Travelgate Depositions

MARSHA SCOTT



   COMMITTEE ON GOVERNMENT REFORM AND OVERSIGHT
   
   U.S. HOUSE OF REPRESENTATIVES
   
   WASHINGTON, D.C.
   
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   :
   
   In the matter of: :
   
   :
   
   WHITE HOUSE TRAVEL : DEPOSITION OF MARSHA SCOTT
   
   :
   
   :
   
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   Wednesday, June 19, 1996
   
   Washington, D.C.
   
   The deposition in the above matter was held in Room 2203, Rayburn
   House Office Building, commencing at 3:00 p.m.
   
   Appearances:
   
   Staff Present for the Government Reform and Oversight Committee:
   Barbara Comstock, Investigative Counsel; Kristi Remington, Majority
   Investigator; Daniel Hernandez, Minority Professional Staff
   
   For MARSHA SCOTT:
   
   STUART F. PIERSON, ESQ.
   
   DAVIS WRIGHT TREMAINE
   
   Suite 700
   
   1155 Connecticut Avenue NW
   
   Washington, D.C. 20036
   
   THEREUPON,
   
   MARSHA SCOTT,
   
   a witness, was called for examination by Majority Counsel, and after
   having been first duly sworn, was examined and testified as follows:
   
   Mr. Pierson. Before you begin, Ms. Comstock, I have a statement for
   the record.
   
   At our request the committee provided air fare for Ms. Scott to come
   here from Chicago and return. It turns out she came last night and did
   not use the tickets, so I am returning it to the committee unused.
   
   Ms. Remington. Are you able to use the second leg of the ticket?
   
   The Witness. I could, but --
   
   Mr. Pierson. We are prepared to give it back to you.
   
   Ms. Remington. You are more than welcome to use the second --
   
   Mr. Pierson. We would rather not.
   
   The Witness. Thanks.
   
   Ms. Comstock. I don't know how that is being handled.
   
   The Witness. We will give it back to the government. I think they can
   use it.
   
   Ms. Comstock. We are on the record this afternoon for the deposition
   of Marsha Scott, which will be administered under oath. I will
   identify who is here today. My name is Barbara Comstock. I am Majority
   investigative counsel. Kristi Remington; Dan Hernandez with the
   Minority.
   
   The Witness. Dan or Stan?
   
   Mr. Hernandez. Dan.
   
   The Witness. I can't hear today.
   
   Ms. Comstock. I would like to provide you with some background
   information concerning this investigation and your appearance here. As
   you know, pursuant to its 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 19th, 1993 firings
   of the White House Travel Office employees and includes all
   information provided about the White House Travel Office and any
   employees at the White House Travel Office at any time from January 1,
   1993 to the present.
   
   Our investigation also encompasses the activities of Harry Thomason,
   Darnell Martens and Penny Sample while they were at the White House,
   and it also includes all allegations of wrongdoing concerning Travel
   Office employees made by these individuals.
   
   The Committee investigation is reviewing all actions taken by the FBI
   and Department of Justice prior to and after the firings, and the
   investigation includes, but is not limited to, the investigation and
   prosecution of Billy Ray Dale and all investigations and subsequent
   reviews of the Travel Office firings by any agency including, but 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 U.S. House of Representatives
   "Resolution of Inquiry" considered and voted on in July of 1993.
   
   We are reviewing all actions relating to or describing the criminal
   investigations into the White House Travel Office matter including any
   subsequent action or activities of any kind as a result of the
   above-mentioned events by the White House, the Treasury Department,
   the IRS, the General Services Administration, the General Accounting
   Office, the Federal Bureau of Investigation, the Independent Counsel
   (both Mr. Fiske and Mr. Starr) and the Department of Justice up to the
   date of this request unless otherwise limited.
   
   Do you understand that your answers are to include all information
   which you have involving these subjects?
   
   The Witness. Yes.
   
   Ms. Comstock. 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 7th, 1996. Pursuant to
   Committee Rule 19, Majority counsel and Minority counsel will be
   afforded an equal opportunity to pose questions to each witness.
   
   You are here today voluntarily and not by subpoena; is that correct?
   
   The Witness. Yes.
   
   Ms. Comstock. And you understand this deposition is under oath, and we
   have sworn in the witness this afternoon. If you don't understand any
   question and you need time to confer with your attorney, please let me
   know, and we can stop. Or if you need to have me rephrase a question,
   let me know that also.
   
   I ask that all objections raised by your attorney be stated for the
   record with the reason for the objection clearly stated.
   
   You will be given a 5-day time frame in which you and your attorney
   may review your deposition once it has been transcribed and to correct
   any technical problems that you perceived occurred in the
   transcription and to clarify any matters. We have an arrangement where
   we can mail the deposition with a confidentiality agreement for people
   out of town.
   
   Mr. Pierson. You will want to mail that to me.
   
   Mr. Hernandez. The Minority has a brief statement that it does the not
   necessarily agree with the scope of the investigation as outlined by
   the Majority counsel.
   
   Ms. Comstock. Do you have any questions before we get started?
   
   The Witness. I don't think so
   
   EXAMINATION BY MS. COMSTOCK:
   
   Q Could you give us a brief work history from college forward?
   
   A Let me see.
   
   Q We are doing this to everybody.
   
   A I am 49. That is going to be hard to do. I worked in Head Start as a
   Head Start teacher; was an interior designer for 14 years. I had my
   own business for 3 of those 14. I did design remodel construction. I
   managed a furniture store. I have sold newspaper advertising. I worked
   for Senator Fulbright for 3 years; gone to school in and out of that
   time. That is kind of the basics.
   
   Q And your position when you joined the White House in 1993?
   
   A Deputy Assistant to the President and Head of Correspondence and
   Presidential Messages.
   
   Q And prior to joining the White House in that position, had you
   worked on the Clinton campaign?
   
   A Uh-huh.
   
   Q And what position did you have in that campaign?
   
   A In the primary I developed field operations and was field director
   in California; and in the general I was the Northern California
   campaign director.
   
   Q Are you -- you have been living in California prior to --
   
   A About 19 years, uh-huh.
   
   Q And when you joined the White House in the Correspondence Office,
   how long did you stay in that position?
   
   A About a year and a half; a little over a year, maybe not quite a
   year and a half.
   
   Q And then what did you do after that?
   
   A Then I went -- I think I was under the Office of Public Liaison and
   then moved to the political office.
   
   Q That was all at the White House?
   
   A Uh-huh.
   
   Q And what is your current position?
   
   A I am now in the Chief of Staff's Office until tomorrow or the next
   day. Then I will be in Chicago in charge of the VIP operations at the
   convention.
   
   Q How long have you known the President and Mrs. Clinton?
   
   A Well --
   
   Mr. Pierson. Let's break it down. Let's take the President first.
   
   The Witness. I have known the President since I was 18 or 19, and I am
   a year younger than he is, so however many years that is. I have known
   Mrs. Clinton as long as they have been married, and I may have met her
   before they married, I could have. So a long time.
   
   BY MS. COMSTOCK:
   
   Q Do you know Harry Thomason?
   
   A Sort of.
   
   Q Do you know how long you have known Mr. Thomason?
   
   A I won't say I really know Harry. I know who he is. I have probably
   spoken to him twice, maybe three times. That's been since after the
   Inaugural probably, since we have been up here. I don't think I ever
   had contact with him prior to working up here.
   
   Q So while you were the field director in California, you did not work
   with Mr. Thomason?
   
   A My territory went from Bakersfield up, and he lives in Southern
   California, and we ran two very distinct and separate campaigns.
   
   Q Did you know Craig Livingstone at all during the campaign?
   
   A No.
   
   Q Do you know who Craig Livingstone is?
   
   A Uh-huh.
   
   Mr. Pierson. You need to answer orally.
   
   The Witness. Yes.
   
   BY MS. COMSTOCK:
   
   Q Did you work at all at the White House with Craig Livingstone?
   
   A Everybody works with the Security Office, so in that sense, yes, and
   because I was hiring a large number of staff in the beginning, and
   they all had to be vetted in, they go through him. So in that sense,
   yes.
   
   Q When did you first meet Catherine Cornelius?
   
   A I might have seen her after the election in Little Rock because I
   went to Little Rock and worked on the economic conference. If she had
   been in Little Rock at the time, I would have met her then, I would
   assume, but I don't have a memory of that if I did. I didn't know
   Catherine prior to.
   
   Q And did you come to know Ms. Cornelius during your time at the White
   House?
   
   A Yes.
   
   Q And did she work for you at any time?
   
   A Yes.
   
   Q Could you describe how that came about?
   
   A I think it was -- you probably know this better than I. I don't know
   whether it was before she was in the hospital or after she was in the
   hospital coming back. That part I don't remember. She worked for me
   for maybe 6 weeks, maybe 3 to 6, somewhere in there. Catherine was
   still, I think, real sensitive and real sickly, and she was a sweet
   kid, and I had an opening, and I thought she could help.
   
   Q This was following the events with the Travel Office firings?
   
   A Yes, but I honestly don't remember where in that sequence of events
   in that time period in there, but it's a short period of time.
   
   Q I will return to that, and I do have some documents that may assist
   in discussing that more.
   
   How long have you known David Watkins, or do you know David Watkins?
   
   A I have known of David for a long time.
   
   Does the air seem weird in here to you? My eyes are getting really
   dry.
   
   I don't think -- I think the first time I actually met David was at
   the New York convention in 1992, but I had known who he was for a long
   time just because he was a friend of the President and prominent in
   Little Rock. I think his wife, I think, played tennis with my mother,
   so I think that is how I knew who he was.
   
   Q Your family is in Arkansas?
   
   A Little Rock, uh-huh.
   
   Q And how long did you know Mr. Foster?
   
   A I got to know him better up here. There again, I think I met Vince
   years and years ago, probably after I was out of high school, because
   we have a lot of mutual friends, but I don't remember when I actually
   knew that I knew Vince.
   
   Q Who is your direct supervisor in your first position at the White
   House?
   
   A John Podesta.
   
   Q Could you describe your -- what the duties of your job entailed and
   how you -- the duties of your job?
   
   A It was at the time I came in, it was the largest -- historically
   largest department in the White House when I came in. I think there
   were 11 or 12 offices that fell within that scope, and essentially it
   was taking care of any of the correspondence in or out, and
   correspondence in the sense of any packages, letters, phone calls,
   faxes.
   
   We subsequently within the first year set up an e-mail system, which
   hadn't been in existence until our coming in. The postal service was
   under me, the volunteer -- I set up a volunteer program in the White
   House. We initially set up the intern program there. We also had a
   small sort of little-known agency that has historically been in the
   White House called an agency liaison that essentially acts as a social
   service department where people who -- for instance, if they couldn't
   get a veterans check, and they felt like they had a grievance against
   the government in some way that something was working, they would call
   the President or write their President, and we would refer that into
   this office. Then we would try to track it through the system.
   
   Q Sort of caseworking?
   
   A Yeah, exactly.
   
   Then the rest was just the routine movement of correspondence. Then we
   created all the messages and proclamations that are read before
   Congress, all the official-sounding stuff.
   
   It was a big department. I think when I came in, there were, if I
   remember correctly, 100 -- I want to say 36 to 140 people that were on
   the rolls, and that had been downsized due to attrition from the Bush
   administration. They just didn't fill jobs as people were leaving to
   find other jobs.
   
   So I inherited a fairly large -- even though "career" is not the
   proper word -- people who had been working in the White House for many
   years. So I had what was as close to being called a career staff
   initially.
   
   Q Were there people let go? Was that one the office that has had a
   large number of people let go in the early days?
   
   A Yes, uh-huh.
   
   Q And can you describe how that process -- how that came about?
   
   A It was one of our commitments during the campaign, subsequent -- I
   think we started it during the campaign, but it became something that
   we focused on very, very early that we would do a 25 percent budget
   reduction and 25 percent staff reduction, so I came in knowing that
   the size of this department that I inherited was going to be cut. So
   one of my first jobs was to scale down the budget to reflect this 25
   percent budget cut and cut back staff position.
   
   So it was sort of a twofold effort that I went about doing. One was
   restructuring the department to reflect a new President in the way
   this new President wanted to do his correspondence. And also at the
   same time I had to factor in that we had to cut the overall amount of
   the slots for the department. So I eliminated jobs and moved people in
   different positions and out of positions.
   
   Q In that first six months that you were in the new administration in
   1993 or thereabouts, do you recall any discussion about using
   Presidential Inaugural Commission funds to assist the Correspondence
   Office?
   
   A There was a discussion -- let me see if I can remember this. No. I
   mean, the first answer is no, I don't think there was ever a serious
   discussion of doing that, but I think there was a lot of discussion. I
   don't think -- I know we had lots of discussions about how we could
   take care of the huge volume. I hope this is in there.
   
   The President -- Bill Clinton -- in his first year we had six times
   the amount of correspondence that President Bush had had. So by March
   of that first year, we were getting approximately 83,000 types of
   correspondence in on a daily basis. We had a backlog that grew
   exponentially. We had to have some way to respond to it. Unlike our
   predecessor, we were committed to answering every letter. That had not
   been the policy of the Bush administration, nor had it been the policy
   of the Reagan administration, but it was our policy, so we were
   looking for ways we could do that. We didn't have the staff to do it,
   so we were trying to figure out other ways. If that would have come
   up, it would have come up in that context.
   
   Mr. Pierson. I have a statement for the record. I am not sure whether
   or not to object to that question. It is not clear to me how questions
   about the expenditure of the Presidential Inaugural Commission funds
   relates to the Travel Office matter which you have described in your
   preliminary statement. I will take your representation this is
   germane, but I have an objection if it's not.
   
   Ms. Comstock. Okay, well, I will -- I think as we go into the
   questioning it may become more apparent.
   
   BY MS. COMSTOCK:
   
   Q Were you aware of Mr. Foster or Mr. Thomason working on how to use
   the Presidential Inaugural funds in any way to assist your office at
   any time?
   
   A Mr. Thomason or Foster?
   
   Q Harry Thomason?
   
   A No.
   
   Q Or David Watkins being involved in any such efforts?
   
   A David I know was trying to figure out ways -- David was head of --
   what do we call that -- management operations, so we all reported back
   to him. In other words, staff secretary, I think, was right under
   David, so that would have been his responsibility to help us figure
   out how to take care of the backlog.
   
   Q And did anybody ever at any time to the present discuss with you any
   notes that Vince Foster had had about this use of PIC funds for the
   Correspondence Office?
   
   A Has anyone ever discussed that with me?
   
   Q Yeah.
   
   A No.
   
   Q Do you know what the Hope Foundation is?
   
   A Is that to do the --
   
   Mr. Pierson. Answer the question.
   
   The Witness. No, I am not sure I do. No.
   
   BY MS. COMSTOCK:
   
   Q Do you know anything about PIC funds -- Presidential Inaugural
   Commission, known as PIC. PIC money being used as the Hope Foundation?
   
   A No, no.
   
   Q When you said you had had discussions with people about how to deal
   with the backlog, do you recall who those discussions were with?
   
   A Our entire staff, we met as a group with all the staff directors,
   and so we met once a week, and we were always trying to figure out
   ways to take care of that backlog, so we would discuss that daily.
   
   Q People within your office?
   
   A Within my office. Then I would have discussed it in my meetings with
   John Podesta. I know that at some point we had a meeting. I don't know
   who was there, but David Watkins was at some point discussing it with
   us. I did a presentation --
   
   Mr. Pierson. Time out. What is the "it"?
   
   The Witness. How to get rid of the backlog. Isn't that the original
   question?
   
   BY MS. COMSTOCK:
   
   Q Yes, who you were discussing the backlog, and what to do with the
   backlog?
   
   A I think I probably talked to everybody in the world because it was
   plaguing me, and I was looking for some creative ways to do it. Any
   meeting I would have been in would have been -- my number one priority
   was getting help on taking care of the backlog.
   
   Q Do you recall having any meetings with Harry Thomason in the spring
   of 1993 about this topic?
   
   A I don't know that I have ever had a meeting with Harry. I would say
   -- I don't think I have ever had a meeting with him.
   
   Q Do you know if anyone brought this to his attention?
   
   A That I don't know. If so, he never came up with a solution, so --
   
   Q What process did you report to Mr. Podesta? How did that
   relationship work in terms of reporting?
   
   A Sometimes he would come to my office, and we would meet. I would go
   to his office and meet with his staff. We met irregularly. I think, if
   I remember correctly, we had scheduled staff meetings, but we didn't
   always hold them. Just because we said there was going to be a staff
   meeting doesn't necessarily mean I went or we had the staff meeting. I
   think we had the regularly scheduled times, whether it was once a week
   or in the morning, but whatever it was, it was at 9 o'clock in the
   morning.
   
   Q Did there come a time in the spring of 1993 when you learned that
   the White House Travel Office employees were going to be fired or had
   been fired, depending on when you learned?
   
   A I did not know they were going to be fired. I only knew that they
   had been fired, I think, from the press. I am trying to remember. I
   probably saw it on TV or something.
   
   Q Had you ever heard of any rumors of wrongdoing in the Travel Office
   prior to hearing about that report in the press?
   
   A Yes.
   
   Q And who did you hear that from?
   
   A Probably from people on my staff. Like I told you, I inherited
   career -- what I would have called a career staff, although, you know,
   there is no such thing in the White House. But I had a large number of
   people who had been there, and I believe at the time there was one
   woman who had worked there under Eisenhower, so I had people going all
   the way back.
   
   The people initially -- all the people that had to staff up the
   Executive Office, which was my suite of six offices, were all from
   this career pool because they were -- there was a secretarial pool. At
   the time they were the only people that could take dictation and type,
   and when we came in the White House, there was a subpoena for all our
   hard drives. We had no computers, we had typewriters, and not many of
   my staff typed, so we had great use for this -- for their services.
   And they talked about it.
   
   Q Do you recall what they said?
   
   A It was kind of anecdotal stuff. One of the things when I come into
   any new company or new place is I want to find out who works there,
   how do you get things done, how do you get your carpet cleaned, how do
   you get your supplies in the room.
   
   We had nothing. When you go into the White House, there isn't
   literally anything in the room except a desk, a chair, and in my case
   a computer on the floor and a typewriter. So we had to stock up with
   everything. So I was asking everybody, and I went around and met
   everybody on my floor, and my floor was the floor that the Travel
   Office was on. They were right down the corridor from me.
   
   So I made it a point to know everybody on this basement floor, and I
   also made it a point because my offices were scattered all over the
   building, and I wanted them condensed into one area, so I was partly
   looking at office space that we could horse trade over to get.
   
   So in the course of this, I went and asked people now who works here,
   who are they, and in conversations over a period of time, different
   people had told me that the Travel Office people were really nice, and
   they'd been there a long time, and they had a great deal going. And I
   asked what the great deal was. The implication was -- and I apologize,
   I don't remember the exact words -- was that it was sort of a quid pro
   quo arrangement, and they did favors for the press, and the press did
   favors for them.
   
   And there were some anecdotal stories. One involved one of the
   reporters who supposedly brought back these Oriental rugs, these
   expensive rugs, and didn't want to pay the tariffs on them. So he put
   them on the press plane, and Billy Dale's office arranged all that,
   and this was pretty common practice, and if -- the Press Office always
   had sort of goodies, and I didn't pay much attention to it beyond
   that.
   
   Q Did you talk to anyone else about that?
   
   A Probably.
   
   Mr. Pierson. You mean other than her staff?
   
   BY MS. COMSTOCK:
   
   Q Other than your staff?
   
   A Probably, because I thought that was kind of bizarre, but I don't
   remember making an issue of it at all, no.
   
   Q Do you recall talking to Mr. Foster or Mr. Kennedy about it?
   
   A I don't recall that. I could have.
   
   Mr. Pierson. Let's make sure we understand what it is you are talking
   about, anecdotal rumors.
   
   Ms. Comstock. Yes.
   
   The Witness. I don't recall.
   
   BY MS. COMSTOCK:
   
   Q Do you recall if you ever told the President about that?
   
   A I doubt if I ever did.
   
   Q Or the First Lady?
   
   A No, I don't recall.
   
   Q In the spring of 1993, did you ever see Harry Thomason at the White
   House; spring, summertime?
   
   A Right somewhere in there. I don't know if I do remember seeing him
   there. Probably.
   
   Q Did you have any knowledge what he was doing at the White House at
   that time?
   
   A If I did, I probably knew it at one time, but no, there was no
   reason for me to know what he was doing there or not, so I am not sure
   I would have paid any attention to that because I didn't really know
   him.
   
   Q Did you have any knowledge he was working on an imaging project
   whereby he was going to bring many folks from California to try and
   improve the President's public relations?
   
   A No, but it was probably a good idea at the time.
   
   Q Did you ever hear anybody say firing the Travel Office would be a
   good press story?
   
   A That firing them would be a good press story? No, I can't believe
   anyone ever said that.
   
   Q You hadn't heard any reports of that?
   
   A No.
   
   Q After the Travel Office employees had been fired, did you talk with
   anybody in your office about what had occurred?
   
   A Probably.
   
   Q Do you recall what you discussed with them?
   
   A Too long ago. That is old news.
   
   Q Do you recall anything that anybody at the White House told you
   about why they had been fired aside from what was in the press
   reports?
   
   A It is all too jumbled now. No, unfortunately I don't.
   
   Q Did you become aware of a management review that was conducted under
   the auspices of Mr. McLarty, under him Mr. Podesta, that was going to
   review the Travel Office firings?
   
   A I did know that, uh-huh.
   
   Q Did you ever discuss that --
   
   Mr. Pierson. Time out. Just so we make it clear, did you know before
   it was to happen, or did you know afterwards, or do you remember?
   
   The Witness. I don't know. I worked for John, so I probably -- if he
   knew, I might have known. I don't know.
   
   BY MS. COMSTOCK:
   
   Q And placing it in a time frame, the firings occurred on May 19,
   1993, and the review was completed on July 2nd, 1993. Do you recall
   discussing the review at all with Mr. Podesta?
   
   A No.
   
   Q Were you aware of any unhappiness of White House staffers with the
   review process?
   
   Mr. Pierson. The review process you are talking about --
   
   Ms. Comstock. The review Mr. Podesta was doing.
   
   Mr. Pierson. Of the Travel Office -- of the Travel Office, are you
   aware of people complaining about --
   
   The Witness. About John?
   
   BY MS. COMSTOCK:
   
   Q About the review Mr. Podesta was doing.
   
   A There again I don't -- no, I don't have a specific recollection.
   
   Q Following the firings, the issue of Catherine Cornelius being put
   into the office became a big press issue, I guess it is fair to say.
   
   A Put in which office?
   
   Q Being put into the Travel Office, at the time that a cousin of the
   President's was being put into the Travel Office.
   
   A She was an incredibly distant cousin.
   
   Q I guess we didn't know what level at that point.
   
   Did you have any discussions with anyone about Catherine Cornelius'
   role at the Travel Office?
   
   A I am sure I did.
   
   Q Do you know who you would have discussed that with?
   
   A Probably everybody. I am -- particularly back then was pretty
   opinionated, so I am sure -- anyone who was talking about it, I am
   sure I weighed in.
   
   Q Do you recall what your opinion was at that time?
   
   A I like Catherine. I still think she is a delightful person, and I
   felt very badly for her being so young, caught up with such a public
   display, and I was always worried about her, her health, and I didn't
   like to see anybody in that position. So I didn't like it.
   
   Q Did you discuss this with Catherine?
   
   A Uh-huh.
   
   Mr. Pierson. You need to answer audibly.
   
   The Witness. Yes, I did.
   
   BY MS. COMSTOCK:
   
   Q What did Catherine tell you about the events?
   
   A I don't know that we talked about the events. We talked about how
   she felt and what it was doing to her, and I was -- I was less
   concerned about the details by then. What the press was saying and
   what others was saying was less important to me, but how it was
   affecting the people that were being talked about was important to me,
   and she was a really nice young lady, and she could hardly talk at
   that time without crying, and so I really tried to help her
   emotionally.
   
   Q And were you aware of any problems that she was having with David
   Watkins at that time following the firings?
   
   A I think Catherine felt probably very alone and very upset, and so I
   don't remember that she had specific problems with anyone. I think she
   had problems with everything and everyone, and that is a very lonely
   feeling when you are only 20 something years of age, and you are
   singled out by the press as being a malicious person who has been
   sneaking around doing things. So I imagine she was upset with
   everybody at that time period.
   
   Q Do you recall her discussing who had asked her to undertake the
   activities that she did in the Travel Office?
   
   A You all should have done this back then. I am sure we discussed a
   lot of things. I apologize, I just don't remember the specifics.
   
   Q Do you recall if she ever told you that David Watkins had instructed
   her?
   
   A See, I know that now from having read so much about it. I don't know
   who I know that from. I don't know that I know that as a fact. I know
   that as it is stated, and I don't know where I know that.
   
   Q Have you talked with Catherine Cornelius recently at all?
   
   A Recently being like --
   
   Q In the past several months?
   
   A Probably not. I may have seen her in the hall once or twice. We now
   work in different places.
   
   Q Do you recall if she ever told you anything about having problems
   with Patsy Thomasson in her office?
   
   A There again, I don't have a specific memory of a conversation on
   that.
   
   Q Do you have any general recollection?
   
   A Well, Patsy worked, came in at some point, and I don't remember when
   Patsy was hired, but she came in at some point and was David Watkins'
   deputy and -- I am trying to remember.
   
   At one point Patsy and I had offices right next to each other. The
   problem is what I think I remember anymore I can't attribute to anyone
   anymore. There has been too much written about it and said about it.
   It is not -- it wasn't useful information to me, so I haven't kept it.
   
   Q Do you recall if Catherine ever told you that Patsy or David were
   trying to get her to leave her job following the firings?
   
   A I believe that to be true, but I don't know -- I don't know that
   Catherine told me that. Too much -- it has been too long. Too much has
   happened since then. I am so uninvolved with this issue. This has not
   been information that I have made any attempt to keep in my head. And
   my concern was over all of those people involved on an emotional
   level, less so on the details of what was going on. I wasn't involved
   in rebuilding the scenario, but I felt very personally involved in
   trying to help people rebuild their egos around it. So I just didn't
   deal with those kinds of facts that you want.
   
   Q Do you recall if one of the things that Catherine was upset with at
   the time was that she might be fired or asked to leave the White
   House?
   
   A Sure that scared her. She was a young kid. She didn't know what kind
   of protection she would have. She didn't know if she would be able to
   keep her job. I do remember that kind of concern.
   
   Q Did she talk to you about that?
   
   A She talked about her fears about her life, that she was ruined at a
   young age, that everyone in the country thought she was one kind of
   person when she was another, and it has hard to imagine where you go
   after that when your public humiliation occurs in the White House. It
   is very hard to think beyond that. She was, I think it is fair to say,
   terrified about what her life was going to be like, how people would
   treat her, whether she could get a job, and so the thought of losing a
   job factored in on the same level as what do I do with the rest of my
   life now; how do I get my life back?
   
   Q Did she ever discuss with you that she was just following directions
   that individuals gave her?
   
   A Here again, these are impressions. I don't remember exact words, but
   my impression always of Catherine was of a young person, smart,
   capable, but still a young person, in an organization, and I would
   just -- knowing Catherine, I would be very surprised that she would
   have taken actions on her own.
   
   So -- I know what has been said, and I am really trying very hard to
   separate what has been said and what I think I know she may or may not
   have told me, and I just know -- what I know of Catherine from that
   time period is that she would have been working within -- she wasn't a
   rogue, she wasn't a freelancer. She would have been working within
   some sort of context of a chain of command. That is not even a good
   word. I don't even know who her immediate supervisor was at the time,
   but she would have reported to that supervisor. She was a young staff
   person. She would have told people about what she was doing.
   
   Q And do you recall if she ever discussed with you that she was sort
   of being asked to take the fall for this action when she really
   hadn't?
   
   A I remember Catherine feeling that way. I don't remember her telling
   me she'd been asked to do that. I know she felt that way, and I think
   that is a pretty natural feeling, particularly because she was so
   young, and she didn't have the depth of relationships that other
   people had because they were older and had been working together and
   knew each other longer. I think you are fair in assuming that she felt
   that way.
   
   Q Do you recall on July 2nd, when the report was released, Catherine
   Cornelius was one of the people that was reprimanded for the Travel
   Office firings and her actions related to that. Do you recall
   discussing that --
   
   Mr. Pierson. You have two questions.
   
   The Witness. Yes, I recall that.
   
   BY MS. COMSTOCK:
   
   Q And in that context do you recall having any discussions with her
   about that reprimand?
   
   A I know that I had discussions with Catherine. I don't recall
   specific ones, and I tried to -- I actually tried very hard to check
   in with a lot of people during that period to help them keep their
   spirits up.
   
   But I don't remember a specific -- any one specific conversation.
   
   Q Could you recall if you had discussions with other -- any of the
   other people that had been reprimanded?
   
   A Tell me who they were again.
   
   Q Mr. Kennedy, and Jeff Eller and David Watkins.
   
   A I feel pretty confident that I probably went to each one of those
   people and told them that I thought it was awful. I was sad for them,
   was there anything I could do to help, to hang in there, don't get
   discouraged, this will pass; that kind of stuff.
   
   Q Do you recall any conversations that you had with Mr. Foster around
   this time frame, being the release of the report, early July?
   
   A I don't recall any specific conversations, but it would have been
   something I would have talked about a lot. I would have talked about
   how people would have felt, how I felt, how sad it was, how wrong I
   thought it was. I didn't like the way the press was doing it and
   handling it. I don't remember a specific conversation.
   
   Q So you generally recall having conversations with Mr. Foster as well
   as others?
   
   A That is not really fair to say, no.
   
   Mr. Pierson. Time out. On this subject or generally?
   
   Ms. Comstock. On this subject, on the release of the report and the
   reprimands.
   
   The Witness. I want to -- I am sure that I did talk to Vince about it,
   but I don't remember a specific conversation.
   
   BY MS. COMSTOCK:
   
   Q Do you recall how that type of conversation would have come up with
   Mr. Foster? Would it have been in the office?
   
   A Probably wouldn't have. I probably would have brought it up. Vince
   was not a man that talked about his business. He -- that wasn't the
   nature of my relationship with Vince.
   
   Q Do you recall were you talking to him as a friend in this context of
   how --
   
   A I didn't work directly with Vince. There were rare occasions that I
   ever used him. I think the counsel -- he was not the counsel assigned
   to my department for any legal issues I might have had, so my
   conversations with Vince were friend to friend.
   
   Q And did he ever tell you any concerns he had about that there would
   be ongoing investigations about the Travel Office matter?
   
   A I don't remember that. That -- no, I don't remember that.
   
   Q Can you recall generally at all what he discussed about the Travel
   Office matter, some general discussions you may have had with him?
   
   A It is really important to remember at the time we had no context of
   ongoing investigations. There weren't investigations going on. We
   didn't have a history. We didn't know this was the way things were
   done here. There was no assumption that because something had happened
   that there were going to be subsequent investigations going on
   forever. We are almost 4 years later still talking about this issue
   that never came up.
   
   Q At this time, after Mr. Dale had been fired, there hadn't been a
   criminal investigation started as a result of that, if I could refresh
   your recollection in terms of investigations.
   
   Mr. Pierson. Objection. Ask the question. Don't make a statement. Are
   you asking whether she knows that to be true --
   
   BY MS. COMSTOCK:
   
   Q Do you recall having any knowledge about there was a criminal
   investigation about the Travel Office at this time?
   
   A Before Vince died?
   
   Q Uh-huh.
   
   A When did they start it? I don't know that I knew that.
   
   Q When the employees were fired, do you recall there being statements
   when the employees were fired that the FBI was investigating?
   
   A Right, I do remember that. There was a press conference.
   
   Q And in that context do you recall Mr. Foster having any concerns
   about that investigation going forward and what that might mean for
   the Counsel's Office tour for him personally?
   
   A No, I am going to Help you. I don't think you are asking -- I don't
   remember him being concerned about the investigation going forward. I
   don't remember that at all. I remember him being concerned about the
   firings themselves and the reprimand. That is what I remember him
   being concerned about, but I don't remember a concern about what you
   just asked me, about having implications on the Counsel's Office or
   ongoing investigations.
   
   Q When you say you recall him being concerned about the reprimand, was
   that about the reprimand that he might get in the matter?
   
   A No, I don't think Vince was ever -- no. He was concerned about the
   effect it had on the people that were reprimanded, and it was a
   concern that I shared, and it was something I talked to him a lot
   about.
   
   I believe that while those people may or may not have been involved in
   it, and I have been very public about this, I felt it was the Chief of
   Staff's responsibility, and that is where it should have rested.
   
   So I discussed that with Vince, that I thought that these four other
   people were being singled out when it was my opinion that when a
   mistake is made, if you are head of the office, you take the
   responsibility for it.
   
   Q And did you have knowledge that Mr. McLarty had been involved in the
   decision-making process of firing employees?
   
   A He was the Chief of Staff, so it was an assumption. I don't know if
   I knew the specifics.
   
   Q Aside from him being Chief of Staff, do you have any recollection of
   knowing any involvement he had in the process leading up to the
   firings of the employees?
   
   A I didn't know anything about the firing of the employees until it
   was -- until you knew about it probably, so I don't know anything
   about the process leading up to it.
   
   Q After the fact, do you recall learning anything about Mr. McLarty's
   role?
   
   A From the papers, uh-huh. It is really hard. I know that you want to
   know what I know, when I knew it, and I don't know what I know because
   I have read too much about it. It has been too long, too much said
   about it.
   
   Q I think in your -- many of your prior statements with Mr. Fiske that
   had been published, you discussed a conversation you had with Mr.
   Foster the day before his death. Do you recall if any of these topics
   were discussed in that?
   
   Mr. Pierson. Objection. Let's take one topic at a time so it is clear.
   
   BY MS. COMSTOCK:
   
   Q Anything relating to the Travel Office?
   
   A The day before Vince died, do I remember anything about the Travel
   Office?
   
   Mr. Pierson. Again, time out. This is July 1993?
   
   Ms. Comstock. Yes.
   
   Mr. Pierson. This is when you stopped by his office.
   
   BY MS. COMSTOCK:
   
   Q Just so I can make the record clear, I think the record is you had
   stopped by his office on that afternoon; is that correct?
   
   A The day before.
   
   Q Do you recall how long you were there?
   
   A No, there has been some dispute over that. No, I don't. I have
   always questioned the notion that I was there very long, but I
   subsequently read that I have been there -- I was there anywhere from
   20 minutes to an hour. I don't believe that. I don't think it was a
   long conversation.
   
   Q So you are aware of other reports that you were there for up to an
   hour. You don't think you were there that long?
   
   A Uh-huh.
   
   Mr. Pierson. You have to answer audibly.
   
   The Witness. Yes, yes, I am aware of those, and I think they are
   wrong, yeah.
   
   BY MS. COMSTOCK:
   
   Q Then it gets back to the original question: Do you recall if you had
   any conversations relating to any matters relating to the Travel
   Office?
   
   Mr. Pierson. On July 19th?
   
   The Witness. I know it. I know it. I got the date.
   
   I don't -- I don't recall that. Did I recall it at one time? If you
   have got it, I don't. Sorry, I don't remember anymore.
   
   BY MS. COMSTOCK:
   
   Q Do you recall if he said anything about Mr. Watkins or any problems
   he was having with Mr. Watkins?
   
   A Vince did not talk about -- particularly at work he didn't talk
   about work, and he rarely, if ever, talked about work, and that isn't
   how I talked to Vince. I talked to Vince -- particularly at that time
   I was talking to Vince about how he felt and what was going on in his
   life personally, how he felt inside, and whether he resolved his
   issues about trying to rest, and spend more time with his family, and
   do a good job, and all the public scrutiny he was getting and how he
   was holding up under that.
   
   I didn't go in there that day with an agenda. I think I just stopped
   by, as I did often, just to say hello because he been away on the
   week, and I wanted to see if he was okay and had a good time. Like a
   number of us at that time, we were working incredibly long hours under
   a lot of stress of trying to get a government up and going with the
   new administration, and then with all the public scrutiny that was
   starting to occur, particularly through the Wall Street Journal, and
   that kind of scrutiny was aimed at some wonderful good friends, so I
   was concerned about a friend who was for the first time in his life
   being exposed to some viciousness that he wasn't used to, and I was
   concerned about it. So I would be surprised if we talked about
   anything substantive other than me really trying to get him to talk
   about what he felt, which wasn't easy to do. He didn't like to do
   that.
   
   RPTS COLCHICO
   
   DCMN KRISTOFFERSEN
   
   BY MS. COMSTOCK:
   
   Q Were you aware of any disagreements that he was having with Mr.
   Nussbaum at the time and how to handle -- well, first, any matters
   related to the Travel Office?
   
   A We didn't discuss that.
   
   Q Okay. Do you have any general understanding of any disagreements he
   was having with Mr. Nussbaum at that time?
   
   A Here again, I know that that's been alleged. I don't know if I knew
   that then. I don't know if I talked about it then. I don't know
   whether I believed it or not.
   
   Q Okay. The evening of Mr. Foster's death, I believe, in the other
   interviews that you have had with Mr. Fiske, you said that you were
   with Mr. Hubbell that evening. Is that correct?
   
   Mr. Pierson. Is that a question?
   
   Ms. Comstock. Is that correct?
   
   Mr. Pierson. Were you with Web Hubbell the night --
   
   The Witness. Was I with Web the night that Vince died?
   
   BY MS. COMSTOCK:
   
   Q Yes.
   
   A Yes.
   
   Q And can you just describe briefly -- you don't need to make too long
   of a record -- what you did that evening?
   
   A I had dinner with Web and his wife, two of his kids, and a friend,
   at least one friend of theirs, maybe two friends of theirs, and we
   were out to eat when Web kept getting paged, and then finally he came
   back and he told Suzy and I that we had to go, something had happened.
   And so then we left.
   
   Q And did you go to the Fosters' home that evening?
   
   A Eventually, uh-huh.
   
   Q And did you talk with anyone about why this had happened?
   
   A Everybody that was there, yes.
   
   Q And --
   
   Mr. Pierson. Are you okay?
   
   The Witness. Yes. You all aren't getting all gunked up in here?
   
   Ms. Comstock. My throat is --
   
   The Witness. You are? I am, too. I feel like everything is kind of
   closing up on me.
   
   Mr. Pierson. If you want a break, just say so.
   
   Ms. Comstock. Yes. If at any time --
   
   The Witness. Does my voice sound raspy? It feels really raspy. I am
   going to start going into a spaz attack here, an allergic attack.
   
   Ms. Comstock. I would say no, because mine is normally like this. It's
   all relative.
   
   The Witness. Where were we?
   
   Mr. Pierson. Was there any discussion that Vince might take his own
   life at the Fosters' the night he died.
   
   The Witness. That's all everybody was talking about. It was just
   shocking, absolutely shocking. I did not believe it was Vince.
   
   BY MS. COMSTOCK:
   
   Q And after you were at the Foster home that evening, do you recall
   where you -- what you did after that?
   
   A Yes. Mickey Kantor and I left and came to the White House, and then
   at some point I would have ended up back where I was staying, and then
   it's a blur.
   
   At some point, I came -- I think -- I don't remember -- I to this day
   don't remember this, but I have been told that I the next day then
   went and picked up Web and brought him to the White House with me, and
   then I was with the White House, and then I'm sort of blank until -- I
   mean, I don't have a -- I don't know when things fit in there.
   
   Q Okay. Had you had a -- I guess there was -- there was reported that
   there was a group of people from Arkansas who got together regularly.
   
   A Uh-huh.
   
   Q Were you a part of that group that got together regularly?
   
   A Uh-huh.
   
   Mr. Pierson. You have to answer audibly.
   
   The Witness. Yes.
   
   BY MS. COMSTOCK:
   
   Q Who did that group include?
   
   A It was -- it originally started -- I think the very first time we
   did it, it was probably myself, Nancy Hernreich, Vince and Web, Bruce
   probably, Bruce Lindsey, and I think on that very first night Sheila
   Anthony, and I think the very first time we ever did that -- and I
   could be wrong about that -- and the very first time we did it, we
   went to Two Quails Restaurant.
   
   Q It's a great restaurant.
   
   A Yes, the different chairs and tables. We had a great time, so we
   decided we would do this, we decided to make it a regular thing. We
   did it on Tuesday nights, and we all worked 6 and a half, 7 days a
   week. We never got out of the offices before 10:00, ever. So we
   decided we would one night a week -- promised we would all get
   together and we would go have dinner together and, granted, it would
   be around 9:00 or 10:00. And so that's how it started.
   
   Now, to that -- anyone that wanted to come could come, and we
   particularly reached out to the Arkansans who, I think, felt the most
   alien in this environment up here.
   
   And so Deb Coyle, who was Bruce Lindsey's secretary, she became the
   one that had to organize it because she was the most organized of all
   of us. And then as spouses came, they got included.
   
   I think the only non-Arkansan that we would periodically let in would
   be John Emerson, and we just sort of adopted him. Sort of pathetic. We
   took him on, just -- you know, it was just -- then -- the intent was
   to get out of here at least one night a week, make sure that everyone
   ate. It was fun. So we ate and they drank. I don't drink. I am always
   the designated driver.
   
   Q And was Mr. Foster a part of this group sometimes?
   
   A Yes.
   
   Q And the week or so before, do you recall if he had been a part of
   this Tuesday night group or if you had gotten together?
   
   A Well, as it got -- it got harder and harder to get people together.
   At one point it got too big, and then we went back to our original
   little group, became rather cliquish, we did. It was harder and harder
   to get people to leave.
   
   Vince -- looking back on it after that, I realized that I wished -- I
   wish we had paid more attention to the fact that it was harder and
   harder to get him to come do it. He always had something else that he
   had to do.
   
   Q Did you ever discuss with Mr. Hubbell any of the problems that Mr.
   Foster had relating to any of the Travel Office matters?
   
   A I would have discussed anything and everything in my own way with
   Vince or Web, and my own way was, I knew nothing about any facts of
   anything; I would have just had an opinion on it. Now, how or -- how
   they would have responded to that usually was just to let me run off
   at the mouth.
   
   I don't have a memory of a conversation. I mean, you probably have
   serious conversations with your friends. I didn't with mine. I mean,
   we were pretty loose. We didn't talk --
   
   Q Now, do you ever recall anyone, Mr. Hubbell or Mr. Foster's sister,
   ever saying -- telling you that Mr. Foster said something to the
   effect of, you wouldn't believe our own people would lie to us, and
   this would be a statement that he made in reference to the Travel
   Office matter?
   
   A Who is he referring to as "our own people"?
   
   Q He said something -- actually, it was reported, I think, by Mr. --
   Mr. Anthony. Beryl Anthony had said that several times in the weeks
   prior to Mr. Foster's death, that Mr. Foster said to him, "You
   wouldn't believe our own people would lie to us." Do you have any
   knowledge that you can put that in the context of what that might
   mean?
   
   A No.
   
   Q Do you know of any of the group from Arkansas that Mr. Foster may
   have been concerned about wasn't telling him the truth about anything
   relating to the Travel Office or might --
   
   A Was Vince -- I am not sure I understand you.
   
   Q Was there anybody -- I guess in terms of if you were to think of
   "our people" as people from Arkansas or people that he knew, "our own
   people," do you know of any people from Arkansas who --
   
   A I would assume he meant Arkansans with that.
   
   Q And I am not assuming that I know what he meant by that.
   
   A Okay.
   
   Q Whether it was "our people," Democrats; "our people," people in the
   White House; or "our people" --
   
   Mr. Pierson. American citizens.
   
   The Witness. Okay.
   
   BY MS. COMSTOCK:
   
   Q So if you have any knowledge of what he meant by "our people" or any
   people that you know of that he was concerned about that might be
   lying to him.
   
   A I mean, I know just what the note said, that they found in his
   briefcase that he thought the FBI was lying. That's the only time I
   have ever heard that. And I think in that note he also alluded to
   something with the Usher's Office.
   
   Q Do you know if he ever referred to the FBI as "our people"?
   
   A I don't have a clue what he meant by that phrase.
   
   Mr. Pierson. If, in fact, he said it.
   
   BY MS. COMSTOCK:
   
   Q I mean, did he ever say anything like that to you?
   
   A No.
   
   Q Did you think --
   
   A No, I have never heard that phrase before.
   
   Q All right. I just want to return briefly to the White House Project
   matter which was -- actually, it's the imaging project that we were
   talking about earlier with Mr. Thomason.
   
   A The one I don't know anything about.
   
   Q Yes. This is the document which -- the direct Bates stamp number is
   on here, but it's CGE 1461 through 1468.
   
   A I have got to get my glasses.
   
   Q All right.
   
   Mr. Pierson. Do you want her to see first whether she is familiar with
   the document first, or do you want her to read it?
   
   Ms. Comstock. I thought she wasn't.
   
   BY MS. COMSTOCK:
   
   Q But if you want to look at it?
   
   A No, I have never seen this document before.
   
   Q Directing your attention to the second to the last page of the
   document, it is discussing the correspondence department.
   
   A Okay.
   
   Mr. Pierson. And this is would be Bates stamped 1467?
   
   Ms. Comstock. Yes, CGE 1467.
   
   BY MS. COMSTOCK:
   
   Q And this document, for your knowledge, is a document that has been
   identified to us by the White House as having been prepared by Harry
   Thomason in dealing with various departments in the White House. And I
   was just wondering if you want to review that correspondence section
   and see if that refreshes your recollection as to any work that you
   might know of that Harry Thomason was working on in this regard.
   
   A Good suggestions.
   
   See, at --?
   
   Mr. Pierson. The question to you is: Does this refresh your
   recollection about any knowledge you may have had about the so-called
   imaging project?
   
   The Witness. No.
   
   Mr. Pierson. Okay.
   
   The Witness. It does not. Thank you.
   
   BY MS. COMSTOCK:
   
   Q Directing your attention to the second paragraph, it is discussing
   the danger of destroying mail.
   
   A Yes.
   
   Q Do you know what mail -- anything about mail being destroyed at that
   time?
   
   A That was routinely done in the Bush administration, and we prided
   ourselves on doing it differently, and we -- when I found out that
   that had been done and it was just a matter of course that it had been
   done; in fact, starting in August of President Bush's last year, they
   rarely answered any mail because they had a problem -- they had a
   policy of not answering anything that was critical to the President;
   they wouldn't answer those letters. Most of them became critical after
   August.
   
   So we determined not to do that. So there was a precedence in the
   White House mail operation, correspondence operation, for destroying
   mail. I assume that that is what he is referring to.
   
   At the same time, I am not aware of anything that Harry was working
   on, but I had asked various people to come into the White House and
   study the Correspondence Department to come up with a better way that
   we could do it. We needed to streamline.
   
   And so I had a task force of people, Government employees, and they
   were from five different departments, that were conducting a review of
   my department at my request. And I would assume some of this
   information that's contained in here would have come from, if Harry
   was doing this, some project. He or his people, I would hope, had been
   talking to some of those people and talking to people to find out
   about --
   
   Mr. Pierson. Do you know that they did?
   
   The Witness. I don't know that they did, but I would assume they would
   have.
   
   BY MS. COMSTOCK:
   
   Q Okay. In the last sentence in that second paragraph, it discusses
   destroying the name -- destroying the mail, and then the last thing it
   reads is, "It is a name also lost to the database for the next
   campaign."
   
   Were you aware of any databases that were being maintained at the
   White House?
   
   A Well, there was no database at the White House at all, and that
   shows Harry's lack of knowledge of the rules of the White House.
   
   Mr. Pierson. If, in fact, this came from Harry?
   
   The Witness. If, in fact, it came from Harry.
   
   I mean, if this was a memo written from Harry -- thank you -- then he
   is very incorrect in assuming that anything that we produce at the
   White House can be used in a campaign, and since he didn't work for
   the White House, that's probably why he didn't know that.
   
   But all of us that worked there were very cognizant of the fact that
   we were not in any way allowed to, encouraged to, and, to my
   knowledge, no one ever did anything to create any kind of campaign
   context or database.
   
   BY MS. COMSTOCK:
   
   Q Okay. Thank you. I will just make that Exhibit 1.
   
   [Scott Deposition Exhibit No. 1
   
   was marked for identification.]
   
   The Witness. Okay. Who is that memo written to?
   
   Ms. Comstock. It didn't have a "to." It just sort of appeared.
   
   The Witness. Maybe it never went anywhere.
   
   BY MS. COMSTOCK:
   
   Q Do you know?
   
   A No, I don't know.
   
   Q I guess it was delivered to various people.
   
   Mr. Hernandez. An hour is up. I don't have any questions at this
   point, but do you need a brief break?
   
   The Witness. Yes.
   
   Ms. Comstock. All right. We will take a break.
   
   [Recess 4:20 to 4:22.]
   
   Ms. Comstock. This is CGE 38443, which is a memo to Vince Foster from
   Marsha Scott, I guess, CC'd to John Podesta.
   
   Mr. Pierson. Dated May 5, 1993.
   
   Ms. Comstock. Thank you. I am trying to find my copy.
   
   Mr. Pierson. Are you going to make this Exhibit 2?
   
   Ms. Comstock. Yes.
   
   [Scott Deposition Exhibit No. 2
   
   was marked for identification.]
   
   BY MS. COMSTOCK:
   
   Q This is regarding financing of correspondence projects. I was
   wondering if this connects up at all with the previous document we
   were discussing or if you know if any of these ideas you generated
   were being worked on by Vince Foster?
   
   A They weren't.
   
   Well, the first thing you asked me, does this relate to the first?
   
   Q Yes.
   
   A Not to my knowledge. No, this is one of my ideas that didn't go
   anywhere, one of the many things that no one paid any attention to me
   about.
   
   Mr. Pierson. But her last question was: To your knowledge, were any of
   these ideas being worked on by Vince Foster? And the answer was?
   
   The Witness. No, they were not.
   
   BY MS. COMSTOCK:
   
   Q You have no knowledge of if anyone was trying to use any kind of
   independent financing to work on this project?
   
   A No. This project never went anywhere. No.
   
   Q All right. This is Exhibit 2.
   
   This is CGE 29028 through 30, and it's a letter to Bill Burton, who
   was in the Chief of Staff's Office. And it was from Catherine
   Cornelius' lawyer, and it was regarding -- it is about the time, I
   guess, that Ms. Cornelius switched over to your office. And I was
   wondering -- I guess directing your attention to the second page
   there?
   
   A Okay.
   
   Mr. Pierson. Let me make sure the record is clear. It is dated August
   6th, 1993?
   
   Ms. Comstock. Yes.
   
   BY MS. COMSTOCK:
   
   Q It is a letter to Bill Burton from Steve Braga, who is an attorney
   for Catherine Cornelius.
   
   A Uh-huh.
   
   Q And in the letter, Mr. Braga discusses conversations that Catherine
   had about coming to your office. I was wondering if you have any
   recollection of such conversations?
   
   Mr. Pierson. Let's talk about specific portions of the document, which
   is 3 pages long. Do you have a specific reference in the document?
   
   BY MS. COMSTOCK:
   
   Q Well, actually before -- I mean, I just wanted to give that to you
   for a context.
   
   A Okay.
   
   Q But maybe before we go into the document, if you recall, you know,
   having conversations with Catherine about coming to work in your
   office?
   
   A I don't recall specific ones, but yes, I -- in fact, I think it was
   my idea that she come work in my office.
   
   Q Okay. Was that because she had been asked to leave the Travel
   Office?
   
   A I don't know that she had been asked to leave. I knew she had been
   gone and she was on medical leave, and I don't know that Catherine was
   ever asked to leave the Travel Office. Was she?
   
   Mr. Pierson. Let her ask the questions, and you give the answers.
   That's the way this works.
   
   BY MS. COMSTOCK:
   
   Q We will chat later.
   
   A I am sorry.
   
   I don't know that she was asked to leave, but when she was coming
   back, I had talked to her a couple of times to see how she was
   feeling, and I had -- she was very worried about what she was going to
   do, and I had said, "You can come work for me."
   
   Q Okay. Was this -- was she -- did you have any knowledge of if she
   felt that people were trying to push her out at this time? We were
   talking about before maybe a little bit more generally, and I was
   wondering if in this time frame --
   
   A I think Catherine felt that people would not want her around because
   she was hot. I mean, her name drew attention. She had been in the
   press constantly.
   
   Q Okay. Were you aware of her attorney trying to seek a higher salary
   than apparently you might be able to provide for her in the position
   that you had offered her?
   
   A Was I aware of that?
   
   Q Why don't I ask, were you aware of any salary -- efforts to get a
   higher salary, that she was trying to deal with the Chief of Staff's
   Office trying to get a higher salary than you were able to offer?
   
   A Only vaguely, but I don't have any specific -- here again, I know
   all of this, but I don't know if I know it from then. I don't know. I
   don't even know what we settled on.
   
   Q And you had said that she stayed in your office about 6 weeks or so?
   
   A I don't know that. That was my guess.
   
   Q It was a brief time that she was in your office?
   
   A Very brief, uh-huh.
   
   Q And do you recall why she left your office?
   
   A Let me think. She was in -- I think I put her in Agency Liaison,
   which was the case worker office. She may have -- she may have left
   because she then went to work in the Scheduling Office, which was
   closer to what she had done before.
   
   Q In the campaign?
   
   A Uh-huh. I don't know what Catherine's background was prior to the
   campaign, but that was the group of people she knew best, and I think
   that she -- I think that's where she went. Let me see if I can
   remember this.
   
   I think Catherine -- I think she appreciated getting to work -- do
   what we were doing, but I think it was too hard on her emotionally
   because a lot of the case work was very emotional. And I think she
   missed younger people. I don't think she was used to sitting, poring
   over documents like that. You may find that hard to believe, but --
   
   Q So exciting.
   
   Okay. Directing your attention to this letter, on the bottom of the
   paragraph Mr. Braga says, "First, there can be no doubt" --
   
   Mr. Pierson. Which paragraph?
   
   Ms. Comstock. I am sorry. The last sentence in the bottom of the page
   where "first" is underlined.
   
   Mr. Pierson. Paragraph number 2, sentence beginning, "First"?
   
   Ms. Comstock. Yes. "First, there can be no doubt that Catherine was
   the only 'victim' of the internal review of the administration's
   handling of the White House Travel Office."
   
   It goes on to discuss her adverse personnel action, and then the end
   of that paragraph says, "She has nowhere publicly complained to this
   end and/or told her side of the story. She has instead admirably
   chosen to remain silent as a complete team player in an administration
   trying to put this affair behind it."
   
   Do you have any knowledge as to what Ms. Cornelius was staying quiet
   about in regard to the Travel Office?
   
   A That -- no. But that isn't how I read that.
   
   Q Okay. Do you have any knowledge as to what this might -- as you read
   this, what you think this refers to?
   
   A I think what it means is that she was not literally complaining to
   anybody, that she had accepted this reprimand and it was causing her a
   lot of internal grief and personal grief, but she was doing nothing
   about it. She had not gone to anyone. She had not talked to anybody to
   say, "I am just a young kid, and I am scared, and I want help."
   
   So I don't -- I don't read that in the bigger sense that she is
   staying quiet because she knows something. I think it means she is a
   person who has been reprimanded and she is not publicly complaining
   about that, even though she thinks that it was unfair and unjustified.
   
   Q Were you ever aware of her having any conversations with the
   President about any of these problems that she was having?
   
   A No, but I know that she probably talked to him.
   
   Q All right. Did she ever ask you to talk to the President about any
   of these problems that she was having?
   
   A I talked to the President about her working for me.
   
   Q And can you describe what you discussed?
   
   A Just that, that I -- that I wanted her to work for me and I wanted
   him to know that I was going to try to take care of her as a friend. I
   really, really was concerned about Catherine's emotional state, and I
   wanted her to be in a safe place where she would have people who
   nurtured her and cared about how she felt.
   
   Mr. Pierson. This was in August, after Vince's death?
   
   The Witness. Uh-huh. Uh-huh. This was in the context of this time
   frame right here that I am talking about.
   
   BY MS. COMSTOCK:
   
   Q All right. Were you aware of -- directing your attention to the
   third paragraph at the bottom of the second page.
   
   Mr. Pierson. The third numbered paragraph?
   
   Ms. Comstock. Yes, number 3, where it says number 3.
   
   Mr. Pierson. Beginning, "Anyone who has read"?
   
   Ms. Comstock. Yes. Actually, the middle of that paragraph discusses
   Patsy Thomasson has engaged in repeated instances of unethical,
   possibly illegal, and certainly harassing conduct towards Catherine.
   
   Do you know of any such conduct that Catherine ever told you about?
   
   A That's how a lawyer would say it. Let me see what I remember. I
   remember -- I don't remember specifics, but Catherine and Patsy did
   not get along, and so anything Patsy said to Catherine, Catherine took
   it in the harshest light.
   
   I think it's really important to remember that Catherine was a very
   fragile young person at this time and what she may or may not have
   said to anybody about what may or may not have happened has to be
   viewed in the context of, this is a kid that almost had a complete
   breakdown, and some would judge that she did, both physical and
   emotional.
   
   And I think it's really important to remember her -- and I don't mean
   to harp on her age, but she was a young person from a small town in
   Arkansas with tremendous pressure and severe medical problems, and all
   of this was very, very difficult on her, and she talked and acted like
   someone who was on the verge of complete collapse.
   
   So I viewed then and still view with great skepticism any actions she
   may or may not have attributed to somebody else, and I also know Patsy
   to be sometimes a very gruff, blunt, hard-talking boss, and I can see
   how she and Catherine would have been like oil and water.
   
   Q Now, but in reference to anything illegal that Patsy Thomasson would
   have done in terms of harassing or unethical?
   
   A Again, that's a lawyer's comment. I have --
   
   Mr. Pierson. The question to you is: Do you know of anything?
   
   The Witness. No, no. No, I don't, and I don't -- that's just a
   lawyer's interpretation of what she may or may not have said.
   
   BY MS. COMSTOCK:
   
   Q Were you aware of Ms. Thomasson being directed by anybody to get rid
   of Catherine or do anything about Catherine?
   
   A No. I know that's been alleged, but I'm not -- I wasn't aware of
   that, I don't think.
   
   Q Do you recall if you resolved these salary issues with Catherine and
   how they were resolved?
   
   A Do.
   
   Mr. Pierson. Objection. Let's define what you mean by "salary issues."
   I am not certain this witness has testified to a salary issue.
   
   BY MS. COMSTOCK:
   
   Q The first page of this August 6th letter discusses that you had
   advised Catherine that she could be compensated at $45,000. Do you
   recall any salary disputes there and how they were resolved?
   
   A Salary levels were determined by me in theory and acted on by either
   John Podesta or it would have gone up to -- who was head of personnel
   then?
   
   Q Mr. Lindsey?
   
   A I don't know if it would have gone to him or whether it went
   straight to -- I apologize. I don't remember. It would have been
   resolved at a level higher than mine, and that was -- that wasn't an
   issue to me.
   
   Q Okay.
   
   A It got resolved because she got hired. So I just don't remember.
   Whatever we hired her at meant it had been resolved. I didn't have an
   issue with that.
   
   Q Do you have any knowledge as to what Mr. Burton's role was in
   resolving any of this or dealing with Catherine?
   
   A If he was involved in that, it would have been because he worked
   directly for the chief of staff and he acted in the capacity of being
   the chief of staff's chief of staff. So he would have -- if he was
   involved -- I don't know that he was, but if he was, it would have
   been perfectly proper for him to have been involved in this in some
   way, acting on -- for the chief of staff.
   
   Mr. Pierson. Is this Exhibit 3?
   
   Ms. Comstock. Exhibit 3, yes.
   
   [Scott Deposition Exhibit No. 3
   
   was marked for identification.]
   
   BY MS. COMSTOCK:
   
   Q In the fall of 1993 and into early '94, were you aware of any
   problems that David Watkins was having with Mr. McLarty or with anyone
   in the White House?
   
   A The fall of '93/'94? That was -- give me a context of something that
   it happened. The dates mean nothing.
   
   Q No. I was just wondering if, following Mr. Foster's death, if you
   recall any problems that Mr. Watkins had with any -- with Mr. McLarty
   or any management at the White House?
   
   A Had anything happened? I mean, had the --
   
   Q Did he have any work problems, any disagreements with --
   
   Mr. Pierson. That you can place in time?
   
   BY MS. COMSTOCK:
   
   Q That you know of?
   
   A No, I don't know.
   
   Q All right. The presidential personal correspondence, that's all
   handled by Mrs. Huber in her office? Is that separate from the
   correspondence that you did?
   
   A Yes and no. Mrs. Huber handled Mrs. Clinton's -- well, Mrs.
   Clinton's personal correspondence -- Mrs. Huber did not handle Mrs.
   Clinton's personal correspondence; it was Millie Alston that did.
   
   Millie, Caroline Huber and Trey Schroeder and one other person -- I
   don't remember who it was at the time -- all worked over in the East
   Wing offices. They were within the Department of Correspondence. Mrs.
   Clinton's other correspondence was handled by one of the divisions
   within my department. Personal correspondence for both of them fell
   under my department, but they worked more directly to their
   principals.
   
   In other words, Trey Schroeder wrote for the President, and so he
   worked directly with the President and Nancy Hernreich. Millie Alston
   worked for Mrs. Clinton. She worked directly with Mrs. Clinton on the
   correspondence or whomever Mrs. Clinton -- it might have been Maggie
   she worked directly with.
   
   Does that answer your question?
   
   Q Well, maybe.
   
   I am just showing the witness CGE 39294. It's a letter to the First
   Lady from David Watkins. I was wondering if you had ever seen this
   letter before?
   
   Mr. Pierson. May 3, 1994?
   
   Ms. Comstock. May 3, 1994. It is on the personal letterhead of Mr.
   Watkins. It's a handwritten note to -- that says, "Hillary," and then
   it discusses the GAO report, and then it's signed by Mr. Watkins.
   
   The Witness. No. I have never seen that.
   
   Mr. Pierson. Did you get that answer?
   
   The Court Reporter: Yes.
   
   BY MS. COMSTOCK:
   
   Q Do you know if something like this would have gone through your
   office at any point?
   
   A No.
   
   Q Or would that have gone directly over to Millie, or how -- or if you
   have any knowledge how it worked?
   
   A There were --
   
   Q If it were inner office mail?
   
   A I don't have a clue how David would have gotten a message to Mrs.
   Clinton.
   
   Q You have never seen this letter before?
   
   A No. No.
   
   Mr. Pierson. Is that Exhibit 4?
   
   Ms. Comstock. Yes.
   
   [Scott Deposition Exhibit No. 4
   
   was marked for identification.]
   
   The Witness. Was that mailed?
   
   BY MS. COMSTOCK:
   
   Q All we have is this form, so I don't know.
   
   May 3rd, 1994, was the day after the GAO report had been issued on the
   Travel Office matter. Do you recall any discussions in the spring of
   '94, after that report had become public, about anything having to do
   with any representations that David Watkins had made about the First
   Lady's role in the Travel Office firings?
   
   A I don't know that I remember that from then, no.
   
   Q And you are familiar with the incident where Mr. Watkins took a
   helicopter and went to the golf course?
   
   A Uh-huh.
   
   Mr. Pierson. You have to answer orally.
   
   The Witness. Yes.
   
   BY MS. COMSTOCK:
   
   Q Were you supposed to go on that trip that day?
   
   A Yes.
   
   Q Could you describe what that was about?
   
   A David had come to me saying that he -- it was a twofold purpose. He
   really wanted the President and the First Lady to start going to Camp
   David more, one, because it was a facility that he knew they would
   really enjoy, and he felt that it was real important for the morale of
   the facility people themselves that -- we were -- I think, if I
   remember correctly, we used it less -- at that point in time, we were
   not using it very much. And it's really a nice place, and he wanted to
   increase use of the facility.
   
   They were also doing some refurbishment there in some of the areas
   that needed it. So he wanted me to go out and see Camp David, which I
   had never seen, so that I would then come back and talk to the First
   Lady and the President about how wonderful it is and think of more
   creative ways that they might use it and that Chelsea would enjoy it.
   
   He was looking for an ally to increase use of the place, and one of
   the ways that he thought that he could entice the President to want to
   use it more was to tell him how great the golf courses were around
   there.
   
   So this particular time he was going to go, he was going to go and
   check out the facility and he was going to check out the golf courses.
   
   David is a very good golfer, the President aspires to be a great
   golfer, and I play golf and have played golf with the President. And
   so David thought, let's do it, let's go out there, do as he -- I think
   he may have called it a reconnaissance mission, so we can check
   everything out. We will come back, and then you go in there and
   convince the President; you work on him on the golf side and then talk
   to Hillary about how great a place it will be for Chelsea, and we can
   get them to come out there more. And that was the reason why he wanted
   to go do it.
   
   Q All right. And were you aware of, after the problems that arose out
   of that trip, Mr. Watkins' response internally about that matter?
   
   A I am not aware, and I don't know what he said about it. I have never
   known officially what his response to that was.
   
   Q Did you ever explain to anybody why you were going to be going on
   it?
   
   A Yes, sure.
   
   Q Who did you talk to?
   
   A Probably -- I think John Podesta called me. I think he was the one
   that called me to tell me that that had happened with David. I think
   that's how I first knew about it, was John called me to tell me. And I
   laughed. I said --, "I said I was supposed to be on that trip." I said
   -- I was sick; I was home with the flu.
   
   And I had -- I had actually counseled David on not going on
   helicopters, and I had talked to -- he had told me that he was going
   to take the helicopter. And I said, "Can you do that?" I said, "Is
   that permitted?" And he said, "They have to routinely be taken out,
   and they have to do" -- "they have to get in so many hours anyway.
   This will just be part of their regular training."
   
   So I think I told John all of that when he called me, because I
   thought -- I thought he was joking at first. I thought this was --
   this was silly.
   
   Q All right. So Mr. Podesta handled some kind of internal look at that
   matter, if you know?
   
   A John was -- I think the reason why John called me is because John
   was my immediate supervisor. I don't know that it had anything to do
   with the context of investigating anything. We -- to my knowledge, we
   were not knee deep in investigations at that point.
   
   Q And were you aware of any other problems that Mr. -- around the time
   of this helicopter incident, were you aware of any other internal
   problems that Mr. Watkins was having within his office?
   
   A You mean with people that worked for him?
   
   Q Yes, that's what I mean.
   
   A I don't know if I was or not. David is a difficult man to get along
   with sometimes, so -- I don't know that I remember anything specific,
   no.
   
   Q Were you aware of any efforts to fire him or to move him out of the
   White House prior to the helicopter incident?
   
   A I think "firing" is not a good -- I wouldn't use that word.
   
   Q Or easing him out?
   
   A I would -- I think that -- let's see. What time frame was that? I
   can give you a better answer.
   
   Q May of 1994.
   
   A Okay. So he had been there a year and a half?
   
   Q Yes.
   
   A I know that David was frustrated. That was not the kind of work that
   he had done pre -- that's not fair. He had done that kind of work. I
   don't think that was the kind of work that he necessarily enjoyed and
   where it played to his strengths, and so I was aware that he was tired
   of doing that particular job and that he was probably interested in
   doing something else. And I think when someone is feeling that way,
   others that they work with are probably feeling that way, too.
   
   I do not know of anyone talking about any kind of efforts to do either
   of the things you suggested, which was to fire or move him out, but I
   think at that point he was very burned out and tired and wanting to do
   something different, and it probably reflected with those who worked
   around him.
   
   Q In this letter that we were looking at, the May 3rd, 1994,
   handwritten letter from Mr. Watkins, Exhibit 4, the last sentence in
   it says, "I have always known who my client is."
   
   A Uh-huh.
   
   Q Did he commonly refer to the President or First Lady as his clients?
   
   A Those of us who work in retail always do. I do. I mean, we come --
   David and I both share a background in sales, and we are PR people,
   and so, unlike the jargon of Washington, we talk in terms of client
   services and the client. My assumption on reading that is, that's what
   he is referring to.
   
   Q Okay. And were you aware of Mr. Foster referring to the President
   and the First Lady as "the clients" in a legal context?
   
   A No, I am not aware of that.
   
   Q Are you at all familiar with the memo that surfaced earlier this
   year by Mr. Watkins discussing the Travel Office matter?
   
   Mr. Pierson. This is the memo he has described himself as a CYA?
   
   Ms. Comstock. I think he described it as a soul cleansing memo.
   
   Mr. Pierson. He also described it as a CYA.
   
   The Witness. The memo that wasn't sent?
   
   Ms. Comstock. I don't know that he has described it that way. I think
   others may have.
   
   The Witness. Are you asking me if I knew about it at the time?
   
   BY MS. COMSTOCK:
   
   Q Yes.
   
   A I didn't.
   
   Q If you had any knowledge of that memo prior to it being released?
   
   A No, I didn't.
   
   Q Did he ever describe to you any of the sentiments in that memo?
   Specifically, did he ever discuss with you the First Lady's role, any
   role that the First Lady had in the Travel Office firings?
   
   A I don't remember him ever doing that, no.
   
   Q Or did he ever discuss with you any pressure that he had felt by Mr.
   McLarty to fire the Travel Office employees?
   
   A I remember sort of oblique references to pressure on David's part,
   but David felt pressure in general. I have -- I do not remember him
   ever saying Mack or anybody else was telling him to fire them.
   
   I think that he felt -- God, I don't even know if I remember this
   right, so maybe I am blabbing. He knew it was an area that had to be
   cleaned up, and he wanted to fix what he perceived to be a problem,
   and so he felt pressures in that, in that David's speed at which he
   did things sometimes was different from the speed others might have
   wanted of him. He just had a way of fixing a problem that might have
   been different from others, and so in that sense I think that he felt
   pressure. But, no, I did not hear specifics.
   
   Q And were you aware of anything having to do with any Secret Service
   problems that had been raised by the President or the First Lady in
   the spring of 1993?
   
   A I am aware of the press report of a lamp incident, and I am aware of
   when Mrs. Clinton or her -- or someone dismissed one of the ushers.
   That's not Secret Service. Just generically.
   
   Q So you are only familiar with -- familiar with it from the press
   accounts of those matters?
   
   A And in a more generic way of, we were all -- none of us came from an
   environment where you had bodyguards or guards around, and it was --
   it was very confining, and it felt restrictive, and so all of us,
   meaning that -- that is a topic that would come up in discussions of
   things like, well, we would like for the President to be able to go
   across the street to the Blair House or go have dinner out.
   
   We talked about having him come with us some night on our Tuesday
   night group, just in generic. Then it would always be, he can't do
   that because of the Secret Service, and it was like the Secret Service
   were the bad guys because they were there to keep us from doing
   anything fun. But it was not -- not serious, other than just the -- I
   think probably every administration comes in, and unless they have
   been a Vice President before and have lived through one of these
   cycles, you come in and you don't know how to adjust to people who
   seem to be staring at your every move. And those guys stare at you,
   unblinking. So it's a bit unnerving to get used to. So we talked about
   it. We sort of joked about it. It was kind of a general --
   
   Q You weren't aware of any problems that had been expressed to David
   Watkins or any management at the White House about the Secret Service?
   
   A Yes, but I don't know when I knew that. I don't know -- I don't know
   how I knew it. I mean, it seemed oppressive. It seemed too much.
   Everybody seemed to be trying too hard to do too much, the Secret
   Service included. We didn't know how they operated. They didn't know
   how we operated. So I think everybody was bumping into each other, so
   we all complained about each other.
   
   So I am sure -- and I was aware that people had complained to David
   about it. I don't know who those people were. I mean, I am not aware
   that the President said, David, the Secret Service is bad, or that
   Mrs. Clinton said that. I think in general, those of us who came in
   found it difficult.
   
   And I know that the President and the First Lady, they are young. They
   have got -- had a young child. This was -- it's unnerving to have
   people following you around constantly. So I -- you know, my
   recollection is, we all joked about it, complained about it, and
   groused about it. And we have gotten over it, and we work well with
   them now, and so we will advise whatever next administration --
   however long away that is -- that, get over it quickly; they are
   really -- they will be okay.
   
   Q They are nice guys?
   
   A Yeah.
   
   Q And women?
   
   A Yeah.
   
   Q Okay. I think we are just about done here.
   
   A Good, because I am almost through with this glass of water and will
   have to take a break again.
   
   Q All right. Do you recall having any discussions with anybody at the
   White House about Billy Dale's trial or anything connected with Mr.
   Dale's trial?
   
   A I don't remember, no. I don't think so. I don't think I ever had any
   conversations about that trial.
   
   Q Okay.
   
   Ms. Comstock. Okay. I believe that's all I have. Thank you.
   
   The Witness. Okay.
   
   [Whereupon, at 5:00 p.m., the deposition was concluded.]




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