Travelgate Depositions

DEE DEE MYERS



   COMMITTEE ON GOVERNMENT REFORM AND OVERSIGHT
   
   U.S. HOUSE OF REPRESENTATIVES
   
   WASHINGTON, D.C.
   
   Errata sheet of corrections for the Deposition of Dee Dee Myers
   
   can be found at the end of this document.
   
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   :
   
   In the matter of: :
   
   :
   
   WHITE HOUSE TRAVEL : DEPOSITION OF DEE DEE MYERS
   
   :
   
   :
   
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   Friday, April 19, 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:
   
   Present: Representative Clinger.
   
   Staff Present for the Government Reform and Oversight Committee:
   Barbara Bracher, Chief Investigative Counsel; Barbara Comstock,
   Investigative Counsel; Laurie Taylor, Majority Investigator; David
   Schooler, Chief Minority Counsel; Ronald Stroman, Deputy Staff
   Director; Don Goldberg, Assistant to Chief Minority Counsel; and Dan
   Hernandez, Minority Professional Staff Counsel.
   
   For DEE DEE MYERS:
   
   PETER J. ROMATOWSKI, ESQ.
   
   STEPHEN M. BYERS, ESQ.
   
   Crowell & Moring
   
   1001 Pennsylvania Avenue, N.W.
   
   Washington, D.C. 20004-2595
   
   Ms. Bracher. We are on the record in the deposition of Dee Dee Myers
   which will be administered under oath.
   
   Let me identify the people who are present in this room. Present is
   myself, Majority counsel, Barbara Bracher; as well as Laurie Taylor
   from Majority staff; Minority Staff is here, Don Goldberg and Dan
   Hernandez.
   
   Ms. Myers is here with two of her attorneys, Peter Romatowski and
   Steve Byers.
   
   Before you are sworn in, Ms. Myers, I would like to provide you with
   some background information concerning this investigation and your
   appearance hear.
   
   As you know, pursuant to authority under Rules 10 and 11 of the House
   of Representatives, the Government Reform and Oversight Committee is
   investigating the White House Travel Office matter. This matter refers
   to all events leading to the May 19, 1993 firings of the White House
   Travel Office employees and includes information provided about the
   White House Travel Office and any employees of the White House Travel
   Office at any time from January 1st, 1993, to the present.
   
   Our investigation also encompasses the activities of Harry Thomason,
   Darnell Martens and Penny Sample at the White House, as well as all
   allegations of wrongdoing concerning the Travel Office employees.
   
   The committee investigation is reviewing all actions taken by the FBI
   and the Department of Justice both prior to and after the firings.
   These actions include any actions by field office personnel and any
   White House involvement in the coordination or attendance of
   interviews with the FBI or Department of justice.
   
   The investigation includes, but is not limited to, the investigation
   and prosecution in the United States v. Billy Ray Dale case and all
   investigations and subsequent reviews of Travel Office firings by any
   agency, which include, but are not limited to, the White House
   Management Review, the FBI Weldon Kennedy/I.C. Smith review, the FBI
   OPR review, the Justice Department OPR review, the IRS internal
   review, the Treasury Inspector General review, the GAO review and the
   proposed United States House of Representatives "Resolution of
   Inquiry" which was considered and voted on in the House Judiciary
   Committee on July 1993.
   
   We are reviewing all actions relating to or describing the criminal
   investigations into the White House Travel Office matter which include
   any subsequent action or activities of any kind as a result of the
   above-mentioned events by the White House, Treasury Department, IRS,
   GSA, GAO, FBI and Independent Counsel, as well as Department of
   Justice up to the date of this request.
   
   Do you understand that your answers should include all information
   which you have involving these subjects?
   
   Mr. Romatowski. No. There is no way, counsel, that anyone who is
   provided notice by the litany you have just read for the first time
   this morning as we begin this deposition could possibly have absorbed
   all the subjects, which stray far beyond what I read in the House
   Resolution you are investigating, which says simply, "The White House
   Travel Office Matter."
   
   Ms. Bracher. The definition of the White House Travel Office Matter is
   contained in the committee report which was put out by the Committee
   on Rules. As you are aware, quite often resolutions will use terms
   which are not fully defined and then rely on the committee report to
   define them.
   
   The information I have just given you absolutely tracks the committee
   report from the Committee on Rules. I have a copy on paper and I will
   be happy to give you this copy to review with your client before we
   begin.
   
   Mr. Romatowski. We are not going to undertake to memorize this litany
   of which we have had no prior notice. I don't doubt, counsel, that it
   is printed somewhere in some committee report, or what have you. But
   no one could hope to as they address each of your questions here this
   morning, review that laundry list of what has to be several dozen
   subjects and answer comprehensively as to all those wide topics.
   
   Now, I think that it is probably going to be, as a practical matter,
   indifferent to you because I don't think this witness has much to say
   about whatever proposed resolution of inquiry dated umpty-umpth, to
   pick an example from your litany you have recited, I don't think she
   is going to have much to say on those subject.
   
   But please don't ask her to adopt what you have just read from two
   single-space pages and then promise you that as we proceed here today
   she is going address ever single one of your questions with all of
   that detailed recitation in mind. It is simply not possible.
   
   Ms. Bracher. The purpose of the statement of scope is so that the
   witness understands that if she is answering a question only partially
   because she believes that it is not within the scope, then this
   statement serves to inform the witness and put her on notice that the
   questions include a lot of different aspects of the White House Travel
   Office matter and she should not limit her answers because they do not
   particularly pertain to the Travel Office firings per se. It only
   serves to have a notice to understand that her answers should include
   information which she possesses which might come under any of those
   topics.
   
   Mr. Romatowski. And my response is that it is inadequate to provide
   the kind of notice that you are purporting to foist on this witnesses.
   What we are going to do, counsel, is address ourselves this morning to
   each of your questions and the witness will interpret the White House
   Travel Office matter as broadly as she can and we will proceed on that
   basis. But please don't ask us to adopt and accept that she is going
   to respond as to each of a couple of dozen topics you just read off a
   list which she has never heard before.
   
   Ms. Bracher. I ask that if the answer is being limited in any way, we
   will be happy to stop, take a break so that the witness can confer
   with her counsel and see if the limitation of her answer is
   appropriate in light of the scope.
   
   Mr. Romatowski. The scope we are addressing here today and her answers
   is as to the White House Office matter. If you ask her any particular
   question that strays beyond that and focus her attention on a
   particular subject, no doubt she will answer as best she can all
   questions within the broad scope of this committee's business. But we
   can't adopt the long recitation you just made.
   
   Mr. Goldberg. And let me state for the record that Minority does not
   necessarily concur in the description that Majority staff has made,
   and also believes that the Resolution defines the scope of this
   particular deposition. If the Members wanted to expand it beyond the
   White House Travel Office matter, they clearly could have done that.
   They chose not to.
   
   Ms. Bracher. With that statement, I would like to add that the
   Chairman has always considered this to be the scope of our deposition
   authority and it is the scope according to the Chairman of this
   committee.
   
   Mr. Goldberg. I don't know of any authority for the Chairman to
   determine the scope that a Resolution voted on by the House has.
   
   Ms. Bracher. The committee has been granted specific authorization to
   conduct this deposition, pursuant to House Resolution 369, which was
   passed by the House of Representatives on March 7, 1996. Pursuant to
   Committee Rule 19, which I believe has been provided to you through
   your attorney, both Majority counsel and Minority counsel will be
   afforded an equal opportunity to pose questions to each witness.
   
   Committee counsel will proceed with equal rounds of questioning
   lasting up to one hour until both counsel have completed their
   questioning. The only exception to this will be if a Member of this
   committee is present and wishes to pose questions to the witness. If
   so, the Member will be afforded an immediate opportunity to question
   the witness and committee counsel will then resume questioning when
   the Members have completed their questions.
   
   Ms. Bracher. You are here today voluntarily and not by subpoena, is
   that correct?
   
   Ms. Myers. Correct.
   
   Ms. Bracher. You understand that this deposition is under oath. You
   will be allowed to confer with your attorney. If you do not understand
   a question, please tell me and I will try to rephrase the question.
   
   I ask that all objections raised by your attorney be stated for the
   record with the reason for the objection clearly stated. At that point
   committee Majority counsel will determine whether to accept the
   objection as a proper objection.
   
   If Majority counsel does not agree that the objection is properly
   before this deposition, I will confer with Minority counsel and ask
   this that they express their views on the record. If the objection
   remains, it ultimately may be presented to the Chairman of the
   committee or his designee for resolution. The Chairman will consult
   with the Ranking Minority Member before issuing his final decision on
   the objection.
   
   You will be given a 5-day time frame in which you and your attorney
   may review this deposition once it has been transcribed and to correct
   any technical problems that you perceive occurred during the
   transcription. You will also be allowed to clarify any matters which
   you feel need to be clarified.
   
   After the review period, you will be asked to sign the transcript. Do
   you understand that?
   
   Ms. Myers. Yes.
   
   Ms. Bracher. You are accompanied by counsel this morning and I ask
   that you be sworn in at this time.
   
   WHEREUPON,
   
   DEE DEE MYERS,
   
   a witness in the above-entitled matter, was called as a witness, and
   having first being duly sworn or affirmed to tell the truth, the whole
   truth, and nothing but the truth, was examined and testified as
   follows:
   
   EXAMINATION BY MS. BRACHER:
   
   Q Do you have any questions before we start?
   
   A No.
   
   Mr. Romatowski. I have a couple.
   
   Can I ask that there be marked as exhibits to this deposition my
   letters of April 16 and April 18 to Chairman Clinger requesting access
   to certain documents referred to in earlier committee correspondence
   that I believe has been made public concerning Ms. Myers?
   
   Ms. Bracher. They will be marked as Deposition Exhibit 1, letter of
   April 16th, and Deposition Exhibit No. 2, is a letter of April 18th.
   
   Both Exhibit 1 and 2 are from Ms. Myers' attorney, Peter Romatowski.
   
   (Myers Deposition Exhibit Nos. 1 and
   
   2 were marked for identification.)
   
   Ms. Bracher. Have you in fact been allowed to review the GAO report
   that you discuss in your letters?
   
   Mr. Romatowski. No. We have seen a GAO report but I have had no
   response from you or from anyone on the committee regarding those
   requests that we have an opportunity to look at those notes that are
   referred to in Mr. Clinger -- in Chairman Clinger's letter of October
   7, 1994. I have had no response of any sort.
   
   The reason I asked that they be marked is to ask whether you have a
   response as to whether or not we will be allowed to look at those
   documents.
   
   Ms. Bracher. The documents from Chairman Clinger's letter is taken
   from the GAO report. There is only, I believe, one GAO interview with
   Ms. Myers, which you have now stated that you reviewed, and that is
   the report, to my knowledge, that his letter refers to.
   
   Mr. Romatowski. I think we have seen the public report. Mr. Clinger's
   letter refers to GAO notes of an interview that Ms. Myers granted on,
   I believe it was September 19, 1993, and those are the subject of my
   request and which we have had no opportunity to review. We have had no
   response from the committee about that.
   
   Ms. Bracher. Can you refer me to where in the October 7, 1994 letter
   that you requested?
   
   Mr. Romatowski. There is a reference to Ms. Myers on page 3 of the
   letter, and again in Attachment E and Attachment F.
   
   Ms. Bracher. I think page 3 of the letter states that "Press Secretary
   Dee Dee Myers' statements to GAO that she had no contact with Darnell
   Martens about the White House Travel Office is contradicted by her own
   statements to the press," Attachment E.
   
   On two occasions prior to her press briefing on May 19, 1993, the
   White House Press Secretary Dee Dee Myers disclosed that the FBI was
   investigating the Travel Office. That action was inappropriate. Even
   more inappropriate was her subsequent denial at the May 19th press
   briefing that there was not an ongoing FBI investigation, Attachment
   F.
   
   Mr. Romatowski. Right. That is what I was -- you have read the
   portions of the October 1994 letter which prompted my request to the
   committee that we be allowed access and a opportunity to review in
   advance of this deposition the documents that provide the basis for
   the criticism of Ms. Myers here and the alleged contradictions.
   
   Ms. Bracher. You have reviewed that statement. It is from the GAO
   interview. There are no GAO notes that are mentioned in this letter.
   It says, "statements to the GAO." Ms. Myers was interviewed September
   16, 1993, which, if my understanding is correct, you have reviewed
   that interview.
   
   Mr. Romatowski. No. The answer to that is no, and that is the nature
   of my request. Apart from whatever summary conclusion is drawn in the
   GAO report, we would like to see whatever interview notes there are to
   support that statement.
   
   Ms. Bracher. The interview notes are the record of interview which was
   taken by the GAO on September 16th. You have not seen the record of
   interview?
   
   Mr. Romatowski. That is correct.
   
   Ms. Bracher. What GAO interview of Ms. Myers have you seen?
   
   Mr. Romatowski. Zero.
   
   Ms. Bracher. We will mark this as Deposition Exhibit 3.
   
   (Myers Deposition Exhibit No. 3 was
   
   marked for identification.)
   
   Ms. Bracher. The first page is the relevant part which discusses Ms.
   Myers' contacts with Mr. Martens. Certainly we will allow you to make
   a record, if you would like to, regarding that first statement and
   what Ms. Myers meant by that statements.
   
   We do not at this point intend to try to make an inaccurate statement
   or catch her in anything. We are trying to get her full view of what
   occurred and her best recollection of events as they happened.
   
   Mr. Romatowski. Thank you, counsel.
   
   I will be happy to take a few minutes here to take the opportunity to
   acquaint myself with this now. I regret that we didn't have an
   opportunity earlier, so we will have to delay proceedings this
   morning.
   
   But is it your statement that there is no other record of this GAO
   interview other than this typed summary, which was clearly prepared
   after the fact?
   
   Ms. Bracher. To my knowledge, there are notes. The GAO has not
   released us the entire set of their notes. I don't believe we have
   handwritten notes. They certainly were not reviewed when this letter
   was written.
   
   Mr. Goldberg. For the record, we have at least two sets of handwritten
   notes.
   
   Ms. Bracher. I know GAO has released to the Minority its notes but has
   not fully released all copies of notes to Majority Counsel.
   
   This letter, the notes were not used for the letter that was drafted
   to then Chairman Conyers on October 7, 1994. I believe that it was the
   record of interview, which I think if you read the first page, you
   will see that that is where that information came from.
   
   Mr. Romatowski. I don't mean to split hairs, and I would like to make
   plain what is my interest. I don't mean to confine my request to a
   particular phrase or paragraph of that letter. That is just referred
   to by way of orienting you to the general interview and the basis for
   my request.
   
   I am interested in whatever record you have in your possession of Ms.
   Myers' various volunteer interviews on these subjects that you intend
   to review for the third or fourth time in her case. She has now
   voluntarily described these matters for GAO investigators, for FBI
   investigators, she agreed to do so last fall, when you requested an
   interview unconditionally, that was first scheduled and then cancelled
   at your request.
   
   I would like to know, in fairness to this witness, before we review
   these matters for at least the third time, is there any record that is
   in your possession that records in any fashion those statements at the
   earlier interview which Mr. Clinger has seized upon in a letter a year
   and a half ago to criticize Ms. Myers for alleged contradictions?
   
   If we are going to air out those alleged contradictions and we mean to
   get to the facts here. We would have liked to have seen before today
   everything you have got that purports to record what it is she said.
   It is as plain as that.
   
   I don't mean to confine myself to a particular paragraph and what you
   regarded as the basis for something that is in a particular paragraph
   of a particular letter. The letter is what prompts my request and is
   meant to draw your attention to the prior interviews that are the
   subjects of the request.
   
   Ms. Bracher. First of all, we are not going to provide everything in
   our files that we have. This deposition is merely to ask Ms. Myers
   what her recollection is of events. If she needs her recollection
   refreshed, then I assume there will be documents and we will take time
   and let her review those documents.
   
   We really would like to sit down here and have Ms. Myers give us her
   recollection of events as they are today. We can put on the record
   what she has and has not reviewed. I have no problem with that. But
   there is no need for her to go through documents and interviews.
   
   I understand your concern about the Conyers' letter. That is why I
   have given you the GAO report. To my knowledge, that was what was used
   in the Conyers' letter by the Chairman.
   
   There is reference in the GAO report where Ms. Myers says that she
   never spoke to Darnell Martens. You will notice that that is exactly
   what is stated.
   
   If you read the interview, that she had no contact with Darnell
   Martens. If you read the interview on the first page, you will see
   that is where she made that statement to GAO. There are other
   statements that were made in a press conference also that Darnell
   Martens had called. We will go through those at that time.
   
   If you want to review materials and refresh her recollection, if you
   want to look at any materials I am referring to, we will take ample
   time for you to be able to look at it and review it with your client.
   But I would like to begin the deposition.
   
   Perhaps when we come to that area we can stop, I can give you ample
   time to review documents and feel comfortable with her answers.
   
   Mr. Romatowski. Counsel, you were the first to mention a few minutes
   ago of a game of "Gotcha," and that captures my concern, that what we
   have here is repetitive questioning for now at least the third time,
   this time under oath at your request, by a witness who has shown up
   voluntarily and cooperated with every person who has had questions of
   this sort.
   
   You are the first to have alleged that she has contradicted herself in
   some fashion, based on evidence that until this morning when I pressed
   the request for the third time, you have declined to produce at all,
   and now have offered us an opportunity only to review in part, and
   perhaps the least satisfactory part, because what we have here is a
   typed interview summary prepared -- I can't tell when, but clearly not
   the contemporaneous notes of the interview.
   
   I see in various markings here, it is initialed and dated the day
   after. That is my concern, counsel. I don't know the reason why it is
   that if what we are after is an accurate recounting of the events
   here, the method to proceed is to withhold from this witness, who is
   already accused publicly of a contradiction, the details of the prior
   statements, as you have a record of them, and try to put the same
   questions again. I don't see any purpose --
   
   Ms. Bracher. You have been given the item that was used when the
   Conyers' letter was written in '94. You have that before you. You can
   certainly make a record.
   
   Ms. Myers will be allowed a full opportunity to explain any perceived
   misstatements or discrepancies or any reasons why she would have said
   what she said to GAO. And in fact if she didn't say what is down there
   to GAO, we will give her a full opportunity to explain that. This was
   a very minor point which was brought up in the Conyers letter about
   the fact that Ms. Myers said she didn't believe she had met with Mr.
   Martens. It is in the GAO report on page 1.
   
   When I come to that area, I will allow you a full opportunity to make
   whatever record you want to make concerning that one point. We have a
   lot of area to cover and we would like Ms. Myers to sit here, and as
   she can recall things, to give us her best recollection.
   
   RPTS STEIN
   
   DCMN HERZFELD
   
   Mr. Goldberg. For the record, I have interview notes that I could find
   from the GAO. If the majority agrees, because I have them the here, I
   will make them available to the witnesses.
   
   Ms. Bracher. They were not used when the 1994 report was drafted. I
   believe those notes were just delivered to you within the past four
   months.
   
   Mr. Goldberg. I am just making a statement for the record that the
   witness's attorney has requested to review notes. I have them to make
   available.
   
   Ms. Bracher. I don't believe they are relevant since all the Majority
   had when the Conyers letter was written in 1994, if they had an actual
   copy of the GAO report, they did not have notes. Therefore they don't
   become relevant. I think we are making a large issue out of a rather
   minor issue that came out of the Conyers report and have now provided
   what materials we used to draft that issue.
   
   Mr. Romatowski. Are we going to take a break for me to review this? We
   understand how you are going to proceed. I have made my request. I
   think your response is on the record that you don't think any of it is
   relevant.
   
   Ms. Bracher. I did not say I didn't think any of it was relevant. I
   said that what is relevant is Ms. Myers' recollection and present
   sense recollection today as she remembers those events. When I get to
   the area and ask her questions whether she spoke to Mr. Martens on
   that date, I think it would be helpful to stop at that point so you
   can review it with her. And maybe at that point you will realize it
   will be in a better context.
   
   Mr. Romatowski. I don't think -- your response doesn't address my
   concerns, but I hear your response and I don't know that there is a
   point to beating it to death any further.
   
   If you are going to ask the same questions that have already been put
   to her several times, it is not fair to this witness to do in this
   fashion so without her counsel having had a full opportunity to
   consider the full basis for these earlier statements. I understand
   that you don't accept that, and you mean to go forward anyway.
   
   Ms. Myers is here voluntarily, cooperating, as she has offered to do
   since you first asked last fall, and we are willing to go forward on
   that basis.
   
   But we will have to be careful about how we address each of your
   questions because you are sitting on details from prior answers to
   this that you believe to accurately reflect earlier interviews which
   you have afforded us no opportunity to see. Let's go forward.
   
   One other thing on scheduling. A couple of things. As she addresses
   your questions this morning, I hope you will understand that she will
   treat your questions as if they do not call on her to reveal any
   privileged communications with her counsel, that is to say not to
   disclose anything she has learned in the course of conversations with
   her counsel seeking or obtaining legal advice.
   
   Ms. Bracher. Certainly with that caveat, if it is in conversations
   that she has had with counsel that regard legal advice, we will set
   that aside and exclude that from any of her answers.
   
   Mr. Romatowski. We need to break by 3 o'clock today. Do you have any
   idea how long you might be?
   
   Ms. Bracher. We will probably go until 3:00 then.
   
   BY MS. BRACHER:
   
   Q Ms. Myers, if you would give me a brief history of work from the
   time you graduated from school until the present.
   
   A I graduated from college in 1983. I went to work for an organization
   called Citizens Action League in Los Angeles. In January of 1984, I
   went to work for the Mondale for President campaign. Following that I
   worked for a State senator from California named Art Torres. Following
   that I worked for the Mayor of Los Angeles, Tom Bradley.
   
   In 1988 I went to work for Michael Dukakis' Presidential campaign.
   Following that I worked for Tom Bradley's reelection campaign in 1989.
   Following that I went to work for Dianne Feinstein, who was running
   for governor of California.
   
   In 1991 I worked for -- I had my own business, which was a
   communications consulting firm. I had a number of clients.
   
   In the fall of 1991, I went to work for the Clinton for President
   campaign. When Clinton was elected, I went to work for the White House
   in January of 1993. I left the White House at the end of 1994. In the
   spring of 1995, I went to work at CNBC and Vanity Fair, where I am
   currently employed.
   
   Q The communications consulting business that you had in 1991; where
   was that located?
   
   A California, Los Angeles County.
   
   Q Were any of the individuals that you worked with in the White House
   clients of yours when you had your consulting business?
   
   A No. Not that I recall. I don't think so.
   
   Q When you went to work for the campaign, what was your position with
   the campaign?
   
   A Press Secretary.
   
   Q And when you began working in the White House, what was your title?
   
   A White House Press Secretary.
   
   Q Who did you report to as your position as Press Secretary while you
   were in the White House?
   
   A Originally George Stephanopoulos. In June of 1993, it became Mark
   Gearen. In the fall of 1994, it became Leon Panetta.
   
   Q Do you recall when your first involvement was in any White House
   Travel Office matters?
   
   A Can you be more specific?
   
   Q Certainly.
   
   By involvement, I am referring to when was the first notice you had of
   the White House Travel Office review or that there was any activity
   looking into the employees' actions in the White House Travel Office?
   
   A On the Friday before the dismissals, Harry Thomason and Jeff Eller
   mentioned to me that there was some kind of review ongoing that might
   precipitate changes.
   
   Q Do you recall where you were when you spoke with Mr. Eller and Mr.
   Thomason?
   
   A In George Stephanopoulos' office.
   
   Q Was this a formal meeting or just a stop-by?
   
   A A stop-by.
   
   Q Was there any description of the kind of problems by either Mr.
   Eller or Mr. Thomason that you recall?
   
   A I don't recall specifically. My recollection is that they didn't go
   into detail, but led me to believe that there were some irregularities
   that were causing them some concern. But we didn't discuss it at any
   length.
   
   Q Did they mention -- just for your reference, I believe that Friday
   you referred to is May 14th.
   
   A That is correct.
   
   Q The firings would have been on the 19th, which was a Wednesday. Did
   they mention that this had gone through any other individuals in the
   White House besides Mr. Eller and Mr. Thomason?
   
   A I don't recall how they described the process.
   
   Q Did they state that they had been to David Watkins?
   
   A I don't recall.
   
   Q At that time, although you don't specifically recall what Mr.
   Thomason said, do you remember there being any mention of kickbacks?
   
   A Again, I don't recall specifically what was said at that time;
   certainly later, but I don't remember exactly when I first heard that.
   
   Q Prior to the time on May 14th when Mr. Eller and Mr. Thomason came
   in, had you heard any general rumors about problems in the Travel
   Office going around the White House or within the press?
   
   A Not related to financial irregularities, no. There were always
   problems dealing with the logistics and the cost of travel. The Press
   Office complained to me about the exorbitant cost of traveling with
   the President. I don't remember hearing anything else about financial
   irregularities and the handling of travel matters.
   
   Q Do you remember rumors in the White House about improper actions by
   the employees before that date?
   
   A No.
   
   Q You said you were in George's office. Can you explain to me where
   your office was and his office within the White House compound?
   
   A In the West Wing there was a suite of offices where George had an
   office, Ricki Seidman at that time had an office and I had an office.
   There were three offices that opened onto a common reception area. His
   was two doors down from mine.
   
   Q Was this a receptionist that answered the phones for the three of
   you?
   
   A Each of us had assistant that worked in the common area, in the
   reception area of the suite.
   
   Q Who was your assistant?
   
   A David Leavy.
   
   Q Who was Mr. Stephanopoulos's assistant?
   
   A I believe that he had two. One was certainly Heather Beckel, and the
   other at that time I believe was a woman named Amanda Cromley.
   
   Q Were they still there when you left the White House, or had they
   changed; do you recall?
   
   A George Stephanopoulos changed jobs and offices, and his assistant
   Heather went with him, and Amanda went to work for David Dreier. Mark
   Gearan took over George's office and had two assistants of his own.
   Mine was the same and we switched offices again at a later date.
   
   Q But Mr. Leavy remained your assistant?
   
   A Yes.
   
   Q I want to go back to Friday, May 14th when you first heard this
   information about problems. Were you aware that David Watkins had
   called the First Lady from his daughter's graduation on that same
   Friday, May 14th, at that time?
   
   A I have no recollection of that.
   
   Q Were you aware or did Harry Thomason by any chance mention the fact
   that David Watkins had called him after his conversation with the
   First Lady?
   
   A I have no recollection of that. I seem to recall -- I believe that
   when Harry and Jeff came to me sort of maybe late morning, I think we
   had a fairly early departure for California.
   
   Q And the trip that you took to California, was Mr. Eller on that
   trip?
   
   A Yes, I believe he was, but I don't remember whether he was on the
   entire trip or whether he went out to California in advance to set up
   an event and then joined us as the trip was in progress.
   
   Q I think there was somewhere in one of the notes about that, there
   was a trip during that weekend also to New Mexico. Was that a part of
   the California trip?
   
   A I haven't reviewed the itinerary from that trip. It is entirely
   possible.
   
   Q Do you recall during that trip in California reviewing any memos
   having to do with the White House Travel Office or with Harry
   Thomason?
   
   A No.
   
   Q Do you recall if Bruce Lindsey was on that trip?
   
   A I don't recall specifically. Generally he traveled with the
   President. It would have been more unusual that he would not have been
   there.
   
   Q When they travel, the flight would include -- you would be on the
   same plane as the President and any of the other people who were
   flying --
   
   A Generally I would fly on Air Force One. Occasionally I would fly a
   leg on the press charter depending on what was happening, whether
   there was work that needed to be done on flights.
   
   Q On Monday, May 17th, after this trip, did you receive a memorandum
   which was to Mr. McLarty concerning the firings of the Travel Office?
   
   A I was traveling with the President at that time, and as I said, I
   don't recall receiving any memos or learning anything about what was
   happening with reference to the Travel Office while I was on the road.
   
   Q I am going to show you a copy of the memo and see if you recognize
   having either received this memo, or seen this memo either while you
   were traveling or afterwards. There are two versions of this memo, and
   I will have both marked as Deposition Exhibits Number 4 and 5.
   
   (Myers Deposition Exhibits Nos. 4 and 5 were marked for
   identification.)
   
   Ms. Bracher. For Minority counsel's benefit, the memorandum is the May
   17, 1993 McLarty memorandum, CGE 018686 and the other version is CGE
   001321.
   
   BY MS. BRACHER:
   
   Q Have you ever seen this memorandum? They are basically the same
   except for the CC was crossed out on some copies, and there is some
   handwriting, but the text is basically the same.
   
   Mr. Goldberg. This is the same memo that is as an attachment?
   
   Ms. Bracher. Yes. One is with the CC, and the other has the CC
   scratched out.
   
   The Witness. I don't recall ever seeing this memo.
   
   BY MS. BRACHER:
   
   Q Having not actually seen the memo, were you aware, or did you have
   information, or were you told that Mr. Lindsey spoke with the
   President about this memo on Air Force One during the trip back from
   California?
   
   A I may have learned that subsequently, but I have no recollection of
   knowing that at the time.
   
   Q And thus would it be fair to say that you also wouldn't have
   discussed the memo with the President at that time?
   
   A Correct.
   
   Q On one of the memos, there is a dot, which I believe we have learned
   is a red dot. It was a red dot, and therefore, what effect does it
   have, if any?
   
   A Generally, depending on where it comes from -- and I think the use
   of dots changed, a red dot could mean one of two things: it could mean
   urgent, or it could mean classified. Usually I guess it meant urgent.
   And there was a red dot -- there could be one red dot or more than one
   red dot depending on the urgency of documents. But again, the dot
   system changed, I believe, and I don't recall what it was at this
   time. But generally it meant an urgent document.
   
   Q Were they handled in a different manner from regular memos if they
   had red dots?
   
   A I don't know the answer to that. My understanding at the time was
   that the delivery of the documents would be expedited, but I don't
   know that there were any other special instructions about handling of
   urgent documents.
   
   Q I believe you got back to the White House on Tuesday May 18th. Do
   you recall anything in particular --
   
   A I believe it was about 2:00 a.m. on Wednesday, May 19th, and I
   remember --
   
   Mr. Romatowski. Back at the White House, or back in Washington?
   
   The Witness. Back in Washington. Or we could always arrive back at the
   White House and then go home from there. I remember we arrived home
   very late. I went home, caught a couple of hours sleep and came back
   the following morning.
   
   BY MS. BRACHER:
   
   Q When you arrived back at the White House that evening, did you go
   into the White House, take care of any business that you recall?
   
   A Not that I recall. Generally at that hour I tried not to.
   
   Q On Wednesday, May 19th, can you go through what happened after you
   arrived at the White House that morning?
   
   A I don't recall exactly. I believe I arrived -- generally there was a
   morning meeting, a senior staff meeting, about 8 o'clock, and I came,
   I think, in time for that. And I remember I passed George
   Stephanopoulos in the hall, who was leaving to go, I believe, to
   Columbia University to give a speech.
   
   We spoke briefly, and he left, and at the senior staff meeting or
   after the senior staff meeting, I don't recall, I learned that David
   Watkins was planning to dismiss the Travel Office. I don't remember
   exactly what context it was, whether it was discussed in the meeting,
   whether I was told afterwards.
   
   And at some point that morning David Watkins produced talking points
   that myself and others who would be talking to the press were to use
   in explaining why they had happened and what was subsequently going to
   happen.
   
   I do remember -- again I don't remember exactly what context, but it
   was decided that Jeff Eller would brief certain members of the press
   about it including George Condon, who was the president of the White
   House Correspondents' Association.
   
   At the time I think the consuming issue in the White House was passage
   of the President's budget, and I left fairly early that morning with
   the President to come up to the Hill, where he met with the Democratic
   Caucus and, I believe, the Democratic leadership to try to convince
   Members to vote in favor of the President's budget.
   
   Q The talking points; was there one person generally in charge of
   drafting talking points?
   
   A No. Talking points were generally drafted by people who were
   involved with a particular topic. For example, the National Security
   Council drafts talking points on foreign policy issues. In this case,
   since David was the senior staff person overseeing the Office of
   Administration, things having to do with administration, sometimes his
   office would draft talking points.
   
   Q I have a copy of some talking points dated May 13, 1993. I will mark
   these as Deposition Exhibit Number 6.
   
   (Myers Deposition Exhibit No. 6 was marked for identification.)
   
   BY MS. BRACHER:
   
   Q I show the witness these talking points marked CGE 7933. I will give
   you a moment to look those over and then ask if you recognize those.
   
   A I don't remember exactly this document, but the information in it
   certainly tracks with what I remember at the time.
   
   Q May 13th was the Thursday before the actual firings. Do you recall
   any conversations about a firing happening on that date?
   
   A No. I don't recall anything about that.
   
   Q Do you know who drafted talking points, either those -- do you know
   who drafted those talking points?
   
   A No.
   
   Q Do you know who generally drafted talking points other than David
   Watkins?
   
   A I don't know that David Watkins would draft them so much as oversee
   the drafting of them. I don't know who in his office might have
   actually sat down at the word processor and hammered out the language.
   
   Q Do you know if Jeff Eller drafted White House Travel Office talking
   points around May 19th period?
   
   A It is possible, but I don't know for sure whether he did.
   
   Q Did you instruct anyone to draft talking points on that date that
   you know of?
   
   A On May 13th?
   
   Q On May 19th.
   
   A No, not that I recall.
   
   Q When I interrupted you, you said you had gone to the Hill to
   discuss, I think, matters on the budget. Can you tell me what happened
   after you returned from the Hill?
   
   A I believe that on that day the President had a lunch or an event in
   the residence of the White House, and I believe we came back sometime
   around noontime, maybe a little later, and generally at the top of
   those meetings -- and this may have been -- I don't recall exactly,
   but some kind of an event to highlight all the attributes of passing
   the President's budget. Generally we would begin those kinds of events
   with something we called the pool display which means we would invite
   the press in and take a picture.
   
   I don't remember whether they shouted questions at the President. They
   probably did. But I do remember learning from a couple of the
   reporters that were in the residence that the word was out that the
   Travel Office had been dismissed, and it was clear to me it was going
   to be of some interest to the press.
   
   I went back to my office and received a phone call from Terry Hunt of
   the AP, who asked me had the Travel Office been dismissed. I said yes.
   He asked was the FBI investigating, and based on what I had seen which
   was in these talking points, I answered yes.
   
   Mr. Romatowski. Are these the exact words of the conversation?
   
   The Witness. No. I don't remember the exact words of the conversation.
   
   BY MS. BRACHER:
   
   Q To the best of your recollection.
   
   A I am certain that I talked with Terry Hunt and I am certain that he
   asked me to confirm that the FBI was investigating. I did that.
   Generally I would brief at about one or 1:30, but because of of the
   trip to the Hill I think my briefing was postponed. Sometime between
   the time when I talked to Terry Hunt, they moved the story on the
   wire, and my briefing -- David Watkins came back to me and said -- my
   recollection is incomplete, but I believe he came to see me in my
   office and said that these talking points had been revised, but that I
   had not been informed before I spoke to the press, and so then we
   began to discuss what was appropriate to say about the dismissals and
   about the FBI's role.
   
   Q I want to do go back to the point where you are with the President,
   and as I remember, your best recollection was that there was a comment
   from the press. Had you talked with the President up to that time
   about the White House Travel Office matter?
   
   A Not that I recall. It wasn't the top order of business.
   
   Mr. Romatowski. I would like to clarify. You mentioned in your
   previous answer you referred to these talking points.
   
   The Witness. Right. I don't remember. Whatever the talking points I
   had been given and I don't remember --
   
   Mr. Romatowski. You don't know if it was Exhibit 6?
   
   The Witness. I do not. This is dated May 13th. That was May 19th.
   
   BY MS. BRACHER:
   
   Q So all reference has been to a May 19th talking points that you
   received regardless of whether it had the date?
   
   A Correct. I don't know whether it was this or another version.
   
   Q So after the press comment, do you recall having any conversations
   with the President at that time about the Travel Office firings?
   
   A I don't recall.
   
   Q Did the President act surprised to the question that the Travel
   Office had been fired; do you recall what his reaction was generally
   when the question was posed?
   
   A I don't remember what his reaction was. My recollection -- I don't
   recall. I don't recall him answering the question. I don't recall
   seeing it on the news that night. He may have just chosen not to
   answer the question, and we shuffled the press out. But again, I don't
   recall.
   
   Q At that point had you had any conversations with the First Lady
   concerning the White House Travel Office?
   
   A No.
   
   Q The meetings -- after you went back to your office, do you recall
   any other meetings occurring that day, after you had talked to Mr.
   Hunt?
   
   A The next couple of days were pretty much a nonstop series of
   meetings beginning after my briefing, and I don't recall exactly which
   meetings happened at what time or who was in them. But certainly there
   were meetings that afternoon to discuss what was happening.
   
   RPTS STEWART
   
   DCMN KRISTOFFERSEN
   
   [11:00 A.M.]
   
   BY MS. BRACHER:
   
   Q Specifically, I wanted to ask you about a meeting where KPMG Peat
   Marwick was present. Do you recall the meeting?
   
   A I recall the meeting, but I don't recall exactly when it happened,
   and I don't believe it happened on that Wednesday, but, again, my
   recollection is far from perfect about who was in which meetings and
   what the sequence of those meetings was.
   
   Q During the meeting where KPMG Peat Marwick was present, were you
   aware that the final report was not finished on Wednesday?
   
   A I became aware of that at some point during those days, that they
   were in the process of finalizing the report and had not yet been
   finalized.
   
   Q Do you recall a conversation either with you and Mr. Hermann or Mr.
   Stephanopoulos and Mr. Hermann concerning receipt of the KPMG report?
   
   A Again, I remember at some point discussing it with Larry Hermann --
   was that his name? -- with him and other people from the White House
   staff. I don't remember exactly who was in the room. I don't remember
   exactly what was discussed.
   
   I can say that there was some interest in getting the final version.
   They had, I believe, at that time a draft report, but they were still
   finalizing it, and obviously we were interested in getting that final
   version.
   
   Q At any time were you present during what's been described as a
   shouting match, with Mr. Hermann demanding the report?
   
   A I don't recall a shouting match.
   
   Q Harry Thomason was at some of those meetings; is that correct?
   
   A Yes, Harry was present, but, again, I don't recall at which
   meetings. But I do remember seeing him at the White House in 2 or 3
   days following the May 19th dismissals.
   
   Q When did you first meet Harry Thomason?
   
   A I first met Harry Thomason during the campaign in the fall of 1991.
   
   Q And under what circumstances? Was he also working with the campaign?
   
   A He was an early supporter of President Clinton.
   
   As you know, he's originally from Arkansas. The day I actually went
   down to spend time with then Governor Clinton as sought of an
   interview process, I was working in San Francisco and doing a project.
   
   The President, then governor, was in Los Angeles. I flew into L.A. to
   spend time with him. One of his events was a fund-raiser at Harry
   Thomason's residence. That was the day I first met Harry, early
   October '91.
   
   Q Do you recall the first time that you saw Harry Thomason in the
   White House? Other than social events, obviously.
   
   A No.
   
   Q And what was your knowledge of Harry Thomason in the White House
   during the May 1993 period?
   
   Mr. Romatowski. Her knowledge of him in the White House?
   
   Ms. Bracher. Of his activities in the White House and presence there.
   
   Mr. Romatowski. Of his activities.
   
   The Witness. Harry was obviously a friend of the President. He had
   been a key organizer of certain events; for example, the convention he
   organized; the President's walk into the convention. He played a key
   role in the Inaugural, and I believe he was doing some follow-up work
   on the Inaugural in the early months of the administration.
   
   I don't think I knew much else about or had occasion to think much
   else about what Harry was doing. It didn't really concern me. He was a
   friend, so if I saw him occasionally, I was certainly friendly with
   him, but what he was doing I don't believe intersected very much with
   what I was doing.
   
   BY MS. BRACHER:
   
   Q Did you know what office that he had within the White House
   compound?
   
   A No.
   
   Q Did you know Bobbie Ferguson at all?
   
   A No.
   
   Q Were you aware of any telephone, computer, any other --
   
   A No.
   
   Q -- office materials he might have had while in the White House?
   
   A No. I mean, it came up later.
   
   Q During that time?
   
   A No.
   
   Q Also during that time period, did you meet with Harry through, I
   think, Rahm Emanuel concerning Harry's image-making for the White
   House?
   
   A I don't recall -- not that I recall specifically, but that had been
   part of Harry's role in the campaign, and it wouldn't surprise me if
   there had been conversations about how to use the resources, press,
   and to compliment the Presidency. But I don't remember a specific
   meeting. But that was something Harry had done during the campaign and
   done effectively.
   
   Q Was Harry in any of the senior staff meetings, that you recall,
   prior to the May 19th firing?
   
   A I never recall him at the morning staff meeting. I don't have much
   of a recollection of him in any meetings, but it is possible he may
   have been at one or two, but not at the daily senior staff meetings.
   He was not considered a member of the staff, but he certainly was a
   friend of both the President and Mrs. Clinton.
   
   Q I want to go back to some of the meetings that were occurring on
   Wednesday, May 19th, and Thursday, May 20th. Some of the meetings, the
   notes, and different things that we have indicated that Ricki Seidman
   was in the meeting. Do you recall her being in any of these meetings?
   
   A Ricki was in the same suite of offices as George and me and often
   got involved, particularly -- she was a lawyer, and Ricki had the
   unenviable job of being brought into a crisis where there was a lot of
   detailed information, so I am sure she was around.
   
   But I don't, again, specifically remember what she might have said,
   what meeting she might have been in.
   
   Q That was my follow-up question. I was going to ask you if you had
   any recollection of what role she played or what types of
   contributions she made in these meetings?
   
   A No. Other than generally what she did, I don't have any specific
   recollection.
   
   Q During these meetings, you had said that when you spoke to Mr. Hunt,
   you discussed that the FBI was investigating. Can you just tell me, as
   best you recall, the situation concerning disclosing the FBI
   investigation from the point of talking to Mr. Hunt on?
   
   A He asked me to confirm whether it was, in fact, true, and I
   confirmed it.
   
   Q Had you ever had a situation where you had had a reporter call you
   to request that you confirm an FBI investigation before?
   
   A Not that I recall. I don't believe so.
   
   Q Had there been any general discussions with you or generally with
   staff that you recall concerning FBI investigations and how to handle
   them on a press level?
   
   A No.
   
   Q Who was it at the FBI that you regularly dealt with if you did have
   issues that interacted with the FBI?
   
   A I don't remember ever really dealing with the FBI. Before that, the
   protocol would be to deal with the office, the press secretary, and we
   certainly did subsequent to that, but I don't recall if I ever dealt
   with the FBI or with the spokesman's office prior to that is the kind
   of thing that might have dealt with, but I don't recall.
   
   I don't recall when Louis Freeh was appointed. I think Judge Sessions
   was still in place.
   
   But anyway, that is the kind of thing we would -- the press office
   would normally deal with the FBI office about.
   
   Mr. Romatowski. Vincent Foster's death was the 20th.
   
   BY MS. BRACHER.
   
   Q The only contact you had would have been with the FBI press office?
   
   A That is what would have been likely. I don't remember any other
   contacts with them other than, you know, you have to go through
   background checks, and I may have dealt with things like that.
   
   Q But from a press standpoint, can you just tell us how often you
   would have had contact with the FBI press office coming up to that May
   period?
   
   A I can't recall. I don't remember ever having any contact with them,
   but it is possible we might have on occasion.
   
   Q Do you recall a point during these meetings that occurred on May
   19th and 20th that the New York partners from KPMG Peat Marwick came
   down to join the meetings?
   
   A I do remember a meeting, and, again, it could have been more than
   one. But I do remember meeting with Larry whatever-his-name-was.
   
   Q Hermann.
   
   A Hermann, and maybe one or maybe more than one other people, and I do
   recall that they were people from New York. I don't remember if Larry
   Hermann was out of New York or Washington.
   
   Q Do you remember if any conversations then ensued after the partners
   from New York joined the meeting?
   
   A No. Again, I don't have specific recollection. My general
   recollection was, they went through the process and what they had
   found in the process of their review.
   
   Q Did they go through that process with the press office, with you and
   Mr. Stephanopoulos?
   
   A Again, I don't remember who was there, but throughout the course of
   those days, obviously, we were getting a lot of questions from the
   press, and there was great interest in establishing the sequence of
   events and evidence on which we based the decision to fire the seven
   employees, and so George Stephanopoulos was present, but, again, it
   was sort of in and out of meetings, depending on what else he had to
   do.
   
   Jeff Eller was present at times, and one or both of my deputies I am
   sure was present at times, as well as my assistant, Dave Levy.
   
   Obviously, we were trying to get as much information we could so we
   can accurately report the incidents to the press.
   
   Q Can you just tell me generally what Mr. Eller's participation would
   be in these meetings?
   
   A Helping to established -- again, I don't know exactly what he said.
   Jeff knew more about the sequence of events and had more involvement
   in it up to the point of the firings. So I think he was helping both
   to restrict the sequence of events, fill in the details, and help us
   determine -- establish what we could say to properly explain it.
   
   Q For the FBI investigation, do you recall any information during
   these meetings given to you regarding how to handle that whole issue
   or divulge the FBI investigation?
   
   A It was something, obviously, we were quite concerned about because,
   again, I don't remember exactly when or how, but it became clear to me
   that was not consistent with standard operating procedure, that the
   FBI did not generally confirm or deny that an investigation was
   ongoing.
   
   But since the information was out there and the FBI -- I don't
   remember -- I think the first day they said they didn't confirm or
   deny the investigations were ongoing because I had already confirmed
   it and because it was my understanding -- it became my understanding
   that they had established a predicate that we wanted to be able to say
   something that accurately reflected ongoing events, that accurately
   described what they were doing, but did not contradict what their
   standard operating procedure was, and that was obviously a difficult
   task.
   
   Q Do you remember who told you about the predicate and that that had
   been established?
   
   A It came up in one of these series of meetings. It may have been
   somebody from the Counsel's Office like Bill Kennedy, but I don't
   recall for sure.
   
   Q There was an issue early on with Mr. Kennedy regarding his contact
   with the FBI.
   
   A Early on in the Travel Office?
   
   Q And I was wondering if you recalled if Mr. Kennedy briefed you on
   what happened, or did you get your briefings from the FBI?
   
   A No. There may have been an FBI agent present at some of the
   meetings, but I do remember discussing with Kennedy and with Vince
   Foster how this had happened, and since Bill had been the primary
   contact with the FBI, he went through his series of contacts at one
   point and explained why he had originally called, who he called, what
   their response had been.
   
   Q There became an issue of whether or not Mr. Kennedy had told the FBI
   that it was coming from the highest levels. Do you remember during
   that period discussing that with Mr. Kennedy?
   
   A No.
   
   Q Did Mr. Kennedy at any time describe where this had all come from
   and what had started this with you?
   
   Mr. Romatowski. Well, can we refine that question? That is quite a
   broad question.
   
   Did he ever describe to you where this all came from?
   
   BY MS. BRACHER:
   
   Q Did Mr. Kennedy ever communicate to you where the impetus to make
   the call for the FBI or the subsequent investigation and conversations
   that he had with the FBI came from?
   
   A To the best of my recollection, what was said at times was that
   through Catherine Cornelius and other -- maybe only Catherine; I don't
   remember -- there was evidence that suggested there was some
   irregularities. So Kennedy went to the FBI to seek guidance on how to
   proceed with that, had conversations, and ultimately, eventually, he
   figured out who he should talk to and how to proceed.
   
   Q Other than it coming from a level -- the outside such as Catherine
   Cornelius or what I am going to call a level below Mr. Kennedy, did
   Mr. Kennedy ever have any discussions with you of questions or sense
   of urgency coming from levels above him?
   
   A Not that I recall.
   
   Q Was there any request, that you recall, for KPMG Peat Marwick to do
   a press conference or to help you or Mr. Stephanopoulos with the
   briefings, that you recall?
   
   A I don't remember. I don't think he ever did, but I don't remember
   why that was.
   
   Q Had you met Mr. Hermann or others from KPMG Peat Marwick before May
   19th?
   
   A No.
   
   Q Do you recall anyone -- whether you asked Mr. Hermann or you heard
   anyone ask Mr. Hermann if Peat Marwick had found at least what we said
   you did in the report -- in other words, questioning Mr. Hermann about
   the materials that had been given to the press and whether it was
   accurate, and did the report contain the materials that you were
   telling the press it would contain?
   
   Mr. Romatowski. I lost the antecedent of various of the pronouns in
   that question. Could we at least have it read back or restated?
   
   Ms. Bracher. I can restate it, because it is confusing.
   
   BY MS. BRACHER:
   
   Q Do you recall either you or Mr. Stephanopoulos asking Mr. Herman "at
   least what we said you did," end of quote in the report?
   
   Mr. Goldberg. What are you quoting from?
   
   Ms. Bracher. It is from a Larry Hermann -- actually, it is from an
   interview with someone. I don't even know exactly.
   
   Mr. Goldberg. Have you showed it to the witness to refresh her memory?
   
   Ms. Bracher. No. The witness was not at the interview.
   
   Mr. Goldberg. What are you quoting?
   
   Ms. Bracher. I am quoting a statement from someone to Mr. Hermann. I
   don't know who it is from. I don't know. Mr. Myer said it. I don't
   know if Stephanopoulos said -- I don't know if it was said. All I am
   asking Ms. Myers is if that was what was contained in the report.
   
   A That sounds like a legitimate concern, but I don't recall that
   statement ever being made.
   
   BY MS. BRACHER:
   
   Q Do you recall if Harry Thomason was giving background to the press
   during this period of May 19th and May 20th?
   
   A I don't. I think Jeff was doing most of the background.
   
   Q You said you recalled Harry at some of the meetings. Do you recall
   him doing any interviews in particular that was requested by you or
   Mr. Stephanopoulos?
   
   A No -- oh, he -- I don't recall. I don't believe I asked him to talk
   with Markus about the Darnell Martens memo, but I may have. I don't
   recall. I do, of course, recall Darnell talking with Markus about
   that, if that was specific to the memo.
   
   Q Which I think came public a little bit later?
   
   A Yeah, Friday.
   
   Q There was a notation which was made by one of the people during the
   White House Management Review, and it wasn't attributed to you, but it
   was just sort of a notation that said that the facts didn't match what
   Eller told the media on background.
   
   Do you have any knowledge of that? Do you recall any instances where
   the facts didn't match what Eller was telling the media on background?
   
   A Nothing specific I could speculate, but I will not do that.
   
   Q No; just if you have any recollection of that specifically
   occurring.
   
   On Thursday, May 20th, there was a meeting that occurred where Mr.
   Collingwood from the FBI came over. Can you just tell me, did you have
   any contact with the FBI or with Mr. Collingwood coming over prior to
   coming over to the White House?
   
   A Again, I don't remember the exact sequence of events, but we were
   trying to find out what the FBI was saying and what we could and
   should say in order to be accurate and clear.
   
   I am almost certain that I talked to him on the phone at some point;
   then as we were going to these series of meetings, decided it would be
   best if he were actually there as we were discussing the sequence of
   events and exactly what the status of the investigation was. And it
   was my assistant to David Levy who actually made the call and
   suggested to John he come over, and he did.
   
   Q The discussion that it would be best for Mr. Collingwood to be
   there, do you recall how that decision was being made?
   
   A We were having an ongoing conversation about what did the FBI
   usually do and how do they handle these inquiries since he was the
   person that usually handled them, and it kept cropping up during the
   course of the conversation.
   
   I was trying to establish the facts to accurately describe the
   circumstances, so it seemed it would be easiest and best and most
   accurate if he would actually come and be there for that meeting, and
   he did.
   
   Q Do you recall if any White House Counsel individuals were in those
   meetings when you were discussing?
   
   A They were, and I don't remember.
   
   Again, it is kind of one long play with changing cast of characters.
   But yes, they were there and sort of over the course of these couple
   days helping us to establish the facts.
   
   Q Do you remember Bernie Nussbaum attending any of these meetings?
   
   A Uh-huh.
   
   Q Do you recall what his participation was?
   
   A No. Again, in the context of trying to unravel the events and to
   establish the sequence of events that led up to this and to establish
   what we could say, because there was a great deal of press interest in
   it, I don't recall Bernie being there at every meeting. He wasn't one
   of the constant presences, but I do remember talking to him about
   seeing him in the meetings, I should say.
   
   Q Do you know if he was asked to make any phone calls over to
   Department of Justice regarding the press position on what could be
   said?
   
   A I don't recall that.
   
   Q So it would be fair to say you didn't personally request he make a
   phone call to the Department of Justice?
   
   A I don't recall doing so.
   
   Q On this same period during these meetings, did you have any
   conversations with Harry Thomason about his financial interest in the
   Travel Office?
   
   A In the aftermath, when the reporters from the Washington Post were
   bringing me the memo from Darnell Martens, I asked Harry what his role
   in the company TRM was, but I don't -- we didn't go into any details
   about how much money he had invested in it, although I remember his
   answer was essentially, he was an investor in the business and not
   active, didn't run the business, just simply owned part of it.
   
   Q Do you recall if he made any representations about whether he had
   financial interest in activities in the Travel Office?
   
   A He certainly presented his position was that he wasn't doing this to
   make money. Given that he had two companies in syndication, I believed
   him.
   
   Q And, in your opinion, do you believe that that was a true statement
   today?
   
   A Yes. Given what he does for a living and what his income is, I don't
   think he was looking to enrich himself. He had already done that.
   
   Mr. Romatowski. By other means.
   
   The Witness. By other means. Thank you.
   
   BY MS. BRACHER:
   
   Q I want to discuss for a little about the February 15th Catherine
   Cornelius memo, which I will just refer to as the Cornelius memo.
   
   A And which one is that?
   
   Q We will get a copy.
   
   A Is this one from Catherine or Catherine and Clarissa?
   
   Q This is the February 15th memo with Catherine -- that Catherine and
   Clarissa had written. Why don't I skip it. If it's an attachment in
   here, I can give you a copy.
   
   I am showing the February 15th Catherine Cornelius memo which says it
   is by Catherine Cornelius and Clarissa Cerda, C-E-R-D-A?
   
   A Do you have a cover page on it? Here it is, yeah.
   
   Q Do you recall when you first saw that memo?
   
   A I sure do. It was on Thursday night when it was brought -- Thursday,
   the 20th, when it was brought to the attention of either myself or
   George, who then -- anyway, by two reporters.
   
   Q And can you tell me, what did you do in reaction to seeing -- after
   you heard about the memo?
   
   A We asked -- I don't remember why. I think it must have been late. It
   must have been fairly late at night. We asked them not to run the
   story overnight to give us a chance to find out as much about it as we
   do and respond, and they held the story.
   
   I believe we had -- it may have been as late as 10 o'clock at night or
   something. But we had a meeting early the next morning where we tried
   to establish when this memo had been written and what the facts
   surrounding it were.
   
   Q Do you remember who was at the meeting about the memo?
   
   A I don't believe -- I don't. I would have to just guess, but --
   
   Q Do you know if David Watkins was in that meeting?
   
   A Again, I can't imagine he wasn't, but I don't remember. But I do
   remember that both CNN and Reuters reported that story that morning,
   maybe 10 o'clock that morning.
   
   Q Did you ever become aware of an issue whether or not David had read
   the memorandum, this February 15th Catherine Cornelius memorandum?
   
   A Now that you say that, I actually remember at the time he said he
   put it in his files and never read it.
   
   Q Do you recall any responses that came from Catherine Cornelius or
   Clarissa Cerda regarding his statement about putting it in his files
   and never reading it?
   
   A No.
   
   Q Did either of them ever come to you at this time or at a later time
   to describe whether or not he had read that memorandum?
   
   A Not that I recall.
   
   Q The FBI press responses from the beginning or after the firings, did
   you see any FBI press responses initially as the announcement was
   going out from the White House after the May 19th firings?
   
   A Did we see it? We talked to Collingwood, and he -- Collingwood
   meeting was on the Friday. So I think we saw a response from them on
   Thursday. Then after the meeting, I believe the FBI drafted something
   else, which was then faxed over to us.
   
   Q The first responses that you were getting on Thursdays, did you make
   any changes or suggest any language to those responses?
   
   A Not that I recall. We discussed, you know, sort of what was being
   said, what we could say, what questions we were getting. Then they
   faxed us a response based on how they normally craft such press
   responses, I guess.
   
   Q Do you recall if, on that Thursday, were you having a lot of
   conversations with Mr. Collingwood regarding these press conferences,
   or was George the person who was dealing with those?
   
   A No. I am sure I talked to him, and given the number of conversations
   that were going on, I don't remember whether I talked to him more than
   once. I just don't recall.
   
   Q And had you met Mr. Collingwood face to face before then?
   
   A Not that I recall. I don't believe so.
   
   Q So do you recall any White House meetings he might have been at
   prior to that date?
   
   A No, I don't.
   
   Q On the Friday, the 21st, in the FBI meeting that you had, do you
   know, did Mr. Nussbaum or Mr. Foster or Mr. Kennedy provide any
   counsel, advice, that you recall, or any guidance concerning --
   
   A Specifically, pursuant -- with reference to the press release? Not
   that I recall.
   
   Q Or with reference to their presence or any of the other issues that
   were going on during that meeting with Mr. Collingwood?
   
   A They certainly -- I am not sure I quite understand your question.
   
   Q I am just asking if you recall any advice or any suggestions that
   may have come from the White House Counsel's Office, and I included
   the three members, whereas if you don't remember specifically which
   one --
   
   A They were there sort of participating in the conversations,
   providing information, helping us piece together the facts. But I
   don't remember specifically what they may have said other than
   participating in the ongoing conversations.
   
   Mr. Romatowski. You say they were there. We are talking now about the
   Collingwood meeting?
   
   The Witness. I am sorry. Thank you for pointing that out.
   
   I don't remember specifically who was at any of these meetings, and I
   don't remember whether or who from the Counsel's Office was in the
   particular meeting where Collingwood was there. I don't remember how
   long Collingwood was there. He wasn't there all day. He was there for
   a portion of a meeting, as best I can recall. Then he left.
   
   So I don't remember -- but certainly members the Counsel's Office had
   been around, and, again, I don't remember exactly who was in what
   meeting.
   
   BY MS. BRACHER:
   
   Q You have no specific recollection whether or not the White House
   Counsel was in the Collingwood meeting?
   
   A Not specifically or who might have been there. I don't remember.
   
   Q During the Collingwood meeting, do you recall whether he brought any
   drafts of his press response with him?
   
   A No, I don't recall.
   
   Q Did you ever at any time revise any of the drafts written in a
   written manner -- either you might receive a fax or might have faxed
   back to Mr. Collingwood?
   
   A I don't remember exactly specifically. We had copies of statements
   that they had put out, I think, maybe Wednesday and Thursdays.
   
   I don't remember if he came with a draft of anything. I do remember
   discussing, again, what it was that we could say or how they would
   normally respond to these kinds of situations, and it was sort of a
   unique situation or something that at least hadn't come up while we
   were there in the Clinton administration.
   
   But I don't remember whether he had a document with him, some language
   that he was proposing.
   
   Q Do you recall discussing with Mr. Collingwood or being present
   during discussions with Mr. Collingwood concerning whether the FBI
   would state that they had predication in their responses?
   
   A That was the crux of the discussion.
   
   We were trying to determine how we could describe what was going on,
   particularly in light of the fact that I had said to Terry Hunt of the
   AP that the FBI was involved and had certainly led the press to
   believe that the FBI -- it was unclear to me on the first day exactly
   what the FBI was doing as we tried to figure that out and came to
   understand what I think was, they had established a predicate, but
   they hadn't begun investigating.
   
   We were trying to figure out what we could say about that and describe
   it in a way that was both accurate and consistent and consistent with
   FBI policy. This is not only what we had said, but this is what the
   FBI usually did that was the crux of the whole discussion. Could you
   say they had established predication? Did they normally say that what
   language could we or should we use? How can we satisfy the press's
   questions about it?
   
   Q Can you just describe in your own words why it was important that
   there be a predicate stated for an investigation by the FBI, why it
   was important to you?
   
   Mr. Romatowski. Why it was important that the FBI had a predicate for
   the investigation.
   
   BY MS. BRACHER:
   
   Q Why it be stated that the FBI had a predicate for the investigation?
   
   A The point was what we could say about it? I didn't care if the word
   was predicate or whatever. I wanted to know what we could say about it
   that would accurately describe what was going on given that we already
   confronted the FBI was involved, they were involved, that they had
   established a predicate. What would we say about this so we could
   answer questions we were getting? I didn't care how it was described,
   and I didn't care whether or not they had found what they found.
   
   The facts were, they had established a predicate; the facts were, they
   were going to begin at some point a -- I don't know when -- an
   investigation. The facts were, the press was very interested in this.
   
   My only interest was in reconciling these things in a way that was
   both accurate and consistent with what the FBI was able to say.
   
   Q Other than the pressure you were receiving, obviously, from the
   press to get answers, was there any pressure, that you were aware of,
   to justify the firings through the FBI investigation?
   
   A No, because, to the best of my knowledge, and I think based on what
   we knew at the time, the evidence was there, the FBI had established a
   predicate, and so our question was more, gosh, I shouldn't have
   disclosed that, but I did. And so the cow is out, the cat was out the
   bag, the press knew the FBI was involved. What do we do, given those
   facts?
   
   But as far as I knew, the FBI had established a predicate based on
   audit and documents they had seen and testimony or accounts they had
   gotten from people at the White House about what was going on. They
   were concerned or interested or whatever they were.
   
   Q You just called based on the audit. I just wanted to ask you a
   question or two. At that time, did you believe that the KPMG Peat
   Marwick people had performed an audit on the Travel Office?
   
   A I use the word "audit" loosely. I am not an accountant. They had
   done something.
   
   Ms. Bracher. I am sorry, I have gone overtime.
   
   Mr. Goldberg. You are right on time. I appreciate that.
   
   BY MR. GOLDBERG:
   
   Q Had you, as the press secretary, had any experience prior to the
   Travel Office matter, answering questions from the press on criminal
   investigations?
   
   A No.
   
   Q To your knowledge, had anybody in the Clinton communications or
   press office had any experience?
   
   A I don't believe so.
   
   Q Did you ever sort of feel like you were flying blind at any point,
   or was this all a new experience for you?
   
   A Yeah.
   
   Q You really didn't have any idea how to respond to the press; you
   didn't really have any idea what the FBI's policies would have been on
   disclosure?
   
   A That's correct.
   
   Q So calling Collingwood from FBI seemed like a natural thing, to get
   some advice?
   
   A It is consistent with how we dealt with other agencies when issues
   in their jurisdiction became press issues at the White House, we were
   calling the spokesman's office, or communications office, whatever the
   appropriate office was, and talked with them. We did the same thing in
   this case to find out what they were saying.
   
   Q On May 19th, 20th or 21st or thereafter, did you attend any meetings
   with Peat Marwick or Larry Hermann?
   
   A Yes.
   
   Q Do you recall how either Mr. Hermann or anyone else from Peat
   Marwick characterized the findings that they had about the Travel
   Office at that time?
   
   A Certainly my impression, based on those meetings, was that they
   found irregularities. There was -- there were things going on in the
   Travel Office that were irregular, and I don't know if it was a
   concern to Peat Marwick, but they certainly raised some red flags
   about how cash was handled, about how records were kept, and it was
   definitely my impression from coming out of those meetings that the
   practices that were employed would not cut the mustard.
   
   Q In your conversations with the press briefings or in response to the
   press questions, did you accurately reflect your understanding of Peat
   Marwick's results or findings?
   
   A Yes.
   
   Q Did you embellish those finding in any way in your statements to the
   press?
   
   A No. I would only report on what I had been -- the information I had
   been able to obtain from the people who were closer to this issue than
   I was.
   
   Q So to your knowledge, you were just a conduit, in a sense, for what
   Peat Marwick had found to the press, at least regarding their
   findings?
   
   A Right.
   
   Q Prior to May 19th -- or let me back that up. Prior to the Friday
   before -- I guess that would have been the 14th, May 14th -- had you
   heard any rumors of any unusual or irregular practices by the Travel
   Office?
   
   A Not that I recall.
   
   Mr. Goldberg. That is all I have right now.
   
   BY MS. BRACHER:
   
   Q I want to do just a follow-up with what Peat Marwick had told you
   about the financial irregularities. Did they ever say there was gross
   mismanagement to you?
   
   A I don't remember whether they used those words. Those were words
   that I used in my initial briefing on the 19th based on what I had
   been told, not by Peat Marwick, because I hadn't met with them, but by
   other people at the White House.
   
   Q Do you know who that group of people would have been that would have
   briefed you initially?
   
   A The principal person was Watkins.
   
   Q David Watkins. And do you recall if Peat Marwick ever said there was
   abysmal mismanagement?
   
   A I don't remember that word being used. That was certainly my
   impression.
   
   Q At that point, who would that impression have been made to you by?
   
   A From Peat Marwick people.
   
   Again, I don't remember who was there other than Larry Hermann, and I
   don't be remember specifically if those words were used. That was my
   impression, that that meeting, from the series of meetings and
   including the ones where -- well, no; whatever meeting it was where
   Peat Marwick was present.
   
   Mr. Romatowski. We are being a little casual here in these questions
   about at that point and at that time and so on.
   
   At the same time, we are getting detailed questions about day by day
   and even meeting by meeting within a particular day.
   
   I would just like to make it clear that these answers of yours depend
   on a state of knowledge at a particular time, and what you are
   speaking of most recently in response to this question about a
   business malmanagement or mismanagement or what-have-you, I gather,
   follows from an impression you took away from what you heard from Peat
   Marwick, whatever it was you heard in sequence from Peat Marwick;
   right?
   
   The Witness. Right.
   
   BY MS. BRACHER:
   
   Q Is there any particular reason that you believed it was necessary to
   confirm that the FBI had a basis to conduct a criminal investigation
   rather than just a general investigation at that time?
   
   A I didn't know there was a difference. I still don't know if there
   is, if the FBI does noncriminal investigations.
   
   Q After the meeting which Mr. Collingwood attended at the White House,
   do you recall receiving FBI responses after that meeting ended?
   
   A I am sorry?
   
   Q Do you recall receiving functional FBI official responses -- press
   responses?
   
   A Yes, I believe they faxed over a statement.
   
   Q Did you do anything with that statement as far as the wording of it
   or the editing of that statement?
   
   A It was on FBI letterhead, I believe, and I think we handed that to
   the press.
   
   Q Do you recall when you first saw the final KPMG Peat Marwick report?
   
   A No.
   
   Q I think it was delivered to the White House on that Friday, the
   21st, and it was released to the press during the 4 o'clock briefing.
   
   Do you recall any discussions about the release of the KPMG Peat
   Markwick report?
   
   A Not specifically.
   
   Q Do you recall any general discussions concerning whether it should
   be released at that time or should be shared with FBI investigators?
   
   A I don't remember discussing that.
   
   Q Do you remember any other general discussions about the release of
   that report publicly?
   
   A Not specifically. I think I do remember that I had been saying to
   the press that we would try to get a summary of it, and that is what
   we did.
   
   Q When Peat Marwick delivered the report to the White House on Friday,
   do you recall anything arising from that meeting with them when they
   gave that report over?
   
   A No.
   
   Q Do you recall any conversations with Mr. Hermann, either with you or
   others, where he would have said that he didn't believe there was a
   reason to call in the FBI?
   
   A No.
   
   Mr. Romatowski. Well, you know, can I ask about the form of these
   questions? You ask them in a subjunctive form that leaves open
   implications and call for speculations when you ask about where
   somebody would have said something or another.
   
   I take it by your questions you mean to ask, did he say such and such.
   
   Ms. Bracher. I am asking Ms. Myers if she recalls. It is not a
   subjunctive question.
   
   Mr. Romatowski. You asked if he would say. Let's limit ourselves to
   what people did say.
   
   Ms. Bracher. I will rephrase my question.
   
   BY MS. BRACHER:
   
   Q Do you recall any conversations by Mr. Hermann, either with you or
   with others, that Mr. Hermann stated he did not believe there was a
   reason to call in the FBI?
   
   A No.
   
   Q Do you recall whether you or anyone else asked Mr. Hermann if he had
   contributed to the campaign during these meetings?
   
   A No, I don't recall that.
   
   Q Was Mr. Hermann's campaign activity an issue that you recall arising
   during these meetings?
   
   A No.
   
   Q On May 21st, Mr. Stephanopoulos stated during the 4 o'clock press
   conference that American Express would be coming into the White House.
   I believe that is his words.
   
   Do you recall where that information came from?
   
   A That was what we were told by, I guess, David Watkins, about how the
   Travel Office would be organized in the wake of the fact there was
   nobody left working there.
   
   Q Do you recall when Mr. Watkins related that information?
   
   A No. Sometime over the course of those dates, but I don't remember
   exactly when.
   
   Q Did Patsy Thomasson discuss her meeting with American Express that
   had occurred on the Friday before, which would have been May 21st?
   
   Mr. Romatowski. Did they discuss it with whom?
   
   BY MS. BRACHER:
   
   Q Did she discuss her meeting with American Express on Friday, May
   21st?
   
   A With me, not that I recall. Patsy was occasionally in those
   meetings, so it may have come up, but I don't recall.
   
   Q Had you worked with American Express before?
   
   A They handled a lot of the campaign travel, but I didn't travel -- I
   mean I didn't really have much reason to interact with them. I was on
   the charter all the time, but I was -- it was handled by other people.
   
   Q On Nightline, which I believe went on that Friday night, May 21st,
   there was a clip of President Clinton shown which discussed, "Let us
   reform our politics so that power and privilege no longer shout down
   the voice of the people; let us put aside personal advantage so we can
   feel the pain and see the promise of America."
   
   Do you think that the actions taken to fire the Travel Office
   employees is consistent with that statement?
   
   A Oh, come on.
   
   Mr. Romatowski. That is argumentative. If you have got factual
   questions. But we are not going to get there by asking the witness to
   adopt argumentative questions.
   
   BY MS. BRACHER:
   
   Q At least lay a foundation. Do you believe that power and privilege
   entered into the decision to fire the Travel Office employees?
   
   Mr. Romatowski. That is argumentative. Let's get to the facts.
   
   Ms. Bracher. Are you asking your witness not to answer her basis of
   knowledge about her basis of firing the Travel Office employees?
   
   Mr. Romatowski. I am asking for factual questions rather than trying
   to get in a debate with the witness over political questions. There is
   no point in this question except to grandstand and make arguments.
   
   It is not calling for a factual response. "When did you stop beating
   your wife?" is not a question that is going to advance the cause.
   Let's move on to factual questions.
   
   Ms. Bracher. I am asking, Ms. Myers, your opinion, and certainly you
   can object.
   
   Mr. Romatowski. She is not here to give her opinion. She'll be
   testifying on facts, on her recollection of facts, but she is not here
   to give her opinions.
   
   Ms. Bracher. So noted for the record.
   
   BY MS. BRACHER:
   
   Q Do you know about the decision to bring in Penny Sample of Air
   Advantage?
   
   A I remember -- my recollection of this was fuzzy. I remember Penny
   Sample. I believe she was one the people that helped us during the
   campaign, and I believe -- I remember her name being discussed at that
   time, around k-- after the dismissals, but I don't remember
   specifically that he was going to do.
   
   Q Had you worked with Penny Sample before and helped her previously?
   
   A I had probably met her. I didn't work with her directly, but I
   believe she was involved in the campaign.
   
   Q On Saturday, May 22nd, there was an article that was printed in the
   paper by William Safire, and, in fact --
   
   A Monday -- Saturday?
   
   Q I think it came out Saturday and in Monday's discussions.
   
   There was a notation by Andrei Oliver of the White House Management
   Review that the Safire story caused media interest in the First Lady.
   
   My question is, did you ever meet with her or her staff regarding the
   Safire article or any of the Travel Office articles during the
   aftermath of the firing?
   
   A Did I ever meet with Mrs. Clinton? I don't believe so. I don't
   believe so.
   
   Q Did you recall discussions with her staff regarding either the
   Safire article or the articles immediately following the firings?
   
   A I don't recall the Safire article from Saturday.
   
   Mr. Goldberg. I believe the indication was Monday at that time, Monday
   and Friday.
   
   Ms. Bracher. May be the Saturday was -- it could have been on the
   wire. May be a precopy of it. I am not sure. Let's say Monday, or
   let's say Monday since we know the wasn't paper printed there.
   
   Do you recall meeting with Mrs. Clinton's staff regarding this
   article?
   
   A I don't recall meeting with them specifically about that. I talked
   to them routinely, but I don't remember any specific conversations
   about the Safire -- that particular Safire article.
   
   Q Did you ever discuss the Safire article with the President?
   
   A I don't recall any specific conversations.
   
   Q Do you recall any conversations with the President concerning the
   press aftermath during this week following the firing?
   
   A I am sure I discussed it with him, but I don't remember the specific
   contents of any of those conversations. It is the kind of thing, since
   you would be getting questions, that I would certainly talk to him
   about, but I don't remember specifically any conversation.
   
   Q Do you remember if there were any talking points prepared for either
   the President or First Lady by you or your assistant?
   
   A Not that I recall.
   
   Q There was an interview that you had on September 23rd, 1993. I think
   you were interviewed by the FBI with an OPR interview --
   
   Mr. Romatowski. By the way, do you have notes of that interview?
   
   Ms. Bracher. Is this an objection?
   
   Mr. Romatowski. It is a question. It is within the --
   
   Ms. Bracher. It is not relevant to the questions I am asking. I just
   asked that your comments, if you have an objection or would like some
   materials for a question I have asked. There isn't even a question
   that has been posed to this witness.
   
   Mr. Romatowski. I just want to remind you that these sorts of
   materials, notes of interviews, of this sort are within the request I
   have made to you both today and previously.
   
   Ms. Bracher. I have not gone into the substance of that interview.
   
   Mr. Romatowski. I know you haven't. I am just pointing out once again
   that these are materials that I had requested and been denied. But go
   ahead and ask your question.
   
   Mr. Goldberg. Let me point out that the interview was September 8th,
   1993. Perhaps you are talking about a different interview?
   
   BY MS. BRACHER:
   
   Q You are right. I am sorry, it is a mistake. The date of
   transcription is on the 24th. It should be the 8th.
   
   No, I am sorry. September 8th, 1993, interview with OPR, FBI: Did you
   request that White House Counsel be present during your interview that
   you had with the OPR on this day?
   
   Mr. Romatowski. You know, I guess we may need instructions with how to
   deal with a question like that, because I am not sure her
   conversations with White House Counsel are in balance here.
   
   Can anybody help me with that? How has that been treated ? It's a
   lawyer's reflex, of course, in conversations between an employee of an
   organization and that organization's counsel routinely are privileged.
   
   Ms. Bracher. Under what basis?
   
   Mr. Romatowski. The attorney-client privilege.
   
   Ms. Bracher. Within the Government, if she had conversations with
   White House Counsel.
   
   Mr. Romatowski. Sure.
   
   Ms. Bracher. I think you need to call the White House and assert the
   privilege, the executive privilege, and we will take a break while you
   contact the White House.
   
   Mr. Romatowski. Let me make clear, if we are going to do this as to
   other questions in the area, you can help us expeditiously --
   
   Ms. Bracher. Any conversations she had with White House Counsel
   regarding her interviews. It would probably be a broad enough area.
   
   Mr. Goldberg. Would that include this interview?
   
   Ms. Bracher. It would include their presence at the OPR interview,
   their presence at her GAO interview, and the preparation for those
   interviews by White House Counsel as well as the presence by White
   House Counsel.
   
   Mr. Goldberg. Is that the limit you think you are going into?
   
   Ms. Bracher. I think that is broad enough.
   
   Mr. Goldberg. Let me just state, you may want to check with the White
   House. My understanding, is for those type of questions, you cannot
   assert attorney-client privilege.
   
   Mr. Romatowski. Okay. Let me explain that an individual witness in
   this position, who is alerted to the possibility that they are a
   stakeholder of information arguably privileged on behalf of somebody
   else who whom they have a duty, has an obligation to see to it that
   they are not inadvertently revealing privileged information that they
   are bound to keep confidential.
   
   It is not a personal privilege of Ms. Myers that we are concerned
   about here, but I recognize in this line of questioning a potential
   obligation of hers, and I am sure, with Mr. Goldberg's help -- that
   must be right, but I have to take my instructions -- she has to take
   her instruction from White House Counsel.
   
   Mr. Goldberg. I certainly do not speak for the White House.
   
   Ms. Bracher. And I do not speak for the White House. Mr. Goldberg has
   information, and that is fine. I am reluctant to claim anything in the
   name of White House regarding privilege if the White House wants to
   assert privilege. I prefer you speak to them and allow them to sort
   through it.
   
   Mr. Romatowski. We will calm them and see how quickly we will get
   guidance.
   
   (Discussion held off the record.)
   
   RPTS STEIN
   
   DCMN QUINTERO
   
   [12:00 p.m.]
   
   Ms. Bracher. Back on the record.
   
   Mr. Romatowski. Let me say that I have consulted with White House
   Counsel, and you are free to answer questions regarding conversations
   with White House Counsel in preparation and in the aftermath of these
   interviews that we are talking about.
   
   BY MS. BRACHER:
   
   Q I think I can repose the question.
   
   Did you request White House Counsel be present during your interview
   with OPR on September 8, 1993?
   
   A I discussed with White House Counsel whether or not they would
   accompany me, and said that I would be more comfortable if they did.
   
   Q I believe both Neil Eggleston and Cliff Sloan were there. Did you
   request that they both be present?
   
   A No. I definitely remember speaking with Neil about it, and I guess
   Cliff was there, too, but Neil was the person I primarily recall
   dealing with, and he was there.
   
   Q What did you do in preparation for that interview with Mr.
   Eggleston?
   
   A He told me what it would be like, who would be in. He gave me
   advice. Having never been deposed or questioned, I don't remember if I
   was under oath, but having never been through that, he told me not to
   speculate. If I didn't remember, say I didn't remember. He sort of
   gave me the lay of the land, who would be there, how I should respond.
   
   Q Other than sort of conversations to form, did you have any
   conversations with anyone in the White House concerning the substance
   of those interviews?
   
   A We were specifically told not to, and I did not.
   
   Q Who were you told not to by?
   
   A I don't remember. I think -- I think that there may have been a memo
   or something that went to staff or to people who were involved, saying
   that -- or else we were just told by somebody in the Counsel's Office
   not to discuss this with each other.
   
   Q The DOJ OPR interview occurred at the White House in Mr. Sloan's
   office. Did you make any request that it be done there?
   
   A No. That is where they were I think doing a number of interviews out
   of the Counsel's Office.
   
   Mr. Romatowski. Well, OEOB.
   
   The Witness. Counsel's Office in the OEOB.
   
   Mr. Romatowski. If it were in Mr. Sloan's office, that would have been
   in the OEOB rather than in the White House?
   
   The Witness. Correct. But there is a whole suite there that is
   counsel, as opposed to the Counsel's Office; you are right.
   
   BY MS. BRACHER:
   
   Q Did you know in what capacity Mr. Eggleston and Mr. Sloan were
   present at your interview, who they were representing?
   
   A No.
   
   Q Did you believe they were representing your personal interests
   during that interview?
   
   A I never considered the question.
   
   Q After the interview occurred were you debriefed or interviewed by
   anyone in the White House?
   
   A No.
   
   Q Concerning the substance of the information that you had given?
   
   A No.
   
   Q Similarly, when you were interviewed by the General Accounting
   Office, I believe that was on September 16, 1993, did you request that
   White House Counsel be present during that interview?
   
   A What was the one we just discussed?
   
   Q That was the FBI OPR interview. The next interview I think you had
   people from the GAO interview you. My question is, did you request
   that there be any White House Counsel present for that interview? I
   think Neil Eggleston also sat in.
   
   A I cannot distinguish between those two interviews in my mind, and so
   -- and I have only -- I can remember being in Counsel's Office and
   answering questions but I can almost not remember that they were two
   separate occasions. I just remember talking to Neil about being with
   me at these interviews, and he was.
   
   Q Similarly, any conversations that you had prior to the OPR
   interview, would that apply to the GAO interview as well?
   
   A Yes. My recollection is indistinguishable. I remember talking to
   Neil about here is how the thing is going to proceed and him being
   there at one or both. But in neither case or either case, or any case,
   I should say, did we discuss afterwards -- he was there, so we didn't
   have to discuss afterwards what I had said.
   
   Q Or any discussions with anyone outside of the interview?
   
   A No.
   
   Q Did you have any conversations with Jeff Eller about the reprimand,
   that you recall?
   
   A I don't recall any specific conversations. I felt bad for him and I
   am sure I told him that. He is a friend of mine. But I don't remember
   a specific conversation about its.
   
   Q Here is a FBI press response, which is dated May 21st, and I am
   showing you a copy. It is marked CGE 7902. There is handwriting on
   that. Do you recognize that handwriting?
   
   A It could be -- I am not 100 percent --
   
   Mr. Romatowski. It could be anything, but do you recognize it?
   
   The Witness. Not with certainty. No.
   
   BY MS. BRACHER:
   
   Q Is that your handwriting?
   
   A No.
   
   Q I have a memo which I am going to put in the record as Deposition
   Exhibit No. 7.
   
   (Myers Deposition Exhibit No. 7 was
   
   marked for identification.)
   
   Mr. Romatowski. You don't want to mark this last one?
   
   Ms. Bracher. No. She doesn't recognize the handwriting.
   
   This memo has a date of January 29, 1993. It says, "to Harry Thomason
   from Darnell," and is entitled, " TRM Action Items." I will show the
   witness that document.
   
   BY MS. BRACHER:
   
   Q Look it over and tell me if you recognize it.
   
   A No. It is a little hard to read, but I don't recognize it.
   
   Q I know it is not a good copy.
   
   With that, this will be Deposition Exhibit No. 8.
   
   (Myers Deposition Exhibit No. 8 was
   
   marked for identification.)
   
   BY MS. BRACHER:
   
   Q I have a document that I will show you, which is another memorandum
   from Darnell Martens to Harry Thomason, and the date on that is
   February 11, 1993. Specifically, I would like to draw your attention
   to the first paragraph.
   
   Mr. Darnell Martens writes: On January 29, "I sent you and Dee Dee
   Myers a memo in which I stated that, based on the administration's
   directive to consider cutbacks wherever feasible, TRM should solicit a
   consulting project from the White House." The memo then goes on.
   
   Do you know if a memo was ever sent to you by Darnell during that time
   period, that you recall?
   
   A I have no recollection of receiving a memo from him.
   
   Q Did there come a time where you were given this January 29th memo,
   which is marked as Deposition Exhibit No. 7?
   
   A No. I don't recall ever seeing this.
   
   Q So to the best of your knowledge, you believe this is the first time
   you have reviewed that memo?
   
   A Yes.
   
   Q We were discussing earlier what had been characterized as the
   Martens' memorandum.
   
   And I am going to give you a document. I will mark it as Exhibit No.
   9.
   
   (Myers Deposition Exhibit No. 9 was
   
   marked for identification.)
   
   BY MS. BRACHER:
   
   Q I ask you to look at this memorandum and tell me if you recognize
   it?
   
   This is the White House Press Charter's confidential memorandum that
   has been referred to as the Martens' memorandum, also.
   
   A This is the memo I received from Ann Devereau and Ruth Marcus of the
   Washington Post.
   
   Q You have any discussions with anyone in the White House regarding
   this memo after you received it from the press, that you recall?
   
   A Sure.
   
   Q Can you tell us generally what those discussions were?
   
   A Will, since it was a press -- the memo came to me from reporters.
   The discussions were, how do we handle the response and how can we
   explain this?
   
   Q Were there certain individuals -- did you talk to Harry Thomason
   about the memo?
   
   A Yes. I called Harry, and I don't remember where I called him. I
   might have had his beeper number, but I called Harry. He happened to
   be in Washington, and he -- and Darnell Martens also happened to be in
   Washington, and they came to my office to discuss this with me.
   
   Q Do you recall that they told you about this memo?
   
   A Generally they -- I remember trying to ascertain what it was TRM
   did, but I don't really remember what the answer was. And they sort of
   walked me through why they had written this memo, what they were
   trying to accomplish. Again my recollection of exactly what the
   answers were is kind of fuzzy.
   
   Q Do you recall generally what they said to you about the purpose of
   drafting this memo?
   
   A That they -- I believe that it was that they thought the Press
   charter business, the White House Press Charter business could be
   handled more efficiently and they had some ideas for how that could be
   done. We talked about what it was their company did. Again, I can't
   remember exactly what that was.
   
   Q The first paragraph of the memo which is under a subheading called
   "The Proposal" says: "Dee Dee Myers stated to both Harry Thomason
   personally and Darnell Martens by phone that the White House was not
   tied to any particular charter operator and that based on that
   assumption, she saw no reason why Thomason, Richland and Martens,
   Incorporated, should not be able to compete for the White House Press
   Corps charter business."
   
   My question is, do you recall your conversation with Harry Thomason
   regarding TRM competing for the Press Corps charter business?
   
   A I don't remember whether it was on the phone or in person, but I do
   remember having a brief conversation with Harry. What he said -- I am
   summarizing -- this wasn't the exact conversation -- do you know how
   White House charter business is handled? And I did not. I said no, I
   am not sure. He said, well -- I said -- he said my guy, Darnell
   Martens, is going to call you. If you could just direct him to the
   appropriate place, or whatever, that would be great.
   
   I asked somebody about it, and found out that the Travel Office was
   headed by Billy Dale, which I don't think I knew before that. I am
   sure I didn't. It was early on. When Darnell called, I actually
   transferred him to the White House Travel Office and didn't ever speak
   to him about any of the details.
   
   Q Do you remember the time frame when Harry called you --
   
   A I don't know whether Harry was in person or on the phone. Within the
   first month of being at the White House.
   
   Q Would that be January?
   
   A January or February.
   
   Q Subsequently, do you recall when Darnell made the telephone call to
   you?
   
   A Sometime also within that same time frame, within the first month, I
   believe, but I don't remember exactly.
   
   Q Did Darnell send you any other memos or materials, that you recall?
   
   A I don't remember ever hearing Darnell Martens' name again until this
   was presented to me on Friday.
   
   Mr. Romatowski. May 21st.
   
   The Witness. Correct.
   
   BY MS. BRACHER:
   
   Q The bottom of the first page under "Research Information," says that
   "TRM has learned that, contrary to Dee Dee Myers' understanding, the
   White House Press Corps has been flown on a virtually exclusive basis
   by Pan Am and the son of Pan Am known as the Airline of the Americas."
   
   Did you have any conversations with Mr. Thomason concerning that
   paragraph?
   
   A The only conversation I had with him ever about the Travel Office
   before the Friday the 14th conversation, conversation that I have
   already described, was a very brief one where I don't recall ever
   knowing how the White House charter business operated.
   
   I may have speculated to him that it was a competitive bid, since most
   government contracts are, but I never independently undertook to find
   out. So contrary to my understanding, I don't know that I had an
   understanding other than an assumption, which may have been wrong.
   
   Q On the second page under a subheading called "The Result," it says:
   "Dee Dee is wrong. The White House is tied into two operators, one
   essentially domestic and one essentially international, operators who
   did everything possible, and then some to get President Bush
   reelected, apparently without the full knowledge and cooperation of
   the White House Travel Service Department."
   
   Do you have any knowledge of what they are referring to in this memo
   when they say "Dee Dee is wrong"?
   
   A No, I don't know. I can make an assumption, but I don't know. I
   didn't write the memo.
   
   Q Did you have conversations with them other than the ones you have
   just described, where you talked about the two operators tied into the
   White House or the fact that those operators tried to get President
   Bush reelected?
   
   A I had again, until the Travel Office firings, I had no idea who the
   operators were. I didn't have any conversation with anybody about
   this. It was so far down my list at that point that I never -- I don't
   remember ever even thinking with about it.
   
   Q Were you aware of in the campaign that there was a problem with
   operators trying to get President Bush reelected and that there was
   some question about the charter operators billing with President Bush?
   
   A No.
   
   Q There is a memorandum which I will mark as Deposition Exhibit No.
   10.
   
   (Myers Deposition Exhibit No. 10 was
   
   marked for identification.)
   
   BY MS. BRACHER:
   
   Q This is Bates stamp CGE 008114, to David Watkins from Dee Dee Myers,
   Arthur Jones and Jeremy Gaines, dated May 14, 1993.
   
   Will you look that over and tell me if you recognize that document?
   
   A Yes. I remember this.
   
   Q Did you draft this memorandum?
   
   A I don't think so. I believe -- I believe it was Arthur Jones. Or
   maybe Jeremy; I am not sure.
   
   Q Do you know what prompted the drafting of this memorandum?
   
   A Certainly; a catastrophe of a trip to New Hampshire the Saturday
   after the Travel Office dismissals, firings, whatever.
   
   Q In the memorandum it states that "the May 22nd trip using Midwest
   Express instead of UltrAir, provided stark and in some ways
   embarrassing contrast to previous trips."
   
   When did you receive notice that there were problems with that trip?
   
   A I was on the trip. We were receiving notices of it all day when the
   press couldn't get off the ground due to mechanical failures.
   
   Q So you flew on the press plane?
   
   A No, I flew on Air Force One. I believe Arthur was stuck on the press
   plane with an angry Press Corps.
   
   Q One thing pointed out is that the charter crew and aircraft arrived
   at Andrews 2 hours prior to the scheduled departure. Later in that
   paragraph it says that "The practice of early arrival was instituted
   by UltrAir to avoid delays."
   
   Did that occur with this trip; that the departure was held up because
   of a mechanical failure?
   
   A I believe that is what the memo says, and that is my recollection.
   It says, "discovered the troubling mechanical failure following
   routine post-flight inspection at approximately 4:38 a.m."
   
   Q Who did this memorandum go to other than, I assume, David Watkins?
   
   A I don't know.
   
   Q Did you have any meetings or discussions with anyone as a result of
   this memorandum?
   
   A Yes. I think there were several meetings and conversations over the
   course of the next several weeks. I think I met with representatives
   of the White House Correspondence Association who itemized their
   complaints.
   
   I then met with on sort of a ongoing basis or over the course,
   probably of a couple of weeks, members of the Office of Administration
   as we tried to put together a Travel Office and to anticipate upcoming
   trips and to try to avoid some of the problems that we had.
   
   Q Were you aware that there was a contract for UltrAir to have done
   this trip before the firings, an oral contract?
   
   Mr. Goldberg. I don't think that has been established.
   
   BY MS. BRACHER:
   
   Q Were you aware if there was an oral contract between Ultra --
   
   A No.
   
   Q Do you know who was responsible for the primary arrangements of this
   trip on Midwest Express from the White House?
   
   A I don't know specifically. I think -- I don't. There was a number of
   people involved. I don't know who primarily.
   
   There was a woman who worked for me named Ann Edwards, who handled a
   lot of the press logistics and she was somebody that I routinely
   talked to about these things, in addition to my staff, who dealt with
   the press on a more editorial basis but also was on the receiving end
   of their complaints. So talked to a lot of people. Watkins was
   overseeing the Office of Administration in which the Travel Office was
   sort of grouped, and so there were a lot of people who had a piece of
   this.
   
   Q Did you deal with anyone in the Travel Office as a result of this
   trip, the Travel Office as it existed on May 24th; did you have
   conversations with anyone in the Travel Office?
   
   A I probably did, but it was a short-lived arrangement. I suppose
   Catherine Cornelius was there, but you know, I don't remember
   specifically.
   
   Q So the meetings that you had, did they go beyond the press group
   meetings or did you have meetings outside --
   
   A Press and administration. I don't recall that there were people
   other than that, although George Stephanopoulos would fit under press,
   but I don't remember anybody else being there.
   
   Q I have a final memorandum which I will mark as Deposition Exhibit
   No. 11.
   
   (Myers Deposition Exhibit No. 11 was
   
   marked for identification.)
   
   BY MS. BRACHER:
   
   Q This is Bates stamped CGE 008447. I ask you to look at that document
   and tell me if you recognize it. It is dated July 2nd, 1993:
   "Memorandum to the Communications Staff. From Mark Gearen for
   Procedures for Contacts with the FBI."
   
   A Yes. I can remember this.
   
   Q Do you recall participating in the drafting of this memorandum?
   
   A I remember participating in discussions about it. I don't remember
   who drafted it, but certainly in conversations about the -- becoming
   aware of problems and of the, you know, potential dangers of calling
   the FBI. It was something that we discussed obviously subsequent to
   the whole Travel Office episode.
   
   Q Did you review any other procedures in order to come up with this
   memorandum, that you recall? Did you review any FBI procedures or any
   other materials to use as a basis for this memorandum?
   
   A I don't recall. I don't recall any.
   
   Q Can you just tell me what your participation was on this memorandum?
   
   A Well, we had conversations about what had happened and what we --
   what kinds of guidelines we could establish to prevent something like
   that from happening again. We discussed the value of having a clear
   and established policy to guide people on issues of FBI contact.
   
   Q Did you have any other policies that you reviewed?
   
   A I guess I am not sure what kinds of policies you are talking about.
   
   Q I don't know either. I am just trying to find out if there are any
   policies you recall specifically reviewing, whether they be White
   House or FBI.
   
   A I don't recall specifically. I am sure that we discussed, based on
   what we learned over the course of the Travel Office, what established
   FBI procedure was, and I don't remember whether we discussed, say, how
   previous White Houses had handled it or not. But we tried to establish
   policy that would protect people and the White House from making the
   kind of mistakes that we made in regard to the Travel Office episode.
   
   Q I have through your document production -- it is not your document
   production. This is a document production from the White House which
   includes your notebooks that you kept.
   
   Have you reviewed these notebooks prior to coming here today?
   
   A Yes.
   
   Q The first one is dated, May 20th, and it says '93.
   
   I give you the entire copy. We might as well mark it as Deposition
   Exhibit No. 12.
   
   (Myers Deposition Exhibit No. 12 was
   
   marked for identification.)
   
   BY MS. BRACHER:
   
   Q Would you turn to the page, about three pages in, and it should be
   marked CGE 39790. There is a statement about halfway down, the head
   says, "travel story," the headline on this page. Halfway down it says,
   "examples of mis," and if you can read what that note, that word is
   after "examples of mis" --
   
   A Management.
   
   Q Underneath it says, "i.e., bill left over from December 30th."
   
   Do you recall where you received that information that you wrote down?
   
   A I don't.
   
   Q On the following page, it is dated May 21st, and there is some
   information at the top about NPR. Did anyone tell you that this was a
   part of NPR, the review of the White House Travel Office?
   
   A Yes. That was part of the original talking points that I received
   from David Watkins.
   
   Q Can you tell me what information did you have about it being a part
   of NPR?
   
   A My recollection is that it was not so much a part of NPR as an
   offshoot of NPR as part of the National Performance Review the Office
   of Administration had undertaken to review White House operations,
   particularly those that handled large amounts of cash, and that as
   part of this ongoing review, irregularities in the Travel Office were
   first uncovered, and then upon further investigation, decisions were
   made to fire the seven employees.
   
   Q Did there come a time where you were told that this was not a part
   of NPR?
   
   A I don't remember ever being told that specifically. I think it
   became clear that that wasn't really the impetus for the original
   investigation, that that had come from a staff member's observations
   and not so much from the performance review.
   
   Q The following page of your notes, which is CGE 39792, I believe it
   says, "CC, distant cousin, began pushing 3 months ago." Is that
   correct?
   
   A Yes.
   
   Q What information did you have concerning CC began pushing 3 months
   ago?
   
   A I don't know specifically what that was in reference to. I could
   speculate, but I don't know what this particular notation means.
   
   Q Do you have any general information apart from this notation that
   CC, I take it, refers to Catherine Cornelius?
   
   A I assume so, yes.
   
   Q That Catherine Cornelius began pushing 3 months ago, which if these
   were in May, that would have been February?
   
   A I think Catherine had some ideas about how the Travel Office would
   be managed, in her opinion, more efficiently, better, and I think she
   began discussing her ideas about that, including in a memo, which you
   have already seen, to David Watkins.
   
   Q The following page, which is CGE 39793, at the very top you have,
   "lack of accountability, controls, documents, et cetera," and then
   "petty cash."
   
   Do you know where this information came from that would cause you to
   write that note?
   
   A I don't specifically know, no.
   
   Q Do you recall any conversations about petty cash that you had during
   this period following the aftermath of the firings?
   
   A Not specifically. I remember that that was one of the areas cited
   throughout that period, but I don't remember specifically who might
   have said it, particularly now, with reference to that notation.
   
   Q Was Billy Hamilton, the name that is on your notes, was he at the
   White House?
   
   A I don't know who Billy Hamilton is.
   
   Q Okay.
   
   The following page has at the top, "Bill Kennedy." Will you look at
   that page and tell me if that was information from Bill Kennedy or had
   a relationship to Bill Kennedy?
   
   A I don't remember specifically, because I don't remember writing this
   note, but I believe that is probably true.
   
   Mr. Romatowski. Which note?
   
   The Witness. I don't remember writing this page of notes. I believe
   that this is information that I got from Bill Kennedy.
   
   Mr. Romatowski. The question was in the alternative, whether it was
   information about Bill Kennedy or from Bill Kennedy?
   
   The Witness. Oh; from Bill Kennedy.
   
   Ms. Bracher. To make sure the record is clear, that is CGE 397894.
   
   BY MS. BRACHER:
   
   Q The next page, which is CGE 39795, has a note about "predication to
   investigate established by meeting with auditors."
   
   Do you recall who informed you that predication to investigate was
   established through that meeting?
   
   A Again, I don't remember specifically, but my pattern would have been
   this would have been a continuation of the notes that I said I
   believed came from a conversation with Bill Kennedy.
   
   Q The following page of your notes, CGE 39796, has the name "Darnell"
   at the top. Specifically, I want to focus on the line in the middle
   that says: "Broker. Took fee."
   
   Do you have any idea of what that is in relation to or where you
   received that information?
   
   A I believe that that is a description of Darnell Martens' or TRM's
   role in the campaign where they helped us line up aircraft.
   
   Q There is a few pages in, the number is CGE 39798. It says: "H.T. own
   8-seater, took."
   
   Do you recall what that is in reference to?
   
   A I do know that Thomason owned a jet, probably an 8 seater, also. In
   fact, we used it occasionally in the early days of the campaign, in
   fact.
   
   Q Further in to page CGE 39803, another page that has the name
   "Darnell" at the top, says: "Bush holdover."
   
   Do you recall what that is in relation to?
   
   A I don't. It was very likely in discussion of the memo.
   
   Q The Martens' memo that you reviewed?
   
   A Correct.
   
   Q Would that have been Deposition Exhibit No. 9?
   
   A Correct.
   
   Q Later on, also on the same page, it says: "TRM wrote contracts,
   received small commission."
   
   Do you have any recollection of where that information came from?
   
   A I don't, but again I think that is in reference to TRM's role during
   the campaign where they served as a broker and helped us charter
   aircraft.
   
   Q Just to be clear, are all these your notes and your handwriting?
   
   A With the exception of one page.
   
   Q The pages we have gone through so far?
   
   A Yes.
   
   Q The following page is 39805, a few pages in, there is a, halfway
   down is a heading called "Harry," and it says: Has no phone, office,
   occasionally works out of E. wing visitors office. Administration
   office answers phones, takes messages.
   
   Can you explain what that refers to?
   
   RPTS STEIN
   
   DCMN HERZFELD
   
   A The previous page says, "Tuesday, 5:25." This came from a meeting, I
   believe -- I am not sure what this came from, but it looks to me like
   information that I obtained at a meeting or in conversation with
   people.
   
   There had been press questions about Harry's role, did he have an
   office at the White House, and this looks to me like an answer to that
   question from somebody, I am not sure who, explaining that Harry, in
   fact, had no office in the White House.
   
   Q Do you recall who gave you that information?
   
   A I don't.
   
   Q Did you discuss it with Harry Thomason?
   
   A Probably, but I don't remember doing so specifically.
   
   Q Going on to page CGE 39808, there is a reference to a Thomason memo,
   and I just ask if you recall any specific Thomason memo or making that
   reference?
   
   A No. It could have been this Darnell Martens memo.
   
   Q That is Exhibit Number 9?
   
   A Exhibit Number 9, correct.
   
   Q And similarly on the same page where there is, "Questions. Better
   description of Harry's role. Susan Thomases," and, "FOB's with ID's."
   
   A That looks to me like the kind of questions I had either gotten or
   was anticipating from the press.
   
   Q Did you talk with Susan Thomases during this period of the firing?
   
   A I don't remember talking to her, but she was an FOB somebody who had
   a hard pass. One of the next series of questions was who has hard
   passes, and how do they get them, and how do you make those decisions.
   
   Q CGE 39811 has a date on the top of 5-25. At the very bottom it said,
   "Also time to time talk to 2 agents stationed in OEOB."
   
   Do you recall what that is in reference to?
   
   A That was in reference to Bill Kennedy's role and his relationship
   with the FBI.
   
   Q Did you receive this information from Mr. Kennedy?
   
   A I don't recall specifically, but I believe so. I believe that this
   is a description of the sequence of events around the Travel Office
   firings beginning with what was Bill Kennedy's ongoing relationship
   with the FBI.
   
   Q Did Mr. Kennedy at any time go into detail regarding the two agents
   that were stationed at the OEOB?
   
   A Not that I recall.
   
   Q Did you know the agents that were stationed there?
   
   A No, but there was an Office of White House Personnel, and there were
   FBI agents there to deal with not only White House personnel, but with
   ongoing background checks for potential appointees.
   
   Q On the next page, which is CGE 39812, it says, "Kennedy went to HQ,"
   which I assume is headquarters, "following procedures."
   
   Do you know what procedures he was following?
   
   A No. I mean, I believe it was -- I don't know if it was written or
   his understanding of procedures guiding the Counsel's Office contacts
   with the FBI.
   
   Q There is also -- underneath that, it says: Two previous contacts
   with headquarters regarding events on premises.
   
   Do you recall what the two previous contacts with headquarters were?
   
   A I don't, but I think it was something like somebody came to the gate
   who had a police record, something like that. I don't know that that
   was it specifically, but --
   
   Q Would those have been contacts with Bill Kennedy or just general
   contacts?
   
   A No, I think they were contacts with Bill Kennedy.
   
   The procedure for contacting the White House was through the Office of
   Internal Security or through the Counsel's Office when something like
   that happened that they thought the White House should know about as
   opposed to just law enforcement agencies, the Secret Service or FBI or
   whatever.
   
   Q The page at CGE 39813, in the middle it says, "3 facts," and then,
   "didn't know about Cornelius/Cerda memo." The next fact is, "Had
   Martens memo." Then: Harry made clear he would have no role, in paren,
   financial, in future of office. Clearly understood.
   
   A I think this was Harry's explanation of his role or orientation
   toward the whole Travel Office thing.
   
   Mr. Romatowski. You are inferring that from what you read here, or do
   you remember it?
   
   The Witness. I have a vague recollection of talking to him. He went
   through a period of continually trying to explain to the world and to
   me as the President's spokesman what his role had been, and there were
   a lot of questions about it. This is consistent with my memory about
   what kinds of things he had told me.
   
   BY MS. BRACHER:
   
   Q The following page, which is CGE 39814, the last sentence says,
   "Bill said urgency."
   
   Do you know what that "urgency" referred to?
   
   A No. I don't remember. I think he was trying to find a contact at the
   FBI to discuss this with.
   
   Q Did you ever discuss where urgency might have been coming from with
   Bill Kennedy?
   
   A No, but I know at the White House everybody thinks everything is
   urgent.
   
   Q Did you ever hear from Bill Kennedy or anyone else that there was a
   sense of urgency coming from the First Lady's Office during this time
   period?
   
   A I have no recollection of that, but I think there was -- at the time
   my general recollection was that people thought there was some serious
   questionable practices going on, and there was a sense of urgency
   about dealing with those as opposed to letting it go on. I don't
   remember that it had to be stated that it was coming from anyone in
   particular. It was the kind of thing that people felt needed to be
   dealt with. If you let it go on, you would get criticized for letting
   it go on.
   
   Q Were you aware at all during the time of any involvement by the
   First Lady leading up to the firings?
   
   A Not that I recall. It wasn't the focus of what I was doing. I don't
   recall. I don't recall.
   
   Q There is -- two pages down is CGE 39816, and in the middle of the
   page it says, "Based on what CC said, FBI has enough to go forward."
   In paren it says, "Mostly rumor of kickbacks," with an arrow going to
   "predication."
   
   Can you just tell me the basis for that note?
   
   A I believe what that means is that based on the FBI's interviews with
   Catherine Cornelius, they believed there was predication for further
   investigation. But, if you read on, Vince Foster didn't think that was
   enough. The White House thought there needed to be more than the FBI
   did.
   
   Q The rumor of kickbacks; did you know where that was coming from?
   
   A No. I suppose from -- I don't know.
   
   Q The following page is CGE 39817. It says, "Later, BK," Bill Kennedy,
   "talks to agents. They admit that 'hearsay,'" and that is in quotes,
   "not predication. Should proceed with audit."
   
   Do you know why you used the word that they admit that hearsay was not
   predication?
   
   A No. I mean, my recollection is that they agreed that it would be
   stronger with some documentation.
   
   Q And this does follow the statement that you are making where Vince
   thinks that we -- says: Let's proceed with independent audit.
   
     "Later, Bill Kennedy talks to agents. They admit that 'hearsay' not
     predication."
     
   Do you know of any discussions between Vince Foster and the FBI
   concerning whether or not they had sufficient basis --
   
   A No.
   
   Q -- to perform an investigation at that time?
   
   A I don't know.
   
   Q At the bottom of the page, "Larry briefed trainees about VP's NPR.
   Also, leading expert on performance reviews."
   
   Do you know who would have briefed you on Larry's experience?
   
   A It could have been -- since Watkins was the person who brought in
   Peat Marwick, it may have been Watkins. It may have been somebody
   else.
   
   Q On the following page you have, in the middle, "Used NPR as cover."
   Can you explain that?
   
   A I think it is explained in the rest of the notation. "Did not want
   to tell Travel Office they were suspected of wrongdoing."
   
   Q So a cover was merely for the statement to the Travel Office
   employees?
   
   A Correct, as to why an accounting firm was coming in and going
   through Travel Office records at the time.
   
   Q Did you believe that it was NPR being the umbrella reason of the
   initial review?
   
   A I did at the time.
   
   Mr. Goldberg. At what time?
   
   The Witness. At the time that it was first presented to me.
   
   Mr. Goldberg. But not at the time you took this note?
   
   The Witness. By the time I took this note, I believe I was beginning
   to have my suspicions.
   
   BY MS. BRACHER:
   
   Q Which would have been May 20, 1993?
   
   A May 25th, isn't it?
   
   Mr. Romatowski. I think you will find -- I am inferring from the
   sequence here, and I am not sure the witness can do better than that,
   but she can describe her practice and infer from these notes. But if
   you look at page 811 that is Bates stamped CGE 039811, this appears to
   be a sequence of notes in order that are dated at the top 5/25, so
   that these appear to be notes of activities on May 25th; is that
   right?
   
   The Witness. Correct.
   
   BY MS. BRACHER:
   
   Q Can you explain your practice of keeping these notebooks during this
   time period?
   
   A I generally carried around a reporter's notebook, which I took notes
   in about anything that I wanted to remember, whether it was questions
   I needed answers to or facts I felt might be useful later, or phone
   calls I needed to make. Generally I tried to date -- write the date in
   at the top of the day as opposed to on every page. But I didn't always
   do that, but generally I wrote the date at the beginning of every day,
   and everything that followed was notes from that day.
   
   Q That same day under the NPR: Thursday via Vince Foster tells Mack
   and Friday A.M. Vince Foster talks to Ricki.
   
   Do you know the contexts of any of those events?
   
   A Well, these notes go in sequence about the decision to investigate
   the Travel Office, and so this appears to be that on Thursday Vince
   Foster told Mack McLarty about the -- about their concerns and about
   their decision to go forward with an audit. On Friday Vince talked to
   Ricki, presumably about the same thing.
   
   Q Ricki Seidman?
   
   A Correct.
   
   Q Do you know why Vince Foster would have talked to Ricki Seidman
   about this?
   
   A Ricki as a lawyer was involved in a lot of things, like reviewing
   backgrounds of nominees. She was a liaison between the communications
   department -- her title at the time was Deputy Communications Director
   and the Counsel's Office because she was the only one in the
   communications department who was a lawyer, and she dealt with
   Counsel's Office routinely on a variety of issues, whether it was the
   President's taxes or nominees of people being considered for
   appointments. Things like that.
   
   Q At the end it says: Eller, Harry. Mentioned it to.
   
   Do you recall who they mentioned it to?
   
   A They mentioned it to me. So it could have been me.
   
   Mr. Romatowski. You are uncertain of the record in your notes, but you
   know that on May 14th your best recollection is they did mention it to
   you?
   
   The Witness. Correct.
   
   BY MS. BRACHER:
   
   Q On page CGE 39820, there is a statement that says: Talked to Office
   of Public Integrity. And then it says: Run traps internally.
   
   Can you tell us what that refers to?
   
   A I assume -- I don't know if I should assume. Again, this appears to
   be a chronology of events that I believe came from Bill Kennedy, and
   so it looks like Bill Kennedy talked to the office -- or somebody from
   the Counsel's Office, I don't know that it was Bill, talked to the
   Office of Public Integrity at Justice, and "run traps internally"
   generally referred to making sure that the people who needed to know,
   like the Chief of Staff, were informed.
   
   Q On Monday at the bottom of that page it says: A.M. Watkins meets
   with Mack.
   
   Do you have information about that Monday meeting?
   
   A I don't. I believe I was in California at the time, and I believe --
   my recollection is that David briefed Mack about what they had found
   over the weekend.
   
   Q On page CGE 39822, it lists three actions, and the first being to
   interview Clarissa and Catherine.
   
   Can you tell us what that had to do with? Do you recall?
   
   A I don't know. I believe David Bowie was an FBI agent, so I don't
   know if these were actions that the FBI had taken to establish the
   predicate or was planning to take, but I think it refers to actions
   that the FBI had either taken or was going to take. Since they had
   looked at some of the records in establishing a predicate, that may be
   what it is referring to.
   
   Q Do you have independent information about interviews with Clarissa
   or Catherine occurring with the FBI during that period?
   
   A No; only what is in my notes, which says they interviewed her and
   felt that was sufficient to establish a predicate. I guess I am
   focusing on Clarissa. I don't know.
   
   Q Underneath is "Check White House computers."
   
   Do you know of any issue concerning White House computers other than
   what you just said about the FBI with the records?
   
   A No.
   
   Q Also on that page, 822, at the bottom it says: Look at Travel Office
   records going back to '85.
   
   Do you know any -- do you have any independent knowledge about a look
   at Travel Office records going back to 1985?
   
   A No, and I don't recall how far back either the FBI or the Peat
   Marwick review went.
   
   Q Page CGE 39825, there is -- it says: Harry's message service. Need
   answer on Harry.
   
   And the second part says: Gore's comments not part of NPR. Knew
   nothing about it.
   
   Can you tell us where that came from and what knowledge you have of
   those statements?
   
   A I have no idea on what I needed an answer from Harry. Gore said at
   some point that he was unaware of the Travel Office review and that it
   was not part of the NPR program under his purview. I don't remember
   who he said that to, but I believe he said it somewhat publicly.
   
   Mr. Goldberg. Would this be a good time to take a lunch break?
   
   Ms. Bracher. I don't have that much left. It shouldn't take probably
   an hour when we come back. If we could come back right at 2:00 so I
   could have a full --
   
   Mr. Romatowski. How about 1:30.
   
   Mr. Goldberg. I think you will find it difficult to eat there and come
   back by 1:30.
   
   Ms. Bracher. Let's go off the record.
   
   [Whereupon, at 1:00 p.m., the deposition recessed, to reconvene at
   1:30 p.m. the same day.]
   
   RPTS STEWART
   
   DCMN PARKER
   
   [1:50 p.m.]
   
   BY MS. BRACHER:
   
   Q I have a couple of documents I wanted to ask you if you recognize
   them. One is CGEPR 582. It's entitled chronology of White House Travel
   Office fires as of 5/25/93. Showing the witness the document and ask
   you to look that over and tell me if you recognize that document?
   
   A I vaguely remember this, but I don't remember who actually did it.
   
   Q Can you just tell me the circumstances of any meetings that you were
   in or any discussions concerning this chronology or others?
   
   A I don't remember the exact circumstances, but it is clearly put
   together after May 25th, and this is as of the 25th. I think there was
   an ongoing effort to try to establish as accurately as possible the
   chronology of events leading up to the firings and to track what had
   happened since the firings and that was the daily theme.
   
   Q As an ongoing effort, can you describe what actions took place that
   were part of an ongoing effort?
   
   A Just the meetings to ascertain what had happened and certain facts
   had come to light. One day they'd be complemented by additional facts
   over the coming days. For example, the Cerda-Cornelius memo appears on
   Thursdays, the Darnell Martens memo appeared on Friday and then new
   allegations from the press.
   
   Q Your view is although this chronology states it is as of 5/25 it was
   created after 5/25?
   
   A No the only reason I said that is because it goes through the 25th.
   
   Q Do you recall any specific meetings that you attended where you
   reviewed chronologies or helped to devise chronologies?
   
   A Well, certainly the point of several of the meetings was
   established, the chronologies, and judging from my notes there was a
   conversation on the 25th where we clearly sat there and Bill Kennedy
   and others went through what had transpired and this goes with some of
   the things I had in my notes. I don't know if this was called to help
   flush this out, but it certainly would be a useful document.
   
   Q Do you recall being shown finished chronologies such as the one
   before you?
   
   A No, I vaguely remember seeing this. I don't know if there was
   anything before this other than what was in my notes, which really was
   the one day from the 25th as well.
   
   Q There is some handwriting on that document. Do you recognize that
   handwriting?
   
   A It is George Stephanopolous'.
   
   Q Did you review chronologies specifically with Mr. Stephanopolous?
   
   A Oh, I am sure I did. Again, I don't remember specifically, but
   trying to establish, again, the chain of events was important in
   trying to understand what had happened and being able to explain that
   to the press.
   
   Q Let me make that part of the deposition record. I am going to mark
   and put that in the record as Deposition Exhibit No. 11, I believe. --
   No, 13. So the chronology as of 5/25/95 which is CGEPR 582 is
   deposition Exhibit No. 13.
   
   (Myers Exhibit No. 13 was marked for identification.)
   
   Ms. Bracher. I have got another chronology that I'm going to show you
   which will be deposition Exhibit No. 14 and one against it's CGEPR 565
   and the title is the same, "Chronology of Travel Office firings as of
   5/25/93," and ask you if you recognize that chronology in particular
   as opposed to the chronology that is Deposition Exhibit No. 13.
   
   (Myers Exhibit No. 14 was marked for identification.)
   
   Mr. Romatowski. This a copy of the different marginal notes?
   
   The Witness. Yeah, I don't recognize either of them specifically. It
   looks like an earlier draft to me.
   
   BY MS. BRACHER:
   
   Q Can you identify the handwriting on that?
   
   A It is also George's -- George Stephanopolous'.
   
   Q Were you in a meeting with Mack McLarty after the 25th where these
   chronologies were discussed?
   
   A Again, I don't remember specifically.
   
   Q Do you recall any discussion of pressure from any of the individuals
   in the meetings on these chronologies?
   
   A No.
   
   Q Do you recall any discussion of the First Lady's role in any of
   these meetings while you were doing these chronologies?
   
   A No, I don't.
   
   Q Was there any discussion whatsoever of the First Lady's role in the
   Travel Office firings during any of these meetings?
   
   A I just don't recall that being discussed in these meetings trying to
   establish a chronology of the specific events, and I think that is
   reflected in these documents, but I don't remember anything about Mrs.
   Clinton's role.
   
   Q Do you recall any conversations of events that would have occurred
   between David Watkins and the First Lady being discussed concerning
   these chronologies?
   
   Mr. Romatowski. Can we try that one again?
   
   BY MS. BRACHER.
   
   Q Do you recall a discussion of any events between David Watkins and
   the First Lady being discussed in the context of these chronologies?
   
   A Not -- no, huh-uh. I don't remember who David Watkins called when
   you mentioned earlier he called somebody from his daughter's
   graduation. I don't remember who that was, but I suppose it is
   possible he called her. It may have come up, but I don't recall it.
   
   Q Do you recall any discussion of the First Lady putting pressure on
   individuals on May 16th three days before the firing within the
   context of these chronologies?
   
   A No. I mean it is something that certainly had been discussed and
   discussed in the press subsequently, but I don't remember it
   contemporaneously with the events around the actual firings.
   
   Q I have got another set of your notes which -- there is only a few
   pages. I am going to ask you questions. I thought I had given you the
   whole set so you can refer to them in context. They begin with the
   Bates-stamp number CGE39251 and they appear to be Ms. Myers' book from
   4/16/94 to 5/16/94. Do you recognize this document?
   
   A Uh-huh.
   
   Q And are these notes that you kept?
   
   A Yes.
   
   Q And in 1994 were you still keeping notes in the same manner as you
   previously described that you were in '93?
   
   A I was.
   
   Q On the page CGE 39252, at the top of the page is entitled "Catherine
   Cornelius," and at the bottom it states people say, then, it is in
   parentheses, "several, that you and someone else" there are three
   ellipses, "moved out of his office reassigned because of his
   harassment," and underneath it says, "informally complained" can you
   please describe what knowledge you have of any harassment that would
   have been in his -- and who do you think his refers to?
   
   A What this note refers to is the conversation I had with Catherine
   Cornelius. A reporter from Business Week and Mitchell Schroeder was
   trying to write a story that David Watkins had been harassing her, and
   she did not want to talk to him. She said he called her at 9:30. I
   don't know if it was a.m. or p.m. on Sunday and started to lay it out
   for her, and she said let me stop you. That is what that reference is,
   I don't talk to the press, here is my attorney's number.
   
   She said he kept pushing her. He also called Clarissa to say Catherine
   had been warned what he said to her. The people say that you and
   someone else, I don't know who that someone else was, moved out of
   his, which refers to Watkins' office, that you were resigned because
   of that harassment?
   
   A I don't know whether she had actually complained or not, but this is
   her comments to me about a conversation she had with this guy,
   Mitchell Schroeder.
   
   Q Other than just this reference, do you have any knowledge about a
   situation regarding Catherine Cornelius and Mr. Watkins?
   
   A Only what she told me with reference to this guy and the story he
   was trying to write.
   
   Q Other than what you have said that the gentleman recounted, those
   events that Catherine described, the events that were occurring with
   her and David Watkins?
   
   A She told me they had not gotten along. I guess she -- I think she
   got reassigned to the Office of Administration and that they had a
   very strange relationship and she thought that he was not sexually
   harassing her, but was a sexist, was my words, but my interpretation
   of her comments, and he sort of thought she should fetch coffee and
   answer phones.
   
   Q Did Clarissa ever describe her views about a similar situation with
   David Watkins to you?
   
   A I don't recall ever talking to Clarissa about it.
   
   Q Were you aware of such a problem with Clarissa and David Watkins in
   the White House?
   
   A Only because Catherine told me about it in the context of this
   reporter's inquiry.
   
   Q Did Catherine tell you about informal complaints to the White House
   counsel's office regarding David Watkins?
   
   A If she did I don't remember exactly. She -- and I don't remember
   whether she told me that she had informally complained or whether the
   Schroeder reporter alleged that.
   
   Q Do you know if any action was ever taken regarding allegations of
   harassment by David Watkins?
   
   A I don't know and he wasn't around much longer.
   
   Mr. Romatowski. Do we have much more on this? This seems to me to
   stray somewhat far afield from the White House Travel Office and we
   have limited time.
   
   Ms. Bracher. We started late from lunch. The issue of David Watkins
   and harassment of individuals is relevant to our investigation, and it
   is a topic which we are going into on its face. I don't have much
   left.
   
   Mr. Romatowski. I am not aware of the relevance of the Travel Office
   matter.
   
   Ms. Bracher. Are you objecting?
   
   Mr. Romatowski. If you go any further I probably will.
   
   Ms. Bracher. Certainly you have the option to objection.
   
   Mr. Romatowski. If it goes any further, I probably will object.
   
   Ms. Bracher. I will continue.
   
   BY MS. BRACHER:
   
   Q There is a page CGE38398?
   
   A I am sorry 39 --
   
   Q 38398. It is on in. If you keep going in a bit I know the numbers
   jump down. It is just the way it was produced.
   
   A Okay.
   
   Q Is that your handwriting?
   
   A Yeah.
   
   Q There in the middle of the page there is a statement that says
   "tricky" then has a colon, and "we have been consulting with
   employees; now satisfied that there is no obstacles too permanent."
   Next line says, "hope to have them very much. " Can you explain what
   that is in reference to?
   
   A I am just looking for a date in reference here. I guess it is -- I
   know that it is in reference to trying to place the Travel Office
   employees except Billy Dale in other government jobs, which we had, I
   think, had been the -- we had said we would do it in the wake of the
   management review. There were some obstacles. It was tricky for
   reasons of available positions at comparable salaries, the jobs to
   which they were qualified.
   
   Q The following two pages in CGE38400 discusses, I believe, it is in
   reference to Catherine Cornelius. The page before the bottom it says
   ", Catherine Cornelius left Travel Office always on the payroll,"
   continues on 38400, "hasn't been there since July 13th or 14th" and
   "appendix out at Houston."
   
   Did you have any conversations with Catherine while she was in
   Houston?
   
   A I don't think so.
   
   Q Did Catherine ever discuss why she left the White House for this
   period?
   
   A No, I don't remember ever talking to her about that other than to
   say -- I talked to her periodically. I don't ever remember talking to
   her in Houston. Obviously, this was pretty traumatic for her. She
   ended up thrown in the middle of this controversy and she is fairly
   young and it took its toll.
   
   Q Did she ever describe what kinds of activities -- what kind of tolls
   that were taken on her because of actions by David Watkins?
   
   A No, I think that was -- I don't want to put words in her mouth --
   the least of her concerns. I shouldn't say that I don't know. But I
   talked to her from time to time about she occasionally would come to
   me for advice because she was often the subject of the press stories,
   and I would try to guide her, just try to mostly cheer her up and to
   remind her that she didn't have any obligation to talk to the press
   and she was welcome to kick any inquiries to me and I would handle
   them on her behalf. It is been a very hard couple of years for her.
   
   Q The following page has "Jody Torquelson trying quietly to place
   them." Can you tell me who this refers to?
   
   A The other six Travel Office employees, I believe.
   
   Q The other page, 38402, it has the date, Thursday. It says, "Travel
   Office," I guess I was going to ask you a question about the line that
   -- "to pull Mack's comments, sheet on polls." Can you tell me what
   comments there were that Mack had and how they related to the Travel
   Office?
   
   A I have a vague recollection that he may have said when asked
   probably at the presentation of management review in early July that
   he didn't rule out that they would be reinstating the Travel Office.
   Although nobody had any intention of that happening, so I think that
   is a notation to me to pull his exact comments because I probably had
   gotten a question from it from the press inquiries of things is kind
   of unrelated.
   
   Q Do you know why there wouldn't be any intention of reinstating the
   other five fired Travel Office employees back into the Travel Office?
   
   A Given what had happened I think the feeling was that wouldn't have
   been feasible from the standpoint of who they would have had to work
   with. It wouldn't -- I don't think it would have been -- this is my
   own impression, not so much that I was told, and even though they had
   been cleared of, or I don't know cleared. I don't know what the status
   of the investigation was.
   
   There were still questions about practices in the Travel Office plus
   there were interpersonal questions they would have to preparing travel
   for an administration for which they probably had bad feelings.
   
   Q Going on in page CGE 38412, there is some discussion on this page
   about David Watkins, and it says, "David Watkins authorized all
   military aircraft only be used when absolutely necessary. Didn't meet
   the criteria outlined." And it says, "President had no plans to play,
   of course." Can you please tell me what these notes are in relation
   to?
   
   A This describes David Watkins' helicopter trip to a golf course in
   Maryland.
   
   Q Did the helicopter trip have any relationship to the Travel Office
   that you know of?
   
   A No, it did not.
   
   Q There is a series of notes beginning on CGE 38414 that is dated
   9/11/93, and if you go into page CGE 38416, it says "Heymann," and it
   has a hyphen, or Heymann, "to say referred, quote, FBI lied issue to
   OPR real..." Or maybe you can tell me what the rest of that says.
   
   Mr. Romatowski. It says "rest".
   
   The Witness. Rest of issues.
   
   BY MS. BRACHER:
   
   Q Then there is "Office of Public Integrity section of Criminal
   Division investigating travel and other issues in the note." Can you
   please tell me --
   
   A This has to do with Vince Foster.
   
   Q What does it have to do with Vince Foster?
   
   A I don't know exactly, but obviously the notation here that is about
   a note refers to something about him, but I don't remember what -- I
   have no idea what the reference to FBI lying was.
   
   Q Do you know who gave you this information or provided the source of
   this information to you?
   
   A I don't remember. This doesn't make much sense to me.
   
   Mr. Romatowski. Can I help here?
   
   Ms. Bracher. I would prefer unless it is testimony about this document
   I prefer it not be done.
   
   Mr. Romatowski. Do you want to know what this is or not? I can ask a
   question that may prompt a recollection.
   
   Ms. Bracher. Oh, that is fine if you think you can prompt a
   recollection from the witness. I was trying to avoid your recollection
   of what it is or outside of Ms. Myer's recollection.
   
   Mr. Romatowski. I don't have any recollection, of course, because I
   didn't participate in the events, but does this have anything to do
   with the note that Vincent Foster left behind?
   
   The Witness. Yeah, I believe and that is what I said. The Office of
   Public Integrity was conducting the investigation into the issues
   outlined in Vince's note, one of which was referenced to the Travel
   Office, but I don't remember why I would have had that notation about
   Phil.
   
   BY MS. BRACHER:
   
   Q Did you know Phil?
   
   A Yeah. Not well.
   
   Q Did you have conversations with him during this period?
   
   A He came to some meetings where Vince was discussed in the aftermath
   of Vince's death, but I don't remember the chronology of it. I don't
   remember why in September -- what was going on in September that would
   have prompted this.
   
   Q Do you know who would have -- who told you that the Office of Public
   Integrity was investigating travel and other issues in the note?
   
   A I don't know.
   
   Q Do you recall ever having those kinds of conversations with Mr. --
   
   A It wouldn't have happened one on one. He might have been in a
   meeting or somebody might have made a reference to him, but I wouldn't
   have called him on the phone or anything like that.
   
   Q On the following page at the bottom, "we were made aware of an
   allegation against the Travel Office during a previous administration.
   We have forwarded that information to the Justice Department."
   
   Do you know where you received that information?
   
   A No, I don't. Probably we likely refers to the White House. I don't
   remember what that was either. I have a vague recollection that that
   came up in an issue where somebody had -- I just can't remember what
   the allegation was. My memory is getting mixed together.
   
   Q Do you recall receiving information about the criminal investigation
   that was going on at public integrity?
   
   A I wouldn't have received information other than perhaps the
   investigation was going on.
   
   Q Do you recall receiving information about topics of the
   investigation or status, any kind of briefings?
   
   A It says the topics in the notes so I was familiar with the topics in
   the notes, but beyond that --
   
   Q At the bottom of that page it says, "Cliff, working on
   investigations independent counsel."
   
   Do you recall what information you had about Cliff Sloan? I take it
   that is who this Cliff is.
   
   A I presume -- I don't know what that would have been.
   
   Q Were you aware of any discussions about Mr. Fiske who was doing his
   report on Vince Foster?
   
   A This was -- is this in 1994?
   
   Q Uh-huh.
   
   A So he was appointed in January of 1994 so this is September of 1994?
   
   Q I am sorry this is September 1, 1993 through September 11th.
   
   A I am not remembering any -- we hadn't gone through our independent
   counsel phase yet at that point that I recall. I don't remember an
   independent counsel investigation.
   
   Mr. Romatowski. Fiske was appointed in January 1994.
   
   The Witness. January 1994, so I don't know what that may have been.
   
   BY MS. BRACHER:
   
   Q Are there any other independent counsel investigations that you were
   aware of?
   
   A I don't remember any at that point. The best was yet to come.
   
   Q The following on page CGE 38340 is a notebook that --
   
   A 38340, okay.
   
   Q And we have not been able to read the date on that notebook. Were
   all these notebooks left at the White House?
   
   A No, I took them.
   
   Ms. Bracher. Can we just make a note for the record if we could get a
   copy of the cover. I guess your number on it is 1902. I take it that
   is an internal number.
   
   Mr. Romatowski. I think that is probably a number we put on it.
   
   Ms. Bracher. If someone could make a copy of that so it is readable
   just so we have a reference. It appears from the material that follows
   that it is made --
   
   Mr. Goldberg. I think I can read mine, 5/20/94.
   
   Ms. Bracher. So you say it is 5/20/94.
   
   Mr. Goldberg. Or something 20/94.
   
   The Witness. This is the one --
   
   Mr. Goldberg. I am sorry. I can't definitely make out the five
   something 20/94.
   
   The Witness. I think this is the one I misdated.
   
   Mr. Romatowski. This certainly looks --
   
   The Witness. This looks like May '93 to me.
   
   The Witness. When I went back through my records pursuant to any
   number of the subpoenas I received, I tried to put my notebooks in
   chronological order so I could -- and they weren't all dated on the
   cover because sometimes I would not date the cover. I had put a start
   date, but not an end date so I went back in and wrote the dates, so
   the best I could sort of figure out when they were. I think I dated
   this the wrong year.
   
   And I just probably went to the first date written here as May 20th,
   and so this could actually be from May, be the day before, but it
   looks clearly to me like '93 because there is a reference here to
   Vince Foster, among other things. Maybe I had two notebooks going for
   some reason.
   
   Mr. Romatowski. Reference to Vince Foster as an active participant in
   something?
   
   The Witness. Yeah, on 1908.
   
   BY MS. BRACHER:
   
   Q The document that has previously gone in the record, which is
   deposition Exhibit No. 12, that front page is dated May 20th 1993. And
   looking at -- my question is, looking at CGE 38340, are you aware of
   two sets of notes from that date?
   
   A If you look through this and these pages aren't all continuous, are
   they? But sometimes I have to admit I had a reputation for
   occasionally leaving my notebooks around so it is not common, but it
   wasn't unheard of that I had overlapping notebooks because I would
   start one, leave it in somebody's office, open up another one, record
   some stuff in there, maybe go back to the first one, but that is what
   this looks like to me because it then appears to skip forward quite a
   bit, which based on my own practices leads me to believe that I put it
   down until I filled up the other one then went back to it.
   
   Q Are you aware of Government's Exhibit No. 12 being recently produced
   to this committee?
   
   Mr. Romatowski. We are aware that materials from at least one of her
   note books had just been recently produced, and she is aware of that.
   I don't think she knows specifically which one it is.
   
   Ms. Bracher. It is that notebook that was recently produced and as
   matter of fact, Deposition Exhibit No. 12, I think, includes all of
   the documents that were produced. It was that packet. Can you please
   tell me the circumstances for the late production of that notebook, if
   you know.
   
   Mr. Romatowski. Tell her what you did.
   
   The Witness. I received a memo from the White House counsel's office
   saying that I should produce the information to them, and they would
   then produce it to you all, which we did, with my attorneys and they
   produced everything, then notified us that they had somehow overlooked
   this. I guess Steve found it.
   
   Mr. Romatowski. We can pick up this story there. We submitted to the
   White House for their review all of her notebooks.
   
   Ms. Bracher. Which would include Deposition Exhibit No. 12.
   
   Mr. Romatowski. Correct.
   
   Ms. Bracher. Do you know when that was produced?
   
   Mr. Romatowski. When we produced it to them? It was approximately the
   dates that are reflected on the correspondence.
   
   Ms. Bracher. Your initial production would have included that exhibit?
   
   Mr. Romatowski. Well, it is a little more complicated than that. Your
   subpoena was of a certain date. About a week later we got a memorandum
   from White House counsel on behalf of the witness saying that is the
   way we are going to produce this. Any White House document, quote,
   unquote, by which they defined to mean roughly anything generated in
   the court of your official duties, please submit to the White House,
   and we will decide what is responsive and produce it to the committee.
   Since these were generated in the course of her official duties, we
   promptly thereafter in a matter of days submitted all of her
   notebooks, all of her original notebooks for their review.
   
   They told us that they selected certain portions and produced them to
   the committee pursuant to the committee's subpoena to the White House,
   which I don't think we have ever seen, but I assume it is like the one
   we got on behalf of Ms. Myers.
   
   We then responded to the committee explaining what he had done. She
   had nothing personal, nothing in her personal possession beyond what
   we produced to the White House and a alerted you that you would hear
   from them. White House subsequently returned the original notebooks to
   us, and in the course of review of the notebooks for other purposes,
   just this week.
   
   Mr. Byers. That's correct.
   
   Mr. Romatowski. We recognized White House Travel Office references
   that we recognized were not included in the White House's original
   production to you. The one step I have skipped is to say that the
   White House gave to you from her notebooks. They also gave copies to
   us so we were acquainted with what you had received in these
   notebooks.
   
   When going through these for a different purpose, those additional
   references were recognized. We alerted White House counsel that
   perhaps what we asked, whether this had been overlooked or whether it
   wasn't required or what have you, they immediately requested a further
   opportunity to review these materials and the result of that is they
   concluded this ought to be produced just as fast as they could, which
   is in the last couple of days. That is how that happened.
   
   Ms. Bracher. For the record, we did receive it yesterday, the day
   before this deposition. You referred to a memo and I would like to put
   this in the record as Deposition Exhibit record number 14.
   
   The Witness. No, this is 14.
   
   Ms. Bracher. 15, thank you.
   
   (Myers Exhibit No. 15 was marked for identification.)
   
   BY MS. BRACHER:
   
   Q Ms. Myers, I would ask you if you recognize this memo, which is
   addressed to you from John M. Quinn, counsel to the President,
   regarding subpoenas issued by Government House Reform and Oversight?
   
   A Yes, this is the memo from which we took our direction, produced
   everything I had relative to my work at the White House to the White
   House counsel's office with production to you.
   
   Q There is a, if we go on back in your notes CGE 38347, the very
   bottom it states, "Hinson dash" and Hinson is H-i-n-s-o-n dash FAA
   Goodwin.
   
   Do you recall what the circumstances are under which you would have
   written down Hinson with the FAA?
   
   A Huh-uh.
   
   Mr. Romatowski. Do you recall what that is?
   
   The Witness. I have no idea what this is. "Predication," I know what
   that is. I have no idea what that refers to.
   
   BY MS. BRACHER:
   
   Q Above it is says, "freshman Republican, Harry Thomason's company,
   who was company, how much, who had dinner, Hinson FAA?"
   
   A I have no idea.
   
   Q Were you aware that Darnell Martens had written in a memo that he
   wanted to help select the FAA chief?
   
   A No.
   
   Q Do you recall ever being told that that was one the things Darnell
   --
   
   A It sounds absurd to me on its face, but I don't recall ever hearing
   it.
   
   Q Just to give you a reference in the January 29th memo, which is
   Deposition Exhibit No. 7, the very last action item for TRM was
   selection and policy recommendations for the FAA Administrator Hinson.
   Does that refresh and give you any additional --
   
   A It doesn't, and as I had nothing to do with the selection of those
   kinds of appointees, I can't imagine that -- it is not something that
   I would have ever been -- ever had anything to do with.
   
   Q I was just asking in relation to your notes if that jogs your memory
   why you would have written down FAA and Hinson's name?
   
   A Huh-uh.
   
   Q Page 38349 of your notes just simply says Travel Office and IRS, and
   I was just going to use this page as a means to ask you what your
   knowledge was of it -- the involvement in the whole Travel Office
   matter?
   
   A I don't know they had any. I know there were allegations in the
   press that Bill Kennedy had threatened to go to the IRS if the FBI was
   not responsive. Again, those were allegations being tossed around, and
   I don't have any information that that was true.
   
   Q Did you ever receive any knowledge to substantiate those
   allegations?
   
   A No, in fact the knowledge I received was that laid out in my notes
   about the chronology of events about Kennedy contacting the FBI.
   
   Q The very last page of your notes, which is CGE 38391.
   
   A The last page of this whole packet?
   
   Q Yeah, I believe it should be. At the very top it says, "it has
   aroused suspicion. We should do everything in power." And once again
   it refers to "Heymann/Reno have had a strong disagreement about the
   way this has all been handled."
   
   Do you know what that disagreement was?
   
   A Yeah, there was disagreement between the White House and the Justice
   Department, and I guess within the Justice Department about how
   documents in Vince's office were viewed subsequent to his death.
   
   Q Do you know what the disagreement was specifically between the two
   of them? In other words, what positions they were taking?
   
   Mr. Romatowski. Aren't we in the wrong committee for this? This one
   has been thrashed over at great length in the White Water Committee
   across the Hill.
   
   Ms. Bracher. Is this an objection? Vince Foster's notes, diaries and
   the findings of his documents are relevant in this investigation so
   far as he had a Travel Office file which disappeared for two years.
   
   Mr. Romatowski. We have literally done weeks on the search of Vince
   Foster's office. I am sorry. Is there a pending question?
   
   Ms. Bracher. There was one.
   
   Mr. Romatowski. Could you restate it?
   
   BY MS. BRACHER:
   
   Q I just asked specifically if you knew the position of Miss Reno and
   -- Attorney General Reno and Mr. Heymann concerning this disagreement?
   
   A I don't.
   
   Q If you go on two pages, I think the next page dates July 15th 1993,
   and the following page is CGE 38337 and says, "what White House role
   in persuading House Judiciary not to pursue travel investigation."
   
   Can you tell me the basis for that question insofar as you recall?
   
   A Probably it is a question from the press. It may have been one I got
   in the briefing or over the phone. I don't recall. Usually, when I
   would list questions they were press-generated questions.
   
   Q Do you recall any discussions as a result of that question?
   
   A No, I don't.
   
   Q Do you know of any White House role there was in persuading the
   House Judiciary not to pursue a travel investigation?
   
   A I don't.
   
   Mr. Romatowski. If any.
   
   The Witness. Yeah, if any. I don't know of any.
   
   BY MS. BRACHER:
   
   Q On January 4, 1993, in the beginning of the administration there was
   a meeting that was within --
   
   A January 4th, 1993.
   
   Q It was a Monday there was a meeting that was scheduled with David
   Watkins, George Stephanopolous, you and Jeff Eller. This followed a 2
   o'clock meeting which many of these people had with Betta Carney. Do
   you recall any meetings that you might have had in Little Rock with
   Betta Carney or World Wide Travel during this period?
   
   A None.
   
   Q January, early January 1993, late December 1992 early January?
   
   A I don't remember ever -- I don't know who Betta Carney is. She was
   from World Wide Travel? I don't remember ever meeting with her. We had
   a lot of meetings in that period about a lot of stuff, but I don't
   remember having any conversations about how travel would be handled
   until we got to the White House. Even then, until this happened.
   
   Q Do you recall any discussions about meetings that occurred about
   Catherine Cornelius and David Watkins about future travel in the White
   House Travel Office?
   
   A No, I sure don't.
   
   Q On May 1, 1993, Harry Thomason had a notation in his calendar of an
   11:30 meeting with you on communications.
   
   Do you recall that meeting?
   
   A I don't specifically, but as we talked about a little bit earlier,
   you had asked about his role as an image polisher or whatever it was
   and certainly that was something that he had been involved in during
   the campaign and I don't really remember specifically his involvement
   during those days at the White House, but it doesn't seem out of --
   completely out of the question. It is certainly possible to me that
   that would have happened.
   
   Q I have got an E-mail we are going to show you and see if you
   recognize this. It is an E-mail that was sent to Jeff Eller from a
   Lisa Mortman?
   
   A She worked for Jeff.
   
   Q It refers to a Tom Seam, S-e-a-m.
   
   A Producer at CBS. I never learned how to access E-mail at the White
   House though.
   
   Q We did not receive any E-mails, that may have been why. Here is the
   E-mail and I just asked you -- I think it probably, it is more
   explanatory now that I know that Tom Seam is a producer. "Tom called
   and wanted to arrange a meeting with you, Dee Dee. It is appropriate
   to talk about the network's concern for a set up at the White House
   Travel Office"?
   
   A I remember talking about -- in fact, we may have had this meeting.
   Tom Seams is a very straight-up good guy who is a veteran producer and
   had some suggestions for things that would be helpful to the
   television people in facilitating their travel at the White House.
   
   Q So this was dated May 20th?
   
   A It is entirely possible that he rightly had concerns about the
   upcoming trip and wanted to hear some of the things that the White
   House Travel Office did for us and --
   
   Mr. Romatowski. May 20th, 1856.
   
   Ms. Bracher. 1993.
   
   Mr. Romatowski. I am sorry, the time, the time occurs 18 after 56,
   which is before 6:00 p.m.
   
   The Witness. 7:00 p.m.
   
   Ms. Bracher. Those White House archives.
   
   The Witness. It took them a long time to produce that record.
   
   Ms. Bracher. On May 21st that Friday following, Harry Thomason had a
   message to call you specifically. Would that be in regards to the
   incidents that you described earlier with the press and questions.
   
   The Witness. Absolutely.
   
   Mr. Goldberg. The record should show, too, that Mr. Thomason's
   calendar was not all that accurate necessarily.
   
   Ms. Bracher. Do you have information of the inaccuracy?
   
   Mr. Goldberg. I think we had testimony of a prior witness that she had
   no idea how to enter these things correctly.
   
   Ms. Bracher. These are handwritten.
   
   We should make that clear then.
   
   Mr. Romatowski. This record should reflect that neither one is before
   us today, but we will accept your representation as to what it says.
   
   BY MS. BRACHER:
   
   Q I am asking Ms. Myers if she has any recollection or memory of any
   conversations.
   
   On June 25, 1993, which was, I guess, about 15 days after your White
   House Management Review, to put it in some sort of relation?
   
   A My interview in --
   
   Q For the White House Management Review was July 10th.
   
   Mr. Romatowski. It was repoliced in early July.
   
   Ms. Bracher. The actual interview.
   
   The Witness. With John Podesta?
   
   Ms. Bracher. Yes, and I think Dwight was there. They talked to you.
   This is just to put it in perspective on June 25th, 1993, there was a
   meeting that was scheduled between George Stephanopolous and you with
   the President. Do you recall that meeting?
   
   A We met with the President pretty much every day.
   
   BY MS. BRACHER:
   
   Q I guess my question would be if it had anything to do with the
   Travel Office during that period?
   
   A I don't recall ever meeting with the President specifically and
   there would be no reason I would have met with the President
   specifically about the Travel Office. We met every day about the
   scheduling of events and what have you. It could have been an
   interview. It could have been a number of things.
   
   Q Loraine -- did Loraine Voles work for you?
   
   A She did the first year.
   
   Q Then where did she go?
   
   A She is now the Vice President's Press Secretary.
   
   Q Was she working for you in August of '93?
   
   A Yeah.
   
   Q April of 1994 was a phone message that you had received to call a
   Charles Stein, and the message was about the Justice Department and
   Mr. Fiske. Do you know who Charles Stein, S-T-E-I-N, is?
   
   A I looked at the record of those recently and I remember that it is
   noted on the original record that he was calling from Orlando. And my
   recollection was that it was sort of -- what he wanted he was a bit of
   an odd ball.
   
   Q There was a phone log with a handwritten note that talks about
   information being passed on to Robert Fiske and you talked to Fiske's
   Secretary?
   
   A I didn't, I think he did, and he was trying to, for some reason,
   thought the White House urgently needed to know he had this
   conversation with Fiske's Secretary, which I am sure -- it is not
   germane to anything we were doing.
   
   Q On May 14th, 1994, you received a message from Catherine Cornelius
   to call in the Travel Office, and it says, re the Watkins issue?
   
   A That is probably in reference to the reporter from Business Week who
   had called.
   
   Q On June 9th, 1994, you received a message from Lisa Nibbons and the
   message said Bartlett and Gingrich hold press conference on demanding
   more info on Coptergate and in paren Carville and Bagala trips on
   board?
   
   A I believe what that was was just a press request, a reporter calling
   and saying she had attended the Gingrich-Bartlett press conference,
   which was probably here in Washington and that they had raised the
   fact, that inaccurate fact that James and Paul may have been flying on
   government helicopters, which probably I looked in and determined it
   was not true and got back to the reporter.
   
   Q Is there some references in your notes as well as a phone message
   and the phone message is August 4th, 1994. This one was from the
   Boston Globe, Mike Carnish. It says Maggie Williams and Foster files.
   My question is were you ever given any information concerning the
   Travel Office file that was in my Foster's office?
   
   RPTS STEIN
   
   DCMN QUINTERO
   
   [2:45 p.m.]
   
   A Not other than what -- than widely reported.
   
   Q Did you know of the Vince Foster Travel Office file --
   
   A I had no independent knowledge of it. It certainly became an issue
   that I was asked about as a Press Secretary. There was the White
   House's version of that which I believe, and then there are
   allegations of other things.
   
   Q I am asking back in January of '93 if you had any meetings that you
   attended or any independent knowledge regarding Mr. Foster's Travel
   Office file at the time.
   
   Mr. Romatowski. January?
   
   Ms. Bracher. July of '93.
   
   The Witness. The only thing I knew about what was in Vince's office
   was what was reported to me by Bernie Nussbaum and his descriptions of
   his review of that office, which had been widely covered in the press.
   He went through his own review of documents and said what he found in
   there.
   
   I have no independent knowledge of what was in Vince's office. I was
   never in his office looking through his files either before or after
   his death.
   
   BY MS. BRACHER:
   
   Q Did Mr. Nussbaum ever mention to you that there was a notebook that
   Mr. Foster kept that concerned the Travel Office?
   
   A No.
   
   Q I have a few other questions just from the press conferences that
   are fairly brief.
   
   During the press conferences on May 19th that you held, there were
   several statements, and I have it, the May 19th -- here if you want to
   look at it. There were several statements about Peat Marwick went in
   and did a full accounting. Then you made a statement that we think
   that we can save not only the government money but the press, and
   later discussion about the fact that you believed that there would be
   the same level if not a better level of service for the press and that
   you expected the cost to go down with the new Travel Office. Who
   provided that information to you?
   
   A I assume, and I don't have a complete memory of this, but that it
   was David Watkins.
   
   Q There is also a statement on that same date where you said: I think
   we will use a travel agent to do some of the actual booking of travel
   flights, which, as you know, they do on commission from the airlines.
   It doesn't cost anybody anything. The same question; do you know where
   you received that information?
   
   A Watkins and whoever else might have been there, Patsy. The
   implication was we would bring in American Express to handle a lot of
   what Travel Office employees had handled in the past.
   
   Q This was May 19th, the day of the firings where you were talking
   about commission from the airlines. Was that still your knowledge that
   it would be American Express on the 19th?
   
   A That was before, that was Worldwide. I must have thought -- I guess
   presumably it was Worldwide. That became a flap so we switched to
   American Express.
   
   Q So the reference would be that we will use a travel agent to do some
   of the actual booking of travel flights which you know they do on
   commission from the airlines and it doesn't cost anything; that would
   have been a reference to Worldwide Travel?
   
   A Right.
   
   Q Do you know where you received that information?
   
   A I assume from Watkins who briefed me on why we had done it, what we
   had done and what the benefits were.
   
   Q On the 19th, page 14, you also state that there are a number of
   charter companies out there who we can work with to provide the kind
   of service that we need and do it very quickly. Who provided you
   information that there were other charter companies out there that
   wanted to work with the Travel Office?
   
   Mr. Romatowski. Could we slow you down and ask for the opportunity to
   catch up to your references?
   
   Ms. Bracher. Page 14, of the 5-19 White House press conference. It
   says: I think at a minimum we can maintain the current level of
   service. We hope to improve it.
   
   Specifically, what I was asking about was the statement, but I think
   there are a number of charter companies out there who we can work with
   to provide the kind of service that we need and do it very quickly.
   
   BY MS. BRACHER:
   
   Q And the question was --
   
   A I assume Watkins also.
   
   Q Did there come a time where you found that there were not a number
   of charter companies out there who could provide the kind of service
   that the Travel Office needed?
   
   A No. I think exactly the opposite. I think there are a number of
   charter companies that do do it now.
   
   Q I am referring back to the memorandum that you wrote on May 24
   concerning Midwest's flight that they took.
   
   A That was one charter company, and I believe Midwest has been used by
   the White House subsequently and has performed quite well. There is no
   doubt the White House has used probably a dozen different companies in
   the years since this all happened.
   
   Q On the 20th press conference, there was a question which was posed
   to you about Worldwide Travel, and one of the reporters talked about
   complaints from people who had traveled during the campaign on
   Worldwide Travel and how they couldn't get billing, detailed billing.
   Were you aware of problems with Worldwide Travel that came from the
   campaign days?
   
   A There's always a few complaints when you deal in that kind of volume
   with that many people. There's always a few complaints. I don't think
   I had -- I don't think I knew about any of them in particular and I
   certainly hadn't received more than sort of passing references to it
   from any of the reporters that I dealt with every single day.
   
   Q On page 17, maybe I should turn to that page, the reporters go into
   a great deal of detail --
   
   A A reporter goes into a great deal of detail.
   
   Q Were there any meetings or discussions about those kinds of problems
   once Worldwide Travel was in the White House?
   
   A Worldwide Travel never came into the White House. American Express
   did because of the uproar over Worldwide Travel.
   
   Q So you are not aware of Worldwide Travel being at the White House on
   the 19th?
   
   A Maybe for one day, but Worldwide Travel and their billing practices
   never became an issue. They may have done one trip. They were replaced
   after that. I don't know whether they had a problem with billing
   practices pursuant to that trip, but given the volume of White House
   travel, one trip wouldn't have generated that much discussion.
   
   Q Are you aware of the circumstances under which Worldwide Travel left
   the White House on that Friday, the following Monday after the firing?
   
   Mr. Romatowski. Are we speaking now of Monday the 24th?
   
   Ms. Bracher. Yes.
   
   The Witness. Well, I think a big stink was made out of the fact that
   we had called for competitive bidding of charter travel and that no
   similar competitive bidding had been used to determine who the travel
   agent would be in the White House. Because of Worldwide's Arkansas
   routes, it was decided that even though they might have been the best
   and cheapest company, it wasn't worth the political risk. So they were
   replaced.
   
   BY MS. BRACHER:
   
   Q Did anyone tell you during the period from the 19th until the 24th
   that Steve Davidson had requested that the Travel Office employees be
   brought back in?
   
   A No. Who is Steve Davidson?
   
   Q He is one of the people from Worldwide Travel that was brought into
   the White House. Were you aware that Worldwide Travel was in town
   waiting to come to the White House before the actual firings on May
   19th?
   
   A Yes; I think I probably knew that. I learned after the fact.
   
   Q You did not have that knowledge, though, at the time of the firing?
   
   A I think I found out the day of the firing. They may have come a few
   days early. I think they did. But I didn't know that until the
   firings.
   
   Q Do you know who called them in a few days early?
   
   A I don't. I assume it was somebody in David Watkins shop.
   
   Q There was a statement that was made by Mr. Stephanopoulos during the
   May 25th press conference and it was his description of Harry
   Thomason, and he said that when Mr. Thomason was here, referring to
   the White House, he used the phone and the visitors lounge in the East
   Wing and that he doesn't work out of management offices and that he
   didn't have an office. Was that your belief of Mr. Thomason's status
   at the White House at that time?
   
   A Yes. As reflected in my notes, I did not know him to have an office
   and was told that he didn't. As George said, he used the visitors
   office in the East Wing.
   
   Q Do you know who told you that he didn't have an office at that time?
   
   A I don't. It might have been Harry, but I am not sure. It might have
   been Watkins, who was in charge of assigning office space.
   
   Q Did there come a time when you learned that wasn't a true statement?
   
   A No.
   
   Q You were never told that he did in fact have an office, and
   secretary, and a telephone and a computer?
   
   Mr. Goldberg. I don't think it has been established that he had a
   secretary and computer.
   
   Ms. Bracher. Mr. Goldberg, if you want to make a record, I will give
   you plenty of time.
   
   Mr. Goldberg. What is the foundation for your question?
   
   Ms. Bracher. I try to be polite during your questioning. That is not
   something I want to argue with you here. I will give you the document.
   
   BY MS. BRACHER:
   
   Q There was a question that you were asked on the 20th of May, if the
   individuals that were fired were informed of the allegations that were
   made, and your response on page 15 of the -- is, I think they knew. In
   fact, I know they knew about them -- referring to the allegations.
   Page 15.
   
   Your response is: I think they knew. In fact, I know they knew about
   them. They were interviewed during the financial review process and
   knew that the management of that office was under serious review.
   
   This was in response as to whether the Travel Office employees were
   informed of the allegations that were made from the podium, which I
   assume refers to the FBI investigation. My question is, was that a
   true statement that you made to the press?
   
   A To the best of my knowledge.
   
   Mr. Romatowski. Hold on now. If we are going to get into adopting
   word-for-word statements, we are going to sit and read this entire
   briefing.
   
   Ms. Bracher. Okay.
   
   Mr. Romatowski. Question and answer; not your paraphrase.
   
   Where do we start, counsel?
   
   Ms. Bracher. You have the entire press conference in front of you and
   you certainly can read it.
   
   Mr. Romatowski. Draw my attention to exactly the question and answer
   that you are referring to.
   
   Ms. Bracher. The question is: Dee Dee, when the individuals were fired
   yesterday, were they informed of the allegations that were made from
   this podium?
   
   Mr. Romatowski. Answer: I think that they knew about them. In fact, I
   know that they knew about them. They were interviewed --
   
   Ms. Bracher. I have already read that part. If you would like to read
   it to yourself, I will have time with the witness. I don't see any
   point in rereading it into the record.
   
   Mr. Romatowski. The point of rereading it into the record -- unless
   this is the game of "gotcha" that you talked about this morning.
   
   Ms. Bracher. I never said the word "gotcha." I think you started with
   the word "gotcha."
   
   Mr. Romatowski. The point of reading it is to make sure the witness
   has a full opportunity to consider the question and answer to which
   you refer. You know, this is not some careful academic exercise that
   was going on here. This is the rough and tumble --
   
   Ms. Bracher. Is there objection to me asking this question rather than
   you explaining press conferences? I think that is improper. This is a
   deposition. I am attempting to do your time schedule, and I would like
   an answer, unless there is an objection. I will consider any objection
   to that question.
   
   RPTS STEIN
   
   DCMN HERZFELD
   
   Mr. Romatowski. I am trying to explain why we can't tolerate your
   repeated interruptions to the full detail of this question and answer.
   
   Ms. Bracher. Please review it.
   
   Mr. Romatowski. Because what you have got here are a crowded room full
   of reporters asking questions on all different subjects from all
   corners of the room.
   
   Ms. Bracher. Mr. Romatowski, respectfully, it is not appropriate for
   you to be responding on the record during a deposition to what you
   believe was going on with Ms. Myers at a press conference that you
   were not at. All the question posed to Ms. Myers is, was that a true
   statement. It does not require you to explain the White House press
   conference circumstances. I object and do not want you to explain on
   the record what you believe the White House press conference was. If
   it is an improper question, please object, and we can discuss that.
   
   Mr. Romatowski. What is troublesome and what is improper and what
   really gives us pause is that you begin the process by denying us an
   opportunity to review matters germane to this deposition as to which
   this witness has been asked --
   
   Ms. Bracher. Do you have copies of these press conferences in your
   possession that you have reviewed with your client?
   
   Mr. Romatowski. Not this one, I don't believe. We perhaps have it
   available.
   
   Ms. Bracher. They are public documents that I am asking about.
   
   Mr. Romatowski. What is troublesome is the way you continue to badger
   and interrupt any effort by the witness to acquaint herself with the
   full details of what you are asking. And I have to say --
   
   Ms. Bracher. If you feel I have badgered your witness, I apologize. I
   don't think I have badgered her. What I have tried to stop is her
   attorney from making a record and describing events rather than having
   his client describe and answer a simple question.
   
   Mr. Romatowski. Once again, you continue to interrupt and browbeat and
   try to interfere with a full opportunity to consider context and
   answer questions accurately, fully informed as to the detail of what
   is written here.
   
   Ms. Bracher. Then take time to review it with your client. I will
   repose the question after you have had a full opportunity to review
   this.
   
   Mr. Romatowski. Do you have another copy?
   
   Ms. Bracher. No.
   
   Mr. Romatowski. Now, what is your question?
   
   Ms. Bracher. Whether that was a true statement.
   
   Mr. Romatowski. Which one?
   
   Ms. Bracher. I will reread the section for the record.
   
   BY MS. BRACHER:
   
   Q You stated that you thought that they knew, in fact, "I know they
   knew about them." That is in response to a question, when the
   individuals were fired yesterday were they informed of the allegations
   that were made from this podium?
   
   Mr. Romatowski. Actually you have just made the case in spades why
   your method is inadequate to the purpose and misleading, because you
   have just read a portion of an answer. The complete question and
   answer as it appears in the transcript is: Question: "Dee Dee, when
   the individuals were fired yesterday, where," w-h-e-r-e -- it appears
   to be a typo for were, w-e-r-e -- "were they informed of the
   allegations that were made from this podium?"
   
   Ms. Myers: "I think that they knew about them. In fact, I know they
   knew about them. They were interviewed during the financial review
   process and knew that the management of that office was under serious
   review."
   
   BY MS. BRACHER:
   
   Q Is that a true statement, Ms. Myers?
   
   A To the best of my knowledge, it is. One, I think we have already
   established that they -- when Peat-Marwick went in to do the review,
   they were interviewed as part of that process. And I don't -- and then
   of course David Watkins told them that they were fired. He told me
   that they were told that they were being fired because the office was
   poorly managed.
   
   The allegations from the podium the previous day were not anything to
   do with criminal anything. They were that the office was being
   mismanaged, and that as a result, they were being dismissed. I never
   made allegations of criminality, and I think I was the only person
   that was at the podium and questioned the previous day.
   
   Q So it was your belief that they, in fact, did know about the --
   
   A That they were being dismissed because of mismanagement.
   
   Q There is serious overbilling of the press, I believe, that you
   discussed on page 2 of that same date, that they knew that based on
   that decision, the decision was made that it was prudent to go forward
   with an investigation, which I believe you stated on page 7. Are those
   the allegations that you were thinking of, or were they other
   statements from the podium other than that?
   
   Mr. Romatowski. Counsel, if you are going to quote from a document,
   you will have to give me a reference.
   
   Ms. Bracher. You have the only copy of the document. I apologize. I am
   working from my handwritten notes.
   
   Mr. Romatowski. Now we are confused, because I thought what you
   purported most recently to quote from was a transcript of the briefing
   on the 19th.
   
   Ms. Bracher. Which I have written down the transcript from the
   briefing on the 19th, and I have it sitting before me. But the actual
   transcript I have given you as a courtesy, even though I assume you
   have a copy of it.
   
   Mr. Romatowski. I have the transcript for the 19th, and let me offer
   you back your copy, because what your notes have just demonstrated
   from your last previous question is that they are incomplete, hence
   inaccurate, and risk creating a misleading record as to what was asked
   and what was answered.
   
   Ms. Bracher. I would like an answer to the question.
   
   BY MS. BRACHER:
   
   Q On page 2, 5-19, one of the statements made at the podium was that
   "we think there has been some serious overbilling of the press." That
   was stated during the 5-19 White House press conference on page 2.
   
   During the 5-20 press conference on page 7, your statement was that as
   soon as the review has been made final and is final,"it will be
   forwarded to the FBI, and there will be an investigation."
   
   My question is that when you made this statement on 5-20, which I
   believe it is on page 15 --
   
   Mr. Romatowski. Can you give me the reference on page 7 on 5-20 again,
   please?
   
   Ms. Bracher. It starts with an answer by Ms. Myers that says, "The FBI
   interviewed the accountants over the weekend, and so they have some
   preliminary knowledge. Based on that, the decision was made that it
   was prudent to go forward with an investigation. Peat-Marwick did a
   review of the finances of the Travel Office. There is a draft report
   based on that review which is now being looked at by White House
   counsel. As soon as that has been reviewed and final, it will be
   forwarded to the FBI, and there will be an investigation."
   
   Mr. Romatowski. That is a portion of the paragraph I recognize. I
   didn't get an opportunity to follow it word for word except to notice
   you omitted certain portions , but I am not sure they are material.
   
   Ms. Bracher. I think the material part --
   
   BY MS: BRACHER:
   
   Q Ms. Myers, you were being asked if they were informed of the
   allegations that were made from this podium. Those allegations did
   include an FBI investigation?
   
   A An FBI investigation; I am not sure that is an allegation. I was
   under the impression, and I still am under the impression, that they
   were told they were being dismissed because of financial improprieties
   including alleged overbilling or actual overbilling, in fact, of the
   press.
   
   I don't want to get into a war of words, but of course I believe what
   I was saying was true. I don't know what they knew about the FBI, but
   I wasn't making any allegations of criminality. I did say that the
   Peat Marwick or whatever would be forwarded to the FBI.
   
   Did they know that before? I don't know. Was I answering a question
   saying did they know what the allegations were when dismissed? The
   answer is yes, of course, I think they knew. Of course I believe that
   David Watkins told them why they were being fired. I still don't know
   that he didn't tell them.
   
   Q By asking if it is a true statement, I only meant did you, in fact,
   believe it to be a true statement?
   
   A Of course I believed it to be a true statement.
   
   Q This does recognize, as Minority counsel stated, you were a conduit
   of other information to the press.
   
   A Correct, and I think I am still not sure that it is not true.
   
   Q You also on, January 20th, on page 16, state that you -- that Billy
   Dale never asked you for a meeting. Is that your belief, that Mr. Dale
   had never asked you for a meeting until that point?
   
   A That is still my belief. I know during his trial he said something
   else, but I never met Billy Dale. He never called me. If he ever asked
   for my assistance for a meeting, I was unaware of it. I will say
   categorically, if he wanted me, he didn't try very hard.
   
   Q The final question that I have really involves the documents that
   you reviewed before your deposition here today. If you could briefly
   recount what types of materials you did review and look at the
   material in light of the discussions on the record by your counsel. I
   would like a recounting as best you can of what you looked at prior to
   coming to this deposition.
   
   A I looked at, correct me if I am wrong, this May 20th notebook. I
   looked at -- I guess we went through everything that was produced, or
   we talked about things that were important. We talked about things we
   thought were important from documents produced from my notebooks. I
   looked at the transcript of my briefing from the 19th, from George's
   briefing -- from the 24th, and I think -- is there anything else?
   
   Mr. Romatowski. That is it. We didn't make a particular effort to keep
   track of exactly what pages she looked at, but she looked at pages of
   her notebooks.
   
   THE WITNESS: I reviewed the letter asking for notes from my previous
   interview.
   
   BY MS. BRACHER:
   
   Q Did you review any of the interviews that you had done with the GAO
   or the White House Management Review?
   
   A No. I didn't have access to any of the -- my interviews, but we did
   refer a couple of times to things that were in the Management Review.
   I didn't read it, the whole thing.
   
   Q By the Management Review, you mean the actual report that came out?
   
   A Yes.
   
   Q You said you didn't have any copies of your interviews. That would
   include any of your interviews with the White House Management Review
   or GAO or OPR?
   
   A Correct. We had no transcripts or notes from any of those
   interviews; only what was in the Management Review itself.
   
   Mr. Romatowski. Can we have a minute?
   
   Ms. Bracher. Certainly.
   
   [Discussion off the record.]
   
   Ms. Bracher. Back on the record.
   
   THE WITNESS: I want to correct something I just said. In addition, we
   had some handwritten notes that I believe were from my interview for
   the management report, which would have been John Podesta was there,
   and Dwight Holton, and I don't know whose notes they were. They were
   mostly illegible due to bad handwriting and bad copies.
   
   Mr. Romatowski. For the most part, you can't read them.
   
   BY MS. BRACHER:
   
   Q I have a copy I would like to show you to see if you can identify if
   these were the handwritten notes, although they might have been in a
   little better shape.
   
   A There were in worse shape. I don't think we had all of these. These
   are Dwight's notes?
   
   Q Yes.
   
   A Yes. These look like them, although they were much less legible than
   this.
   
   Q I will put the number in for the record, CGE 0374, which is the
   White House Management Review on June 10th.
   
   Other than these notes and your records that you have, were there
   other interviews or notes that you recall you read in preparation for
   this?
   
   A I don't believe so.
   
   Mr. Romatowski. No, not that I can recall.
   
   BY MS. BRACHER:
   
   Q Were there any other documents that you have in your possession that
   you now know might be responsive to any of the requests by this
   committee for documents from you that have not already been turned
   over?
   
   A No.
   
   Q In the letter that when the documents were turned over, it stated
   that there were no documents being withheld for privilege other than
   conversations that you had with your attorney about representation.
   Are there any documents that you know of that are being withheld?
   
   A No.
   
   Ms. Bracher. I am done. Mr. Goldberg, do you have anything?
   
   Mr. Goldberg. No.
   
   Ms. Bracher. The record is down. Over at 3:20.
   
   [Whereupon, at 3:20 p.m., the deposition was concluded.]
   
   May 30, 1996
   
   ERRATA SHEET
   
   Deposition of Dee Dee Myers
   
   before the
   
   United States House of Representatives
   
   Committee on Government Reform and Oversight
   
   April 19, 1996
   
   Page 31, line 6: Replace "why they" with "what".
   
   Page 38, line 23: Replace "sought" with "sort".
   
   Page 42, line 21: Insert period after first occurrence of "that".
   
   Page 42, line 21: Replace "is" with "It's"
   
   Page 42, line 21: Insert "we" after second occurrence of"that"
   
   Page 44, line 19: Replace "Levy" with "Leavy".
   
   Page 45, line 2: Replace "restrict" with "reconstruct".
   
   Page 47, line 7: Replace "times" with "the time".
   
   Page 49, lines 16 and 18: Replace "Markus" with "Marcus".
   
   Page 50, line 5: Insert a period after "specific".
   
   Page 50, line 19: Replace "to" with "through".
   
   Page 50, line 20: Insert "we" before "decided".
   
   Page 50, line 22: Strike "to".
   
   Page 50, line 23: Replace "Levy" with "Leavy".
   
   Page 51, line 24: Replace the comma with a period.
   
   Page 52, line 1: Insert "--" after"about".
   
   Page 52, line 25: Replace "companies" with "sitcoms".




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