with anybody at the White House?
Answer. No.
Question. Or why certain matters, how the billing was done?
Answer. No. I did have to speak to the President once or twice,
because they hadn't been paid, and Penn & Schoen advised me that they
had not been paid, and I mentioned it on one or two occasions to the
President, and then shortly after, Doug Schoen told me that they had
received payment, and then he paid me.
Question. Do you know what type of lag time you are talking about
in terms of payment?
Answer. I can't be certain, but I think it was in the range of
somewhere between 60 and 120 days.
Mr. Lenefsky. Excuse me.
[Counsel and witness conferring.]
The Witness. Yeah, right. I'm not sure how long--it was in
yesterday's deposition. I saw a document from Penn & Schoen to Ickes
complaining that they hadn't been paid in a long time, and actually it
did--it was more than 120 days, but I don't really know how long,
because it wasn't, it wasn't my bill or wasn't my company.
EXAMINATION BY MS. COMSTOCK:
Question. All right. Now, was their payment, though, contingent
upon Penn & Schoen getting paid or did Penn & Schoen pay you
immediately?
Answer. I think that what worked out was because the cash flow was
limited that they advanced monies to me from the--once they got one or
two checks, they advanced monies to me for the polling, for the future
polling, because they were in a sense postponing taking their profit
and paying me first. So it wasn't directly contingent, one wasn't
directly contingent on the other.
Question. Okay. And when these bills were late, you mentioned that
you went to the President about those bills?
Answer. Yes.
Mr. Ballen. Excuse me, Mr. Morris. I am going to object to this
line of questioning.
Counsel, I have let it go forward here for a little while because I
thought it was exploring the nature of the background of Mr. Morris'
relationship to the President. But I thought--and the resolution, if
you can point to me in the resolution or the report where we are
investigating campaign expenditure, polling expenditures, the billing
of polls, whether those polls were late or paid in a timely fashion,
what conversations Mr. Morris may or may not have had with the
President, if these somehow constitute an impropriety or a violation of
the law or fund-raising impropriety, a campaign impropriety or a
violation of the law, let me know, because then I would be happy to
withdraw my objection as to relevancy. But I don't--I fail to see how
this is relevant or pertinent to the scope of our investigation.
Mr. Lenefsky. May I take a 2-minute break to consult with my
client?
Ms. Comstock. Sure. We can go off the record.
[Discussion off the record.]
Ms. Comstock. This is another Majority counsel, Greg Zoeller, Z-O-
E-L-L-E-R.
The Witness. So Minority counsel had just objected.
Mr. Lenefsky. What was your last question?
[The reporter read back as requested.]
Ms. Comstock. Your counsel is the relevant counsel here in terms of
answering questions.
Mr. Lenefsky. I instructed him to answer the last question.
EXAMINATION BY MS. COMSTOCK:
Question. And in these discussions, what was your understanding of
what the President did following your discussions?
Answer. I don't know. The bill--I don't know what he did, but I
know that the payment flow improved.
Question. And what was your understanding of fund-raising
activities at the White House at that time?
Answer. None.
Question. And would you get the payments within a week or so, or do
you have any sense of the time?
Answer. No. There was still a lag, but since I didn't receive the
payments, I didn't monitor it closely. If they were unduly late, Schoen
would complain to me and I would mention it to the President, and if
they continued to be late, he continued to mention it to me, and when
he stopped mentioning it to me, I stopped asking him about it.
Question. Did you ever write any memos or----
Answer. I never did.
Question. Did Mr. Penn?
Answer. I saw yesterday in the deposition in the Senate some memos
that Penn & Schoen had sent to Ickes in connection with the delayed
payments, but that was the first I knew--it was the first I saw of
those memos.
Question. This would have been after the March '95 time when the
bills were sent to Mr. Ickes as opposed to sent through Ms. Hernreich?
Answer. Yes.
Question. Okay. And could you tell us when the bills started going
through Mr. Ickes, did any problems arise in that context?
Answer. Well, I became convinced over a period of time that Ickes
was deliberately slowing the payment process of the bills in the hopes
that we would become discouraged, die of cash flow starvation and go
away, and I voiced those suspicions to the President, and that was part
of the process of payment being speeded.
I do recall one time, sometime in the first half of '95, where I
was particularly vociferous in my criticism of Ickes to the President,
and accused him of manipulating the cash flow so that we couldn't
afford to continue to work for the President. Because we were--Penn &
Schoen were incurring huge interviewing costs that had to be paid when
the survey was done, and if the payment wasn't received for 6 or 8
months, and we were doing a survey virtually every month, they would
owe hundreds of thousands of dollars that they would have paid out to
the phone company and to their interviewers that they had not been
reimbursed, and at some point that nut would become so large that they
would have to stop doing polling. So I advised the President that that
was a possibility, and then as I recall, a number of checks came
through to Penn & Schoen shortly after that conversation.
Question. All right. Did you ever have conversations with Mr. Ickes
about these matters?
Answer. No.
Question. You went directly to the President?
Answer. Not that I can recall. I could have, but I tended to avoid
conversations with Mr. Ickes.
Question. And so you would go directly to the President about these
matters?
Answer. Yes.
Question. And what was the President's response?
Answer. There was one time when he said that's just outrageous that
you are not being paid for this work, you should be paid for this work;
I will take care of it. Other times he would just say, I will take care
of it, in a more muted tone, but once he expressed some anger that we
had not been paid.
Question. Okay. Now, initially you had said you had agreed upon the
payment rates with the President?
Answer. Yes.
Question. Did that continue throughout your time at the White
House?
Answer. No. After--well, why don't I just do a financial narrative
through the end of the time and then you can backtrack.
Question. Okay.
Answer. After March, after mid-March, the billings were sent to
Ickes, no longer to Hernreich, but it was still on a poll-by-poll
basis, and the costs of the poll were still agreed between the
President and myself. Then, at some point, and I don't recall when, but
it would have been around mid-1995, Harold secured--Harold was vested
by the President with the authority to approve polling--to approve
polling, and his approval was required before any poll could proceed.
Question. Is this any poll for the Clinton/Gore campaign?
Answer. Any poll that we undertook, that Penn & Schoen or I
undertook at the President's request, and I was not aware then, nor am
I aware now, of in the early days of who was the vendor on that poll,
who was paying for the poll.
Question. So you aren't aware in the '95 time frame whether it was
Clinton/Gore or DNC who was actually paying?
Answer. I'm not aware through about June of '95, before June of '95
who paid for it, roughly.
Question. Okay.
Answer. Then, at that point, the price negotiations as to what
would be charged for each poll were handled between Schoen and Ickes,
or Penn and Ickes, and I was no longer involved in that.
Let me just continue the polling piece of it.
At the end of June 1995, I stopped being paid as a subcontractor to
Penn & Schoen and established a direct financial relationship with the
Clinton/Gore campaign, which I will explain in a minute. But let me
continue the polling piece straight through.
After May or June of 1995, a procedure was developed by Ickes where
each poll that was conducted under this arrangement with the President
would be allocated retroactively to one--either to the DNC or to
Clinton/Gore, and each questionnaire was scrutinized, I gathered by
Lynn Utrecht and her staff question-by-question, and a percentage of
that survey questionnaire was assigned to DNC and a percentage was
assigned to Clinton/Gore.
Then I gather, although I didn't actually receive the checks, that
proportionate payment would be rendered by each of those committees.
The reason I know this is that a bottleneck developed and Utrecht was
very slow in making that assessment, and that caused cash flow problems
for Penn & Schoen that I again had to go to the President over and,
again, he had to speak to Ickes, and again, the bottleneck eased for a
short time.
Question. So each question was allocated as a DNC or a Clinton/Gore
question?
Answer. That's my understanding.
Question. And then payments would be split?
Answer. That is my understanding. Now again, I was not directly
involved in it. This is secondhand.
Mr. Ballen. Mr. Morris, Lynn Utrecht was a counsel?
The Witness. Counsel for the Clinton/Gore campaign.
My understanding is that each polling questionnaire had a separate
ratio of the two committees.
My financial relationship changed in--starting July 1st, 1995. I
became a consultant to--I became a consultant to the Clinton/Gore
campaign and was paid $15,000 a month by that campaign, and that
arrangement lasted until I resigned at--until I was fired at the end of
August. That was one source of compensation for me.
The second source of compensation was that when advertisements were
placed in connection with this process, whether by Clinton/Gore or by
the DNC, a commission arrangement was negotiated for each flight of
television, for each purchase of television, and those commissions were
then retained at first informally and then formally, by a collection of
the campaign consultants who I had brought in to work on the
advertising.
When I say informally, we at some point early on we would just
split the commission and then after a while we set up an entity called
the November 5th Group that had a contractual division among the
various consultants participating of each of the media commissions. The
source of the money for those commissions, of course, related directly
to who was paying for the advertising flight, so that if the Democratic
National Committee were paying for it, the commissions would come from
them, and if Clinton/Gore were paying for it, the commissions would
come from them.
EXAMINATION BY MS. COMSTOCK:
Question. It was the same rate for each?
Answer. Yes. And that arrangement continued straight through the
end of my tenure, so that I was compensated in those two forms through
the commissions and as a direct consultant for the Clinton/Gore
campaign.
Question. There was a commission for each flight of media and that
was split among the consultants?
Answer. That is correct.
Question. And how did you determine how the split?
Answer. We negotiated a split.
Question. Was that done by you among the consultants or was that
done by the White House?
Answer. Me among the consultants. We at one point, Erskine Bowles
asked us what the splits were and I told him. But they were determined
among the consultants.
Question. And the actual commission itself was negotiated with the
White House?
Answer. Yes, between--our negotiators for that--I felt that it was
unwise for me to negotiate this directly with Ickes so I appointed Mark
Penn and Bill Knapp, K-N-A-P-P, as the negotiators for us, and they met
with Ickes and Bowles and then Ickes and Sosnik after Bowles left, and
negotiated the commissions on a flight-by-flight basis. That was very
frequently an acrimonious negotiation, and on several occasions the--
and there was a great deal of friction in connection with those
discussions.
Question. And where did that friction come from?
Answer. Ickes trying to hold the figure down and we trying to move
the figure up.
Question. And can you just describe generally some of that
friction, you know, what occurred, the outcome of it?
Mr. Ballen. I am going to object again. This is very entertaining;
we have been going on for half an hour on this. But I fail to see--I am
happy to withdraw my objection if Majority counsel is simply willing to
state how this relates to campaign fund-raising, fund-raising
improprieties, I emphasize the word ``fund-raising'' and possible
violations of law. There is absolutely no plausible basis to articulate
that there is any possible violation of law here. If there is, we would
certainly be interested in hearing it because we are interested in
that. But there is no issue as to coordination or anything that
suggests it is a possible violation of law.
Mr. Lenefsky. Mr. Morris is free to answer.
The Witness. I was never present in these negotiations, so it is
secondhand, but at one point Ickes got so furious that he slammed the
door of his office as deputy chief of staff and broke the door frame
and contractors had to come in the next day and repair it, and there
was one occasion when Ickes refused to allow the time buy to proceed
unless we agreed to a lower commission rate, and we refused to agree to
a lower commission rate, and the President was confronted with the
decision that he would go off the air unless he resolved the dispute.
And he did resolve the dispute by ordering Ickes to accede to our
requests and the advertising continued uninterrupted.
EXAMINATION BY MS. COMSTOCK:
Question. Do you recall when that time frame was?
Answer. Sometime around May or June of 1996. But those kinds of
disputes were relatively frequent and I believe that they were a
deliberate attempt by Ickes to sew discord between myself and the
President and to try to disrupt my relationship with him.
Question. Now, back in the May-June, the summer of '95 time period,
did there come a time where you advocated some large media buys at that
time?
Answer. Yes. When I--the President had always known during his--
from the days of his relationship with me in Arkansas, that I believed
the campaign should be mainly waged over television and that anything
else you spend money on is more or less a waste of money, and that I
believed in heavy media expenditures, heavy paid media advertising.
When he hired me back in November and December, I told him that we
would have to--I said we should make this the first fully televised
Presidency in American history. Literally from wall to wall, we should
just be constantly on television using paid media as a new form of
Presidential communication, very much like Woodrow Wilson invented when
he delivered the State of the Union message in person as opposed to
sending it in writing. I recall citing the ratcheting up of
Presidential communications over the course of the 20th century.
But in November and December, January and February, we were so
focused on the State of the Union speech, the response to the
Republican contract proposals, and the development of our rhetorical
theme in opposing those or in accommodating them and opposing them,
that there really wasn't a lot of time for us to focus on the issue of
paid media.
In early March of 1996, I began a much more insistent request for
us to begin advertising, and I proposed----
Question. March of '96?
Answer. '95, excuse me. I proposed in early March of '95 that we--
that the Clinton/Gore campaign purchase $2.5 million of ads to stress
the President's anticrime record, and I recommended that those ads run
during April. April became May, May became June, and I finally got
permission to run the ads starting in the last few days of June, and
they ran throughout the month of July, paid for by the Clinton/Gore
campaign.
Question. At this time were you aware that the Clinton/Gore
campaign had resources to pay for this media?
Answer. I was not advised that they didn't have resources, but I
was unaware until--I was unaware of the precise financial condition of
the Clinton/Gore campaign until a meeting I had with Terry McAuliffe at
some point during the middle of 1995, at which point he briefed me on
the financial status of the Clinton/Gore campaign. And his briefing was
a very optimistic one, that they were going to reach their maximum
probably by the end of the year, and after that, there would be a
little bit of--the end of '95, and that there would be a little bit of
additional fund-raising, but that would trickle in through direct mail
and he wouldn't have to bother with it.
In March, April, May, June and July, I waged a vigorous campaign,
not just to get on the air, but to urge the President to reject Federal
matching funds. I felt that--and during the course of that period I
said that the Federal matching funds which would permit only about $30
million to be spent in nonfund-raising costs in the preconvention
period was an unduly low restriction and would not afford us the
capacity to advertise that we need it.
I said that since we likely did not have a primary, I felt the
public would be perfectly happy for us to say we don't have a primary,
so we are not going to take Federal funds to fight a primary.
Particularly when budget cuts were reigning down on the country, if
the President said, I would like that $11 million to go to the Head
Start program instead, that that would be a very good position for him
to take. I battled incessantly to get us not to accept Federal funding.
Question. And that would be so that you could have a larger media?
Answer. Yes.
Question. And you spoke with the President about this?
Answer. Frequently.
Question. So did you mainly speak with the President about it, or
were others involved in those conversations?
Answer. These conversations all tended to take place at weekly
strategy meetings that we held.
Question. And who was involved in those?
Answer. Okay. At the--in November of 1994, the President, the First
Lady, and me. In December 1994, the same. In January of 1994, the First
Lady----
Mr. Lenefsky. January of '95.
The Witness. '95, excuse me. The First Lady stopped attending and
she never attended again, and they would be just between the President
and myself.
Starting in the middle of February of '95, Doug Schoen was added to
the group and it was the President, Schoen, and myself. In about the
early part of March, and I could be wrong on these dates, but roughly
early March, Leon Panetta was added to the group, and at the end of
March, the Vice President, Erskine Bowles, Harold Ickes, and the Vice
President's chief of staff at the time, Jack Quinn, was added to the
group. Quinn continued to attend meetings until he left as chief of
staff for the V.P., at which point I believe David Strauss replaced him
for a few weeks, and after that, Ron Klain served in that position.
Question. So once Mr. Quinn moved over to be White House counsel,
he no longer attended these strategy meetings?
Answer. That is correct.
Question. Okay.
Answer. The meetings gradually expanded. I think the next expansion
was in September when Doug Sosnik and George Stephanopoulos started to
attend, and then the meetings expanded month-by-month, and I can't
really keep track of the actual expansion. If you hand me my book, I
will tell you the full list of people who attended these meetings.
Mr. Lenefsky. It is there on Page 26.
The Witness. It is written in there. It would be easier than trying
to remember it.
Ms. Comstock. I had it marked.
The Witness. I can find it faster than you. I wrote it.
Okay. Eventually included in these strategy meetings were the
President, the Vice President, Leon Panetta, Harold Ickes, Evelyn
Lieberman, George Stephanopoulos, Don Baer, Doug Sosnik, Ron Klain,
Sandy Berger, Senator Chris Dodd, John Hilley, Maggie Williams, Mike
McCurry, Henry Cisneros, Mickey Kantor, Mack McLarty, Peter Knight,
Anne Lewis, Ron Brown, and myself, Doug Schoen, Mark Penn, Bob Squier,
and Bill Knapp.
Mr. Lenefsky. Just for the record, it is on Page 26.
The Witness. And these----
Ms. Comstock. Page 26 of Mr. Morris' book, which is entitled
``Behind the Oval Office,'' is what we have been referring to here.
The Witness. So these discussions increasingly took place in these
strategy meetings or in telephone conversations with the President.
Shall I continue with the narrative on that?
Ms. Comstock. Yes.
The Witness. In early July of 1995, even as the Clinton/Gore
campaign ads were running on crime, Erskine Bowles called me and told
me that I was going to loose my battle to get us not to take Federal
funds and that the President had decided that he wanted to take Federal
funds, or actually Bowles predicted that would be the President's
decision, and he said, I think you should come up with a plan B.
At that point, I revisited an issue that I had vaguely heard about
prior to that time where I had vaguely heard that there was some
advertising capability at the DNC, that there was some type of ads that
could be run by the Democratic National Committee, but I hadn't focused
on it until then, because I was determined to not take Federal funds
and do it all through the Clinton/Gore campaign.
At that point, in the middle of July, I spoke to a number of people
to learn what the laws were regarding DNC advertising. Since I'm not an
attorney, and I'm not an election lawyer certainly, I had no previous
knowledge of that. This was my first Presidential campaign, so I--and I
never worked for the party, per se, for either party committee much, so
I didn't really know it, so I needed to learn it.
I can't recall exactly who said what to me when, but among the
people who I consulted to learn about it were Lynn Utrecht, the
campaign counsel, Joe Sandler, the Democratic National Committee
counsel, and Bob Squier, who was doing our media creation, and Bill
Knapp, his partner, and they had a longer institutional memory of this
because they worked for the party for many years. Doug Sosnik and
Erskine Bowles as well were sources of information for me on this.
At that point, I learned that there was such a thing called ``issue
advocacy advertising'' which could be done by the Democratic National
Committee, and I was informed that that advertising had to be related
to an issue that was currently hotly in play in Congress, that it had
to articulate a party-wide position, not just a position of one
candidate, that it had to draw a contrast between the position of the
other party or the other point of view, and that it could not be
expressly designed to facilitate the re-election of the President or
the defeat of a particular Republican.
Well, when I heard that, I was overjoyed, because this is precisely
the description of the advertisements I used to run all the time in
Arkansas. In 1982, when the Governor was elected, after he had been
defeated, he was confronted with the necessity of raising the sales tax
on education and he came to me and said, the first thing I am going to
have to do when I take office is raise taxes again. I am going to get
killed for that. I said, well, what I think you really need to do is
explain to the people of the State why you are doing it and what they
are going to gain by it. He said, well, the press isn't covering me
much on this; they don't get my message out. I said, I think you should
buy advertising time explaining this, and the Governor followed my
advice and did, and that became something that really he and I more or
less invented. I don't think anybody had ever done it before in the
country, that a sitting Governor would actually use ads to push his
legislative program way away from the re-election, having nothing to do
with a re-election campaign. That came a constant political strategy
that he and I used in the '80s.
Then when I found that there was a law permitting precisely this
type of advertising, I said great, and I went to the President and I
said, you know, maybe we don't have to spend all this money out of
Clinton/Gore, because all I want to do in these ads is win the budget
fight. I am not particularly concerned at this point about re-election.
The issue now is winning the budget fight. I told him that if he didn't
win the budget fight, I would urge him not to run for a second term,
that the only important thing was to win this fight.
I reminded him that he was heavily outgunned during the health care
fight and ran relatively little in the way of ads, and that the ads
that were run were often done by independent groups like the AFL, and
the message was I felt botched by them, and it wasn't the President's
message, it was their message, and it wasn't a message that--and I
said, if you let me put our message on and you let me formulate the
message, we can win.
EXAMINATION BY MS. COMSTOCK:
Question. Meaning the President's message?
Answer. Yes, we can win the budget fight. Parenthetically, I ought
to note at this point that I had just concluded a very vigorous effort
to get the President to endorse a balanced budget within a certain
number of years, and most of the White House staff opposed that, and in
June of '95 he overruled their objections and delivered this speech.
So my concern was that if we didn't do advertising on the budget,
that the AFL-CIO would, and I was about--I was equally afraid of the
AFL's ads as I was of potential Republican ads, because the AFL would
say, fight these cuts, and we would go into a class warfare kind of
thing and we would never talk about tax cuts as being good things or
balancing the budget as being something good. I said, we have to get
out the message that we are for tax cuts and we are for balancing the
budget, but we are opposed to certain of the specific cuts the
Republicans are trying to make, particularly in education, environment,
Medicare, and Medicaid.
Question. At this time, did you have any doubt that the President
was going to be running for re-election?
Answer. Oh, yes. Absolutely.
Question. In 1995, that he was considering not running for re-
election?
Answer. I don't know if he was considering it, but I was sure
considering advising him not to if we didn't win the budget fight.
Question. Did you ever have any discussions with the President that
you thought that he was considering not running in 1996?
Answer. No, but I did tell him flat out that if we didn't win the
budget fight that he might as well save himself the time and trouble,
and I made clear to him that unless the Democrats and he, particularly
he, won the budget fight going on in Congress, that there was no point
in even looking at a re-election campaign.
So I at that point insisted and pushed hard for advertising by the
DNC on the issue of the budget fight, and we retargeted----
Question. Are we talking about approximately September of '95?
Answer. July, August, and September.
Question. All right.
Answer. And we retargeted the advertising that we had done in the
Clinton/Gore phase at States where moderate Republican Senators,
moderate Republican Congressmen, and Republican freshmen and
conservative Democrat boll weevils or yellow dogs or whatever they call
them, blue dogs, lived, and targeted the media in those States
deliberately to try to hold the conservative Democrats so that we could
block a veto override, and to bombard the moderate Republicans so that
we could break their discipline.
Question. Did these also happen to be target swing States?
Answer. Some were and some were not, many were not. For example, we
advertised in Rhode Island, which is a Democratic State. We advertised
in Vermont, which is too small a State to fuss with as a target. We
advertised in New Mexico, which was at that point not a target State.
We advertised in South Dakota, which we had no prayer of carrying. We
advertised in Texas, which we never felt we could carry. So that about
half of the media was aimed--was targeted based on Congress.
The other half was targeted on what we could do to most influence
national public opinion, because the polling that reflected national
public opinion would, I felt, be the barometer of who wins or loses
this fight. We knew that in the States where swing voters lived, we
would have a much better capacity to be able to influence the national
polls, because it is a hard sell in North Dakota to sell a Democratic
alternative; it is an unnecessary sell in Rhode Island, but you have a
pretty good shot of selling that kind of idea in a State like Missouri,
which is a swing State.
But the whole point of the--and at one point I submitted a memo to
the President where I said these ads are reaching 97 swing Republicans,
18 swing Republican Senators, Congressmen and Senators.
At first, Ickes strongly opposed this--Ickes always strongly
opposed this advertising campaign and the strategy meetings
increasingly assumed the aspect of debates between Ickes and me over
this. Panetta and Stephanopoulos gradually came around to the view that
we should be doing the advertising, because they felt that it was the
only way to win the budget fight, and I told them that I felt it was
crucial that the President veto the Republican budget, and that the
veto not be overridden, and that he be willing to accept a government
shutdown and survive a government shutdown. The only way you are going
to get the President to stand firm with this kind of courage is if
there are ads running in the country and he knows that he is carrying
the majority of the people with him. Otherwise, he will be perceived
wrongly. He will sense it, and he will crack, and we will lose.
And after I explained that to Panetta, I think at one point I said
decisively to Leon, when Clinton is on the air, he has got a lot of
guts, and that was a quote, I think, and as a result of that lobbying I
think of Panetta, he and Stephanopoulos sort of switched and advocated
the ads running, and that was really the key switch and with that there
was a consensus for which Ickes absented himself for this advertising
to proceed.
But during this entire process, it was an issue advocacy effort in
just the same way as if we had advertised for health care reform in
1994, or for the stimulus package in 1993. Did it help the President
get reelected? Yeah, anything a President does helps the President get
reelected. Was it expressly designed for the President to get reelected
and the substantive battle merely invented as a ruse? Absolutely not.
Because the entire concept of Clinton's re-election had to hinge on a
victory in this fight. We couldn't even reach the issue of re-election
given the President's popularity numbers until we won this fight.
Question. And during the issue--well, we can come back to that. At
this time when you said Mr. Stephanopoulos and Panetta changed and came
around to your view, was there a discussion of a $10 million media
budget for the fall of '95?
Answer. Yes.
Question. And just so--I know the Minority has expressed some
concerns to date on--this morning on going into this, and I would like
to spend some time talking about this $10 million budget. I think
that's a lot of what we have been leading up to here in discussing, is
your advocacy of that and the President's acceptance of that and others
at the White House accepting that and clearly that led to some, you
know, fund-raising efforts. And we have particular interest in that
time frame. We would just like to go into that at some length here now,
if you could.
Do you recall in early September having some meetings on this $10
million budget?
Answer. Yes.
Question. Of '95?
Answer. In early September of '95, Erskine Bowles came to me and
said, you can't go on piece by piecemeal advising that we spend this
amount of money and that amount of money.
By way of background, we had spent $2.5 million from Clinton/Gore
in July and had spent $800,000 from DNC during the Senate--during the
congressional recess in August. I pushed for that money because I
wanted to hit Republican Congressmen and Senators when they went home
to their districts.
Question. These were on Medicare ads?
Answer. Yeah. And I wanted people to be hollering at them about
Medicare cuts so that when they got back to Washington, they would be
less likely to be disciplined.
My whole hope was to break the cohesion of the Republican Majority
that they could not pass a budget, that we would have to veto, and then
if that failed, which it did, my next hope was to have a strong enough
base of public support so that the President could veto the budget and
could block its being overridden, and could win the public relations
war over that, and we did succeed in that.
Question. The $800,000 Medicare ad campaign you said was paid for
by the DNC?
Answer. That's right. Because they were clearly issue advocacy ads
and they were entirely aimed at influencing the Senators and
Congressmen during the recess.
Question. Was the President involved at all in working on that ad
campaign?
Answer. Yes.
Question. Could you describe that----
Mr. Ballen. Excuse me, Counsel. I am going to object. I think Mr.
Morris has already made clear, and I am going to make clear, that there
is absolutely no violation of law in regard to these kinds of
activities. I am going to cite the opinions, because I want to know,
and I think the Minority is entitled to know, how this violates the law
and how this relates to our inquiry about campaign fund-raising
improprieties.
Relevant FEC decisions, Advisory Opinions 1985-14 and 1995-25, make
it absolutely clear that coordination with political parties and their
candidates concerning contents of placement of advertising is entirely
legal as long as the advertisements in question do not cross the line
of express advocacy. Even when coordinated, party-funded ads do not
constitute contributions towards expenditures on behalf of the
candidate unless the ad expressly advocates the election or defeat of a
clearly identified candidate for Federal office. This understanding of
the law has been reiterated by the FEC and the Department of Justice in
the March 1996 Supreme Court brief.
Ms. Comstock. Obviously, Mr. Ballen, these are fact-based questions
and the witness is someone who has information on facts and you are
making conclusions before we have the facts. I am trying to find out
the facts on this matter.
Mr. Ballen. That is absolutely incorrect. You are asking him a line
of questions that go into areas that are not comprehended by the
resolution or by any--or the report that was under consideration here.
And if you could articulate how this relates to what we are
investigating, I would be happy to withdraw my relevancy objection.
But I don't see how, and my consultation with the Minority members
of this committee, this line of questioning--I know maybe perhaps the
committee or certain people would like to relive the last election and
uncover why the President won and the Republican candidate lost, but I
did not understand that to be the purpose of our inquiry. Our inquiry
was looking into campaign fund-raising improprieties or possible
violations of law, period, not the strategy. Mr. Morris is a brilliant
strategist I have no doubt, but that is not the purpose of what this
investigation is supposed to be about.
Ms. Comstock. Well, that includes FEC, possible FEC violations and,
as you said, we have to know what the facts were so that we can know
what we are talking about here.
Mr. Ballen. The point is here you haven't articulated what the
possible FEC violation could be.
Ms. Comstock. If we could move on.
Mr. Ballen. I mean, I would like to hear what possible violation.
If you can articulate that, then I will stop objecting. I mean, if
there is a nexus, if you have some good faith reason to believe that
there were possible FEC violations committed by this witness or the
campaign, lay them out and then the Minority would be happy to join in
investigating any possible FEC violations, but these questions don't go
to possible FEC violations.
Ms. Comstock. Mr. Ballen, I think you are familiar with civil
deposition practice. We are looking at anything that relates directly
or indirectly. This witness has a lot of information as to how the ad
campaigns which were driving fund-raising which he himself has
discussed as driving fund-raising were conducted and how, the
interaction between the various campaigns, and that is what we are
discussing here, and I would like to move forward on that.
Mr. Ballen. I understand that you are discussing that by eliciting
the fact that he has already testified about the $10 million budget,
and then you can move on from that. What the strategy of the ads were,
the content of the Medicare ads have nothing to do with any possible
violation of law.
Ms. Comstock. We are talking about who created the ads.
Mr. Ballen. What does that have to do with it?
EXAMINATION BY MS. COMSTOCK:
Question. If you could tell us what the President's role was in the
Medicare ad that you were speaking of in August of 1995.
Mr. Lenefsky. Answer the question.
The Witness. The President's level of investment in the Medicare
ad, and in all of the DNC advertising, and in all of the Clinton/Gore
advertising, except for the first flight of Clinton/Gore which ran in
July, could be described as follows: He received drafts of the text of
the ads, and he edited them, he changed them, he adjusted the wording,
and he received a description, a story board description, which is a
rough description, of what the visuals would be.
Subsequently, in preparing later DNC ads, the story board was
replaced with something called an animatic, which is a very cheap,
inexpensive simulation of what the ad will look like, usually involving
borrowed or stolen footage that you couldn't put on the air, but that
you could have for private use, in other words, someone else's footage
that we would just dub in. So based on the animatic or the story board
and the text, the President then approved the advertisement.
At that point, the advertisement would then go through a vetting
process. First, it would be vetted--and I'm speaking of this ad and all
subsequent DNC ads. First, it would be vetted for factual accuracy
through George Stephanopoulos, Rahm Emanuel and/or Gene Sperling.
Secondly, it would be vetted for its legality by Lynn Utrecht and
Joe Sandler. After a few weeks of this, Joe--I made a decision to ask
Joe Sandler to actually attend the meetings at which we designed these
ads, and we would have these creative meetings where the consultants
would meet to design the advertisement and Sandler was literally in the
room when that was taking place. Every moment when we looked at an ad,
someone came up with an idea, we would flesh out the idea, and then I
would go to Sandler and I would say, is this okay for DNC? And he would
say, no, this goes over the line to express advocacy of a candidacy;
you got to take the picture out, you got to shorten the thing. You have
Clinton on for 7 seconds; he can only be on for 2 seconds. You have
Dole on, but you don't have Gingrich on, so it is anti-Dole as opposed
to anti-Republican leaders in Congress.
Question. You actually have seconds and times that he had this all
worked down to?
Answer. Precisely. And these all flowed from a series of meetings
that took place in the office of Lynn Utrecht at which present were
Utrecht, Sandler, Ickes, Sosnik, me, Tom Freedman, Mark Penn, Bill
Knapp. And at those meetings, and there may be some other people,
sometimes Jane Sherburne came.
Question. Jane Sherburne, special counsel at the White House at
that time?
Answer. Yeah. I think she was there at one or two of them.
Actually, no, Jane wasn't. There was somebody else.
Question. Cheryl Mills?
Answer. Cheryl Mills was there at one or two of them.
Anyway, at those meetings, Utrecht and Sandler would lay down the
law in terms of every specific part of that ad. They would tell whether
we can use the President's picture, whether we can have the President
speaking, how many seconds you can have the President on, whether we
could use Dole, whether we could use Gingrich, and they would work on
the guidelines and copy, and then those guidelines would then be
enforced on an intimate involvement in the creative process by Sandler
being there at every step.
So the President, after he signed off on the rough text and the
animatic or the story board, this would then be resubmitted to Sandler
who had been present during the story boarding and the animatics and
the scripting and----
Question. Okay. And when the President--would you give him the
copy? Would you physically give it to him and then he would make the
changes on that?
Answer. Yes.
Question. And then who would you give that copy to?
Answer. I would then--these were typically done at the strategy
meetings, and the President, the Vice President, Senator Dodd, and
Ickes and Stephanopoulos and Panetta all assumed active roles in
dealing with, in discussing the text of the ads.
I would then have--these meetings were generally at night, the
strategy meetings. Then I would have a creative meeting----
Question. Were these Wednesday night or Thursday night meetings?
Answer. They had been called that in the press, but they were often
on Monday evenings or Tuesday evenings as well.
Question. When you physically gave the documents to the President,
would you take them back from him yourself, the changes that he made?
Answer. Yes.
Question. And where did you physically take those to?
Answer. Oh, you mean his handwriting? No. I would just be sitting
with the ad copy and as people agreed on changes I would be making the
changes, yeah. And they would be rough--they wouldn't be the actual
changes, they would be the concept, because I wasn't about to time it
to be sure it came in at 30 seconds while the President was sitting
there.
But we got the point that, you know, this is too heavily anti-Dole,
or I don't want you to use that old picture of Dole, it looks like we
are using the age issue against him, or you used this word and I want
this kind of sense. It wasn't a text by text thing, it was a--it was
conceptual, and when it was textual, he would usually include so much
language that you couldn't fit it in a 30 second spot. So I would copy
all of that down, and then the next morning we would have a creative
meeting with the political consultants. Attending those meetings were
Bob Squier, Bill Knapp, Mark Penn, Doug Schoen, Tom Freedman, Joe
Sandler, one or two members of Squier's staff, and usually one or two
other members of my staff. And later in the process we were joined by
the opposition research experts at the DNC.
At these meetings, we would then take the input that had been given
by the participants in the strategy meeting and accepted by the
President and we would then redraft the ad so that it came in at 30
seconds and it took account of their concerns. We would then also note
changes in the visuals that needed to be made. Then, we would call by
phone usually Stephanopoulos, Sperling or Emanuel and get their
specific factual changes, if there were any factual issues. Then we
would take that entire product and run it by Sandler again, and he
would then say, well, this and this change you have made are over the
line, you have got to pull it back, and so on.
At that point we would then come up with a text and a visual
concept. I would then leave, and the actual media creators would then
take that and fashion it into an ad, and they consisted of Bill Knapp,
Hank Sheinkopf, who was at the creative meeting as well, and Marius
Penczner, who was at the creative meeting. The three of them would
actually go into the editing room and design and produce the ad.
Usually Knapp would call me and would say, this ad is too long, you got
to take some words out, or this doesn't work with the visual, you got
to change the copy, and again the copy would be changed. Or he would
say, we don't have a particularly good visual of this, we need
something of that, and we would change the visual.
Then, that advertisement, when it finished with that process, would
then be put on the air without prior approval from anybody except me,
and the ad would run and we would show the ad to the strategy group,
which included the President, at the subsequent session of the group,
usually after the ad was actually running.
So the President was heavily involved at a given point in the
process, but in almost every case, the ad that ultimately ran was
significantly different, both in visual content and in text, from the
ad he had seen and approved several weeks--several days before. It was
only one----
Question. That ad that he had approved, was it his understanding
that these were DNC ads?
Answer. Yes. Clinton/Gore ads followed the exact same approval
process.
Question. And during this time frame when you were doing the issue
advocacy ads, were you also doing polling of the President's numbers?
Answer. Yes. But perhaps I could just summarize the content portion
of it. My point about the content is that the inputs on the content
were very pluralistic. There were probably 30 people or 40 people that
had some role of input to the process.
Question. I understand.
Answer. And while the President had a significant role in that, it
was as the first among equals, and he was not the final arbiter went
on, because he never saw what finally went on because his schedule
didn't permit it.
Question. Did you maintain copies of documents of these various ads
as you prepared them?
Answer. No. I am not now in possession of any such documents. Bill
Knapp was the one who kept those documents, because he was sort of the
operating officer in charge of the ad campaign, and a number of other
documents of that sort were documents that I had at my campaign office,
but when I was fired, the campaign office was sealed and I have had no
access to my papers since then. But you probably have a bunch of
scripts lying around that office.
Question. What do you mean your office was sealed?
Answer. There was a padlock put on it and I was not permitted
access to it.
Question. So your Clinton/Gore office was sealed by Clinton/Gore
officials?
Answer. Yes.
Question. And could you describe what happened with that?
Answer. I don't know. I was never there; I was just told that I
could have no access to it and I have never tried.
Question. And that happened immediately--in the August 26th time
frame when you were leaving Chicago?
Answer. Correct.
Question. And you came back and you never were able to get into
your Washington, D.C., office?
Answer. Well, I came back to Connecticut and New York, I didn't go
back to Washington, but I was told it was sealed and I never tried to--
I was told--I never physically went there to, you know, to challenge
the padlock, but I was told it was locked and sealed.
Question. And who told you that?
Answer. Peter Knight.
Question. And what did he say to you?
Answer. Your office has been sealed, and we have had to seize the
documents, and you can't have access to them.
Question. Do you know who seized the documents?
Answer. No.
Question. Do you know where those documents are now?
Answer. No.
Question. Have you heard anything about what was done with those
documents?
Answer. No.
Question. Okay.
Answer. So----
Question. At the time when you--we haven't really directly
addressed that, but you had said both, when you resigned and when you
were fired in August of '96. How would you--how do you characterize it?
Answer. I was fired.
Question. And who fired you?
Answer. The President.
Question. And what did he tell you in terms of firing you?
Answer. He sent Erskine Bowles to say that he was requesting my
resignation.
Question. And at that point you resigned?
Answer. Yes.
Question. Did anybody else talk to you about the President's wish
for you to resign?
Answer. Subsequently Jack Quinn came in to talk to me as well about
it.
Question. And at that time Mr. Quinn was the counsel to the
President?
Answer. Yes.
Question. And what did he tell you?
Answer. At the first conversation, Erskine and I were alone and he
said, the President wants me to request your--wants to request your
resignation. Then I objected to that and asked them to revisit the
issue with the President and several hours later, Bowles and Quinn came
back and said, we have revisited the issue with the President and the
President wants to offer you the alternative of either resigning or
taking a leave of absence during which you will seek counseling and
therapy and after that, after a suitable interval, you might be able to
rejoin the campaign, and in the interim between those two meetings I
had made a judgment that I needed to resign. So when they came back and
offered that, I said, that's fine, I will just resign.
Question. Did you speak with the President prior to resigning?
Answer. No.
Question. Could you just tell us briefly, when you left the
campaign at that time, what documents you can recall being in your
office at that time?
Answer. A relatively complete or perhaps fully complete set of the
agendas that I prepared for the President's review, which would be
strategic documents that we used at the weekly strategy meetings.
Question. And where was your office located?
Answer. In the Clinton/Gore campaign office on 20th and M, and----
Question. Did you have an office at the White House at all?
Answer. No. So the agendas were there. Probably I would think all--
my staff kind of decided what they were keeping and what they weren't
keeping, so I am not fully familiar with it.
[Discussion off the record.]
The Witness. I am fairly certain that all of the memos from Sandler
and Utrecht as to what the ground rules were for DNC advertising were
there. Most likely all copies of the surveys were there. Most likely
all memos that I had sent to the President, giving him advice on
different topics, were there.
I would send the President four or five notes every day, short
little notes, just as things arose during the course of the day, and
probably most of them were there. And assorted other things, analyses
of the nightly TV news, analyses of the content of local newspaper,
issues memoranda on different substantive issues we were working on, a
variety of things like that; nothing linked to fund-raising at all,
because I never had any involvement with that.
Question. Did these memos to Mr. Sandler you said involved--would
be in your documents?
Answer. Yes. The memos from Sandler and Utrecht outlining--or from
Bill Knapp summarizing the conversation with Sandler and Utrecht for
their approval, the memos for their approval.
But documents that laid down the ground rules for DNC advertising,
we had several meetings on that, seven or eight, because as the time
frame unfolded, the ground rules changed, because the circumstances
changed. The Republicans had a nominee, or there were primary fights
going on, and the ground rules to which we were subject evolved over
that period. These documents traced that.
Question. Is that the full extent of the documents you believe were
maintained in your offices?
Answer. I am sure----
Question. To the extent you can recall.
Answer. I am sure there is probably a lot of other stuff hanging
around there, but that is the main stuff.
Question. Did you maintain copies of documents, notes the President
had written to you, things like that, in your office?
Answer. The President rarely did that. In fact, he really--oh, yes,
a lot of the things that might be there might be articles that the
President sent over to me with his writing on it saying, you know,
please note this, and generally those were on issues or ideas. But,
yes, there would be some of those.
Question. Did you have a separate phone number for the Clinton/Gore
office?
Answer. Yes, but it was--yes, there were phone numbers where one
could call directly and reach my office, yes.
Question. And what was that phone number?
Answer. I don't recall.
Question. Did you have somebody who maintained your files for you
at the Clinton/Gore office, or did you do that yourself?
Answer. No. Two people who did, Tom Freedman, my chief of staff,
and--I am blocking out his name.
There was a guy who was on my paid staff, and I can't remember his
name, who kind of was in charge of the office. I am sorry; I will
remember his name.
Mr. Lenefsky. We will provide that.
EXAMINATION BY MS. COMSTOCK:
Question. When you had mentioned your staff, can you provide the
names of the other staff who were the individuals who generally were
working with you?
Answer. Actually, if I can have my book?
Question. Yes.
Answer. Thank you. Just a minute.
The name of the gentleman I was groping for, who kind of ran the
office, is Brian Lee, L-E-E, and my other staff members were Mary
Smith, Matt Levine, and Mark Schwartz.
Question. You had said you did not have an office at the White
House. Did you have occasion, though, to spend a fair amount of time at
the White House in 1995 and 1996?
Answer. Yes.
Question. And where would you be physically based when you were at
the White House?
Answer. Well, I never had a hard pass, so I was only----
Question. At any time?
Answer. At any time. So I would always have an appointment with
somebody, and I would enter pursuant to an appointment.
Question. Who would that be? Why don't we start with initially when
you started, sort of the secret phase when people didn't know you were
there, who you would go to.
Answer. Nancy Hernreich, and thereafter it would depend on who I
was seeing. Leon Panetta in June of 1995 had a meeting with the
President and Bowles--with the President, myself, and the Vice
President, and asked that I spend as little time in the White House as
possible, and that I not roam the halls of the White House catching
people at random, but I only go in to see specific people.
At that point, I opened an office at the Clinton/Gore campaign, and
I spent most of my time either there or in my hotel. I only entered the
White House or the OEOB for specific meetings with specific people, and
it was not my practice to linger there.
Question. And during this time, I guess starting from November '94
time frame forward, were you staying at the Jefferson Hotel generally
when you were in town?
Answer. Yes.
Question. Who were paying for those bills?
Answer. The Clinton/Gore campaign had a per diem maximum of, I
believe, $185 a night, and my hotel bill was 200-something dollars a
night, and they paid up to $185, and I paid the rest of it out of
pocket, as well as any other expenses in connection with that out of
pocket.
Question. Do you know where the bills that the hotel had--where
they were sent to?
Answer. Yes. They are in the possession of my--I think they are in
the possession of my assistant, and if you want me to furnish them to
you, I would be happy to.
Question. That would be Tom Freedman?
Answer. No; my personal assistant, Maureen Maxwell.
Question. Okay. And how did you take those bills and then get
reimbursed for them? What was that process?
Answer. Maureen would send those bills, as well as air receipts and
other expenses, to Joan Pollitt at the Clinton/Gore campaign, and she
would then reimburse the portion of it that the campaign deemed
reimbursable.
Question. Those bills were sent to Joan Pollitt, as opposed to the
consulting bills that went through Harold Ickes?
Answer. That is correct.
Question. Okay. So from the start, like in November, December, '94,
those bills went to----
Answer. No. This arrangement started in July of 1995. Prior to July
of '95, I received no reimbursement for expenses.
Question. So when you were staying down here, that was out-of-
pocket expenses for you?
Answer. Yes.
Question. Starting in June of '95----
Answer. July.
Question. You sent the bills to Clinton/Gore?
Answer. Correct.
Question. And at any time did you learn of anyone reviewing your
hotel bills?
Mr. Lenefsky. Can we go off the record now?
[Discussion off the record.]
The Witness. What was your question?
EXAMINATION BY MS. COMSTOCK:
Question. Were you aware of people reviewing your hotel bills?
Answer. Yes. I became aware of that. Yes, I was aware of that.
Question. How did you become aware of that?
Answer. Ickes--well, first Ickes would send me memos objecting to
things in my hotel bill, and at first the campaign was paying my full
hotel bill, and then Ickes said, we will only pay it up to $185, and
then I said I would like to pay the rest of it out of pocket, and he
said that was okay.
And then I became aware that Ickes was reviewing them because of
his feedback on them. And then I had occasion to read in the Washington
Post an account which indicated that I had charged mini bar expenses
and pornographic movie rentals to the campaign.
In fact, I never received reimbursement for anything above the
$185, so uses of the mini bar, which were generally Diet Pepsis, were
not reimbursed in any case by the campaign, nor were movie rentals of
any description reimbursed.
I showed the hotel bill to the Washington Post, and it became clear
there were no movie rentals on the hotel bill.
Question. Do you know who at the White House was working on that
for Harold, who reviewed bills in general, whether it was the hotel
bills?
Answer. No.
Question. Or the other bills sent over to Harold Ickes?
Answer. No.
Question. Do you know someone named Jennifer O'Connor who worked
for Mr. Ickes?
Answer. Yes.
Question. Do you have an understanding of what her role was working
for Mr. Ickes?
Answer. My only interface with Jennifer was when Harold was asked
by the President to review a proposal for a public statement that I
would make, an issue proposal that I would make.
Part of my job was to recommend issue positions to the President,
to speeches or proposals he made, and when Ickes was charged with
reviewing those proposals, as he was with some of them, he would
delegate that task to Jennifer O'Connor. That was my sole involvement
with her.
Question. And did you have any understanding of her being involved
in reviewing bills at all?
Answer. I have no idea.
Question. I am going to return a little to the--I think we diverged
a little bit when we were talking about the issue advocacy ads and
whether or not there was polling done of the President's numbers.
Answer. Yes.
Question. As these ads started appearing.
Answer. We polled constantly. Every week we polled.
We polled weekly, and at the beginning that would be spelled W-E-A-
K as well as W-E-E-K.
And in that polling, we had about 30 different measurements that we
included every week to measure what was going on. Those included the
President's favorability, the President's job rating; we would ask,
whose plan to balance the Federal budget do you approve of more, the
President's or those of the Republicans in Congress? Who do you trust
more to balance the budget, the President or the--President Clinton or
the Republicans in Congress? Who do you trust--who do you think will do
the better job of holding down taxes, the President or the Republicans
in Congress? Who do you think would do the best job of balancing the
budget in a way that preserves our values?
Question. Were these the ads that were then broken down between
DNC----
Answer. These were the polling questions.
Question. And then they would be allocated?
Answer. That is right.
Question. Part of this, though, was determining the President's
general favorability numbers?
Answer. Well, what I am saying to you is, there were about 30
different questions that we routinely and repetitiously asked each
week, and we tracked and monitored fluctuations in those numbers and
briefed the President at the strategy meetings on those changes. One of
them was the President's favorability. One of them was his job
approval.
But I was giving you the list of questions that we tracked. So they
were the ones on the budget; they were the ones on the tax cut.
Then we would read people summaries of the President's and the
Republicans' budget positions and say, who do you agree with more? We
would say, who do you blame more for the shutting down of the
Government, the President or the Republicans in Congress? Who do you
feel is doing the best job of protecting Medicare? Who is doing the
best job of protecting Medicaid? Who is making the best job of
promoting education?
We would have a whole series of questions, largely issue questions,
which were designed to track how the advertisements were affecting the
perception of the President's issue position vis-a-vis the Republicans.
We did not in most of these polls ask head-to-head questions at
that point in that period, if only because they were too dire for us to
contemplate, and also, we didn't know the name of the Republican
opponent yet.
But the President's favorability or job rating were components that
we reviewed to assess the progress of the weekly campaign. But they
were only 2 of about 30 questions, and the other 28 virtually all
related to the issue differences between the two.
Question. And then were these polls used to develop the issue
advocacy ads?
Answer. Yes.
Question. Getting into the President's review of these ads, did you
sometimes meet with the President, just by yourself with the President
on these, or was it usually with a group of people who were reviewing
the ads?
Answer. I very rarely, if ever, met alone with the President about
the ads. They were either--I either met with him in the strategy group,
or in '96, as the need for changing ads became more immediate, Nancy
Hernreich would arrange a 10-minute gathering in the Oval Office or
adjacent to it, where as many of the strategy meeting participants as
could be summoned would come into the room and actually look at
animatics and scripts and make a judgment there on the media. But
generally these were done at the strategy meetings.
Question. And your experience with Governor Clinton, you had worked
on writing ads with the President?
Answer. Yes.
Question. Is that correct? And you recall the number of anecdotes
in your book about when the President's polling--I think it was in the
1990 campaign--when the President's poll numbers had fallen quickly,
you had woken him up at 2:00 in the morning and wrote an ad together?
Answer. Yes.
Question. And during the '95-96 time frame, did you also write some
ads like that with the President?
Answer. Well, I have tried to lay out for you--I have tried to
answer that question previously. I walked you through the process, and
that is the process we followed.
Mr. Ballen. Excuse me--all right.
EXAMINATION BY MS. COMSTOCK:
Question. What was Mr. Ickes' role in this process of approving the
ads?
Answer. He attended the strategy meetings and occasionally had
comments on the text or the visuals in the ads, and he also had to
receive final texts of the ads and a video of the ad before the ad ran.
Question. And he would have his input?
Answer. He would have made his input at the strategy meeting. I
can't recall any instance in which he had any changes when he received
the final copy.
Question. If we could return now to the September '95 time frame
when you were working on advocating the $10 million budget, you spoke
of the initial meeting with Mr. Panetta and Mr. Bowles and Mr.
Stephanopoulos where they came around to your thinking on this.
What was your understanding of the President's position at that
time?
Answer. Generally he was in favor of the advertising, but he was
concerned about whether we could afford it, and his mind was open at
that point on the question of how much we should do and when we should
do it, and he was following the debate among his advisers.
Question. And did that debate include that the DNC financial
situation was not great in the fall of '95?
Answer. Not in front of me, it didn't. The President at the
strategy meeting in September said, as I recall--at one point, Ickes
spoke of the financial difficulties the DNC was facing, and the
President said, ``Hold it. I don't want to have that discussion here.
We are going to have a separate meeting where we are going to focus on
that.''
And then there was, I have since heard, a separate meeting, to
which I did not attend--I have read this in the paper--at which that
was reviewed and discussed.
If you will pardon the President, the President, he recognized a
Chinese wall between me and the fund-raising.
Mr. Ballen. So you did not have any involvement in the fund-
raising? Just to make that clear on the record.
The Witness. I had absolutely no involvement in the fund-raising at
all, nor knowledge about it.
[Discussion off the record.]
EXAMINATION BY MS. COMSTOCK:
Question. Okay, we can just move along. I just have a New York
Times article in April of this year which discusses some of the matters
that you have been relating, some of the meetings that you have been
discussing. What can you tell me about what you know about the
subsequent meeting on how the DNC was going to come up with the money
to pay for the $10 million budget once that had been approved?
Answer. I know nothing about what went on in that meeting. I did
hear at one of the strategy meetings that the DNC had acquired a line
of credit of $7 million and that it was planning to use that line of
credit to help finance the advertising.
I do know that at one point in late 1995, Ickes was opposing my
request for advertising money and said, ``This will mean the DNC could
be 7 to 9 million dollars in debt at the end of the year.'' And I
answered, ``I would rather the DNC be in debt than the Republicans win
the budget fight and the DNC be dead.''
But those two were the only insights I had into the DNC's financial
condition during that period.
Question. Okay. Did you have any knowledge about a meeting that Mr.
Ickes and Don Fowler and the President and the Vice President had on
this budget shortly after it had been approved in early September?
Answer. No.
Question. On September 13th, 1995, the President, it has now been
reported--and the committee received a number of documents relating to
it--there was a meeting with the President, James Riady, John Huang,
Bruce Lindsey, and Joe Giroir, and in this meeting one of the topics
discussed was John Huang raising money for the DNC.
Mr. Ballen. Hold it. I object. Is that your testimony? How do you
know?
Ms. Comstock. It has been reported that is what was discussed in
those meetings. Unfortunately, some of the principals are no longer in
the country, are not available, and I believe the President has said
after a number of disagreements among staff that this topic was
discussed, fund-raising and Mr. Huang going to the DNC, as well as
there has been a fair amount of testimony in the Senate on that last
month.
At any rate, at any time in or around September of 1995, did you
learn that there had been some kind of fund-raising solution that had
been found for the DNC?
Answer. No.
Question. Or any people that were going to be involved in raising
money?
Answer. Absolutely none.
Question. Were you aware of Bruce Lindsey meeting with anybody
regarding fund-raising efforts?
Answer. No. I am not trying to give a specific denial to a specific
question. I never knew anything at all about how the money was being
raised by the DNC. I never knew the names of the donors, the modalities
that we used in raising the money, the projections of how much they
expected to raise, or any of that information.
Question. So you had no knowledge of Mr. Ickes meeting with Mr.
Huang at any time?
Answer. I had no knowledge of that or any other fund-raising
discussion.
Question. You said you did learn about the DNC obtaining a loan
regarding----
Answer. I heard at the strategy meeting--I have answered that
question.
Mr. Lenefsky. It was a line of credit, I think.
EXAMINATION BY MS. COMSTOCK:
Question. Do you know who told you about that in the strategy
meeting?
Answer. It was in the strategy meeting.
Question. Do you know who raised that?
Answer. Ickes, I think, but I am not sure.
Question. Did Ickes ever raise any concern about that line of
credit?
Answer. Yes, as I think I was just testifying, he said he would end
up in debt at the end of the year, and that was the reason not to do
the advertising. As I said, I said I would rather the DNC be in debt
than the DNC be dead.
Question. It was your understanding the line of credit had been
extended and Mr. Ickes was trying to cut back on how often the line of
credit was utilized?
Answer. I have no idea.
Question. Do you know a woman named Janice Enright?
Answer. Yes.
Question. And do you know who she is?
Answer. Yes.
Question. Could you tell us your understanding----
Answer. She was Harold's chief assistant, Harold Ickes' chief
assistant. Her office was located inside his office, their desks were
joining, and she was virtually constantly with Harold, and I would deal
with her frequently to get messages to Harold.
Question. And what was your understanding of what her role was?
Answer. His executive secretary.
Question. And to your knowledge, did most--if you have any
knowledge--of the documents that went into Harold's office, did she
deal with them generally?
Answer. I don't know.
Question. When you were at the White House, did you have any
particular phones or faxes that you were supposed to use, if you indeed
did use any at the White House?
Answer. No. I always charged calls to my credit card, my campaign
credit card, when I made them from the White House.
Question. Did you ever have occasion to use faxes when you were at
the White House?
Answer. I might have. Yes, I probably did.
Question. Do you know if you were directed to any particular faxes
which you were supposed to use at the White House?
Answer. No.
Question. When you first began working with the President in late
'94 and '95, you have written that when you were working on this State
of the Union address, you were faxed things back and forth and there
was a lot of faxes that went to the White House from you to the
President. Did you have a particular fax line that you were directed
to?
Answer. That I was supposed to send to?
Question. Yes.
Answer. Yes.
Question. Do you remember what the number was?
Answer. [Redacted]. But I would ask, in your final report, you not
make that number public, because it still is the fax number of the
President's office.
Question. I understand. Is that in his private office or in the
residence?
Answer. It is in the Oval Office.
Question. And do you know if there was a fax machine in the
residence that the President utilized?
Answer. Yes, there was, in the Usher's Office. I would frequently
fax things to the Usher's Office as well.
Question. Do you know what that fax number is?
Answer. I don't have it memorized. I knew it and used it, but I
don't know what it is.
Question. Can you recall how frequently you sent documents by fax
to either of those numbers or other numbers?
Answer. Three or four times a day.
Question. In that late '94/early '95 time period?
Answer. Constantly, from late '94 through August of '96.
Question. And do you have any knowledge as to how those documents
were maintained or who maintained them at the White House?
Answer. No.
Question. Would the President send you back faxes?
Answer. Yes, but not in that way. The documents I received from the
President were usually memos--they were usually documents that he had--
almost always they were like a magazine article or something that he
had read, and stamped ``the President has seen,'' and he would write my
name next to it that I should be sent a copy of that.
The President almost never sent me any documents. It just wasn't
his style, to actually put something in writing and send it to me. It
was kind of a one-way street. I was sending him documents, papers,
constantly.
Question. Did you maintain any of the documents that were sent to
you from the White House?
Answer. A great many of them, but they are all in my office.
Question. So you maintained none of your documents, in the entire
time you were working for the President, at your home?
Answer. No.
Question. Or in any other personal office?
Answer. No, except I do have an incomplete set of the agendas for
the Oval Office, for the Wednesday night meetings.
Question. Those were the only documents you maintained personally?
Answer. That is right. Occasionally--a few other random documents.
I think I have a copy of the draft--the initial drafts and edits of
each of the State--two State of the Unions I worked on, and I have some
personal notes that he sent me just of a personal nature, birthday
present and stuff like that, but nothing systematic; I kept all of that
at my office.
Question. And you said your assistant that you mentioned earlier,
Maureen was it?
Answer. Maureen Maxwell, yes.
Question. Is she based in Connecticut?
Answer. No; she lives in Pennsylvania.
Question. So the bills that you would send for her to handle were
sent to Pennsylvania?
Answer. Yes.
Question. Do you have any knowledge of what Ms. Enright's role was
in terms of Mr. Ickes' interactions with the DNC, if she had a role?
Answer. None. I have no idea.
Question. You have no idea, not that she had no role?
Answer. I have no knowledge.
Question. What is your understanding of what Doug Sosnik's role was
in relation to the DNC and the work you were doing?
Answer. He was the political director at the White House, and he
functioned as Ickes' number two in command. By that, I don't mean his
chief of staff, or that would have been Enright, but his number two
professional person.
And my understanding was that he frequently transmitted
instructions from Harold Ickes to--certainly to me and to the other
consultants, and I have no knowledge that he transmitted them to the
DNC, but it would have been reasonable to assume that he did.
Question. And what was your understanding of Mr. Ickes' control
over the DNC?
Answer. That it was total; that he was the moment-by-moment, day-
to-day manager of every aspect of the President's campaign, whether
that campaign related to activities of the Clinton/Gore campaign or to
the extent that it related to DNC activities.
I know that in my personal bailiwick we needed Harold's approval
for every poll, every focus group, every mall test of ads, every
production of ads, every animatic that we produced, every media buy;
any expenditure of any amount of money other than petty cash, we needed
Ickes' approval.
We would go about that by submitting the information to Sosnik, and
Sosnik would then get back to us--Sosnik would either approve it on
Ickes' behalf, which he was permitted to do by Ickes, or earlier,
before he got that authority, he would go back to Ickes and would get
back to us with Ickes' approval.
Question. And did you have an understanding of the President's
knowledge of Mr. Ickes' role?
Answer. I believed that the President--I believed that Ickes was
given this authority by the President.
Question. The President had an understanding that Mr. Ickes did
have the type of control that you have described?
Answer. Yes. In general, I was under that impression. I know that
specifically the President directed that Ickes was to approve all
polling questionnaires and all polling expenditures in advance.
I know that because I opposed giving Ickes that authority and
objected to the President over it, and the President overruled me and
ordered me to deal with Ickes on the polling issues.
Question. I am showing the witness EOP 34213, which is an April 17,
1996, memo to Chairman Fowler, cc'd to Chairman Dodd, B.J. Thornberry,
Marvin Rosen, Brad Marshall, Doug Sosnik, Karen Hancox, from Harold
Ickes dated--the memo is dated April 17th, 1996, regarding an April
15th, 1996 meeting.
This document discusses a meeting that apparently occurred between
Mr. Ickes and Mr. Fowler and Doug Sosnik, in which it was agreed that
all matters dealing with the allocation of expenditures and monies
involving the DNC are subject to the prior approval of the White House.
Do you know if this is the time frame when this discussion
occurred, April 1996?
Answer. I have no knowledge of this document nor of this procedure,
and it is my impression that the requirements that were imposed upon my
consulting group predate this significantly.
Ms. Comstock. I guess I can make that Deposition Exhibit Number 1.
Mr. Lenefsky. Are you marking this?
Ms. Comstock. Actually, we have to keep the documents. I think
there is a different process in the Senate.
Mr. Lenefsky. There sure is.
Ms. Comstock. Document protocol does not allow us to disseminate
the document.
Mr. Lenefsky. That is a new one on me.
Ms. Comstock. You can keep it to look at for now.
[Morris Deposition Exhibit No. 1 was marked for identification.].
[Note.--All exhibits referred to can be found at end of
deposition.]
EXAMINATION BY MS. COMSTOCK:
Question. Are you familiar with the documents Mr. Ickes has turned
over to this committee at all and the Senate committee?
Answer. No.
Question. Other than seeing them, did you have any knowledge of
them before news accounts?
Answer. I don't know what documents were turned over, so I can't
answer the question. There may be documents that he turned over that I
know of, but I don't know that I know of them.
Question. Maybe an easier way would be, while you were dealing with
Mr. Ickes, did you have occasion to receive memos on a regular basis
from Mr. Ickes?
Answer. Yes.
Question. What type of memos did you receive from Mr. Ickes?
Answer. Memos which would clarify campaign procedures, approvals,
memos which would lay out policies for reimbursement, memos which would
be instructions to campaign staff people, things of that sort.
Question. Okay. Do you have any knowledge if Mr. Ickes maintained
these types of documents?
Answer. I have no knowledge.
Question. Do you know, have you heard from any source, whether or
not these are some of the documents Mr. Ickes took with him when he
left the White House?
Answer. I have no knowledge.
Question. Do you have any knowledge about Mr. Ickes taking his
documents from the White House?
Answer. No.
Question. On a July 18th, 1997, article in the Washington Post----
Mr. Lenefsky. '97?
EXAMINATION BY MS. COMSTOCK:
Question. '97, I am sorry--last month, you were quoted as saying,
``If Harold really unloaded, there would be a whole lot more going on
now than there is. If Harold ever broke with Bill Clinton, you would
know it, believe me.'' Can you tell us what you meant by that
statement?
Answer. That it is my impression that Harold has had a long and
close relationship with the President and has been privy to all of the
President's political operations over a long period of time, and that
if Harold--what I meant in that is that if Harold Ickes were to reveal
everything that he knows, my impression is that the time period covered
and the substance covered would go far beyond the scope of the document
release he was alleged to have made pursuant to the committee's
request.
Question. And what type of matters are you referring to?
Answer. Matters that would relate to the 1992 campaign, that would
relate to the Democratic convention and the President's strategy there
in 1992, things that would relate to the President's fund-raising
operations.
I believe that someone who is in Ickes' position would have access
to far more material than was released pursuant--was released in
connection with the document release that Ickes made after--he was
alleged to have made after he left the White House.
I do not, however, know of any specific piece of information that
Ickes might possess which could be injurious to the President.
Mr. Lenefsky. Can you tell me which page you are on?
Ms. Comstock. It is----
The Witness. Could I ask for literally a 2-minute recess? I just
need to return a page. I will be back.
[Brief recess.]
Ms. Comstock. Okay, we can go back on the record. Congressman
Cummings has joined us. I will turn the questioning over to him.
Mr. Cummings. Thank you very much.
Good afternoon--good morning, rather.
Mr. Morris, I just wanted to stop by here to ask you a few
questions.
The Witness. Sure.
Mr. Cummings. While I am a lawyer with 20 years of criminal
practice, I am not here in that capacity today but as a member of the
Government Reform and Oversight Committee. I am just interested in this
case.
It is my understanding, over the last 2 and a half hours of
questioning there have been no real questions about campaign fund-
raising. While Mr. Morris has stated he has no knowledge of John Huang,
Charlie Trie, the Riadys, or any other matter related to possible
campaign fund-raising, it is my understanding Mr. Morris has testified
about political strategy, advertising and polling, all matters of which
neither this committee or the full House authorized an investigation.
Mr. Morris, I would like to ask you some questions about fund-
raising that you may actually have some knowledge about.
It is my understanding you worked for the Bush campaign--is that
correct?--back in 1988?
The Witness. Yes.
Mr. Cummings. Did you work for George Bush's Presidential
campaign--is that right?--in 1988?
The Witness. Yes. But I am----
Mr. Cummings. Let me say this. If I ask you anything and you are
not clear, I am sure your counsel advised you, you can ask me to
rephrase it.
The Witness. Yes, I know. I worked to help Bush get elected, but I
cannot recall whether I was paid by the Bush campaign or by the
Republican National Committee.
Mr. Cummings. Okay. Do you recall what your responsibilities were?
The Witness. Yes.
Mr. Cummings. What were they?
The Witness. I was--I advised Lee Atwater, the campaign manager,
and Roger Ailes, the media creator, on the content and timing and
issues of the negative campaign against Dukakis.
Mr. Cummings. And so you provided advice as far as negative
campaigning is concerned; is that what you said?
The Witness. Yes. I had worked for Weld, who had defeated Dukakis
for Governor of Massachusetts, so I was sort of the house expert on how
to beat Dukakis.
Mr. Cummings. Were you involved in any way or did you have any
knowledge of the type of fund-raising conducted in that campaign?
The Witness. No.
Mr. Cummings. Do you remember what Robert Mosbacher's role was in
the campaign?
The Witness. No.
Mr. Cummings. What kind of access did you have to the Vice
President, Bush, during that campaign?
The Witness. None. I have never met him.
Mr. Cummings. You never met him?
The Witness. Nor spoken to him.
Mr. Cummings. Are you familiar with Team 100, the group of $100,000
contributors to the RNC?
The Witness. No.
Mr. Cummings. Do you know whether any large contributors were made
specific promises by the Bush administration? That is, people that
contributed to the Bush campaign?
The Witness. No.
Mr. Cummings. Would you know whether any were promised
ambassadorships? That is, large contributors?
The Witness. No. I know as little about the Bush campaign fund-
raising as about the Clinton campaign fund-raising.
Mr. Cummings. All right. Let me just go to something else. I just
want to go--I had an opportunity to read some documents from
``Crossfire'' back on March 3rd, 1997. I just want to ask you, do you
remember that?
The Witness. I am sorry?
Mr. Cummings. You appeared on ``Crossfire;'' is that right?
The Witness. Yes.
Mr. Cummings. And there is a quote, and I would like you to tell me
whether it is accurate or not. This is a quote that is attributed to
you, and I just wanted to know whether you made this. It says, ``I have
sat in the room with six different currently serving Republican Members
of United States Senate in their Senate offices, and they pick up the
telephone, and they ask somebody for a campaign contribution.'' Do you
remember saying that?
The Witness. Yes.
Mr. Cummings. And can you identify who those Congresspeople were
that you were talking about?
Mr. Lenefsky. Wait a minute. Congressman, with all due respect, I
don't understand the relevance of this line of questioning. Correct me
if I am wrong. I thought the committee's jurisdiction was fund-raising
improprieties or illegalities with regard to the 1996 Presidential
election. If I am wrong, please correct me.
Mr. Cummings. Well, as I sat in the committee, we said we would
take this anywhere it went. And that is my understanding; it is not
limited.
Ms. Comstock. I think the witness may be confused, because
previously Minority had objected to this line of questioning.
Mr. Ballen. No, I did not. I objected to the question. Absolutely
untrue. I objected to a question that didn't relate to fund-raising.
Mr. Cummings' questions relate to fund-raising.
We have asked as well--it is well established there have been
questions about 1992 and beyond.
So we also had questions about the 1980s and 1970s, what was done
for President Clinton.
Mr. Lenefsky. I would like to consult with Mr. Morris for just a
moment, please.
[Discussion off the record.]
Mr. Lenefsky. Can we have the question read back?
[The reporter read back as requested.]
The Witness. Yes.
Mr. Cummings. And who were they?
The Witness. Well, after I had made the statement, the statement
was a spur-of-the-moment statement in which I was in the heat of
argument with Haley Barbour, and Mr. Barbour had professed shock and
indignation about the Vice President's making calls from his office.
And I said, ``It is the routine practice of Members of Congress to make
phone calls from their offices for fund-raising, and you know that.''
And I am under the impression that that is the routine practice.
I blurted out a figure without necessarily concocting it in my
mind. Subsequently, I had an opportunity to reflect on it and figure
out who I actually have seen physically picking up the telephone,
talking into the phone, and asking people to do fund-raisers or to
contribute money in their Senate office, and I come up with three
names: Senator Phil Gramm of Texas; Senator Paula Hawkins of Florida;
and at the time, Congressman Buddy Roemer of Louisiana.
Mr. Cummings. Now, let me make sure I am clear on what you just
said, that although you mentioned, you said--talked about six, actually
there were only three that you could remember?
The Witness. Yes, that I could actually say I sat in their office
and watched them make fund-raising phone calls.
Mr. Cummings. Now, let's go back to these three people for a
second. As to Senator Phil Gramm, can you remember when it was that you
observed the fund-raising calls? First of all, do you remember whether
it was more than one? I am specifically talking about Senator Gramm.
The Witness. Yes. I cannot fix a date. I had occasion to meet
frequently with Senator Gramm during the Kay Bailey Hutchison campaign
when she was first elected to fill an open seat, and I was employed by
the Republican Senate Campaign Committee as a consultant to them in
working for the Republican candidate in that race.
As you recall, there were three Republican candidates and three
Democrats, and the top two, one from each party ran it off.
But the Republicans did not have a specific candidate, so I was
kind of in charge of the negative campaign against Kruger, who was the
most likely Democratic opponent. And I had run a campaign that had
defeated Kruger before, so, again, it was useful for me to do that.
In the course of that period, whatever date that campaign was--I
even forget the year, but you can check it, when she was first
elected--I was in Gramm's office a lot, like five or six or seven--five
or six times, maybe seven or eight times. And it was my specific
recollection that we would be meeting, and then somebody, his
secretary, would buzz in and say Mr. X is on the telephone, and then I
would see him lean back in his chair and say, ``Hi, Charlie, how are
you doing,'' and basically ask him either to set up a fund-raiser or to
give money.
I do not recall with any specificity whether he was asking to
arrange a fund-raiser or solicit a contribution, ask someone to
contribute to a Republican Senate candidate, since he was head of the
Senate campaign committee, or to contribute to his own campaign. But I
was constantly--the meetings were constantly interrupted by fund-
raising phone calls by the Senator.
Now, when Channel 7--ABC, rather--called me after this
``Crossfire'' and said now, can you recall whether--exactly the nature
of the conversation? the gentleman--the reporter told me it would be
illegal if he actually asked someone for funds; but if he asked someone
to set up a fund-raiser party, that might not be illegal; and if he
asked him to give money to another person, another campaign, that might
not be illegal. And I can't recall which of those activities the
Senator engaged in.
Mr. Cummings. Now, when you said you were in his office, was this
here in Washington?
The Witness. Yes, in his Senate office in the--I believe it is in
the Russell Senate Office Building.
Mr. Cummings. With regard to Senator Gramm, when you saw this take
place, did you comment on it at all?
The Witness. No.
Mr. Cummings. Within the office?
The Witness. No. It is my understanding that this is----
Mr. Lenefsky. The answer is no.
The Witness. The answer is no.
Mr. Cummings. So can you tell us about the circumstances, what you
observed with regard to Buddy Roemer.
The Witness. He was a candidate for Governor of Louisiana in 1983.
At that time he was a Democrat, he has become a Republican
subsequently, and I was a consultant on his campaign.
And, once again, I recall strategy meetings with him being
interrupted by callbacks from contributors where he would take the call
and he would discuss a campaign contribution or a party or some fund-
raising issue in the middle of the meeting that I was having with him.
I recall these because the interruptions were annoying to me and I
just wanted to have my meeting and not have to sit there and listen to
phone calls.
Mr. Cummings. And where did those calls take place?
The Witness. From his congressional office in one of the House
office buildings.
Mr. Cummings. And Paula Hawkins?
The Witness. I worked for Senator Hawkins on her initial election
campaign in 1980 and her re-election in 1986, and during the period of
'85 and 1986 I met with her almost weekly in her Senate office, and I
recall her making calls in connection with fund-raising from that
office.
Mr. Cummings. I want to go back to Phil Gramm for a second. You
said that you heard the callbacks. Did you hear--did you observe any
calls being made with regard to fund-raising, if you can recall?
The Witness. No. I don't think that he actually interrupted a
meeting with me to say, please wait while I call this person. I think
what would happen is that his secretary would buzz him and say, Mr.
Jones is returning--is on the line, and then he would speak to Mr.
Jones, and I inferred that it was a callback of a call he had
originally placed. It might not have been.
Mr. Cummings. Now, would that be the same for Paula Hawkins?
The Witness. Yes.
Mr. Cummings. So you don't recall--you don't remember hearing or
seeing her actually make a call out.
The Witness. That is correct.
Mr. Cummings. Now, are you aware of any other instances where
Congressmen have engaged in fund-raising phone calls in their
congressional offices?
The Witness. I have never directly witnessed that, but it is my
impression that it is the routine practice engaged in by, as I have
said, the vast majority of the House and of the Senate.
Mr. Cummings. Back on March 3rd, 1997--let me go back to what you
just said. Is there--I mean, when you say it's your--you said it's your
impression----
The Witness. [Affirmative nod.]
Mr. Cummings. Strike that. On March 3rd, 1997, the edition of
``Crossfire,'' you said, ``Every single Republican Senator spends about
80 percent of his time, including Senator Nickles, raising money, from
those high-back chairs in the United States Senate office.'' What did
you mean by that?
The Witness. Well, some of it might have been hyperbole. I don't
know if United States Senators spend 80 percent of the time while they
were in their office making fund-raising phone calls. It is my
impression that when candidates are up for re-election, Congressmen or
Senators, they end up spending, if they are in contested races, sharply
contested races--they end up spending a huge proportion of their time
dealing with fund-raising, and they--and my impression is that a vast
amount of that is from the Senate office.
As I'm saying that, I recall that--I recall learning from somebody
that Senator Cranston was legendary for sitting in his office and
making millions of phone calls--thousands of phone calls to donors. I
remember at one point someone telling me, I don't remember who, that
Cranston would literally treat his office like a fund--his fund-raising
headquarters.
So I was expressing on the program that when Senator Nickles, in
particular, expressed shock that the Vice President was doing it, was
making calls from his office, I think on the program I said it was akin
to the scene in the movie ``Casablanca'' where Humphrey Bogart, with a
French cop, bursts in and says he was shocked to hear that gambling is
going on, and the hotel clerk interrupts him and says, ``Here are your
winnings from last night, sir.''
Mr. Lenefsky. Claude Renee?
The Witness. Yeah, that's it.
Mr. Cummings. I think back on that program you also said that six
Members of the Senate, including half of the Republican leadership--do
you remember that?
The Witness. Yes. What I had in mind when I said that was, Phil
Gramm was part of the leadership and I did not--it was hyperbolic.
I have been asked in the past whether that included Trent Lott,
because I have been Senator Lott's consultant and I have said on the
record and would affirm now that I have never seen Trent Lott make a
fund-raising call from his office. I suspect that that's largely
because he has never had to.
Mr. Cummings. You worked for Congressman Dickey also?
The Witness. What?
Mr. Cummings. Congressman Dickey.
The Witness. Yes, Jay Dickey.
Mr. Cummings. And when was that?
The Witness. In 19--in his 1994 re-election campaign.
Mr. Cummings. And what were your responsibilities there?
The Witness. I did his polling and oversaw his advertising.
Mr. Cummings. Do you remember whether Congressman Dickey made any
fund-raising calls from his office that you would know of?
The Witness. I remember that he did not.
Mr. Cummings. Okay.
The Witness. I only met with him two or three times in his office
in Washington, and most of the rest of our meetings were in Arkansas,
and I know that those meetings in Washington were not interrupted by
fund-raising calls.
Mr. Cummings. Did you do any kind--type of fund-raising for him?
The Witness. No.
Mr. Cummings. You worked for Senator Helms, too?
The Witness. Yes.
Mr. Cummings. And when was that?
The Witness. In his re-election campaign of 1990.
Mr. Cummings. And what were your responsibilities with Senator
Helms?
The Witness. I conducted some of his polling and advised him on his
advertising.
Mr. Cummings. Now, do you recall him making fund-raising calls from
his office or receiving callbacks?
The Witness. No. I only met with Senator Helms once, which was in
his Senate office. It was a meeting of about an hour, and that was the
only time I have ever seen Senator Helms. He did make no fund-raising
phone calls. My contacts were with his campaign staff in North
Carolina.
Mr. Cummings. So you had nothing to do with any campaign fund-
raising for him; is that correct?
The Witness. That's correct.
Mr. Cummings. Are you aware of whether anyone affiliated with the
1990 Helms campaign provided information to the Christian Coalition
about needs, plans, or projects on the campaign?
The Witness. No.
Mr. Cummings. So you have no knowledge of that whatsoever?
The Witness. That's correct.
Mr. Cummings. Give me one second, please.
You worked for Senator Wilson; is that right?
The Witness. Yes, but I worked for him only in his campaign to be
elected to the Senate. I never worked for him after his election to the
Senate. When I worked for him, he was mayor of San Diego.
Mr. Cummings. And what did you do for him?
The Witness. I worked on his polling and on his advertising.
Mr. Cummings. So as far as fund-raising is concerned, nothing?
The Witness. No connection at all to his fund-raising.
To spare you, I would be happy to list my Republican clients, but I
have never worked on anybody's fund-raising in either party. It is not
what I do, and I know nothing about it.
Mr. Cummings. So you don't even get involved in that at all?
The Witness. That's right. There are occasions, and there have been
candidates, none of the ones you mentioned, where I am invited to speak
at a fund-raiser to urge a candidate's donors to give money. I did
that, for example, for Warren Rudman when he was running for the Senate
for the first time. But I never know who is in the audience, I never
view the invitations, and I never receive the checks or raise the
money, I just give a speech as to why I think he can win.
Mr. Cummings. You generally paid close attention to television
advertisements, ads by the Republican Party and its candidates for
President in 1995 and 1996, didn't you?
The Witness. Yes. Rather close attention.
Mr. Cummings. And why was that?
The Witness. Well, I was running the President's advertising, so I
needed to know what the other side was doing.
Mr. Cummings. So you personally reviewed many of the Republican
television spots in 1995 and 1996?
The Witness. Yes.
Mr. Cummings. And when you would review them, what were you
reviewing them for?
The Witness. To find out what they were saying about President
Clinton so that I could respond to them in the President's
advertisements.
Mr. Cummings. Do you recall seeing ``Dole for President'' spots
during the Republican Presidential primary?
The Witness. Yes.
Mr. Cummings. One of Dole's ads was a biographical spot produced by
Don Supple. Do you remember that?
The Witness. Yes.
Mr. Cummings. And does--I mean, can you tell us about it, as best
you can?
The Witness. Yes. I believe what you're referring to was a 60-
second advertisement that was run by the Republican National Committee
under the same rubric of issue advocacy advertising that the Democrats
did for President Clinton.
It was notable in my recollection because it systematically
violated every single one of the ground rules that Lynn Utrecht and Joe
Sandler, the counsel for the campaign and for the Democratic Committee,
had laid down for us and that we had to abide by.
It was a spot that had absolutely no issue content at all. It was a
warm and fuzzy biographic spot talking about where Senator Dole grew up
and his background and his war record and a lot of things like that,
and it had no reference that I can recall to issues at all.
I remember being outraged by it, and I called Utrecht and Sandler,
and I said, why are we being barred--I wanted to run an ad for Clinton
that talked about--that he was born poor, that he worked his way up,
that he went to school on scholarships, and flesh out some of his
background so that we could present that.
I was told by Utrecht and Sandler that if we did that, it would
have to be out of Clinton/Gore because it was not issue advocacy, and I
accepted that. But then when Dole did the exact same thing, I said, why
are you unilaterally disarming us?
I would like to state, in answer to your question, a little more
broadly, that whereas the Clinton--the Democratic National Committee
ran about $30 million of advertising that were issue advocacy ads, the
Republican National Committee ran between 20 and 25 million dollars of
advertising for Dole, which were issue ads, and whereas the Clinton/
Gore DNC issue ads--that is, the DNC issue ads that I supervised--were
run largely during the budget fight, the Republican ads were run--80
percent of them were run after June 1st, 1996, when it was clearly re-
election ads. During much of it the Congress wasn't even in session, so
there wasn't even an issue advocacy possible.
So I do want to point out that all of the accusations that have
been made about the Democrat issue advocacy advertising being thinly-
veiled re-election commercials, which I believe not to be true in our
case, were overwhelmingly and abundantly true in the case of the
Republicans.
Mr. Cummings. So you really are concerned about that, huh?
The Witness. What?
Mr. Cummings. You sound like you got very upset about that.
The Witness. I got very concerned when, in the last 3 months before
the Democratic convention, we were being outspent by 3-to-1 on issue
advocacy ads by the Republican Party.
I also was interested to note in the Washington Post today that the
Democratic Party spent 122--raised $122 million in soft money and only
$14 million of that went to the advertising campaign. We spent $45
million in pre-convention ads, 15 from Clinton/Gore, 30 from DNC, and
of the 30 from DNC, $16 million was hard and $14 million was soft. So
the parent to the advertising campaign was only responsible for about
11 percent of the total expenditures of soft money by the DNC.
Mr. Cummings. Now, you said you did run a biographical ad on Bill
Clinton; is that right?
The Witness. No, we never did. I wanted to, but we couldn't unless
it was Clinton/Gore money, and we elected not to do so.
Mr. Cummings. And the 1995-1996 DNC issue advertisements, I take it
that they focused on legislative issues; is that right?
The Witness. Yeah, they were overwhelmingly focused on the budget
fight, and they exclusively related to the contrast between President
Clinton's plan and the Republican plan to balance the budget, and they
would summarize the salient elements of each and advocate the
President's plan as opposed to the other plan.
For example, I remember that we could never use the name
``President Clinton,'' we had to say, President Clinton, apostrophe s,
plan--``President Clinton's plan''--because it had to be related to the
substance of the issue rather than the personalities involved.
Mr. Cummings. Now, you just laid out--the answer you just gave, you
said it had to be, and what are you basing that on? What were the
ground rules, and where did those ground rules come from?
The Witness. Lynn Utrecht, the campaign counsel, and Joe Sandler,
the DNC counsel, had presided over a series of meetings at Lynn
Utrecht's office, the sole purpose of which was to discuss what was
permissible in DNC issue advocacy advertising and what was not. They
laid down rules that were subsequently incorporated into memoranda that
was circulated that provided the ground rules as to what we could or
couldn't include.
Further, Mr. Sandler was present at each of the creative meetings
where we worked on developing these ads and constantly was editing and
fine-tuning the most minute details of the advertisements, text and
visuals, as well as its placement, in order to observe those ground
rules.
For example, I was--we were instructed that Democratic National
Committee issue advocacy ads could not run within the 28 days prior to
a primary contest in a given State, and that if we chose to advertise
within 28 days of the primary, even though Clinton was unopposed in the
primary, we would have to use Clinton/Gore money.
So, for example, we would refute--we couldn't advertise in the
Philadelphia media market during the New Jersey primary, the
Pennsylvania primary, and the Delaware primary. Even though the
Delaware was just a minute little portion of the Philadelphia media
market, we couldn't be on in the entire media market for the 28 days
before the Delaware primary, because of Joe Sandler and Lynn Utrecht's
rules.
The Republicans, on the other hand, ran their issue advocacy
advertisements on cable throughout this entire process and in
Washington, D.C., throughout the whole country, regardless of when the
primaries were taking place, and in the D.C. media market, even though
it was run on occasions that were proximate to the Maryland, D.C., and
Virginia primary dates.
Mr. Cummings. Help me with something. I'm just curious. What--you
keep referring to Joe Sandler, and I think he was the general counsel
for the DNC. Is that right?
The Witness. Yes.
Mr. Cummings. When you began your work with President Clinton, were
there discussions with regard to what your relationship would be with
regard to Joe Sandler as far as advice? I mean, were there guidelines
set out from the very beginning? because it sounds like Joe Sandler was
very much involved in what was going on here, and I was just wondering,
how did that relationship start with regard to you?
The Witness. When the advertising--when the decision was made by
the President to engage in issue advocacy advertising through the
Democratic National Committee, Sandler and Utrecht were appointed as
a--by the President and Ickes to be a group--to be the arbiters of that
campaign and to set the rules, the legal rules.
And then I suggested that rather than make that an ex-post-facto
review of the script or of the spot--not ex post facto, but a last-
minute review before it went on the air, which would inevitably cause
major revisions and delays, that we actually take the unprecedented
step, from my political career, of actually having the DNC lawyer,
Sandler, sit in meetings so that he was present at every instant while
the ads were being developed and, rather than just give this commentary
at the end, would comment literally as we had the visual on a freeze
frame, and he would say, you are leaving that on for 4 seconds, you can
only put it on for 2 seconds, or that ad says President Clinton, it's
got to say President Clinton's plan, or that picture is Bob Dole's
picture and Bob Dole has retired from the Senate and you can no longer
use Bob Dole's picture in your ads, because he is not a Senator
anymore, and therefore you cannot be engaging in legislative advocacy
by using his picture.
Those are all specific examples of the kind of ruling that Sandler
insisted upon while we were actually creating these advertisements.
Mr. Cummings. So the kind of meeting that you just spoke about,
would that be considered a creative meeting? Is that what they are
called?
The Witness. Yes.
Mr. Cummings. And you said--I think you used the word
``unprecedented'' for you.
The Witness. Yes. I had never had a lawyer in the room when I'm
writing ads. It was a unique experience.
Mr. Cummings. And why did you have a lawyer in the room here? I
mean, why were you----
The Witness. Because we were instructed by the President to follow
the specific advice of the attorney in the DNC advertising so that we
did not engage in any advertising that was over the lines drawn by the
Federal Elections Commission.
Mr. Cummings. So I take it that Sandler and----
The Witness. Utrecht.
Mr. Cummings. Newtrecht.
The Witness. Utrecht--U.
Mr. Cummings. Were engaged in all of these creative meetings.
The Witness. No. Only Sandler was, but Utrecht, in addition to
Sandler, cleared all scripts and all visuals before the advertisements
were permitted to run.
Mr. Cummings. And I take it that you, a few questions ago--answers
ago, you talked about the detail of looking at each advertisement as it
was developed. Was that the process that was--was that the pretty much
consistent process, for Mr. Sandler to look at every single aspect of
the ad?
The Witness. Yes. It was not pretty much consistent, it was
completely consistent. Not a single DNC ad was ever run where Sandler
was not intimately involved from the very beginning in the formulation
of the ad, except for the first ad that was run in August, which was
before there had been that kind of input. But Sandler and Utrecht
approved that ad before it went on.
Mr. Cummings. Now, did there ever come a time when you disregarded
Mr. Sandler's advice?
The Witness. No.
Mr. Cummings. Why not?
The Witness. Because I wasn't allowed to. My instructions were that
I had to obey every ruling of Sandler and Utrecht, and I did, down to
the last detail.
Mr. Cummings. I just want to go back to just one thing for a
second. We talked about the Republican ad, the one that you were kind
of concerned about.
The Witness. The Dole ad, yes.
Mr. Cummings. Do you believe, based upon--I mean, apparently you
had some concerns, and I take it that you don't believe that they met
the letter of the law.
The Witness. I can't comment on that, Congressman, because I'm not
an attorney. They certainly went far over the line that was drawn for
us by the counsel to the Democratic National Committee. I don't know if
his opinion was accurate, but if he were their counsel, he wouldn't
have let them do any of the things that they did.
Mr. Cummings. When you--let me talk about Joe Sandler a bit, just
ask you a few questions.
You gave us examples of things where Sandler said, look, you have
got to stay within a certain situation, and I think you referred to the
State races and the media markets and whatever.
The Witness. Yes.
Mr. Cummings. Were there other examples of what--of when Mr.
Sandler said, look, you got to stay in this box?
The Witness. Yes.
Mr. Cummings. Can you give us some examples of those instances?
The Witness. Before he would let us do an advertisement on a
subject for issue advocacy, we had to establish that the subject was a
current subject of political controversy in the U.S. Congress, not
simply that a bill had been introduced but that it was actually before
the Congress in an active and aggressive way.
So, for example, after the welfare reform legislation was passed
and signed by the President, we could not run ads on issue advocacy
relating to welfare reform, because it was no longer a question before
the Congress; it had been passed. Even though the President continued
to want changes in that legislation modifying the cuts, we were not
permitted to address that in the advertising. We were only permitted to
address topics that were front stage before the Congress.
Another example was that we were required in our attack, whenever
we presented Dole's picture, to present Gingrich's as well, and
whenever we mentioned the name ``Dole,'' we had to also mention the
name ``Gingrich,'' to emphasize that we were mentioning the name
``Dole'' not in the context of his Presidential candidacy but in the
context of his position as majority leader in the Senate.
As another example, Sandler and Utrecht, when it looked as if Lamar
Alexander might be the Republican candidate, they told me at that point
that we could not mention Lamar Alexander's name in our issue advocacy
ads because he was not a Member of Congress and had not been a Member
of Congress and was not--didn't have--and even though he had positions
on the issues before Congress, he was not a participant, and therefore
we could not mention his name.
At one point, I was terribly concerned that if he were the nominee,
he would be able to use issue advocacy ads to attack Clinton because we
were President but we could not use issue ads to attack him because he
wasn't in Congress.
Those are all examples. I could literally give you 50 more.
Mr. Cummings. Well, what about as to the Dole ad--and I know you're
not a lawyer, but based upon your knowledge of what you--the ground
rules that you were working under, can you give us examples of the
things that concerned you there?
The Witness. First, that they--well, all I can tell you is examples
of what they did that Sandler wasn't letting us do.
Mr. Cummings. I understand.
Mr. Ballen. You mean the RNC, sir?
The Witness. The RNC. First, the RNC advertised in States
immediately prior to their primaries; we did not; the DNC did not.
Secondly, the RNC permitted biographic ads to be run that had no
issue advocacy by the RNC; the DNC was not permitted to do that.
Thirdly, the RNC ran an advertisement that showed Bill Clinton
saying, ``We can balance the budget in 7 years,'' and then there were
films clips of him giving different time deadlines: We can balance it
in 10 years, 7 to 10 years, 8 years. And there were film clips of
Clinton contradicting himself on when the budget would be balanced. It
did not indicate the Republican position on the issue; it did not
discuss the President's position on the issue; it was a negative ad out
of the blue.
We would never have been permitted to run that ad. We would have
had to state what our position was and what the conflict was.
So there were, long after--long after the welfare bill had been
passed, the Republicans were running ads attacking Clinton on welfare
reform with DNC--with RNC funds paying for it, and we were not
permitted to reply to it effectively because we could not address that
with a DNC ad, we had to use Clinton/Gore ads to deal with welfare
reform, because it was no longer in play before the Congress.
I would go to Sandler and I would say, ``They are running an ad
attacking us on welfare reform with an RNC label. Why can't we reply to
that ad with a DNC label?'' And he would say, ``You can't.''
I actually had occasion to--at some point, to speak to the
President and say we were being unilaterally disarmed by Utrecht and
Sandler and being required to be held to a standard that the
Republicans were nowhere near approaching. I said, ``Mr. President, we
are being outgunned 3-to-1 here in quantity and we are fighting with
one hand tied behind our back because of the''--``our inability to do
what they are doing, what the Republicans are doing.'' He said to me,
``I don't care. Follow their instructions.''
Mr. Cummings. I'm just curious, did you ever go to Sandler and
Utrecht and say look, guys, basically what you just said? Did you ever
say, look, you got--I mean, our hands are tied behind our backs?
The Witness. Constantly. I recall one meeting with Utrecht where we
had one of these legal meetings where we literally screamed at each
other. I shouted at her. I said, ``You are deliberately trying to
sabotage this advertising campaign because you are a pawn in a tool of
Harold Ickes''--Ickes was there--``and you are using this legal fiction
that you are developing as a tool of emasculating our advertising
campaign because Ickes opposes it and you are following his orders.''
And she screamed back at me that that was outrageous accusations,
Ickes was furious, and everybody's tempers cooled after a little while,
but it was tremendous friction of my resentment against what I
considered to be their unreasonable imposition of rules that the other
side wasn't following.
I was perfectly willing to follow their rules, but only if the
other side did, and when the other side broke them, I didn't see any
reason that we should be subject to them. But we were, and we continued
to be, and I didn't like it one bit, but I had to follow it.
Mr. Cummings. I take it that you had--you just used a term that I
hadn't heard before in your testimony. You used the term ``legal
meeting.''
The Witness. Yes.
Mr. Cummings. Is that what you said? So I take it you had the
creative meetings, which was creating the ads, and then there were
legal meetings.
The Witness. Yes.
Mr. Cummings. What are legal meetings?
The Witness. I testified on that earlier.
Mr. Cummings. Oh, I'm sorry.
The Witness. It's okay. The legal meetings included Ickes; Sandler;
Utrecht; Cheryl Mills; sometimes Jack Quinn; sometimes Ron Klain;
myself; Tom Freedman, my chief of staff; Mark Penn, our pollster; and
Bill Knapp, our media creator; and also the gentleman who was our time
buyer-,--I forgot--Jamie Sperling I think was his name, our time buyer
who worked for Squier, and we had six or seven of those over the course
of the campaign.
Every time the campaign entered a new phase, the primaries were
here, or Dole was the nominee, or the budget, you know, different
phases as the campaign progressed, when the circumstances changed, we
would have a meeting to outline the ground rules of the new situation.
Mr. Cummings. Going back for a moment, I guess you felt kind of
pressured with the President over this whole issue of counsel
restricting you and----
The Witness. Yes.
Mr. Cummings. That really bothered you, huh?
The Witness. Yes.
Mr. Cummings. And the President's--it was basically almost, from
what you said, when you told the President, look, our hands are tied
behind our backs, I take it that there was very little discussion,
except you got to follow the law?
The Witness. Yes.
Mr. Cummings. So did you get the impression from your discussions
with the President when you complained that he had full confidence in
these two counsel?
The Witness. Yes.
Mr. Cummings. I don't have anything more. Thank you very much.
The Witness. Thank you very much. Good to meet you, Congressman.
Mr. Cummings. My pleasure.
The Witness. Hey, off the record.
[Discussion off the record.]
EXAMINATION BY MS. COMSTOCK:
Question. Were you familiar with many of the various campaign
accounts that were being used to pay for ads by the RNC?
Answer. No.
Question. Were there any written legal opinions regarding the rules
of issue advocacy ads that you discussed?
Answer. Yes.
Question. And would those be some of the documents that I think we
previously discussed would be at your office?
Answer. Yes. There are other places they would be. Lynn Utrecht
would have them, Joe Sandler would have them, and most likely Bill
Knapp of Squier, Knapp, Ochs would have them.
Question. Were there discussions over the use of coordinated
accounts?
Answer. No. There were--with one exception, which I will get to in
a minute, we were--I was never involved, nor were--to my knowledge,
were any member of our media team, ever involved with the formulation
of any coordinated expenditure--any independent expenditure.
That's what you mean, right? Not coordinated, but independent
expenditure by the AFL, or any other--Sierra Club or any other group.
Am I responding to your question? You said ``coordinated.'' It just
dawned on me.
Question. The coordinated accounts.
Answer. I don't understand the question.
Question. Talking about the coordinated accounts run by the States
and the soft money that----
Answer. Oh, yes, I did know about that. There was--we were informed
at some point in September or October, I believe, of '95, I believe by
Ickes, that when a State party ran an ad, under its disclaimer as
opposed to the Democratic National Committee, the ratios of hard and
soft money were less--were less onerous, and I was informed at that
time that we had no problem having enough soft money, but the hard
money which was Federal money was a problem, and that if the ad were
run by the State party, you had to have less hard money in it.
Therefore, we were requested to prepare separate ads for each State
party. The media people would then prepare an ad sponsored by each
State party. There would be a separate disclaimer line for each State
party, and the ads would be identical except for a different
disclaimer, and therefore the buy was technically 30 or 20 separate
buys, one for each State. I was aware of that.
Question. These were generally the same ads?
Answer. They were always the same ads.
Ms. Comstock. Okay. I'm showing the witness DNC document 310398
through 701. I may have given somebody my copy, I'm sorry. Can I check
these again? I'm sorry.
[Brief pause for document examination.]
EXAMINATION BY MS. COMSTOCK:
Question. The front page of this is a handwritten note, apparently
Don Fowler of October 12th, '95, and it's attached to an information
sheet in the memo to Bill, Bill somebody. It says, ``Thank you for
returning my call today. Attached is an info sheet about our efforts to
raise money to fund 10 million of paid TV ads over an 8-week period
during October and November. This effort is at the specific direction
of the President.''
Was that your understanding of this media buy in October of '95?
Was it at the specific direction of the President?
Answer. Yes.
Question. And it continues, ``We would like for you to give some
more, if you can, but more important, get some others to help. We
really need another $250,000. Thanks, best wishes, Don.''
Then it is attached to a memo that is to Chairman Don Fowler from
Squier, Knapp, Ochs Communications, and that memo is dated October 5th,
1995.
Were these the kind of State buys that you're referring to that you
were discussing just a moment ago?
Answer. Yes.
Mr. Ballen. Could you ask the witness if he has ever seen this
document before?
The Witness. Are you asking me? No, I have never seen this document
before.
Ms. Comstock. I am asking if this is the type of media buy that you
were talking about.
The Witness. Yes.
EXAMINATION BY MS. COMSTOCK:
Question. Okay. And the States outlined here the States for an
early October media buy, October 3rd through October 12th, '95; is that
correct?
Answer. Yes.
Question. I think earlier when we discussed some of the States, you
had mentioned Vermont and Rhode Island as being among the States that
were selected. Directing your attention to DNC 3103700, at the bottom,
it talks about--under New York, it has ``Burlington-Plattsburgh
market.'' Was that the Vermont reference----
Answer. Oh, Burlington. Yes, of course, Burlington, Vermont. Right,
that is correct.
Question. To your knowledge, does that market also expand into New
York State?
Answer. Yeah, but very limited. They really should have listed
Vermont; it gets virtually all of Vermont.
Question. And then on Rhode Island, does that market, the
Providence market, extend at all into the Connecticut area?
Answer. A small amount. This document illustrates the point that I
was trying to make, that these buys were primarily targeted at
Republican and conservative Democratic Senators or Congressmen.
The Arkansas buy was not targeted at individual Senators, but there
was a Republican Congressman from Little Rock who we were targeting.
In California, I don't recall the Congress people from these
markets, but I think that's how we arrived at these markets.
In Colorado, we were targeting Nighthorse Campbell to hold him as a
conservative Democrat, and we had high hopes of breaking off Hank
Brown.
Again, I'm afraid I don't recall the names of the Congressmen, but
I do know the Senate strategy.
Question. Was Colorado also a swing State in '96 that you were
focusing on for the President?
Answer. It is, but it is not the reason--well, yes, it is, and that
is part of the reason it is included here, not because it was a swing
State we were focusing on for the President, but because when we are
trying to move national poll numbers, the best place to move them is in
swing States.
When you have a State that is determinantly Republican or
determinantly Democrat, you are going to have less movement on national
polling numbers on the budget packages if you go into those States than
if you go into swing States. But most of this buy was particularly
animated by a desire to move Congressmen.
We were in Iowa because the Republican primary was in Iowa, and we
felt that if we could make Iowa hate the Medicare cuts, Dole would find
it difficult to push those cuts, because he had to win the Iowa
primary.
In Illinois, these markets correspond to Congress people who we
were attempting to target. If we were attempting to do Illinois, we
would push Chicago as a swing State, but we were trying to hit
Congressmen.
Kentucky, we were trying to hold Ford and we were trying to get at
McConnell.
Louisiana, we wanted to make sure that Bennett Johnson was not
tempted to vote for an override and that Breaux was not tempted.
In Maine, which, goodness knows, is not an important State in a
Presidential contest, we were going after Olympia Snowe, and I forget
who the other Republican Senator was from Maine at that point.
Question. Senator Cohen?
Answer. Senator Cohen, of course, the two liberal Republicans we
had a pretty good shot at.
Michigan, that was much more to hold the Democrats.
Minnesota, we were targeting both for congressional reasons and for
Senate reasons.
Missouri, I know we had an extensive discussion about the chances
of moving Ashcroft to support the budget--the President's budget.
In New York, these are tiny New York markets, and the goal was to
make it hard for D'Amato, whose political base is upstate New York, to
support the budget and to move over people like McHugh and Houghton and
other moderate Republicans.
In Ohio, we were attempting both to make sure that we could hold
Glenn's support on this issue and to give us a realistic shot at
DeWine.
In Oregon, that was exclusively dominated by our efforts to get
Packwood and Hatfield to support the President from the Republican
position.
In Pennsylvania, these individual local markets were largely
dictated by congressional considerations and the fact that we had a
very good shot, we thought, of making this vote one that Specter would
have difficulty casting.
Rhode Island is completely a Democratic State, it is never in play
in a Presidential race, and we did this exclusively to influence
Chafee.
In Tennessee, we were trying hard to influence Thompson and to
affect some of the congressional people.
Washington, I don't recall the targeting thinking there. And
Wisconsin, again, I don't recall it specifically.
But the point is that these buys, these little picayune markets,
each place which were aware of the advocacy issue ads ran in 1995 were
largely dictated by my strategic view that I would frequently
articulate at strategy meetings, and I remember I did so rather
colorfully. I said, our goal is to split the Republican majority into
small hunter-gatherer groups that we can pick off one at a time. And
that phrase sort of stuck with them. And I was predicting the
dismemberment of the Republican majority into hunter-gatherer groups
with some optimism in September and October. Unfortunately, I
underestimated the proclivity of the Republican Party for suicide.
Ms. Comstock. Okay, I will make this document Deposition Exhibit
Number 2.
[Morris Deposition Exhibit No. 2 was marked for identification.]
EXAMINATION BY MS. COMSTOCK:
Question. Could you describe what you know about how financially
these media buys were paid for by the States and how that money was
sent back to Squier, Knapp or Penn & Schoen?
Answer. I only know it secondhand. Bill Knapp was in charge of
that, and he would receive money from the State parties, and that would
fund the time buy.
The only reason I know that is that, after we had run this for a
while, there were a number of State parties that were slower than
others in paying, and I--he acquainted me--Knapp acquainted me with
that, and I mentioned it to Sosnik, and he followed it up, and that was
the last I had heard of it.
I don't know the mechanical process by which the money was given.
Question. I want to show you CGR 010924, a document the committee
received from Mr. Ickes dated June 26th, 1996, a memo to Chairman Dodd,
Chairman Fowler, B.J. Thornberry, and Brad Marshall, cc to Doug Sosnik,
Karen Hancox, and Jennifer O'Connor, from Harold Ickes, and it is
regarding bills for Squier, Knapp and Penn & Schoen.
Have you seen this document before?
Answer. No.
Question. Do you recognize any of the handwriting on the document?
Answer. No.
Question. You're not familiar with Mr. Ickes' handwriting
generally?
Answer. No.
Question. Okay. This document reads, ``Until further notice, I
request that you hold payments on all bills of any kind, other than for
time buys owed to Squier, Knapp and to Penn & Schoen until they have
clarified a number of questions and provided adequate documentation
regarding bills they have submitted.''
Do you recall any discussions about that?
Answer. Yes.
Question. Could you describe those?
Answer. Yeah. This was during a period of fairly acrimonious
negotiations and discussions between the consultant group and Ickes
over the issue of the media commissions that we would be permitted to
retain as compensation, and I suspected at the time that Ickes was
deliberately using the facade that this document speaks of, that there
was inadequate documentation as a method of slowing or stopping
payments for polling and production costs to these two companies, Penn
& Schoen and Squier, Knapp, Ochs, as a way of pressuring them to come
to a quick agreement on his terms over the commissions that they would
be permitted to retain.
I harbored these dark suspicions during this period and yesterday
was shown a document which was a memorandum from Ickes to the President
in which--at the Senate deposition, I was shown this document in which
Ickes specifically said, ``I am holding up further payments to Squier,
Knapp, Ochs and Penn & Schoen for their polling and their production as
a method of bringing pressure on them to get them to agree to a
contract on our terms.''
And that was very enlightening for me to see, because it was
precisely what I thought was happening then, and it turns out that I
was correct in that supposition.
Question. Can you generally tell us what the difference is between
what you were asking for in terms of money and what Mr. Ickes was
trying to bring it down to, generally, if you can give us ball park
figures?
Answer. I don't recall, because they involved a minutia of
discussions, but ultimately I think the average commission that the
consultant group received on the entire flight of Clinton/Gore and DNC
pre-convention media ended up being about 7 percent, and I think Ickes
wanted it to be more like 5 or 6 percent.
Question. Initially, had you all asked for something like 15
percent?
Answer. In the first buy, which was the crime ads, the Clinton/Gore
ads, we were paid 15 percent because we had been working for a
considerable period of time without any compensation on the media for
Squier, Knapp in particular. Then in the--then for a long time starting
in August, it was pegged at 10 percent.
Question. August of '95?
Answer. Yes. And then I believe it was at 10 percent for the next
12 or 13 million dollars of media, and then after that, it dropped to 6
or 7 percent, and then it dropped further. The average was a little
over 7 percent, as I understand, over the entire process.
Question. And was part of what Mr. Ickes was trying to do because
of pressures from DNC fund-raising, to your knowledge?
Answer. I have no idea. I don't know. I felt that it was not a
good-faith effort on his part. I felt that we were talking about a $45
million time buy that was ultimately spent, $30 million of it from DNC,
and a 1 percent difference on half of the buy would amount to $1
million.
I didn't think that that was his motivation at all. I felt that his
motivation was to try to raise a thorny issue to interrupt the smooth
flow of my relationship with the President and to use the disagreements
over money as a method of antagonizing the President, of making the
President antagonistic toward me and toward the consultant group. He
didn't succeed in that, but I felt that was why he was doing it.
Question. So you think the amount of difference was somewhere in
the ball park of $1 million that he may have been----
Answer. Yes. Probably even less, because as time went on, the
amount of money--for example, this memo was June 26th. We knew that we
would stop any advertising other than--we knew that in the general
election we would have a completely different commission arrangement.
So this pressure would have been designed for a 2-month period, and in
that 2-month period we probably sent about $6 million. So a 1 point
difference over $6,000,000 is a $60,000 difference.
When I suspected that he was playing hard ball over $60,000, it was
not because he genuinely wanted to save the $60,000, it was because he
wanted to find an issue where he could try to impair my relationship
with the President.
Question. Were you aware at this time, at or around late June,
early July of 1996, Don Fowler putting a lot of pressure on both the
fund-raisers at the DNC to raise a lot more money?
Answer. No.
Question. Do you have any--have you learned at all about any
particular pressure that was put on John Huang to raise money in July
of '96?
Answer. No.
Ms. Comstock. I would like to make this document Deposition Exhibit
Number 3.
[Morris Deposition Exhibit No. 3 was marked for identification.]
The Witness. By the way, it is 12:53. Maybe at 1 o'clock we could
break for----
Ms. Comstock. I know you do want to get out at 4:00, so if we could
go until about 1:30, and then we can see where we are at.
The Witness. 1:00, if you would.
Ms. Comstock. Okay.
The Witness. I have a phone call that I scheduled at 1 o'clock.
Ms. Comstock. Okay.
EXAMINATION BY MS. COMSTOCK:
Question. I'm just showing you for reference purposes, because I'm
talking about a document and these are Mr. Sandler's handwritten notes,
I have no reason to believe you have seen these or you don't know
anything about them, so we can say that at the outset.
But in here, this is DNC 3096675 through 81. It's talking about FEC
reports and State committees and how the money is spent at the State
level. We were just talking a little bit about how the States were
doing media buys and then the bills were being--they would send the
payments back to Penn & Schoen.
I was wondering if you ever recall hearing any discussion about
that the FEC doesn't usually audit State committees in any way?
Answer. No, nothing.
Question. Directing your attention to the--I mean, there are some
handwritten notes here.
Answer. Yes, I read that. As you can tell, I have been reading
through the document, and I see nothing here that I'm familiar with.
Question. So in terms of any of your discussions with Mr. Sandler,
these--I will let you look through the document here initially and
maybe just ask you if you generally recall some of the topics that are
referenced here, if any conversations you had with Mr. Sandler, if
these topics may have come up.
Answer. No.
Question. So I will just allow you to--I think one of the issues
is, the FEC doesn't audit State committees.
Another issue----
Mr. Ballen. I want to state for the record, since the witness
doesn't know anything about this document, hasn't seen it, I don't want
any inferences drawn as to the meaning of the document or what Mr.
Sandler intended or----
Ms. Comstock. I think that is clear from the record. I am just
using this as a point of reference to see if any of these topics may
refresh his recollection as to any topics that Mr. Sandler may have
raised with you.
The Witness. No, in answer to FEC audit, and nothing that I can see
in the document.
EXAMINATION BY MS. COMSTOCK:
Question. Do you recall any--in regards to the State parties, do
you recall there ever being any effort to have some type of State party
coordinating body that would filter out everything and that there would
be some counsel that would work with the State parties at any time?
Answer. No.
Question. Okay. Were you aware of Mr. Ickes having meetings with
Mr. Sandler separately to discuss these State party issues and how they
would get the money out to the State parties and back to Penn & Schoen
and Squier, Knapp?
Answer. Squier, Knapp, but no.
Ms. Comstock. Okay. I will go ahead and make that Deposition
Exhibit Number 4.
[Morris Deposition Exhibit No. 4 was marked for identification.]
Ms. Comstock. I guess we are at a breaking point.
The Witness. Okay. So 1:30?
Ms. Comstock. Do you want to do 1:30?
The Witness. Good. Okay.
[Whereupon, at 1:00 p.m., the deposition was recessed, to reconvene
at 1:30 p.m.]
EXAMINATION BY MS. COMSTOCK:
Question. We can get back on the record. I am going to pick up on
something we were on before the break, before Mr. Cummings came in. We
had been discussing a Washington Post article that had appeared, July
18, 1997, about Harold Ickes, and we had been discussing the comment
you made about if Harold really unloaded, there would be a whole lot
more going on now.
I think you pretty much completed going through that, but I was
wondering if you had any particular knowledge about any information Mr.
Ickes had about any investigation into the President or the First Lady?
Answer. None.
Mr. Ballen. It has been asked and answered.
EXAMINATION BY MS. COMSTOCK:
Question. In the past you had been reported by, I believe it is
Republican operatives or whatever, saying you thought the President
might be indicted. Did you ever say that to anyone in public?
Answer. The allegation was I said that to Governor Weld. That is
the allegation that appeared in print.
Governor Weld and I have both denied it on the record. Governor
Weld's denial appeared in the Boston Herald a few days later. I do not
recall making such a statement to anybody.
I think I did during the course of my work with Republicans in '93
and '91 and '93 and '94 indicate that I thought that Clinton would be
perpetually grilled for scandal-type investigations because I knew all
of the controversies that surrounded him and I was aware of those
before the world at large was just simply because I was with him in
Arkansas and I knew what was publicly reported then.
But this was never derived from any inside knowledge or inside
information about any of these scandals. It was just that I read the
press on Clinton a lot before anyone else did, because I was working
for him for 20 years.
Question. Do you know anything--do you know a group called the Back
to Business Committee?
Answer. I don't think so.
Question. And Louis and Lynn Cutler were affiliated with?
Answer. I have heard about that, yes.
Question. Do you know if Penn & Schoen or Squier Knapp ever did any
work for the Back to Business Committee?
Answer. No, I don't. I would be surprised if they did because they
never told me they did, but I don't.
Question. Did you ever do any work for the Back to Business
Committee?
Answer. No.
Question. Do you have any knowledge about any of the polling that
you did being shared with the Back to Business Committee at any time?
Answer. No. Could you clarify for me the time frame of when they
operated?
Question. I believe it was somewhere around 1994 to--I am not quite
sure when they disbanded.
Answer. Well, my polling really was only there in '95.
Question. They definitely were in existence in '95.
Answer. Were?
Question. Yes.
Answer. Yes, I have no knowledge of it being shared with them. The
reason I say that is, and Lewis had access to all of our polling data
after September or October of '95 when she joined the White House
staff.
Question. She would have had access to the polling, but you have no
knowledge of anything related to Back to Business?
Answer. No.
Question. Aside from the fact that Ms. Lewis is associated with
Back to Business?
Answer. Yes.
Mr. Ballen. For the record, it is clear the witness stated she had
access to the polling after she joined the White House in September or
October.
The Witness. Yes, but not before.
EXAMINATION BY MS. COMSTOCK:
Question. And did you conduct polls regarding Whitewater or
Filegate or other matters that arose, investigations----
Answer. Yes.
Question [continuing]. During your polling? And do you recall who
paid for those polls?
Mr. Ballen. I am going to object. We are now into discussing the
actual kinds of questions that were on the polls?
Ms. Comstock. I am asking about who paid for the polling.
Mr. Ballen. He already testified as to his knowledge of the payment
of the polling.
The Witness. I can short-circuit the debate by saying as I
mentioned each question was allocated to one or the other, and I have
no knowledge of how those particular questions were allocated.
EXAMINATION BY MS. COMSTOCK:
Question. So you don't, for example, if a Filegate question, Craig
Livingstone would be a DNC question or a President Clinton--Clinton/
Gore question?
Answer. That is correct.
Question. I believe you have made statements, public and reported,
regarding Harold Ickes and his temper. I believe you said he exercised
a reign of terror at the White House. Is that an accurate portrayal?
Answer. It is accurate that I said it and it is an accurate
portrayal.
Question. Could you just briefly describe why, the kind of things
that led you to say something like that?
Answer. When I got to the Clinton operation in 1994 and early '95,
and I began to interact with the staff, with the White House staff,
everybody on the staff was terrified of venturing forth with any ideas
that would be moderate or centrist in nature, because they were certain
that they would be fired, in particular Don Baer, who was the first
White House staffer that I dealt with concerned about it.
I remember being shocked about it, because the way I met Baer was
that the President called Baer and had him up to the White House with
me, and he said, I would like you two to meet each other, and he turned
to Don and said, I would like you to work as closely as you possibly
can to Dick and listen to what he says and work very closely with him.
And I said great, and we left and went to Squier's office to work
together on our first speech. And he said, ``you mustn't tell any one
that I am doing this.'' I said, what could you mean? He said, nobody
should know that I am working with you. I said, the President just told
you to work with me. And he said, no, no, if Ickes finds out, I am dead
meat, I am out of here. No way--I said, you are following the
President's directive, Don. And he said, yes, but tell that to Ickes.
That was repeated, that kind of thing was repeated a dozen times,
that people were--that people were terrified of advancing any political
idea, other than left wing Democratic Party liberal approved thinking.
There was, as I said, a reign of terror going on, and many White House
staffers who were closet moderates greeted my emergence with some power
in the White House with a great sigh of relief, because they could
finally come out of the closet and share their real opinions with
people.
In fact, many of the moderates had resigned by the time I got
there, Galston among them, in despair at their ability to have any
influence in moderating the left wing drift of the White House.
Question. Were you ever concerned that given--and did Harold use
his temper, I think you described previously the situation where the
door had to be fixed and that kind of situation. Were you ever
concerned that his behavior and the way he treated staff might cause
people to do things that they--in response to him that maybe they
shouldn't or would get the President in trouble because they were
trying to respond to Harold, that they wouldn't be using judgment?
Mr. Ballen. I am going to object to this entire line of
questioning. We are now in an investigation that is supposed to be
about campaign fund-raising. We are getting into Mr. Morris' insights,
which are quite interesting, into an area that has absolutely nothing
to do with the subject matter of this investigation, Mr. Ickes' temper,
his temperament, how he conducted himself, whether a door was rattled
or not.
Ms. Comstock. I am asking about the climate created by the central
person which this person has testified is in charge of the budget of
the DNC, and I would like to discuss the climate he was creating.
Mr. Ballen. That is not what he testified to. He didn't say he was
in charge of the budget. There is no relationship of these kinds of
questions to the subject matter of this investigation.
Mr. Lenefsky. You can answer.
The Witness. I was rather hoping someone would be mad enough at him
to shoot him, but other than that I didn't have any serious concern he
would turn people off the President, no.
EXAMINATION BY MS. COMSTOCK:
Question. Were you concerned that actions taken by anybody would
not be consistent with the law or doing things the right way, because
if Harold told you to jump, you were going to jump, regardless. Did you
ever have any concerns like that?
Answer. It makes sense now, but I sure didn't think of it then.
Question. You hail from New York as well as Mr. Ickes does. Are you
familiar with his--do you have any personal knowledge about any legal
problems in his background?
Mr. Ballen. Objection.
The Witness. No.
Mr. Ballen. Objection. Relevancy. Mr. Ickes' personal legal
problems are not a subject matter of this investigation.
The Witness. Off the record.
[Discussion off the record.]
EXAMINATION BY MS. COMSTOCK:
Question. Have you talked recently with the President about Harold
Ickes and these documents that were turned over to Congress?
Answer. I don't understand the question.
Question. Have you talked with the President about Harold Ickes'
documents that were turned over to the Congress?
Answer. No.
Question. Have you talked with the President about Harold Ickes
since January 20th of this year?
Mr. Ballen. Objection, relevancy.
Mr. Lenefsky. I have no problems with that.
The Witness. No.
EXAMINATION BY MS. COMSTOCK:
Question. How often do you currently speak with the President?
Mr. Lenefsky. How often----
EXAMINATION BY MS. COMSTOCK:
Question. Do you currently talk to the President?
Mr. Lenefsky. You can answer, if you recall.
The Witness. I would rather not answer it.
Mr. Ballen. I object as to the relevancy.
The Witness. I would rather not answer that question.
Mr. Lenefsky. You don't have to explain.
Ms. Comstock. Are you instructing your client not to answer?
Mr. Lenefsky. Yes.
The Witness. If you want to ask me about specific topics that I may
or may not have spoken to the President about, feel free to do that,
and I will answer, but I don't want to answer an open-ended question of
how often we speak or an open-ended question about what we talk about.
EXAMINATION BY MS. COMSTOCK:
Question. I understand that.
The second one, I am not going to be going into it, the whole array
of what you may talk about. I would like to just get a general idea how
often----
Answer. I would rather not answer that question.
Mr. Lenefsky. I object.
EXAMINATION BY MS. COMSTOCK:
Question. Have you talked with the President about anything
relating to the general matters that are under investigation by this or
the Senate committee?
Mr. Lenefsky. By this committee?
Ms. Comstock. This, the Justice Department, the Senate. The general
fund-raising matters, the matters re the John Huang, John Trie, Harold
Ickes' documents.
The Witness. Yes, I have.
EXAMINATION BY MS. COMSTOCK:
Question. Can you describe what those conversations were and when
they occurred?
Mr. Lenefsky. Do you want to talk outside?
The Witness. Yes.
[Discussion off the record, 1:50 p.m. to 1:53 p.m.]
Mr. Ballen. Before you answer or not answer, let me just raise
something. White House, for your consideration, White House counsel has
requested to be at depositions of White House employees or people who
have worked for the White House in order to be able to assert any
claims of executive privilege----
Ms. Comstock. I don't believe Mr. Morris testified he ever worked
at the White House.
Mr. McLaughlin. The opinion of the D.C. Circuit judge extends the
privilege to lawyers----
Ms. Comstock. To campaign consultants?
Mr. McLaughlin [continuing]. To people working for the President
giving advice.
Mr. Lenefsky. I have reviewed Mr. Morris' response to the question.
I have no objections whatsoever to Mr. Morris responding. I don't think
the President would have any objections. I don't think the Senate
Majority would have any objections. I don't think they are
objectionable anyhow.
The Witness. So I choose to respond. I have had--I cannot recall
when, but these conversations took place subsequent to the 1996
election. In one conversation I advised the President that I felt the
way to defeat the partisan attempt of the Republican investigating
committees is to outflank the Republicans by stronger advocacy of
campaign finance reform.
I remember telling the President that the Republicans don't really
want campaign finance reform, they just want to narrow the focus to
scandal, and if possible only the Democratic scandals, and that the
public doesn't particularly care about the scandal, they care about
finance reform. And by playing what I called jujitsu, which is
harnessing the enemy's strength against him, he can take the impetus of
your investigations and turn it against the Republican Party by taking
advantage of the elevation of the germaneness of the issue of campaign
funding reform and becoming a better advocate of it than the
Republicans are. I went through that. That is essentially what I said
to him.
The second----
EXAMINATION BY MS. COMSTOCK:
Question. Somewhat like what appeared on the front page of the
Washington Post this morning?
Mr. Lenefsky. That is the article I told you about.
The Witness. I didn't see it. I had nothing to do with that story.
And then the second time that we discussed it----
EXAMINATION BY MS. COMSTOCK:
Question. What was the President's response?
Answer. He just listened. Generally when I speak to the President
and give him advice, sometimes he will question it or he will comment
about it, but most of the time he will just listen and he will just say
okay, what else.
And then the second thing was that at least one and perhaps two or
three junctures since the election I have told the President that it is
my opinion that he should continue to oppose the appointment of a
special prosecutor; that sooner or later the Justice Department will
actually begin to produce indictments, and once they do, everybody will
accept their investigation as being intensive, intrusive, and
legitimate.
I also said that I felt that in opposing the campaign--the
appointment of a special prosecutor, he should stress Senator Helms'
involvement in that process through the judge, whatever his name is,
and that in focusing on--the way I urged him to frame the issue was,
who do you want to name the prosecutor, Janet Reno or Jesse Helms, and
we would come out ahead in that comparison. And I said I felt that the
special prosecutor's position had so diminished in public prestige that
he should not feel under compulsion to urge that appointment.
He then replied to me that he felt that he agreed with me, that he
felt that there was ``nothing there,'' and that the investigation--that
sooner or later people would get that the investigation was a very
aggressive one.
I then cracked a joke to him where I said, Mr. President, there
were times during the first term when I had the impression you would
have welcomed a special prosecutor assuming some of the jurisdiction
that Ms. Reno assumed. You would have probably gotten a better break
from them.
And he didn't laugh.
Question. I believe you had been quoted as making some comments
about why Janet Reno didn't appoint a special prosecutor and about
meetings she had with the President.
Mr. Lenefsky. Do you remember any quote?
The Witness. Yes. I was quoted in the National Review on it.
Yes, I can't recall what I said or didn't say at that juncture, but
let me answer your question. I believe that subsequent to Election Day,
the President had a meeting with Janet Reno, which was unusual because
they had been on very icy terms during the last 2 years of his first
term, and to my knowledge there was a time when they were really
basically not speaking to each other. I mean, they just didn't talk. It
was done through intermediaries.
They had a meeting and it was my impression that--actually the
President told me that the air--that that had cleared the air and he
felt much better about Reno, and that he felt that she--that he wanted
her to stay. I said that I felt that their relationship had improved
since Election Day.
I specifically at the same time said I did not feel--that I had no
information and I would doubt very much that any specific issue about a
special prosecutor was discussed between the two of them. I don't think
the President would discuss that, and I don't think Reno would permit
him to discuss that. But I do think the relationship warmed
considerably, and I was surprised at that.
I think that what happened was during the period when Reno was
being considered, was looking at reappointment, I think that she--I
think that she began to reflect on the President's merits and he began
to reflect on her merits, and I think there was a more of a bond
developed.
That is what I said and what I know.
EXAMINATION BY MS. COMSTOCK:
Question. You said they previously had spoken through
intermediaries. Did you have any knowledge as to who those
intermediaries were?
Answer. Yes, only insofar as we are talking about crime issues,
public policy issues. And in that interface, it was usually through
Rahm Emanuel----
Question. But in terms of these investigations, you don't know of
any intermediaries speaking with the President on Ms. Reno's behalf?
Answer. No. Correct. You have to understand that I kept as far
away, not just from fund-raising, but from the whole issue of
Whitewater and scandals, as I possibly could in the White House. I used
to tell people my job is to man the pump and engines, not to repair the
hole in the bottom of the boat.
Question. Earlier you appeared on Fox News where you had discussed
polling. You said your polling shows that this fund-raising scandal
doesn't make any difference about how people feel about the President.
Are you conducting polling for the President or for the DNC on any
of these matters?
Answer. No.
Question. What type of polling was that that you were referring to?
Answer. Since I left the White House, I have made it a practice on
six or seven occasions to do polling at my own expense on my own to get
data which I then use in my public comments on radio, TV, and in print.
Shortly after the, in fact, the day after the Woodward story broke in
the Post about first suggesting that there was an organized effort by
the Chinese government to influence American politics and to funnel
money to politicians, including the President, I polled that and I
asked people if it made a difference to them, if it made them more or
less likely to support Clinton and all of my usual way of examining
that. And I found that the majority said it made no difference and that
the people that said it made them less likely to vote for or support
Clinton, were people that were against him before they were asked that
question.
So on that basis, I was on the McLaughlin TV program that weekend,
and I quoted that information, and indeed gave it out over the air. I
sent a copy of that information to the President, and I have sent
copies of all my polls to the President, but he has neither authorized
the polling nor reviewed the questions nor asked me to poll nor paid
for it. I just pay for it out of my own pocket.
Question. And have you discussed these with the President at all?
Mr. Ballen. I object. I think this is really very far afield, what
his discussions now are with the President about polling, about----
Ms. Comstock. The issues that are raised in terms of fund-raising
matters.
The Witness. I think I may have called his attention to that
particular piece of data verbally.
EXAMINATION BY MS. COMSTOCK:
Question. I think in this same Fox News Sunday show, March 2nd,
1997, you were discussing Vice President Gore's phone calls. I believe
you indicated that you did know that the Vice President was making
phone calls.
Do you recall when you became aware that the Vice President was
making phone calls for the DNC?
Answer. Well----
Question. For fund-raising?
Answer. In the show I indicated that I knew that the Vice President
was making phone calls, but that I did not know from where he was
making the calls, because the issue at that time was not that he was
making the calls, but that he was making them from his office. I said I
don't know where he made them from.
The way I came into knowledge about it was that at some point, and
I can't be very precise about the time, I was talking to either Bob
Squier or Ron Klain or Jack Quinn, I can't recall who I was talking to,
but those would be the people who would have been one of that cast of
characters, and one of them mentioned to me that the Vice President was
working very hard at raising money, making all of these phone calls,
and he felt the President really wasn't working as hard as he needed to
work and wasn't making phone calls. And he indicated the Vice President
had a certain amount of resentment, that he was doing his job and the
President was not aggressively working on raising money, on making
phone calls. And I replied that the President never--that as Governor,
Bill Clinton hated making fund-raising calls, and it was pulling teeth
to get him to do it, and that was a casual conversation and that is
what I related on Fox News.
Question. I am showing the witness DNC 3234267, a document, a memo
of November 20, 1995, to Harold Ickes from Don Fowler, Marvin Rosen,
Scott Pastrick, and Richard Sullivan, regarding additional DNC fund-
raising requests. It references 18 to 20 phone calls by the President
were needed and 10 calls by the Vice President. This was a proposal
apparently submitted by Mr. Fowler, et al.
Answer. I have read the document.
Question. Had you seen this document?
Answer. No.
Question. Were you aware of efforts, from the conversation you had
with Mr. Klain, was it, did you----
Mr. Ballen. He said he wasn't sure who it was with.
The Witness. It was one of three or four people.
EXAMINATION BY MS. COMSTOCK:
Question. From this conversation, was it your understanding that
the President had been asked and had agreed to do some fund-raising
calls? Or hadn't? But hadn't been living up to that agreement?
Answer. I don't know whether he had agreed to make them and had not
made them, or if he simply had not made them. The purport of the
comment that was made by Klain or whoever was that he was not making
the calls, whether it was things he agreed to do or not, I don't know.
This is the first I have heard of this--first I have seen of this memo
or the first I have known of any of the substance it contains.
Question. You were not aware of any calls or anything like that
that were ever provided to the President?
Answer. That is correct.
Question. In your book you discuss conversations you had with the
President about how much fund-raising he had to do and how unpleasant
this was for him. Aside from those conversations that you recounted in
your book, did the President ever discuss with you in general what he
was doing to raise money?
Answer. Yes. He was constantly complaining about the amount of his
time that had to be spent on fund-raising and the physical strain that
it took on him, but I always had the impression that those complaints
related to his physical appearance at fund-raisers. It was a grueling
task. The fund-raisers, I went to six or seven fund-raisers, always as
a donor paying my own way, and I used to use it as an opportunity to
introduce family members of mine to the President and kind of, you
know, make up for some of the absences that I was going through. And I
would always make a point of going after the paying customers, the ones
who were really major donors who had shaken his hand.
What would happen, there would be an event, he would come in, and
then the guy would stand there for 3 or 4 hours, standing, posing for
pictures and shaking hands with each person as they walked through.
And I would--at one event--I live in Stanford, Connecticut--I
decided I would stand just as long as he was standing so I could have
some appreciation of what he was going through. And I wanted to lean
against the wall. I wanted to sit down. I was going crazy. And when I
came up to him, I said, your feet must be killing you. And he said, I
hate it. I just hate it. I have to stand here.
And a lot of times he would complain. He would say, I haven't slept
in 3 days; every time I turn around they want me to be at a fund-
raiser. At one point I quote in the book he said, you want me to issue
these executive orders, I cannot think, I cannot act, I can't do
anything; every minute of my time is spent at these fund-raisers.
But I didn't have the impression, do not have the impression, he
was complaining about phone calls. He was complaining about the number
of fund-raising events and the physical wear it took on him.
Ms. Comstock. I am going to go ahead and make this document
Deposition Exhibit Number 5.
[Morris Deposition Exhibit No. 5 was marked for identification.]
EXAMINATION BY MS. COMSTOCK:
Question. Were you aware of events at the White House, the White
House coffees that have been generally referred to now?
Answer. Not at the time. Only subsequently in reading about them.
Question. You have no knowledge other than the public accounting
that has come out in the past few months?
Answer. That is right. The only connection I had with those kinds
of private raisers, the seven or eight fund-raisers I attended were all
large ticket public events, $1,000 a head events with hundreds and
thousands of people in the room. In fact, one of the reasons I went, in
addition to the opportunity to introduce members of my family to him,
was that I would, after I became well-known, I would walk up and down
the receiving line and just thank everybody for their help and shake
hands and stuff.
The only times that I was ever involved in small--that I have any
knowledge at all of these small fund-raisers, was two or three
occasions I would stop by a fund-raiser he was having at a hotel and
just pass a note in to him through the Secret Service, because he
wouldn't get home until late at night and I didn't want to have him
call me at 1 o'clock in the morning so I passed him the note that
evening so I wouldn't have to bother him.
Question. Were these fund-raisers at the Jefferson Hotel?
Answer. One or two at the Jefferson, one or two at the Hay-Adams. I
was never in the room. I passed it through the Secret Service.
Question. Do you have any idea who these small fund-raisers were
with?
Answer. No.
Question. Did you ever attend the President's birthday party fund-
raising events?
Answer. Yes, I attended his 50th birthday party fund-raiser.
Question. Would that have been last year, in '96?
Answer. Yes.
Question. Were you aware of Johnny Chung being a sponsor of that
event?
Answer. No.
Question. Have you ever met Johnny Chung?
Answer. No.
Question. Do you know anything about Johnny Chung's fund-raising?
Answer. No.
Question. Or frequent visits to the White House?
Answer. Nothing.
Question. Did you have much contact with the First Lady's office
when you were----
Answer. Yes.
Question [continuing]. Working for the Clinton/Gore campaign?
Answer. Yes.
Question. And what kind of contact was that?
Answer. I met with the First Lady subsequent to June of 1995. I met
with the First Lady about every 2 or 3 weeks to give her political
briefings. Maggie Williams was occasionally there, Melanne Verveer was
more often there, and usually Mark Penn was there with me. Since she
didn't attend the strategy meetings, I would summarize what we were
thinking and what we were planning for the campaign.
I also would give her personal recommendations as to things that I
thought she should do, issues I thought she should talk out about, and
advice on public policy positions that she should take. I worked
extensively with her staff to work on getting her speeches down and her
rhetoric down on public policy.
I never participated in any advice sessions concerning her handling
of any of the scandal issues, her testimony or anything like that.
Question. Did you ever hear from anyone, were you aware of her
participation in fund-raising events at the White House, lunches or
coffees or anything like that?
Answer. No.
Question. Did you ever hear from any of her staff about whether it
was Johnny Chung, or if he didn't have a name identified with it,
somebody who was making--coming by frequently----
Answer. No.
Question [continuing]. And making a nuisance of himself in any way?
Answer. No. The only indication I had that she was doing fund-
raising actually was the passage I quote in the book, the President
after he said he couldn't think and spend time, he said, Hillary can't,
Al can't, none of us can. And I was surprised when he said it, because
it hadn't occurred to me she was spending a lot of time on fund-
raising.
Question. I wanted to show the witness another document dated
December 20, 1995, DNC 3234272, a memo to Harold Ickes and Karen Hancox
from Marvin Rosen and Richard Sullivan regarding DNC finance update.
Again, this goes through some of the money that needs to be raised by
the end of the year, apparently.
I guess directing your attention to Terry McAuliffe and it
discusses received from labor on Thursday re Terry McAuliffe.
Were you aware of Terry McAuliffe doing any fund-raising from the
labor groups for the $10 million media fund you were trying to get
raised in the fall of 1995?
Answer. Not particularly from labor. I was of the opinion that
McAuliffe was the President's best fund-raiser, and I thought it was
silly that he was spending his time raising money for Clinton/Gore when
we wouldn't be spending Clinton/Gore money until later in the process;
that in 1995 the major need was for money at the DNC in order to pay
for the media and the other expenses that were being incurred then.
I remember mentioning to the President that it would be good--I
thought it was silly for McAuliffe to be concentrating his energies on
Clinton/Gore when he should be concentrating them on the DNC. And I had
that conversation with the President sometime around October. That is
the only knowledge I have had of McAuliffe being involved and not with
the DNC.
Question. And what did the President say?
Answer. He didn't comment. He just heard it.
Question. Directing your attention to the Vice President calls, it
indicates received to date at this time were $195,000 from the calls
and commitments from the Vice President; calls that had not yet been
collected at that time were approximately $65,000.
Do you recall ever hearing about a figure that the Vice President
raised in terms of money?
Answer. No.
Mr. Ballen. I want to point out for the record the witness
testified numerous times he wasn't involved with fund-raising and
didn't know about fund-raising. In the interest of his schedule and
everyone's schedule----
Ms. Comstock. I will make this Deposition Exhibit Number 6.
[Morris Deposition Exhibit No. 6 was marked for identification.]
EXAMINATION BY MS. COMSTOCK:
Question. Were you aware of the Lincoln bedroom being used as a
fund-raising opportunity----
Answer. Not until I read about it.
Question. You have made comments regarding that.
I show the witness a February 27th, 1997, NBC news report by Jim
Miklaszewski, M-I-K-L-A-S-Z-E-W-S-K-I. Directing your attention to the
second page, you are quoted as saying, ``I am surprised he didn't
auction off places in his own bedroom. He would probably sleep on the
floor if someone would give him a million.''
Answer. That was a joke.
Question. Did you ever talk to the President about those comments
or anything about them?
Answer. No.
Question. Did you ever spend the night at the Lincoln bedroom?
Answer. No.
Question. Or any of the bedrooms in the residence?
Answer. No. I was having problems enough in my nights at the
Jefferson.
Question. You have no knowledge--do you have any knowledge of
donors or people, large dollar donors who being at the White House,
regardless of whether you knew they were any kind of entrance fee or
payment?
Answer. None, none, none.
Ms. Comstock. I will make that Deposition Exhibit Number 7.
[Morris Deposition Exhibit No. 7 was marked for identification.]
EXAMINATION BY MS. COMSTOCK:
Question. Can you describe George Stephanopoulos' role in the work
you did while you were working with the Clinton/Gore campaign and the
DNC?
Answer. There were essentially four operations with which I was
involved that were relatively discrete operations that were part of the
message, getting the President's message across, which was my mandate.
One was paid media, which Bill Knapp was the sort of COO of, chief
operating officer. The other was the President's speeches, which Don
Baer was in charge of. The third was rapid response, which
Stephanopoulos was in charge of. And then the fourth, which was outside
of any jurisdiction of mine and I never was involved in, was Whitewater
response, which Ickes and a variety of other people were in charge of.
So Stephanopoulos was essentially the person who was in charge of
rapid response. The President had given him that task. And what that
meant was that when the Republicans did anything, he would orchestrate
the rebuttal, the reply, the answer, to feeding their attacks on a day-
by-day basis.
In addition to that, Stephanopoulos was in charge of coordinating
the activities of the government so that they went toward the
substantive agenda the President had in mind. So he was the one that
would sort of send the President's line out and make sure that
everybody was echoing it, that everybody was on the same page. And when
somebody was off the page or said something that the President would
not have wanted them to say, they would get a call from George and he
would urge them to take a different approach in public.
Question. Do you know----
Answer. He also was the fact checker on our ads and he also worked
very closely on all aspects of the positioning that the President took
on substantive issues.
Question. Do you know anything about his roles that would have him
in contact with somebody like John Chung for any reason?
Answer. I have no idea.
Question. Do you know anything he was working on matters related to
China?
Answer. No.
Question. Did there come a time when Mr. Stephanopoulos told you
about the discovery of life on Mars?
Answer. Yes.
Question. You are recounted that incident in your book?
Answer. Yes.
Question. Did he ever mention anything to you about this being
classified information or that it couldn't be shared with anybody?
Answer. No. He told me that he wanted it to be kept secret so that
it would not be released to the public until the start of the
Republican Convention, and his thought had been that the story would
break on Monday of the Republican Convention and would drown out
coverage of the convention. But he cast that in a political context,
not in a national security context.
Question. So he never told you that any of that information was
classified?
Answer. No. He also was aware that I had no security clearance nor
had I sought it, even the lowest level, and I would doubt--and I
doubted that he would ever share with me classified information,
because it would be illegal, so I inferred that this was not
classified.
Question. After this became public that he had discussed this with
you, did anyone ever raise this issue with you from the White House?
Mr. Lenefsky. What is the relevance of this?
Ms. Comstock. National security issues.
Mr. Lenefsky. Is that within the purview?
Ms. Comstock. It actually is. National security.
Mr. Ballen. I join in counsel's objection.
The Witness. The generic answer is I never had access to national
security information that I knew was national security. The President
never shared classified information with me, and I never, as I sit here
now, I do not know that I ever was in possession of national security
information.
EXAMINATION BY MS. COMSTOCK:
Question. But it was clear to everybody at the White House that you
had not had a clearance, you had not ever gone through anything.
Answer. Correct.
Question. There was no reason for anyone to think you had a
clearance?
Answer. That is correct.
Mr. Ballen. I may want to note on the record that life on Mars has
nothing to do with national security.
The Witness. It depends on what it is.
Mr. Ballen. One cell life.
EXAMINATION BY MS. COMSTOCK:
Question. Do you recall raising issues about Mr. Penn's work for
foreign--on foreign elections?
Answer. Yes.
Question. Can you describe what issues you raised and why you had
concerns about that?
Answer. It arose in two contexts. One was that I was requested to
make a public disclosure of my income sources and my assets and
clients, and that request, to my knowledge, was also addressed to the
other consultants who worked with me. I had an extensive discussion
with Mr. Penn about his compliance with that directive, and he
indicated to me that he was working for a candidate in Turkey and that
the terms of his arrangement were such that the relationship had to be
secret while the election was going on and that the election was being
held in the third week of December of 1995, and that therefore he would
rather that he not make his disclosure until after that date, where he
would disclose the Turkish relationship, but it was subsequent to the
Turkish election and therefore would not be embarrassing to his
candidate in Turkey. I told him I thought that was okay.
Secondly----
Question. Who was that candidate?
Answer. The woman in Turkey. I forgot her name.
Then secondly, in September or October of '95, he took a walk-in
closet in Doug Sosnik's office, which was a political office, and
converted it into an office space for him, and he told me that he had
brought in the campaign computer and the campaign-dedicated phone line
and had had it installed in that walk-in closet and made it a little
office for himself.
I was concerned about his having an office in the White House for a
variety of reasons. I felt it was a bad idea. I told the President that
I thought it was a bad idea because he had conflicts of interest in
terms of his commercial clientele and his foreign clients, and I
particularly cited his work for ATT and his work in the Turkish
elections.
Since the political office was right next to the communications
office and those issues were being reviewed in the communications
office, I thought that it was inappropriate for him to have an office
in the White House.
The reason I raised it with the President was I knew Penn would not
like my telling him he had to close his office, and I wanted to be
certain I had the support of the President in doing that. The President
told me that he supported me. I asked Penn to remove himself from the
office and he did.
Question. Did Mr. Penn have a White House pass at that time?
Answer. Not to my knowledge.
Ms. Comstock. If I could take a brief 5 minutes here and see if we
are close to wrapping up.
[Brief Recess.]
EXAMINATION BY MS. COMSTOCK:
Question. You know Susan Thomases, is that correct?
Answer. Yes.
Question. And how long have you known Ms. Thomases?
Answer. Since the early '80s.
Question. And do you have any knowledge about any work that Susan
Thomases did for the Lippo Group or the Riadys?
Answer. No.
Question. And do you know Webster Hubbell?
Answer. Yes.
Question. How long have you known Mr. Hubbell?
Answer. I just met him once, and have never spoken with him, other
than at a White House reception a few weeks after he resigned.
Question. Did you ever talk to anybody at the White House about Mr.
Hubbell's legal problems?
Answer. No.
Question. Did you ever----
Answer. Yes, I did. I met with the President sometime in--this is
before I worked there regularly, but I met with the President at some
point before Hubbell resigned, I met with the President and the First
Lady, and I urged them to fire Hubbell, Kennedy, Altman----
Mr. Ballen. Excuse me?
The Witness. Altman. This was after Nussbaum had left. I urged him
to fire Kennedy, Altman, and Hubbell, and I said rather than doing this
piece by piece, get rid of them all so that you don't--so that you can
stay ahead of the investigation. Don't do what Nixon did and wait until
they come to your door with each individual one, because you will
suffer 20 times more.
He rather heatedly replied that he wasn't going to ruin people's
reputations by getting rid of them when they had done nothing wrong,
and this was a witch hunt, and why did I think that he was prepared to
injure people and wound them and destroy their reputations to save his
skin from some bad publicity, when there was nothing there and they had
done nothing wrong.
Question. Did you have any other discussions about Mr. Hubbell at
any later date after he had pled guilty?
Answer. No.
Question. Were you aware of anyone at the White House assisting Mr.
Hubbell with finding work after he left the Justice Department?
Answer. No.
Question. Regarding the----
Answer. When I say ``no'' to any of these, it means other than what
I have read in the paper.
Question. I understand that, and I hope that is clear for the
record. I am after your personal knowledge, or if you have other
knowledge, to tell us it is only from newspaper accounts.
Regarding the issue of whether or not Webb Hubbell was paid sort of
what was generically referred to as hush money, you made the statement
in reference to the President saying he is too much into denial on one
hand and too much of an ingrate on the other.
What did you mean by that?
Answer. That the President, that I doubted seriously that the
President was involved in any payment of hush money to Hubbell; that it
is not his style. On the one hand, he never believes that he has done
anything wrong, and he is constantly of the opinion that he has always
acted properly. Because that is always his opinion and everybody
doesn't always act properly, I have to believe there is a certain
amount of denial involved.
Secondly, I have always felt that he is a bit of an ingrate, that
when people work hard for him and help him and they finish their
usefulness to them, he basically does not feel personally obligated, he
feels that they are helping the country and they are doing their civic
duty, and other than a sort of polite thank you, there is no great
sense of personal obligation.
So I summarized it pithily in that statement. I felt that hush
money requires a certain guilty conscience that the President never
has.
Question. Are you aware--there have been reports, and the committee
has received documentation indicating that Mr. Hubbell was receiving
quite a large amount of money in 1994 from various sources. Did you
have any knowledge of this in 1994 or '95?
Answer. No, none.
Question. Do you know of any other--you spoke of the President
often didn't treat people well after they had left. Do you know of any
other people who kind of got this kind of treatment, from all the
President's friends getting jobs and things like that?
Answer. Yes--oh, that was given good treatment or bad treatment?
Question. Good treatment.
Answer. No.
Question. In terms of being hired----
Mr. Ballen. Excuse me, I am going to object to that question. You
are assuming a fact not in evidence. Mr. Hubbell got good treatment by
the President? We don't know that and the witness doesn't know that.
The Witness. In any case, I don't know.
EXAMINATION BY MS. COMSTOCK:
Question. Have any of the President's friends, when you left in
August, did they come and offer you consulting contracts?
Answer. No.
Question. Or offer to give you----
Answer. No.
Question [continuing]. Jobs?
Answer. No. I might just indicate I know several examples of people
who were very intimately involved with all of the President's affairs
who, when they left their employ, couldn't get the right time of day
from him. And quite the opposite of hush money, I felt that there was a
tremendous amount of ingratitude in the way he dealt with them.
Betsy Wright, David Watkins, David Gergen, are all good examples of
that. And I was, frankly, shocked at the callousness with which the
President treated Betsy Wright and David Watkins after I personally
witnessed 15 years of the most loyal kind of help of him by them.
Betsy Wright probably knew everything that the President did during
the period he was Governor. If there was anything he was trying to hide
or use hush money to hide, she would be a pretty good candidate for
recipient of hush money.
Not only wasn't she getting hush money, she couldn't talk to him.
He was never returning her calls, he wouldn't see her, she wasn't
invited to the White House social events.
Question. Do you think Mr. Hubbell was being treated like Betsy
Wright or David Watkins?
Answer. I never knew Hubbell. I know Betsy Wright and David Watkins
were considered good friends.
Question. Have you ever talked to the President about how he
treated David Watkins or Betsy Wright?
Answer. Betsy Wright, frequently. I would always say she treated
you incredibly, and you will not give her the right time of day. He
would say, I will call her, and he never would. It caused Betsy a great
deal of personal agony.
Question. In your book, revisiting a little bit the ad campaign,
you wrote on page 144 that ``the President became the day-to-day
operational director of our TV ad campaign. He worked over every
script, watched each ad, ordered changes in every visual presentation,
and decided which ads would run and where.''
Do you recall discussing with the President the particular markets
where ads would run?
Answer. Yes. I outlined earlier the process of his control over
content in the media and the fact that he had tremendous input, but
ultimately never saw the final ads before they ran, even though they
changed significantly.
In terms of the time-buy, he was always shown the time-buy, he
reviewed it, and he would occasionally ask for specific changes, some
of which I thought made no sense, but he wanted to do them and we went
and did them.
But as I said, while his inputs on this matter as well as the
content of the ads was significant, he was really the first among
equals in terms of the approval process.
In terms of the actual formulation of the advertisement, he had a
much smaller role than any of the consultants did, and in terms of the
allocation of where the money was spent, he had a much smaller role
than Mark Penn or Doug Sosnik, who really were more effectively in
charge of that.
Question. I am showing the witness a document from the DNC, 309623
through 38, which is Squier Knapp DNC media buys. As you review that
document, you mentioned the President reviewed these often. Are these
backward checks on these, are those checks that you recognize as the
President's check mark?
Answer. It is clearly by a lefty. The President's check marks
usually have a sharp downward check and then a check like that. These
seem to be just like that. The President's check marks are usually
down, ``boom.'' I don't think translates well. They are usually down
and diagonally up to the upper left. So I would not conclude from this
that these are necessarily his check marks.
Question. Do you know somebody else reviewing the media buys who is
a lefty that made the kind of checks?
Mr. Ballen. I object.
The Witness. I don't know if anyone else is left-handed, no.
EXAMINATION BY MS. COMSTOCK:
Question. These are not your checks?
Answer. No. But I have testified that it was routine for the
President to review the time-buys.
Ms. Comstock. I would like to make that Deposition Exhibit Number
8.
[Morris Deposition Exhibit No. 8 was marked for identification.]
EXAMINATION BY MS. COMSTOCK:
Question. Do you have any knowledge of how the President's legal
defense fund was being handled? Did you ever have any discussions with
anybody about that?
Answer. None whatsoever.
Question. I believe there have been news reports that some of the
phone records from your hotel showed you calling Bob Bennett.
Mr. Lenefsky. What was the name?
Ms. Comstock. Bob Bennett, the President's attorney.
EXAMINATION BY MS. COMSTOCK:
Question. Did you ever talk with him about legal defense fund or
any matters related to the President's defense?
Answer. Not the legal defense fund. I did speak to him about the
Paula Jones case.
Mr. Ballen. I object to any questions in that regard on relevancy
grounds.
EXAMINATION BY MS. COMSTOCK:
Question. Did you talk with him about--is that the only matter you
talked with Mr. Bennett about?
Answer. I think it would be better if you asked me what I did talk
with Mr. Bennett about. Again, not an open-ended question.
Question. If you can just tell us----
Answer. I did not speak to Mr. Bennett about anything related to
fund-raising, the fund-raising investigation, fund expenditures.
Question. Actually I am more interested in the President's legal
defense fund.
Answer. No.
Question. And what did you speak with Mr. Bennett about, then?
Mr. Lenefsky. I am going to object.
The Witness. I did not.
EXAMINATION BY MS. COMSTOCK:
Question. You did not. Aside from the Paula Jones matter, were
there other matters you discussed with Mr. Bennett?
Answer. Yes.
Mr. Lenefsky. Mr. Morris said he would answer questions perhaps if
you identify a subject matter of discussion between he and Mr. Bennett.
Mr. Ballen. Excuse me----
EXAMINATION BY MS. COMSTOCK:
Question. Aside from the Paula Jones matter and any allegations
regarding the President and First Lady, did you ever talk with Mr.
Bennett about that?
Mr. Ballen. Excuse me. The witness was in the middle of the
sentence when counsel asked a question.
Mr. Lenefsky. Let me go outside.
Mr. Ballen. Let me finish for the record. He began to state that he
did not discuss with Mr. Bennett any of the fund-raising, of campaign
fund-raising or fund expenditures. I believe he was in the middle of
completing the thought of the subject matters of these investigations.
The Witness. I would rather answer--I would rather if you asked me
did you talk to Mr. Bennett about this particular Filegate or
Whitewater or any of the specific things, I would be prepared to give
you yes or no answers to that. But I would rather not answer the open-
ended question of what did I talk to Mr. Bennett about.
EXAMINATION BY MS. COMSTOCK:
Question. Okay. Because Mr. Bennett is the President's attorney, I
on the Paula Jones matter, I am not asking you about the Paula Jones
thing, so I will just make that clear. But did you have frequent
contact with Mr. Bennett?
Answer. I met with him on two or three occasions, and I spoke with
him on eight or nine occasions.
Question. Did you speak with him on matters related to Whitewater?
Mr. Ballen. Objection. Relevancy.
Mr. Lenefsky. I would like to discuss something with my client
outside.
Ms. Comstock. Just for the record, the committee scope does include
investigations of the President and First Lady.
[Brief Recess.]
The Witness. What was your last question? I believe your last
question was did I ever speak to Mr. Bennett about Whitewater.
EXAMINATION BY MS. COMSTOCK:
Question. Yes.
Answer. The answer to that question is yes.
Question. Okay. Can you just generally tell us what you were
talking with----
Mr. Ballen. Before he answers, I am going to object to relevancy. I
do not believe Whitewater is a subject matter of this investigation in
any way, shape, or form, and I am going to renew my objection as to
relevance.
Mr. Lenefsky. Just a minute.
[Discussion off the record.]
Mr. Lenefsky. Mr. Morris will answer the question.
The Witness. The question was what--the content of the
conversation. I asked Ben if he thought that the President or Hillary
were in any trouble over Whitewater that I need to take account of in
my political consulting work, and he analyzed the situation for me and
was largely positive and reassuring on the subject and said that he did
not feel that they were in any kind of serious trouble.
EXAMINATION BY MS. COMSTOCK:
Question. Did you speak with David Kendall about this, also?
Answer. No, I have never spoken with David Kendall. I don't think I
have ever spoken with David Kendall. I don't recall.
Question. Was this a number of occasions then you spoke with Mr.
Bennett about those matters? You indicated there were a number of
conversations.
Answer. Yes. I would routinely be in touch with him whenever there
was a major new development to get his take as to whether there was
something I needed to worry about politically, and he was always, and
so far it has turned out accurate, reassuring on this subject and
positive or optimistic about whether the President or First Lady were
in any serious difficulty.
Question. Was that something you incorporated into your polling,
was that just information?
Answer. Well, if he told me he felt there was a serious chance of
something legally adverse happening to the First Lady or to the
President before the 1996 election, it would have been important for me
to develop contingency plans as to what to do. His assurance that was
unlikely satisfied me and I did not spend much time developing
contingency plans.
Question. Do you recall generally when these calls occurred?
Mr. Ballen. Excuse me. I object to this line of questioning, asking
the witness about political strategies.
The Witness. Think I have answered. They occurred while I worked
form Clinton, '95 and '96, but I don't know the dates. I mean--yes.
Mr. Lenefsky. There is no question before you.
EXAMINATION BY MS. COMSTOCK:
Question. Do you know a gentleman named Jack Palladino?
Answer. No. I think he is some way involved with the DNC, but I
don't know who or what.
Question. Do you know of any private investigators that were ever
hired to investigate any Members of Congress or anybody who was
investigating the President or First Lady?
Answer. Do I know of any private investigators that were ever hired
to do what?
Question. Who were ever hired by anyone affiliated with the Clinton
campaign or the DNC or any private friend of the President or First
Lady to investigate any Members of Congress who were conducting
investigations?
Answer. Of any Member of Congress?
Question. Of the President and First Lady.
Answer. Yes. In other words, investigate the investigators?
Question. Exactly.
Answer. No.
Question. There was testimony last month about the IGI group, Terry
Lenzner's group, investigating Senator Nichols. Did you have any
knowledge of anything like that going on in the '92 or '96 campaigns?
Answer. No. I believe I knew that Terry Lenzner was hired to do
investigative work and was serving under Ickes' direction, but I had no
idea what he was investigating.
Question. Do you know about Mr. Ickes hiring Mr. Lenzner?
Answer. I heard that he had done so. I don't know where I heard it,
but I knew that he had, and I don't know anything further about it.
Question. Do you know who you heard that from?
Answer. No. I think I may just have read it in the newspaper
earlier, while I was working there. But while I was there I knew the
name Terry Lenzner and I knew that he worked for Ickes. I don't know
how I knew it. I did know.
Question. Do you know anything----
Mr. Ballen. This is not firsthand knowledge?
The Witness. No. I have no idea what he is doing. I have never
spoken to him or anything like that.
[Discussion off the record.]
EXAMINATION BY MS. COMSTOCK:
Question. Was your understanding that Mr. Lenzner was hired in
connection with the DNC work that Mr. Ickes was overseeing?
Answer. I don't know.
Ms. Comstock. I believe that is all I have for now. Thank you.
The Witness. Thank you. Thanks very much.
EXAMINATION BY MR. BALLEN:
Question. Mr. Morris, just a few questions. I want to, first of
all, take this opportunity to thank you. Your testimony has been very
forthcoming. We appreciate your coming and taking your time from your
busy schedule. On behalf of the Minority members, we thank you for
that.
You mentioned to Representative Cummings that you offered to list
to him the Republican campaigns that you have worked on for years. I
would like to take you up on that offer, if you could go through
chronologically the significant Republican campaigns.
Answer. My memory of winners is better than losers.
Ms. Comstock. Your memory is far better than most.
The Witness. Why don't I go through winners, or people that are
serving in office.
EXAMINATION BY MR. BALLEN:
Question. That would be good.
Answer. In 1980, I worked for Paula Hawkins, Senator from Florida,
in her election as Senator from Florida. I worked for Senator Warren
Rudman from New Hampshire, Senator Paula Hawkins from Florida, and
Senator Mark Andrews from North Dakota.
In 1982, I worked for Senator Pete Wilson from California. In
1980----
Question. That is all right, the dates.
Answer. '86, I worked for Governor Arch Moore of West Virginia. In
1988, I worked for Senator Trent Lott of Mississippi, and I worked for
President Bush. In 1990, I worked for Governor William Weld of
Massachusetts, Senator Jesse Helms of North Carolina, Senator Dan Coats
of Indiana, and Senator Kay Bailey Hutchinson of Texas, and Senator
Hank Brown of Colorado.
In 1994, I worked for--I worked for no successful Republican--no, I
am sorry, 1992, no successful ones. In 1994, I worked for Governor Tom
Ridge of Pennsylvania, Governor Don Sundquist of Tennessee, Senator
Trent Lott, and Governor William Weld.
Question. Any Members of Congress? You mentioned Senators and
Governors. Any Members of Congress? I believe you testified Congressman
Jay Dickey.
Answer. Jay Dickey.
Question. Any other Members of Congress?
Answer. Congressman John Mica of Florida, who is a member of this
committee.
Mr. Lenefsky. Did you work for Ed?
The Witness. He is asking about Republicans.
Ms. Comstock. Are you only asking Republicans?
Mr. Ballen. That was my question.
Ms. Comstock. Did you work for Mr. Schumer at some point, Chuck
Schumer?
The Witness. Yes, I did, but he is only asking about Republicans.
Congressman from Louisiana, Baton Rouge, Republican Congressman from
Baton Rouge.
Ms. Comstock. Tauzin?
The Witness. No, a next-door neighbor.
Ms. Comstock. Baker?
The Witness. Richard Baker of Louisiana. That's it.
EXAMINATION BY MR. BALLEN:
Question. We have----
Answer. I am sorry, there are other Members no longer in the House.
I worked for John Ashbrook of Ohio and maybe some other Republican
House Members that are no longer serving, but I don't--that would take
a whole other time for me to think about.
Question. I don't want to take any more time. I will note for the
record we started this deposition at 9 o'clock. We are now at 3
o'clock. Most of the time you have been here you have discussed in
detail the content of, over the objections of the Democratic side, you
discussed the consent of ads that you reviewed with the President,
political strategy, the markets, where those ads were run, the time-
buys, polling, advice, considerations of political strategy, the
formulation of advertisements, where the money was spent on
advertisements, and I would assume, and correct me if I am wrong, Mr.
Morris, that with all the names that you just mentioned, Senator Lott,
Senator Coats, you also testified you consulted with Senator Gramm,
Congressman Mica, et cetera, you had similar discussions with those
candidates on their campaigns; is that correct?
Answer. That is correct. I never worked for Senator Gramm on his
own campaigns. I worked for Senator Gramm in connection with the
Republican Senate Campaign Committee.
Question. But you would have had similar conversations with Senator
Gramm concerning the work on the Senate campaign committee on how ads
were constructed, on coordination between the committee and other
groups, and other candidates, et cetera. You would have had discussions
with all of these candidates. Would that be a fair statement, sir?
Answer. Well, it is, except for when you get to the issue of
coordination. I never engaged in any campaign discussions about
coordination between expenditures of the campaign and independent
expenditures, because I know that that's illegal.
Question. And that's the same case with the President's past
campaign in 1996; is that correct?
Answer. Well, there was one occasion where there was an activity
that smacked of coordination in which I was engaged that I rejected.
There was a meeting in the Roosevelt Room----
Question. Why don't you describe that?
Answer. There was a meeting in the Roosevelt Room of the White
House, and I do not recall the date, it was late '95 or early '96, that
Mr. Ickes convened, at which he invited five or six people from the
labor movement, from the labor community. I don't recall the names of
the people, because I didn't know them, but there was somebody from
AFSCME, there was somebody there from one of the teachers' unions.
There was somebody there from COPE, C-O-P-E, the AFL, and I believe
there was somebody there from the media firm of Victor Fingerhut, F-I-
N-G-E-R-H-U-T, who does the advertising for the AFL, and I attended,
Mark Penn attended, and I believe Bill Knapp attended.
Ms. Comstock. Was the LIUNA union involved?
The Witness. What's LIUNA?
Ms. Comstock. International----
The Witness. Labors International? I don't think so.
And from the White House there was Ickes and Sosnik, and
Stephanopoulos may have been in that meeting, I'm not sure.
The purpose of the meeting was for the labor people to show us the
ads that they had run and were planning to run, and I criticized their
ads, because they failed to mention the balanced budget or tax cuts,
and I felt they relied too much on rhetoric against tax breaks for the
rich, which is something I was constantly opposed to our talking about.
They then invited me to coordinate my time-buying plan, our time-
buying plans with them on a basis where, for example, they suggested we
want to advertise in Vermont to go after Jeffords, and you don't care
about winning Vermont particularly, so why don't we take Vermont, but
you take, you know, Missouri, where it is a swing State. And I rejected
it because--first of all, I rejected it partially because I felt it was
not lawful, and, secondly, because I felt that their media was not only
not helpful to the Clinton campaign, but destructive.
I am of the opinion that at this moment the Democrats would control
the House of Representatives if the AFL-CIO never ran an ad. I believe
their advertisements had more to do with the Democrats losing Congress
in '96 than any Republican ad. And I felt that the stark left-right
comparisons that they were attempting to make were totally against the
strategy I had in mind, and in fact, I decided that when I learned that
they were advertising, I'd make a point that we would advertise to
repair the damage. But that was the only--and that meeting ended on a
rather unhappy note, because I did express my views fairly frankly, and
there was, in fact, no coordination, but that's the only time when I
have ever been in a meeting in connection with coordination.
EXAMINATION BY MR. BALLEN:
Question. And at that meeting, you rejected that firmly?
Answer. Yes.
Question. What happened as a result of your rejection?
Answer. I don't know, but I know that I was never involved, nor
were any of the consultants that worked with me to my knowledge ever
involved in any coordination with any independent expenditure,
including the AFL.
Question. So you were comfortable with the fact that you were never
involved or anyone you were in contact with was involved with any
coordination with the AFL or any other group like that?
Answer. That's right. That's correct.
Question. And no one asked you to coordinate at any time subsequent
to that meeting?
Answer. That's correct.
Question. So back----
Answer. And it should be noted that the request for coordination
did not come from Mr. Ickes, it came from someone from the labor
community.
Question. And you rejected it?
Answer. Yes.
Ms. Comstock. What was Mr. Ickes' response.
The Witness. I don't believe he had one. The minute they mentioned
it, I jumped all over it, because I hated the ads.
EXAMINATION BY MR. BALLEN:
Question. And that was the end of it as far as you knew?
Answer. Yes.
Question. But back to, let me just review and then I think you
already answered the question, but the kinds of issues that you
discussed at great length today about assistance and advise that you
gave the President in the 1996 campaign, you could also discuss with
all the other people that you represented in varying degrees over the
years; isn't that correct?
Answer. That's correct.
Question. There is nothing particularly--I mean, there may be
unique features to the President's campaign, but there is nothing
particularly unique about the kinds of issues or strategy or ad
concerns or other things that you discussed; is that correct?
So if you were asked--let me finish this. If you were asked at a
future date to describe what ads were run for Senator Lott or what ads
might have been run for Senator Coats or what discussions you may or
may not have had with Senator Coats or Senator Lott, you could answer
those questions?
Answer. Yes, I could. The only unique feature of the Clinton
campaign was that I never previously worked on an issue advocacy
advertising campaign for a national committee.
Question. All right. And you have already testified in length as to
that?
Answer. Yes.
Mr. Ballen. Thank you very much.
Ms. Comstock. I just have a few follow-up questions.
EXAMINATION BY MS. COMSTOCK:
Question. In any of those other campaigns that you were talking
about, were you aware of millions of dollars being returned after you
had worked on the campaign?
Mr. Ballen. I am going to object because he has testified he wasn't
involved in fund-raising.
Ms. Comstock. I am just saying if he is aware or any knowledge, or
learned from it.
Mr. Ballen. From reading the newspapers?
Ms. Comstock. Exactly. If he was aware of millions of dollars of
campaign contributions----
Mr. Ballen. Well, you can ask him about anything in the newspapers,
if he has personal knowledge.
The Witness. I have no knowledge of millions of dollars being
returned.
EXAMINATION BY MS. COMSTOCK:
Question. On the meeting that you talked about with Harold Ickes,
the labor meeting, was it your understanding that Harold Ickes set up
that meeting?
Answer. Yes.
Question. And do you recall who asked you to come to the meeting?
Answer. No. I mean, someone on Ickes' staff told someone on my
staff that I had to come. It was not Harold who personally invited me,
but I don't know who from their staff spoke to who on my staff. I just
was told by someone on my staff that Ickes wanted me at this meeting.
Question. Who usually invited you? I mean, who from Ickes' staff
contacted your staff when he invited you to meetings?
Answer. He very rarely did, but when he did, it was usually Janice
Enright.
Question. And she would contact one of your assistants?
Answer. Yes.
Question. And you had previously testified that usually you tried
to avoid each other, essentially?
Answer. Yes. We communicated with each other chiefly through leaks.
Question. Are you aware of Mr. Ickes working with any voter
participation groups?
Answer. Not specifically, but I--that would have fallen within his
mandate.
Question. Do you have any knowledge of him--do you know anyone
named Gary Barron?
Answer. No.
Question. Did you have any knowledge, prior to the news reports,
about the situation with Warren Meddoff receiving the fax from Mr.
Ickes asking for contributions to a number of groups, including Vote
Now and an antiproposition 209 group? Did you have any knowledge about
those events prior to the news reports?
Answer. No.
Question. Okay. Have you learned of anything about--since the news
reports or through any source about Mr. Ickes coordinating with any of
these voter participation groups?
Answer. No.
Question. Do you know how he would have gotten their bank account
numbers or have any of that type of information?
Answer. No.
Question. In your book, you described the President is very hands-
on and very involved in his re-election campaign. Is that a fair
characterization of his participation?
Answer. Yes.
Question. And is very detail oriented and attentive to a lot of the
things that you were working on?
Answer. Yes.
Question. And very interested in what you were working on?
Answer. Yes.
Question. And wanted to know on a day-to-day basis what it was that
you were working on, or week-to-week?
Answer. Yes.
Question. Was that your understanding of how he dealt with Mr.
Ickes, also?
Mr. Lenefsky. If you know.
The Witness. I was not really privy to his discussions with Ickes,
so I really can't comment on--I can't comment on that.
EXAMINATION BY MS. COMSTOCK:
Question. From your discussions with the President, did you have a
sense of how often the President spoke with Harold Ickes?
Answer. Whenever I was--yes, I had the sense, both from personal
observation and from times that I would call Ickes' office and learn
that he wasn't there, that he saw the President at least every day and
usually very frequently throughout the day.
Question. Did he often travel with the President during the
campaign?
Answer. Yes.
Question. And did you have one of your assistants traveling with
the President also during the campaign?
Answer. On political trips only paid for by the Clinton/Gore
campaign. I was not permitted to have anyone travel on official trips,
and where the trip was funded by the DNC, I was also generally not
permitted to have someone there.
Question. Was that Tom Freedman who usually went on those trips?
Answer. Tom Freedman most often. Sometimes Mark Penn.
Question. Did either Tom Freedman or Mark Penn ever tell you about
donors flying on Air Force One or anything to that effect?
Answer. No. I never flew on Air Force One.
Question. All right.
Again, you were describing that the President was very involved in
the details. I was wondering, do you have any reason to believe that
the President has any memory problems or any problem with recalling
events?
Mr. Ballen. I am going to object to that kind of a question.
Mr. Lenefsky. I will object, also.
EXAMINATION BY MS. COMSTOCK:
Question. From your experience of knowing the President for over 20
years, does he have a good memory?
Answer. Yes.
Ms. Comstock. I believe that's all I have today. Thank you for your
time.
[Whereupon, at 3:15 p.m., the deposition was concluded.]
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[The deposition of Eric Sildon follows:]
Executive Session
Committee on Government Reform and Oversight,
U.S. House of Representatives,
Washington, DC.
DEPOSITION OF: ERIC SILDON
Tuesday, July 29, 1997
The deposition in the above matter was held in Room 2203, Rayburn
House Office Building, commencing at 10:00 a.m..
Appearances:
Staff Present for the Government Reform and Oversight Committee:
James C. Wilson, Senior Investigative Counsel; Miki White,
Investigative Counsel; Maria Wusinich Intern; Kenneth Ballen, Minority
Chief Investigative Counsel; and Christopher Lu, Minority Counsel.
For MR. SILDON:
JUDAH BEST, ESQ.
DeBevoise & Plimpton
Attorneys at Law
555 13th Street, N.W., Suite 110 E
Washington, D.C. 20004
Mr. Wilson. Good morning. On behalf of the Committee on Government
Reform and Oversight, I appreciate and thank you very much for coming
here today.
This proceeding is known as a deposition. The person transcribing
this proceeding is a House reporter and notary public. I will now
request that the reporter place you under oath.
THEREUPON, ERIC SILDON, a witness, was called for examination, and
after having been first duly sworn, was examined and testified as
follows:
Mr. Wilson. I would like to note for the record that those who are
present at the beginning of this deposition are James Wilson, the
designated Majority Counsel for the committee. I am accompanied by Miki
White and Maria Wusinich, who are both with the Majority staff.
Christopher Lu is the designated Minority counsel for the
committee, and the deponent is represented by Mr. Judah Best.
Although this proceeding is being held in a somewhat informal
atmosphere, because you have been placed under oath, your testimony
here today has the same force and effect as if you were testifying
before the committee or in a courtroom.
If I ask you about conversations you have had in the past and you
are unable to recall the exact words in the conversation, you may state
that you are unable to recall those exact words, and then you may give
me the gist or substance of any such conversation to the best of your
recollection.
If you recall only a part of the conversation or only part of an
event, please give me your best recollection of those events or parts
of conversations that you recall.
If I ask you whether you have any information upon a particular
subject and you have overheard other persons conversing with each other
regarding it or have seen correspondence or documentation regarding it,
please tell me that you do have such information and indicate the
source, either a conversation or documentation or otherwise, from which
you derived such knowledge.
Before I begin the questioning, I want to give you some background
about the investigation and your appearance here.
Pursuant to its authority under House Rules 10 and 11 of the House
of Representatives, the committee is engaged in a wide-ranging review
of possible political fund-raising improprieties and possible
violations of law. Pages 2 through 4 of House Report 105-139, a copy of
which you have received, summarizes the investigation as of June 19,
1997, and encompasses any new matters which arise directly or
indirectly in the course of the investigation.
Also, pages 4 through 11 of the report explain the background of
the investigation. All questions related either directly or indirectly
to these issues or questions which have the tendency to make the
existence of a pertinent fact more or less probable than it would be
without the evidence, are proper.
The committee has been granted specific authorization to conduct
this deposition pursuant to House Resolution 167, which passed the full
House on June 20, 1997. Committee Rule 20, of which you have received a
copy, outlines the ground rules for the deposition.
Majority and Minority counsel will ask you questions regarding the
subject of this investigation. Minority counsel will ask questions
after Majority counsel has finished.
After the Minority counsel has completed questioning you, a new
round of questioning may begin. Members of Congress who wish to ask
questions will be afforded an immediate opportunity to ask their
questions. When they are finished, committee counsel will resume
questioning.
Pursuant to the committee's rules, you are allowed to have an
attorney present to advise you of your rights. Any objection raised
during the course of the deposition shall be stated for the record. If
the witness is instructed not to answer a question or otherwise refuses
to answer a question, Majority and Minority counsel will confer to
determine whether the objection is proper.
If Majority and Minority counsels agree that a question is proper,
the witness will be asked to answer the question. If an objection is
not withdrawn, the Chairman or a Member designated by the Chairman may
decide whether the objection is proper.
The deposition will be held open subject to rescheduling for the
purpose of resolving any disputed issue.
This deposition is considered as taken in executive session of the
committee, which means it may not be made public without the consent of
the committee, pursuant to clause 2(k)(7) of House Rule XI.
You are asked to abide by the Rules of the House and not discuss
with anyone, other than your attorney, this deposition and the issues
and questions raised during this proceeding.
Finally, no later than 5 days after your testimony is transcribed
and you have been notified that your transcript is available, you may
submit suggested changes to the Chairman. The transcript will be
available for your review at the committee offices. Committee staff may
make any typographical and technical changes requested by you.
Substantive changes, modifications, clarifications or amendments to
the deposition transcript submitted by you must be accompanied by a
letter requesting the changes and a statement of your reasons for each
proposed change.
A letter requesting any substantive changes, modifications,
clarifications or amendments must be signed by you. Any substantive
changes, modifications, clarifications or amendments shall be included
as an appendix to the transcript, conditioned upon your signing of the
transcript.
Do you understand everything we have gone over so far?
The Witness. I do.
The Wilson. Do you have any questions about anything we have gone
over so far?
The Witness. No.
Mr. Wilson. I am prepared to begin asking some preliminary
questions. Do you have any initial comments?
Mr. Lu. No, not at this time.
Mr. Wilson. I will be asking you questions concerning the subject
matter of this investigation. Do you understand?
The Witness. Yes.
Mr. Wilson. If you don't understand a question, please say so and I
will repeat it or rephrase it so that you do understand the question.
Do you understand that you should tell me if you do not understand the
question?
The Witness. I do understand.
Mr. Wilson. The reporter will be taking down everything we say and
will make a written record of the deposition. Please give verbal,
audible answers in that the reporter cannot record what a nod of the
head or a gesture means.
Do you understand that you should give audible answers?
The Witness. Yes.
Mr. Wilson. If you can't hear me, please say so and I will repeat
the question or have the court reporter read the question to you. Do
you understand?
The Witness. Yes.
Mr. Wilson. Please wait until I finish each question before
answering, and I will wait until you finish your answer before I begin
the next question.
Do you understand that this will help the reporter make a clear
record because she cannot take down what we are both saying at the same
time?
The Witness. Absolutely.
Mr. Wilson. Your testimony is being taken under oath, as if we were
in court, and that if you answer a question, it will be assumed that
you understood the question and the answer was intended to be
responsive to it.
Do you understand that?
The Witness. Yes.
Mr. Wilson. Are you here voluntarily or are you here as a result of
a subpoena?
Mr. Best. He is here voluntarily.
Mr. Wilson. Do you have any questions about the deposition before
we begin the substantive portion of the proceeding?
The Witness. Not based on what you have said so far.
Mr. Wilson. Okay.
EXAMINATION BY MR. WILSON:
Question. Please state your full name and spell it for the record?
Answer. My name is Eric, E-R-I-C, Kasle, K-A-S-L-E, Sildon, S-I-L-
D-O-N.
Question. Have you used or gone by any other names?
Answer. No.
Question. Have you been known to others by any other names?
Answer. No.
Question. What is your date of birth and Social Security number?
Mr. Lu. Counsel, let me interrupt you a second. I am not sure why
you need Mr. Sildon's Social Security number or frankly, for that
matter, any witness' Social Security number.
The Wilson. Verification for information we might receive.
Mr. Lu. Could you make some kind of proffer as to what type of
information that would be? I would understand if Mr. Sildon was a
target of this investigation, but he is not. And as you know, once you
have obtained somebody's Social Security number you can, you know, run
all kinds of credit reports and, you know, other invasive types of
searches on him.
The Wilson. I am actually not sure whether I can run any credit
reports or invasive searches with a Social Security number, but to the
extent that it is an identification of materials and business, I ask
for it. It is a common thing in depositions and I never heard you
object to it before.
Mr. Lu. Is this--do you intend to ask for this for all witnesses?
The Wilson. I may and I may not. But I would ask, counsel, Mr.
Best, are you instructing your client?
Mr. Best. No, I am just speaking to him.
The Wilson. I apologize for that. Are you instructing him not to
answer my question about his Social Security number?
Mr. Best. I am interested to hear this colloquy. Do you intend to
check his credit references?
The Wilson. I do not. I do not intend to check credit references.
Mr. Best. Do you intend to use his Social Security number in some
fashion?
The Wilson. I don't know.
Mr. Best. What would you do if you did?
The Wilson. To the extent that it might be an internal
identification device, it might be relevant.
Mr. Lu. I am not sure I understand. I mean, is there any sense that
there is another Eric Sildon out there that you might need to verify
that this is the actual one who might appear on a document?
The Wilson. Not at this point, no.
Mr. Lu. Well, I am not sure I have heard a sufficient reason, but I
am going to object to the question. I am going to leave it up to Mr.
Sildon as to whether he wants to answer it or not, that part of the
question.
The Witness. Well, I----
Mr. Best. One second.
[Witness conferring with counsel.]
Mr. Best. Mr. Sildon has expressed a concern with regard to the
answers regarding the potential use of his Social Security information,
and at this point would prefer not to divulge that information.
The Wilson. Are you instructing your client not to answer the
question?
Mr. Best. I never instruct a client. I just recommend to him and it
is the client that makes a determination based on that. I recommend
that he not answer the question.
The Wilson. I am prepared to go on in that I am satisfied to have
the deposition left open pending resolution of this matter, if I decide
to continue, which I may or may not.
The Witness. That's fine.
EXAMINATION BY MR. WILSON:
Question. What is your current address?
Answer. I live at [redacted].
Question. How long have you lived at that address?
Answer. [Redacted].
Question. Have you lived outside of the United States?
Answer. No.
Question. Did you attend college?
Answer. Yes.
Question. Where did you attend college and what degree did you
receive, if any?
Answer. I graduated from [redacted] with a Bachelor of Science in
business administration.
Question. When did you graduate?
Answer. [Redacted].
Question. Do you have any post graduate degrees?
Answer. No.
Question. Please briefly describe your employment history after
college.
Answer. I came to Washington, D.C. in the fall of 1985 and worked
as a paid intern for Congressman Alan Wheat, then- Congressman Alan
Wheat, while I was looking for a more permanent position. I was hired
in late December, 1985 and began work on January 2nd, 1986, for then
Congressman Dan Glickman. I worked for Congressman Glickman until March
of 1992. I left Congressman Glickman's office to be a legislative
representative for the National Federation of Independent Business. I
was with NFIB until the fall of 1992, when I went to work for the
Presidential Inaugural Committee to work on the 52nd Presidential
Inaugural.
Mr. Best. That would not have been the fall of 1992, would it?
The Witness. That is correct. It was in November of 1992. After the
inauguration, I was offered and accepted employment at the Democratic
National Committee, where I worked until September of 1995. I left the
DNC in 1995 and went to work for the Democratic Governors Association.
I worked at the DGA until the 53rd Presidential Inaugural when I was
asked to come back and help produce an event. I was at--after the
Inaugural Committee, I have worked a succession of political and event-
resulting jobs, basically working for myself as a consultant with a
series of clients that I have represented.
EXAMINATION BY MR. WILSON:
Question. Could you please provide an approximate month date for
your tenure at the DGA?
Answer. Sure. September 1995 is when I was hired. I actually may
have begun work in early October there, but right around the first of
October, end of September, and I was at the DGA until early December
1996.
Question. Did you review any documents in preparation for this
deposition?
Answer. Just a few documents.
Question. Where did you review these documents?
Answer. At the office of my counsel.
Question. Do you keep work-related files in your personal
residence?
Answer. No.
Question. Do you have any papers from your time at the DNC at your
personal residence?
Answer. No. And I have made a search to confirm that, and I do not
have any documents.
Question. Who approached you formally about taking your position
at the DNC?
Answer. A woman named Nancy Jacobson contacted me.
Question. And who is Nancy Jacobson?
Answer. At the time, Nancy was--Nancy had been placed as the
National Finance Director for the DNC and I knew Nancy from my days
working on Capitol Hill. She had been a fund-raiser for one of the
Members of Congress, and I had worked for a reelection of his.
Question. And did you receive any recommendations to work at the
DNC?
Answer. I am not sure I understand your question.
Question. Did any--apart from speaking with Ms. Jacobson, did
anybody recommend you for the job or a job at the DNC?
Answer. Sure, Nancy--I am sure Nancy called my references.
Mr. Best. Do you know that for a fact?
The Witness. I do not know that for a fact.
EXAMINATION BY MR. WILSON:
Question. Do you know if anybody submitted a written
recommendation on your behalf?
Answer. I do not know if anybody had submitted a written
recommendation.
Question. Did you interview with anybody prior to being offered
the job at the DNC?
Answer. Other than Nancy?
Question. Well, in addition to.
Answer. Nancy Jacobson asked me to come in and talk to her about
the position and talk to her about my experiences, and also talk to her
Deputy Finance Director, a woman named Hannah Spillman, I believe, and
just my conversations with them.
Question. Do you recall interviewing with anybody else?
Answer. I don't recall if I interviewed with anybody else.
Question. What were your job responsibilities at the DNC?
Answer. Would you like all my responsibilities?
Question. Yes.
Answer. From day one on?
Question. If you could provide a general overview.
Mr. Best. He had different positions.
The Wilson. I understand that.
EXAMINATION BY MR. WILSON:
Question. If you could break down your different positions and
overview of your responsibilities?
Answer. I worked on the fund-raising staff from 199--from early
1993, early February 1993, until, I would say, early 1994. I then left
the finance staff and went to work in the office of the chairman where
I worked until I left the DNC in 1995.
Question. What were your--what were your job titles?
Answer. In the Finance Division, my job title was Regional Finance
Director. When I moved to the chairman's office, my title was Director
of National Membership Services.
Question. Did you replace anybody in the position of Director of
National Membership Services?
Answer. No. It was a new--newly created office.
Question. Who did you report to in your first job as Regional
Finance Director?
Answer. I reported to Nancy.
Question. And who did she report to?
Answer. I am sorry. Who did Nancy report to?
Question. Correct.
Answer. I don't know the hierarchy structure of who she directly
reported to.
Question. I think you stated before that--I am just wanting to
clarify for myself. She was the National Finance Director at the time?
Answer. Correct.
Question. And in your position as Director of the National
Membership Services, to whom did you report?
Answer. I reported initially to Martha Phipps who was, I believe
she was Deputy Chief of Staff, but more specifically she was, and I am
not certain what her exact title was, but she essentially ran the
office of the chairman's office.
Question. You said initially you reported to her. After Martha
Phipps, did you report to somebody else?
Answer. I did. Martha left the DNC at some point in late 1994, I
believe, or perhaps early 1995--I am not certain of the date--but when
she left, she left around the same time that a new chairman came to the
DNC and he brought with her a staff woman named Carole Khare, I think
it is K-H-A-R-E.
Question. In your position as Regional Finance Director, and I
will--once we finish this, I will try not to jump back and forth so
much----
Answer. Okay.
Question [continuing]. Did you have any subordinate employees?
Answer. I did. Well, as--I should actually restate that. I didn't
have subordinates who necessarily reported directly to me on a full-
time basis. However, when I would go out and work on an event, there
would always be a lead on the event and a few other staff people, and I
was always an event lead--I shouldn't say ``always.'' When I was an
event lead, there were other staff people working on the event who
would report to me about that event as a--in developing kind of a
hierarchy tree of who reported to who, there was no one underneath me
per se whose responsibility was to report to me on a full-time basis.
Question. When you were working with colleagues in your position
as Regional Planning Director, who were you working with? What were the
names of the people that you were working with?
Answer. Well, first of all, generally it was a rather small staff
so we all would be working with each other. But on specific events, I
worked with Sam Newman and Jay Dunn and Peter O'Keefe, and I believe on
one event I worked with Erica Payne.
Question. Do you recall any other individuals that you worked with
at that time, and I am asking for your immediate office?
Answer. I want to make sure that I understand what you are asking.
Are you talking about for these specific events or are you talking
about my day-to-day responsibilities as part of the Finance Committee?
Question. In your daily responsibilities on the Finance Committee.
Answer. Without trying to be too vague, I worked with everyone on
the staff. It is a small staff. Just as, for example, you may be
working with lots of people on the committee staff, you come in contact
with them or you have a conversation with them. I mean, you know, we
were a staff of, I don't know, approximately 15, 20, 25 people, in a
space no larger than this room. So we would see each other every
morning or have, you know, a staff meeting a couple times a week.
Somebody would call in and you would happen to answer the phone and
somebody would be on the other line.
Question. In your position as Director of the National Membership
Services, who else worked in the office of National Membership
Services?
Answer. For a period of time, Jay Dunn, who I had previously
mentioned was the Deputy Director of the program, and after--after a
period of time, Jay left the program--you have to understand, the
program left the Finance Division and Jay was really more interested in
doing finance than staying necessarily with this program. And so he
went back over to the Finance Division and a new deputy was assigned to
me, and her name was Brook Stroud.
Additionally, another woman came on board at the DNC and she was
assigned to the program as well. Her name was Susan Lavine.
Was National Membership Services originally a part of the Finance
Division?
Answer. Yes. National Membership Services initially was--the answer
is, yes.
Question. Could you explain the chronology or how--where National
Membership Services was located in the DNC flowchart when you arrived
at the DNC, and then until the time you departed from the DNC?
Answer. National Membership Services did not exist when I arrived
at the DNC. The program was created initially in the Finance Department
because that's where I worked, and it was created in early 1996,
because I was still fund-raising around the country in 1995. It was
created in early 1996 and within a matter----
Question. If I could?
Answer. I am sorry. In 1993 I was fund-raising around the country.
In early 1994, as I best recall, the program was created in the Finance
Division, primarily in response to the fact that I was tired of being
out on the road and I worked for Nancy in the Finance Division and she
wanted me to stay on board and I had expressed an interest in doing
more constituent types of work, but almost immediately, within I would
say 8 to 12 weeks, approximately 8 to 12 weeks, it was moved from
Finance to a broader location within the DNC so that it truly could
provide services to all the members of the DNC, not just people on the
Finance staff or contributors of the DNC.
So sometime in early 1994, maybe the spring of 1994, it was moved
out of Finance and into the Chairman's office.
Question. When this move, presuming there were discussions about
this move, who took part in discussions to move the NMS from Finance
Division?
Answer. Initially, I had those discussions with Nancy. Again, I
had--she was my superior. I had an interest in not traveling as much as
I had been traveling as a regional finance person; spoke with her. She
said, well, I would like to keep you on board. You know, I think you
are an asset to the organization.
After speaking with her, because obviously we were at some point in
time, when we were interested in--when I was interested in moving it
out of the finance division, then we talked to the Chairman's office
and probably the Chairman himself and certainly Martha Phipps about the
idea of bringing the program to a broader position at the DNC.
Question. Who did you speak with in the Chairman's office?
Answer. Martha Phipps, as I recall, was the initial contact. I
really don't recall if I talked to Chairman Wilhelm about it or not or
if Martha did. But I know a discussion was had within the Chairman's
office about, this is a new area; where is the most appropriate place
for it. And a decision was made that their office would be the best
place.
Question. Where physically was NMS located compared to the
Chairman's office in the DNC?
Answer. Down the hall--the Chairman's office, his personal office,
was at one corner of the building and there was a hallway leading to it
and you passed a series of secretarial kinds of cubicles and at almost
a semicircle around his office in the corner were a variety of other
offices of people who reported to the Chairman, and I was in one of
those offices.
I was essentially four offices away from the Chairman's office.
Question. In your position at the NMS, did you type your own
letters and memoranda?
Answer. Occasionally.
Question. If----
Answer. I did not have a secretary per se, but I--you know, there
were--I had obviously staff, as I have mentioned previously, who worked
for me and occasionally they would type a memo putting their name and
my name on the memo, or my name on the memo, to someone.
Question. Did anyone, other than Jay Dunn, Brook Stroud or Susan
Lavine prepare written typed materials for you?
Answer. Not that I am aware of. You mean with my name on it, in
other words?
Question. Correct.
Answer. From me or authored by me?
Question. Correct.
Answer. Not that I am aware of.
Question. Did you fax your own material?
Answer. Again, often I would fax my own material. Again, I did not
have a secretary working for me, and I tried not to have those other
people treated as assistants to me. So I did my own faxing, typed my
own memos, but occasionally somebody would be going to the fax machine,
and I would say can you do me a favor, fax this. Or they would do a
memo in my name, show it to me or verbally say, this is what we--you
know, this is what he said. I am going to send this fax to whoever. I
would say, that's fine.
Question. Did you use e-mail in your position as Director of the
NMS?
Answer. Internal e-mail within the DNC, I did. I actually did not
send e-mail outside of the DNC.
Question. In your position in the fund-raising aspect, as Regional
Finance Director, did you have contact with White House employees?
Mr. Lu. You mean in his professional capacity as opposed to a
personal capacity outside the office or something like that?
Mr. Wilson. In his position as Regional Director.
The Witness. Yes. As I recall, I had occasional conversations,
frankly not too many because issues--you know, I am in a location, be
it Miami or Philadelphia or Minneapolis doing what I am doing. The
answer is, yes, to your question.
Question. Who did you speak with on the White House staff?
Answer. Oh, I would talk to people in the Vice President's office
because he was a principal coming to a fund-raising event and we needed
to coordinate schedules, arrival time, the hotel logistics, movements,
things like that. So I don't recall specifically who on his staff 4 or
5 years ago I spoke to about that, but I would talk to that person.
I mean, candidly, I don't recall the specific people 5 years ago
that I talked to. I just know that there was need to have contact with
the White House dealing with logistical aspects of the events that we
were preparing. At the time, early at the DNC, when we had a fairly
small staff, we didn't have an events staff as they then started to put
into place a year or two later.
So it was up to the fund-raisers to deal with some of the
logistics. It also was up to the people in Washington. So very often I
talked to Nancy Jacobson or her deputy, Hannah, or people who were back
here in D.C. to say here are a variety of issues that we need to get
answered in advance of the Vice President's arrival for an event.
Can you get us answers to these? Again, I don't specifically recall
who I talked to, which conversations I may have had with the White
House versus which ones I had at the DNC, but they were all primarily
logistics-related conversations, as I recall.
Question. In your professional capacity as Director of the NMS,
did you have contact with White House employees?
Answer. I did.
Question. And with whom would you--who would you contact at the
White House?
Answer. Well, that's a fairly broad question. I can--I would be
happy to tell you offices that I had contact with. I can try to recall
specific individuals within these offices.
Question. Actually, to short-circuit, I will ask you questions
about specific individuals later.
Answer. Okay.
Question. But if you could give me a broad sense of the offices
that you would interact with.
Answer. I probably interacted most often with the Office of
Political Affairs, because they were the ones that were deemed to be
the appropriate source of some of the issues that we were discussing. I
also dealt with the White House Photo Office, the Office of
Correspondence, the Office of Public Liaison. You know, again, in my
professional capacity, that certainly is a good indication of the
majority of the places that I contacted.
I had, of course, over the years developed friendships with people
who happened to work in the White House and, you know, may have
occasionally called them because I knew they were a pal and, you know,
they could help get an answer for me to something or explain something
that was going on that I was, you know, hearing about on television. I
would say primarily those four offices are most directly--also the
Office of Scheduling and Advance.
Question. Were you the primary person in your office to either
contact or be contacted by the White House?
Answer. While I was the primary person, again, as I mentioned
previously, I like to empower people and allow people to grow in their
jobs. I wasn't looking to have a bunch of assistants with me. So
everyone on our staff had a relationship with people at the White
House. So not only did I call political affairs, but I know Brook also
would call political affairs, and I know Susan would call political
affairs and, frankly, they may have called--they had their own contacts
as well.
Question. Did your colleagues have areas of particular
responsibility or expertise that would have them interacting more or
less constantly with anybody at the White House?
Answer. Well, the--of all of us, the only person who had specific
responsibilities was Susan Lavine because she was responsible for
conducting tours of the White House on behalf of supporters, political
supporters or what have you.
That was primarily her sole responsibility. She may have had other
areas where she assisted, but if a tour request came in, it went to
Susan. If any other kind of request came in, Brook and I would figure
out who had what on their plate, who might be too busy to handle a
specific request. We would just kind of assign that out accordingly.
Question. Did you ever attend meetings at the White House?
Answer. Yes.
Question. Did you attend regular--aside from meeting about a
particular individual, did you attend regularly scheduled meetings?
Answer. Yes.
Question. And what were those meetings?
Answer. Initially, I was able to attend a daily scheduling meeting
that occurred in the morning that was run by the President's Scheduling
and Advance Office. But this was not a meeting where decisions were
made as much as a meeting where the President's schedule, frankly which
was a public schedule, was disseminated just a few extra days in
advance. So on a Monday they might discuss that whole week's schedule
and that meeting was attended by lots of offices within the White
House.
I think there were even other outside people who were not permanent
White House staff that were able to attend this meeting to understand
where the President might be traveling to or the kinds of big public
events that he would be doing. In fact, there would be lots of
discussion where the President will have private time from this and
they would not discuss what was going on in the private times.
So this was discussions about we are going to have a big event on
the south lawn and a thousand people are coming for this event and then
tomorrow the President is traveling to this location and that location.
And I attended that--I was allowed to attend it on a regular basis. I
did not actually travel over to the White House every day to attend the
meeting, but a couple of times a week I would attend that meeting.
Then there was a series of meetings in--I don't remember--I don't
recall if it began in 1994 or early 1995, but at some point there was a
series of regularly scheduled meetings dealing with upcoming events at
the White House. It was a chance, again, for all the different
departments within the White House, as well as some outside
organizations, to come and hear about--a little less about the minutia
of the scheduling, a little bit more about there is an event 2 weeks
from Wednesday and there is a dinner 3 weeks from Friday, for a broad
discussion about upcoming public events, not private scheduled events.
Question. Just asking a quick question about the previous
category, you discussed the scheduling events. Were those daily
meetings?
Answer. As I understand, those meetings were held daily. There may
have been days when they were cancelled, but it was known that at a
certain time every day in a certain room, there was a meeting hosted by
the scheduling--Office of Scheduling and Advance, primarily the
scheduling staff, to discuss the President's upcoming immediate
schedule in the upcoming--immediate meaning the next week.
Question. Who--for the immediate, who chaired the meetings?
Answer. They were run by the scheduling staff. The Director of
Scheduling was never in those meetings. They were run by various
members so on a particular Monday it might have been run by one person.
I recall Stephanie Streett, for example, would run a meeting and then
on another day a different person might have run the meeting. Just I
think--I don't know how their office decided who would run the meeting.
Question. And the second category of meetings you were describing,
the meetings about impending events at the White House, were they
regularly held meetings? For example, weekly or monthly?
Answer. They would be held weekly or every couple of weeks. It was
usually decided at the previous meeting, okay, we will next meet at. So
in that sense, there was a scheduled time for a future meeting. It
wasn't necessarily every Tuesday or Thursday at 3:00 or every other
Monday. It was just agreed upon when the next time a meeting needed to
be held.
Question. Were there any other recurring types of meetings that
you attended at the White House?
Answer. No--well, in 1994, I attended meetings in the Office of
Correspondence, just on one special project, and that was the White
House Christmas card project. And we did meet weekly for a period of
maybe 3 to 4 months.
Question. Did you have a pass to gain access to the White House?
Answer. I did not have a hard pass which had my picture on it,
which allowed me into the White House.
Question. Did you have any type of pass?
Answer. I did have a security clearance to allow me to present my
driver's license to a Secret Service desk once you enter the White
House, which would then be run through the system where I had--where I
was on what was called an access list and they would then present me
with essentially a temporary pass that I wore while I was in the White
House and returned when I left the White House.
Question. Did you ever receive any type of background check for
that pass?
Answer. Yes.
Question. And who conducted the background check?
Answer. As I understand, the FBI conducts that background check. I
was interviewed by an FBI agent to get my information. I know that
people such as former employers or people at my university were
contacted by the FBI. I don't know if other law enforcement
organizations were involved in that background check.
Question. Do you know of any other DNC employees that had--I
shouldn't say any other because you told me you didn't have a hard
pass, but do you know of any DNC employees that had a hard pass to get
into the White House?
Mr. Lu. You mean all employees at the DNC?
Mr. Wilson. Correct.
The Witness. I know that Susan Lavine, while she was working with
me for a period of time, had a hard pass with her photo on it. She had
previously worked at the White House. Candidly, I wasn't sure what the
arrangement was, but she had it and seemed to be able to use it. I
don't know anyone else who had a hard pass with their photo on it.
EXAMINATION BY MR. WILSON:
Question. Did Susan Lavine have a hard pass for the entire time
you worked at the DNC?
Answer. I don't recall. She certainly had a hard pass when she
began at the DNC and she certainly had a hard pass at least 6 months
into her job at the DNC, but it had to be reviewed at--I don't know if
the White House renews their passes on some regular basis, and I am not
certain if her hard pass was reviewed. It is not something you wear
around the DNC. You don't keep your White House hard pass hanging
around your neck. So I don't know at what point--she may have, she may
not. I just don't know.
Question. And did you ever discuss with Susan Lavine, Lavine,
where she had the hard pass?
Answer. I generally recall having conversations with Susan, since
she was conducting tours, and helping with tour aspects, you know, this
hard pass and how great it must be to have a hard pass and be able to
have the ability to give these tours. You know, you have to understand
what we were trying to do in the national membership service was be
responsive to requests, just as when I worked on Capitol Hill.
Constituents would call and they would want a tour of the--or they
would want a tour of the Capitol and it was nice to be able to provide
that tour. Susan had that ability at the White House.
So in that sense, I recall--generally recall discussing with her
how she got the pass, and she had explained that she had worked for
Mack McLarty, who was at one point the Chief of Staff to the President.
She had worked in his office and had the hard pass and when she came
over to the DNC, I did not know her prior to her arriving. I did not
hire Susan. She came with a hard pass and I assumed she was supposed to
have it.
Question. Did any of your DNC colleagues ever ask you about why
she had such a pass?
Answer. I don't recall if they asked me why she had such a pass.
Question. It is my understanding that a significant part of your
job was handling requests made by financial contributors or donors to
the DNC. Is that correct?
Answer. I would not characterize it that way. I would say that a
significant part of my job was to handle requests provided to me from
all departments within the DNC, be it political affairs, the Office of
State Chairs, the Communications Department, the Finance Department.
Question. When a request was made of you that involved an
individual, for example, for a tour or for some type of event, did you
have sort of a standard operating procedure for how to handle that
request?
Answer. Well, for tours we had a standard procedure. I would pass
the request along to Susan and she would--you know, we had a specific
number of tour tickets each week. Just as when I worked on Capitol
Hill, as all Members of Congress get a small allotment of tickets they
can provide to constituents, the DNC also got a small allotment of
tickets that we could provide to our constituents. So if a tour request
came in, in that sense, yes, there was some kind of a regular
logistical practice of taking requests and moving it. For all other
kinds of requests, it really was an issue of what is the request, how
do we best handle the request, and there was not a specific practice.
Question. Did you ever do any background check or analysis of any
individuals that were mentioned in requests?
Answer. I did not, but part of that--part of the reason for that
was because it really wasn't my responsibility, and I do not say that
somehow to sound like I did not want to take responsibility. If someone
came to me with a request, I trusted that they vetted it. If they
thought it was so important that this person got some of our limited
tickets to take a White House tour or attend an event that was
occurring at the White House, they must feel that that person is
important enough to them that they know that person well enough that
they have done the background information they need to do that they are
confident that they can submit it to me for me to provide that name to
the White House or try to resolve the request.
Mr. Lu. Mr. Sildon, when you just said someone, were you referring
to another office in the DNC, when another office provided you with a
name?
The Witness. Correct. When another office, such as the Office of
Political Affairs, had a specific request, I trusted that they did
whatever background check needed to be done, that they vetted whatever
information needed to be vetted and they provided it to me.
My role in our office, in membership service, was really to be the
office that tried to do the physical work to get things accomplished.
We didn't--I didn't meet with contributors in long meetings and then go
and try to arrange things for them. I did not meet with people who
might be a State chair or a strong political supporter out in the
country. The request came--I basically dealt with DNC staff. So they
would come to me with requests, ``they'' meaning various DNC staff
members. I would try to resolve that request for them, figuring they
had done whatever appropriate background needed to be checked to
determine that it was appropriate to submit the request to me.
Mr. Wilson. Mr. Lu, to the extent that I ask egregiously unclear
questions, I have never objected to people clarifying them, but you
will have an opportunity to ask questions later and would it be
appropriate to leave your questions for your round?
Mr. Lu. Well, I like to think that was a clarifying question that
actually helped the answer. Obviously, I will keep my questions to a
minimum, but I think I am perfectly entitled to clarify the record. I
think in this instance, actually, it actually helped.
EXAMINATION BY MR. WILSON:
Question. Do you recall whether there were any instances where you
did express concern over a particular request made of you and called
somebody back to ask questions of them about an individual involved in
a request?
Mr. Best. You are asking him about where he had a concern about an
individual or about the particular kind of request?
Mr. Wilson. About the individual.
The Witness. Could you repeat the question?
EXAMINATION BY MR. WILSON:
Question. Were there any instances where a request was made of you
for something and it involved an individual and you were--had concerns
or wanted some clarifying information about the individual? I am not
asking about what their Social Security was or for a White House tour
or something, but any type of substantive concern about the individual,
whether you, yourself, wanted to pass that individual along down the
food chain.
Answer. Not that I recall on specific requests.
Again, many of these people I did not even know who they were.
Their names were provided to me by a department within the DNC and as I
previously stated, I trusted that that department did whatever vetting
they needed to do so that they were comfortable to provide the name to
me.
As I said, I knew very few of these people and, therefore, would
not have had any concerns about any of these people. They were just
another name to me.
Question. Was there a system within your office to keep track of
requests made of National Membership Services?
Answer. Initially, we had--we, being Jay Dunn and I, when Jay was
the deputy, we set up kind of a spreadsheet where we tried to list
individuals' names and what we might have been able to help them
accomplish, just to--I did not want to get the same person on a White
House tour eight different times for all of their friends.
At some point, you say, look, on November 22nd and sometime in
December and sometime in January we have gotten you tours. I am just
not going to help you this month. That was the only time that we
actually had some kind of tracking system like that.
Examination by the time the program moved over to the chairman's
office, as I indicated, which was only a few months after the start of
the program, the process of tracking really was that we simply tried to
keep files with contributors' names on it, just so we didn't throw out
the paper and we knew who we had previously helped on certain projects.
Mr. Best. You indicated, in answer to Mr. Wilson's question, that
you kept files on contributors. Did you only keep files on
contributors?
The Witness. Actually, no. We kept files on any individual that we
tried to help with a request. Really, any request that came to me,
regardless of what department it came from, I would simply start
another file in the drawer so we had a reference of maybe a letter that
they had sent or a thank you note or, you know, background information.
EXAMINATION BY MR. WILSON:
Question. Was there a standard method of making requests of your
office? Did people use a form or did you require people to submit
something to you?
Answer. I required DNC staff--``required'' is a strong word. I
asked DNC staff to try to fill out a form that we had created that
basically provided the supporter's name and address and a phone number
and a fax number, in case we ever needed to deal directly with them.
And there were occasions when I did deal directly with these people
either to get follow-up information or to, you know, get a piece of
information back to them.
And so I asked staff to try to provide me with all the kind of
logistical background.
Question. Did you provide these forms to the other offices of the
DNC?
Answer. We created a general form and kept it in the office. If you
want a White House tour, there is a tour form to fill out, the date you
would like the tour and all available dates and is there a local phone
number. I believe we had a form for general requests, you know, nature
of the request, background, information that we would need to know,
again, you know, pertinent logistic kinds of information; name and
address information.
Question. Were these hard copy forms, forms on paper that you
would actually distribute to the offices?
Answer. Uh-huh.
Mr. Best. You have to answer, yes, to that. You went ``uh-huh.''
You two have begun a discussion rather than a question and answer.
The Witness. I am sorry. Okay. Yes, there were forms on paper.
Initially, late in my tenure with the program, I tried to create a form
on the internal e-mail so that anybody could log into the database and
get the form and type it at their desk and not have to come down to my
office and fill out a form.
It was not used very widely among DNC staff.
EXAMINATION BY MR. WILSON:
Question. Were the hard copy paper forms used fairly widely?
Answer. We asked them to. There were people who just--they were too
busy to fill out the paper. But, yes, we asked them to fill--I would
say a majority of the time, a request came with some kind of paper
documentation.
Question. And if there was no paper request, how would they make
the request?
Answer. They might stop by my office. They might--again, I shared
an office with Susan and Brook, so they might poke their head in the
office and talk to one of my colleagues, who might verbally pass it on
to me or they might stop in the office and deal directly with Susan,
because people at the DNC knew that she was conducting the tours and
handling the kind of hospitality aspect.
Mr. Wilson. I am showing the witness a document, which is--it is a
copy of a check with information about a contributor underneath.
EXAMINATION BY MR. WILSON:
Question. And there is a notation on the side that says, ``in,''
and I think it is ``AS-400.'' And I am wondering, what is--what does
the AS-400 refer to on this form?
Answer. First of all, I want to be clear, this is not my document
or my form. Since we just had a discussion about forms, I want to make
sure that--this is not a form that I have ever seen before.
But to answer your question, AS-400 was the internal DNC database.
That was the name of the complete database, but not everyone at the DNC
had access to every aspect of the DNC database. You had to have a
password and so, for example, people in--in Political Affairs, I don't
believe, could just get on to AS-400 and get access on a contributor's
background information.
Mr. Best. Let me also state that this document that you have shown
the witness bears dates on it in 1996, a period well after his
termination, his conclusion of his service at the DNC.
EXAMINATION BY MR. WILSON:
Question. Did your office have access to the AS-400 system?
Answer. Generally, our office had access to the AS-400 system. I
never--first of all, I didn't have a password. Once I left the Finance
Division in early 1994, I did not have a password and I actually did
not use the AS-400 system for probably the last year and a half of my
employment at the DNC.
We had access to AS-400 and my staff may have used it because,
again, that was the complete database. If you just needed to get a name
and address for, you know, a political supporter from back in the
Midwest from 5 years ago, that's where you would find their name and
address. And as I understand the AS-400 was also used by, for example,
the direct marketing people, who were receiving thousands of
correspondence from around the country.
Question. Was a password required to access it?
Answer. You had to have a password to get on to AS-400. As I
understand, that password only gave you access to certain accounts. As
I recall, that's how it worked. So certain staffs had access to certain
information. Other staffs to other information.
Question. Did you regularly--and when I say regularly, I am not
asking if you called somebody up and said, could you give me some
information on so and so--but did you regularly receive material that
was produced by the AS-400 system?
Answer. I never received information that was produced by the AS-
400 system, other than perhaps trying to track down a name or address.
But I never ever received any kind of printed information from AS-400.
There were not regular reports, at least that I saw. There aren't
regular reports.
Question. Are you referring now to your time as Director at NMS?
Answer. Correct.
Question. Did you receive AS-400 material when you were in your
position as Regional Finance Director?
Answer. Yes.
Mr. Best. When you say AS-400 material, you mean computerized data
derived from the AS-400?
Mr. Wilson. Correct.
The Witness. The AS-400, like any spreadsheet--like any data
system, can provide information in any manner you want it provided. So,
for example, when I was on my way to Miami, Florida, to run a fund-
raiser, I would want to get the list of names of past DNC supporters
who lived in Florida or lived in the region.
So in that sense, I could go into AS-400 and call up everyone in
the State of Florida who had supported the DNC since year X, whatever X
is, and I could get a printout of those names or names and addresses or
just phone numbers, just like any kind of data search.
But, again, that was while I was part of the Finance Committee,
doing fund-raising in specific cities.
When I stopped--when my role as a fund-raiser ended, and I became
Director of National Membership Services, I did not have an account at
AS-400, with AS-400, because I didn't need it. It wasn't part of my
role to get any kind of background. It was up to the staff to give me
name and address and I didn't need any other background information.
Mr. Lu. Counsel, could I interpret, whenever we reach a good
stopping point, can we take a break?
Mr. Wilson. Absolutely.
The Witness. At some point, I would like to take a break, if you
think there is a natural break point, I would appreciate that.
Mr. Wilson. If we can go off the record now, that would be
acceptable.
[Recess.]
Mr. Wilson. Are we ready to go back on the record?
Mr. Lu. Absolutely.
EXAMINATION BY MR. WILSON:
Question. In your--when you were Director of NMS, did you receive
contribution records of individual donors?
Answer. No.
Question. Generally, were there limited spaces available for tours
or other types of visits to administration buildings that you would
arrange for people to go on?
Mr. Best. I am not sure I understand.
Mr. Lu. I am not sure I understand that. Do you mean the public
tours? And I am also not sure what you mean by administration building.
EXAMINATION BY MR. WILSON:
Question. Administration building, buildings such as the Holocaust
Museum or the White House or Old Executive Office Building, if people
requested to have a tour of those types of things, was there generally
limited availability for those types of tours?
Answer. There were a specific limited number of tickets that we
were allowed to have for tours to the White House, the same ``VIP,'' in
quotes, tours at the same times that Members of Congress, Republicans
and Democratics, also had access to; 8:15, 8:30, 8:45 in the morning.
There were a limited number of tour tickets for that. There were not--
we did not have any kind of regular allotment of tour tickets for any
other site in the city.
Question. Who set the number for the tickets that you were
provided access to?
Answer. Someone in----
Mr. Best. You are talking about the tours now?
Mr. Wilson. Correct.
The Witness. Are you talking about tours for the White House?
EXAMINATION BY MR. WILSON:
Question. Yes.
Answer. Somebody in the White House visitors' office.
Question. How would you prioritize among multiple applicants? Do
you have more requests for a particular tour than you had tickets
available?
Answer. Yes.
Question. How would you determine between the requests?
Answer. Very often it was first-come, first-served, just as it used
to be when I worked on Capitol Hill. Occasionally, we would maybe have
a few remaining tickets left, you know, two or four of our allotment
left and we would have on the same day a request for 10 different
tickets and then we would try to figure out who should get those
tickets. But there was no particular way that we qualified who got
those tickets.
Maybe somebody had tried a month before and didn't get them so we
would provide them to that particular person the next time around. Or
somebody who was traveling all the way from California and they were
only going to be here for one day and that was the only day they could
go and we happened to have two tickets for that day. So primarily it
was first-come, first-served, though.
Question. Was the size of a financial contribution ever used to
help make the determination?
Answer. Well, again I did not have access to the financial records
and I think there were times when we knew that based on, you know,
someone saying, look, I really would like to help this person get a
tour, you know, they are--you know, they are strong supporters of the
party, but I never knew specific dollar amounts, who gave what. Very
often I wouldn't find that information out until I read it in the paper
when the Post would do their quarterly list of contributors.
Question. When people used the request form that you provided to
the various offices for making requests for tours, or whatever else the
request forms were used for, was there a system for people to indicate
how much they wanted you to be able to respond affirmatively?
Answer. Well, I provided a space for--I don't recall specifically
what I called it, but, you know, additional information or background
or something--whatever they wrote, they wrote. But I did not have a
specific language that asked for a contribution level and, again, I
want to remind you I was taking care of--or trying to help all
departments within the DNC. So contributions were not the sole focus on
what I was looking at.
I also would like to maybe state the obvious, which is while
finance may have thought that their group of constituents was the most
important, so did political and so did the Communications Department.
Political didn't care how much money someone gave. They were more
interested in the person who went out and put door hangers on 10,000
houses. To them that was important. So it did not matter to me how much
money someone gave. I was just trying to be responsive to all the
different staff people at the DNC who were trying to be responsive to
all of their constituent bases around the country within their
divisions.
Question. Did you ever receive instructions or any type of
indication from the White House that somebody should be given priority
to receive a particular type of--to be helped by your office?
Answer. Absolutely not.
Question. Did you ever have access to any computer databases of
names of individuals generated by the DNC?
Answer. Well, as we talked about before, the AS-400 system was the
database collection and repository for the whole DNC.
Question. I am asking you--you have indicated you didn't have a
password. Was there any other type of database or repository that you
used that gave you names of individuals?
Answer. Not that I recall.
Question. What do the terms ``trustee''--and these are terms of
art ``trustee'' and ``managing trustee'' mean?
Answer. Those were donor councils at the DNC.
Question. Specifically, do you recall what trustee category--what
was required to be in the trustee category?
Answer. I don't recall because their requirements changed over the
course of the years and, again, that wasn't relevant to my
responsibilities.
Question. Do you recall what was required to be part of the
managing trustee category?
Answer. Again, as I just stated, A, I was not a member of the
Finance Division beyond 1993, and B, the amounts that were requested of
members--or requested of supporters to become members of these donor
councils was changing.
Question. Did you ever arrange for meetings between individuals
who were referred to your office and White House staff?
Answer. I generally recall trying to make a connection between two
people. I don't specifically recall who in the White House I might have
asked to meet with someone, but, again, that would have only been
because a DNC staffer would have come to me and said, I really need
person X or can you help me get person X to meet with staff person X.
Mr. Lu. Counsel, I am not sure if your question is looking at the--
are we now focused strictly on the national membership's time as
opposed to a specific fund-raiser?
Mr. Wilson. I am actually wanting to focus at this point on the
National Membership Services.
Mr. Best. His answer seems to be with regard to meetings with
regard to DNC staff personnel and White House personnel. You used the
word ``individuals'' and I am not sure what you meant by that.
Mr. Wilson. Right. And I will re-ask the question for clarity's
sake.
Question. Did you ever receive names of non-DNC employees for
suggested meetings with White House staff?
Answer. I don't specifically recall that occurring. It certainly
may have, and if someone knew that perhaps I knew someone at the White
House, a staff person might have got in touch with me on behalf of one
of their constituents, again, be it the political division or the
communications division.
Question. Do you recall whether the request forms that you
circulated to the offices were ever used to make a request of your
office that you facilitate or set up a meeting between a non-DNC
employee and somebody in the White House?
Answer. It's possible. I don't specifically recall, but it
certainly is possible.
Question. Do you recall whether there was anyone at the DNC who
was in charge of facilitating meetings between non-DNC employees and
administration officials?
Mr. Best. Now we are going from meetings at the White House?
Mr. Wilson. I am asking again about the NMS staff.
Mr. Best. You have now enlarged it from White House staff to
administration officials?
Mr. Wilson. Correct. Correct.
The Witness. There were times when I was responsible for that.
There also were a lot of people at the DNC who had relationships around
town. They had worked with these people during campaigns or they knew
them socially and also formed a professional relationship where they
would just call them directly. So there were certainly times when I
would make phone calls out into the administration. And as I previously
indicated, it is certainly possible that I made phone calls to staff
people at the White House on behalf of the DNC constituents who, as I
indicated, could be from political or any other department, the
chairman's office.
But that doesn't mean that I exclusively, I, meaning I or my staff,
exclusively were the ones who made such contacts because there were all
kinds of people out there who had their own relationships.
EXAMINATION BY MR. WILSON:
Question. Well, avoiding personal contacts where somebody might
call a friend and attempt to get something done, was your office the
office that people would turn to if they wanted to suggest that a non-
DNC employee meet with a White House or an administration employee?
Answer. Even making the void which you just made, there is nothing
which prohibited some, you know--not that--not that a staff person is a
lone ranger, but nothing to prohibit some staff person from picking up
the phone and calling an office around the administration. So while
sometimes staff would come to me and help me to ask with an initial
phone call, for all I know they were making their own phone calls and
calling out to the administration themselves, or the White House to a
staff person themselves.
Question. Understood. I am just trying to get a sense of whether
that was one of the purposes or functions of the request forms that you
circulated to other offices, was to be used for that type of purpose,
if somebody wanted to use it for any purpose.
Answer. I believe this will help answer the question. That request
form was a catchall request form. If you have either seen it or will
see it, it is a very vague, general form that asks for people's names
and addresses and phone numbers and nature of the request. And so it
could be for anything, and we got requests for anything: Can you
recommend a good golf course? I am coming to Washington. Somebody would
write it on paper and give it to me and I would have to respond to it.
You know, or my kids are coming to town, what are fun things to do
with kids for 3 days in Washington? Or it certainly is possible that
the form could be used for anything, including interest in having a
meeting or getting a tour or the kinds of things that we were talking
about.
Question. Did you ever have discussions with DNC colleagues while
you were director of the NMS about using White House, for want of a
better term, perks as a means of raising financial contributions?
Mr. Lu. I am not sure I understand the term ``White House perks.''
I mean, if the witness understands that term.
Mr. Best. I have less problem with that aspect of your question
than the portion that deals with raising money. I am not sure if you
are saying that you--the use of this, that it should be linked to the
availability of a tour of the White House.
Mr. Wilson. Or just using the carrot of a visit to the White House
or a night in the Lincoln bedroom or a visit to a particular event as a
means of stimulating people to contribute money.
Mr. Best. And the question is: Have you ever had conversations of
that nature?
The Witness. Well, I don't recall having such conversations. Again,
I was not concerned about the fund-raising aspects exclusively. I was
trying to be helpful to all of our constituents and figure out ways
that we could be responsive to all of our constituents. So I don't
recall having conversations.
EXAMINATION BY MR. WILSON:
Question. Understood that you weren't concerned about fund-raising
exclusively, but to the extent that you were concerned about fund-
raising, did you have discussions with how--and again this is in the
time that you were director of NMS--White House benefits, benefits
being access to the White House or any other type of--you know, that
somebody might not have public access to but might like to have access
to, how they might be used to stimulate people to contribute money?
Mr. Best. I am sure that the witness has testified that he had a
concern about fund-raising, which was one of the predicates of your
question that you just formed. I believe his testimony has to do with
providing service to the finance department, as well as the other
departments and offices at the DNC.
But to the extent that you can answer his question, you may do so.
Perhaps the best thing is to maybe reformulate it.
Mr. Wilson. Just to clarify, Mr. Sildon indicated that he wasn't
exclusively concerned about something, and I interpret that to mean
that, therefore, there was some concern, given that it wasn't
exclusive, there was some small concern.
The Witness. Perhaps I choose--this was a matter of semantics. I
probably should have said specifically concerned about fund-raising as
opposed to exclusively. Again, I trusted that the people who worked at
the DNC in the finance division were doing their job to raise whatever
money they needed to raise. My responsibility was not necessarily one
of making sure that they were meeting their financial targets.
Mine was a responsibility of being responsive to that department,
as well as the chairman's office, and political, and the Office of
State Chairs, and anyone else at the DNC that might seek some kind of
assistance for them to all better do their jobs.
And so maybe exclusively was the wrong word. I guess I should say I
wasn't specifically aware of the financial implications and how it
might help a division, because that wasn't my specific charge as
Director of National Membership Services.
EXAMINATION BY MR. WILSON:
Question. Did you ever make any suggestions to any of your--of DNC
colleagues, either in NMS or in other divisions, as to how you might
use to better advantage for fund-raising purposes access to the White
House or other similar and for want of a better word I will use perks?
Mr. Lu. I am sorry. Could you read that question back.
[The reporter read back as requested.]
The Witness. Again, it was not my responsibility to be--I was
trying to be responsive.
Mr. Best. No. He asked you if you had conversations. You are
explaining why you didn't have conversations but you never say whether
or not you had such conversations.
The Witness. Thank you. And, no, I have not--I don't recall having
such conversations.
EXAMINATION BY MR. WILSON:
Question. Do you know if the White House mess was ever used to
entertain supporters, DNC supporters?
Answer. I don't know. I didn't have mess privileges.
Question. Did you ever facilitate individuals--any individual's
use of the White House mess?
Answer. Not that I recall.
Question. Do you know if anybody in your office helped people to
go over and eat at the White House mess?
Answer. Again, I don't recall.
Question. Did you ever send any names of people to be considered
as White House overnight guests, send to the White House such names?
Answer. No.
Question. Did you ever receive requests--a request from anybody at
the DNC about having somebody spend the night at the White House?
Answer. I am sorry. Can you repeat the question?
Question. Did you ever receive a request from anybody at the DNC
about helping somebody to go and spend the night at the White House?
Answer. Again, I don't recall that.
Question. Do you recall whether you ever received a request from a
non-DNC person to help them to spend the night at the White House?
Answer. No.
Question. Do you know how somebody who is interested in spending
the night at the White House might go about getting an invitation to
spend the night at the White House?
Answer. I don't.
Question. Did anyone ever discuss with you whether the President
was interested in having people stay at the White House?
Answer. No. I don't believe I ever had such a conversation.
Question. Do you know if places were reserved on either Air Force
One or Air Force Two for DNC supporters?
Answer. I am not aware of spots being reserved.
Question. Did you ever have any discussions with DNC colleagues as
to whether it was a good idea to have Air Force One or Air Force Two
places reserved for DNC supporters?
Answer. Actually, I should tell you that in 1993 I was told
specifically by--well, I remember this information being discussed. I
don't recall who I talked to about it, but we were told--I was told
that DNC supporters were not going to be able to be on Air Force One,
and I never thought twice about it again.
It was someone at the White House, I believe maybe in political
affairs. The discussion came up while I was fund-raising for an event
in Miami, one of the first events. The President was going to fly down.
There were discussions about, well, the Republicans used to have people
fly up to Washington and get on Air Force One with the President and
travel with him to event sites, and there were all these people in
Florida who knew that that occurred, and they wanted to go to
Washington to get on Air Force One or actually in this case to get on
the Vice President's plane and fly down with the Vice President so they
could get off the plane with the Vice President and walk down the steps
with the Vice President in their hometown.
And I was specifically told, though I don't recall by whom at the
White House, I was specifically told by the Office of Political Affairs
that will not happen. And don't ask. And I never asked again, ever.
Question. And to the best of your recollection, was this--did this
take place when you were regional finance director?
Answer. Did what take place?
Question. The conversation or communication that you have just
alluded to.
Answer. Yes, that was while I was in the finance division trying to
deal with logistics of a particular event.
Question. Do you know if places were reserved at White House
private dinners for financial contributors to the DNC?
Answer. I know that the----
Mr. Best. He is asking about financial contributors. Listen to the
question.
The Witness. I appreciate that.
Mr. Best. Okay.
The Witness. There were no spots ever reserved for DNC people,
period. There would be times when the White House might say, we are
having a dinner and if there are people that you think are important to
attend the dinner, you might provide us with a few names. But there was
no guarantee that the names that we sent over would get into the
dinner.
There were no specific slots assigned; gee, we have got X number of
slots which you can fill. And certainly, those people, if we did send
over names, weren't necessarily finance contributors. The White House
would say, if you want to send over a few names, you can send over a
few names. They might all be from the chairman's office or they might
all be political supporters. And there is no guarantee that any of them
got in. And, in fact, frankly a lot of times our names weren't put into
events.
EXAMINATION BY MR. WILSON:
Question. Are you aware of this from your time as director of the
NMS?
Answer. Correct.
Question. And did you sometimes receive phone calls like the one
you have just described or communications like the ones you have just
described?
Answer. We had previously discussed meetings that occurred about
events at the White House. During those meetings, they would indicate,
there is a dinner in 3 weeks and there is a large event on the South
Lawn in 6 weeks and if you want to submit some names, we will consider
them among the many names that we are considering for an event.
So while I was--those conversations occurred while I was director
of the program, attending those meetings.
Question. While you were director at NMS, did you ever receive a
request from the White House to provide names of certain categories of
financial contributors for one of these types of events?
Answer. I am sorry. I need you to repeat the specific question
again.
Question. I will ask the reporter to help me out.
The Witness. No.
Mr. Best. What do you mean by specific categories?
EXAMINATION BY MR. WILSON:
Question. Did you ever get a phone call where somebody might have
said something like, we are having a dinner, can you send over some
names of managing trustees?
Answer. No.
Question. And going from that, that is a specific question going
to a very general question. Do you recall any instance where the White
House mentioned that there would be an event of any sort and they were
interested in having names that would be delineated by amount of
contribution or amount of support to the DNC?
Mr. Lu. I am going to object to that question. I think Mr. Sildon
has already testified repeatedly that the services were not distributed
based on financial contributions. In fact, he never even had access to
that information. So if he wants to answer the question, he can.
Mr. Wilson. That wasn't my question. That wasn't even implicit in
my question.
Mr. Lu. You are asking him whether the White House called asking
for names of people based on contributions.
Mr. Wilson. Correct.
Mr. Lu. What I am saying is that Mr. Sildon has already testified
he never had access to financial information about the supporters.
Mr. Wilson. That wouldn't prevent the question being asked of him.
Mr. Lu. I will object to the question.
Mr. Wilson. That wouldn't prevent the question being asked of him
at all.
Mr. Lu. I think we have gone through this.
The Witness. I will----
Mr. Best. Let them finish.
Are you finished?
Mr. Wilson. Yes.
The Witness. My answer is no.
EXAMINATION BY MR. WILSON:
Question. Did you ever discuss requests made on behalf of
individuals for the individual being put on a board or a commission?
Answer. Well, I generally recall discussions about boards and
commissions, but I don't remember if that was just hearing
conversations or somebody specifically asked me. But I didn't handle
boards and commissions.
Question. Do you know who at the DNC might have been more directly
involved in handling requests of that nature?
Answer. I don't.
Question. Did the DNC ever use the President's box at the Kennedy
Center?
Answer. Yes.
Question. Just by way of background, because I literally don't
know this, how often did the President or does the President have
access to events at the Kennedy Center?
Answer. I don't know, because I don't work for the President--I
didn't work for the President.
Question. Have you ever had conversations with people who do work
with the President where they have indicated to you that the President
has access to the Kennedy Center?
Answer. I don't recall those conversations.
Question. You mentioned the DNC did use the President's box at the
Kennedy Center. For what purpose?
Answer. To allow supporters to watch events that were occurring at
the Kennedy Center.
Question. How frequently did that occur?
Answer. How frequently did what occur?
Question. DNC supporters using the President's box?
Answer. Maybe a couple of times a month. You know, there were--
there were three halls at the Kennedy Center so I would say a couple of
times a month total amongst all three halls, matinee and evening and
weekend performances.
Question. That actually goes to my earlier question. Again, I
don't know what the background is, but is it your understanding that
the President has space reserved for all performances in all venues
within the Kennedy Center?
Answer. Well, your previous question was, how often does the
President have access to these. And I answered, I don't know how often
President Bill Clinton had access to his box. If you are asking about
the President's box, I mean, it is his box. They don't rent that out to
other people. They don't sell that to the public. That's a privately
reserved box, just as any corporation, I assume, can lease a box at the
Kennedy Center.
So he, therefore--I don't know about him and that's why I answered
your previous question as I did. If you are asking about other things,
if you want to restate the question, I would be happy to try and answer
it.
Question. That gives me all the background I need.
Who, within the White House, was in charge of access to the
President's box?
Answer. A woman named Debi Schiff was the person to whom I believe
the Kennedy Center sent the tickets.
Question. Did she ever contact you offering you use of tickets----
Answer. Yes.
Question [continuing]. For events?
Answer. Yes.
Question. Did you ever contact her asking for tickets for specific
events or specific nights?
Answer. Yes.
Question. How often would you do that?
Answer. Well, I certainly probably contacted her a few more times
than she was able to help out. There appeared to be many people,
including White House staff and administration staff, who also put in
requests to get--sit in these seats, and so I don't recall specifically
how many times I contacted her. It wasn't a significant number, but it
was an occasional number. Someone was in from out of town.
Question. Did you send out formal invitations to the people for
whom you were helping to get tickets to the Kennedy Center?
Mr. Best. What is a formal invitation as compared to just a regular
invitation?
Mr. Wilson. Actually, I will rephrase that.
EXAMINATION BY MR. WILSON:
Question. Did you send out invitations of any sort to people,
written, in advance invitations?
Answer. Not that I recall. And very often we did not get these
tickets until the very last moment. You know, a phone call at 4:00 for
a 7:00 performance. And oftentimes we were called to say if a staff
person wanted to go, is there someone over there who would like to go?
We have two tickets for tonight that aren't going to be used.
Question. Do you recall whether there was a special arrangement
between the White House and the DNC for access to Presidential tickets
on any particular night of the week?
Answer. We are still referring to the Kennedy Center?
Question. Yes.
Answer. Again, not that I recall. I mean, I don't think the Kennedy
Center had a regular schedule so that we could have automatically had,
you know, every Saturday matinee, for example, because they might not
have a Saturday matinee.
Mr. Wilson. I would just like to provide Mr. Sildon with a
document. It is a memorandum to Eric Sildon from Jay Dunn dated
September 2, 1993.
EXAMINATION BY MR. WILSON:
Question. It is my understanding that this is--was a memo that you
had received when you were regional finance director in the finance
department. Am I correct on that time frame?
Answer. That--the time frame would look right, that's correct.
Question. And the bit I direct your attention to is the first
sentence on the second bullet point, which reads, we have the box every
Thursday evening for performances at the Kennedy Center.
Is this an accurate statement?
Mr. Best. Is what accurate? Did he get the memo or was Dunn correct
when he made that statement?
Mr. Wilson. Correct.
EXAMINATION BY MR. WILSON:
Question. Was Dunn correct when he made this statement?
Answer. I have no reason to think that Jay would have written that
to me if that wasn't the case, but it doesn't refresh my memory.
Question. Do you recall receiving this memorandum?
Answer. I don't recall receiving it, but I am--no, I don't recall
receiving this memo.
Question. Do you recall any conversations that you participated in
wherein it was discussed having regular access to a box on a particular
night of the week at the Kennedy Center?
Mr. Best. We are now referring to the period in 1993, when he was
regional----
Mr. Wilson. To any time at all during employment at the DNC.
The Witness. About a specific evening?
EXAMINATION BY MR. WILSON:
Question. Right.
Answer. Again, I don't recall such conversations.
Question. Did you ever receive any requests from Mark Middleton
expressing an interest in having financial contributors to the DNC use
the President's Kennedy Center box?
Mr. Lu. Again, we are talking about this time in September of 1993
or at the time that he was in National Membership Services?
Mr. Wilson. If you could read the question, I believe I asked ``did
you ever.'' So my question is, did you ever.
If I could ask the reporter to read the question back.
Mr. Best. We will assume that's what you asked in terms of
responding.
The Witness. I don't recall having such conversations with Mark.
EXAMINATION BY MR. WILSON:
Question. Do you recall any conversations where Mr. Middleton
requested that you help him obtain Kennedy Center Presidential box
tickets?
Answer. Well, I don't recall such conversations and I--not to
belabor this point, but Mark worked at the White House in the chief of
staff's office. I don't know why Mark would call me to get tickets that
were at the White House. First of all, we didn't get tickets very
often, as I have previously stated; just a couple of times a month. So
I don't see any logic to why he would have contacted me to get
something that, frankly, his place of work controlled.
Question. Do you know who invited DNC supporters to Presidential
radio addresses?
Answer. No.
Question. Did your office ever invite individuals to attend
Presidential radio addresses?
Answer. Well, I need to clarify for just a minute. We never invited
anyone. If somebody came to us and said--if a DNC staff person came to
me and said, there is somebody I would like to try to get into a radio
address, I just as a matter of form had a memo to a staff person at the
White House that I just would change the person's name and send it over
with their date of birth and social security asking the White House to
consider inviting them. It didn't mean that the White House necessarily
did it. I couldn't issue the invitation because I didn't have a regular
slot to put people into a radio address.
Question. Do you recall who your form memorandum would be
addressed to?
Answer. Well, there were a couple of different people, I believe,
who were working that department. David Levy was the person who most
often, I believe, I sent the memos to. But David wasn't there the
entire time. I don't think he was in that role initially, and there may
be others as well. But I do recall David Levy.
Question. Do you know what people were instructed to do if they
were to attend a radio address? I am asking for mechanics here, where
they would go, who they would report to, what they would have to do to
actually listen in to the address?
Answer. I am not sure how this is relevant to my job at the DNC.
Question. No, I am just asking you whether you do know, to the
extent you might have forwarded requests along to help facilitate
somebody attending a radio address. Do you know what they had to do
when they actually attended?
Answer. I generally know what they had to do.
Question. And in a general sense, what was required of them?
Answer. They would go to a previously designated gate, White House
gate, as determined by White House staff, where they would present
identification. I am guessing there was some kind of list but I don't
know that for certain.
They would then be directed towards the--towards the West Wing
lobby, I assume, and then somebody from the West Wing lobby would take
them from there to wherever they needed to go, wherever the radio
address was occurring.
Question. Do you know where the radio addresses were broadcast
from?
Answer. I understand the location of the radio address has changed
based on a variety of circumstances.
Question. Do you know whether the President held any regular
lunches for CEOs or for businesses?
Answer. I very vaguely recall hearing about--well, perhaps I more
generally recall hearing about--that there was some kind of gathering
for CEO lunches. Frankly, that rings a bell.
Question. Do you know if DNC supporters were invited to any of
these lunches?
Answer. Well, again I just--I kind of generally remember that these
lunches were occurring, but I don't think I have enough recollection
about the lunch to be able to specifically answer a question like that.
Mr. Best. Was it something that you did in your position in
Membership Services?
The Witness. I really don't recall. It wasn't something that I did
regularly. Like if you asked me, did we handle White House tours, I
could tell you yes because we did it every week. I don't recall any
kind of regular lunch or that I was responsible for placing people in
any kind of lunch like that. But I will say that it does sound familiar
that such a lunch may have occurred, but I don't know if it was on a
regular basis or who attended. But I do recall that there--generally
recall.
EXAMINATION BY MR. WILSON:
Question. Do you know if any spaces at these types of lunches were
set aside for DNC supporters?
Answer. I don't. I don't know that.
Question. Did you ever----
Mr. Best. You used the term ``supporter'' and you have used it
before, and I take it you mean a fund--in a fund-raising capacity.
Because the term ``supporter'' is a more generic term in the political
business. I understand to include as a supporter someone who goes out
and does political outreach is a supporter. So that I am a little--I am
a little concerned that what you mean by the term ``supporter'' when
you use it.
Mr. Wilson. Well, what I do mean is that a financial contributor
would be a subset of the term ``supporter'' and the term ``supporter''
is a very wide universe of people who could be volunteer workers or
columnists who write articles favorably. It could encompass many
different things. If there was indication, I would probably attempt to
go and be a little more definite. I ask these across the board. If I am
asking these questions and there is just a straight no, then that
enables me to move on.
The Witness. Great.
Mr. Wilson. And I will attempt not to belabor points that are just
completely unknown to you.
Mr. Best. That's helpful. Thank you.
EXAMINATION BY MR. WILSON:
Question. Do you know, did you ever help to arrange for meetings
with the Vice President? Having just come down from this supporter
dialogue, any type of individual that would be referred to you as
somebody, I would like you to help this individual to get a meeting
with the Vice President, who is a supporter?
Mr. Lu. I think he has already testified in his capacity as a fund-
raiser that he arranged events for the Vice President. I assume you are
talking about in his second role at the DNC.
Mr. Wilson. Well, my understanding is that if somebody arranged
events for the Vice President that doesn't necessarily mean that he is
helping an individual get a meeting with the Vice President.
Mr. Lu. Well, I don't know if we have established it or not, but
what Mr. Sildon testified to----
Mr. Wilson. So I asked a very different question.
The Witness. Why don't you tell me if--are you asking in my role--I
am sorry. But we just keep jumping back and forth between my fund-
raising responsibilities in 1993 and my service and constituent
responsibilities in '94 and '95.
EXAMINATION BY MR. WILSON:
Question. It makes it difficult.
Answer. Yes, it does make it difficult.
Question. I will ask one and then I will ask the other.
Answer. Okay.
Question. In your role as regional finance director, did you ever
set up meetings between an individual and the Vice President or help to
set up meetings?
Answer. One-on-one meetings?
Question. Yes.
Answer. Not that I recall.
Question. Did you ever set up small group meetings between
individuals and the Vice President?
Answer. In advance of a fund-raising event, there might be a small
gathering of 20 people in a room to greet the Vice President when he
arrives at a hotel to shake his hand.
Question. In your capacity as director of the NMS, did you ever
attempt to facilitate one-on-one meetings with the Vice President?
Answer. Again, not that I recall.
Question. Did the DNC ever issue invitations to people to attend
movies at the White House?
Answer. No.
Question. Did you ever help to facilitate people going to attend a
movie at the White House?
Answer. Candidly, I may have, but I don't recall.
Question. Do you know if you ever received schedules of movies in
advance?
Answer. No.
Question. You don't know or you didn't receive any schedules?
Answer. I don't believe that I received a schedule of movies
indicating that on this night they are showing this movie and on this
night they are showing that movie.
Question. Do you recall whether you ever helped--and this is
exclusively at the time period when you were director of NMS--to
facilitate a lunch between somebody and Mack McLarty?
Answer. Not that I recall.
Question. Did you ever receive any requests for individuals to
have lunch with Ira Magaziner?
The Witness. Can we take a break for just a minute?
Mr. Best. Sure. We can take a break any time.
Mr. Wilson. That's all right.
The Witness. Excuse me just one second.
Mr. Wilson. Surely.
[Discussion off the record.]
Mr. Wilson. If we could go back on the record. If you will, please,
read back the last question that I asked.
[The reporter read back as requested.]
The Witness. I don't recall that, but I need to state, you know,
this was 3 and 4 years ago and I just don't recall every request that
came to me or every memo I may or may not have written. If you have
information that you would like to provide to me or show to me, if
there is something I ought to see, I would be happy to look at it and
try to respond. But as far as generally what do I recall from a job
that occurred in some cases more than 3 years ago, I don't recall that.
EXAMINATION BY MR. WILSON:
Question. Did you ever have requests brought to your attention for
people to use the President's box at the Warner Theater or Wolf Trap?
Answer. No, not that I recall.
Question. Did you ever work to--did you ever help people to have
their photo- graphs taken with the President?
Answer. Yes.
Question. How did that process work?
Answer. Well, I am not sure it was a process. That was a pretty
general question. You know, if somebody is attending an event that's at
the White House and they want to get their picture taken with the
President, I might contact someone at the White House and give them
that head's up.
But, again, it was simply to pass along information to someone over
there to make them aware of it.
Mr. Best. Let me ask this: A photo opportunity with the President
was not a-- was not an isolated event; was it? It was always in
conjunction with attendance at another function at the White House?
The Witness. As far as I know, that's correct.
EXAMINATION BY MR. WILSON:
Question. Which anticipates my next question. Were there
situations where you would get a request for an isolated event for
somebody to go up and have their pic- ture taken with the President,
outside of an event, outside of some prescheduled event?
Answer. You mean that someone, a staff person at the DNC would
contact me and say, we have heard from so and so and they would like to
go over to the White House and get their picture taken with the
President?
Question. Correct.
Answer. It is possible. I don't think that there was any kind of
specific formula for that. I don't--I certainly on a regular basis was
not sending requests over to the White House that a certain person
wanted to come over and have a one-on-one and while they were there
have their photo taken.
Question. Do you remember any specific instances where somebody
did go over and have their picture taken outside of going to an
official event?
Answer. I don't recall any situation like that.
Question. Did you have any requests while you were director of NMS
to get photo- graphs signed by the President?
Answer. Yes.
Question. And how would you generally get that done?
Answer. All photos I would send over to the Office of Political
Affairs and let them handle it however they did, whether it was an auto
pen or a real picture of the President. That was something that they
handled.
Question. And by that, do you mean the Office of Political Affairs
in the White House?
Answer. I am sorry, in the White House, correct.
Question. Do you recall whether DNC supporters were ever sent
birthday cards from the President?
Answer. Yes.
Question. Do you know how people were selected to receive a
birthday card from the President?
Answer. Are you talking about people meaning DNC supporters?
Question. Yes.
Answer. I would simply send a request over to the White House and,
you know, somebody said to me that for something innocuous like a, you
know, a form--it is not an actual letter from the President. Usually it
was a card or maybe it was some kind of form letter that they just
ginned out, you know, send a request over to political affairs and say
this person is turning 65 or 80 or 50 or their child is turning 16, can
the President send a birthday letter?
Question. Was this always done on a case-by-case basis?
Answer. Well, again, it wasn't up to--as I previously stated, I
wasn't the person vetting the request. If somebody thought it was
important enough that they came to me, you know, I would send it over.
It is up to the White House whether or not they want to fulfill the
request. And it was up to some person previous to me as to whether it
was worthwhile enough to submit to me to submit to the White House. I
was simply being a conduit between departments that had requests and
the appropriate place at the White House that would consider whether
they wanted to resolve the request.
Question. Did you ever receive requests for a card to go to more
than one individ- ual at any one time? And by that I mean, did anybody
ever give you a list of people and say, could you please arrange for
these people to get birthday cards from the President?
Answer. Well, we only--I mean, it is possible. Is there more--I
tended to make a request for a birthday card around the time of
somebody's birthday. Are you asking did I send over a list of 10,000
people and say, here are the birthdays, fire at will? I don't recall
doing that.
Mr. Wilson. I would like to show the witness a memorandum, which it
is dated November 29, 1993, and it is to a number of people who are not
designated by last names from somebody named Tara.
The Witness. I see it.
Mr. Wilson. There is a handwritten note on the bottom of this memo
that reads, ``Eric, Pls. see me about the birthday project Ceandra
started,'' and ``Thx,'' I believe, ``Martha.''
EXAMINATION BY MR. WILSON:
Question. First does the ``Eric'' referred to in this note refer
to you?
Answer. I don't know. I would assume so.
Question. Do you recall seeing this particular memorandum?
Answer. I actually do not recall seeing this.
Question. Do you know what the birthday project was?
Answer. I do not.
Question. There is what I believe is a name here in this note. I
think it would be pronounced Ceandra, C-E-A-N-D-R-A.
Answer. Correct.
Question. Who is that individual?
Answer. Well, I only know one Ceandra, so I am assuming it is
Ceandra Scott, who did work in the chairman's office at the DNC and
reported to Martha Phipps. And at the top of the memo it indicates
Martha Phipps, so I am assuming.
Question. Do you recall any discussions about something that was
termed ``the birthday project''?
Answer. I do not.
Question. Do you recall whether you ever sent a list of DNC
trustees to the White House?
Answer. If I sent a list of DNC trustees to the White House?
Question. Yes.
Answer. The complete trustee list?
Question. Well, any list. You know, I am not asking for knowledge
of a specific list, but do you recall whether you ever sent over a list
of trustees, be it inclusive or partial, to the White House?
Mr. Best. You mean in response to this memorandum----
Mr. Wilson. No.
Mr. Best.--of 11-29.
EXAMINATION BY MR. WILSON:
Question. No. In general, do you recall ever submitting a list of
trustees, DNC trustees, to the White House for any reason?
Answer. I don't recall that but--I don't recall that.
Question. Do you recall whether there was any discussion among
your colleagues in the general time period that this memorandum is
dated, and the memorandum is not dated--I will make that clear for the
record--it is dated November 29, with no year. There is a fax
transmission at the top which indicates that it was faxed from somebody
to somebody on November 29, 1993. So, again, I assume this is the time
that you were regional finance director at the DNC.
Do you recall whether there were any conversations that either you
participated in or you overheard that involved having a list of
trustees sent to the White House?
Answer. No. And I also would like to add, I can recall that around
that time I was in Philadelphia because I was responsible for a fund-
raising event with the President in Philadelphia that occurred, I
believe, the first week in December 1993, and I was in Philadelphia for
about 3 weeks. I mean, I remember coming from Philadelphia to
Washington to come home for Thanksgiving and then driving back to
Philadelphia. So on 11-29 I would not have even been in Washington.
Question. When you were regional finance director, do you recall
whether the White House ever provided the DNC with a list of birthdays?
Answer. I don't recall that.
Question. Speaking of either when you were regional finance
director or director of the NMS, did you ever see any list of names
that were provided to you or to the DNC by the White House?
Mr. Lu. What types of names?
Mr. Best. Yes.
Mr. Wilson. Names of individuals, people.
Mr. Best. For what purpose?
The Witness. From the White House back to me?
EXAMINATION BY MR. WILSON:
Question. Correct.
Answer. That's such a vague--it's such a broad question. I mean----
Mr. Best. Can you elucidate in any way?
Mr. Wilson. I am trying to be very vague, actually. Thus far, I
think my understanding is that there have not been lists of any sort
passed back and forth between the DNC and the White House that you are
aware of.
Now, I should clarify that. I could take that out of your--the
realms of when you were in the fund-raising capacity because I have no
interest in knowing whether there were names sent back and forth when
you were a fund-raiser at the DNC.
But from the time that you were director of National Membership
Services, do you recall whether you would get a database or a spread
sheet of names from the White House for any purpose? And, you know, to
not be so mysterious, my understanding is that a lot of what you were
involved in doing was facilitating requests, helping people get things
done, and pretty much ad hoc situations where a few people would do one
thing or maybe more than a few people, but I am trying to determine
whether there was a reason for the White House to send you any list of
names of individuals.
The Witness. Not that I recall.
EXAMINATION BY MR. WILSON:
Question. Are you familiar with the White House database?
Answer. I am only familiar with it in the sense that I have read
about it in the newspaper.
Question. Is your knowledge of the White House database, then,
confined exclusively to media reports about its existence?
Answer. That's correct.
Question. Do you know if anybody in your office ever had access to
the White House database? And your office being the National Membership
Services office.
Answer. I need you to define what the White House database was.
Question. Well, I mean I am asking you that question, in terms of
are you familiar with something that was called the ``White House
database''?
Answer. As I previously stated, the only information I know about,
a broad database referred to a term of art, the White House database,
is what I have read in the newspaper.
Question. Did either you or any of your employees or colleagues in
the NMS have access to any White House computer database?
Answer. Yes.
Question. And what was that?
Answer. In the social secretary's office, there was a--as I
understood it, it was their own internal list of people that had
attended social secretary events such as a jazz festival for a thousand
people on the South Lawn or fireworks on the 4th of July or a private
dinner. And there would be occasion to almost exclusively call over to
the White House and say, in response to a White House request from a
different area, without getting into too many tangents, somebody at the
White House would say there is an upcoming event and if you would like
to submit a few names, you may do so.
Again, as I previously stated, no guarantee that those people were
getting in. Those weren't names submitted for specific slots; it is
just we are doing an event, if you would like to submit some names we
will consider them in the big list of names.
So in trying to figure out who to submit, I think there was an
interest not to keep putting in the same people. It wasn't fair for
someone to go three times if someone else hadn't gotten to go to the
South Lawn.
In that regard, we might call over and say, here are 10 names but
we only get to submit 3, can you help us figure out who has been,
because we might think that a person, a DNC supporter, had never been
to the White House and later we find out they have been four times
because we didn't invite them, the White House, of course, invites
them. So we wanted to try to preclude the same people being invited
over and over again.
So I might occasionally call over to say, I have a chance to submit
a few names as a request in response to--in response to a request from
a different department. Can you help me find out if any of these people
have been there at all? And they might respond back accordingly.
Question. And who did you call for help of that nature?
Answer. Oh, just staff in the social secretary's office.
Question. Did they ever send you lists of names so that you could
check yourself as to whether people had attended or not?
Answer. No. And as a matter of fact, they were pretty clear about
the fact that that was not the kind of information that they could ever
provide to us.
Question. When you were making requests of that nature, checking
to avoid duplication of people who would attend events, did you ever
have discussions with people in the social secretary's office or did
they ever ask you to send over names of individuals that they could
enter into their whatever type of database they were using to help
avoid duplication?
Answer. In the social secretary's office?
Question. Yes.
Answer. No.
Question. Do you know if any other DNC officials or colleagues of
yours ever would get lists of names from the White House to help
facilitate attendance at White House events?
Answer. I wouldn't know.
Question. Do you know if there was any political information, such
as whether a DNC--whether a person was a DNC trustee, whether that type
of information was contained in the information that the White House
kept on computer?
Mr. Lu. Are you referring to the social secretary's computer that
he has testified about or any other database?
Mr. Wilson. Any other.
Mr. Best. Do you know?
The Witness. I don't know.
Mr. Best. Okay.
EXAMINATION BY MR. WILSON:
Question. Did you ever work with Truman Arnold on providing names
of individuals to the White House for events that the White House was
hosting?
Answer. I never directly worked with Truman Arnold.
Question. Did he ever work with anybody in the National Membership
Services?
Answer. He may have but I am not aware of any.
Mr. Wilson. I will provide the witness with a letter from Al Gore
to B.J. Thornberry. If you would take just a moment to read through
this letter, please.
The Witness. Uh-huh.
Mr. Best. You understand that this letter was written after this
witness left the Democratic National Committee?
Mr. Wilson. Yes.
The Witness. Okay. I see the document.
EXAMINATION BY MR. WILSON:
Question. Bearing in mind that this letter did go to the DNC after
you had left, do you know of any discussions during your tenure as
director of NMS about a database kept by the Vice President?
Answer. No.
Question. Were you aware that such a database existed?
Answer. I was not aware of it until you presented this piece of
paper to me.
Mr. Best. This is almost a year after this witness has left the
Democratic National Committee.
EXAMINATION BY MR. WILSON:
Question. In arranging activities for DNC members, did you have
any contact with Ann Stock?
Answer. Yes.
Question. Do you recall what her position was?
Answer. She is--was, as I understand it still is, White House
social secretary.
Question. Why did you interact with Ms. Stock?
Answer. Because she, as White House social secretary, was
responsible for the planning of practically all the events at the White
House.
Question. Was her authority more or less over all of White House
events or did she have an area of concentration or expertise?
Answer. Well, I am sorry, it would be difficult. You would have to
talk to Ann Stock about what her responsibilities are. I just know her
as the White House social secretary.
Question. Did you have any contacts with Ricki Seidman----
Answer. No.
Question [continuing]. When you were at NMS?
Answer. No. I am familiar with her name. I did not have any direct
contact with Ricki.
Question. Do you know if any of your colleagues in NMS contacted
or worked with her at any time during your time at NMS?
Answer. What was her role? I don't know.
Question. Okay. Do you know--do you know who Mike Lufanio is?
Answer. Yes.
Question. And who is he?
Answer. There was a period of time, I believe, that Mike Lufanio
was either--he was a senior official in the Office of White House
Advance.
Question. And did you have any reason to contact him when you were
at NMS?
Answer. Well, I don't recall. I mean, I--I knew Mike outside of my
role as director and so I may have had contact with him, but I don't
specifically recall if there was a reason why professionally I may have
contacted him.
Question. Do you know whether or not he had any role in arranging
for people to fly on Air Force One or Air Force Two?
Answer. I don't know. I certainly didn't have any kinds of
conversations with him like that.
Question. At the time you were director of NMS, did you have any
conversations with Alexis Herman?
Answer. Not--not directly.
Question. Did you have any--did you relay requests to her
indirectly?
Answer. No. But she was in charge of the Office of Public Liaison,
which is, as I previously stated, was an office I did have contact
with. So, you know, my requests would be sent to the Office of Public
Liaison for which he was--whatever her title was, director, but I did
not have direct conversations--she didn't call me; I didn't call her. I
didn't bump into her in the hallway and stop and, you know, have a
conversation with her about anything.
Question. What does the Office of Public Liaison at the White
House do?
Answer. I don't--you would have to ask them specifically.
Generally, they handle outreach to the various constituent groups.
Question. Did you have any contacts, at the time you were director
of NMS, with Patsy - Thomasson?
Answer. I was introduced to Patsy. I specifically recall it was
just at a meeting and she was there, and I was introduced to her. And I
never had any kind of direct----
Mr. Best. The extent of your contact with her was this
introduction?
The Witness. It was.
EXAMINATION BY MR. WILSON:
Question. Do you recall whether any of your colleagues at NMS had
any contacts with Patsy - Thomasson?
Answer. I don't recall. Certainly it is possible but I don't recall
that.
Question. Earlier you mentioned the name David Levy. I believe I
recall that you mentioned it in connection with radio addresses.
Answer. Correct.
Question. Did you contact him on any other matters while you were
director of NMS?
Answer. Well, I would like to restate something I said earlier,
which is I don't recall that. He was in the Office of Communications.
It is possible that I perhaps contacted him on something else that fell
into the purview of the Office of Communications just because he was a
contact that I knew would take my call. We had a friendly relationship.
So it is possible I may have contacted him on something else. I don't
specifically----
Question. I may have misspoke. I didn't mean to put words into
your mouth and I may not recall correctly. So I wasn't trying to
characterize what you said about David Levy. I just remember you
brought the name up before.
Answer. Sure.
Question. What was his position?
Answer. Well, I don't know his specific title but he did work in
the--and I am not even certain of the exact title of the office but it
was basically the communications office. And, you know, we had common
interests so we would strike up conversations every once in awhile
about things totally unrelated to work. So it is possible that I may
have contacted him on something else, but I don't recall specifically
any reason to contact him professionally for anything other than to
submit those radio address requests.
Question. At the time you were director of NMS, did you have any
conversations with Jack Quinn?
Answer. Yes.
Question. And what did you discuss with Mr. Quinn?
Answer. In that sense, I definitely don't specifically recall.
Question. And do you recall why you contacted Mr. Quinn?
Answer. Well, he had a variety of responsibilities during his
tenure at the White House, including responsibility, I believe, as
chief of staff for the Vice President and, again, you know, in 19--oh,
you asked as director of Membership Services.
Question. Just director of Membership Services?
Answer. It is hard for me to separate the time lines. You know, I
have--you know, I have--I don't recall. It is possible.
Mr. Best. That's fine.
EXAMINATION BY MR. WILSON:
Question. Do you know who Marge Tarmey is?
Answer. No.
Question. At the time that you were director of NMS, did you have
any conversations with Maggie Williams?
Answer. Yes.
Question. And do you recall the subject matter of any of these
conversations?
Answer. I do.
Question. Could you please recount any of the conversations you do
recall, of the conversations you do recall?
Answer. The only conversation that I do recall, not that I
specifically recall the content of the conversation, but I remember
Maggie attending a meeting, one of the final meetings, of the White
House Christmas Card Project, as I refer to it, and I think something
may have come up in that conversation.
Question. Do you recall what you discussed?
Answer. I really don't. I mean, again, it--it couldn't have been
very substantive and it was at least 3 or 4 years ago.
Question. To the best of your recollection when you were director
of NMS, was that the one conversation you had with Ms. Williams?
Answer. That was actually the only time I believe that she and I
attended any kind of meeting or--yes, that's correct.
Question. Do you know Jodie Torkelson?
Answer. I know the name.
Question. Do you recall having specific conversations with Ms.
Torkelson?
Answer. I don't recall having any conversations with her.
Question. As director of NMS, did you have conversations with
Nancy Hernreich?
Answer. Yes.
Question. And what did you discuss with Nancy Hernreich?
Answer. I probably discussed a variety of things. She was in the
President's personal office.
I remember there was one DNC supporter in particular who had golfed
with the President once, and during the course of their outing this
particular supporter said to the President, I really would love to have
you come to my club once and play golf, and the President said, I would
love to do that, and I recall specifically this supporter contacting me
and said the President said it, he said it himself, could you please
call over and see if he would like to come and play golf with me at my
club. And I remember having that conversation with her.
I am certain I reached out to her on other times, you know, to say
that I had sent a photo over to the political affairs office but it
really would be great if the President could personally sign it, and I
know they would be getting in touch with her, those kinds of things;
real small things to try to be responsive to people's requests.
Question. Aside from the sort of back and forth of responding to a
particular request, do you recall whether she ever contacted you to ask
anything--to ask you to do anything?
Answer. Well, she may have had. I wouldn't preclude that. But I
don't have a specific recollection.
Question. Do you know Doug Sosnik?
Answer. Yes.
Question. Did you, at the time you were director of NMS, have
conversations with Doug Sosnik?
Answer. Well, I am sure I did. Again, I don't--I don't recall what
we may have talked about. You know, these are people who may be at
meetings that I am at. You know, I just----
Mr. Best. You don't have to explain.
The Witness. Okay. Thank you.
Mr. Best. Just answer his question.
The Witness. Thank you.
EXAMINATION BY MR. WILSON:
Question. Do you recall any specific requests Mr. Sosnik might
have made of you during the time that you were director of NMS?
Answer. I don't specifically recall requests that he may or may not
have made.
Question. Do you recall whether Karen Hancox ever called you and
asked you to do something?
Answer. I can't imagine that she would have called me to ask me to
do something for her.
Question. Do you have any recollection of specific requests that
you made of her?
Answer. Well, Karen was--I need to clarify this. Karen was a name
who I was told I should send memos to if I was sending a memo to the
Office of Political Affairs. So Karen and Doug Sosnik as well would
often be names on my ``to'' line on a memo. It doesn't necessarily mean
I was really requesting anything of Karen or Doug. I was just told
formally, if you are sending a request to the Office of Political
Affairs, send it to Karen or Doug. It would go to a staff person.
Whether it ever made it up the food chain to those folks, if they ever
saw my memos, I don't know.
Question. What type of memoranda would you send over to the White
House Office of Political Affairs?
Answer. These are all the kinds of things we have discussed,
somebody would like to get a birthday card for their 80-year-old
mother. Somebody would like, you know, to--whatever, attend--I know, go
to the President's box at the Kennedy Center. All of those kinds of
requests I would submit to the Office of Political Affairs for them to
decide how to appropriately disseminate and handle the requests or not
handle the requests in the White House. Once it got sent to Political
Affairs, they did whatever they did and they would provide the answer.
So I would send these memos of all different kinds of nature to
Karen or Doug. I just want to be clear about that in case you have a
series of memos with my name on it to Karen or Doug that, you know, I
probably talked to Karen Hancox half a dozen times in my whole life.
But I have probably sent several memos to her. I just want to clarify
that.
Question. Where else would you send written memoranda in the White
House, if anywhere?
Answer. Memos could have gone to Debi Schiff who, as we talked
about, was in charge of Kennedy Center tickets. It could have gone to
the photo office where sometimes the photos that we were seeking could
be found and purchased by the DNC, just as any outside person could
call the White House and say, I was at an event. Can I have a photo?
Sure, $8.80. That was my responsibility to go to the photo office and
perhaps look for a photo for someone, and perhaps send a memo along
with it. Maybe someone in the Office of Political Affairs, public
liaison, you know, we have talked about Ann Stock and the social
office, because I submit names for events. Mostly there was a lot of
hierarchy just as anywhere in the work world, there is a lot of--I
might have to put names on memos because I was told you need to make
sure this person gets copied and this person gets copied, but it is not
like I was dropping off that memo to all of their services. I would
send one memo over to one contact at the White House. However they
disseminated it, it was up to them.
Mr. Wilson. If we could go off the record for a moment.
Mr. Best. Yes.
[Off the record.]
[Whereupon, at 12:50 p.m., the deposition recessed to reconvene at
1:45 p.m. this same day.]
EXAMINATION BY MR. WILSON:
Question. Do you know whether regular meetings were held at the
White House to discuss invitation lists?
Answer. I need you to be more specific regarding invitations.
Question. To discuss any type of list of names that would be
invited--to people who would be invited to attend events at the White
House.
Answer. Yes.
Question. And did you attend such meetings?
Answer. Occasionally.
Question. Where were such meetings held?
Answer. They were either held in a room in the Old Executive Office
Building or they were held in the Roosevelt Room in the West Wing.
Question. What types of events were discussed?
Answer. Upcoming dinners, events on the South Lawn, events like
that.
Question. Were there ever spaces allocated for different types of
attendees at such dinners?
Answer. There were spaces allocated for the number of names we
could submit to attend such events, but I don't know if the White House
allocated a certain number of spaces.
Question. Were there different numbers allocated for different--
for official events as opposed to private events?
Answer. No, the difference in any kind of allocation number would
be, you know, the location of the event. A South Lawn event obviously
could accommodate more people than a--than a dinner in an interior room
could accommodate.
Question. Were bill-signing ceremonies discussed during these
meetings?
Answer. Not that I recall.
Question. Do you know whether the DNC used the Indian Treaty Room
for any purpose?
Answer. I believe that they did.
Question. And do you know for what purpose?
Answer. I don't, but the Indian Treaty Room was used by all kinds
of groups for, you know, receptions, and I'm sure the DNC--I recall the
DNC, you know, hearing about the fact that the DNC was going to do
events there, but I don't know specifically what the events were.
Question. Do you know whether the DNC had an auto pen for the
President's signature?
Answer. At the DNC?
Question. Yes.
Answer. Not that I'm aware of. I would say no.
Mr. Best. Do you know? Do you know whether they had the pen?
The Witness. I can't say with certainty, but I don't believe that
there was such an auto pen.
EXAMINATION BY MR. WILSON:
Question. Did you or your colleagues at NMS ever draft letters to
be signed by an auto pen with the President's signature?
Answer. No.
Question. Did the National Membership Services' office ever handle
letter requests to go out to individuals, series of letters that would
be sent to a group, a number of people at one time?
Answer. I'm not sure I understand the question.
Question. Did your office ever have letters go out over the
President's signature?
Answer. No.
Question. Did your office ever generate any letter that was signed
either by the President or the auto pen using the President's
signature?
Answer. Not that I'm aware of.
Question. Did your office ever draft notes that ultimately would
be sent out over the President's name?
Answer. Not that I recall.
Question. I ask this because my understanding is, there are many
pieces of correspondence and they aren't necessarily drafted always by
the same person who signs them; and I'm just trying to get a sense of
whether there was anything that went out of your office that
ultimately--a form letter of any sort that would be signed by the
President.
Answer. I--not that I'm aware of. Again, I appreciate that, but not
that I'm aware of.
Question. Are you aware of your office procuring gifts of any sort
for DNC supporters?
Answer. Yes.
Question. What types of gifts would your office get for
supporters?
Answer. Well, actually, we initially, in '94 in the initial stages
of the program, helped try to obtain items that the DNC was paying for
that the White House was giving out as gifts, a business card holder,
presidential cuff links. Events like--or gifts like that.
And there was a feeling that if the DNC was paying for these items,
maybe we could try to get some items too. But I didn't actually--so
perhaps a modification of the previous question, I didn't actually
procure these items. I didn't actually purchase the items, but
initially, when the DNC kind of got into this business of having to pay
for these items, some of those items ended up in my shop.
Question. And----
Answer. That actually stopped, though, pretty quickly. Somebody
else--it wound up being that the Chief of Staff had responsibility, or
the Chief of Staff's office at the DNC had responsibility for
procuring, obtaining, holding those items.
Question. And when did the change occur?
Answer. Well, I don't specifically recall, but sometime in '94.
Question. How would you determine who received one of these types
of gifts?
Answer. Well, again, that was--that was part of the reason why we
wound up not having responsibility for that for very long because it--
it really wasn't something appropriate for us to decide who should or
should not have gifts, because we didn't really have relationships with
any of these people.
You know, the reason I initially got involved in it was because
they saw me as someone who would try to help, you know, resolve the
situation. And I--somehow it just ended up on my desk.
It was just basically assigned to me, you will get the gifts. Okay,
fine, I'll get the gifts. Not purchase, but when they arrive, we are
going to give you some of the gifts.
So when they arrived, they were put in my office and, well, I
didn't know what to do with them. And meanwhile everybody else wanted
to have their hands on the cuff links and the other gifts, so they were
pretty quickly taken from our shop, not because we had done anything
wrong, just there was no real reason for us to have them.
Question. When you did have control of the gifts, did people ever
make requests of you on the forms that you sent around to the various
offices, the request forms that the offices had to give something to
somebody or send something to somebody?
Answer. No, not that I recall. I mean, they may have, but it
wouldn't have been my responsibility to provide it, again, to the
supporter out there. So somebody came down and said, gee, I'd like to
have one of those pens with Bill Clinton's signature on the pen. It
was--that's why they had been given to me and stuck in my drawer. It's
not like it was a candy jar where people could come take them, but
there were very limited numbers and they were there. And I wasn't the
person reordering them, and I wasn't restocking them. It really was not
something that was around for very long.
Question. Do you recall at the time you were Director of NMS
whether you actually did directly give one of these types of gifts to
somebody who wasn't a DNC employee?
Answer. Yes. I don't specifically recall, but--who, but, yeah, you
know, there was a drawer full of these, and I'm sure, you know, they
were----
Question. Do you recall how you got the gift to the recipient?
Answer. I don't.
Question. Did you ever help arrange for DNC supporters to watch
sporting events in the White House residence?
Answer. No.
Mr. Best. I take it you're referring to televised sporting events.
Or actual boxing matches at the White House?
Mr. Wilson. I was being very general, not aware of any boxing
matches at the White House. I would have been interested in the
response if there was such an event.
The Witness. I do want to be clear that there are sports teams that
come to the White House.
That's not what you're talking about? You're talking about watching
an event that's on TV at the White House?
Mr. Wilson. Yes.
The Witness. No.
EXAMINATION BY MR. WILSON:
Question. You had mentioned earlier that you attended on occasion
the daily scheduling meetings for the President. Did any other DNC
employees go with you to attend these meetings?
Answer. Yes, initially Jay Dunn went with me and then later, after
Jay had left the program, and Brooke was--Brooke Stroud, who I
previously mentioned, became the Deputy, she would attend those
meetings.
Question. After attending such meetings, did you serve as a
liaison to other offices within the DNC to communicate information to
them about the President's schedule?
Answer. Yes.
Question. How did that work?
Answer. Well, sometimes verbally I would say--you know, pass on
information I had learned. Sometimes maybe I'd send a memo to
department heads and say, this is what we've--you know, this is what
we've learned in the meeting, whatever the appropriate information was.
Question. Did you have a usual practice?
Answer. Well, I know that I tried to forward schedules on to people
as schedules were made available for us, all internal, not to be
distributed outside the DNC. But sometimes it would just be verbal or
there actually wouldn't be a printed schedule.
Question. Was there a distinction between the official and private
schedules for the President when you attended the meetings that you
attended?
Answer. Well, the only schedules that I saw were the ones that they
were willing to also let the Office of Public Liaison and the DNC and
other offices know. So I never--I don't know the term of art, ``private
schedule,'' I don't know how that is necessarily defined. But I would
not be given information about, you know, certain private meetings that
the President might be having. During certain blocks there would just
be something like private time or down time in some of the schedules,
as I recall.
Question. Were you ever the DNC liaison for official overseas
delegation trips by senior administration officials?
Answer. Just, it's been so long, it's just--I don't remember a
specific trip where I may have been.
Question. Do you recall whether people contacted you and told you
that there was a trip, an upcoming trip about to occur, and asked for
any input as to whether you had any suggestions for people to go on the
trip?
Answer. Yes.
Question. And on what occasions; do you recall?
Answer. Well, I do recall specifically there was a gentleman named
Howard Glicken who wanted to go on a trip to South America, and he
was--you know, he had contacted the DNC several times and was trying to
also deal with the White House. And I think he was looking for every
possible open door that he could find to help try to move his name
along.
Question. Did he contact you directly?
Answer. Howard did, because I knew Howard from my previous role at
DNC. Others generally were supposed to contact a relevant department
within the DNC, because again I didn't know many of these people, these
names, so they wouldn't have known me to call me; but had they called
me, I wouldn't have known who they were.
And again, I wasn't the final decision-maker on that. I might
forward information along, I've been contacted by someone, he's
interested.
Question. Do you recall other people that you were contacted by in
relationship to trips?
Answer. Well, he's the only one I specifically recall.
Question. Do you recall whether you were ever contacted by Ernest
Green in relation to a trip?
Answer. Not that I recall.
Question. Do you recall whether anybody mentioned to you Mr.
Green's interest in being part of an official delegation on an overseas
trip?
Answer. Again, I don't recall that right now.
Question. Do you know if any DNC employees went on official
delegation trips abroad?
Answer. What do you determine an official delegation trip?
Question. Well, any----
Answer. Paid for by the administration?
Question. Paid-for-by-the-administration trip?
Answer. Not that I'm aware of.
Question. Do you know of any DNC employees accompanying officials
who were going overseas to perform some type of government function,
attend an event, attend a funeral, attend a meeting or a conference or
that sort of thing?
Mr. Lu. When you say ``DNC official,'' would you include Chairman
Dodd as a DNC official?
Mr. Wilson. Yes.
Mr. Lu. Okay.
The Witness. Well, I still don't--the answer is no, even including
the Chairman. He kept his own schedule; I wasn't aware of it, and at
this point, I don't remember the trips that the Chairman may have taken
a few years ago.
EXAMINATION BY MR. WILSON:
Question. Have you ever met Mark Middleton?
Answer. Yes.
Question. When did you first meet Mr. Middleton?
Answer. I vaguely remember in 1993, perhaps maybe '94. Sometime in
the first year that I was at the DNC, a year or two, so I would say
probably 1993--probably.
Question. Did you ever work with him on any project?
Answer. I may have. I may have, but I don't specifically--I can't
recollect a specific project that I might have been working with him
on.
Mr. Best. I'm not quite sure I understand what a ``project'' is as
you have used the term. Trying to get someone a seat on a tour might be
a project as you have defined it.
Mr. Wilson. I was going to follow up and ask whether----
EXAMINATION BY MR. WILSON:
Question. And my understanding is, Mr. Middleton was a White House
employee at the time you were the Regional Finance Director?
Answer. Right.
Question. And so did Mr. Middleton ever make requests for you to
do anything on his behalf?
Answer. Really not that I recall.
Question. Do you know whether Mr. Middleton was affiliated with
the DNC in 1996?
Answer. I didn't work at the DNC in 1996, so I don't know.
Question. Do you know whether Mr. Middleton assisted in organizing
any fund-raising events for the DNC?
Answer. I'm not aware of him doing that.
Question. Are you aware of whether Mr. Middleton hosted any fund-
raising events on behalf of the DNC?
Answer. I'm not aware of Mark Middleton hosting any events.
Question. Do you recall whether Mr. Middleton ever contacted you
to arrange tours of the White House?
Answer. No, he did not contact me to arrange tours. And as I stated
before, when we went kind of down this line of questioning regarding
the President's box at Kennedy Center, he had worked in the Chief of
Staff's office at the White House. So if you are asking about the
period while he wasn't at the White House, he wouldn't come to me--
because he worked at White House--looking for a White House tour. He
wouldn't have called the DNC. And he never came to me after he left the
White House, and I'm assuming because he knew dozens and dozens of
people at the White House, including his former boss, Mack McLarty,
whom he could have called.
Question. Do you know whether he contacted any of your colleagues
at NMS after he left the White House to help arrange for tours or,
well, to help arrange for White House tours?
Answer. I don't know if he contacted any of my colleagues. I do
know he did not contact me.
Question. Do you know who Holli Weymouth is?
Answer. No.
Question. Do you know if Yusuf Khapra ever contacted you to
arrange tours of the White House?
Answer. No.
Question. You know that he did not contact you to arrange tours?
Answer. Yeah, Yusuf didn't contact me to arrange tours. He only--my
knowledge of Yusuf was in his role when he worked for the Chief of
Staff.
So, again, just as I previously answered with Mr. Middleton, I
don't know why someone from the White House would contact someone from
the DNC to get a tour of the White House. And those people were all
capable of giving--you know, they all had hard passes, and they could
conduct a tour themselves. So I don't know why they would call me, with
limited White House tickets and no White House access, to give a tour.
Question. Did Mr. Khapra ever contact you for any other reason?
Answer. He was a staff person in the Chief of Staff's office who I
occasionally had conversations with. But I don't remember if he called
me or I called him and I certainly don't recall any kind of specific
conversation with him.
Question. Why did you have conversations with Mr. Khapra?
Answer. I know this is going to sound crazy, but I don't know why I
had conversations with him. He was a White House staff person that I
had come in contact with, so--but I don't recall the specifics of our
conversations that occurred more than a couple of years ago.
Question. Do you recall anyone making a request of either you or
your office to make arrangements for a White House tour for the Widjaja
family in 1995?
Answer. When in 1995?
Question. Late, late in the year.
Mr. Best. He left in September.
The Witness. Well, I left the DNC in September of 1995.
EXAMINATION BY MR. WILSON:
Question. Again, I will ask you--I'm not certain of the time
myself--do you recall anybody making a request of your office to
arrange for a tour of the White House for the Widjaja family?
Answer. No. And again tours, even though they were officially under
my jurisdiction, I just--whenever a tour request came in, I would
provide it to my staff person who was responsible for all aspects of
tours. I didn't feel like I needed to check with her to find out who
she was providing White House tickets to.
Question. Are you aware any of member of the Widjaja family
contacting any DNC employee?
Answer. I'm not. And I also have to tell you, I've never heard the
name before until you mentioned it about two questions ago.
Question. That helps, and I'll move on.
Answer. Sure.
Question. Do you know Charlie Trie?
Answer. I've never met him. I am aware of Charlie Trie, but I
became aware of Charlie Trie just in name only.
Question. Have you ever spoken with Mr. Trie?
Answer. No.
Question. Are you aware of any of your colleagues at the NMS being
in contact with Mr. Trie?
Answer. I am not aware of any of my colleagues--in the National
Membership Services program dealing directly with him. Again, it is
possible, as we talked about earlier, but I--I--you know, my staff had
their own conversations that I wasn't fully briefed on, but I'm
certainly not aware of it.
Question. Are you aware of any White House tours that were
arranged for Mr. Trie or on behalf of Mr. Trie?
Answer. No.
Question. Are you aware of any occasions in which it was arranged
for Mr. Trie to have lunch at the White House mess?
Answer. No.
Question. Are you aware of any occasion on which Mr. Trie used the
President's box at the Kennedy Center?
Answer. No.
Mr. Wilson. I'm showing the witness a memorandum to Debi Schiff and
Donald Dunn for Mr. Sildon.
The Witness. Okay.
EXAMINATION BY MR. WILSON:
Question. Does this--do you remember drafting this memorandum?
Answer. Well, I don't remember it, but that's certainly a form that
I used, and I'm--I will tell you, I'm confident I wrote that, but I
would like to comment on it if I can.
The White House asked me, whenever someone used the President's
box, to report back to them the name. In other words, the White House
might call and say, we have two tickets for tomorrow night's
performance; would you like them? And I would then go to different
departments at the DNC, maybe the Chairman's office or Political or
Finance, and say, listen, we've got two tickets, and if somebody can
use them, let me know. And then somebody might come back to my office
or call me on the inside line and say, okay, we can use them.
Let's take, for example, Political would say, yep, we can use the
two tickets; and I'd say, great, and I'd get the two tickets and I'd
provide them to the person in Political Affairs, DNC Political Affairs.
And when I handed them the tickets, I would say, here are the tickets,
here is the information on the show, but you need to provide back to me
the name of the person who's using the tickets; and they would say,
fine, and then after the fact, or on the day of the fact or whatever,
they would say, okay, this is the name of the person we've given the
tickets to.
So, I do see this, I did write this memo, I'm confident I did
because it's that, but I didn't do anything other than provide two
tickets to a staff person at the DNC, who did their job and reported
back to me the name of the person who used the tickets.
Mr. Best. When, in September of 1995, did you leave the DNC?
The Witness. And I left right around that date. I actually was
hired sometime in mid- to late-September, and I don't recall the exact
date; but I think it was around the 20th of September that I was hired
by the Democratic Governors Association, and I actually started working
there the next week.
Mr. Best. So the record is clear, the memorandum which is EOP
051237 is dated September 15th, 1995.
EXAMINATION BY MR. WILSON:
Question. When you received indication that there were tickets for
an event, did you have a usual method of letting other people in the
DNC know that you had those tickets?
Answer. Yeah, I'd send out a memo or an e-mail. I might e-mail
department heads and say, I've been contacted by the White House, and I
have two tickets for--using this example, two tickets for tomorrow
night's performance of something, of the National Symphony Orchestra;
if you would like the tickets, if you can use the tickets, please
contact me.
Question. And how did you decide who would end up getting the
tickets?
Answer. Well, it was always first come, first served. If somebody
raced down and said, we definitely have somebody who wants them, I'd
say, that's great, here are the tickets; or I'll get the tickets sent
over, and I'll get them to you.
Question. Did Susan Lavine ever discuss with you being on the
permanent admit list to Charlie Trie's Watergate apartment?
Answer. No.
Question. Were you aware during the time that you were Director of
NMS that she was on the permanent admit list to Mr. Trie's Watergate
apartment?
Answer. No, I was not while I was Director. And, in fact, I will
tell you, I did not know that until you just told me that. Nor did I
even know Charlie Trie had a corporate apartment at--where did you say,
the Watergate Hotel?
Question. Watergate.
Answer. I was not aware of that until just this moment.
Question. Do you know Pauline Kanchanalak?
Answer. I have met her before.
Question. Where did you meet her?
Answer. I met her at--I don't recall the exact--the specific
function, but I know I met her while I was fund-raising for the DNC.
Question. Did you ever have any conversations with her when you
were the Director of the National Membership Services?
Answer. I may have. I--I don't recall specifically whether I did or
not.
Question. Did you ever arrange introductions for Ms. Kanchanalak
to meet administration officials?
Answer. Again, not that I recall specifically. I don't believe that
I made a phone call on her behalf. I really didn't know--I mean, I met
her, but I didn't really know her.
Question. Do you have any general recollections of requests made
by Ms. Kanchanalak to meet with administration officials?
Answer. Can I have a moment?
Question. Sure.
[Witness confers with counsel.]
The Witness. I don't recall.
EXAMINATION BY MR. WILSON:
Question. Did Ms. Kanchanalak ever ask you to assist her in any
way?
Answer. No, the only time I spoke to her, again, was just at some
event prior to my days before National Membership Services.
Mr. Wilson. Providing the witness with a document. It appears to be
a memorandum to Mr. Sildon from Luren Supina. If you would take a
moment and review the document.
The Witness. Okay. I see this document.
EXAMINATION BY MR. WILSON:
Question. Do you recall Ms. Kanchanalak's name coming up in
relationship to the Bureau of Labor Statistics?
Answer. I see it here. It does not refresh my recollection.
I also will indicate that despite the fact that Luren Supina says
in her memorandum that Pauline Kanchanalak mentioned that she's working
with me, if you'll notice, the handwritten notes down below indicate
that I was not speaking with Pauline; I was speaking with someone on
her staff who never sent a request over in writing and, therefore, I
never provided it.
On September 9th, I indicated if she wanted me to try to do
anything, she would need to send it over in writing; and on the 15th, I
called to say we discussed this a week ago and I don't have any written
information. The assistant indicated that he wasn't going to put the
request on paper, and I indicated that I'm not proceeding ahead with
it. And I do see it here, but I don't recall it.
Question. Do you know whose handwriting this is?
Mr. Best. Where?
The Witness. Where?
Mr. Wilson. On the document.
The Witness. The handwriting below the line and, for sure, the
handwriting where it says ``9/8'' is mine.
EXAMINATION BY MR. WILSON:
Question. Do you know, I'll work from the top of the document
down. There's a telephone number written right next to Ms.
Kanchanalak's name on the ``re:'' line. Do you know whose handwriting
that is?
Answer. I know this may sound interesting, but it may be my
handwriting, but I'm really not certain. It looks like it has the
potential it could be mine, but it looks like either I was writing
quick or somebody else wrote that. That doesn't really look like my
handwriting.
But from ``9/8'' down, I would say that's probably my handwriting
and certain--``9/9'' and ``9/15,'' that is certainly my handwriting.
But again, even though I see it here, it doesn't refresh my memory.
Question. Do you recall whether you made any contacts with other
DNC employees about this general subject matter?
Answer. You mean this specific request?
Question. The mention in the memo, yes.
Answer. I mean, I may have discussed it with Luren Supina who sent
the memorandum to me.
Mr. Best. Do you have a recollection of that?
The Witness. But I don't recall that.
EXAMINATION BY MR. WILSON:
Question. What was Ms. Supina's position at the time the memo was
drafted?
Answer. Luren was the director of a program that was called
something to the effect of the Women's Leadership Forum; they changed
names during the course of that period of time that I was Director of
National Membership Services, but she was essentially--that's a donor
council within the DNC, and she was--she had gotten it up and running
and was its Director, or whatever the title may be, but she ran the
council.
Question. Do you know why she would have directed this memo to
your attention?
Answer. Again, because as Director of National Membership Services,
I think she was hoping that I could--I don't know why she----
Mr. Best. Do you know?
The Witness. No, I don't know why she sent me the memo.
EXAMINATION BY MR. WILSON:
Question. Do you recall having any conversations with any
employees of the Bureau of Labor Statistics in 1994?
Answer. No.
Question. Were you aware at the time that Ms. Kanchanalak
expressed an interest in being invited to a lunch at which the Queen of
Thailand was also in attendance?
Answer. I have a vague recollection of that.
Question. Did Ms. Kanchanalak contact you directly about this
event?
Answer. I don't believe she did.
Question. Do you recall whether she contacted anybody else in your
office about the Queen of Thailand lunch?
Answer. I really don't recall. I just don't recall.
Question. Do you know whether you ever helped to arrange for Ms.
Kanchanalak to meet with any administration officials at the time you
were Director of Membership Services?
Answer. I don't recall.
Question. Do you recall whether you helped Ms. Kanchanalak to meet
with any administration officials at the time that you were Regional
Finance Director?
Answer. No, I would not have done that.
Question. Were you aware at the time that you were Director of NMS
that Ms. Kanchanalak was a financial contributor to the DNC?
Answer. Yes, I knew that she was a contributor.
Question. Did you know whether or not she was--she herself was
making contributions to the DNC?
Answer. I did not know the source of the contribution.
Question. Was it your understanding at the time that she was
making--she was, herself, making contributions to the DNC?
Answer. Well, it's not something that I ever would have thought
about. You know, some people are members of our Donor Council because
they raise a lot of money and they never write a check themselves. So I
don't look at people and figure out, who is a raiser and who is a
writer; they're a member of the Donor Council. I had no reason to
assume that either she did write checks or she didn't write checks, or
that she raised--it just wasn't a factor, and particularly when I was a
Director of National Membership Services, I didn't care about the
money. I just wasn't focused on that.
Question. Do you know John Huang?
Answer. I have met John Huang. But I met John Huang after I left
the DNC.
Question. When did you meet Mr. Huang?
Answer. When I was working for the Democratic Governors Association
in 1996.
Question. Did you at any time speak to Mr. Huang when you were the
Director of NMS?
Answer. I did not.
Question. Are you aware of any arrangements made by any of your
colleagues at NMS on behalf of Mr. Huang?
Answer. I--I'm not aware of it, no.
Question. Do you know whether any of your colleagues at NMS spoke
directly with Mr. Huang?
Answer. I can't--I can't speculate on what my colleagues at NMS
did, whether or not they talked to him.
Question. But you have no recollection or knowledge of whether
they did or did not?
Answer. That's correct.
Mr. Best. You understand that Mr. Huang did not become an employee
of the DNC until after the witness left the DNC, and so you may be
asking him about conversations, if any, that took place after his
employment at the DNC?
Mr. Wilson. Right. I do understand that.
EXAMINATION BY MR. WILSON:
Question. Are you aware of either your colleagues or anybody at
the DNC making any arrangements on behalf of Mr. Huang to visit the
White House or meet with anybody at the White House?
Answer. No, I'm not aware.
Question. Are you aware of any requests made either to yourself or
colleagues at the NMS on behalf of the Riady family?
Answer. No.
Question. Specifically are you aware of any requests made on
behalf of James Riady?
Answer. No.
Question. Are you aware of any requests to either visit the White
House or meet with any government official on behalf of Mr. Mochtar
Riady?
Answer. No.
Question. Do you have any knowledge of whether anyone suggested
that the Riady family be invited or any members of the Riady family be
invited to the White House?
Answer. Can you read the question again?
[The reporter read back as requested.]
The Witness. No.
EXAMINATION BY MR. WILSON:
Question. Do you know what the TRULIST was, spelled T-R-U-L-I-S-T?
Answer. No.
Mr. Wilson. I'm providing the witness with a document that is
titled at the top DNC Finance Executive Summary dated 7/26/94. And the
record can reflect, this does not indicate that Mr. Sildon's name
appears at all on this document.
There is a handwritten notation at the bottom deleted from TRULIST,
7/26/94.
EXAMINATION BY MR. WILSON:
Question. Does this provide any additional assistance to your
being able to recall what the TRULIST is?
Answer. It doesn't. I don't recognize that at all. And again, I was
not a member of the Finance staff in July of '94, so it could be
something that was--that they were aware of. I'm not. I don't know what
that is.
Question. Do you know why Mr. Huang was invited to attend the
state ceremony for the arrival of Boris Yeltsin in 1994?
Answer. No, I really don't.
Mr. Wilson. I'm providing the witness with a document that's a
memorandum to State Arrival Coordinating Committee from Mr. Sildon, and
it lists Mr. Huang as an individual who did not pick up tickets for the
state arrival ceremony for Boris Yeltsin.
Mr. Best. So the record's entirely clear, Mr. Huang's name is one
among something like 50 names on a list on this document, which is F
0013666.
EXAMINATION BY MR. WILSON:
Question. Do you recall receiving a list of potential invitees to
the state arrival ceremony for Boris Yeltsin?
Answer. Well, I need to explain how this works, and I think this is
important to do.
The White House would invite literally somewhere between 6- and
10,000 people to the South Lawn to watch an arrival ceremony, including
members of the public, but you actually had to have a ticket to get
onto the grounds.
As the Director of Membership Service, I was the one responsible
for sending a memo to all departments at the DNC saying, we have X
number of tickets, which usually was 300 or more, to be among the 6-,
8-, 10,000 people on the South Lawn to attend an arrival ceremony. It's
not like you're up close; you're just on the lawn.
And I would offer to all department heads the opportunity to
provide me with some certain amount of names, and usually it was
divided evenly; Political could have 50 names and Finance could have 50
names and the Chairman's office; and everybody could have whatever the
appropriate number was, and all they had to do was simply give me a
name, date of birth and Social Security number. And I provide that to
the White House, and they do their own background check with the Secret
Service to make sure that the person could get on the lawn which they
would fill out with the person's name. So I get a list back for Robert
Clay, Joan Coplan, Elizabeth Dozoretz and Paul Equale--I would get a
list with 300 names on it, and then people could come over to the DNC
and collect their ticket.
I simply have sent this memo to the State Arrival Coordinating
Committee. All those names in the upper right are people who are heads
of departments at the DNC so you can see it went to literally like 10
or 12 different departments at the DNC saying--I don't even know who
gave me these names; I am going to tell you, all the names didn't get
their tickets, so if you happen to recognize their names, you can do
whatever you need to do, but we have a ticket downstairs in the lobby,
approved by the Secret Service that they are not a security risk, that
they can be one of 6-, 8-, 10,000 people on the South Lawn. That's what
this memo is.
So I see here that John Huang's name's on there, but as my counsel
pointed out, he is one of 50 names. Don Fowler, before he was Chairman
of the committee, is one of the people whose name's on here. I didn't
even know Don Fowler in 1994. He was some gentleman from South
Carolina, and I didn't pick up his ticket. I didn't know how to get in
touch with Don Fowler.
I appreciate that John Huang's name's on this memo, but that is
because I'm going through a list and seeing it on a list and going
through the memo.
Mr. Best. Half of humanity is on this list.
EXAMINATION BY MR. WILSON:
Question. What was the State Arrival Coordinating Committee?
Answer. That's just a name made up for the people in the DNC for
who is going to be the liaison from Communications and from Political
Affairs, and then the state chairs, and----
Question. You mentioned earlier that you might have as many as 300
tickets to allocate. Would you send over a list to the White House of
all of the DNC invitees?
Answer. Yes, because the White House had to run--as I previously
stated, the White House had to run that list through Secret Service,
checking out their date--I had to provide to the White House their
name, date of birth and Social Security of the people that we wanted to
have fill those slots; and this was really one of the only times where
the White House would say you get this many slots and that many people
can go.
We previously talked about dinners. It's not that I had a slot for
a dinner; they'd just say, provide a name and we'll see whether they
fit in. But for arrival ceremonies, when Boy Scouts would come and out-
of-town guests would come, they said, look, we are going to print 6,000
tickets and you can have 300 of them.
Question. Did the White House ever reject any of the suggestions
that you sent over to them?
Answer. Not that I'm aware of.
Mr. Best. Is there a difference between rejecting and not giving a
ticket to?
EXAMINATION BY MR. WILSON:
Question. Yes, I'm specifically asking, did you ever get an
indication, call, memorandum back saying, you have indicated that you
want so-and-so invited, and we do not want that person invited?
Answer. Not that I recall.
Question. Did you generally prepare a memorandum indicating who
had not picked up tickets for large events that had multiple tickets to
be given out to people?
Answer. Well, I actually think that I stopped doing the memorandum
because, as you can see, a fourth of the list doesn't pick up their
tickets, you know. And so after a while, people didn't really care.
They wanted to offer someone--people in the DNC didn't care if
someone did or didn't pick up their ticket. If they offered a ticket to
Joe Smith, as far as the person in the Office of Political Affairs of
the DNC's concerned, that's good enough. They've offered Joe the
ticket. If Joe doesn't pick it up, Joe doesn't pick it up, but he had a
chance to go.
So I stopped writing these memos because nobody cared about the
information. It wound up being a waste of my time.
Mr. Wilson. I'll mark this document as Exhibit ES-1 and submit that
for inclusion in the record.
[Sildon Deposition Exhibit No. ES-1 was marked for identification.]
[Note.--All exhibits referred to can be found at end of
deposition.]
EXAMINATION BY MR. WILSON:
Question. Do you know Mr. Johnny Chung?
Answer. I do.
Question. Where did you first meet Mr. Chung?
Answer. He was introduced to me at some point by someone on the
finance staff. I met him after I became director of National Membership
Services.
Question. Did you meet him on more than one occasion?
Answer. After I initially met him, I did see him on other
occasions.
Question. Approximately how many times would you have met him?
Answer. He would just show up at the DNC, so I would say probably
half a dozen times, give or take one or two. But, you know,
approximately half a dozen times.
Question. Did Mr. Chung ever telephone you?
Answer. Yes.
Question. Approximately how many times did he call you?
Answer. I couldn't recall with certainty, but approximately the
same number of times.
Question. And why did he call you?
Answer. Well, I--I--he had a variety of requests.
Question. If you could, be a little bit more specific on the types
of requests and the specific requests that he made of you.
Answer. Well, let me say I don't recall why he called me every
time. I do recall at least one specific time and, candidly, I--I recall
it and it has been further reinforced by all the news articles that
have been about a particular time.
He--he went to a White House radio address that I was not
responsible for submitting his name for. I did not even know he went to
the address until he called me to say, last week I got to go to the
radio address, and I really would like to get--and my picture was taken
with the President, and I had a few friends there, and their pictures
were taken with the President; can you help me get the pictures?
This was--this was not highly unusual that someone who goes to a
radio address gets their picture taken with the President, little kids,
basically if you're in the room, the President if he has time will
shake everyone's hand and you get your picture taken or maybe you
brought your own camera. Usually a picture is taken.
So I called over to the White House in response to a phone call I
got from Mr. Chung asking for his photos.
Question. Do you recall when that was?
Answer. The only reason I recall it is because I've read in the
newspapers approximately the date, and that was March of 1995.
Mr. Wilson. Providing the witness with a document, it is a--this
is a letter to Mr. Sildon from Johnny Chung dated February 27, 1995.
EXAMINATION BY MR. WILSON:
Question. Do you recall receiving this letter?
Answer. I actually do recall receiving this. Can I tell you why I
recall it?
Question. Absolutely.
Answer. Because it was one of the most preposterous letters I had
ever received in my life. Somebody just calls me and says, I want to
meet with the President and the Vice President. You know, I had never
seen anybody who thought that all they had to do was send a letter and
then they could meet with the President. I have never arranged a
meeting with the President, so I also thought it was, I mean, with all
due respect, a little laughable, that somebody would send me a letter
thinking I could just pick up the phone and arrange a meeting with the
President on his behalf, regardless of the merit of whether or not such
a meeting should occur.
Question. What did you do after you received this letter?
Answer. Well, I believe I did not move very hard--very--I was not
very active to pursue these requests. It is possible that--first of
all, I know that I talked to Martha Phipps, who was my supervisor, and
showed it to her. I may have talked to others about it. And I believe
that I probably tried to get him a tour of the White House, and it is--
anything else beyond that point I don't particularly recall.
Question. Do you recall whether you replied in writing to him?
Answer. I would be very surprised if I replied in writing, because
I seldom had time to do my job as it was, let alone take time to sit
down and write letters to people who contact me. Plus, again, just I
can't imagine I would have considered it a very serious request.
Question. Did you discuss this request with anybody else at the
DNC?
Answer. Besides Martha Phipps, who I previously mentioned?
Question. Yes.
Answer. I may have. I don't recall.
Question. Do you recall receiving other faxes or letters from Mr.
Chung?
Answer. If you have something to show me, I would be happy to
respond to it. I don't particularly recall whether or not he sent
another fax as a follow-up to this or any other kind of request.
Question. You discussed earlier the Presidential radio address and
photographs that were taken at the address. Did you know in advance of
the radio address who Mr. Chung's guests were?
Answer. No. Are you talking about these business leaders from
China, as he describes in this letter?
Question. Actually, I have moved from this. I am not referring to
this document at all at this point.
Answer. Okay.
Mr. Best. There is a problem with your question because he does not
know of the radio address until after the event when Mr. Chung calls
him and seeks the photographs. Implicit in your question is that he had
some knowledge prior to the radio address, and he has already testified
the first thing that he knows about it is subsequent to the event when
Mr. Chung calls him.
Mr. Wilson. Actually, just to clarify that for myself.
EXAMINATION BY MR. WILSON:
Question. Short of going back, was the first time you knew of the
photographs and the radio address after the actual event?
Answer. Yes.
Question. Were you made aware, when you did learn about the event,
of who the guests of Mr. Chung were?
Answer. No. And I actually even today don't know who they are,
other than having read in newspaper articles within the last few
months.
Now--you know, I did not know who these people were; basically
still don't. I couldn't tell you today what any of those people do and
if they are from China; I couldn't tell you what they do right now even
having read the newspaper articles. I don't know who these people are.
Question. Did Mr. Chung request directly of you to get help to get
the photographs from the White House?
Answer. Yes.
Question. And how did he do that?
Answer. He called me. He either called me or stopped by my office.
That, I don't specifically recall. But I do know that he issued the
request.
Question. And what did he tell you at that time?
Answer. It was just--he made it sound very innocuous. He had been
to a radio address and pictures were taken, could I help him obtain the
picture. It sounded at the time innocuous to me because that's--as I
indicated before, that's standard practice, if you go to a--not
standard but pretty common practice, if you go to a--if you go to a
radio address, you can get your picture taken.
Question. And what did you do?
Answer. I called over to the White House to see if we could help
him get his pictures.
Question. And what were you told?
Answer. After somebody said that they would check on it, they
called me back and they said that those pictures wouldn't be made
available.
Question. Did they give you a reason why they wouldn't be made
available?
Answer. They did. They--I actually do recall this because it's the
first and only time it has been told to me. They said, the pictures
aren't available because the President doesn't want them released and
the National Security Council is--does not believe they should be
released to him. They are concerned about his guests.
Question. And who told you this?
Answer. I don't recall. It was someone in the President's personal
office.
The reason I don't recall is there were two different staff people
I would often call for these kinds of requests, something that happened
like a radio address with the President. I just don't remember which
staff person it was.
Question. And when they told you this, what did you do next?
Answer. I immediately told Johnny that I was not going to be able
to get his pictures, that the National Security Council was
uncomfortable with him having those pictures.
Question. What did he say?
Answer. I don't recall what he said, but it didn't matter to me
because I disengaged at that point. I figured if the NSC--I wasn't
asking questions. It wasn't my situation. I didn't put him in the radio
address. I was doing my job trying to resolve a constituent request.
The request was to have photos. The National Security Council said he
shouldn't have these photos. That was good enough for me. I provided
the answer. I considered that as a closed issue and I disengaged.
Question. Did Mr. Chung make any further requests of you about
these photographs?
Answer. He did not. And I assumed he did not get his photos.
Question. Were you aware at any time before the--were you aware at
any time in 1995, at the time you were director of National Membership
Services, that Mr. Chung had been described as a quote, hustler,
unquote?
Answer. No.
Mr. Best. He is asking--okay. You have answered it.
Mr. Wilson. I will provide the witness with a document which has
been premarked E0P 005439, which it is indicated that the sender was a
Mr. Robert L. Suettinger.
Mr. Lu. For the record, this document, so the record is clear, this
document was produced by the White House.
EXAMINATION BY MR. WILSON:
Question. Have you ever seen this document?
Answer. No.
Question. Do you know if Mr. Chung was ever solicited regarding
debts from White House Christmas parties?
Answer. I don't know.
Question. Do you know, and this is returning to the subject we
were discussing a moment ago, the radio address photographs, do you
know whether anybody else at the DNC made any requests to the White
House for Mr. Chung to get his photographs?
Answer. I am sorry, can you repeat that question? I was reading
this document. I apologize.
Question. Sure. Do you know of anybody else at the DNC who made
requests for Mr. Chung to get the photographs that were taken at the
radio address?
Answer. Just because I want to be able to answer your question, I
apologize for doing this. I need you to read it back one more time.
[The reporter read back as requested.]
The Witness. I do not.
Thank you. I am sorry. I just wanted to make sure I understood the
question.
I do not.
EXAMINATION BY MR. WILSON:
Question. Did you have any conversations with anybody else at the
DNC about Mr. Chung's desire to get the radio address photographs?
Answer. I did. I know I talked to Richard Sullivan, and I believe
at the time he was deputy finance director, eventually became finance
director, but I don't think at that time he was. And I also talked to--
I believe I talked to Carol Khare, who was the chief of staff in the
chairman's office. She ran the chairman's office. Again, that's to whom
I reported to as my supervisor, just to bring them both up to date,
particularly Richard, because he was the first person who had kind of
been the connection for Johnny Chung to the DNC. In other words, when
you make an initial contribution, you are a member of a donor council
which was the head at one point of the Business Leadership Forum. Mr.
Chung was a member of that donor council. So I always assumed Richard
to be a staff contact.
Question. What did Mr. Sullivan tell you when you explained the
situation?
Answer. I really don't recall. I mean, I--you know, I provided the
information. Johnny Chung called me. I made a phone call. I got an
answer that I felt was good enough for me. I passed that information
along. I just wanted to make the two of them aware of the situation. I
wasn't looking for any kind of response back from them. If they gave me
one, I don't recall.
Question. Why did you call Ms. Khare?
Answer. Because she was my supervisor.
Question. Do you know Roger Tamraz?
Answer. No.
Question. Have you ever spoken with Mr. Tamraz?
Answer. No.
Question. Apart from subsequent media accounts, did you at the
time that you were the director of NMS, did you know of anybody else at
the DNC attempting to arrange introductions for Mr. Tamraz to meet
administration officials?
Answer. No.
Question. Had you ever heard the name ``Roger Tamraz'' when you
were at NMS?
Answer. Not that I recall.
Question. Had you ever heard the name ``Eric Hotung'' when you
were at NMS?
Answer. No.
Question. Had you ever heard the name ``James Riady'' when you
were director of NMS?
Answer. Well, I don't recall. Because I have heard his name so
often recently in the news, I don't recall if I had heard it before,
but I don't believe so.
Question. Do you know whether Mr. James Riady made any requests of
you or your colleagues at NMS?
Mr. Best. You have already asked him earlier if he had ever spoken
with Mr. Riady. Now you are coming back around to the same----
Mr. Wilson. With his colleagues, correct.
The Witness. Prior to this conversation today, prior to this
deposition, I was not aware of that. Based on information you told me
earlier in this deposition, I would say now obviously I am aware of
that, but prior to today, during my time at the National Membership
Services, as director of the program, I was not aware of him having any
kind of direct contact with my colleagues on my staff.
Mr. Best. Riady, are you talking about? Was that your question?
Mr. Wilson. It was my question, and there might be clarification in
order there.
Mr. Best. I don't believe you have made any assertion of a prior
contact.
Mr. Wilson. I don't believe I have, either.
The Witness. I apologize.
Mr. Wilson. I don't believe I have, either.
The Witness. I apologize. In just recalling what we spoke about
earlier today----
Mr. Wilson. Mr. Trie.
The Witness. It was Charlie Trie and I was thinking James Riady. I
don't have any reason to know that James Riady had any conversation
with any people on my staff. I apologize about that confusion.
EXAMINATION BY MR. WILSON:
Question. Is your answer the same for Mochtar Riady?
Answer. Yes.
Question. Do you know, either or both, Arief or Soraya
Wiriadinata?
Answer. Again, I have no recollection of that name.
Question. Do you recall hearing the name ``Wiriadinata'' when you
were director of NMS?
Answer. No.
Mr. Best. Since the first contributions were made by the
Wiriadinatas after this gentleman left the DNC, it is most unlikely
that he would have heard of them.
Mr. Wilson. Well, that's something I don't know and presumably
that's something that you don't know. I think it has to be determined.
EXAMINATION BY MR. WILSON:
Question. Have you ever heard anybody discuss whether Arief
Wiriadinata attended a movie at the White House?
Answer. No.
Question. Do you know Yogesh Ghandi?
Answer. I have heard the name in recent news reports. I had not
heard the name prior to reading them in Washington Post news stories
during the course of this spring and summer, 1997.
Mr. Lu. Again, I would just make the same point that Mr. Best made,
which is, that Mr. Ghandi's contributions to the DNC came after Mr.
Sildon left the DNC.
Mr. Wilson. Could I just ask for a clarification?
Mr. Lu. Yes.
Mr. Wilson. I am just wondering how that has any bearing on my
question as to whether he has ever heard the name before.
Mr. Lu. It is just not clear to me why he would have heard the name
if Mr. Ghandi's involvement with the DNC came after he left.
Mr. Wilson. He might have met him.
Mr. Ballen. He might have met anyone in the world. Are you going to
ask him everybody in the phone book?
Mr. Wilson. That's why I am asking the question.
Mr. Ballen. This deposition--I am going to say something. This
deposition has gone on twice the length of time than a much more
prominent person. There has to be some reasonableness to the questions
that have to relate to knowledge the witness reasonably could have. You
could ask the witness does he know about Mount Vesuvius if you want,
but you have to conduct a deposition that is fair to the witness and we
are going on and on and on with no end in sight. That's the purpose.
That's the clarification.
Mr. Best. Let me say this for the record: We want to give you every
opportunity to ask reasonable questions, but I certainly know, and I
would have thought that you would know, that in the first instance the
Wiriadinatas first make their first contributions to the Democratic
National Committee in November of 1995, and after this witness has left
the Democratic National Committee and Yogesh K. Ghandi makes his
contribution in May of 1996, almost a year before this--after this
witness has left the Democratic National Committee. That clearly still
leaves open the question whether or not he knew these people prior to
the time that they made the contribution, so that there is a basis for
you to ask the question. But the likelihood that he would know them is
so improbable under all of these circumstances that given the length of
this deposition I object, so that the record is clear, to the questions
as they are going on. You are just trolling for information at this
point.
Mr. Wilson. Well, at the extent of drawing this out even further,
when individuals make contributions in excess of $300,000 as their
first contribution, it is not out of the realms of possibility that
somebody has met them, heard of them, come across them, seen them,
sometime within the past 1-year period. I mean, that's just my common
sense, which obviously from your perspective is not very common. But it
is a simple one-line question that could have been answered no and we
could have continued on to the next phrase. That's all I am interested
in.
Mr. Best. That's always the response when you point out the
improbability of the question, that you are wasting more time with the
objection. But you have got to make the objection so as to perhaps
bring this back to a sense of reality. But go ahead. Go ahead with your
questions.
EXAMINATION BY MR. WILSON:
Question. Are you aware that the President attended a series of
coffees held at the White House during 1995 and 1996?
Answer. Only because I have read about them in the newspaper.
Question. Did you know of the coffees at the time that you were
director of NMS?
Mr. Best. When you say ``coffees'' now, you must understand that
there were a whole raft of coffees at the White House, some sponsored
by the Democratic National Committee, according to the facts as I know
them, some by the Clinton/Gore campaign and by other organizations as
well. So when you say ``coffees,'' are you only referring to those
sponsored by the Democratic National Committee or generally coffees
with a whole group of other sponsors as well?
Mr. Wilson. I was being inclusive.
The Witness. That occurred in 1996?
EXAMINATION BY MR. WILSON:
Question. 1995 and 1996.
Answer. I was not aware of those coffees occurring while I was in
my role as director of National Membership Services.
Question. Did you have any knowledge at the time you were director
of NMS that the DNC was paying for the costs of coffees held at the
White House during 1995?
Mr. Best. You mean reimbursing for costs?
Mr. Wilson. Correct.
The Witness. Well, I wasn't aware of that. Again, I wasn't on the
fund-raising staff and wasn't--I had nothing to do with the coffees so
I wouldn't know about any of the other aspects.
EXAMINATION BY MR. WILSON:
Question. Did you on any occasion, when you were director of NMS,
see any memoranda or spreadsheets that alluded to any financial returns
from coffees that were held at the White House?
Answer. No.
Mr. Best. See what a good no does for you.
EXAMINATION BY MR. WILSON:
Question. Did you ever have any interaction with Harold Ickes?
Answer. No.
Question. Have you met Mr. Ickes?
Answer. I have met him.
Question. When have you--when did you first meet Mr. Ickes?
Answer. Again, I don't recall specifically when I met him, but--and
it could have been in either role. You know, you meet someone and then
you know you have met them. I can't tell you now, 4 years later, tell
you while I was fund-raising or while I was director of Membership
Services, but I had some occasion to meet him.
Question. Did Mr. Ickes ever call you when you were the director
of NMS?
Answer. No.
Question. Did you ever call Mr. Ickes when you were director of
NMS?
Answer. No.
Question. Do you ever recall Mr. Ickes contacting one of your NMS
colleagues directly?
Answer. No.
Question. Do you ever recall one of your NMS colleagues contacting
Mr. Ickes directly?
Answer. No.
Question. Did you ever discuss--did you ever have any discussions
with colleagues at the DNC about contributions or donations to tax-
exempt organizations?
Mr. Lu. While he was a fund-raiser or while he was with NMS?
Mr. Wilson. Ever.
Mr. Lu. Ever? Okay.
The Witness. I am sorry. Would you repeat the question?
Mr. Wilson. Could you repeat the question, please.
[The reporter read back as requested.]
The Witness. No.
EXAMINATION BY MR. WILSON:
Question. Did the NMS office collect or have any information about
tax-exempt voter registration organizations?
Answer. No.
Question. Do you know what the arts project was?
Answer. I don't, based on that title. I mean, if you have a
document that might refresh my memory, I would be happy to look at it.
I mean, is that an official title or is that just a term of art?
Question. There is no mystery. I don't know, either. So I am
asking you.
Answer. Okay.
Question. It appears to be a term of art, and if you don't know,
you don't know.
Mr. Lu. Counsel, if we are at a breaking point now----
Mr. Wilson. Actually, you will be very happy to know that I have
two questions and I am happy to take a break.
Mr. Best. No, I am perfectly happy.
Mr. Wilson. I will soldier on.
Mr. Best. March.
Mr. Lu. Please.
The Witness. I am not aware of a project officially called the arts
project.
EXAMINATION BY MR. WILSON:
Question. Do you have any knowledge of whether anyone at the DNC,
at the time you were regional finance director or the time you were
director of NMS, provided a list of Chinese American trustees to anyone
at the Taiwan Economic and Cultural Representative Office in the U.S.?
Answer. I am sorry. Can you repeat the question?
[The reporter read back as requested.]
The Witness. I do not.
EXAMINATION BY MR. WILSON:
Question. Have you ever heard the name ``Andrew Shi,'' S-H-I?
Answer. No.
Mr. Wilson. That concludes my round of questioning.
If you would like to take a break before yours, I would be happy
to.
Mr. Lu. No. I would just as soon we wrap up.
The Witness. Good.
EXAMINATION BY MR. LU:
Question. Mr. Sildon, thank you for coming today. On behalf of the
Democratic members of the committee, I would like to thank you. I know
this has been an imposition on you and your time, and I will try to
keep my questions reasonably brief.
Answer. Thank you.
Question. And we will wrap this up.
Answer. Thank you.
Question. As I understand your testimony, one of your goals in
setting up NMS was to separate these services from the finance
department; isn't that correct?
Answer. That is correct.
Question. In fact, I believe you have testified that you did not
want these services to be--or decisions about how these services were
to be provided to be based on the amount of money that a supporter had
contributed; isn't that correct?
Answer. That is correct.
Question. And, in fact, when the supporter called your office
asking for assistance or asking for a tour to be arranged, you didn't
check first to see how much money that supporter had given.
Answer. Correct.
Question. In fact, I believe you testified that you did not even
have access to that type of financial information.
Answer. That's also correct.
Question. And I believe, if my understanding is correct, that's
why throughout this deposition you have been using the term
``supporter'' or ``constituent'' as opposed to ``contributor'' when you
talk about the type of services that your office provides.
Answer. That's correct.
Question. Isn't it true that the arrangements your office made for
supporters were similar to the types of services that a Congressman or
Senator's office would make for his or her constituents?
Answer. I had worked on the Hill for 7 years. I understood about
constituent service. You don't--you don't ask someone when they call a
Member of Congress' office if they made a contribution to a recent
campaign or election. I just--if people need help, I want to try to
provide it.
If someone contacted me, that's correct, I tried to simply take the
request and fulfill it regardless or irregardless of other factors,
such as contributions.
Question. And would I be correct in guessing that the Republican
National Committee probably provides the same types of services that
the DNC or Congressman or Senator's office also provides for its
supporters?
Answer. That's not only correct but a lot of the impetus for
starting a program like this was because they had done that as well,
and they had paved the way and we understood that those kinds of
opportunities existed and had been done so in the past.
Question. And when you say that they paved the way, can you
elaborate for me on what types of services you are aware of that the
RNC provided for its supporters?
Answer. I had seen a brochure of a group called Team 100 and the
Eagles, which talked about all of these opportunities people would
have, you know, with the President and, you know, be it tours or going
to events. I was simply interested in moving this away from the finance
division of the DNC and being responsive to people just as previous--
previous--previously had been done by the RNC.
Question. Just so the record is clear, when you were talking about
Team 100 and the Eagles have access to the President, you meant
President Bush or President Reagan?
Answer. Correct. Correct. And I had seen that in brochures that the
RNC had put out.
Question. Can you recall any other types of, for lack of a better
word, perks that were available that the RNC provided to its supporters
that you read about in those brochures?
Answer. Well, I really don't recall others that they offered that
we didn't offer or vice versa. They were very different
administrations, you know, with different staff and a different
President. It just--it was trying to respond to the fact that we now
were looking for ways to be responsive to our constituents, just as the
RNC had always been, just as when I worked on Capitol Hill when a
constituent contacted a Member's office and they wanted information or
to be pointed in the right direction.
You know, this program, everybody keeps talking about this program,
and I won't belabor this point, but everybody keeps talking about this
program that we were putting people in radio addresses and doing these
other things. We were doing things like helping an out-of-towner
figuring out what is a good Italian restaurant to go to in Washington
or what is something interesting so their kids won't be bored all
weekend long when they come to town or what is appropriate for a 5-
year-old to do versus a teenager to do.
Our program did so much more than just radio addresses and putting
people in South Lawn events, as we discussed this morning. Our program
was to try to be responsive to anyone. We were the catchall when
somebody called the DNC; nobody knew who to turn to, let's have them be
able to talk to National Membership Services. Maybe they will have an
idea for them.
We have got a list of 50 fun things to do in Washington, D.C., that
we could send any constituent who called. It didn't matter if they
wrote a $100,000 check or, you know, they were just some little old man
out in the Midwest who was coming to Washington for the first time.
That's why we started the program and I did not want it to be tied
to money. That's why I left the finance department. That's specifically
the reason why I talked to the chairman and, as I previously testified,
to Martha Phipps and to my former boss, Nancy Jacobson, and we decided
to move it out of the department, because it didn't have to do with
money. And we didn't want there to be this perception that we were
telling people where to eat or trying to help them get a tour at the
White House simply because they wrote a check.
Question. And I don't mean to belittle the work your office did,
but it sounds as if a lot of the services your office provided were
similar to what perhaps a hotel concierge would provide.
Answer. Exactly right.
Question. Let me just go back for another second or to the
discussion we just had about the RNC's services. Would it surprise you
if I told you that the RNC had special briefings for administration,
Bush administration briefings, for its large contributors?
Answer. It doesn't surprise me because I know it happened.
Question. Do you know a specific example in which that happened?
Answer. Well, I have knowledge from my days when I was a lobbyist
for the National Federation of Independent Business that I would go to
White House briefings on the fourth floor of the OEOB when, you know,
the--I mean, there was one time when President Bush himself came, but
where they would have, you know, somebody from the--you know, Carla
Hills was at one of the briefings, and I just--you know, that's what
they did. They held briefings, and I sat in those briefings when I was
a lobbyist, and I also knew from people who were supporters of the DNC,
who would, you know, look, a lot of these people are interested on both
sides. So they--you know, they supported the RNC and they supported the
DNC and they would come say to us, look over at the RNC, they are doing
all of these things for us; you guys have got to get on the ball; you
guys need to be responsive to our interests as well.
Question. And would it surprise you if I told you that the RNC had
staff members who also arranged services or performed services, made
arrangements for its large contributors or arranged meetings with
Members of Congress?
Answer. It would not surprise me.
Question. Did your office ever provide services to a supporter so
that supporter might encourage foreign nationals to contribute money?
Answer. Absolutely not. In fact, I knew that was illegal anyway, so
we certainly wouldn't have done anything for those reasons.
Question. And to your knowledge was there ever any communication
or any hints from the President or the Vice President that the DNC
should use their office in that way to encourage foreign nationals to
give contributions?
Answer. No. And to follow up on something you said a minute ago,
and I don't think it belittles the program either, I doubt the
President or the Vice President even knew our little shop existed. We
were there to provide constituent service to all kinds of people. I am
pretty certain they did not know that this little shop of three people
was over at the DNC helping people figure out a good restaurant to go
to or who should come to the South Lawn along with 6,000 other people
to see Boris Yeltsin shake the President's hand.
Question. At the time your office made tour arrangements and
provided other services, we have talked about Charlie Trie today,
Johnny Chung, Pauline Kanchanalak, had there been any news stories,
media accounts about them?
Answer. No.
Question. Can you estimate for me the number of requests for all
types of services that your office received during the time that you
worked there? Would it be fair to say it was thousands?
Answer. Yes. Which is part of the reason I have a difficult time
recalling when all of these names are asked. We probably had, no
exaggeration, 3 dozen requests a day, or a couple dozen requests a day
for, again, all kinds of things. We were usually some of the last
people there, because we were at 7:00 or 8:00 at night still trying to
be responsive to people, whether we were able to get them that White
House tour the next day or where they should go to dinner or something
upcoming that weekend.
We had dozens and dozens of requests that had nothing to do even
with politics, you know, a golf course to play on, you know, did we
have a connection to help somebody get a ticket to a sold-out Orioles
game because they were coming to town? I mean, just all kinds of little
things that every project took 20 minutes. And we had 3 dozen a day to
do.
Question. So as far as you know, there was no reason your office
should treat Mr. Trie, Mr. Chung, Ms. Kanchanalak, any different from
these thousands of other requests that you received?
Answer. Correct, because at the time I certainly was not aware of
the things that now, because of recent newspaper articles in 1997, 2
years after I left the DNC, I have since learned. But at the time they
were supporters, just as I have said before, the little old man from
out in the Midwest who did door hangings before elections every 2 years
for the last 50 years, just as he was a supporter. It was my
responsibility to be responsive to all supporters of the DNC. And
that's why--and I didn't have access to the money. I didn't know how
much these people gave, and it wasn't an issue because money wasn't an
issue. I took care of--I didn't take care of Pauline Kanchanalak or any
of the people that you have previously mentioned, frankly I don't think
I did anything for them, but I wouldn't have taken care of them any
better than I would have somebody that the DNC Political provided to me
or the Office of State Chairs or any of the other departments. They all
were important to me. It was my job to try to respond to as many
requests as I could do, to try to be responsive and fulfill these
people's requests.
Question. I believe you have also testified that you were involved
in trying to acquire Mr. Chung's photos from the Presidential radio
address. Is that correct?
Answer. Correct.
Question. And at that time, or any time when you worked at NMS,
did you have any suspicion that he might be an agent for the Chinese
government?
Answer. No, absolutely not. He just--he just was--just, I think,
always looking to speak to someone, you know, and for awhile I was
talking to him and after me I am sure there was somebody else and
probably somebody else. I had no knowledge of his--the question that
you asked. I would not have known that.
Question. I just have a few more questions. These are some
questions that one of the Members on our committee has asked that we
ask all the deponents.
If you could just hold on a second.
If I can, before I do that, let me just jump back a second to some
of the answers you just gave me. You mentioned that when you were at--
when you were legislative representative for a group here in town that
you attended some special briefings at the Bush White House. Isn't that
correct?
Answer. Correct.
Question. And you mentioned one specific briefing with the
President, President Bush, another one with Carla Hills. Can you give
me--can you think of any other specific examples of briefings that you
attended with Bush administration officials?
Answer. I have a vague recollection of also attending a briefing, a
labor-related briefing, up on the fourth floor of the OEOB. But I--I
don't recall specifically who was there or what the--what the topic of
the briefing was.
Mr. Lu. Actually, can we go off the record for just a minute,
please.
[Off the record discussion.]
Mr. Lu. Let's go back on the record. Could you read back the last
part of his answer.
[The reporter read back as requested.]
EXAMINATION BY MR. LU:
Question. Were these briefings that you attended because your
organization had given money to the RNC or to other Republican groups?
Answer. Well, I am not sure I could say that that is the reason
why. We were involved in legislative efforts that were similar to
legislative objectives and interests of the Bush White House, and so we
were, as one of the friendly organizations, invited to substantive
issue briefings, updates, at the White House.
Question. I believe you also mentioned earlier, when I asked you
some questions, that you knew of some DNC supporters that had also
supported the RNC and that some of these--sometimes these DNC
supporters told you about the services that had been provided to them
by the RNC. Are you able to describe for me any of those types of
services that those supporters mentioned?
Answer. Well, one supporter mentioned that he was able to play
tennis on the South Lawn at the White House, and that was certainly
something I was not aware would even be a remote possibility. And as it
turned out, I did not ever really pursue that ability, that
opportunity. I didn't get people into the White House so they could go
play tennis on the South Lawn, but I was told that the Bush
administration had--that President Bush had allowed people to come over
and play tennis with him, with others, on the tennis court.
Question. And other than playing tennis on the South Lawn, can you
recall any other services that these supporters had mentioned that the
RNC had provided them?
Answer. Well, I thought I remembered that actually supporters got
to fly on Air Force One, but, again, that was not something that I was
responsible for at the DNC so that didn't really matter. And I don't
recall specifically all the things that were said, but somebody handed
me the Team 100 and Eagles brochure from prior to 1993 when President
Bush was--and his administration were here in town, and it showed a
variety of these benefits.
Question. Some of which the DNC provided and some of which the DNC
did not provide?
Answer. Correct.
Question. As I stated earlier, one of the Democratic Members of
our committee has asked us to ask all the deponents some questions and
they are pretty standard questions.
Have you been asked by any other official investigative body to
testify or provide evidence on any of the fund-raising or other matters
being investigated by this committee?
Answer. No.
Question. So you have not been interviewed or deposed by the
Senate Governmental Affairs Committee?
Answer. I have not.
Question. Or the Department of Justice?
Answer. Correct.
Question. And I assume, because you are not a current employee,
you also did not provide any documents to this committee?
Answer. Correct.
Question. Although I believe you said you searched your own
personal records for those documents.
Answer. I was told I needed to do that to see if I had any
documents, and if I had them I would have been happy to provide them,
but I didn't think I did.
Question. And have you received any requests to provide documents
or be interviewed or be deposed by any other investigative body in the
future?
Answer. No.
Question. Can you estimate how much time--how much of your time
you have spent in preparing and attending this deposition?
Answer. Besides the daily anxiety of anticipating a deposition and
then my deposition last week being postponed because the morning
deposition was running too long?
Question. Yes.
Answer. You know, I have been here all day and I have had to have
two meetings with counsel, rearrange schedules. I actually was supposed
to be out of town today, flying back in this morning actually, but I
flew in yesterday so I could make this deposition. So time wise, you
know, 15 or 20 hours.
Question. And I think you told us at the outset of your deposition
that you are self-employed as a consultant?
Answer. Correct.
Question. So in terms of any costs to your employer, those would
be really costs to you?
Answer. True. But my costs is that I am not working today and I am
not either seeking clients, which are my sole source of income, and I
am not working for the few clients I have to help them, you know,
finish up projects I am working on for them.
Question. Has this committee offered to reimburse you for your
time and/or expenses?
Answer. Not that I am aware of.
Question. If it is available, will you seek reimbursement from
this committee for your expenses?
Answer. Probably not. I don't know. I would like to reserve
judgment on that. At this time, that's not something that I was
considering.
Mr. Lu. No further questions.
EXAMINATION BY MR. WILSON:
Question. Was there any distinction between the types of events
that you helped people attend at the White House in terms--and that's a
self-imposed distinction, a hierarchy where one was more important than
another in your mind?
Mr. Best. Do you want him to distinguish in terms of importance? Is
that what you are saying?
Mr. Wilson. I am asking whether the NMS staff prioritized or had a
hierarchy of the different types of events that you helped people--
facilitated for people.
The Witness. I would say only one kind of event would be considered
more important to us than any other, and that's a State dinner, and
they are obviously important enough that the guest lists are published
in the Washington Post and it is always a big story in the Style
section when there is a State dinner. Other than that--and this
President hasn't done many State dinners. He didn't do one his entire
first year in 1993, so they are much more few and far between compared
to other kinds of events.
Beyond that, no, all events are the same.
EXAMINATION BY MR. WILSON:
Question. You mentioned earlier that Mr. Chung's laundry list of
requests was--it is my words, not yours, but somewhat farfetched. Were
you aware of any other requests by DNC supporters that were simply
deemed inappropriate? And I am not asking whether they were not
possible but just simply inappropriate.
Mr. Best. Deemed by him inappropriate?
Mr. Wilson. Deemed by Mr. Sildon to be inappropriate.
The Witness. Requested of me?
EXAMINATION BY MR. WILSON:
Question. Correct.
Answer. Since some requests may have come in that DNC staff never
submitted to me?
Question. Yes.
Answer. Well, I don't--I don't recall. I certainly don't recall.
There either may have been some--I am sure there were some. I am sure
there were requests that came in that you just looked at and went, I
don't think so, but I don't recall specifically such requests.
Question. Do you recall requests being made by individuals that
any of your DNC colleagues thought were inappropriate because of who
the person was who was making the request?
Answer. Not that I am aware of.
Question. Was there any distinction that you knew of, when you
were at both NMS and in your position as regional finance director,
where there were distinctions drawn between facilitating meetings for a
policy nature or for doing something that was more of a spectator sport
type of request, for example, going on a tour or visiting a building?
Answer. I am sorry. I actually need you to rephrase the question.
Question. I don't think anybody would have understood that
question. was there a distinction drawn by anybody at the DNC that you
knew of, for the entire time that you were there, between the types of
events that involved meeting with policy-type employees and simply
attending events or going to look at a building?
Mr. Best. Are you characterizing a meeting with a policy-type
official as an event?
Mr. Wilson. Yes.
The Witness. I want to make sure I understand the question.
It appears to me what you are asking is, did I weight equally,
providing--helping provide a tour and meeting with an administration
official? Is that your question? I want to make sure. Is that your
question?
EXAMINATION BY MR. WILSON:
Question. Right.
Answer. No, I would say I probably would not have weighted those
equally.
First of all, again, I very, very seldom asked to arrange for a
meeting for someone, but if I was, and there was--first of all, I
didn't arrange any meetings. All I did was forwarded information on to
an office on behalf of some constituent for that office to decide
whether or not they wanted to take a meeting.
But if I was asked on the same day to help get somebody a tour and
to help forward information along for a meeting, I would certainly do
the tour without qualification and I would want to--I would want
someone to tell me that I was supposed to make a call for a meeting.
Again, I did it so seldom, but when I did do it, it would have been
because there was some reasonable explanation for why this person
needed to or wanted to meet with that person in the administration. And
it was not for any reason other than whatever they put in their letter
to whoever they sent a letter to at the DNC that got forwarded to me
that I simply put in a fax and sent along. Then at that point it was up
to that administration office to decide whether or not they wanted to
have a meeting.
Question. Were you aware of any guidelines when it came to
facilitating a meeting between a DNC supporter and an administration
official?
Answer. Self-imposed guidelines, DNC guidelines?
Question. Either self-imposed or written or verbal or any type of
guidelines.
Answer. Again, I wasn't trying to arrange meetings. I was simply
forwarding letters.
Question. Were you aware of any guidelines?
Mr. Best. With regard to forwarding letters?
Mr. Wilson. No, with regard to facilitating meetings with
administration officials.
The Witness. Can I have just a moment?
Mr. Wilson. Absolutely.
[Witness conferring with counsel.]
The Witness. Okay. When I received a request, I would only forward
requests along that were not competitive in nature where it looked like
the DNC was representing one company, corporation, individual versus
others in any kind of--if there was--we weren't allowed to--if somebody
had a contract with the Federal Government, we weren't allowed to
contact that agency on their behalf. We weren't allowed to--in that
sense, there were those guidelines. But those weren't the kinds of
things that ever came to me. I mean, that's not what people were
bringing to me when someone from the Office of Political Affairs at the
DNC or whatever would hand carry over a letter and say, I received this
letter, it is addressed to me but I want to pass it on to you, can you
forward it on to so and so in the administration? And, sure, put a
cover note on it and say, this has been sent to us, we are sending it
to you. This person would appreciate having a chance to talk to her.
Here is their phone number. It is up to you.
But I certainly didn't forward things along if it had to do with--
they had a bid or a contract with the government. I mean, another
guidelines is, we weren't supposed to ever contact the Department of
State, the Department of Justice or the Defense Department. I mean,
those were just hands-off agencies. We weren't going to get involved in
foreign policy decisions or recommending people, anything, at the State
Department, Justice Department or Defense Department. We just wouldn't
even consider forwarding it, even a letter, even just a letter that
someone wanted to send out.
EXAMINATION BY MR. WILSON:
Question. How would you know if somebody had a contract with the
Federal Government?
Answer. In that sense, I probably wouldn't. I wouldn't know if
someone had a contract, but if in a letter it said, we would like to
talk to you about the contract which we have with you, which--I don't
know whatever they could say in the letter, that would be something
that I wouldn't forward along.
But, sure, you are right, if--this didn't happen but if the
chairman of a large corporation like AT&T called me and said he wanted
a meeting, I wouldn't know whether they have or don't have a contract
unless the text of the letter said we want to talk about it.
Question. Do you know if the DNC made any attempt to screen
political contributors from meeting with administration policy staff?
Mr. Best. Screening? What do you mean by ``screening''?
Mr. Wilson. To either seek to learn what their interests were or--I
will leave that--seek to learn what their interests were before they
went to do whatever it is they were going to do.
Mr. Best. You are assuming that such meetings took place?
Mr. Wilson. Yes.
The Witness. I don't know, because, again, I--I certainly wasn't
involved really in this aspect. And I didn't set up meetings. You know,
I forwarded a couple of letters along during the course of 2 years in
the job role. So I appreciate the question you are asking me. Since I
had very little, if any, experience with it in the first place I
certainly don't know about the pre-vetting process for any of the other
kinds of meetings that might have been set up by others.
As we discussed before, there were a lot of people at the DNC who
had relationships around the administration and they would just call.
They would call on their own.
EXAMINATION BY MR. WILSON:
Question. Do you know of any situations where the DNC made an
attempt to prohibit a political contributor from meeting with any
administration policy staff?
Answer. No. I don't know of--no, I don't know of such a situation.
Mr. Wilson. Thank you very much on behalf of the Majority. I
appreciate your coming here and taking your time to speak with us.
I don't mean to cut this off.
Mr. Lu. We have nothing. Thank you.
Mr. Wilson. Thank you very much.
[Whereupon, at 3:45 p.m., the deposition was concluded.]
[The exhibits referred to follow:]
[GRAPHIC] [TIFF OMITTED] T5667.584