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OFFICE OF THE INDEPENDENT COUNSEL 

______--_---__--------- 

DEPOSITION OF 

CHARLES F. O'MALLEY 

Deposition of 

_- X 

Tuesday, September 8, 1998 

Washington, D. C. 

CHARLES F. O'MALLEY 

before the Independent Counsel, held at the offices of the 

U.S. Secret Service, 1800 G Street, N. W., Eighth Floor, 

Washington, D. C., beginning at 1O:lO a.m., when were 

present: 

For the Independent Counsel: 

EDWARD J. PAGE, ESQUIRE 

Associate Independent Counsel 

MARY ANNE WIRTH, ESQUIRE 

Associate Independent Counsel 

Court Reporter: Elizabeth A. Eastman 

Deposition Services, Inc. 
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PROCEEDINGS 

WHEREUPON, 

CHARLES F. O'MALLEY 

having been called for examination by the Office of the 

Independent Counsel, and having been first duly sworn, was 

examined and testified as follows: 

EXAMINATION BY COUNSEL FOR THE INDEPENDENT COUNSEL 

BY MR. PAGE: 

Q Would you tell us your full name, please? 

A My name is Charles Francis O'Malley. 

Q Where do you work? 

A Currently I work at the Foreign Missions Branch of 

the Uniformed Division, Secret Service. 

Q How long have 

A This past May 

months. 

you worked with the Secret Service? 

it was 24 years; 24 years, three 

Q Before you were assigned to the Foreign Missions 

Branch of the U. S. Secret Service, what was your assignment? 

A I was assigned as the Deputy Chief 

House, Uniformed Division. 

Q Uniformed Division? 

A Yes. 

Q How long were you the Deputy Chief 

Division, approximately? 

at the White 

of the Uniformed 

A At the White House? I was the Deputy Chief from -- 
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it was three years, almost to the day. 

So, what time span would that have been? 

January of '95 through January of '98. 

What kinds of things are you responsible 

Q 

A 

Q 

position 

A 

personne 1 

of Deputy Chief of the Uniformed Division? 

I'm responsible for managing the Uniformed Division 

there, responsible for the policies and procedures 

for in the 

3 

in effect. I'm responsible for manpower, scheduling. I'm 

responsible for equipment. I'm responsible for the overall 

physical security that our Uniformed Division provides at the 

White House. 

Q Basically, the entire operation? 

A Uniformed Division-related, yes. 

Q Are there other deputies besides 

A Yes, there are. 

Q What do they do? 

yourself? 

A There's a Deputy Chief of Foreign Missions Branch, 

which I am now, and they are responsible for providing 

security to the diplomatic community in Northwest Washington, 

D.C. Their responsibilities are similar to mine, but just 

relative to that mission. And we have one Deputy Chief who 

is assigned to the Program Support Branch, who supervises and 

manages our units, our other units, administration, that sort 

of thing. 

Q I presume there is a Chief as well of the Uniformed 
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Division? 

A There is a Chief of the Uniformed Division, yes. 

Q Who is that? 

A His name is Richard Friedman. 

BY MS. WIRTH: 

Q I'm sorry, F-R-I-E-D-M-A-N? 

A Yes. 

BY MR. PAGE: 

Q How long has 

Division? 

Friedman been Chief of the Uniformed 

A 

Q 

A 

Q 

A 

Q 

Division? 

A 

Q 

I would say in the proximity of July of '95. 

To -- 

The present. 

He is currently occupying that position? 

Yes, sir. 

Is he the head, as the Chief of the Uniformed 

Yes, he is. 

Does he have any other people who occupy a similar 

position near him? 

A There's an 

Chief and the Deputy 

Assistant Chief that is between the 

Chief. 

Q You mentioned that in your role as Deputy Chief one 

of your responsibilities was the policies and procedures in 

effect within the Uniformed Division? 
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A Yes. 

Q Can you tell 

responsibility and how 

A The policies 

5 

us a little bit about that 

you carry it out? 

that are in effect at the White House 

regarding security, scheduling, whatever is related, they've 

been developed over the course of years, and many of them 

have been in place for years. When a -- for some reason or 

other, some policy would need to be changed or edited or 

looked at or whatever, it would be my responsibility to farm 

that out to one of my subordinates to take a look at it, have 

it rewritten, and change the policy. Periodically they are 

looked at. 

Q Could you go below your 

nutshell how the hierarchy looks, 

position and tell us in a 

below deputy chief? 

A At the White House Branch? 

Q Correct. 

Q There's one deputy chief. There is two inspectors. 

One inspector is responsible for administration and the other 

inspector is responsible for operations. In January of ‘95, 

there was only one inspector assigned. 

responsible for those two functions has 

year and a half, I want to 

that it justified breaking 

Underneath those 

captains. 

say, because 

This is -- having two 

only been in the past 

the workload was such 

up those responsibilities. 

two inspectors, there are eight 
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BY MS. WIRTH: 

Q Eight? 

A Yes. One of them is assigned in the Deputy Chief's 

office as a -- operations, and one is assigned 

administration. And the remaining captains, the other six 

captains, are assigned operations. 

BY MR. PAGE: 

Q When you say "operations", 

A They would be in charge of 

what do you mean? 

the section. Like our 

day is broken up into three sections: 6:30 in the morning to 

2:3O in the afternoon; 2:30 in the afternoon to lo:30 at 

night; lo:30 at night to 6:30 -in the morning. And generally 

there is a captain as the watch commander of each of those 

respective sections. 

Q The captain acts as the watch 

A Yes. 

Q -- for each of those sections 

A Generally. Sometimes, if the 

commander -- 

of shifts? 

captain is on leave 

or sick or whatever, it would go down to the senior 

lieutenants. 

Q Can you give us an idea, below captains, what 

exists there? 

A Below captains? To carry out the supervision are 

lieutenants. 

Q Approximately how many lieutenants are there? 
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Q 

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Approximately, I'd say 30 1 

Thirty? 

Yeah. 

ieutenants. 

BY MS. WIRTH: 

And this is just at the White House? 

Yes. 

BY MR. PAGE: 

And below lieutenants? 

You would have sergeants. And below sergeants, 

officers. 

Q Approximately how many sergeants? 

A I want to say approximately 50 sergeants. I've 

been away for going on seven months now. 

Q I understand. 

A Eight months. 

Q I'm just getting an idea. That's why I'm asking 

you approximations. 

A Uh-huh. 

Q And the number approximately of officers? 

A I could give you an approximation, but I'm hesitant 

to without checking with legal counsel regarding the security 

of giving out those numbers. 

Q Okay. What kind of incidents, if you will, would 

you learn about that the officers are involved in, in a dayto-day basis, as they are guarding the White House, say at 
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different places around 

A I would be -- 

be notified of probably 

happened. And it could 

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the White House? 

if I'm on duty and working, I wou 

any type of an incident that 

range from an arrest out on the 

street, or someone trying to jump the fence, conflicts 

between our employees and either a passholder or a guest of 

the White House, breaches of security, that sort of thing. 

Off duty, things that could kind of be handled when 

I come in, they wouldn't be -- I'd be notified of them when I 

came in. Things of a higher priority, like an arrest, or 

maybe a confrontation between a passholder or a Congressman, 

that sort of thing, I'd be called at home and notified 

immediately. 

Q so, is it fair to characterize the 1 ist that you've 

just given us as relatively the run-of-the mill kinds 

things that generate your review or your involvement, 

assessment -- 

A Right. 

Q __ of an event? 

A Yes. 

of 

your 

Q So, arrests, jumping the fence, conflicts with 

guests or passholders, breach of security. Is there any 

other category of incident or situation that might fit in 

the, if there is, top five, six or seven? 

A Right off the top of my head, no. And they would 
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notify me on any kind of an incident in which we are going to 

have to look into it, we are going to have to answer for, 

that sort of thing. 

Q Does the Secret Service Uniformed Division 

routinely make arrests around the White House complex? 

A It would be routine if necessary. When we 

stretched the perimeter and closed off 

it brought us into closer proximity to 

The general public out in front of the 

Pennsylvania Avenue, 

the general public. 

White House could 

range from a Congressman on down to a street person. And we 

have gotten more involved since that. 

So, arrests, I would venture to say -- and, really, 

I'm stabbing in the dark here -- there's probably two or 

three a week. 

I'm really kind of guessing, because at the Foreign 

Missions Branch, we have the facilities to move prisoners. 

At the White House, they have vehicles, but we usually do 

their transports to the station house, and I see that. We 

assist at the White House in providing transport to the 

district stations. 

So, maybe two. I'd say two a week is a safe 

number. 

Q These items or situations that we've talked about, 

what kind of policies are there, or rules or guidelines, to 

generate something that memorializes, for example, in a 
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report, a memo, something like that, about an arrest or 

jumping the fence, breach of security, conflicts with guests, 

et cetera? 

A I'm sorry. Would you restate that? 

Q Yes. What kinds of policies or rules control 

whether -- in other words, what kind of paperwork is normally 

or routinely generated? I'll break the question down, for 

these kinds of events? 

A For an arrest, there would be the Metropolitan 

Police forms would be completed. And we have an incident 

report that we would have completed. And the incident report 

would spell out essentially what's in the arrest report. 

Q Jumping the fence, is that an incident report as 

well? 

A Yes, that's an incident report. 

Q You've said that a couple of times now. Is that a 

standard form that -- 

A Yes, it is. 

Q -- the Secret Service Uniformed Division would 

generate upon one of these five or six events -- 

A Right. 

Q -- that we've talked about occurring? 

A Right. 

Q Conflicts with guests or passholders? 

A Conflicts with guests or passholders wou ld just be 
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via memorandum. 

in 

in 

Q Does the 

your experience 

the memorandum? 

Secret Service Uniformed Division, or you 

as one of the deputy chiefs, what would be 

A They would spell out where they were. The 

individual involved in it would spell out where they were, 

what they were doing, their assignment at the time, the 

persons involved in it, the people that -- the complainants, 

if there was a complaint, our version of the story, 

witnesses. 

Q So, a summary of the events basically? 

A Yes. 

Q And is it policy to do that near in time to the 

event so that it is as accurate as possible? 

A Yes. 

Q How is that report used, if at all, within the 

Uniformed Division? 

A That memorandum would be held -- if it was -- we 

would follow up on it. We would try to ascertain, if it was 

an incident with a passholder or a Congressman, ascertain if 

our people were responsible for it, try to get as many 

details as possible. 

Q And is that for a number of purposes? 

A Uh-huh. 

Q For example, to memorialize what happened -- 
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A Yes. 

Q -- so that you don't have to confront failing 

memories later? 

A Uh-huh. 

Q Is it fair to say that that is one? 

A Right. 

Q Is another one to permit an intelligent review of 

the matter? 

A Right. 

Q To see, do we need to fix a policy? 

A Exactly. 

Q Discipline somebody or -- 

A Uh-huh. 

Q -- et cetera? 

A Yes. 

Q Are there any other purposes that you can think of 

for generating the memo? 

A That's essentially it. To continue to operate as 

efficiently as we can, to limit the number of similar 

incidents, and take whatever action is necessary to do that. 

Q Is this kind of report-making process, the memo as 

well as the incident report, required by a rule or 

regulation, or is it a routine practice? 

A It's a routine practice. However, like arrests, 

I'm sure it's documented to the 2032, which is the incident 
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report number. 

Q 2032 -- 

A Yes. 

Q -- is the form? 

A That's right. 

Q The incident report number? 

A It will be completed. 

Q Is there a memo form? 

A Yes, there's a standard memo form, U 

memo form. I don't know the number of it. 

Q ALL ..-I7 right. 

BY MS. WIRTH: 

S. Government 

Q The memo form is just memo to, from, and the date? 

Is there any other -- 

A Subject. 

Q And subject. Okay. 

BY MR. PAGE: 

Q Did you when you were Deputy Chief, or were you 

aware of efforts to educate the staff about their obligations 

concerning these memos or incident reports? 

A No. 

Q Is that done at the basic training level or is that 

a -- 

A My employees? 

Q Correct. 
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A That's done at the basic training level. When they 

come to the White House or the Foreign Missions Branch, new 

employees receive three weeks of -- generally three weeks of 

on-the-job training. And that sort of information is 

covered. 

Q So, that's when I would learn -- take me, 

hypothetically. If I was a new Uniformed Division Officer 

going through that three-week training session, that's where 

I would learn that, hey, when somebody jumps the fence, 

that's a big deal and I write up a memo or an incident 

report? 

A Right. 

Q Correct? 

A Yes. 

Q And I assume that there's some foundation 

underlying that? In other words, some internal Secret 

Service rule or -- 

A 

Q 

it? 

A 

Q 

A 

Q 

Uh-huh. 

-- procedure or guideline that suggests to document 

Exactly. Yes, sir. 

Is that accurate? 

Uh-huh. 

Going back to the hierarchy that you ment ioned or 

testified about earl ier, officers, sergeants, 1 .i eutenants, 
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captains, two inspectors and then the deputy chief, and I 

presume above that the Chief, where do these incident 

reports, if they are generated at the officer level, go? In 

other words, through whose hands in the review process? 

A The officer who is responsible is the reporting 

officer. There could be a sergeant, you know, depending on 

~ if he was directly involved in it. 

Q I understand. 

A That person would do that. They would be 

responsible for all of the reports involved in it, whether it 

be Metropolitan arrests. And it would go to the captain. 

The captain of the section would review it and sign off on 

it. 

Q so, it bypasses the lieutenant theoretically, if it 

is -- 

A Well, theoretically. But the lieutenants, whoever 

is working, the lieutenants that are working that day, they 

would probably get a look at it and say, hey, you spelled 

this person's name wrong. They'd look through it for errors 

also. But it would be ultimately signed off by the captain 

and then it would be forwarded to the deputy chief's office. 

Q so, there is some review by the person immediately 

above the person who -- 

A Uh-huh. 

Q -- witnesses the event? 
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A uh-huh. 

Q IS that accurate? 

A Yes, sir. 

BY MS. WIRTH: 

Q The incident report is filled out normally by the 

officer involved? 

A Yes. 

Q And that's also true about the memo? 

A Yes. 

Q If there's an officer involved? 

A Yes. 

Q And I may have missed what was just said here, and 

I apologize for that, if that is so. But, the sergeant's 

role, does the sergeant have a role at all in reviewing those 

reports? 

A If it happened at an officer's post, the sergeant 

would probably respond, if it went over the radio. And he 

would be there providing any assistance that the officer may 

need, or solving a problem if there's a problem involved in 

it. And he would be knowledgeable of the incident, the 

sergeant that is assigned to that particular area. 

Q Does he sign the incident report, the sergeant? 

A Only -- no. The only person who signs it is the 

person making the report, and it could be a sergeant making 

the report. 
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Q If that's the -- 

A And then reviewing official, which is usually a 

captain, unless it's a lieutenant watch commander because 

there's not a captain working. 

Q But if it's an officer making the report, that 

person is the only person who signs it? 

A Him or her, and the reviewing official. 

Q Which would be a captain? 

A In most instances. 

Q Okay. 

A It could be a lieutenant if the lieutenant was 

acting as a captain. 

Q Okay. 

A If there was 

BY MR. PAGE: 

no captain working. 

Q Can you give us an idea about the kinds of 

conflicts, generally speaking, that arise between Uniformed 

Division officers and guests or passholders? Remember that 

subcategory of the overview of things that generated an 

incident report or memo? What's the normal flavor, so to 

speak, of these things? 

A I could give you one or two examples, and they are 

based on truth. It's like, you know, there's all the 

important people who work at the White House. And you have 

people that work at this level [gestur ,ing , the President's 
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staff, Chief of Staff, everyone on his staff, and the 

workers. And there's a lot of people over there that are 

very important, as you know. And sometimes -- everyone is 

required to wear one of these [indicating]. This is a White 

House pass. 

And when our officers don't know a person, they are 

tasked with asking to see their identification. They should 

have it on at all times. But, if I knew you and you were on 

the President's staff, 

wouldn't challenge you 

Avenue. However, if I 

I wouldn't -- and if I knew you -- I 

for walking up and down West Executive 

didn't know you, we are tasked with 

doing that. And sometimes people get upset about it. 

And if they perceived that the same officer or 

sergeant asked me a half a dozen times, he knows who I am. 

That sort of incident. And sometimes you may get a little 

conflict between our members and them. 

Similarly, Congressmen coming in, they pull up to 

the gate and the officer may not know -- if it's a 

Congressman who isn't 

picture out there all 

instant recognition. 

Q so, we have 

big in the news, who doesn't have his 

the time, they feel that we should have 

That has caused problems in the past. 

your category of very important people, 

Congressmen. Any other kind of things that routinely give 

rise to conflict or tension between the Uniformed Division 

and somebody, some kind of person? 

I 
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A Well, it could happen with an appointment who -- a 

person shows up at a certain amount of time between when he's 

expected. And if he shows up a little early, he identifies 

himself at our entrance gates and we don't have any 

information on the individual, and we direct them to -- 

there's a house phone outside and maybe you should call the 

person who made the appointment for you and get the ball 

rolling to get you into our system. 

Sometimes, depending on the person, the level of 

the person, or just the personalities, we're like kind of 

between a rock and a hard spot out there. We're the ones 

that's holding him up, her up. 

Q You are really -- 

A And really, the appointment may have never been 

made, or the name was spelled wrong and it's not coming up 

when we call it up, that sort of thing. So, we're out there 

facing the public daily. And I'd say that is another area 

where we come into conflict. 

Q Have we just about exhausted the kinds of conflicts 

that might fit within this subcategory? 

A Yes. 

Q Do members of the Uniformed Division, regardless of 

rank, normally have contact with the Deputy Chief of Staff on 

up, say, to the Vice President and President? 

A Hmm. 
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Q And when I say that, I don't mean in letting the 

Chief of Staff have access, or in through the Northwest Gate. 

But I mean on a daily -- 1'11 change that. At any time, do 

they routinely have contact with those people, those quote 

very important people? 

A I'm not sure in what situation. Coming in the 

gate, parking on the Avenue? 

Q Excluding -- 

A Excluding that? 

Q Excluding that kind of thing, where you are doing 

your protective function. 

A I'm assuming you know all the posts where our 

officers are in the West Wing. I think, just by coming into 

contact with our people every day, the Chief of Staff or the 

Deputy Chief of Staff would probably come to know my face 

very well, maybe even my first name. And the same thing with 

the staff as it goes down. 

Our people are generally there, it's the same 

people every day. We rotate shifts and all, but, I mean, 

they would see our people very frequently, our officers that 

are assigned to the West Wing. So, I would say, yes. Yes, 

for Chief of Staff and everyone on down. 

Q What about the President and the Vice President? 

A I would say the President and the Vice President, 

only to the extent -- and it's been my experience, because I 
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worked as an officer at the White House, too -- depending on 

the personality of the individual, a nod of the head or a 

good morning. That was the extent of it. 

Q Does the President have the ability to tell an 

officer of the Uniformed Division what to do or what not to 

do, in his official capacity? 

A That would really be so far out of -- I can't 

imagine that happening. But I -- if the President said, I 

want this door kept shut, it would be done. 

Q It would be done? 

A Yes. We are there to provide the security. We're 

not there to say, well, I've been told by sergeant so-and-so 

to leave it open. He would do what the President said in 

that sort of a scenario. 

Q Can you think of some things that the Uniformed 

Division officers would not do? 

A (No response.) 

Q For example, can the President say at different 

Echo posts, I don't want somebody there at this Echo post I I 

want to create a new Echo post and put you down 15 feet, here 

or there? 

A That, that hasn't been my experience nor have we 

been asked to do anything like that. 

Q But I guess I'm asking hypothetically, the 

interaction between the President and the Uniformed Division, 
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can he direct or give commands to officers or above that are 

in the Uniformed Division? 

A I guess he could. Could. 

Q Has that been your experience during your tenure at 

the White House or within the Secret Service? 

A Never. 

Q Do you know of any instance of that, by any 

President? 

A I know of one instance where someone -- and this is 

the only instance -- like I said, I've probably worked at the 

White House on and off in my various ranks through my career 

maybe 14 years or so -- where a President, and I'm being as 

forthright as I can here, as is possible for me to be. 

Q Yes. 

A An incident happened out on the street where an 

officer divulged to someone where the President was in the 

White House, and I think to the extent of who the President 

was with. And somehow or other the person called into the 

White House, and somehow, however the scenario went, the 

watch commander was in the vicinity of the Oval Office and 

the President addressed him and said -- I don't know if he 

questioned, do our officers do this sort of thing; if they 

do, they shouldn't tell people who I'm meeting with. 

That's to the best of my recollection. That did 

transpire. 
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Q What President was that? 

A It was President Clinton. 

Q When was this incident? 

A To the best of my recollection, it was in maybe the 

spring or the summer of '97. I think that's when it was. 

Q Spring or summer of '97? 

A Yeah. It happened on a Saturday. It happened 

while I was at home and I was notified of it by the on-duty 

watch commander. 

Q Can you give us some of the names of people 

involved? 

A Captain Jeff Purdie was the watch commander, and he 

called me at home and says, I just want to make you notice of 

something that just happened. He said, I spoke to the 

President, or the President spoke to me. I think he was 

outside of the Oval Office. And he indicated that one of our 

officers out on the perimeter was addressed by a female as 

to, is the President in -- I'll tell you, I'm going back on a 

recollection here -- is the 

Wing with him, that sort of 

And the President 

me, Captain Purdie told me. 

President in, who is in the West 

a thing. 

became aware 

And he said 

of that, Jeff told 

that the President 

asked him a question like, do your officers tell people that; 

if they do, stop it, I don't want that happening, words to 

that effect. That's the best of my recollection. 
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Q 

Jeff Pu r 

A 

Q 

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This is a telephone conversation between you and 

die? 

Yes. 

Do you understand it to be on the day that the 

incident occurs? 

A Yes. 

Q I will represent to you that this incident appears 

to have taken place on Saturday, December 6th, 1997. In view 

of that representation, can you do any better with your 

estimate about -- 

A Timeframe? 

Q -- when it occurred? 

A I couldn't, because the thing that's 

mind is I have two children. Both of them are 

fresh in my 

involved in 

soccer and that sort of thing. And it was a sunny day. I 

was in my family room. There's a lot of windows and 

skylights, and it was bright and I was warm. And that's what 

I'm using as a recollection. And that's what I based spring 

or summer on. 

BY MS. WIRTH: 

Q What does it have to do with soccer? Were your 

kids playing that day? 

A Like I say, I cannot remember. But I remember just 

being involved in a lot of activities. 

Q Would they be playing soccer in early December? 
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A No, not really. Tournaments and end of the season 

would be over. 

Q Do you have a recollection -- 

A But they do play basketball, which is coming up 

then. 

Q Do you have a definite memory that they were 

playing soccer that day? 

A No, I do not. 

Q Okay. 

A I do not have a definite memory on that. 

BY MR. PAGE: 

Q so, can you take us through then from whenever this 

occurred, your recollection? I'm not asking you to repeat 

what you've already said. 

I take it the first thing that you learn about 

this, or the first thing that happens in this sequence of 

events is that you get a call at home from Jeff Purdie? 

A Uh-huh. 

Q And he's at the White House complex and apparently 

it's after the event that precipitated this had recently 

occurred? 

A (Witness nodded indicating an affirmative 

response .) 

Q IS that accurate? 

A Yes, sir. 
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Q You have that conversat ion with h 

A Uh-huh. 

26 

.im, correct? 

Q And he's calling for the purpose of putting you on 

notice that he's had a conversation with the President that 

you've described? 

A Uh-huh. 

Q Correct? 

A Yes. 

Q Well, can you tell us the remaining substance of 

the conversation? 

A He indicated his last time with the President 

there, the President just pulled the door shut. I says, 

well, is the President angry, I mean, what was his attitude, 

you know? Because in an instance where the principal like 

this would have some sort of complaint or problem with our 

people, I would be hearing about it soon. 

Q The principal, you mean -- 

A I meant the President. Somebody that's, you know, 

1 ike the President, or somebody that high up, or the Chief of 

Staff, or even some of the other people. When they have 

conflicts with our people, frequently, or sometimes -- I'm 

not the first one who finds out about it. Usually if he 

would go to somebody in the Secret Service, then it would 

come downhill. 

So, what Jeff was doing was giving me a heads-up. 
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I just had this incident with the President, I'm just letting 

you know so that you won't be blindsided when it's brought to 

your attention. 

Q So, he describes for you being near to the 

Office and having a conversation with the President? 

A Yes. 

Q And apparently the Pres 

A Yes. 

ident shut the door? 

Oval 

Q And Jeff asked you, is he mad, or words to that 

effect? 

A No, I asked him. I said to him, well, what was the 

President's attitude, was he all upset about it, was he 

angry? Just trying to get a gauge on how hot this was going 

to be. 

Q And what did Purdie say? 

A He said, no, it was just like take care of it, you 

know, make sure it doesn't happen again, something like that. 

BY MS. WIRTH: 

Q When you said the President pulled the door shut, 

what do you mean? 

A He went back into his office and closed the door 

behind him. 

Q I see. Okay. 

BY MR. PAGE: 

Q Were you appreciative of Purdie's heads-up? 
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1 A Yes. Just if it, like I said, did come downhill, a 

2 complaint from the President would be pretty significant. I 

3 mean, there would be a lot of attention given it. 

4 Q so, what do you recall is the next event as a 

5 result of this phone call that you got from Purdie? 

6 A Well, I told Purdie, make sure, find out, you know, 

7 who may have said something out on the Avenue, because that 

8 was my main concern. I mean, the process for getting people 

9 in is pretty standard. But our officers shouldn't be out 

10 there giving any kind of information out, and that was my 

11 main concern. 

12 Q And that's a request that you made of Purdie -- 

13 A Yes. 

14 Q -- during this conversation? 

15 A Yes. 

16 Q This phone conversation we've been speaking about? 

17 A Uh-huh. 

18 Q What goes on next, to the best of your memory? 

19 A I think I talked to Purdie sometime after that and 

20 he says he spoke to the officers that were on the post and 

21 just, you know, to reinforce what our policies and procedures 

22 are as far as, you know, they shouldn't be giving out any 

23 information, if they are. They shouldn't be saying where the 

24 President is or, you know, who's in the West Wing, or what 

25 appointments are coming up. We just don't give that out. 
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Q IS this an in-person conversation or another phone 

conversation during the weekend? 

A This was, I think, the following week. I can" L 

remember if it was in person or on the phone. It could 

been either, but I would see the watch commanders every 

that I'm working, on duty. 

Q Does Purdie tell 

conversation with you that 

the effect, I trust you'll 

matter? 

you during his first phone 

the President told him words 

use your discretion in this 

A I don't remember that. 

have 

day 

to 

Q Did Purdie indicate to you that the President 

wanted to sort of, so to speak, put a lid on this event, or 

contain it in any regard? 

A I, I can't, I can 

Q So, it could have 

saying, or it -- 

t answer that positively. 

happened? Is that what you're 

A It could have happened. 

Q Do you recall from your first conversation with 

Purdie over the phone whether or not this event involved 

Monica Lewinsky? 

A I cannot remember if he said that name. I honestly 

can't remember if he said that name or referred to it. At 

that time, I wouldn't have recognized it anyway because I, I 

didn't know what was going on. If he said it, I don't 
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remember it. 

But sometime after that, when these things started 

to break, I think I talked to Jeff and I says, was this the 

woman on that, and he said, yes. 

Q Is that the week after, or much, much later? 

A I think it was after the thing blew up in the 

press. 

Q I represent to you that it was made public in The 

Washington Post on Wednesday, January 21st, 1998. Are you 

saying that your conversation about the exact identity of the 

person with Purdie would have occurred after that date? 

A I, I know that -- I'm almost positive of that. 

Now, if he referred to her as Monica Lewinsky before that, I 

don't remember it. I can't recall. But I know that 

sometime -- 

Q You can't 

A Right. 

exclude it? 

Q But you don't remember? 

A Yes. 

Is that accurate? 

Q Could you tell us whether he mentioned the name 

Eleanor Mondale? 

A Yes, he did. 

Q During that phone conversation on the day of the 

event? 

A Yes. 
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Q That's your 

A uh-huh. 

Q Do you know 

being involved in the 

7 - 

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recollection? 

what he said about Eleanor Mondale 

transaction or incident? 

A No. Only that she was the guest. 

Q Did he mention Betty Currie or any other 

participant, witness, or player, so to speak? 

A I can't remember that. But, you know, I think he 

did say he was outside the Oval Office, but he was in Betty 

Currie's office. 

u When? 

A When him and the President had the discussion. 

Q Did Purdie say whether or not he was with anybody 

besides Currie and the President? 

A Like I said, I don't even know if he said Betty 

Currie was there. I don't -- 

Q Did he say -- 

A No, I don't remember any other witnesses to what he 

told me. 

Q Beyond your conversation, I believe you said 

sometime after that with Purdie, perhaps the following 

or thereabouts -- 

A Uh-huh. 

Q -- did you have any other conversations with 

or anybody else about this incident? 

week 

Purdie 
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A I think I only had that one conversation with Jeff 

after that, and it was to 

was at the Northwest Gate 

Q So that you are 

Of 

A Yes. 

You 

Q -- the Monica Lewinsky'matter on -- 

A Uh-huh. 

Q -- January 21st, 1998? 

A Yes. 

Q Besides that conversation and the conversation that 

had with Purdie on the day the incident occurred, you 

the effect, was this the lady that 

or on the perimeter. 

saying after the public revelation 

don't recall any other conversations with him? 

A No. No. Conversations, yes, but not relative to 

this. 

Q From Purdie's perspective, was this a big deal, his 

interaction with the President on this day, as a result of 

this incident? 

A Yeah, uh-huh. 

Q And why was that? 

A Because of the nature of our officer divulging 

someone in the West Wing, or divulging information that the 

President's in the West Wing. 

Q While Purdie's on duty as the captain and -- 

A Uh-huh. 
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in the 

it's a 

Q 

A 

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-- quote, the watch commander, right? 

Purdie, like I said, I can't remember him saying 

Lewinsky was out there, she was the one querying who's 

West Wing, where's the President. But he did indicate 

woman who used to work here and it was kind of -- 

YOU are motioning your hand back and forth. 

I can't -- I'm trying to characterize it. He did 

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indicate that it could be a touchy sort of a thing. 

Q During this initial -- 

A Yeah. 

Q -- phone conversation? 

A Uh-huh. 

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Q What did you take from that, that it could be a 

touchy kind of thing? 

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A I don't know. I took it that it could be a 

personal thing with the President. I took it -- that's what 

I took from it. And, like I said, my main concern was the 

security angle of it. His personal, I wasn't concerned with. 

I was just concerned with getting the appropriate people into 

the White House who belonged, and keeping out those who 

don't. And that was my main issue. Anything personal to the 

First Family, it was personal to the First Family. 

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24 

Q What did 

this was something 

Purdie say that allowed you to infer that 

about a personal thing, or maybe something 

25 about a personal thing? 

I 
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A YOU know, I don't, I don't know if Monica Lewinsky 

was in the press before this at all. But apparently Jeff, I 

guess as you know, used to be on Tours at the White House, 

and he knew a lot of people in the staff. 

Now, if there were -- if there were things that 

were inappropriate up until then, if there was like rumors 

going around, if anybody knew about this beforehand, before 

this incident, I could understand him knowing about it. I 

don't know that to be the case. But I can't exactly tell you 

what he said 

a big thing. 

Q Or 

A Or 

Q Is 

to me that made it seem as though this could be 

a personal matter? 

a personal matter, yes. 

that what you are saying? 

A Yes. 

Q Well, it wasn't in the press as of that date. You 

have this recollection that he did say something -- 

A Uh-huh. 

Q -- that I would assume -- and you correct me if I'm 

wrong -- made you think that this was about a personal matter 

involving the President, correct? 

A 

Q 

Uh-huh. 

so, therefore, it had to come from something Purdie 

told you. 

A Uh-huh. 
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Q IS that accurate? 

A Uh-huh. 

Q Do you recall any other details of the substance of 

your conversation with Purdie over the telephone? 

A No. 

Q so, tell us what your understanding -- when you 

hang up the phone from Purdie, what is your understanding of 

what has happened? 

A That someone on the perimeter answered a question 

that the President's in the Oval Office or with someone, or 

guests have arrived and gave out the name. The President is 

upset -- not upset about it, but the President questions my 

watch commander on it: how did this information get out. 

And, to me, that was the significant thing. Our officers 

aren't doing exactly what we want them to do, if that gets 

out. 

Q And isn't it also part of this story that it may 

involve a personal matter and that \_,is 

involved as well? 

A Well, as far as that was concerned, withand the other people, if they belonged in there, I 

didn't -- we did what we're supposed to do to get these 

people in. That was fine. My main concern, like I said, was 

that our officers aren't giving out information. 

As far as the personal matter, I really didn't have 
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a concern in that. 

BY MS. WIRTH: 

Q To the extent that you understood that it was a 

personal matter, was that with respect to the person out on 

the street as opposed to the person in the President's 

office? Or do you have a sense of that? 

A I just had a sense that it was with the President, 

you know. 

Q So, it wasn't clear to you which individual -- 

A No. 

Q -- that was intended? 

A No. 

Q Okay. 

BY MR. PAGE: 

Q So you viewed this as a 

incident? 

A I wouldn't characterize 

but -- 

breach of security kind of 

it as a breach of security, 

Q Well, somebody within the Uniformed Division 

allegedly indicated to someone outside the location of the 

President or who the President was with, correct? 

A Uh-huh. 

Q Is that accurate? 

A It's a breach of our procedures, yes. 

Q And on a scale of one to 10, is that a one or a 10, 
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in terms of low significance one; 10 high significance? 

A I would say probably right in the middle. It would 

be a four, if you wanted to put a number on it. 

BY MS. WIRTH: 

Q Would you characterize it fairly as a breach of 

security? 

A No, I wouldn't, because the President wasn't 

endangered by it. 

Q Does the President have to be endangered by an 

activity for it to be a breach of security? 

A Not necessarily, no. 

Q Well, why then do you say that this is not a breach 

of security because the President wasn't endangered? 

A It wasn't like there was a physical intrusion. It 

wasn't a breakdown of our technical security systems. It was 

just someone probably saying something that they shouldn't 

have said. That's, I guess, subjective on my part. I didn't 

take it as a serious -- or a breach of security. 

BY MR. PAGE: 

Q In your opinion, would this event warrant either a 

memorandum or an incident report, or some other kind of 

memorialization of what had occurred, in view of the fact 

that Purdie had had personal 

regarding what had happened? 

A No. 

dealings with the President 
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Q Can you help us understand that? 

A I didn't think at the time it was something that we 

had to -- clearly it wouldn't have been on an incident 

report. And as long as 

the post, that's what I 

with it. 

Q In your view, 

would warrant a memo so 

Purdie handled the officer down at 

wanted. That's why I was concerned 

this wouldn't be an incident that 

that you could take a look at -- 

first of all, create a memo of the facts surrounding what had 

happened, as well as to address what you put as a four on a 

one-to-ten, in terms of a potential breach of security? 

A No. Would you rephrase that, or ask that question 

again, please? 

Q I'm just wondering why, if this was a big deal for 

Purdie, who calls you at home -- 1 assume he doesn't do that 

routinely -- that the President has contact. You said in 

your 14 years that doesn't happen routinely; in fact, never 

happened except on this occasion. And in view of all the 

other facts and circumstances you've described, why a 

memorandum of the event is not generated by someone? 

A If this happened with the officer on the post, 

maybe we would have asked him to put it exactly in writing 

the way it transpired. 

Q What do you mean, if it happened with the officer 

at the post? 
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A I'm trying to go back and think, you know, why 

didn't I do that at the time. 

Q Why didn't you do what? 

A Why didn't I memorialize it in a memo, like you 

said. 

Q Well, but you're not a fact witness, are you? 

Wouldn't you tell Purdie, write something down, or tell the 

gate person who was involved in this to write it down? 

A I may have asked Jeff the extent, is this it, is 

this all this is? And he indicated, yeah. And I said, well, 

you got to talk to the guy out on the post, you know, we 

cannot be discussing blah-blah-blah, which we discussed here, 

you and I. 

Q so, your -- 

A But being the watch commander, I didn't direct him 

because I thought we had the facts right here. I didn't 

think it was any more than what was at face value. 

Q Should he have taken it upon himself even absent 

your direction, for whatever reason, in view of your request 

to go talk to the person at the gate and find out what 

happened, should Purdie have taken it upon himself to 

generate a report or incident memo? 

A Incident? No. He could have put it in a memo 

mean, he could have. 

Q Are you aware of whether or not he did it? 

I 
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20 Q I just want to get a couple of things clear. When 

21 you said earlier that in your 14 years at the White House 

22 

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this was the only time that you know that this type of thing 

had happened, what you meant by that, I take it, was direct 

contact between the President and what type of person, what 

level of person in the Uniformed Division? 

40 

A He didn't do it -- I don't know if he did it. It 

didn't go through me if he did it. 

Q Would it have been the routine practice to go 

through you had -- 

A Yes. 

Q -- he done a memo? 

A Yeah. 

Q And why would that have been? 

A Because it's like the chain of -- if he wanted to 

write this to the Chief or to the Director of the Secret 

Service or whoever, he would go through me. 

Did he write a memo? 

Q I'm sorry? 

A Did he write a memo? 

Q I can't represent to you -- 

A Oh, okay. I'm sorry. 

Q -- right now whether or not he did. 

A But I know I didn't get a memo from him. 

BY MS. WIRTH: 
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A At any level. 

Q Any level? 

A Uh-huh. 

Q Including someone such as yourself? 

A Uh-huh. 

Q Okay. So, are you aware of any circumstances 

where, at any time in the 14 years that you've worked at the 

White House, where the President had an issue involving some 

procedure involving the Uniformed Division and did raise it 

with someone at a very high level? 

A Yes. 

Q Or someone did that on his behalf? 

A Someone did it on the President's, or the First 

Lady's behalf. 

Q Okay. And at what level would that be raised? 

A It would probably be leveled at the detail level, 

at the Special Agent in charge of the detail level. I can 

think of a few instances where they didn't -- the First 

Family didn't like what we were doing, like posting a certain 

way when they would be out on the south grounds. 

Q Is that the Clinton Administration? 

A I think one incident was the Clinton 

Administration. 

Q Okay. 

Division now? 

And you are talk ing about the Uniformed 
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A Yeah. 

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Q Questions about the Uniformed Division? I 

A Yeah. And said they didn't like these people too 

I 

close, or too visible, or something like that. 

Q Okay. And who raised what with whom in that f 

/ 

particular case? From their end and your end? i 

A To the best of my memory, it was raised with the 

f 

First Lady's detail and -- 

Q The PBD? 

A Yes. 

Q And the PBD brought it to the attention of the 

Uniformed Division? 

A Yeah. i 

Q Okay. And at what level of the Uniformed Division 

was this discussed? 

A At my level. 

Q At your level? . 

A Yeah. 

Q so, someone from the PBD got in touch with somebody 

at your level? 

A Uh-huh. 

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Q And that's how it was dealt with? 

1 

A Right. / 

Q But this incident at the Northwest Gate that we're / 

i 

talking about today, this is the first one and the only one 

! 
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45 

that you're aware of in your tenure at the White House where 

the President himself had direct contact with someone in the 

Uniformed Division with respect to a complaint? 

A To the best of my recollection, yes. 

Q Okay. Do you know whether in your conversation 

with Captain Purdie, or in any discussions that you've had 

with anybody about this incident, did you ever learn that one 

of the sergeants had been addressed by the President 

directly? 

A No. 

Q Have you ever heard that? 

A I think this is the first I'm hearing it. 

Q Have you had any conversations with anybody about 

this incident besides Captain Purdie? 

A No. 

Q Okay. In any of your discussions with Captain 

Purdie, did Captain Purdie ever tell you that the President 

wanted somebody fired over this? Was the word "fired" ever 

used? 

A I don't remember that. 

Q That the President wanted somebody's job? Anything 

like that? 

A I don't remember that. 

Q You said that you have some memory of Captain 

Purdie telling you that when he was spoken to by the 
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44 

President he was in Betty Currie's office, correct? 

A Yes. 

Q Did Captain Purdie ever tell you whether he had had 

any discussions with Betty Currie about this incident? 

A I don't remember him saying that. 

Q Did Captain Purdie ever say to you, it's my 

judgment that we shouldn't write a report on this, do you 

agree? Anything of that nature, where Captain Purdie raised 

with you the prospect of not doing a report? 

A No. I don't remember that. 

Q And he never said to you, I'm not going to do a 

report, and it's my judgment that this situation doesn't 

require one? 

A I can't remember that. 

Q Okay. 

A I'm sorry. 

Q If indeed someone at the gate had said to a guest 

out at the gate, you know, the President is in the Oval 

Office and he is presently with X person, in this case 

Eleanor Mondale -- 

A Uh-huh. 

Q -- you would view that as a breach of procedure, 

correct? 

A Uh-huh. 

Q Would that be something that would go on that 
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officer's disciplinary record or personnel record, or is that 

some record that should be kept of that person's performance? 

A Performance probably. I mean, depending on how 

many times this person did this, if they'd been counseled on 

it prior. 

Q Did you have any discussions with Captain Purdie as 

to whether the person who had said these things had ever done 

anything like that before? 

A I left it to Jeff. I said, check with -- see who 

did what out there. And I'd assume that if it was something 

that should be pursued discipline-wise, or whatever, Jeff 

would have done it. 

Q Well, you said that you viewed this in seriousness 

as somewhere in the middle on a range from one to 10, in 

terms of a breach of procedure, correct? 

A Uh-huh. 

Q Is there any kind of procedure for recording 

breaches of procedure by individual officers for the purpose 

of keeping personnel records? 

A I would say no, unless a supervisor wanted to 

document this officer's been counseled on numerous occasions, 

or he's been tardy, or for whatever it is. After several 

breaches of them, I'm sure it would appear in his performance 

file. 

Q But how are you supposed to know if there are 
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several breaches if there isn't a record of it every time it 

happens? 

A Well, we kind of rely on the captains to stay 

abreast of the people that they're responsible for, and the 

other officials. 

Q Are there forms dealings with performance issues on 

the part of the employees? 

A Yes. 

Q What are those forms called? 

A I think it's Noteworthy Performance, and it can be 

used negatively or positively. 

Q so, it's like an incident report 

person's performance? 

A I wouldn't use the term incident 

could get confused with the other incident 

a -- I think it's called a 3292, 

regarding a 

report, 

report. 

Q Okay. And it records performance issues 

respect to particular individuals who are employed 

Secret Service? 

A Uh-huh. 

because it 

But it's 

with 

in the 

Q Does it report specific incidents that happen when 

they happen? 

A Sometimes. 

Q And under what conditions are those reports 

prepared? 
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A They're -- and the system is only as good as the 

people that are doing it. Maybe they should be done more 

frequently than they are. I think it depends on, like I 

said, the individual. Sometimes people are too anxious to 

complete them. And on other times, maybe people want to be a 

nice guy and not complete them. 

Q Did you have any discussions with Captain Purdie as 

to whether one would be filled out in this case? 

A No. 

Q Do you think one should have been filled out in 

this case? 

A Yeah. It probably would have been appropriate. 

Q Did Captain Purdie ever tell you that Betty Currie 

was satisfied with the way that this incident had been 

handled? 

A Like I said, I can't say under oath that he 

indicated that Betty Currie was there. 

Q So, you have no memory of that happening, of him 

saying Betty Currie is satisfied with the way that this has 

been taken care of or handled? 

A No, I don't. 

Q And just so the record is clear, do you ever 

remember Captain Purdie saying to you, I'm not going to do 

any paperwork on this because Betty Currie is satisfied with 

the way it's been handled? 
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A No, I don't remember that. 

Q Okay. 

BY MR. PAGE: 

Q Did anybody ever suggest to you, either below the 

chain of command or above your chain of command, anybody, 

that a report shouldn't be written about this incident? 

A No. 

Q And you -- 

A Not to my recollection. I don't remember anybody 

giving me any advice on it. 

Q Can you exclude that event happening, that somebody 

above you, in your chain of command or otherwise, might have 

said, don't do a report about this? 

A I'm not sure if anybody above my chain of command 

even knew it. And I wasn't getting any advice from below. 

Q Did you ever come to understand that anybody, or 

somebody I should say, did not want a memorandum or incident 

report or other memorialization -- 

A No. 

Q -- of this incident? 

A No. 

Q YOU never had that understanding from anybody? 

A Are you saying -- is your question, did someone 

advise you not to memorialize this? 

Q Either advise or -- 
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A Suggest? 

Q -- did you ever come to understand that, from 

whatever source, that a report should not be generated or a 

memorandum should not be generated about this incident? 

A No. 

BY MS. WIRTH: 

Q In your discussions with Captain Purdie, did he 

ever tell you that he had told the officers at the gate, 

after his discussion with the President, anything to the 

effect of, this never happened, today never happened, no one 

is to talk about this, as long as no one talks about this, 

nothing will happen? Anything to that effect? Did he ever 

report -- 

A Did anybody tell me that? 

Q Did Captain Purdie ever tell you that, that he had 

done that? 

A I can't remember anything like that. 

Q Have you ever heard that from any source 

whatsoever, that the officers at the gate were told, this 

never happened, today never happened, anything like that? 

A I don't recall it. 

Q Have you ever heard of anything like that happening 

before, where officers were told to forget about an incident, 

not to report it, not to talk about it? 

A Not in my -- 1 can't remember, no. 
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MS. WIRTH: I don't have anything else. 

MR. PAGE: I think that will do it for today. 

I (Whereupon, at 11:16 a.m., the proceedings were 

concluded.) 

* * * * * 

CERTIFICATE OF COURT REPORTER - NOTARY PUBLIC 

I, Elizabeth A. Eastman, the officer before whom 

the foregoing deposition was taken, do hereby certify that 

the witness whose testimony appears in the foregoing 

deposition was duly sworn by me; that the testimony of said 

witness was taken by me electronically and thereafter reduced 

to typewriting by me; that said deposition is a true record 

of the testimony given by said witness; that I am neither 

counsel for, related to, nor employed by any of the parties 

to the action in which 

further, that I am not 

or counsel employed by 

this deposition was taken; and, 

a relative or employee of any attorney 

the parties hereto, nor financially or 

otherwise interested in the outcome of the action. 

NOTARY PUBLIC FOR THE 

DISTRICT OF COLUMBIA 

My Commission 

July 31, 2000 

Expires: 
3179 

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tot tha District Of Columbia 

3rd ‘ Conw.itaion, Y.". 

~arhinqtcm, D-C. 20001 

Inre: G.mndJqProceedjngs Multi-Pagem August11,1$98 

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PROCEEDINGS 

whereupon, 

JOE BROWN OVERSTREET 

wascalledasawitnessand,afterhavingbeenfirstduly 

sworn by the Fareperson oftbeGrandJury,wasexamined 

te!&ified as follows: 

Q 

A 

Q 

A 

Q 

A 

Q 

A 

Q 

EXAMINATION 

BY MR. PAGE: 

Goodafkmoon. 

How are you? 

Fm. Would you tell us your full name, please? 

Joe B. Over&x&. 

And is that Joe Bmwn Oversheet? 

Mm-hmm. 

All right_ Is it Officer Overstnxt? 

Technician. 

Techniciau Overstreet. All right. My name is 

Edward Page. I work for the Offkx of Independent Count 

and I wanted to go over a couple of basic things before we 

gestartedtoday,aulight? 

Tbefirstisthatwhatwesayhcretodayisbeing 

taken down by tkz court reporter who is immediately to yc 

left and you are sitting now in front of a federal grand juq 

that’s investigating a&& hat&s involving Monica 

Lewhlqandothers. Doyouunderstaodthat? 

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page3 

1 A Yes. 

2 Q Okay. This is our opportun;ty to ask you some 

3 questions about what you might know related to that 

4 investigation. Do you wxkstaod? 

5 A Mm-bmm. 

6 THE COURT REPORTER You bavc to give a vahal 

7 ao!iwu,pkasc. 

8 THEwrrNESS: Yes. 

9 BY MR. PAGE: 

0 Q I un&rstand that WI& not currently working at 

1 t&WhiteHouse,youf-lywor!ccdatthcWhitcHouscasan 

2 offica with tllc uuitcd !Wcs Sazt Schce. 

3 A Correct. 

4 Q Yourc.stillarm.ubcxoftbcUuitcdStatcsSccrct ’

5 Sa-vicc,CxlHcct7 

6 ACorrect. 

7 Q And what is your -t assignmcut? 

8 A Im ’ assignad to tk spccia! opa-ations tminhg 

9 branch. 

10 QAodwhexisthat? . 

!I A Thats ’ at B&vi& Maxyland. - 

I2 Q All right Tk. John T. Riky Training Center? 

!3 A Jams J. R&y. Yes. 

!4 Q JamcsJ.R.iky? 

!5 A Conrct. 

Page 4 

1 Q Before that, up until about Sqrkmber or so of ‘97, 

2 you were employed at the White House. 

3 A 

4 Q 

5 A 

6 Q 

7 A 

8 Q 

9 A 

.O Q 

.l A 

2 Q 

As aa Officer. 

YIZS. 

Andwhatwasyourass@mentthezt? 

BeforeIleftorcorrect. As of tlx date you left. 

Unassigned, 

Did you have posts that you were stationed at? 

Yes. 

.3 atpalticularposts? 

,4 A Yes. 

s Qmposts? 

,6 A Iwasstati~atthsouthwestgateforaytxr. 

.7 priortothat,Iwasintorns,andpriortotbatIwasat 

I8 e, 

:9 Q Andwhat’s-? 

!O A ht‘ sthewestwing. ’

!l Q And within the West Wing,-, did YOU WOrka, 

!2 m orwhatpost? 

!3 A okay. ‘Ibereiswm 

!I Q tit-i&t. 

15 A ,_yes. 

Page 1 -Page4 
3180 

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m re: Grand Jury Proceedings Muk 

Page5 

1 Q m? Is that the post you worked exclusively? 

2 A No.-. 

3 Q SoamdY 

4 A Mostly-. TheonIytimeIwcntto~waSas 

5 Telief,iftheguyhadtogotothebathroomIwouldccmJcup 

6 and let him go. 

7 Q AndwknwereyouattkWhiteHouseworking? 

8 A From ‘92 -- 

9 Q To ‘91? 

0 A -- to ‘97. 

1 Q Allright. DoyouknowapersonnamedMoaica 

2Lcwhky7 

3 A Idonow,yes. 

4 Q WhenyouwereworkingattkWhiteHouse,didyou 

5 everseekr? 

6 A Yes. 

7 Q Onmtn’ethanmetime? 

8 A Yes. 

9 Q IntheWesiWing? 

0 A Yes. 

1 Q ~bwreyouStatiODedatthetime? 

.2 A, 

,3 Q Allright. Andwhim 

.4 A Ihat ‘ sinthebasemenfOffwest~~~ ’ west 

.5 Executive Avenue. 

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Q Andisthat--telluswhat’stkre. 

A It’s -- the Navy mess is down here. National 

Security Council is down then. That’s about - tkre’s a 

few offioes down tkre. 

Q Is it on the ground floor? 

A Well, it’s actually called the basement lobby, but 

it’s on the ground floor, right off of West Executive Avenue. 

IbcVPwmesinthroughtknz,it’swkre-9Opaccntof 

thetrafficthatcomesintotkwin&tkyc4lmetbroUgllthat 

door. 

Q So that’s an entrmceway, you’re saying. 

A ‘I&at’s an entrance post. Yes. 

Q lktimesthatyousawMonicaLewins&,wassk 

entering or leaving tk West Wing? 

A Both. 

Q A.nzthosetheodytimf%thatyousaWherthae? ’

A Yes. 

Q Can you e&mate for tk grand jury approximately 

how many times you saw her aming and going? 

A Iaaday’stimeormyshift? 

Q Yes. 

A Twelve, maybe 15 times a day. 

Q EnteringtkWestWiiandA having. 

Q -- and leaving tk West Wii. 

Page6 

Pagem August 11,1998 

1 

1 A Sbcwaswhatmcalkd-mrcfmultointhc 

2 west Wing as one of mt Pony Expxess paopk. ?bc intans 

3 wouldbringpapasbecLradtofmmtheOldEOBtotheWhitc 

4 Housc,totbcWcstWing,cindshcwasoneofthtm. 

5 Q Do you have soy rpccif~ recollection about brr 

6 canyinganythinginparthhl? 

7 A No, juJtpap=s. 

8 Q WelJwtztkyiaamanillafilc? 

9 A scrmctimcs,ycs. 

0 Q Didyouevusp&witbMonicaLewinsky? 

1 A Othatbansayinggoodmomiqfiminthcmomiq 

2 or ldo, tllat WBS tbc aElt of the coIlvasatioIL 

3 Q Inprtseatto~tbatsbcwasworkingattk 

4 WhikHouseinoneca+tyore&hufranapproxima~ 

5 hlyof’95tlnqJiApdaf’96. Docstbattimhamcsquarc 

6 withyowrccolkctimdhwingsccnhacomcbackandforth 

7 tbroughw 

8 A lht’saboutGgbbccauscIwouldccmcbackin~ 

9 analtmlatbccauscorrcyouworkintk~thcyliLcto 

0 pdlyoubackin. Iftby’rcs~thcy’llpullyouback 

1 ill. Ididn’tworkway&lytherreaftuIIdt. 

2 Q Didyoumrwhibyouwuctkzehavea 

3 convusatiollwdhano~socntwccagcnfwhdba 

4 oflicaorPPDpason,rboutMonicaLcwinsky? 

5 A No. 

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pagea 

Q Did sk do anytbiag aotewoxthy that you nzolIect? 

A No. 

Q whcnyousawkraftertkmediaattentionstarkd 

backinhuaryof 1998,didyouthinkaboutanyeventin 

particularor~~saytoyourself,“Ithoughtthercwasa 

problem,” “I saw kr too much,” or “I saw kr too little,” or 

anything like that? 

A No. SkwasjustlikealItkrestoftkintezns 

thatweretkre. 

BY MS. WIRTH: 

Q ~youkveauyinformation ~aboUtMtiW 

LminskymakinganyvisitstotkOvalOffice? 

A No. 

AJUROR: DidyoueverseekrtkreonaSaturday? 

THEWITNESS OnaSaturday? IfIdi&Icau’t 

recall. It’s possible, but I can’t lCmem~,tobehoncst 

with you 

A JUROR: -you. 

MS. WIRTHZ Any otkr questions? 

(No rcsponse.1 

THE FOREPERSON: You are excused. 

MS. WIRm Thnk you. 

THE FOREPERSON: Thank you. 

lH.EWITNESS: naltkyou 

MR. PAGE: Thank you. I 

Pages-Page8 

Diversified Reporting Servict~. Inc. (2021296-2929 
3181 

II re: Grand Jury Prodgs MUll 

Page S 

1 (73~ witness was excused) 

2 (whereupon, at 4:40 p.m., tk taking of testimony 

3inthepresenceofafullquorumoftfieGrandJurywas 

4 concluded) 

5 ’ ***** 

Pagem August 11,193 

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