White House Compliance with Committee Subpoenas

Segment 6 Of 22     Previous Hearing Segment(5)   Next Hearing Segment(7)

SPEAKERS       CONTENTS       INSERTS

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    Ms. COMSTOCK. I am showing the witness an October 18th, 1996, letter to the President that was signed by Henry Hyde, Chairman Hyde, Chairman Clinger, at the time the Chairman of this committee, and Chairman Thomas of the Committee on House Oversight. I will make this Deposition Exhibit 2. Again, it is an October 18th, 1996 letter.

    [Mills Deposition Exhibit No. CM–2 was marked for identification.]

EXAMINATION BY MS. COMSTOCK:

    Question. Do you recall receiving this letter or discussing this letter with anybody at the White House?

    Answer. I don't recall receiving this letter. I am sure I would have ultimately seen it, but I don't recall receiving this letter or having discussions regarding it.

    Question. Okay. Then directing your attention to the second page, where it discusses Mr. Huang's unavailability at the time in October for various parties to ask him questions about his activities, do you know if anybody at the White House was in touch with Mr. Huang in October of 1996?

    Answer. I do not know.

    Question. All right. So you were not in touch with Mr. Huang or his attorneys at that time?

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    Answer. Correct.

    Question. And you have no knowledge of any other White House attorneys being in touch with him?

    Answer. That's correct.

    Question. Do you have any knowledge of DNC attorneys, Mr. Sandler or others, being in touch with Mr. Huang or his attorneys in October of 1996?

    Answer. It was my understanding that Mr. Sandler was dealing with his attorneys and that Mr. Sandler had indicated that that is why they weren't able to talk with Mr. Huang directly. That's my only understanding.

    Question. Okay. Were you aware of discussions at the White House between and among Harold Ickes and Bruce Lindsey and Joe Sandler about matters related to Mr. Huang?

    Answer. I am sure if they had questions regarding the Hatch Act or his duties, and I recall one of the issues related to his move to the DNC and also Commerce, I would have had conversations regarding that, but I don't recall anything more particular than that.

    Question. Okay. Did you learn of any potential Hatch Act violations that Mr. Huang had been involved in?

 Page 369       PREV PAGE       TOP OF DOC    Segment 6 Of 22

    Answer. The only issue that I recall being raised was with respect to, I guess, his leaving of the Commerce Department and his starting at the DNC and that there may have been some overlapping period with respect to that because of government shutdown and Commerce not taking him off their payroll, something to that effect. That's my best recollection.

    Question. Do you recall how you learned that?

    Answer. I don't recall how I learned that. It might have been in conversations with Mr. Sandler. I just don't recall.

    Question. Okay. And that was when Mr. Huang initially had asked to go to the DNC at September 13th, 1995 meeting with the President and Mr. Giroir and Mr. Lindsey?

    Answer. I wasn't present at that meeting. I am confident you probably know that.

    Question. Yes.

    Answer. Okay.

    Question. So you are speaking, though, about that time when Mr. Huang requested to go to the DNC and then he left his Commerce Department job sometime in December?

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    Answer. I am speaking about having learned in 1996 with respect to one of the questions being the time period in which he may have been on both the DNC and Commerce Department payroll because the Commerce Department had not transitioned him off their payroll. I am speaking about that.

    Question. Okay. And did you have occasion to talk to anybody at the Commerce Department about that?

    Answer. I just don't recall. I am sure if there were questions I would have tried to address them but I don't recall.

    Question. Okay. Do you recall if Mr. Quinn asked you to look into that?

    Answer. He did not.

    Question. Okay. Do you recall if Ms. Sherburne had already looked into that matter at the time when you assumed these duties on October 30th?

    Answer. She may have.

    Question. All right. Do you know if she provided you with any files or notes on that?

    Answer. She may have.

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    Question. All right. And to your knowledge, were all of the notes and files that Ms. Sherburne provided to you preserved—you know, whatever materials she had gathered at that time, she had passed on to you?

    Answer. Right. But the majority of her materials were clips and materials like that and other things that were in her files that had already been produced.

    Question. All right. You mean they have been produced to this committee?

    Answer. Correct.

    Question. Okay. Another one of the issues that came up in October of 1996 were payments to Webster Hubbell from the Lippo Group. Do you recall dealing with that matter at all in October of 1996?

    Answer. No.

    Question. All right. Do you recall at any time, while you were handling these matters during the transition time between Ms. Sherburne leaving and Mr. Breuer coming aboard in February of 1997 handling any matters related to Mr. Hubbell and the Lippo Group, or Mr. Hubbell in general?

    Answer. I recall the issues regarding Mr. Hubbell arising in 1997 as opposed to in 1996. That's my best recollection.

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    Question. Now, there were editorials and stories that appeared about the Lippo Group in early October 1996.

    Answer. Okay. I am not familiar with those.

    Question. If that refreshes your recollection?

    Answer. It doesn't.

    Question. Okay. And earlier in 1996, in February of 1996, in fact, Mr. Hubbell had testified before the Whitewater committee and was asked questions about Lippo. Did you have occasion to be involved in any discussions related to that?

    Answer. No.

    Question. Okay. That would have been Ms. Sherburne's responsibility at that time; is that correct?

    Answer. Yes.

    Question. Okay. And so nobody at any time in February 1996 came to you to ask you about any of those matters related to Mr. Hubbell?

    Answer. That's correct.

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    Question. Okay. Did you ever have occasion to discuss with Mr. Lindsey any matters related to Mr. Hubbell and the Lippo Group?

    Answer. I am confident when this issue arose in the press sometime in early 1997 I would have had conversations with him. I don't recall having conversations with him prior to that time.

    Question. Okay. And we haven't gone through a lot of the preliminaries today, but just for the record, Mr. Lindsey is also Deputy Counsel at the White House?

    Answer. Yes, but he is an Assistant to the President.

    Question. Okay. And do you have any kind of reporting relationship to Mr. Lindsey on any regular basis regarding any of these matters?

    Answer. I do not.

    Question. Okay. But on a regular colleague basis, do you discuss these matters with Mr. Lindsey, or are your duties fairly separate so that you aren't discussing these matters?

    Answer. Our duties tend to be fairly separate. He tends to deal with more substantive issues like securities, litigation, products, tobacco. Those are typically not issues on which we overlap.

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    Question. Okay. Do you know when you first came to take over these duties on October 30th, 1996, did Mr. Quinn give you any type of deadlines or how quickly information should be provided?

    Answer. No.

    Question. Okay. Do you know when you first came on board to take over these duties, did you have Mr. Huang's WAVES records at that time? Were they in the materials that Ms. Sherburne provided you with?

    Answer. Some of them were. The problem is that Ms. Sherburne had not identified that there were two John Huangs. So the process was going through and identifying the wrong John Huang, so that we gave the committee the right John Huang's WAVES.

    Question. How did you learn that there were two John Huangs?

    Answer. In the process of going through and talking with people about potential meetings that might have happened, people would indicate that they had never met with the John Huang that was appearing on the TV, and which ultimately led us to determine that there had been a John Huang who was an IRS employee who had been working on the National Performance Review; and then it was easier to tell by the pattern of meetings which John Huang was the right John Huang and which John Huang was the wrong John Huang.

    Question. Our tongue twister for the day.

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    I am showing the witness an e-mail that is marked EOP 068461, which was—October 31st, 1996, is the date. It is to Jane Sherburne. Maybe you can tell us a little bit about the creation date and that type of thing, how the e-mails read just so we have a clear record of that?

    Answer. Well, this would have been an e-mail that was to Mary Ellen Glynn from Jane Sherburne, and Jane would have been communicating that I had informed her that there were two different John Huangs. That's what it appears to be.

    Question. Okay.

    Answer. This is an e-mail record so the e-mail record that comes back is a confirmation. That's why the ''to'' is to Jane Sherburne. She gets an e-mail record of the transmission of her page.

    Question. Okay. And do you recall transmitting this information to Ms. Sherburne about the two John Huangs?

    Answer. I don't actually have a particular recollection of discussing that with her, but I am sure I would have.

    Question. Okay. At that time, was Ms. Sherburne then still involved to some degree in handling any of the matters related to Mr. Huang?

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    Answer. Well, this was the day after she had given me the files, so I don't know how you would describe that, but I am sure that if she had asked, or if we had had a conversation, I would have informed her of that.

    Question. Okay. Were any contacts made with the other John Huang to find out when he had been at the White House?

    Answer. I actually did not make any contacts with the other John Huang. Basically, we tried by talking to the different staff members to walk through there, and so it was a process that took a little while.

    Ms. COMSTOCK. Okay. This is Deposition Exhibit No. 3.

    [Mills Deposition Exhibit No. 3 was marked for identification.]

EXAMINATION BY MS. COMSTOCK:

    Question. I am handing you two letters of October 31, 1996, one to Terry Good, head of Office of Records Management, and the other to the President.

    Mr. EGGLESTON. You didn't give me the first one, I don't think.

    Ms. COMSTOCK. We will make the Terry Good letter Deposition Exhibit No. 4 and the October 31st letter to the President Deposition Exhibit No. 5.

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    [Mills Deposition Exhibit Nos. CM–4 and CM–5 were marked for identification.]

    Mr. EGGLESTON. Is that another court reporter coming in?

    Ms. COMSTOCK. Yes. Just so you know, the only people that are permitted in the room are court reporters and Majority and Minority staff. We will attempt to identify them as they come in.

    Mr. EGGLESTON. Since she had that pull cart, I thought she was a court reporter, but I thought she might also be Kristi whoever.

    The WITNESS. Remington.

    Mr. EGGLESTON. That's what I wasn't sure about.

EXAMINATION BY MS. COMSTOCK:

    Question. Have you seen either of these letters before?

    Answer. I believe I have seen this letter. I don't recall seeing this letter, but I likely would have.

    Mr. EGGLESTON. The first letter she was referring to was Mills 4 and the second letter she referred to was Mills 5.

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EXAMINATION BY MS. COMSTOCK:

    Question. Okay. Do you recall how you learned about the letter to Terry Good?

    Answer. I don't recall how I learned about it. I am sure I would have probably gotten a copy of it.

    Question. Okay. Do you know if Ms. Sherburne had talked to Mr. Good about obtaining WAVES records?

    Answer. I do not know if she had.

    Question. Okay. Who has WAVES records at the White House? When you need to find the WAVES records and look at them, where do you go?

    Answer. We would go to Records Management, which would have the hard copies of the WAVES records, and review the hard copies to try and determine people's visits. It typically is a pretty long process because there are boxes and boxes of WAVES for all the different years.

    Question. And when—do you know generally when Mr. Good was requested or somebody in the records office was requested to get Mr. Huang's WAVES records?

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    Answer. I do not.

    Question. Okay. Do you know at all how quickly he was able to provide them or when he provided them?

    Answer. It is a process. He can't do it himself. Actually, on a lot of occasions we have to provide people to actually go through it. It is literally boxes and boxes and boxes of material, which is—it is pretty substantial so if one person were undertaking that task it would take them days.

    Question. Okay. Now, on October 31st, this committee had sent a letter to Mr. Good regarding obtaining the WAVES records. He had informed the committee that Mr. Good had the—you know, he could provide these dates—these records within a day or so. Did you have occasion sometimes for Mr. Good in the records office to provide you WAVES records in a day or two?

    Answer. I have never had occasion where they have been able to provide them in a day or two.

    Mr. EGGLESTON. Nor does Ms. Mills have any knowledge about the representation that you just made about Mr. Good.

    Ms. COMSTOCK. No, I understand. I am making that representation.

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    Mr. EGGLESTON. I want to make clear she didn't buy into that, because I don't believe she has any knowledge of that.

EXAMINATION BY MS. COMSTOCK:

    Question. Do you recall any discussions you had with Mr. Good about the WAVES records pertaining to Mr. Huang?

    Answer. No, I don't believe so. I believe that—I believe that those materials might have been in the materials Ms. Sherburne provided to me, because I don't recall having a particular discussion with Mr. Good. But I am only guessing.

    Question. Do you recall then when you first took over these duties and if Mr. Quinn asked you to gather all the information that you could about Mr. Huang and his visits to the White House?

    Answer. I recall when I took this over that there were questions regarding Mr. Huang's visits, so I don't know that anybody specifically had to direct me in that regard. I recall knowing that one of the issues of interest was Mr. Huang's WAVES.

    Question. Okay. I will provide you with a copy—actually, this is EOP 4969 through 5018. And it is a fax cover sheet from the Counsel's Office dated November 2nd, 1996 to Bruce Lindsey from C.D. Mills, which would be you; is that correct?

    Answer. Yes.

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    Question. And can you just tell us about this fax and these WAVES records attached to it?

    Answer. We were trying to attempt to go through and identify and eliminate the wrong John Huang from the WAVES records, and this was, as of the 2nd, what we had been able to eliminate as the wrong John Huang. Subsequently, we identified more, but at this point, this is where I was in my ability to be able to do that.

    Question. Okay. And so is it your testimony then that these WAVES records that are attached to this fax, that you had this information, the WAVES records, when Ms. Sherburne gave you the files on October 30th?

    Answer. I think it is quite possible that that was the case. That's my best guess, because I don't recall speaking to Mr. Good regarding the WAVES records for Mr. Huang.

    Question. So between October 30th, when you took over these duties, and November 2nd, the date of this fax, which has the WAVES attached to it, you do not recall going to Mr. Good and asking him to produce these records?

    Answer. That's correct. I do not.

    Question. You don't have any idea how long prior to this date he had been asked to provide the records?

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    Answer. Correct.

    Question. Do you know if Mr. Good's office keeps track of requests or there is any dating on this document, which indicates when it was requested?

    Answer. No.

    Question. Could you just describe the process, then, by which you went through these WAVES records?

    Answer. I typically tried to speak to the different people, if the person might have been waved in, to try to determine if it was the right John Huang or the wrong John Huang.

    Question. And this fax had been sent to Mr. Lindsey?

    Answer. Yes.

    Question. Why was it sent to Mr. Lindsey?

    Answer. At this point they were receiving questions on the road regarding Mr. Huang's visits to the White House, and I know that one of the issues was whether or not we were able or in a point to accurately identify Mr. Huang's visits.

    Question. When the fax number here says ''Road Runner,'' is that to send the fax to Air Force One or where is it sent to?

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    Answer. Road Runner travels wherever the President is, so if he is down in a hotel room, then Road Runner is in the hotel, if he is traveling, it is on the plane, if he is golfing, it's at the golf course. Road Runner is the particular fax machine that travels wherever.

    Question. So the fax even goes to the golf course?

    Answer. Yes.

    Question. Why don't we then go through these, then, starting on page EOP 4971. These WAVES include both Riady WAVES and then I believe they pick up John Huang WAVES; is that correct?

    Answer. 4978 is where the Huang WAVES start. Prior to that are Riady WAVES.

    Question. Just so that the record is clear, do you recall that the Riady WAVES were also in the group of documents that Ms. Sherburne transferred over to you?

    Answer. I would guess that they were because I don't recall having a conversation with Terry Good about the Riady WAVES.

    Question. Okay. And do you know why the Riady WAVES were collected at this time?

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    Answer. I do not, other than he obviously had an association with Mr. Huang.

    Question. Then if you could just, you know, as we start, then, going through these, this is your handwriting on this document?

    Answer. Yes.

    Question. Okay. And on some of these, for example, on the first one, it says James Riady. Next to it it says, meeting, then it says, Neel, N-E-E-L, and then it says, Huang, Grobmyer, drop by. Would that be, then, information that you learned when you talked to Mr. Neel?

    Answer. Well, just to be clear, meeting is ''MTG,'' so it is referring to meeting but it says ''MTG.''

    Secondly, I don't recall actually having a conversation with Mr. Neel but it would have been through either Mr. Neel or other information that we were able to discern that this was a meeting or our best information was that it was a meeting.

    Question. And what was the body of information that you used to check to determine some of these things?

    Answer. I would ask people for any schedules, what their recollection might be, any of the President's schedules, any kind of materials that might suggest if there were newspaper articles written about that, about particular things at the time period, I might look at that. I would look at anything that would seem to provide information or shed light about the different visits.

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    Question. At this time did you have anybody working with you on this?

    Answer. At this time I had only my assistant, Melissa Murray.

    Question. Okay. And is she still in the office with you?

    Answer. She actually left to go work at Arnold and Porter.

    Question. Is she an attorney?

    Answer. No.

    Question. She is a paralegal?

    Answer. Of a sort. She is better than a paralegal.

    Question. Sort of a super staff assistant?

    Answer. Yes.

    Question. I'm sorry, her name again?

    Answer. Melissa Murray.

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    Question. What was Ms. Murray doing to assist you with this project?

    Answer. She is my assistant so she actually answers my phones, she collects materials if somebody is supposed to be sending them to me. She literally is my assistant.

    Question. Do you sit down and sort of figure out what would be the places to go to find out about these meetings and the sources of information to be able to determine, you know, what these visits to the White House were about?

    Answer. I don't recall really sitting down very often because it was very—there were a lot of requests that were coming in at that point toward these particular materials, but I would obviously sit and try and think through as I went through each one of these who I might need to talk to to try and figure out what the particular visit might be about or what information I might be able to look at to figure that out, so I might ask her to go to the scheduling office and pick up the President's schedule for a particular day and she would go and fetch it for me. I mean, that is what she would do.

    Question. And who would she go to to get that, the President's schedule?

    Answer. We have a scheduling in advance office.

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    Question. And she could go there, pick a date, and get the scheduling information fairly instantaneously?

    Answer. She could get it. Fairly instantaneously might be a little bit of an overstatement, but, yes, she could go to the office and get it.

    Question. She would get it that day?

    Answer. Yes, usually, typically, unless it was late and there was no one there.

    Question. Is this the President's computerized schedule that is kept track of or how is the information scheduled?

    Answer. The President has a schedule every day, which are also published, as you know, in the Presidential documents, they keep a copy of them.

    Question. Are there any other schedules that you had her check?

    Answer. I am sure if there were other schedules, I would have had her check them as well. I had her check whatever materials or information I needed to try and address a particular request.

    Question. Did she check with Ms. Hernreich or with the diarist or any of those sources?

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    Answer. I am sure if there was information that would have been helpful in either of those places, we would have gone there. I don't particularly recall that, but if there would have been information, we would have tried to collect it.

    Ms. COMSTOCK. And why don't I go ahead and—we will go ahead and make this Deposition Exhibit No. 6, which we are going to have to use your copy when we get done here.

    The WITNESS. Could you start again, I'm sorry.

    Ms. COMSTOCK. We are going to make these WAVES records Deposition Exhibit 6.

    [Mills Deposition Exhibit No. CM–6 was marked for identification.]

    Ms. COMSTOCK. But I also wanted, while we are going through this, to show you what would be Deposition Exhibit 7, which is EOP 4499 through 4501, which is a ''Summary of Records of Riady Meetings.''

    [Mills Deposition Exhibit No. CM–7 was marked for identification.]

EXAMINATION BY MS. COMSTOCK:

    Question. And just so we can clarify for the record, is that your handwriting on this document?

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    Answer. It is not.

    Question. Do you know whose handwriting that is?

    Answer. I do not.

    Question. Have you seen this document before?

    Answer. I have.

    Question. Okay. Do you know who is working on ''Summary of Records of Riady Meetings''?

    Answer. I believe Ms. Sherburne.

    Question. And do you recall, then, if she transmitted this to you in the materials she gave you?

    Answer. I believe this would have been something that would have been in the materials. I don't have a particular memory, but this would strike me as something that would have been in the materials.

    Question. Do you know if you did any additional work on this or taught somebody to work on a ''Summary of Records of Riady Meetings''?

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    Answer. Other than the WAVES records we provided and to the extent there are charts that list out each particular visitor and visitee, no, I did not.

    Question. Okay. Do you know if Ms. Sherburne provided you with ''Summary of Records of Huang's Meetings'' at this point?

    Answer. I don't recall. I recall this particular document, but I don't recall whether or not she had done a similar document for Mr. Huang. Mr. Huang's visits were substantially more in number, so I just don't recall actually seeing the Huang chronology. That is just my best memory now.

    Question. Okay. And so would it be a fair guess that the documents that Ms. Sherburne lists in the ''Summary of Records of Riady Meetings'' were included in these records she gave you at that time?

    Answer. They may be, but not all of them would have been. I mean, some of these are just information she might have had through conversations or other things like that.

    Question. Like the first item, it says an April 11, 1993, memo from Hernreich to the President, it says that, quote, Joe Girorir called on behalf of his client, Riady, who is in D.C., and would like to meet with you about Suharta, I think it is Suharta, but would that have been in a document that was in the records?

    Answer. It might have been, though I don't recall that document, quite candidly.

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    Question. Do you recall discussing with Ms. Sherburne, you know, if she had gone out and gathered records from people such as Ms. Hernreich or others about Riady or Huang?

    Answer. I don't recall having that discussion. I recall when she transferred the materials that she indicated that she was transferring what she had done to that point. I don't recall having conversations about how she had gone about doing that.

    Question. Do you need to take a break?

    Answer. No.

    Mr. EGGLESTON. Not right now.

EXAMINATION BY MS. COMSTOCK:

    Question. Okay. And then, also, in this first paragraph it says, ''Betty has in BC memos a letter from Mark Grobmyer on this same topic.''

    Do you know if that is Betty Currie, who works in the President's office?

    Answer. That is what I would have guessed.

    Question. And do you know what BC memos refers to?

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    Answer. Ms. Currie has a practice of when a correspondence comes in, writing a memo saying this is what the correspondence particularly says, and I think you probably have copies of some of those because we provided them in connection.

    Question. So Ms. Currie, as a practice, keeps all of the letters and correspondence that goes directly to the President?

    Answer. No, I didn't say that. She has a practice of summarizing correspondence that she reviews. I don't know what her system is and whether or not she sees all the correspondence or anything with respect to that.

    Question. But any correspondence that she does see, she has a practice?

    Answer. I don't know what her decision-making is to decide what she actually puts in the memo, so I don't know if she sees correspondence that she doesn't put in or if she puts all of it in. I don't know what her practice is in that regard.

    Question. Have you had occasion to gather documents from Ms. Currie in the past?

    Answer. Yes.

    Question. Okay. And do you just have a general familiarity with the BC memos file?

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    Answer. Correct. It is not, to my knowledge, a file, actually. My only experience with it has been with respect to copies of it that have printed from her computer.

    Question. So this is a computerized record that she keeps?

    Answer. It is a memo. I don't know if you all have seen the documents, but we provided to you in your documents a memo where she writes a memo to the President, correspondence and then she writes a summary of each one of them, and I am confident that is in the materials we provided. That is what I am familiar with.

    Question. Okay. So it is your recollection, then, that this ''Summary of the Records of Riady Meetings'' you had at the time when you started going through to assess what some of these meetings were about?

    Answer. It is my best guess that I would have had it. I don't have a specific recollection of having had it, but I recall seeing this document.

    Question. Okay. And, again, could we then just return and maybe go through some of these meetings that Mr. Riady had, and if you can look at the actual record to refresh your recollection of who you talked to and tell us about the people you talked to and what they told you about the meetings?

    Mr. EGGLESTON. Actually, I could use a 5-minute break.

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    Ms. COMSTOCK. We will go off the record for a few minutes.

    [Brief Recess.]

    Ms. COMSTOCK. Back on the record.

EXAMINATION BY MS. COMSTOCK:

    Question. I think we were talking about if you could explain the process whereby you went through and talked to various people in various offices.

    Answer. Generally, what I tried to do is look at the WAVES records and then figure out what information might be helpful in determining what the visit was about and talk to people or look at whatever schedules or other things I could to determine what a particular visit might have been about.

    Question. Do you know if you reviewed any pictures or checked with the photo office about any events?

    Answer. I don't recall. I am sure I might have, but I just don't recall.

    Question. You said the first James Riady visit, which the visitee is identified as Neel, would that be Roy Neel?

    Answer. That is my best information, yes.

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    Question. And do you recall talking to Mr. Neel about this visit?

    Answer. I don't.

    Question. Okay. So is it your guess that you learned from other records who else was at this meeting or do you recall? If you have any recollection.

    Answer. Right, I don't have any recollection so I couldn't guess. I mean, this was for me a while ago so I am not in a position to recall who I spoke to and who I didn't and what materials I might have looked at.

    Question. And then the second person is listed as a visitee for April 13, 1993, visit, is Dickey. Do you recall talking with, was it Robin or Helen, whichever Dickey this is?

    Answer. Right, I don't know which Dickey this is and I don't recall whether or not I spoke to them. I am sure I might have but I just don't recall.

    Question. And then there is another entry on April 13 for Yee. Do you know if that would be Melinda Yee, who worked in the personnel office at that time?

    Answer. That is my best information.

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    Question. Do you recall if you talked to Melinda Yee at any time about John Huang or James Riady?

    Answer. I don't believe I did because I don't believe she was in the White House at this point, so I don't believe I did.

    Question. Do you know if you reached out to anybody outside the White House sort of in going through these?

    Answer. I am sure I might have but I just don't recall with respect to Ms. Yee having had a conversation with her.

    Question. Do you know Melinda Yee?

    Answer. I do know her.

    Question. And have you had occasion to speak with her at all about any of her dealings with John Huang?

    Answer. No.

    Question. Or with James Riady?

    Answer. No.

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    Question. Or with matters related to fund-raising, any of the matters under investigation?

    Answer. No.

    Question. And, again, there is another entry on April 16 for the visitee being Dickey. You don't recall having any conversations?

    Answer. I don't recall what I would have done to determine what that particular visit would have been about.

    Question. And then the 4/19/93 entry is for Rubin, and then it says in POTUS photo, with all three men, Riady, Huang, Grobmyer.

    Do you recall discussing that visit with anybody?

    Answer. I don't recall having discussions regarding that other than trying to figure out whether or not they had actually gone and seen the President on that occasion. I believe, actually, Ms. Sherburne had information about that but I don't recall any particular discussions.

    Question. Okay. Do you recall anything about what that meeting was about or how you learned that there was a photo?

    Answer. I don't recall.

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    Question. The next page of these documents, EOP 4972, it continues with Mr. Riady's visits, and the next two entries are for Aileen and James Riady on June 21, 1993, and the visitee is Middleton. Is that Mark Middleton?

    Answer. Yes.

    Question. Do you recall if you spoke with Mr. Middleton about any of his visits with Mr. Riady?

    Answer. I might have. I don't recall having done so, but I might have.

    Question. You don't have any recollection of talking to Mr. Middleton about these visits?

    Answer. I actually do not.

    Question. Okay. When you say you might have——

    Answer. I just say I might have because he is a person who is still in town, but I don't recall having conversations with him regarding this.

    Question. Do you recall any discussions with his attorney?

    Answer. I am sure I probably would have.

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    Question. Can you tell us what you discussed with his attorney about any meetings?

    Answer. I don't recall having any particular discussions in that regard, other than probably to indicate his name was on these and we were going to be sending out the WAVES records. I think the only other thing, actually now that I think about it, is that his attorney, who is Bob Luskin, I believe, would have indicated, I think, that he would answer questions about this. I am only guessing that because there is nothing next to these so I probably would have referred any questions that came directly to him. I only say that because there is nothing next to these that is written.

    Question. So it is your recollection that Mr. Luskin told you that any inquiries could be directly sent to him?

    Answer. That is my best guess.

    Question. Instead of giving you the information?

    Answer. That is my guess by looking at the records. I don't have a particular recollection.

    Question. And I have asked you about whether you talked to him about Mr. Middleton's visits with Riady. Do you recall if you ever talked to him, Mr. Luskin or Mr. Middleton about his visits with John Huang?

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    Answer. I am sure as we have gone through these records I would have had conversations with Mr. Luskin regarding Mr. Middleton or any questions or information that we needed with respect to that to be giving accurate information. I don't recall any particular discussions.

    Question. Okay. When you spoke with Mr. Middleton's attorney, did he express any reluctance to discuss why he was meeting with Mr. Riady or Mr. Huang?

    Answer. I don't recall that, but I also don't recall what the substance of all of our conversations were, but I don't recall him ever expressing reluctance or anything like that.

    Question. And the time frame of October of 1996, there had been a story about Mr. Middleton allegedly soliciting or being offered $15 million from somebody in Taiwan for the DNC. Do you recall ever having any discussions with his attorney about that matter?

    Answer. I do not recall that matter.

    Question. Do you know Mark Middleton personally?

    Answer. Yes.

    Question. Have you ever had any discussions with him on any of the matters under investigation?

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    Answer. Not that I recall.

    Question. Do you have any knowledge as to why he is taking the fifth on these investigations?

    Mr. BALLEN. I am going to object to that question.

    Mr. EGGLESTON. Because he is exercising constitutional right.

EXAMINATION BY MS. COMSTOCK:

    Question. Do you have any personal knowledge about Mr. Middleton's meetings with John Huang or James Riady?

    Answer. No.

    Question. This is your handwriting. It says the entry that is fifth down, Johnson, visitee, James Riady, on June 28, 1993, and it says that he worked for Middleton. Do you know who that is?

    Answer. I don't know who it is. I think I was able to discern—I believe it might be that the person was Mr. Middleton's assistant. I don't know how I was able to determine that.

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    Question. You don't recall learning that from Mr. Middleton or his lawyer?

    Answer. Correct.

    Question. Let's go on to the next page, EOP 4973. Now, on this page, there is a second entry, James Riady, visitee is Middleton, and it also lists Huang.

    Do you know if you learned that from Mr. Middleton or his attorney or if that was in reviewing other WAVES records or how you learned it?

    Answer. Probably that I would have learned by looking at Mr. Huang's WAVES but that is just my best guess.

    Question. And this visit in June of 1994 was in the time frame when Mr. Hubbell received his payments from the LIPPO Group. Do you recall ever having any discussions with Mr. Middleton or his attorney about Mr. Hubbell?

    Answer. I don't recall.

    Question. And the third entry on this page for June 23, 1994, is for I guess another member of the Riady family, where it says, Nancy. Is that another—it's an Indonesian name. It's spelled T-J-A-H-A-J-A, and then to the left of it it says, Nancy.

    Answer. I don't know why it says Nancy.

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    Question. Okay. And then the visitee is Herman. Would that be Alexis Herman?

    Answer. Yes.

    Question. And do you recall having any discussions with Ms. Herman about Mr. Riady?

    Answer. I do not.

    Question. Okay. Now there is a star on Ms. Herman's name where it says Herman not present, briefing to CEOs, and reps of corps. That is your handwriting. Why don't I have you read it instead, if you can, if it is your handwriting.

    Answer. It is my handwriting but the copy is not clear, though my understanding is, it says, Herman not present, briefing to CEOs and reps of corporations, or C-O-R-P, semicolon, Doris welcome slash Emerson Gatt, slash, Rubin economy in Roosevelt room.

    Question. Okay. And do you recall how you learned of that meeting and that description?

    Answer. I don't recall, actually. It might have been a briefing paper. It might have been anything. I just don't recall.

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    Question. Okay. And Emerson, is that John Emerson?

    Answer. Yes.

    Question. And Rubin, is that Robert Rubin?

    Answer. Yes.

    Question. And then you have no other recollection of what you learned about this meeting?

    Answer. No. This was actually quite a while ago and a relatively detailed process and I just don't recall, actually, with respect to these particular entries, other than I obviously tried to talk to people and look at whatever schedules or other information there might be to try and discern any particularized conversations or other things like that with regard to those records.

    Question. Did you keep contemporaneous notes of these conversations you were having with people at that time or was this the only document you put information on?

    Answer. This is the document I put information on.

    Question. Did you have other notes you kept as you were going along, or that you took but you did not keep?

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    Answer. I don't believe so.

    Question. So were you sitting down as you called people and just noting things on each of these meetings?

    Answer. Or I would recall, based on conversations I had with them, or having looked at something, I would either do it while I was having conversations or I would recall conversations that I had.

    Question. Okay. Do you recall how long of a process this was, going through these WAVES records?

    Answer. I actually don't. But this was the process that helped be able to learn that there were two John Huangs because I placed I think a random call to one person that just looked different than other people, and that is how I started this process, and that is why we started going through the entire process.

    Ms. COMSTOCK. For the record, Kristi Remington is also joining us this morning.

EXAMINATION BY MS. COMSTOCK:

    Question. Okay. And the next entry here is Middleton, again, it is——

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    Mr. EGGLESTON. Ms. Comstock, I am not going to stop you from doing this, but I am fairly confident you are going to get the same answer. You can go through every one of these, and, again, I haven't reviewed these with her, and it's possible I am wrong, but I am willing to bet that every time you ask her she is going to say I generally remember doing this, I can't tell you where I got the information. Again, it is your deposition, I can't stop you, but I am fairly confident she is going to give you the same answer.

EXAMINATION BY MS. COMSTOCK:

    Question. Well, maybe if you can review them, and in reviewing the documents if there is anything that you can tell us about, for example, Mr. Middleton and any conversations you had with him, some of these indicate whether this was lunch or that it was lunch, you know, how you learned about that, who were the sources of information that you would go to to find out if an event was a lunch or how you would determine information like that?

    Answer. Typically, with respect to time frames, if it was around noon or 1:15, our best estimate would be those would be lunches, because those are the sittings for the Mess.

    Question. Okay. And do you recall if you had conversations with Mr. Middleton's attorney about did Mark meet with these guys for lunch or have them over or know generally that he had done so?

    Answer. I am sure I would have asked whether or not it would have been likely he would have been having lunch, but I just don't recall particularly.

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    Question. Okay. And this Weaver is identified here also as one of the visitees. Do you know Vanessa Weaver?

    Answer. Yes, she works in the White House currently.

    Question. And do you recall any conversations you had with Ms. Weaver about the Riadys?

    Answer. I am sure I would have spoken with Ms. Weaver or seen materials or information that led to it. I don't recall particularly, but I am sure I would have.

    Question. Do you have any understanding of what Ms. Weaver's contacts with the Riadys were about?

    Answer. I do not, other than the information reflected on here.

    Question. Do you recall trying to discuss with her why she was meeting with them or why they were there?

    Answer. I am sure I probably would have but I don't recall particularly having those conversations, but I am sure that is something I would have tried to do to try and give accurate information.

    Question. Okay. Was there anybody that the Riadys met with that you have any recollection of talking about what their meetings were about?

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    Answer. I am looking because I recall an occasion where I had a conversation with someone regarding Mrs. Riady. This conversation I recall with respect to Mrs. Mochtar Riady also being present because people remembered her jewelry. I just recall that standing out in my head.

    Question. Is that on page——

    Answer. That is EOP 4976.

    Question. That reflects a record of Mochtar Riady visit, and Weaver is the visitee and it says lunch, Peg Clark, Paul Miller, John Huang, Mrs. Riady, question mark?

    Answer. Correct.

    Question. And do you recall who you talked with about that?

    Answer. It would have been either Vanessa Weaver or Peg Clark.

    Question. And who is Peg Clark?

    Answer. She also works in Presidential Personnel or did work in Presidential Personnel.

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    Question. Who is Paul Miller?

    Answer. He used to work in Presidential Personnel.

    Question. And do you know why all these people in Presidential Personnel were meeting with the Riadys on June 27, 1996?

    Answer. I do not.

    Question. Okay. A number of these meetings were with people in the personnel office—well, I guess with Ms. Weaver, largely, and then, initially, the meetings with Melinda Yee were at a time when she was in the personnel office.

    Do you recall generally learning of the Riadys talking to people in the personnel office?

    Answer. No, actually, I don't. I don't recall learning that.

    Question. Do you have any knowledge as to why they were meeting with people in the personnel office?

    Answer. No. It is my sense that they were actually meeting with people, as opposed to meeting with the personnel office.

    Question. Were you aware of the Riadys trying to recommend people for positions?

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    Answer. That is how I interpreted your first question, and no I was not.

    Question. Did you attempt to learn anything about their attempts to assist people with getting jobs?

    Answer. I was unaware that they made attempts to assist people in getting jobs.

    Question. Do you recall reviewing any correspondence or seeing any records where they were promoting any individuals for positions?

    Answer. I recall that Mr. Huang was interested in a position, and I believe Mr. Huang might have indicated Mr. De Queljoe, I recall seeing correspondence like that that I know were produced to you.

    Question. And did you talk with Ms. Weaver or anybody else at the personnel office about Mr. De Queljoe?

    Answer. I don't believe so. I am sure I might have spoken with someone about Mr. De Queljoe when there were inquiries regarding him and we were looking for materials related to him, but apart from that, I don't.

    Question. So other than this meeting where people recalled Mrs. Riady's jewelry, is there anything else that you recall about the Riadys, hair styles or anything?

 Page 411       PREV PAGE       TOP OF DOC    Segment 6 Of 22

    Answer. That is the one that sticks out in my mind.

    Question. Were you attempting at this time to find out what they were doing there, why they were there?

    Answer. I was attempting to determine what the purposes of their meetings were, particularly as we wanted to ensure that we were obviously providing accurate information.

    Question. And do you have a general impression of what you learned in that process, of what they were doing there?

    Answer. I don't, actually, other than it just appeared to me they were actually visiting people as opposed to having any particular agenda.

    Question. And was it your understanding these were people they knew prior to these individuals joining the administration?

    Answer. I don't know the answer to that question. I don't believe I had that impression one way or another.

    Question. Well, did you inquire as to how they came to meet with these particular people, why were they meeting with Mark Middleton, why didn't he become somebody who was a point of contact for both Mr. Riady and Mr. Huang? Do you recall having any discussions about that?

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    Answer. Setting aside the premise of your question, I don't recall any particular sense of why they were seeing the particular people they were, other than the things I ended up reflecting on this particular document.

    Question. And the premise of my question was that a number of the meetings with both Mr. Riady and Mr. Huang, quite a few of the Mr. Huang ones, and actually, although we don't have them here, Mr. Trie also met with Mr. Middleton quite a bit.

    Answer. Just to be clear, I am only looking at the Riady records right now so I don't have a perfect memory of that.

    Question. And that is why I am saying the entire document here does have—as we move on later, Mr. Middleton also had occasion to meet with Mr. Huang, so I was wondering if that stands out in your mind, having learned about Mr. Middleton being a point of contact for some of these people, Mr. Riady, Mr. Huang, Mr. Trie, others?

    Answer. No, it does not. I don't recall him being a point of contact for them. That is not something that stood out in my mind.

    Question. Now on page EOP 4974, it has an asterisks for Aileen Riady, also present in picture. Again, I know I asked you before about pictures, but do you recall if there were pictures in the file that Ms. Sherburne turned over to you?

    Answer. I do not recall there being pictures in the files. There may have been; I just don't recall that.

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    Question. Do you recall if you asked your assistant to check with the photo office or look into that?

    Answer. Asking my assistant, you said? I thought you said her assistant. I am sure I would have asked if it would have been likely if there was a picture to ask her to go look and see if there was one. I just don't recall that in particular.

    Question. And on page EOP 4975, they have visitee, and on the top entry on September 13, 1995, it says Nancy Hernreich, and that was a meeting with the President and Mr. Lindsey, Joe Girorir, and then John Huang, and I believe Mr. Riady.

    Do you recall having a discussion with anybody about that meeting?

    Answer. I recall there being lots of discussions about this meeting in the press and other places. At the time that I was doing this, I don't recall, other than obviously going through and identifying the participants for that particular meeting. I believe there came a point there was lots of discussion regarding that meeting.

    Question. Okay. And I will go into that a little later but I was wondering, at the time did Mr. Lindsey tell you about this meeting or did you discuss it with him?

    Answer. I just don't recall because I recall this meeting becoming the topic of conversation at some point when there were news articles related to it, and I can't associate in time to tell you when those would have been in relationship to this. I think they may have been subsequent to this.

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    Question. Generally, can you tell us what Mr. Lindsey told you about this meeting? At any time can you recall what his recounting of this meeting was to you?

    Answer. I recall that there were discussions related to Arkansas family and friends. I recall that Mr. Huang had indicated at some point that he was interested in going to the DNC, and I recall that—I think that is my best recollection right now with respect to that. There was a subsequent meeting I guess with Mr. Riady too, and sometimes in my brain I collapse the two because both of those were topics of interest from the press.

    Question. And would that be this October of '96 meeting?

    Answer. Yes.

    Question. Where Mr. Middleton was at that meeting with Mr. Lindsey?

    Answer. Right.

    Question. And Mr. Riady?

    Answer. Correct.

    Question. And do you recall what you talked about at that meeting?

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    Answer. I recall learning that that also was an occasion where Mr. Riady and the President talked about Arkansas and family and friends.

    Question. Did you learn how that meeting came about?

    Answer. Not that I recall.

    Question. Were you told anything about Mr. Middleton setting up that meeting?

    Answer. That would make sense, but I don't recall actually being told it was Mr. Middleton. I am sure at the time period when this was going on, I probably knew, but I don't recall right now.

    Question. Do you have any knowledge, now or then, tell us when you had it, about Mr. Middleton doing any work for Mr. Riady or with the LIPPO Group?

    Answer. No.

    Question. When you say it would make sense he would set it up, why would it make sense Mr. Middleton would set up the meeting with the President for Mr. Riady?

    Answer. Because he was present, so I am just guessing based upon his presence he might have called and said he was going to be in town.

 Page 416       PREV PAGE       TOP OF DOC    Segment 6 Of 22

    Question. And do you know why Mr. Middleton would be the person setting up the meeting for Mr. Riady?

    Answer. I do not.

    Question. Did you attempt to find out anything about what Mr. Middleton was doing with Mr. Riady?

    Answer. I am sure at that time I probably did, but I don't have any particular recollection that stands out in my mind about that.

    Question. You have no recollection of what Mr. Middleton was doing in connection with the Riadys?

    Answer. I do not, but I am sure there are materials or other documents we probably produced to you that might shed light on that that I would have obviously been familiar with at that time, but I don't have a particular recollection of it right now.

    Question. And sitting here today, you didn't get an impression or an understanding of what he was doing?

    Answer. That's correct.

    Question. Were you seeking to find that out or were you just trying to get the basics?

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    Answer. At this point I probably was trying to get the basics, primarily, because obviously we were trying to make sure we had accurate information and there were lots of requests for the materials. I am sure at the time when there were all the different press inquiries and interests with respect to Mr. Riady's meetings with the President I would have learned more. I just don't recall in particular any association with why Mr. Middleton was present at the meeting and why he might have set it up.

    Question. Again, do you recall having any discussions with Mr. Middleton or his attorney about, in particular, him setting up that September '96 meeting or being involved in it?

    Answer. I am sure I would have talked to his attorney. I don't have a particular recollection of what might have been communicated in that conversation, but I am quite confident I would have attempted to speak to his attorney about it.

    Question. When you speak with people's attorneys, do you take notes of those conversations?

    Answer. I do not.

    Question. And is that a practice that you had stopped then at some point at the White House?

    Answer. It is a practice I do not engage in.

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    Question. Okay. Again, EOP 4977 is the September 9, 1996, meeting, which I think we were referring to with Mr. Middleton, Bruce Lindsey and the President, and is that another name for James Riady then? Is that your understanding?

    Answer. Yes.

    Question. And I will try to pronounce that. I don't know if you are able to.

    Answer. No.

    Question. It's spelled T-J-A-H-A-J-A. I know it is not very good handwriting—your handwriting is very good, but the copy isn't very good here, but can you tell us what, to the extent possible, what your notes say on the bottom of that page?

    Answer. Respect to foreign policy, supportive of our trade, I can't read those two, and hope for continuing better relations. There is a part in the middle I cannot read.

    Question. Where there is a slash there, is that something China?

    Answer. It could be. I just can't read it very clearly.

    Question. Do you recall if that referred to Mr. Riady having a general discussion with the President about China policy?

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    Answer. I don't recall him having a general discussion. I actually recall it as Mr. Riady, upon his departure, indicating he was glad the President had addressed China and encouraged that we continue engaging China. That is my best recollection and that is based on all the different attention that ultimately ended up being paid to that meeting and the previous one.

    Question. Can you tell us the time frame of when you were making these notes or doing this?

    Answer. This would have been—I mean, the best guess I would have would be sometime in November I would have been doing these.

    Question. Now this copy was actually sent to Mr. Lindsey on November 2nd?

    Answer. That is not——

    Question. That is not the case?

    Answer. That is not accurate. The copy that was sent to Mr. Lindsey did not have handwriting on it, so it would have been exactly this without handwriting.

    Question. So initially what you sent to Mr. Lindsey on November 2nd was a copy of this document without any handwriting at all?

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    Answer. I don't know if it was exactly this document, yes, it would not have had handwriting on it, or that is my best guess.

    Question. And why do you say that?

    Answer. Because at that point we were still trying to determine what were the actual correct WAVES for John Huang, and so subsequent to the faxes that I sent at that point, we discovered there were more John Huangs that were the wrong John Huang.

    Question. All right. And on the front cover, it says, on the fax sheet, the November 2nd one says, new version, eliminate several instances where it was a different John Huang, otherwise say an exact, is that cleanup?

    Answer. Yes.

    Question. Date of birth in 1996?

    Answer. Correct.

    Question. Could you tell us what that means?

    Answer. That was just trying to eliminate the different John Huangs.

    Question. And how did you do that?

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    Answer. By talking to different people and also by, in certain instances in '96, the date of birth is actually indicated, so we could eliminate based on the date of birth.

    Question. So the date of birth is actually in the database or the WAVES database——

    Answer. In '96 it was. In previous years it wasn't. That is why it requires conversations with people.

    Question. And then on the next fax page of November 3rd, 1996, can you explain your comments there that you made on that fax transmittal sheet?

    Answer. Additional Huang, checked ones are new; total: 11 WAVES; 6 actuals; new total, 140 WAVES; 95 actual WAVES.

    Question. Okay. Could you explain that?

    Answer. It is still part of the process of trying to get rid of the wrong John Huangs and make sure we had the right ones.

    Question. At this time it says you only faxed 6 pages in the second time, 6 pages that were part of this 41 that we—or however many?

    Answer. That is probably right, part of the overall WAVES.

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    Question. Now this is a November 1st, 1996, letter from Chairman Clinger of this committee. At this time when you were working with this, were you aware that Chairman Clinger had requested these records?

    Answer. I don't have a particular association. There were lots of people requesting them so I don't know I would have had a particular association with him versus all the other Members seeking copies of John Huang's WAVE, but I was cognizant of the fact that Members of Congress were receiving the WAVES and were trying to go about determining what records would be responsive to do that.

    Question. And was Kathleen Wallman involved in this process at that time?

    Answer. She was the deputy at that time.

    Question. And were you working with her on these matters at all?

    Answer. Not particularly.

    Question. Now this letter reflects conversations made at the time, and I understand—do you have any knowledge of those conversations Ms. Wallman had with this committee?

    Answer. No.

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    Question. And the letter here refers to a discussion with Ms. Wallman, where she claimed that Mr. Quinn was too busy to get to these records and that they weren't going to be getting to them.

    Do you recall anyone telling you that they weren't going to get to these records or not to do them?

    Answer. No.

    Mr. EGGLESTON. Nor does she know in fact whether that was said by Ms. Wallman.

    Ms. COMSTOCK. I understand. I am just asking about your knowledge of anybody communicating with you that they are trying to get the records to anybody at a certain time.

    The WITNESS. It was my impression that these records were being requested and that we were going about trying to address that request, and that is with respect to what I was doing.

    Ms. COMSTOCK. What document number are we up to?

    Mr. EGGLESTON. I thought this was 8.

 Page 424       PREV PAGE       TOP OF DOC    Segment 6 Of 22

    Ms. COMSTOCK. This is 6.

    I will make the November 1st, 1996, letter to Mr. Quinn from Chairman Clinger Deposition Exhibit No. 8.

    [Mills Deposition Exhibit No. CM–8 was marked for identification.]

EXAMINATION BY MS. COMSTOCK:

    Question. Here is an October 31, 1996, memo for all staff of the White House from Jack Quinn regarding documents of the LIPPO Group, Indonesia and other matters. Do you recall seeing this document?

    Answer. I am sure I did see this document, though I was not involved in this particular request.

    Question. Do you know if this is a request that Ms. Sherburne or Ms. Wallman or somebody else had put together?

    Answer. I do not recall who was tasked with this particular request.

    Question. Now this request attaches a request to it. Do you know where the attachment came from?

    Answer. I do not.

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    Question. And the contact person on this request—actually, why don't I—for the record, this is I guess what will be called a directive to all staff to turn over documents?

    Answer. Correct.

    Question. Regarding certain topics; would that be correct?

    Answer. Correct.

    Question. And it indicates the White House has received a congressional request for production of documents relating to the LIPPO Group, Indonesia and other matters, and it says, ''The precise document requested is attached.''

    Is it your understanding the precise request that came from Congress was attached to this directive?

    Answer. I can only do the same thing you are doing and that is read this particular document. I don't recall being involved with this particular request.

    Question. Okay. And the contact person here was Kathy Wallman or Alan Kreczko. Alan Kreczko is at NSC?

    Answer. Correct.

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    Question. Do you know why they were the contact people on this?

    Answer. I do not.

    Question. Do you recall having conversations with Ms. Wallman about LIPPO documents that were gathered?

    Answer. I am sure there would have been an occasion where we would have had a conversation. I don't recall in particular conversations regarding it, but I am sure we would have discussed it.

    Question. Did Ms. Wallman, in fact, give you documents that had been gathered about the LIPPO Group, Indonesia and the matters we related in the attached two pages?

    Answer. I recall that production being a separate production but I could be wrong and just not having an accurate memory in that regard.

    Question. How do you mean that it was separate production?

    Answer. I don't recall it being part of the request that I ended up—a document I ended up addressing which was we got a request in December from the Justice Department where we circulated a directive, that is, the documents that I recall addressing with respect to collecting materials.

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    Question. Okay. At any time did Ms. Wallman give you the documents that she had gathered?

    Answer. If she had already produced them, she probably wouldn't have. I just don't recall.

    Question. Okay. Because this request, which is about the LIPPO Group and Indonesia, I imagine, overlap some, the request that came from the Justice Department in December?

    Answer. I am certain it would.

    Question. Why don't I just get that for you so you have it in front of you. This is the December 16, 1996, directive to Executive Office of the President staff from Jack Quinn, regarding a document request, and it indicates, we received document requests from certain congressional committees and the Department of Justice, and then asks for a search of records relating to a number of individuals. And then on the second page is a number of entities.

    Question. Do you recall in preparing this directive going back to Ms. Wallman about what she had collected at that point?

    Answer. I don't recall that, but I am certain that if there were materials that had not been produced, those materials would have been captured in this.

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    Question. And this October 31, 1996, directive——

    Answer. Let me just address, as it says on the second page, we recognize that this request, in some respects, is duplicative of a prior document request. To ensure complete response, however, please provide all responsive documents, even those you may have previously provided.

    Question. Was it your understanding, then, that whatever documents had been given to Ms. Wallman or Mr. Kreczko would again come back to you?

    Answer. I don't know that I had an impression, with regard to them transferring materials, every staff member would have to go back through all their materials to make production that was responsive to this request.

    Question. And on that second page of the December 16, 1996, directive, which we will go ahead and make Deposition Exhibit No. 9, you are the contact person on these documents along with Wendy White; is that correct?

    Answer. Yes.

    Question. And what was Ms. White then working on at this time?

    Mr. EGGLESTON. I don't mean to be a housekeeper, but if you didn't make this an exhibit, it maybe should be.

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    Ms. COMSTOCK. I'm sorry. We will make October 31, 1996, Deposition Exhibit 9, and December 16, 1996, Deposition Exhibit 10, and I always appreciate housekeepers.

    [Mills Deposition Exhibit No. CM–9 was marked for identification.]

    [Mills Deposition Exhibit No. CM–10 was marked for identification.]

EXAMINATION BY MS. COMSTOCK:

    Question. And I just wanted you to be able to have both of them in front of you so we all aren't referring to documents that you don't have a chance to refer to, in fairness to you.

    But why don't we return to the October 31, 1996, memo. It does ask the documents be turned over to William Leary in the NSC. Do you know who that is?

    Answer. Bill Leary is their, for lack of a better word, documents person. He is like Terry Good is for records management. He also manages their records for the NSC.

    Question. And it asks that the documents be turned over by November 12, 1996. Do you know if that generally occurred, if documents were produced by that date?

    Answer. I do not know. I was not involved in this request.

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    Question. Okay. Generally, when you have a directive and have a date on it, do you generally get most of the documents by that date, some, all?

    Answer. I would say we get most of them, but we always get documents after that date. If staff have been traveling where they weren't in the office on a day the record went out, and as they come out, they obviously provide their records as quickly as they can.

    Question. Historically has there been particular offices that you have learned, you know, you have to go and kind of bother them or remind them or tell them that it doesn't appear they have looked through the documents?

    Answer. No.

    Question. Is it your experience, then, that people have responded in a timely fashion then to your directives?

    Answer. Usually people try and respond in a timely fashion. Obviously there are things that people schedule, travel and things like that, but people try and respond in a timely fashion.

    Question. So would it be fair to say by November 12, 1996, a body of documents regarding the LIPPO Group and the matters identified on the attached sheets would have been collected within the White House?

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    Answer. I don't——

    Mr. BALLEN. I object. The witness testified she wasn't involved in the directive and you are asking basically speculative questions at this point.

    The WITNESS. I don't know, which I already started to say, I don't know kind of what the production was like on this particular request.

EXAMINATION BY MS. COMSTOCK:

    Question. Okay. Well, then, referring to the December 16 directive, as you noted earlier on the second page, you had said we recognize this request is somewhat duplicative of a prior document request. Do you know if you were referring to any other request, aside from the October 31, 1996, request?

    Answer. I don't know.

    Question. Okay.

    Answer. I just knew there had been lots of requests for information regarding all of these matters, and so to ensure we got all of the records, we required people to do another production.

    Question. And at or around the time of this December 16, 1996, directive, do you recall that you already had gathered a fair amount of documents pertaining to these matters?

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    Answer. No, this was the first request I sent out.

    Question. So the documents that had come in to Bill Leary, you had not seen then, prior to doing the December 16 directive?

    Answer. I don't recall if I had gone through these materials or not. I don't recall.

    Question. Now, generally, Mr. Leary wouldn't be sending out documents in response to a congressional request; is that correct?

    Answer. No, Mr. Leary actually deals with—as you probably can imagine, in the NSC there are lots of materials that are classified, so I am sure part of the rationale for the production, for Mr. Leary, was with respect to ensuring they would be able to be maintained in a fashion consistent with their classification.

    Question. Mr. Leary wouldn't be the person who would bundle them up and send them up to the Hill or to HPSCI?

    Answer. No, I imagine Kathy Wallman and Alan Kreczko would have been playing that role.

    Question. And would they have gone through you at this time, before anything was transferred?

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    Answer. I don't know that they would have gone through me, primarily, just because of their seniority at that time, but I am sure we would have tried to ensure that we had all the appropriate documents and to the extent that this request was sent out, one of the ways we tried to ensure that was to ask for all records to be reproduced.

    Question. And the deadline on this directive of December 16, 1996, Deposition Exhibit 10, was December 23, 1996, and do you recall if you did get a lot of those documents by that date?

    Answer. We got a fair number but because it was the holiday season there were a number of people out so we continued to receive documents throughout the end of the month.

    Question. Okay.

    Answer. Into the beginning of the next year, too.

    Question. So by early to mid January, had you received a lot of the documents, then, pertaining to, for example, John Huang, Mr. Riady?

    Answer. I think we would have received a fair amount of the documents by that point, yes.

    Question. And do you recall any discussions you had about transmitting them to the congressional committees and the Department of Justice?

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    Answer. I recall that obviously we needed to go through, Bate stamp them, review them for responsiveness, and we needed to provide them as we were able to do so.

    Question. Do you recall when you provided the documents to the Justice Department?

    Answer. I believe sometime in January.

    Question. All right. And do you know why the documents at that time were not provided to congressional committees?

    Answer. It is my impression that the documents ultimately were being reviewed to be provided and I just don't recall what the different issues were with committees. If I recall correctly, most of the committees were at that point setting up what were going to be their processes, and there was some discussion regarding whether or not this matter was going to be handled by Mr. Gilman, is it Representative Gilman, is that correct, or this committee.

    Similarly, on the Senate side, I recall there being lots of discussions in that regard, and then I subsequently transitioned out so I didn't participate in the follow-up discussions to determine how you all ultimately ended up resolving that, though obviously the committee ended up with jurisdiction here and on the Senate side they ended up as they did.

    Question. When you gathered these documents pertaining to John Huang or James Riady, and Ms. Kanchanalak is listed on here, Charlie Trie, Johnny Chung, others, do you recall if you had gathered the memos which I think we sort of obliquely referred to earlier, regarding James Riady's visits to the White House, the Sherburne memos, that discussed I guess her disagreements with Mr. Lindsey about various accounts of the Riady meetings?

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    Answer. I don't know what date Ms. Sherburne created her document, but we would have gathered them in the process of all the other requests that we would have been dealing with.

    Ms. COMSTOCK. I will make this Deposition Exhibit No. 11. This was a November 26, 1996, memo to Leon Panetta and Erskine Bowles and Jane Sherburne regarding White House statements regarding the Riady meetings.

    [Mills Deposition Exhibit No. CM–11 was marked for identification.]

EXAMINATION BY MS. COMSTOCK:

    Question. This is an exhibit from a different deposition and I just marked it correctly. So then since this memo was on November 26th, 1996, is it your understanding that it would have been collected pursuant to the December 16th directive?

    Answer. Yes, it should have been collected at that time period, right.

    Question. Do you know if it was provided to the Justice Department in January?

    Answer. I do not know. I don't know that all of our production was complete to the Department of Justice in January. If my memory serves correctly, towards the end of January, we made our initial production but we had subsequent productions that continued throughout March. That's my best recollection.

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    Question. Do you know any reason why this particular document would have been withheld and not provided in January? I am not saying it is. I am just saying, if you know.

    Answer. I don't know that it wasn't. I don't know when it was provided, actually.

    Question. Do you recall any discussions about—there are a number of other documents that are related to this or other copies of this memo, but I will just refer to this one for now somewhat generically if we can on the topic.

    Do you recall any discussions about withholding these—this memo or others related to it for executive privilege purposes?

    Answer. I am sure that because this is a memo from Jane Sherburne we would have had to review this in the context of other documents that might be subject to privilege. So I am sure this one would have had to have been reviewed in that context. I don't recall particularly this particular document but I am sure we would have reviewed it in that context.

    Question. Okay. Did you have any conversations within the counsel's office about claiming executive privilege vis-a-vis Justice Department requests?

    Answer. I am sure we would have gone through, as we do for any document production, to review documents and determined whether or not there is privileges associated with them and then how to address those particular privileges that might be associated with the documents.

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    Question. But in a situation where the Justice Department was asking the White House for documents, or the particular issues that were raised about how to go about claiming executive privilege when the Justice Department is asking you for?

    Answer. I don't know that—since the Justice Department is another branch of the government, I don't know that you have that same issue as opposed to when you are dealing with Congress, quite candidly.

    Question. That's what I am trying to get at. Usually, the counsel's office would go to OLC for advice and counseling on claiming executive privilege. Isn't that correct?

    Answer. It depends. There have been numerous investigations that have been ongoing that we have not been able to engage in that process either because of their particular investigation that they were doing or other reasons, and particularly, for example, in the Whitewater case there were some instances where—in the Whitewater matter there were some instances where we did not consult because of ongoing matters that they might have had.

    Question. Because of potential conflict?

    Answer. I don't know if it is always potential conflict, quite candidly.

    Question. Okay. Were you aware of—did you ever have any discussions with Mr. Ruff about Ms. Reno recusing herself from executive privilege issues as far as the fund-raising investigation is concerned?

 Page 438       PREV PAGE       TOP OF DOC    Segment 6 Of 22

    Answer. I am sure we would have had conversations to conclude that since the Department was going to be reviewing these matters that we would not review with OLC materials that would be going to them. I am sure we would have probably had those kinds of discussions.

    Question. Okay. Do you recall in particular conversations you had?

    Answer. I mean, I just recall that issue coming up. I don't recall particular conversations, but I recall that issue coming up and addressing that issue. Otherwise, as a matter of practice we probably would always be addressing these with OLC so I am sure we did have discussions in that regard.

    Mr. BALLEN. Does that mean that you made a categorical decision not to address it with OLC as to all documents or just you had some discussions about appropriateness?

    The WITNESS. We had discussions regarding what would be appropriate, I am sure, documents for them, given their particular, I guess, investigation.

EXAMINATION BY MS. COMSTOCK:

    Question. Was there ever any decision made that the White House would not claim executive privilege over documents—I mean, that the Justice Department requested?

 Page 439       PREV PAGE       TOP OF DOC    Segment 6 Of 22

    Answer. I don't know that the executive privilege issue arises in that context because it is an executive branch agency. So I don't know that we have the same issue in that context. So I think discussions would have been in that vein as opposed to asserting executive privilege with respect to the Department. They are an executive branch agency.

    Question. Are you aware of instances previously where the White House did withhold documents from the Justice Department based on attorney/client or executive privilege issues?

    Answer. I am not.

    Question. This is a matter Mr. Eggleston and I have discussed previously in another life.

    But did you then not work on any issues related to Whitewater and the withholding of documents in that case on executive privilege—on attorney/client privilege or anything like that?

    Answer. That's correct, I did not work on the Whitewater matter. Otherwise I think we would have worked together.

    Question. As far as—I didn't work on that one.

    Answer. Okay.

 Page 440       PREV PAGE       TOP OF DOC    Segment 6 Of 22

    Question. You aren't familiar then generally with the White House having then withheld documents from the Justice Department in the past, pursuant to any type of privilege?

    Answer. They may have. You may be able to walk me through a scenario where it would refresh my recollection, but I don't particularly have a recollection as I am sitting here, and I did not work on the Whitewater-related matters to the extent it arose in that context.

    Question. In the whole fund-raising case, you do not recall any particular documents where the issue came up and you had any discussions about withholding particular documents and how that might be done?

    Answer. Correct.

    Question. All right. So is it your—and I am gathering from your response that usually it would be unusual for the White House to claim executive privilege over another executive branch. Since you are within the executive branch claiming executive privilege, it is not something that normally one does?

    Answer. I don't know if it would be unusual. In this matter, I recall that they—we are an executive branch agency so to the extent that the context of our discussions arose, or our discussions arose in that context, I don't know what might be the context in which it would arise in other investigations.

 Page 441       PREV PAGE       TOP OF DOC    Segment 6 Of 22

    Question. In the December—I am sorry. Why don't we keep the December 16th directive out and then I think we may still need the WAVES records, too.

    When you compiled this list on December 16th, what was the source of the various names and requests? I mean, it says that there is congressional committees and Department of Justice had requested these things. Were there names on here, some of which you all didn't know who they were or what they were about?

    Answer. My best recollection is that the Department of Justice had been fairly specific in their interest and they were the first ones who were as specific about all the different entities they were interested in, so that's my best recollection of where we would have drawn most of the information from.

    Question. Do you know if there was any effort to find out—for example, the last name on the list Yue F. Chu; did you all look at that and say who is that?

    Answer. I still don't know who Yue F. Chu is.

    Question. Or Keshi Zahn?

    Answer. Right. I mean, all of these were individuals or entities that had been, at least to that point, identified as of interest to, I know, certainly the Department of Justice and many of them overlapped with other requests that we had. And so we attempted to try and do a comprehensive document search at that point.

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    Question. Okay. Was there any attempt to find out internally who these people were? Or was the directive just sent out?

    Answer. We sent the directive out and to the extent that we learned who people were if it was helpful in trying to help people we would, but we basically sent the directive out.

    Question. Okay. I guess we said earlier Wendy White assisted you then with this.

    Answer. Yes, I believe that would be correct.

    Question. And what were Wendy White's duties in this regard?

    Answer. I think Wendy was at that time also assisting with the collection of the materials, and reviewing of the materials.

    Question. And did you task her or anybody else with finding out who any of these people were?

    Answer. I am sure we tried to find out who these people were but I don't recall in particular tasking anybody to try and address them. I think often as documents came in it became clear who the different people were.

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    Question. Okay. For example, were you familiar with Yogesh Ghandi?

    Answer. Yes.

    Question. Okay. Now you had in fact worked on some matters related to Mr. Ghandi?

    Answer. Yes.

    Question. All right. And did you then gather up the files that you had or material that you had on Mr. Ghandi?

    Answer. The material I would have had on Mr. Ghandi would have been a memo that Cathy Whalen had so that would have been something I would have sent back just because at that point I wasn't handling that matter; Ms. Whalen was handling it.

    Question. With respect to what?

    Answer. With respect to the Yogesh Ghandi award, Ms. Whalen was handling that matter.

    Question. In collecting these documents, did you put the Ghandi documents into the pile that was being collected pursuant to the December 16th directive?

 Page 444       PREV PAGE       TOP OF DOC    Segment 6 Of 22

    Answer. Yes, to the extent that I had Ghandi documents.

    Question. Okay. So it is your recollection that you had sent them off to—sent a lot of the documents to Ms. Whalen?

    Answer. I don't recall actually being consulted other than one question that was raised with me with regard to Mr. Ghandi, and that was basically someone forwarding me a request to look at the issue. Since Cathy was already working on it, I just sent it down to her.

    Question. Do you recall in January, when documents were turned over to the Justice Department, if the Ghandi documents were included in that?

    Answer. I just don't recall.

    Question. Okay.

    Answer. I should be clear that we did not complete production to the Justice Department in January. We basically began production in January, towards the end, I believe. So this would have been a process of going through all the materials and it would have taken a couple of months probably before we completed production.

    Question. Okay. And who worked on that, that initial—that January production with you?

    Answer. Karen Popp in our office and then it was transitioned obviously to well, Mr. Breuer's staff and team when they came on board.

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    Question. And when did Ms. Popp come on board?

    Answer. December 23rd, I believe, or the 24th; some awful time right before Christmas.

    Question. And she worked with you exclusively?

    Answer. At that point, she did.

    Question. Okay. Can you tell us when she came on board, what you did to sort of get her up to speed on these matters?

    Answer. I believe at that point we already sent out the directive when she came on board and so I basically asked her to look through the materials. I tried to explain to her where the different places were where we looked for materials, how we gather materials, basically all the things you would need to know to be able to hopefully be helpful and effective in a process like this.

    Question. Okay. Did you indicate to her what offices would be most likely to have documents regarding any of these people?

    Answer. To the extent that there was follow-up required, but I believe that the document requests had already gone out by the time that she came on board so we would have already been receiving in the materials.

 Page 446       PREV PAGE       TOP OF DOC    Segment 6 Of 22

    To the extent that we were trying to follow up on materials or follow up on information, I would obviously describe to her where we might need to follow up based on materials or other information that we had.

    Question. Okay. And can you describe anything else you did to sort of acclimate her to this process and how she would go about gathering the documents and making sure that she would obtain all responsive documents within the White House?

    Answer. Well, these were already coming in so she didn't have an obligation to make sure they were coming in; they were already coming in. We had already sent out the directive. But typically, what I tried to do with her and with others, to the extent that I have information that might be helpful, is to walk them through what I have already learned; walk them through whatever information we already know; walk them through the different places where there might be information coming from based on what we know and also try and introduce them to different people as they are working through the process so that they know who the different people are in the different offices so they can always have a point of contact that they can talk to to ask questions about materials and other things.

    Question. Okay. And who were those key type people?

    Answer. They would be whoever the particular assistants were for the office or other people who might be their assistants. Those would be people who might likely see a lot of the paper or information that goes through the office.

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    Question. Can you tell me some of those office, like the staff secretary's office would have a lot of the people?

    Answer. Staff secretary's office probably I would indicate Terry Good because that comes under there, and Terry Good would be a person—he has another person on his staff who also is particularly responsive in trying to ensure that we go through materials, and so—Tom Taggert, I would indicate he is another person in Records Management to talk to. We would go through the different offices and identify people who were in those offices and likely to be able to provide help or guidance with respect to materials that come from their office.

    Question. Do you know the volume of documents that have been gathered by January that you had collected, you know, boxes or folders?

    Answer. I do not know the volume but it was certainly boxes.

    Question. All right. Do you know where it was being stored or kept?

    Answer. We have a room where we just stored materials, and that's where they were being stored.

    Question. Can you just describe the process, how they came in and what you did when records would come in responsive to a directive such as the December 16th?

    Answer. Typically when records came in we would try and place them in a file folder or something that would help identify the source of those particular records, and then we would just place it in a box and keep collecting the records until the time period when we perceived that we had most of the documents that were out there, which was usually somewhere shortly thereafter the date of production that we had given out our memos.

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    Question. Would you identify the offices from which the documents came as they came in?

    Answer. The name of the person or the office if there was no name associated with it.

    Question. Okay. So as the documents came in to—what was the room number that this came in?

    Answer. They came into my office and then we would put them basically into a box to try and go about identifying them as they came in to ensure that we had all the records identified when they came in.

    Question. If Mr. McLarty sent documents from his office, they would come in from his office and they would be identified Mr. McLarty's documents?

    Answer. Correct.

    Question. Is that correct? And if Terry Good sent over documents from Records Management would he usually—would he know whose offices they had come from?

    Answer. They would be identified in ours as from Records Management.

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    Question. Okay. But would Mr. Good in his records have a record of whose records those are?

    Answer. I am sure he probably does.

    Question. Okay. But so would he then be able to inform you whose records they are when he sent them over?

    Answer. I am sure he could, though typically when they came in they came in as Records Management documents. In other words, they came in as archives documents rather than archive documents of X person.

    Question. If you were to go back to Mr. Good and say, Gee, I have this document, I don't know what it is, can you tell me whose file it came from, does Mr. Good have a process by which any documents he gives to you he can then trace in his tracking system to tell you where he got it initially?

    Answer. I don't know, but I am sure he does.

    Question. Isn't that part of what Records Management is, to know where the records came from that he is managing and filing?

    Answer. It is partially that. It is also just to ensure that we have a complete record so that sometimes there obviously will be occasions where they don't know particularly whose file a record might have come out of but they try and make sure they have all the records.

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    Question. Generally, he tries to identify—I mean, if somebody comes and drops a box on his doorstep and doesn't tell him where it is from, obviously he wouldn't know. But if he was given information when he was given the documents, doesn't the office then go ahead and identify the documents?

    Answer. That's my understanding of their practice.

    Question. Well, in gathering documents in your office, do you then go back and find out the source of those original documents aside from Records Management?

    Answer. Not beyond Records Management.

    Question. All right. When you provided documents to the Justice Department, did you recall if you did a production log to the Justice Department?

    Answer. I don't recall if we did a production log, but if we did we still would have identified it as Records Management unless we had more information.

    Question. Okay. Do you recall—you don't recall if you did a production log for the Justice Department?

    Answer. That's correct. I am sure there was one that was done but it would have been done after the time period that I was handling this matter.

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    Question. Okay.

    Answer. Production logs typically are done at the end of productions. This production was not completed by the time I transitioned out of the matter.

    Question. Okay. How much was completed in terms of the Justice Department production while you were still working on these matters?

    Answer. I believe we had only done our first production to them, and I believe there were several subsequent productions.

    Question. Okay. Do you have any general recollection of how much of a volume of documents you turned over at that time?

    Answer. I don't. I really don't.

    Question. Do you know who would know?

    Answer. No. I mean, I think that's a piece of information we could try and find out for you but I don't have a particular recollection.

    Question. Well, I am just trying to get a sense of by the time you left how much was gathered and together on these various topics.

    Answer. I don't know that I can give you a good answer on that because I wasn't involved in the subsequent aspects of the production and what review went into those in terms of trying to ensure complete production in that sense. That was something that was handled by somebody else. So I can't give you a sense of whether or not we produced 3 boxes to Justice and there ultimately were 12 boxes produced. I just don't ultimately have a sense of that.

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    Question. Okay. I think in looking at the WAVES records—I did not want to return to the WAVES records, but we have probably gone through pretty much all you recall on any of the Riady meetings; is that correct?

    Answer. Correct.

    Question. Okay. And I just wanted to now refer to Mr. Huang's visits at the White House and to the extent you have any knowledge of those events and who he was meeting with.

    Answer. I don't have any particularized knowledge beyond what I ultimately ended up reflecting on these documents.

    Question. Okay. And the bottom of page 4978, that is your handwriting on the February 11th, 1993, notation?

    Answer. Correct.

    Question. Can you make that out?

    Answer. POTUS economic briefing in East Room. I can't make out the next section. Open press. The next line I cannot make out.

    Mr. BALLEN. Cannot make out because the Xerox copy is poor.

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Ms. COMSTOCK. I understand. Ms. Mills has some of the best handwriting that we have seen on documents so that has nothing to do with her handwriting. It is a poor copy.

The WITNESS. The last paren says ''photo, too,'' T-O-O.

Next Hearing Segment(7)