Travelgate Depositions

CAROLYN HUBER



   COMMITTEE ON GOVERNMENT REFORM AND OVERSIGHT
   
   U.S. HOUSE OF REPRESENTATIVES
   
   WASHINGTON, D.C.
   
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   :
   
   In the matter of: :
   
   :
   
   WHITE HOUSE TRAVEL : DEPOSITION OF CAROLYN HUBER
   
   :
   
   :
   
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   Tuesday, April 23, 1996
   
   Washington, D.C.
   
   The deposition in the above matter was held in Room 2203, Rayburn
   House Office Building, commencing at 10:00 a.m.
   
   Appearances:
   
   Staff Present for the Government Reform and Oversight Committee:
   Barbara Bracher, Chief Investigator; Barbara Comstock, Investigative
   Counsel; Donald Goldberg, Assistant to Chief Minority Counsel; Daniel
   Hernandez, Minority Professional Staff.
   
   For CAROLYN HUBER:
   
   HENRY F. SCHUELKE, III, ESQ.
   
   Janis, Schuelke & Wechsler
   
   1728 Massachusetts Avenue, N.W.
   
   Washington, D.C. 20036
   
   Ms. Bracher. Good morning. We are on the record for the voluntary
   deposition of Carolyn Huber. She is accompanied today by her attorney,
   Mr. Henry Schuelke.
   
   Mr. Schuelke. Henry Schuelke of the law firm of Janis, Schuelke &
   Wechsler. You have my card.
   
   Ms. Bracher. Majority Counsel Barbara Bracher and Barbara Comstock are
   here, as well as Minority Counsel, Don Goldberg and Dan Hernandez.
   
   This is a voluntary deposition concerning the chain of custody for the
   May 3rd, 1994, letter from David Watkins and addressed to the First
   Lady. This letter was produced by the White House on March 15th, 1996,
   in response to the committee's January 11th, 1996, subpoenas to the
   Custodian of Records in the Executive Office of the President and the
   White House Office of Administration. Both subpoenas designated that
   on January 22, 1996, return date for all records subpoenaed.
   
   Mrs. Huber, are you here today voluntarily and not under subpoena.
   
   Ms. Huber. Yes, ma'am.
   
   Ms. Bracher. And at this time, I would ask that Ms. Butler swear you
   in.
   
   THEREUPON,
   
   CAROLYN HUBER,
   
   a witness, was called for examination by counsel, and after having
   been first duly sworn, was examined and testified as follows:
   
   EXAMINATION BY MS. BRACHER:
   
   Q During the deposition I will try to phrase my questions simply so
   you can understand. If there are any questions that I raise that you
   don't understand, please ask me and I will rephrase them.
   
   If there are any objections to any questions, I just ask that they be
   stated for the record and the reason for the objection. At that point
   we will confer with Minority Counsel. Ultimately, if there are any
   objections, the Chairman and Ranking Minority Member will resolve any
   disputes.
   
   If you will just give me a general background, your work history
   before coming to the White House?
   
   A How many years do you want?
   
   Q Just going back I guess maybe before the Rose Law Firm.
   
   A I was there since 1976. That is 20 years. I can go back 24 more
   years, if you want to go --
   
   Q No, ma'am. Let's just start with the Rose Law Firm and what you did
   there.
   
   A When I first came there as a secretary from December 1976 to 1978;
   1979 I was at the Governor's Mansion as the administrator for the
   Governor's Mansion for the then-Governor Bill Clinton and Hillary
   Rodham. When he lost the election, I then came back to the Rose Law
   Firm. I was at the Rose Law Firm until January 31st, 1993.
   
   Q And can you --
   
   A As the office administrator.
   
   Q What's your last position at the Rose Law Firm?
   
   A Office administrator.
   
   Q And if you can just briefly tell us what your areas of
   responsibility were.
   
   A My area was hiring all the secretaries, keeping up with the
   day-to-day operations. We owned our own building that was over the
   mail room, seeing it ran smoothly. I had supervisors in all these
   areas. I was not daily in these offices, but that was under my
   responsibility.
   
   Q And did you have responsibilities concerning documents and documents
   retention at the Rose firm?
   
   A No, I did not.
   
   Q When you came to the White House, what was your position again?
   
   A My position is Special Assistant to the President in charge of
   personal correspondence.
   
   Q Can you just tell us what types of duties that entails?
   
   A I open all of the mail. We have a special code for the First Family.
   I open the mail and I have two people that answer the letters, and I
   dole it out to the particular person it belongs to.
   
   Q What type of mail comes to your office rather than to the other
   offices that handle correspondence?
   
   A Personal letters from friends and family.
   
   Q Do you handle any correspondence other than personal correspondence?
   
   A No, ma'am.
   
   Q Do you handle any personal correspondence that would relate to
   business matters such as the Health Care Task Force or others?
   
   A No, ma'am.
   
   Q Perhaps you could just walk us through what you do -- how you
   receive the personal correspondence and what you do with it?
   
   A It comes in the mail to us and I open it. Is that what you are
   talking about?
   
   Q Yes, ma'am.
   
   A I open it and give it to the two people that are responsible for
   answering it. One lady does Mrs. Clinton's and one lady does the
   President's.
   
   Q Who do you report to?
   
   A The Oval Office, the Oval Office operation. There are about six of
   us in that.
   
   Q Is there a direct supervisor you have?
   
   A No, we don't have a direct supervisor, but Mrs. Nancy Hernreich is
   in the Oval operations.
   
   Q The two people you give correspondence to?
   
   A Well, directly usually we first log it in; we have a girl at the
   computer. I give Mrs. Clinton's directly to Milli Alston.
   
   Q So when a letter comes in, it is still sealed in its envelope?
   
   A Yes, and I open it.
   
   Q Can you tell me what kind of logs are kept for the correspondence?
   
   A They keep logs. Mrs. Milli Alston keeps logs.
   
   Q Do you personally hand over that kind of correspondence over to
   Milli Alston?
   
   A Yes, ma'am.
   
   Q And is the computer located in the Office of Correspondence?
   
   A Yes.
   
   Q Do you do any logging?
   
   A No, I do not.
   
   Q Is she the sole person who logs in correspondence?
   
   A That comes in my office, yes.
   
   Q And are there any printouts or regularly kept records of these logs
   of correspondence that you are aware of?
   
   A Miss Alston keeps them.
   
   Q Have you seen -- is there regular course of business where they
   might be printed out and archived that you are aware of?
   
   A She keeps a file of them, yes.
   
   Q Do you know how often she prints them out into hard copy?
   
   A No, I don't.
   
   Q And where is that file kept?
   
   A It is in our office.
   
   Q So once you received a letter and give it to Milli to log it in,
   then what happens, the hypothetical letter?
   
   A I am sure she makes a log to Mrs. Clinton to see if she wants to see
   it. Sometimes it is a letter she doesn't think she could answer and
   she might send it to some other department to answer.
   
   Q So it would be Miss Alston that would then take the log to Mrs.
   Clinton?
   
   A She sends it to her, uh-huh.
   
   Q And how is it sent? Is it by regular White House mail?
   
   A Yes, ma'am.
   
   Q And then if Mrs. Clinton -- can you tell me what happens after the
   log goes to Mrs. Clinton?
   
   A Then Milli gets it back.
   
   Q Is there a matter that there is a notation on the log? How does she
   know whether --
   
   A She has check marks on what to do with the stuff.
   
   Q Can you describe?
   
   A Well, I mean, if you got a letter from someone and Milli does not
   send a letter, she just gets out what maybe the subject is, do you
   want me to respond or no, or go to file or whatever, so Mrs. Clinton
   checks it.
   
   Q Are there standard -- I have never seen the log. I apologize.
   
   A I don't know if there is a standard or not. It kind of looks like a
   standard. Every one of them would be different, all the logs, because
   it is different people.
   
   Q But categories of information, I take it, would be the date it was
   received and who it was from?
   
   A I am sure. I really never paid that much attention to it because it
   is not my jurisdiction. I don't have time to read all that stuff.
   
   Q And then after the log comes back to Milli, what happens to the
   correspondence?
   
   A Well, Milli keeps it. I don't know. She has files of things she
   keeps.
   
   Q Would she -- I assume she would give the First Lady the
   correspondence?
   
   A If she wanted it, uh-huh.
   
   Q If there is a letter that the First Lady personally wants to see,
   when do you fit in the --
   
   A The only letters I get back from Mrs. Clinton are the real personal
   ones that are personal things she might want to save in a different
   file other than Milli's files. I don't even get them back every day.
   
   Q So the options of where a letter might go if the First Lady
   requested to see it would be to Milli Alston's file or if it was
   extremely personal it would go to you.
   
   Is there anyone elsewhere letters might go to that the First Lady
   would see that you know of?
   
   A There are about four different places letters come in to Mrs.
   Clinton. Her other secretary, Pam Cicetti, gets them. Alice Pushkar
   gets the major correspondence that comes in. There are just different
   areas.
   
   Q Pam Cicetti?
   
   A Uh-huh.
   
   Q Can you spell her name.
   
   Mr. Schuelke. C-i-c-e-t-t-i.
   
   BY MS. BRACHER:
   
   Q So her secretary, Pam Cicetti, might get letters and send them to
   her. And you mentioned some other people.
   
   A Alice Pushkar is in charge of the major correspondence that comes
   in. She gets all the letters that does not have this personal zip code
   number on it so everybody in the world doesn't know that zip code
   number.
   
   Q Is this a zip code that has been distributed by the First Lady and
   the President to their friends?
   
   A When they first got here, we told them.
   
   Q Do you have a list of those people that have that limited zip code?
   
   A It is just by who we know that is family and friends.
   
   Q Other than letters coming in to the First Lady, you said that after
   the First Lady would finish reading letters she would request they go
   to Milli Alston or you. Are there any other people she might hand the
   letters back to other than you and Milli Alston?
   
   A I am sure there are other people. I am not in their departments.
   They are in different buildings so I can't speak to them. I am sure
   they would get -- there are things they sent back over.
   
   Q The personal letters, do you know if the First Lady gives any
   letters -- do they go through Maggie Williams?
   
   A I don't know. I don't know. I just know what comes through my
   office.
   
   Q Let me get back to the letters that you received. Do you get them
   back personally through the mail from the First Lady or does she hand
   them to you?
   
   A No, they have a courier from the usher's office who brings them back
   over. They bring them back to Milli in a folder.
   
   Q The usher's office brings all the mail back to --
   
   A Just what Milli sends. We don't get anybody else's.
   
   Q Then the letters that are to go to you, do they come from Milli
   also?
   
   A No. Sometimes I will get a little folder back from Mrs. Clinton or
   sometimes Milli will give me a couple of letters, not every day, but
   sometimes. She will put in there "Put in my personal file." Milli will
   hand it to me.
   
   Q After you get a letter back, what do you do with it?
   
   A I put it in a stack.
   
   Q Can you just describe -- is there some sort of process that you go
   through?
   
   A No, I just stack letters up. I will stack them up in red ropes or
   something until I get time. It is not important that I get in stuff
   filed right away, so whenever I get time I will start trying to go
   through them.
   
   Q These are letters that come back from the First Lady?
   
   A They are not to be answered. They are just letters to be filed.
   
   Q You don't ever get material back --
   
   A I do not ever answer letters or write any letters.
   
   Q So the material you get back solely is material that doesn't need
   any further action?
   
   A No, huh-uh.
   
   Q Where is your office located?
   
   A It is in the East Wing.
   
   Q And in the Office of Personal Correspondence, how many people were
   in that office?
   
   A You mean my office?
   
   Q Yes, ma'am.
   
   A I have two, then a girl that answers our phone. That is it.
   
   Q And the two people that are in your personal office are --
   
   A Milli Alston and Maureen Lewis.
   
   Q And the person that answers the phone?
   
   A Helen Robinson.
   
   Q She answers the phone for both you and --
   
   A For all of us, uh-huh.
   
   Q I wanted to ask you a little more detail about the letters that
   would go into a stack. Do you have dates or are they with dates and
   times or people? Is it alphabetical?
   
   A After I get around to doing it, I do it by years and alphabetize
   them.
   
   Q So if a letter came back to your desk you said you would put in a
   stack. How would you know what stack to put it in?
   
   A I would pile them up until I was ready to go through them.
   
   Q Where are they?
   
   A In my office. I have a shelf and I put them in a stack.
   
   Q Do they all go on these bookshelf stacks or other places?
   
   A Uh-huh, in my office.
   
   Q The ultimate place where they wind up in the file, is that also in
   your office?
   
   A Right now it is, but we keep it -- I have a closet in the residence
   where they will ultimately go because it is personal stuff.
   
   Q Are there file cabinets in this closet?
   
   A No.
   
   Q How are they kept?
   
   A We have them in boxes.
   
   Q By year?
   
   A Uh-huh.
   
   Q And how often do you archive or take things from your files up to
   the residence?
   
   A No, I haven't done it for a long time now.
   
   Q Do you remember when the last time is that you did that changeover
   from the files to the residence?
   
   A No, it has been quite awhile ago. I can't remember.
   
   Q Do you know if you have done it at all in 1996?
   
   A No, I haven't moved any this year. Still in my office.
   
   Q How many file cabinets do you have in your office for these?
   
   A I don't have any file cabinets in my office. I have about 40 boxes.
   
   Q Can you explain -- they are in the stack -- I guess I need you to
   walk me through where they go. I thought they would go into a file
   cabinet?
   
   A No, we put them in archival boxes, gray boxes about like that, and
   they will hold a lot of letters. I have them arranged according to
   years. I don't have that many letters.
   
   Q How many on the average would you get in a week?
   
   A I don't even get them every week.
   
   Q So do you get them -- can you tell me how many you get in an average
   month?
   
   A I may not even get any in a month.
   
   Q So it is that few?
   
   A I get very few letters.
   
   Q When you describe that you do put them in a stack to wait to go into
   these archival boxes, how many stacks are there in your office now?
   
   A Right now I have it all done. I don't have any.
   
   Q Let me ask you about -- since this letter was from May of 1994 --
   
   Mr. Schuelke. Which letter?
   
   Ms. Bracher. Well, I can -- the letter on the chain of custody, which
   I will show you the letter. It is dated May 3rd, 1994, and it is Bates
   stamp number CGE 039294. I am showing the witness. I will make it
   Deposition Exhibit No. 1 and ask you if you recognize that letter.
   
   (Deposition Exhibit No. 1 was marked for identification.)
   
   The Witness. Yes ma'am.
   
   BY MS. BRACHER:
   
   Q That letter is dated in May of 1994, so if you can think back in
   1994, back in May, do you recall how the filing was going then, what
   kind of stacks you had going on the bookshelves at that time?
   
   A No, ma'am.
   
   Q Were these same people working in your office back in May of 1994?
   
   A Maureen was not there but Milli has been there the whole time.
   
   Q Was there anyone other than Maureen back in that period?
   
   A Yes, Trey Schroeder.
   
   Q Trey Schroeder.
   
   A He did the President's memo.
   
   Q Does Maureen Lewis handle the President's personal?
   
   A She doesn't do the President --
   
   Q Similarly --
   
   A -- Milli does.
   
   Q When you said "stacks," I guess I don't have an accurate picture in
   my mind of if you get documents that seldom. Can you tell me how many
   letters approximately would be in a stack in the 1994 period?
   
   A In the '94 period, probably I can't estimate but I know there are, I
   don't know, maybe 50, maybe not even 50. That would be high. That
   would be very high.
   
   Q Had you kept the letters until that point since the beginning -- I
   guess, since '92 was -- what was the normal course that you would go
   through to file these documents since you came in? How often did you
   get around to it?
   
   A We just really kept them in these files because I hadn't gotten
   around to what I was going to do, how I was going to organize this
   stuff until about a year ago when I started with the archival people,
   checking with them on how we can archive this stuff.
   
   Q About a year ago would take us back --
   
   A Maybe a year and a half, something like that. It has not been that
   long.
   
   Q Do you know about when you started working with the archive people?
   
   A It has probably been a year and a half.
   
   Q So that would be -- we would go back to the first of 1994 in
   January?
   
   A I can't really remember what date it was in 1994, but basically I
   had not done Mrs. Clinton's because I had been working on the
   President's.
   
   Q Can you explain why you were working on the President's rather than
   Mrs. Clinton's?
   
   A Because I am in charge of his personal things too. So I was trying
   to get his out of the way before I started on her's, trying to get one
   project done at a time.
   
   Q Can you explain what part of the President's correspondence you are
   in charge of?
   
   A Just like he has personal things he wants to keep like Mrs. Clinton
   does.
   
   Q So when Milli Alston or Trey Schroeder, now Maureen Lewis, is
   finished, they all give the documents to you?
   
   A No, I never see their documents. I don't know what they do with
   theirs. The only documents I get are the ones that the President and
   Mrs. Clinton want to save, and I don't know whether -- now the
   President sometimes answers his and he'll have an attachment to it,
   but Mrs. Clinton's don't have any answers to them. I don't know if she
   has answered them or not. I don't know.
   
   Q You are talking about working with some archiving people. Do you
   remember --
   
   A I don't work with any archiving people. I just get supplies from
   them.
   
   Q When you were trying to --
   
   A Ask what kind of boxes to get so --
   
   Q Other than asking them what kind of boxes, did you discuss perhaps a
   method of archiving?
   
   A No.
   
   Q How did you come to the method that you now use?
   
   A It is just common sense of knowing that we had to keep these records
   some way, so I determined the best way to do it is to alphabetize
   them, to put them in these boxes.
   
   Q They are alphabetized by year?
   
   A Mrs. Clinton's are. I am doing the President's. A lot of his are
   business years and a lot of them are alphabetized since he has been in
   the White House.
   
   Q Is there anyone you have worked with outside of your office
   concerning archiving their materials or White House documents or
   records?
   
   A No.
   
   Q And these boxes that you put them in, how often, I know I have gone
   into it, how often do they go up to the White House residence once you
   fill a box?
   
   A No, I won't take them up there until I am completely through with
   what I am doing, maybe end of '96.
   
   Q Can you describe what makes you at a point where you feel like you
   are through with what you are doing?
   
   A Some of the ones I have in years I can take them on up, but the
   things I am into in '96 I won't take them until the end of the year.
   
   Q Do you recall if at the end of 1994 you took documents upstairs?
   
   A I did not take them up there, no, because I did not have the room
   then.
   
   Q When did you get the room upstairs?
   
   A I had just finished, probably the early part of last year '95, where
   I have all these shelves that I put them on now up there.
   
   Q And before the early part of '95, where were all the boxes?
   
   A They were -- I didn't have that many boxes. They were just little
   boxes like that, and I had this stuff in them to go through.
   
   Q How many boxes did you have accumulated before you took them
   upstairs?
   
   A I don't remember.
   
   Q Would it have been more than 10?
   
   A Oh, no, I don't have that much stuff to go through.
   
   Q Okay. So when you got the room at the early part of 1995 in the
   residence, did you have 1992, 1993, and 1994 to go upstairs?
   
   A No, I didn't. Didn't have them ready then.
   
   Q What do you mean, you "didn't have them ready"?
   
   A I didn't have them all organized then.
   
   Q So they were still in stacks?
   
   A In stacks in my office, yes, ma'am.
   
   Q So they actually didn't even go into the boxes?
   
   A No, I hadn't gotten around to it.
   
   Q So when did you get around to actually putting them in the boxes?
   
   A I have just done it this year when I found this, like in March,
   February, March, is when I started on it.
   
   Q Let me move to the memorandum, the deposition Exhibit No. 1. Can you
   just describe the circumstances where you discovered that document?
   
   A I just had this stack of papers and I was going through them to put
   them out in the years and I saw that. I thought Mrs. Clinton might
   need it back so I sent it back to her.
   
   Q What type of stack were you going through when you saw this?
   
   A Just a little stack of paper, just like that, out the file.
   
   Q If the record can reflect, it was about two and a half?
   
   A Yes, ma'am.
   
   Q Two to three inches. Was this a stack that was solely for 1994?
   
   A I could not tell you I had '92, '93, '94, '95 in it. I do not know.
   
   Q What caused you to start going through this?
   
   A I was getting ready to organize. I had gotten to the point where I
   could start in on getting them organized.
   
   Q So you were going through all the years, not necessarily '94?
   
   A Yes, ma'am. No, I was going through every piece of paper getting it
   organized.
   
   Q Do you recall when you first found this document?
   
   A There it was -- I don't remember the date that I had written down.
   That was the first of March -- third of March, whatever. Around that
   time.
   
   Q And you said you had written it down --
   
   Mr. Schuelke. Do you have a copy of the note that --
   
   Ms. Bracher. That is one of the questions I was going to ask, if you
   have a copy. We never did have a note --
   
   The Witness. I wrote it down on a note to Mrs. Clinton.
   
   Ms. Bracher. We would like a copy of that note. We will obviously call
   the White House to send it on.
   
   BY MS. BRACHER:
   
   Q There was a mention of a note, when you found it you dated the note?
   
   A Yes. I just sent the letter with a note to her. I didn't know if it
   had any significance with what she was doing but maybe so.
   
   Q And the note will give you the definitive date when you actually
   found the document?
   
   A Yes. I found it a couple of days before that.
   
   Q Maybe we can go back, then. Do you have a copy of the note that you
   can share with us for purposes of this deposition?
   
   Mr. Schuelke. I don't think it would be appropriate for me to do that.
   
   Ms. Bracher. I am going to --
   
   Mr. Schuelke. It is a White House document. It seems to me you ought
   to get it from the White House.
   
   Ms. Bracher. I will make a request for that document.
   
   For the record, we have requested all documents and the chain of
   custody, but did not receive the note. There was a mention -- note in
   the chain of custody letter.
   
   BY MS. BRACHER:
   
   Q You said the note you wrote a couple of days after finding it. Can
   you maybe walk me through what you did when you found the letter?
   
   A I just read it and thought maybe this has something -- maybe Mrs.
   Clinton needs to see this. They were out of town. It was Chelsea's
   birthday weekend, so I sent it over Friday evening through the
   interoffice mail, through the usher's office, and they took it up to
   where they take the mail.
   
   Q Do you know if you found it on a weekend?
   
   A No, I found it in the middle of the week but I knew Mrs. Clinton
   would not be back until Sunday so I sent it over on Friday night.
   
   Q So you found the letter in the middle of the week. Did you do
   anything or contact anyone the day you found it?
   
   A No, I did not.
   
   Q Did you tell anyone in your office?
   
   A No.
   
   Q When you sent it over by usher to Mrs. Clinton on Friday, had you
   contacted anyone?
   
   A No.
   
   Q And on Friday is that when you wrote the note and dated it?
   
   A Yes, ma'am.
   
   Q And it was dated on that Friday, you believe?
   
   A Yes, ma'am.
   
   Q And did you send the original copy?
   
   A Yes, ma'am, of the letter.
   
   One thing we have to do is she has got to type a response and answer.
   
   Q If you wait --
   
   The Reporter. Please speak one at a time.
   
   The Witness. I apologize. I'll talk slowly.
   
   BY MS. BRACHER:
   
   Q If you wait until I am completely finished then we won't have us
   talking on top of each other.
   
   Did you contact anyone after you had written the note and sent it over
   to the First Lady?
   
   A No.
   
   Q When was the first time that you heard back about this letter after
   sending it to the First Lady on that Friday?
   
   Mr. Schuelke. Let's take a couple of minutes.
   
   Ms. Bracher. Certainly.
   
   [Discussion off the record.]
   
   Mr. Schuelke. Some of Mrs. Huber's prior testimony regarding the date
   on which she forwarded this document to the First Lady.
   
   Ms. Bracher. Okay, I think --
   
   Mr. Schuelke. I will tell you that her note is dated March 4, 1996,
   which is a Monday, not a Friday.
   
   Ms. Bracher. Okay.
   
   BY MS. BRACHER:
   
   Q So the note was written on Monday, March 4th; is that correct?
   
   A Yes, ma'am.
   
   Q Can you, then, take me back when you first found the letter, if you
   go back from the date you wrote the note?
   
   A It was still like in the middle of the week, like Wednesday.
   
   Q So if you found it approximately on Wednesday the week before, did
   you contact anyone that Friday or that weekend regarding finding this
   letter?
   
   A No, ma'am.
   
   Q You said that when you saw it you thought it might be something the
   First Lady should see. Can you tell me why that would have stopped
   you?
   
   A Well, it was from David Watkins.
   
   Q Can you explain why it being from David Watkins brought it to your
   special attention?
   
   A Well, from what I read in newspapers.
   
   Q Is that the only source of why it would have stuck in your mind to
   be something the First Lady should see or be noticed about?
   
   A Yes, because that is the only way I know anything about Travelgate
   is in the newspaper.
   
   Q This being found the 1st of March, do you know when that letter --
   
   Mr. Schuelke. It was on the 4th of March.
   
   Ms. Bracher. The letter was written on the 4th. It was found the week
   before, so it brought it back to if Monday was the 4th --
   
   Mr. Schuelke. You are right.
   
   Ms. Comstock. Or the 28th or 29th.
   
   Ms. Bracher. Of April.
   
   Ms. Comstock. February.
   
   Ms. Bracher. Sorry. I obviously need a calendar.
   
   BY MS. BRACHER:
   
   Q Do you know when that would have been delivered to you, that letter?
   
   A No, ma'am.
   
   Q We had discussed earlier a log that was kept for the letters that
   come in to the First Lady and the President by Milli Alston. Do you
   know if that letter was logged in?
   
   A I do not know whether it was, but we did not open it. I had not ever
   seen the letter. It did not come to our office or through me.
   
   Q Do you know if it did go through Milli before it went to the First
   Lady?
   
   A No, I don't.
   
   Q Have you had conversations with Milli about whether she received
   that letter before the First Lady?
   
   A No.
   
   Mr. Schuelke. May I inquire for a moment for clarification purposes?
   
   Ms. Bracher. Certainly.
   
   EXAMINATION BY MR. SCHUELKE:
   
   Q You testified earlier, Mrs. Huber, that the personal correspondence
   section had a special zip code set up for personal correspondence for
   the First Family. I take it that means that it was designed to
   accommodate mail that was coming through the Postal Service so a
   certain zip code; is that right?
   
   A Yes.
   
   Q So if there had been some internal intra-White House communication
   from one member of the staff of the White House to another, you
   wouldn't expect it to come through the U.S. Postal Service to that zip
   code, would you?
   
   A No.
   
   BY MS. BRACHER:
   
   Q Do you recall receiving this May 3rd, 1994, letter back from the
   First Lady?
   
   A No, I don't.
   
   Q Do you remember ever seeing a letter before you uncovered it in the
   stack?
   
   A No, I did not. Did not.
   
   Q Do you believe that it was returned to you and that you placed it in
   that stack of letters that you then noticed at the end of February?
   
   A Yes, I am sure it came back in the stack.
   
   Q And why are you sure that it came back to you and you placed it in
   that stack when you found it?
   
   A Because it was a personal letter that Hillary obviously wanted to
   save and that is the type of letters I get.
   
   Q Do you know what happens to letters that the First Lady doesn't want
   to save?
   
   A I told you Milli has them.
   
   Q But I mean, if she decides that she doesn't want to save it nor
   respond, what would happen to a letter that the First Lady would have
   and read it and just decide no action need be taken and she doesn't
   want to save?
   
   A Milli has them.
   
   Q So absolutely everything that goes through the First Lady's office
   for personal correspondence, the personal type as you have described,
   would go to Milli, even if the First Lady didn't want to save it?
   
   A Yes, ma'am.
   
   Q And what would Milli do to it if the First Lady didn't want to save
   it?
   
   A She has it filed. She has lots of file cabinets full of letters.
   
   Q Are any letters ever thrown away or just not filed that would come
   back from the First Lady?
   
   A That Milli and I throw away?
   
   Q Do any letters come back from the First Lady into your office that
   are not filed?
   
   A I don't destroy any. I couldn't speak for Milli, but I know I don't
   destroy any letters.
   
   Q Letters that maybe no one wants to keep, they wouldn't go into a
   burn bag or a bag of letters that are sort of in a dead pile?
   
   A No, I do not destroy any letters.
   
   Q So based on your knowledge everything would be filed in one place or
   the other, whether you had you it or Milli had it?
   
   A Yes, ma'am.
   
   Q When you -- although you have said that you believe that you did
   receive the letter back, once you found this letter, did you discuss
   whether Milli had, in fact, sent it back to you or whether you had
   gotten it straight from the usher's office.
   
   Mr. Schuelke. Discuss with whom?
   
   BY MS. BRACHER:
   
   Q Did you discuss with Milli whether had you gotten it through her?
   
   A I didn't discuss anything with Milli. I never even told her about
   the letter. I didn't tell anybody about it and I just sent it back to
   Mrs. Clinton.
   
   Q And why not?
   
   A Why would I talk to Milli about it?
   
   Q Have you made an attempt, other than conversations, obviously, with
   your attorney, to try to determine whether it went through the routing
   procedure that went from the First Lady to the usher or from the First
   Lady to the usher to Milli to you? Have you tried to determine what
   route that letter took?
   
   A No.
   
   Q When you sent it on to the First Lady on March 4th, when was the
   next time you received it back?
   
   A I never got it back. I don't know where the letter is.
   
   Q After you sent the letter on with the note to the First Lady on
   March 4th, did you have any conversations with anyone in the White
   House about the letter?
   
   A Not until after Mrs. Sherburne called my attorney.
   
   Q Have you talked with Mrs. Sherburne about this letter?
   
   Mr. Schuelke. You may answer yes or no.
   
   The Witness. Yes.
   
   BY MS. BRACHER:
   
   Q And what have you -- what's the substance of the conversations you
   have had with Ms. Sherburne about these letters?
   
   Mr. Schuelke. That is a privileged conversation as between the
   employee of the White House and counsel. White House does not waive
   the privilege so Mrs. Huber is not in a position to disclose that.
   
   Ms. Bracher. Have you spoken to the White House regarding this matter?
   
   Mr. Schuelke. Yes.
   
   Ms. Bracher. Can you tell me who at the White House instructed you
   that the White House was claiming a privilege over their conversations
   with Mrs. Huber regarding this letter?
   
   Mr. Schuelke. The representative of counsel to the President.
   
   Ms. Bracher. Who -- was that Jane Sherburne?
   
   Mr. Schuelke. No.
   
   Ms. Bracher. Can you tell who it was?
   
   Mr. Schuelke. Sally Paxon.
   
   Ms. Bracher. Okay. Can you tell me what the basis of privilege --
   
   Mr. Schuelke. I have no idea. It is attorney-client privilege, yes,
   but whether or not you want to raise with them whether they want to
   persist in maintaining the privilege is something you ought to discuss
   with them.
   
   Ms. Bracher. You have received instructions that they wish to claim
   privilege over --
   
   Mr. Schuelke. They have not waived the privilege and Mrs. Huber is,
   therefore, not authorized to disclose privileged communications.
   
   Ms. Bracher. Okay.
   
   BY MS. BRACHER:
   
   Q I wanted to show you a document that I will mark as Deposition
   Exhibit No. 2. I am showing the witness. It is a Subpena Duces Tecum,
   which is addressed to the Custodian of Records, Executive Office of
   the President, and it is dated January 11th, 1996, and I ask if you
   have ever seen that document before.
   
   (Deposition Exhibit No. 2 was marked for identification.)
   
   Mr. Schuelke. The question is, have you seen this.
   
   The Witness. I don't remember seeing it.
   
   Ms. Bracher. Similarly, I will show you what I have now marked as
   Deposition Exhibit Number 3, and it is a Subpena Duces Tecum, which is
   addressed Custodian of Records of the White House Office of
   Administration. It is dated January 11, 1996, and the same question I
   asked you before, if you have ever seen Deposition Exhibit No. 3.
   
   (Deposition Exhibit No. 3 was marked for identification.)
   
   Ms. Bracher. I can tell you both subpoenas are identical, except for
   the fact that one is to the Office of Administration and the other is
   to the Executive Office of the President.
   
   Mr. Schuelke. Same question, do you recall --
   
   The Witness. I do not recall seeing that.
   
   BY MS. BRACHER:
   
   Q Has anyone ever discussed either of these subpoenas with you at the
   White House?
   
   A No, ma'am.
   
   Q Were you aware that the Committee on Government Reform and Oversight
   had issued subpoenas to the Custodian of Records or the Executive
   Office of the President on January 11, 1996.
   
   Mr. Schuelke. Off the record for a moment.
   
   Ms. Bracher. Sure.
   
   [Discussion off the record.]
   
   The Witness. At the White House, we get little memos about this stuff.
   We don't get to see this stuff.
   
   Mr. Schuelke. This stuff, meaning the Exhibits 2 and 3.
   
   The Witness. Yeah, Exhibits 2 and 3. We do not get to see this. They
   will send us a little memo around and it will basically say, do you
   have any records on Travelgate or whatever.
   
   BY MS. BRACHER:
   
   Q Do you recall receiving any memos concerning these subpoenas?
   
   A I did see -- I am sure I saw a memo that asked about this, so when I
   was going through these records and I saw that letter, I thought maybe
   that had something to do with it so I -- I am sure Mrs. Clinton got
   this information to check her files.
   
   Q You said you were sure, do you know for a fact that she did receive
   it?
   
   A I don't know for sure, but they send out the memos basically to
   everybody at the White House.
   
   Q Did you retain a copy of the memo?
   
   A I don't know whether I have it or not.
   
   Q If you did retain a copy of it, would it be in a file that you could
   identify?
   
   A No, I probably didn't keep it because I just read it and basically
   from memory I know that I never had anything about Travelgate.
   
   Q Would the memo describe the kinds of documents that were being
   sought and what you should look for?
   
   A I thought it just gives the dates and any kind of written
   information or anything you might know about it within that particular
   period of time.
   
   Q Since this was sent out on January 11th, 1996, do you recall the
   date that you might have received a memo concerning these subpoenas?
   
   A We usually get them a few days later. We don't get it usually on
   that day, but a few days later they will send out a notice telling us.
   
   Q Do you know what you did in response to this memo?
   
   A Usually from memory I would, you know, I remember what I have seen
   and nothing hit a bell with me.
   
   Q Did you physically look through any of your documents?
   
   A Well, you know, I see my stacks but I did not go through every piece
   of paper that day looking because I knew that I had never really seen
   anything from David Watkins.
   
   Q But in fact you had.
   
   Mr. Schuelke. No.
   
   The Witness. I had not until in March.
   
   Mr. Schuelke. That mischaracterized her testimony.
   
   The Witness. I had not seen it until March because I had never seen
   that piece of paper until March, the end of February.
   
   BY MS. BRACHER:
   
   Q The first time you ever saw Deposition Exhibit No. 1 was the end of
   February on that that you testified?
   
   A Yes, ma'am.
   
   Q Do you know how it got in that stack that you were looking at?
   
   A A lot of times, Mrs. Clinton, she'll send me a little folder like
   this and say "personal filing." It will be in a red rope and I stick
   it on the shelf and don't look at it.
   
   Q Was the letter in fact in a folder or red rope file?
   
   A I do not -- if it was in a red rope or a folder, I do not remember.
   
   Q Do you remember whether it was in one or the other?
   
   A No, because I have --
   
   Mr. Schuelke. What do you mean?
   
   Ms. Bracher. She says she didn't remember whether it was in a red rope
   or a file.
   
   Do you have any memory whatsoever if it was enclosed in any other
   folder or file or document?
   
   The Witness. All I remember is it was in a stack of stuff I had to go
   through.
   
   Mr. Schuelke. I guess the question is, was that stack inside some kind
   of a folder or red rope.
   
   The Witness. Yes, I put them in reddish ropes. I stick stuff down in
   it. Even the little folders like that, I would stick into the red
   ropes.
   
   RPTS STEWART
   
   DCMN HERZFELD
   
   BY MS. BRACHER:
   
   Q So how much was in the red ropes that you found this --
   
   A Probably over like 25 pieces of paper, and that doesn't mean that is
   all letters, because I also get magazine articles, newspaper articles,
   that type thing, invitations to parties, and programs that Mrs.
   Clinton has gone to. So I just throw all that stuff down in this place
   and keep it, and when I got to organizing it, I had to straighten it
   out, so that is why I had to go through all of the pieces of paper.
   
   Q The stack you were going through in the end of February, did you
   know what kind of material was in that stack that you found this
   letter, Deposition Exhibit Number 1?
   
   A I had letters, magazine articles, newspaper articles, invitations,
   programs.
   
   Q Were they stacked according to a particular date or a year?
   
   A No, ma'am.
   
   Q Did they only have materials from 1994 in the stack?
   
   A No, it was different years.
   
   Q How would there be different years in one stack? Can you just
   explain?
   
   A You get all these pieces of paper -- like if you had 50 pieces of
   paper, would you know if it was one year? I just get them, put them in
   the red ropes. When I got around to sorting them out, that is when I
   put them into years.
   
   Q Do you put the most recent things that you received on top, or does
   it go in?
   
   A No, I just throw them in there.
   
   Q What order do you throw them in?
   
   A I just stick them down in the file.
   
   Q Do you put it on top, in the middle?
   
   A I don't know.
   
   Q So there is no method that you have to always put the newest item --
   
   Mr. Schuelke. So she has testified.
   
   The Witness. No.
   
   BY MS. BRACHER:
   
   Q The red rope that you have described, was that on the shelf that you
   said you had stacks of documents?
   
   A I had stuff on the floor in my office, boxes that I just piled this
   stuff in. It could have been down on the floor, the box. When I get
   it, just put it in there.
   
   Q In particular I am asking about Deposition Exhibit No. 1. Where was
   that document when you found it?
   
   A It was in this stack of stuff. If I got all these papers, it might
   be right in the middle of them.
   
   Q I wonder if rather than it might have been in the middle, where was
   it?
   
   A I have no memory.
   
   Q Do you have a memory whether it was on the floor or on a shelf?
   
   Mr. Schuelke. This has been asked and answered repeatedly. I am not
   going to permit much more of this.
   
   The Witness. No, I don't.
   
   BY MS. BRACHER:
   
   Q The chain of custody that we received from the White House says that
   Mrs. Clinton did not see the letter until March 12th. Do you know why
   she didn't receive your copy of the letter that you sent to her until
   March 12th?
   
   A I don't know.
   
   Q Have you had discussions with anyone regarding the reason why she
   didn't see it on March 12th?
   
   A No, I have not.
   
   Q Do you have any information whatsoever that would tell us why it was
   a period from March 4th to 12th, eight days passed before she actually
   saw a letter that you sent to her?
   
   A I don't know.
   
   Q Did you send it directly to her attention?
   
   A Yes, ma'am.
   
   Q Did this go through anyone else before -- was it addressed to anyone
   else to review it before the First Lady saw it?
   
   A No, ma'am.
   
   Q With your knowledge of what happens in the White House, do you
   believe that this letter did go directly to the First Lady.
   
   Mr. Schuelke. Calls for speculation. Ask her a question she can
   answer.
   
   BY MS. BRACHER:
   
   Q Based on your knowledge, what would be the path of a letter you
   would send to the First Lady?
   
   A I would put it in this little folder I had, and I would have it sent
   -- a note up there to Hillary Rodham Clinton from Carolyn Huber. I
   have a red rope like that, Hillary Rodham Clinton, care of the Usher's
   Office, send it to them, and they take it to her. I don't know how
   long it takes them to get it there.
   
   Q You don't know how long the Usher's Office normally takes to get a
   letter to the First Lady that you sent?
   
   A No, I don't. I don't know if they take it up immediately or if they
   wait and hour or -- I don't know. I am not over there.
   
   Q Based on your experience in the White House, does the material you
   give the ushers usually go to her office within a day?
   
   A Yes.
   
   Q Have you ever known for it to take eight days for a document to be
   lost until it arrives at the First Lady's office?
   
   A Well, no.
   
   Q There is a document I am going to mark as Deposition Exhibit No. 4.
   I am going to show the witness Deposition Exhibit No. 4, a letter
   dated April 5, 1996, from Jack Quinn to Chairman Clinger. At the top
   it says "by telecopy."
   
   (Huber Deposition Exhibit No. 4 was marked for identification.)
   
   Mr. Schuelke. Would you like her to read this?
   
   Ms. Bracher. Yes, please.
   
   The Witness. I have never seen it.
   
   Mr. Schuelke. She has read it.
   
   BY MS. BRACHER:
   
   Q Have you ever seen that document before?
   
   A No, ma'am.
   
   Q In this letter, which is a chain of custody to Chairman Clinger from
   John M. Quinn, counsel to the President, it states that on March 4th,
   Ms. Huber sent the original letter to Mrs. Clinton with her own note.
   
   Do you recall whether or not the file folder that you have described
   that you sent to Ms. Clinton had any other documents in it other than
   the Deposition Exhibit No. 1, Mr. Watkins' letter?
   
   A I don't know, because sometimes I send personal checks to be signed.
   I don't know if I had any of those in there or not.
   
   Mr. Schuelke. Give us just a moment, please.
   
   (Discussion held off the record.)
   
   The Witness. There were two other little letters that I sent along
   with it.
   
   BY MS. BRACHER:
   
   Q Do you know what those letters were?
   
   A Yeah, they were from Mrs. Cardozo and Mrs. Anthony thanking Mrs.
   Clinton for letting them go to Camp David for a year after Vince's
   death. They went up for a day of meditation in honor of his death
   after a year.
   
   Q So those would have been letters written in about July of '95?
   
   A '95.
   
   Q Was there any significance including those letters with this letter
   that is Deposition Exhibit No. 1, Mr. Watkins' letter?
   
   A Were they what?
   
   Q Was there any significance to the fact that those were included when
   you sent the Watkins letter to the First Lady?
   
   A I didn't know they asked us for Foster documents, too, so I just
   sent them along.
   
   Q Who had asked you for Foster documents, too?
   
   A The Senate hearing.
   
   Mr. Schuelke. You mean the White House counsel had notified you of
   subpoenas that cover the Foster death issue as well as the Travel
   Office.
   
   The Witness. As well as Travel Office. We get both of them.
   
   BY MS. BRACHER:
   
   Q After finding the Watkins letter, did you review all of your files
   at that time then to see if any other letters were confined within
   stacks that you had been filing?
   
   A Yes, ma'am.
   
   Q Did you find anything else that you thought might be responsive to
   any of the outstanding subpoenas?
   
   A No, ma'am.
   
   Q Did you also review the boxes that you had taken up to the residence
   to see if there were any documents in those boxes that might be
   responsive to any of the subpoenas that had been sent?
   
   A I don't have any of Mrs. Clinton's documents upstairs. I have them
   all in my office right now at the present time.
   
   Q Did you review all of those boxes to see if there was anything?
   
   A Yes, ma'am.
   
   Q Did you find anything in any of those boxes?
   
   A No, ma'am.
   
   Q Have you reviewed the boxes that are upstairs to see if they have
   any responsive documents?
   
   A The boxes I have upstairs are mainly photos right now. I don't have
   any kind of White House materials upstairs right now. They are all in
   my office.
   
   ( Huber Deposition Exhibit No. 5 was marked for identification.)
   
   BY MS. BRACHER:
   
   Q We are marking a document as Deposition Exhibit No. 5, and I am show
   the witness a copy of a letter that was sent on September 18, 1995,
   and it is a document request which is from the Committee on Government
   Reform and Oversight, Chairman Clinger, September 1995, to the
   Honorable Abner Mikva. And I would ask you if you were ever shown this
   document request.
   
   In particular on page 2 it requests documents under a subheading
   number (1) for any records related to the White House Travel Office
   matter or White House project, and it lists the following individuals,
   and one of the individuals is the First Lady. Similarly, it also lists
   David Watkins as one the individuals. And similarly, on page 3 under
   subheading number 2, it asks for all records relating to the General
   Accounting Office review of the White House Travel Office.
   
   Have you ever seen this document?
   
   A No, ma'am.
   
   Q After September 18th 1995, were you ever contacted by anyone at the
   White House to perform a search of all of your records for documents
   that would be responsive to the Committee on Government Reform and
   Oversight document request?
   
   A I don't remember the dates. You know, when we get those memos coming
   around asking about this, I can't remember the dates.
   
   Q The memos that come, do you recall if they are from the White House
   Counsel's Office?
   
   A Yes, ma'am.
   
   Q And are those memos dated?
   
   A Yes.
   
   Q Do you have my recollection as to whether before the end of '95 you
   were ever requested to do a search of your records for documents not
   only relating to the White House Travel Office matter, but
   specifically documents that might concern the First Lady or David
   Watkins for the General Accounting Office review?
   
   A I don't remember.
   
   Q We have one document, which I will make this a part of the record
   just for the record rather than the relevance. It is Deposition
   Exhibit No. 6, and it is a letter on January 17th, and it is written
   to Chairman Clinger from White House Counsel John M. Quinn.
   Particularly I would ask you if you have ever seen that letter before?
   
   A No, I haven't.
   
   Q I would like to call your attention to page 5. On the first
   paragraph on page 5 -- I will just give you some time.
   
   Mr. Schuelke. Which paragraph?
   
   BY MS. BRACHER:
   
   Q On page 5, the first paragraph. It begins, "On December 7th, 1995,
   you and I resolved several outstanding issues regarding a Committee
   document request. Thereafter on December 19, 1995, a memorandum was
   sent to all staff of the Executive Office of the President instructing
   them to search their files for certain additional materials requested
   by the Committee and to provide any such material to my office."
   
   If, in fact, there was a December 19, 1995 memorandum, do you recall
   receiving that memorandum?
   
   Mr. Schuelke. Do you have a copy?
   
   Ms. Bracher. No, the White House has not produced a copy of that
   memorandum.
   
   Mr. Schuelke. This letter says a copy memorandum is attached hereto as
   Exhibit 5.
   
   Ms. Comstock. We never received it. It indicates it was -- we have
   been trying to get ahold of them to get it.
   
   Ms. Bracher. They omitted to include it. I might ask -- do you know?
   
   Mr. Goldberg. I will check my files.
   
   Ms. Bracher. Would you search your files. We requested it several
   times. I apologize.
   
   Mr. Schuelke. The question is do you recall receiving a memo from the
   White House Counsel's Office.
   
   Ms. Bracher. Asking you to search your files.
   
   Mr. Schuelke. Sometime after December 19, 19 -- no, on December 19,
   1995, asking you to search your files for certain additional materials
   requested by the Committee.
   
   The Witness. I don't remember.
   
   BY MS. BRACHER:
   
   Q Do you know if you made searches of your files for Travel Office
   documents before locating Deposition Exhibit No. 1 at the end of
   February?
   
   A No, I didn't search them.
   
   Q I have also got a document, which I will mark as Exhibit --
   Deposition Exhibit No. 7, and it is a copy of a memorandum dated
   February 1, 1996, and it is sent to all staff of the White House from
   John M. Quinn, and the subject is subpoena from the House Government
   Reform and Oversight Committee.
   
   I will give you a minute to look that over and see if you recognize
   that document.
   
   (Huber Deposition Exhibit No. 7 was marked for identification.)
   
   Mr. Schuelke. This is the memorandum about which you had testimony
   earlier. This relates to the January 11 subpoena of the Committee,
   right? And she has testified she recalls receiving the memo.
   
   BY MS. BRACHER:
   
   Q Now that she is seeing the memo, I would like to ask her if that is
   the memo you recall receiving?
   
   A I remember seeing one, but I can't remember if it was all these
   pages. I can't remember that.
   
   Q Do you recall if you immediately searched files in response to that
   memorandum which is dated February 1, 199 --
   
   A No, I didn't.
   
   Q Have you ever done a search of your files for any documents in
   response to the memorandums that you said you received prior to the
   finding of this Watkins memo, Watkins letter, which is Exhibit No. 1?
   
   A Are you talking about Travelgate?
   
   Q Yes, ma'am.
   
   A No.
   
   Q What did you do in response to the earlier memorandums that you
   received about Travelgate?
   
   A I didn't do anything.
   
   Q Why not?
   
   A Because I didn't think I had anything on Travelgate. I never had
   been involved in it. I never had seen any papers on it.
   
   Q Was there any procedure instituted in the White House that you are
   aware of to collect documents concerning Travelgate?
   
   A All I know is these things I sent around, so I assume they get a lot
   of documents when they send this around.
   
   Q Did you personally have contact with anyone regarding the search for
   documents concerning the Travelgate documents request and subpoenas?
   
   A No.
   
   Q Was anyone available to advise you on the kind of documents that
   were being requested or the scope of documents that were contained in
   the subpoena?
   
   A You mean the White House counsel?
   
   Q The White House counsel, or, you know, were you aware of -- I know
   the memo does list Jane Sherburne or Natalie Williams, but were you
   aware of -- did you have any oral contact with anyone concerning your
   search of documents pursuant to the Travelgate subpoenas and document
   request?
   
   A No.
   
   Q The last page of the memo that is dated February 1st that you are
   looking at the page 5 -- I am sorry, the page 5 that you are at does
   say, it is extremely important that staff members conduct a thorough
   search for documents.
   
   Were you ever advised to go ahead and go through all documents even if
   you didn't think you had anything, just in case something was located
   within those files that had you?
   
   A I was never contacted by anyone.
   
   Q So other than receipt of memos, one of which you believe to be this
   February 1st memo, you didn't receive any other advice or consultation
   regarding your search for documents?
   
   A No.
   
   Q Who would be considered your department head in the Office of
   Correspondence, or do you have a department head? Is there anyone who
   would coordinate efforts to gather documents in the Office of Personal
   Correspondence?
   
   A No, I mean, we just talked to each other about it when we would get
   them, and that was only three of us there.
   
   Q Do you recall any discussions when you would receive these memos to
   go through your documents about what you should do to see if there
   were documents contained within your files?
   
   A No.
   
   Q Who has access to the stacks of documents that are in your office
   waiting -- or that were in your office in 1994 waiting to be filed?
   
   A I don't -- there is nobody that helps me. There is nobody that comes
   -- people come in and out, but they just come in to say hello or
   something.
   
   Q Is your office -- is the office that you share kept locked in the
   evenings?
   
   A I lock my office at night. When I am not in my office, it is locked.
   
   Q And other than the two individuals that you identified are in your
   office, does anyone else have a key to your office?
   
   A Milli does in case something didn't arrive or something, but we keep
   -- her office is locked, too, at nighttime.
   
   Q In this room are they separate offices with doors?
   
   A Yes, ma'am.
   
   Q And your office has a door that you can lock so no one can get into
   the area where you keep your filing?
   
   A Yes, ma'am.
   
   Q Are there any alarms that are connected to that office?
   
   A No.
   
   Q Are there any systems that would record when people go in and out
   that you are aware of?
   
   A Not that I'm aware of.
   
   Q Other than Milli having a key to your office, do you know anyone
   else who has a key to your office?
   
   A The Secret Service, or the GAO, or whoever operates that building.
   
   Q Do you lock your office every evening?
   
   A Yes, ma'am.
   
   Q Does anyone ever come in your office and place documents in stacks
   to be filed that have not gone directly through you?
   
   A No.
   
   Q Do you have any questions.
   
   Mr. Hernandez. No, I don't have any questions.
   
   Ms. Bracher. If I could just have a few seconds. I think I am
   finished. I just want to make sure there wasn't anything.
   
   [Pause.]
   
   Ms. Bracher. I just have a last question or two to clarify.
   
   BY MS. BRACHER:
   
   Q We had discussed earlier on about the boxes being filed and some of
   them going up to a closet in the residence, and you later said that
   you didn't believe there were any documents in that closet in the
   residence. Can you just clarify exactly what's been taken?
   
   A None of Mrs. Clinton's documents are up there. They are in my
   office. The documents we have up there right now are all the pictures
   that -- the White House photos that we catalog there. There are some
   things of the President's mother's after she died. Mementos are in
   there, and there are some of the President's grade school, high
   school, college papers in there right now, and their financial papers
   of theirs from 1979 to 1992.
   
   Q Other than those very personal documents, have any of the
   President's letters been sent up there?
   
   A No, ma'am.
   
   Q So none of the materials that you were filing and putting in these
   boxes currently are up there. And are they all in your office right
   now?
   
   A Yes, ma'am.
   
   Q Have you spoken to the First Lady about this letter?
   
   A No, I have not.
   
   Q And other than the conversations you had with White House counsel,
   have you had conversations with anyone else other than your counsel or
   the privileged conversations with White House counsel about this
   letter?
   
   A No, ma'am.
   
   Q One final question: When you were looking through documents, did you
   also search through the President's letters for documents responsive
   to any of the subpoenas?
   
   A I did not search his. I did not get his documents until about six
   months ago, but Ms. Nancy Hernreich came through and looked at them.
   
   Ms. Bracher. That is all I have. I don't know if counsel for the
   Minority has any questions.
   
   Mr. Hernandez. We have no questions at all.
   
   [Whereupon, at 11:18 a.m., the deposition was concluded.]



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