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SPEAKERS CONTENTS INSERTS
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1998
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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COMMITTEE ON GOVERNMENT REFORM AND OVERSIGHT
DAN BURTON, Indiana, Chairman
BENJAMIN A. GILMAN, New York
J. DENNIS HASTERT, Illinois
CONSTANCE A. MORELLA, Maryland
CHRISTOPHER SHAYS, Connecticut
STEVEN SCHIFF, New Mexico
CHRISTOPHER COX, California
ILEANA ROS-LEHTINEN, Florida
JOHN M. MCHUGH, New York
STEPHEN HORN, California
JOHN L. MICA, Florida
THOMAS M. DAVIS, Virginia
DAVID M. MCINTOSH, Indiana
MARK E. SOUDER, Indiana
JOE SCARBOROUGH, Florida
JOHN B. SHADEGG, Arizona
STEVEN C. LATOURETTE, Ohio
MARSHALL ''MARK'' SANFORD, South Carolina
JOHN E. SUNUNU, New Hampshire
PETE SESSIONS, Texas
MICHAEL PAPPAS, New Jersey
VINCE SNOWBARGER, Kansas
BOB BARR, Georgia
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ROB PORTMAN, Ohio(see footnote 1)
DAN MILLER, Florida(see footnote 2)
HENRY A. WAXMAN, California
TOM LANTOS, California
ROBERT E. WISE, Jr., West Virginia
MAJOR R. OWENS, New York
EDOLPHUS TOWNS, New York
PAUL E. KANJORSKI, Pennsylvania
GARY A. CONDIT, California
CAROLYN B. MALONEY, New York
THOMAS M. BARRETT, Wisconsin
ELEANOR HOLMES NORTON, Washington, DC
CHAKA FATTAH, Pennsylvania
ELIJAH E. CUMMINGS, Maryland
DENNIS J. KUCINICH, Ohio
ROD R. BLAGOJEVICH, Illinois
DANNY K. DAVIS, Illinois
JOHN F. TIERNEY, Massachusetts
JIM TURNER, Texas
THOMAS H. ALLEN, Maine
HAROLD E. FORD, Jr., Tennessee
———
BERNARD SANDERS, Vermont (Independent)
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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
Hearing held on:
November 13, 1997
November 14, 1997
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
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
Williams, Margaret A., accompanied by Ed Dennis, Esq.
Letters, statements, etc., submitted for the record by:
Barr, Hon. Bob, a Representative in Congress from the State of Georgia, exhibit 195
Bennett, Richard, chief counsel, Committee on Government Reform and Oversight:
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Exhibit 232
Exhibit 227
Exhibit 171
Exhibit 172
Exhibit 255
Exhibit 174
Exhibit 259
Exhibit 201
Exhibit 196
Exhibit 198
Exhibit 215
Burton, Hon. Dan, a Representative in Congress from the State of Indiana:
Exhibit C–82
Exhibit 191
Crawford, Kelly, former staff assistant to Ms. Hernrich, deposition of
Cox, Hon. Christopher, a Representative in Congress from the State of California:
Exhibit 187
Exhibit 153
Davis, Hon. Danny K., a Representative in Congress from the State of Illinois, prepared statement of
Dennis, Ed, Esq., letter dated March 6, 1997
Fattah, Hon. Chaka, a Representative in Congress from the State of Pennsylvania:
Newspaper articles
Wall Street Journal article
Horn, Hon. Stephen, a Representative in Congress from the State of California:
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Exhibit 240
Exhibits 204, 205, 206, 207, 208, and 215
Khare, Carol, former assistant to the chairman, Democratic National Committee, deposition of
Kucinich, Hon. Dennis, a Representative in Congress from the State of Ohio, memo dated April 25, 1997
Lantos, Hon. Tom, a Representative in Congress from the State of California:
Letter dated April 6, 1994
Photographs
Morris, Richard, deposition of
Ratliffe, Gina D., deposition of
Rohrbaugh, Robert, senior investigative counsel, Committee on Government Reform and Oversight:
Exhibit 196
Exhibit 198
Exhibit C–79
Exhibit 250
Exhibit 175
Exhibit 251
Exhibit 252
Ryan, Evan, deposition of
Sildon, Eric, deposition of
Swiller, Ari, deposition of
Waxman, Hon. Henry A., a Representative in Congress from the State of California:
Final rule, political activities of Federal employees
Photographs
Williams, Margaret A.:
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Deposition of
Prepared statement of
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.
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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:]
INSERT OFFSET FOLIOS 1 TO 2 HERE
[The official committee record contains additional material here.]
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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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?
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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.
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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 déjà 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.
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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.]
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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.
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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.
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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.
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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:]
INSERT OFFSET FOLIOS 3 TO 4 HERE
[The official committee record contains additional material here.]
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——
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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?
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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:]
INSERT OFFSET FOLIOS 5 HERE
[The official committee record contains additional material here.]
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——
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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.
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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.
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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:]
INSERT OFFSET FOLIOS 6 TO 14 HERE
[The official committee record contains additional material here.]
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?
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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:]
INSERT OFFSET FOLIOS 15 TO 21 HERE
[The official committee record contains additional material here.]
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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:]
INSERT OFFSET FOLIOS 22 HERE
[The official committee record contains additional material here.]
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.
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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.
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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.
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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:]
INSERT OFFSET FOLIOS 23 TO 26 HERE
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[The official committee record contains additional material here.]
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?
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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?
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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:]
INSERT OFFSET FOLIOS 27 HERE
[The official committee record contains additional material here.]
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.
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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?
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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.
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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.''
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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?
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[Exhibit 259 follows:]
INSERT OFFSET FOLIOS 28 HERE
[The official committee record contains additional material here.]
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:]
INSERT OFFSET FOLIOS 29 HERE
[The official committee record contains additional material here.]
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?
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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?
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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.
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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.
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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.
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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.
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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.
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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?
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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?
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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.
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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?
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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.
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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:]
INSERT OFFSET FOLIOS 30 TO 31 HERE
[The official committee record contains additional material here.]
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.
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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.
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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:]
INSERT OFFSET FOLIOS 32 TO 38 HERE
[The official committee record contains additional material here.]
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.''
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[The letter referred to follows:]
INSERT OFFSET FOLIOS 39 HERE
[The official committee record contains additional material here.]
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.
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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.
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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?
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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?
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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.
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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?
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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?
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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.
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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.
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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:]
INSERT OFFSET FOLIOS 40 HERE
[The official committee record contains additional material here.]
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.
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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——
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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:]
INSERT OFFSET FOLIOS 41 HERE
[The official committee record contains additional material here.]
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.
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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.
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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?
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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.
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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.
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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.
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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.
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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——
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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:]
INSERT OFFSET FOLIOS 42 TO 50 HERE
[The official committee record contains additional material here.]
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.
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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.
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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.
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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:]
INSERT OFFSET FOLIOS 51 TO 60 HERE
[The official committee record contains additional material here.]
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.
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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?
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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?
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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.
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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——
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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.
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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.''
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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:]
INSERT OFFSET FOLIOS 61 TO 62 HERE
[The official committee record contains additional material here.]
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:]
INSERT OFFSET FOLIOS 63 TO 73 HERE
[The official committee record contains additional material here.]
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.
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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.
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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.
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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?
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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?
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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.
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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.
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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.
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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:]
INSERT OFFSET FOLIOS 74 TO 78 HERE
[The official committee record contains additional material here.]
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.
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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.
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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?
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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.
4Mica. 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.
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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.
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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.
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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.
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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.
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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.
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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?
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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.
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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——
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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?
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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.
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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?
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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.''
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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
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| 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.
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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.
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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.
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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?
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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.
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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.
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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.
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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?
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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.
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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.
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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?
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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.
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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.
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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.
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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?
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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.
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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.
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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.
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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?
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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.
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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.
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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.
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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.
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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.
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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.
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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?
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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.
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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.
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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.
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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.
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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?
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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?
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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.
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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.
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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——
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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——
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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.
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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?
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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.''
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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.
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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——
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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.
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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——
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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.
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[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?
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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.
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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.
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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.
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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.
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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.''
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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——
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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——
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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?
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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——
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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.
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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:
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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.
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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?
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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.
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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?
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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.
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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.
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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.
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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:
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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?
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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.
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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.
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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?
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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.
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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.]
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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.
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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?
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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?
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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?
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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.
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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?
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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?
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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?
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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?
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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?
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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?
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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?
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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?
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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.''
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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.
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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.
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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.
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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.]
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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?
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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.
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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?
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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——
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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.
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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.
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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.
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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?
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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.
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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——
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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.
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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.
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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.
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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.
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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.
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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?
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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?
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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.
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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?
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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.
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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?
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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.
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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.
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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.
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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.
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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.
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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.
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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?
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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.
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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?
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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.
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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?
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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.
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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.
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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?
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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.
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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?
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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?
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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.
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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?
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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?
11Answer. 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?
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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.
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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.
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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.
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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?
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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.
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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.
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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?
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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.
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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.
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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?
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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?
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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?
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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?
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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.
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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?
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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.
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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.
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[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?
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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?
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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?
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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?
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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?
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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.
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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?
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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.
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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——
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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.
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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.
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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?
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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.
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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.
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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?
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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.
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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.
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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?
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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?
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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:
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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?
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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.
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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?
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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.
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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.
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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?
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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.
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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.
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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.
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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?
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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.
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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.
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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?
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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.
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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?
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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.
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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.
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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.
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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.
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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.
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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?
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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:
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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?
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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——
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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?
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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.
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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.
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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.
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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.
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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——
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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——
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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.]
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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?
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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?
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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?
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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?
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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.
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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.
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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?
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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.
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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?
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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?
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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?
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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——
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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.]
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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.
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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.
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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?
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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?
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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.''
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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?
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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.]
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[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.
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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?
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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.
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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.
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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
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'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.
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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?
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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?
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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?
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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?
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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:
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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?
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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.]
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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?
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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?
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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.
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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?
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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?
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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.
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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——
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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.
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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.
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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——
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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.
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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?
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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?
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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——
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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?
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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——
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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?
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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——
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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?
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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?
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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?
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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.
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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?
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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?
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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.
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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.
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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.
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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.
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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——
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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:]
INSERT OFFSET FOLIOS 109 TO 265 AND 576 TO 581 HERE
[The official committee record contains additional material here.]
[The deposition of Evan Ryan follows:]
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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.
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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.
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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.
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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?
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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?
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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.
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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.
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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.
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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.
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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.
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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?
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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?
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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?
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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.
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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.
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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.
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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?
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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.
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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?
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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?
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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.
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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?
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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?
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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?
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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.]
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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?
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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.
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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.
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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.
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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?
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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.
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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?
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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?
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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?
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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.
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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.
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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.
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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?
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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.
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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?
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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.
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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.
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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.
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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.
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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.
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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?
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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?
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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.
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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?
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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?
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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.''
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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?
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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.
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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:
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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.
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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?
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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?
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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?
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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.
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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.
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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?
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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.
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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?
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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?
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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.
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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.
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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.
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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.
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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.
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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:
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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.
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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.
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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.
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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?
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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.
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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.
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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.
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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.
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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?
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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.
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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.
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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?
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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?
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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.
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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.
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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?
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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?
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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?
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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.
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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.
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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?
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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.
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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?
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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.
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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.
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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.
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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?
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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.
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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?
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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?
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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.
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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.
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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:
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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.
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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.
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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?
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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.
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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.
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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?
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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.
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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?
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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?
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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?
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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?
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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.
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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?
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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.''
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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?
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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.
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[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?
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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.
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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.
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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.
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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?
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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?
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.''
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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?
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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.''
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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?
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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.
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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.
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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?
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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?
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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.
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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.
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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.]
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[The exhibits referred to follow:]
INSERT OFFSET FOLIOS 433 TO 505 HERE
[The official committee record contains additional material here.]
[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
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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.
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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.
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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.
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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.
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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.
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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?
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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.
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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.
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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?
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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?
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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.
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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.
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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.
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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?
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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?
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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?
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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?
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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?
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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.
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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?
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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.
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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.
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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.
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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?
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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.
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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.
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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.
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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.
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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?
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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.
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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.
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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.
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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.
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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.
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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.
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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?
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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.
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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.
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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.]
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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.
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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?
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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.
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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.
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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?
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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.
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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?
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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.
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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.
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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.
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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.
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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.
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[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.
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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?
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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.
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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?
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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?
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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?
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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?
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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.
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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.
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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.
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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.
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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.
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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.
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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?
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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.
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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.''
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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.
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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.
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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.
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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.
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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.
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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.
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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?
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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.
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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?
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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.
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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.
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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.
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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.
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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.
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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.
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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?
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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?
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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?
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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.
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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?
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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.
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[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?
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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.
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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.
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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.''
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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.
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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.]
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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.
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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:
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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?
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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——
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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.
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[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.
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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?
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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.
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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——
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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?
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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.
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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.]
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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.
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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.
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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.
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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.
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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?
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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?
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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?
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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?
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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?
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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?
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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.]
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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.
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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.
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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.
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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.
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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.
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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:]
INSERT OFFSET FOLIOS 325 TO 432 HERE
[The official committee record contains additional material here.]
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.
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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.
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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?
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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?
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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?
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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.
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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?
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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?
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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.
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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?
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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.
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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.
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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.
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[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.
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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.
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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.
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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.
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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.
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[Exhibit 196 follows:]
INSERT OFFSET FOLIOS 79 HERE
[The official committee record contains additional material here.]
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:]
INSERT OFFSET FOLIOS 80 HERE
[The official committee record contains additional material here.]
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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——
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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.
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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?
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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:]
INSERT OFFSET FOLIOS 81 HERE
[The official committee record contains additional material here.]
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?
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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?
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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?
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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.
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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.
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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.
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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?
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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?
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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?
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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.
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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.
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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.
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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——
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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?
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[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.
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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.
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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?
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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.
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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.
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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:]
INSERT OFFSET FOLIOS 82 HERE
[The official committee record contains additional material here.]
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.
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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.
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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.
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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.
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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 déjà 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.
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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.
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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.
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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.
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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?
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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?
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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:]
INSERT OFFSET FOLIOS 83 HERE
[The official committee record contains additional material here.]
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.
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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.
Page 723 PREV PAGE TOP OF DOC Segment 2 Of 3
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:]
INSERT OFFSET FOLIOS 84 HERE
[The official committee record contains additional material here.]
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.
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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.
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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.
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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?
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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——
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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——
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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.
Page 730 PREV PAGE TOP OF DOC Segment 2 Of 3
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.
Page 731 PREV PAGE TOP OF DOC Segment 2 Of 3
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.
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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?
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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.
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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.
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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:]
INSERT OFFSET FOLIOS 575 HERE
[The official committee record contains additional material here.]
[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
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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.
Page 737 PREV PAGE TOP OF DOC Segment 2 Of 3
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.
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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?
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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?
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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.
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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.
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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——
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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:
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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?
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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.
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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.
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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.
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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?
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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.
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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?
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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.
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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.
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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.
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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?
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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.
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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?
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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.
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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.
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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?
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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——
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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.
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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.
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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.
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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?
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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.
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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?
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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.
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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.
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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?
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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.
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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.
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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.
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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?
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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.
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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.
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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:
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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).''
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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.
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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?
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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:
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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?
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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?
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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.
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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.
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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?
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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.
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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.
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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.]
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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.
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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.
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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.
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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:]
INSERT OFFSET FOLIOS 297 TO 324 HERE
[The official committee record contains additional material here.]
[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
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| 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.
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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.
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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.
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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?
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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.
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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.
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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?
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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.
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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?
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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?
Page 803 PREV PAGE TOP OF DOC Segment 2 Of 3
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.
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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.
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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?
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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.
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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.
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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.
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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.
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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.
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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.
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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?
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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.
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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?
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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?
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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?
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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?
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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——
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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.
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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?
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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?
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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?
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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.
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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?
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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?
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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.
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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.
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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.
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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?
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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.''
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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?
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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——
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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?
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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?
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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.
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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.]
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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.]
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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——
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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?
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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.
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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?
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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.
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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?
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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?
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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?
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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.
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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.
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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.
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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.
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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?
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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?
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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?
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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.]
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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?
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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.
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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?
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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.
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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.
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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:
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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.
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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:]
INSERT OFFSET FOLIOS 266 TO 296 HERE
[The official committee record contains additional material here.]
Next Hearing Segment(3)