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UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF VIRGINIA 

(Alexandria Division) 

-- - ---_---_-----x 

: 

UNITED STATES OF AMERICA : 

: 

vs. : Grand Jury Number 97-4 

: 

JOHN DOE : 

: 

--------------_-_x 

U.S. Courthouse 

401 Courthouse Square 

Alexandria, Virginia 

June 10, 1998 

The testimony of HAROLD McEWEN ICKES was 

taken in the presence of a full 

Jury beginning at lo:08 a.m. 

BEFORE: 

JIM CRANE 

Associate Independent 

EDWARD J. PAGE 

Associate Independent 

DAVID BARGER 

Associate Independent 

quorum of the Grand 

Counsel 

Counsel 

Counsel 

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PROCEEDINGS 

Whereupon, 

HAROLD McEWEN ICKES 

was called as a witness and, after first being duly 

sworn by the Foreperson of the Grand Jury, was examined 

and testified as follows: 

EXAMINATION 

BY MR. MR. CRANE: 

Q Good morning, Mr. Ickes. 

A Good morning. 

Q My name is Jim Crane. I'm an Associate 

Independent Counsel. Here at my left is Mr. Edward 

Page, also Associate Independent Counsel. Along the 

back wall is Mr. Barger, also Associate Independent 

Counsel. And these are the members of the Grand Jury, 

the court reporter being opposite you at the end of the 

third table there. 

A Okay. 

Q Now, I understand that you are, in fact, a 

lawyer. However, as we do with all witnesses, I'll go 

over your advice of rights and responsibilities as a 

witness testifying before the Grand Jury, which you're 

probably quite familiar with and so I 

fairly quickly. 

will do this 

You are aware of your Fifth Amendment right, 

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1 i that you need not answer any question which you believe 

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would tend to incriminate you. Is that correct? 

A Yes. 

Q And there are several categories of 

individuals which appear before a Grand Jury. 

Generally, they're broken down into targets and 

subjects, You are not a target, you are a subject, and 

a subject -- 1 will read the definition from the 

Department of Justice manual, just so we have it clear. 

A subject is defined as "A person whose conduct is 

within the scope of the Grand Jury's investigation. In 

some districts, the term subject is interpreted broadly 

and most witnesses are advised to consider themselves 

subjects." Do you understand that you are a subject 

under that definition? 

A I do. 

Q And you understand that although you are a 

subject here today the government cannot promise you 

that you will always remain a subject and that at some 

point you may not become -- that you may possibly 

become a target or even a defendant? 

A Right. 

Q Is that clear? 

A Yes. 

Q Now, you are represented by counsel here 

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A 

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Is that correct? 

I am. 

And that is Ms. Amy Sabrin? 

Sabrin, S-A-B-R-I-N. 

All right. 

Yes. 

And you understand, as I'm sure you do, that 

you have the right to consult with Ms. -- Sabrin? 

A Sabrin. 

Q Sabrin. I'm sorry, I keep saying it wrong. 

A Sabrin, yes. 

Q __ a reasonable number of times should you 

need to, so long as it doesn't disrupt the, the 

questioning, it doesn't become so frequent. 

You understand further that you have the 

obligation to testify truthfully, as you have been so 

sworn by the Foreperson? 

A Yes. 

Q And to testify otherwise would be perjury 

which is in itself a federal offense? 

A Yes. 

Q Anything that you say here can be used in 

subsequent Grand Jury proceedings or in subsequent 

legal proceedings against you. Do you understand that? 

A Yes. 

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Q Okay, this Grand Jury is conducting an 

investigation of what is commonly known as the Monica 

Lewinsky/Linda Tripp matter, as I'm sure you're 

familiar. The offenses that we are looking into and 

the members of the Grand Jury are looking into are 

perjury, obstruction of justice, witness tampering, 

suborning perjury in relation to Monica Lewinsky and 

any other person in the lawsuit known as Paula Corbin 

Jones versus William Jefferson Clinton, et al. And we 

are here as a -- the members of the Grand Jury convened 

to look into that issue. Is all of that clear to you? 

A Yes. 

Q And just finally, the secrecy concerns. 

Rule 6E, as I'm sure you're aware, applies to us, the 

prosecutors, the members of the Grand Jury, the court 

reporter. We are not allowed to talk about anything 

you tell us here today other than the attorneys may 

share the information with other members of our office. 

You, on the other hand, are free to share the 

information with any person to whom you see fit; your 

attorney, of course, and any other person. And all of 

that is clear to you? 

A Yes. 

Q All right. If I could just ask you to state 

your full name again and spell your last name so the 

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court reporter does have it correct. 

A It's Harold Ickes, I-C-K-E-S. 

Q No middle name? 

A I have a middle name, I never use it. It’s 

McEwen, M-c-E-W-E-N. 

Q All right. Could you tell the members of the 

Grand Jury, you were formerly employed at the White 

House, I believe, as -- in a high position. If you 

could describe what that was and where you're currently 

employed, sir. 

A I was employed at the White House as an 

assistant to the President and deputy chief of staff, 

and I currently run my own business. 

Q And what was the time frame that you worked 

at the White House? 

A Approximately, early January of 1994 to late 

January of 1997. 

Q All right. And you had that position 

throughout your roughly three-year tenure there? 

A Yes. 

Q And what is the business that you run now, 

sir? 

A It's a consulting firm in Washington, D.C. 

Q And what sort of consulting do you do? 

A It's mostly with clients who have situations 

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they need to try to solve, probiems they need to try to 

solve in Washington, D.C. 

Q Well, generally, what sort -- is it fair tc 

state that you're not actually practicing law now? 

A No, I'm not -- I do not practice law. 

Q Okay. 

A Have not practiced law since joining the 

White House staff. 

Q 

A 

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All right. But you have been to law school? 

I have been, yes. 

And where did you go to law school, sir? 

Columbia Law School in New York City. 

And when did you graduate? 

In the early 1970s. 

And what year was that? 

I don't recall the year. It was, it was, I 

don't know, '71 or '72, I think, when I got my degree. 

Q And after you graduated, where did you go to 

work or what did you do? 

A I have done a variety 

campaigns and otherwise. 

Q All right. And for a 

of different jobs in 

period of time you did 

practice law with a firm, I understand? 

A I did. 

Q And what firm was that? 

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A The firm is currently Meyer, M-E-Y-E-R, 

Suozzi, S-U-O-Z-Z-I, English, E-N-G-L-I-S-H, and Klein, 

K-L-E-I-N, and it's located in Mineola, New York, which 

is Nassau County. 

Q All right. And what year did you leave that 

law firm? 

A Well, I never really left. I took a leave of 

absence at one point, but I resigned from the law firm 

in December of 1993. 

Q I see. And are you admitted to practice law 

in any jurisdiction in the United States or elsewhere? 

A In the Courts of the State of New York and in 

the Southern District and Eastern District of the 

Federal Courts of New York. 

Q I see. And where did you go to undergraduate 

school? 

A I went to the University of Arizona for my 

freshman year and Stanford University for my last three 

years. 

Q And what year did you graduate from Stanford 

University? 

A 1964. 

Q All right. And what did you major in 

A Economics. 

Q Now, who is Jane Mayer or Jane Mayer? 

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1 A If it's the person that I'm thinking of, she 

2 is -- she works for the -- or she writes for The New 

3 Yorker. She's a, she's a journalist. 

4 Q Turning your attention to the time frame of 

5 mid-March of this year, 1998, can you just tell us what 

6 contacts and dealings you've had with Ms. Jane Mayer? 

7 A. I don't recall specific times. I know that 

8 during this spring that I have talked to her. I've 

9 known her for several years. I've talked to her on 

10 several occasions during 1998, this spring, and I may 

11 have met with her once or twice and talked to her on 

12 the telephone, again, once, twice, three times. 

13 Q And what is the purpose of your conversations 

14 with her? 

15 A She's a journalist and I have talked to her, 

16 I've answered her questions. She typically has called 

17 me to ask me questions about various things. 

18 Q Is your relationship with Ms. Mayer simply as 

19 a private citizen or is it related in any way to your 

20 consulting business? 

21 A It's not related -- I've known her, as I 

22 said, when I was -- I first met her when I was on the 

23 White House staff. We've kept in touch since and she 

24 has not -- my relationship with her has nothing to do 

25 with the consulting business. 

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Q All right. And your conversations with her 

from the March 1998 time period to the present, are 

those purely of a private citizen expressing an 

interest in news or journalistic affairs? 

A Well, when you say -- I'm not, I'm not 

employed by her. She's not a client. So, it -- and we 

don't -- 1 do not have a professional relationship with 

her. 

Q I see. Do you speak to her on behalf of any 

client? 

A No. 

Q And when I say client, I mean a, a paid -- 

individual who would pay you for your consulting 

services? 

A No, I do not. 

Q Do you have any reason to be talking with her 

related to your consulting business? 

A No. 

Q And approximately how many times have you met 

with her in person? 

A I don't know. I know her socially as well as 

as a journalist. I think, by my recollection, no more 

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than two, 

March, if 

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maybe three times have I met with her since 

that many. 

And what about since January, since the 

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Monica Lewinsky/Linda Tripp issue surfaced? 

A How many times have I -- the question is how 

many times have I met with her? 

Q Yes. 

A Face to face? 

Q Yes, since January 21. 

A Again, I've -- I don't 

recollection. Probably not more 

four times. 

have a specific 

than, at the outside, 

Q And when you go to meet with her, where do 

you go? 

A It depends. Sometimes I'll have lunch with 

her, sometimes she'll come to my office. 

Q And after the Lewinsky/Tripp scandal became 

public, you became -- is this accurate, sir? -- 

somewhat more involved in dealing with the media? Is 

that accurate or inaccurate? 

A Well, in dealing with the media in what 

connection? 

Q Reference to the Tripp/Lewinsky matter. 

A And when you say dealing with the media, what 

do you mean? What does that mean? 

Q Talking to them. 

A Yes, I, I would say -- 1 think it's a fair 

characterization to say that after the first publicity 

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about Ms. Lewinsky that I did increase my contacts with 

the media, or they with me. 

Q All right. And was that just out of your 

personal interest or did you talk to anyone else at the 

White House about becoming some sort of a informal 

media advisor? 

A No, I didn't talk to anybody at the White 

House. To my recollection, I did talk to Mickey 

Kanter. 

Q And who is Mickey Kanter? 

A He is the former Secretary of Commerce, 

former trade representative, and is now in private 

practice -- as far as I know, is in private practice in 

Washington, D.C., with a law firm. 

Q All right. And what law 

A He is with Mayer, Brown, 

think, a Chicago law firm. 

Mr. 

the 

and 

Q And do 

Kanter has? 

firm is he with? 

Platt, which is, I 

you know what sort of practice 

A Lucrative. That's what he says. No, I -- 

answer is I don't know. He seems to travel a lot 

apparently gets paid well for it. 

Q So, do you and Mr. Kanter have some 

arrangement whereby you are informal media advisors for 

the White House in this -- in the Tripp/Lewinsky 

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scandal, if you will? 

A Well, all of that's definitional. I, I talk 

to, I talk to Mickey about -- he has a -- I think he 

has a more formal role at the White House certainly 

than I do. I don't have a formal role. My 

understanding is he has a lawyer/client relationship 

with the President. I do not. And he -- 1 talked to 

him about what role he was doing and what -- how I 

might be helpful, and we both agreed -- and this was 

early on in -- right after the Lewinsky situation 

became public. We agreed that I would, to the extent 

that I had time and could take time from my business, 

that I would spend most of my time talking to reporters 

and that's basically what I've done. 

Q 

located 

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All right. And your consulting business is 

here in Washington, D.C. Is that correct? 

Yes, it is. 

And what is the name of that? 

It's the Ickes and Enright Group. 

And Enright is your partner or associate? 

She's my partner. 

And do you have a business telephone? 

I do. 

And what is that number? 

It's - 

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1 Q All right. Do you have a home phone? 

2 A I do. 

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Q And what is that number? 

A -. You'll only get an answering 

machine, so don't call. 

u Do you also have a cell phone? 

A I do. 

Q And what is that cell phone number, sir? 

A --- I'm terrible on numbers -- _ 

Q And were all these phones operating from 

January to -- through, through the present? 

A From January of '98? 

Q Yes. 

A Yes, they were. 

Q Okay. And did you have occasion to discuss 

media affairs with journalists on all three of these 

phones? 

A Well, I don't know what you mean by 

phrase affairs. Have I talked to journalists 

of those phones since January of '98, is that 

question? 

Q Yes. 

A The answer is yes. 

Q So that would be at home, business, 

the cell phone? 

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A Right. 

Q Are there any other places where you go to 

discuss the Tripp/Lewinsky 

telephone? 

A It depends where 

I'm -- we're pretty mobile 

matter on anyone else's 

I am. I mean, you know, if 

and sometimes I use -- if 

I'm in somebody's office and I need to call somebody or 

somebody -- 1 get a message that somebody has called -- 

we have voice mail on our business phone as well as on 

the cell phone, and if I get a voice mail that I think 

I need to return, I will return it, either from 

wherever I am or from a pay phone. 

Q All right. 

A It's fairly infrequent but 

occurred. 

it has, it has 

Q Before I forget, Mr. Ickes, just essentially 

as a housekeeping matter, let me show you what I would 

represent to you to be a copy of the subpoena which we 

sent to your lawyer, just to make sure -- and then ask 

you about some documents you've given us today. Does 

that appear to be a copy of the subpoena that was sent 

to your lawyer? 

A It does. 

Q And in response -- that subpoena calls for 

your personal appearance here. Is that correct? For 

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you to come and talk to the Grand Jury? 

A That's the only reason I'm here. 

Q Right. And it also called for you to produce 

some documents to us, which you have done this morning. 

Is that correct? 

A I -- yes, my lawyer did. 

Q Okay. And did you look over the definitional 

section of the subpoena rider that goes on for a couple 

pages, defining documents fairly broadly? 

A I, I looked it over. 

Q Okay. And are these the only documents that 

you had in your custody, control or know of? 

A Yes. 

Q All right. 

A Yes, to the best of my knowledge. 

Q And just for the members of the Grand Jury, 

the document consists of a number of pages. And 

without looking at each page, it appears to be a copy 

of your civil deposition in the Judicial Watch -- what 

I call the Judicial Watch matter but it's actually 

Cara Leslie Alexander, et al., v. Federal Bureau of 

Investigation. Is that accurate? 

A Yes. 

Q And you have no other documents other than 

your -- the transcript of your civil deposition in your 

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custody? 

A That's correct. I do have -- well, I think, 

if I read that subpoena correctly, it's a long 

definition, but I think you excluded newspaper clips. 

Q Yes, that's correct. 

A Okay. I do have copies of other Judicial 

Watch depositions that were taken in this same case -- 

Q Surely. 

A -- and those were put up on the Internet and 

I pulled some of them down on the Internet, but -- 

Q Right. And I would represent to you that 

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Q But I will just look over the definition 

here. We asked you to produce any and all documents 

and/or files related to the Linda Tripp/Monica Lewinsky 

investigation. And then it goes on, "including but not 

limited to notes, memos and any other correspondence." 

so, I take it there were no other documents responsive 

to our subpoena? 

A No. I searched my files and, as best I can 

tell, this is it. 

Q Did you at any point in the past take any 

notes about Linda Tripp in general since January 21? 

A Not that I recall. 

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Q And didn't produce any document, memo, 

talking point, anything like that for use in dealing 

with the media? 

A No. 

Q What about when you talk to people at the 

White House, if you, if you do talk to them? Do you 

ever take notes relative to Linda Tripp? 

A Not that I recall. I've had very little 

discussion with White House people about Linda Tripp, 

but I don't -- any notes that I would have taken that 

are in existence I would have produced. 

Q And who at the White House would you have had 

conversati ons with concerning Linda Tripp? 

A The -- I think the people that I can best 

recall would include Rahm Emanuel, Paul Bagala. Those 

would be the two primary people. Probably Mike 

McCurry, the press secretary. From time to time, I've 

talked to him. Whether or not I've talked to him about 

Linda Tripp, I don't know. I do talk to the President 

and the First Lady infrequently. I don't recall 

specific discussions with either of them about 

Ms. Tripp. And Ann Lewis is another person I talk to. 

And Lanny Brewer, I've talked to him from time to time. 

So that's sort of the complex of people I've talked to. 

When he was still there, I would talk to Lanny Davis as 

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well. 

Q All right. And is this a fair or an unfair 

statement, Mr. Ickes, that the individuals you've 

talked to at the White House would be quite displeased 

or somewhat displeased with Ms. Tripp? 

A Oh, I don't know. I didn't ask them what 

their attitude was. 

Q From the type of comments since the 

Tripp/Lewinsky matter has hit the papers, do you have 

any inkling to whether they're, they're happy with what 

Ms. Tripp did, in particular the taping of Monica 

Lewinsky, or, or unhappy with her? 

A Again, I don't, I don't recall any specific 

discussions about -- with these people about Linda 

Tripp. So, I would -- as I sit here today under oath, 

I couldn't tell you what their attitude was. I can 

make an assumption that they're probably less than 

happy, but I don't recall any specific discussion with 

any particular person. 

Q What about not just related to Linda Tripp 

but the, the Lewinsky/Tripp scandal at large, not 

related simply to those two individuals? But they're 

at the heart of it, so I'll refer to it as the 

Lewinsky/Tripp scandal. What sort of things have the 

people in the White House told you? 

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A Well, I want to make clear, which I made 

clear already but let me just repeat it because I think 

it bears repeating. I do not have lawyer/client 

privilege with the President or Mrs. Clinton or 

anywhere else who work at the White House. So, I -- my 

knowledge is limited only to what is known by tile 

public at large through media sources. 

I think it's fair to say that it is a very 

unhappy situation and that they would prefer it was not 

around, but it's here. 

Q And who has told you they would prefer it's 

not around but it's here? 

A Well, as I say, I didn't say -- I'm not 

quoting anyone. I say that's my -- I think that's a 

fair characterization, which is my characterization, of 

I think the general attitude at the White House, that 

it is an unhappy situation, an unfortunate one and -- 

but it's here and we have to deal with it. 

Q Okay. And who specifically have you talked 

to at the White House regarding Monica Lewinsky? 

A I have talked -- is there a time period on 

this? 

Q From January -- generally, I will say from 

late January to the present, 1998. 

A I, I have talked to the President, I have 

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talked to Mr. Bagala, Mr. Emanuel, probably Ms. Lewis, 

probably Mr. McCurry, although I don't have a specific 

recollection of discussing it with him, Mr. Brewer, and 

probably Mr. Davis. 

Q What did the President say about Monica 

Lewinsky? 

A The only discussion I recall having with him, 

he denied that he had had sexual relations with 

Ms. Lewinsky and denied that he had -- I don't know how 

to capsulize it -- obstructed justice, let's use that 

phrase. 

Q And how long did this conversation last? 

A I think it -- it's my recollection it was 

quite short. It was on -- that, on that specific 

subject, it was a matter of less than five minutes. 

Q Okay. What you have just told us now, 

without looking at my watch, but that only took like 30 

seconds. What did you all talk about for the other 4% 

minutes reference Monica Lewinsky? 

A Well, that is a summary of a conversation 

which I estimate took no more than five minutes, what I 

just told you. 

Q All right. So, what other details were 

discussed in the other approximately 4% minutes that.-- 

A I have no, I have no recollection of any 

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specific details. I can tell you that's what -- the 

summary of the conversation on that particular subject. 

I met with the President -- that same meeting probably 

lasted an hour in which we discussed a range of 

different things. 

Q Okay. Was this an in-person meeting? 

A Yes. 

Q All right. In the White House? 

A Yes. 

Q What date? 

A It was the Sunday -- I'm sorry, it was the 

Monday morning, early Monday morning immediately -- of 

the week immediately following the first week that the 

Monica Lewinsky situation became public. 

Q All right. So, generally -_ 

A Which I recall was in the middle of the week, 

and then it was either Wednesday or Thursday it became 

public. And so, this would be the Monday morning, 

early Monday morning immediately following when it 

became public. 

Q Did the President ask you to act as sort of 

an informal media advisor for him? 

A He didn't ask me to act as a media advisor, 

he asked my opinion about what I thought of the 

situation and I told him that -- he told me that 

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Mr. Kanter was going to be involved and, in fact, had 

an attorney/client privilege with him. I did not see 

the necessity of having an attorney/client privilege 

myself and I told the President that I would try to be 

helpful and that I would talk to Mr. Kanter about how 

best I could be helpful. 

Q But I think I've asked you this earlier and I 

don't mean to belabor it, but you don't get any sort of 

economic or any tangible benefit out of doing this. Is 

that true? 

A Unless you count negative economics an 

economic benefit. It cost me a considerable amount of 

money appearing before Grand Juries and Judicial Watch. 

Q All right. 

A Tens of thousands of dollars. So, there's a 

negative economic relationship. No, but the answer is 

I don't get any -- 1 don't get paid by the White House 

of Mr. Kanter or any of the President's lawyers in 

connection with this. 

Q All right. And you don't get any sort of 

benefit whereby business is referred to you or some 

sort of informal arrangement whereby they say if you 

help us out here we'll send you, send you clients for 

your, your meat and potatoes business? 

A No. 

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c! What else -- who else was present with your 

meeting with the President? 

A When I first walked 

recollection -- this happened 

My best recollection was that 

into the room, my best 

what, several months ago. 

Roger Clinton was present 

and Harry Thomason was present. One other fellow whose 

name I can't remember was present. But they, they left 

very shortly after I came into the room. 

Q And so, was your meeting with the President 

alone or was there anyone else there? 

A Mr. Thomason was there for -- my recollection 

is that, that the other two people left immediately. I 

think Mr. Thomason was there for a short period of time 

and then he left, also. 

Q And could you just tell the members of the 

Grand Jury who is Mr. Thomason and what is his past and 

present relationship to the White House? 

A He -- Mr. Thomason is a, for lack of a better 

phrase, he is a producer of movies and films, I think 

mostly for television consumption. He lives in 

California. He and wife produce television movies and 

films. And he was born in raised in Arkansas, is close 

to the President, has known the President for a long 

time and is -- from time to time comes east to see the 

President. 

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Q All right. And currently, he's not any type 

of consultant or informal position with the White 

House. Is that your understanding? 

A I have no idea what, what his relationship 

with the White House is. 

Q All right. Have you ever met Linda Tripp? 

A I have. 

Q And when was that? 

A My recollection is it was right after we came 

to the White House in early January of 1994 and I think 

she was -- my recollection is she was working in the 

White House Counsel's Office which is on the third 

floor of the West Wing. From time to time, I would go 

to the White House Counsel's Office and that's -- my 

recollection is that's where I met her. 

9 Did you ever have occasion to look at her 

personnel files while you were employed at the White 

House? 

A Not to my knowledge. 

Q Do you know if anyone else had occasion to 

look through her personnel files for any reason 

whatsoever? 

A During what time period? 

Q During the time period that you and she were 

employed there? 

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A Not that I know of, no. 

Q All right. And do you know where personnel 

files are located within the White House or the 

Executive Office Building complex? 

A I don't. 

Q And do you know who is in charge of personnel 

files? 

A I don't. 

MR. CRANE: Does anyone, members of the Grand 

Jury or the witness, would you like to take a break at 

this time? 

excused. 

GRAND JUROR: Yeah, sure. 

FOREPERSON: Break 10 minutes? 

MR. CRANE: Ten minutes then? Okay. 

MR. BARGER: Permission for the witness to be 

FOREPERSON: Yes. 

MR. CRANE: You may step out, Mr. Ickes. 

I'll be right out. 

WITNESS: Okay. 

MR. CRANE: Thanks. 

(Whereupon, at lo:39 a.m., 

recessed and subsequently reconvened 

FOREPERSON: I remind you, 

still under oath. 

the Grand Jury 

at 11:05 a.m.) 

sir, that you're 

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WITNESS: Yes. 

BY MR. BARGER: 

Q Mr. Ickes, before we proceed with further 

questions, just -- 1 wanted to cover one matter for the 

record. Over the course of the recess, your attorney 

had one question about the fact when you came into the 

Grand Jury you were read a definition of subject and 

told you were a subject. Is it fair to say that prior 

to your appearance that one of the attorneys in the 

Office of the Independent Counsel had advised your 

attorney, at least as you understand it, that your 

status was that of a witness? 

A Yes, that's what I was told. 

Q Okay. Just to clarify, your status is that 

of a witness. The reason the term subject was used 

this morning is that the Department of Justice manual 

basically has two formal categories, target and 

subject. It does not actually use the definition or 

the category witness. However, prosecutors, over time, 

have developed sort of an informal third category of 

people who are viewed as witnesses, that is, they are 

not, they are not subjects, they are viewed as people 

who may have information relevant to the Grand Jury. 

So, there is no formal category of witness and that is 

why you were told, using the Department of Justice 

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definition, you're a subject, but your status has not 

changed from that of what Ms. Corcoran advised your 

attorney. 

A Okay. 

Q Thank you. 

BY MR. CRANE: 

Q Okay, Mr. Ickes, we'll continue and -- 

basically where we left off. I wanted to focus now on, 

more particularly on the Linda Tripp personnel file 

matter, reference mid-March of this year. Now, did you 

have a meeting or a dinner with Mr. Kenneth Bacon at 

some point, February-March of this year? 

A I had dinner with him on -- that I can recall 

on two occasions this late winter-early spring. I 

don't recall the exact -- I don't even recaJ1 the 

months. I do recall one month but I don't recall the 

other month. 

Q What was the one month you remember? 

A We had Passover dinner at, at the same house 

together. 

Q 

A 

Q 

A 

Q 

At where? 

At the same house together. 

Okay. And was that his house? 

No. 

Whose house? 

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A It was Stephen Cohen. 

Q Okay. And who is Stephen Cohen? 

A He's a professor of law at Georgetown 

University School of Law. 

Q And I take it he is a friend of yours? 

A He is. 

Q And also of Mr. Bacon's? 

A Yes. 

Q Okay. And Mr. Bacon is the Assistant 

Secretary of Defense for Public Affairs. Is that your 

understanding? 

A I know he works for the Pentagon and he 

speaks to the press a lot. That's all I know. 

Q Okay. So, one was a dinner at Stephen 

Cohen's house. And did you say that was a Passover 

dinner? 

A 

Q 

check the 

A 

Q 

before or 

A 

Yes. 

Okay. So that would 

date on the calendar 

Right. 

And the other dinner 

after that? 

The other dinner was -- my best recollection, 

it was before the Passover dinner. 

Q And what did you talk about concerning Linda 

be Passover. We can 

. 

you had, would that be 

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Tripp? 

A In, in i;hich situation? 

Q Start at the first dinner. 

A I don't think -- well, at the Passover 

dinner, I don't think there was any discussion. I 

don't recall any discussion with -- about Linda Tripp. 

Q Okay. What about at the earlier dinner? 

A The earlier dinner, it was a very peripheral 

discussion. I think the best that I can recall is that 

there was -- I don't know whether I raised it or 

Mr. Bacon raised it, I may well have raised it, the 

fact that Ms. Tripp, who was in the news at that time, 

was working at the Pentagon. I may have asked Ken when 

she came over to the Pentagon. And that was really the 

extent of it. 

Q Did Mr. Bacon tell you that Linda Tripp 

worked for him? 

A He -- my recollection is that she worked in 

the Public Affairs department, whether -- so if he, if 

he is in fact the head of the Public Affairs 

department, I assume that she worked for him. But my 

understanding is it's a fairly large operation. 

Q Did Mr. Bacon say anything like Linda Tripp 

works for me or is in my chain of command? 

A Not that I recall, anything with that 

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3 dinner to indicate he was displeased with Ms. Tripp's 

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15 A I probably would have recalled that. As I 

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precision, no. 

Q Did he say anything at that first earlier 

actions in taping Monica Lewinsky? 

A No. He expressed no opinion, as far as I 

recall, on what she had done. 

I Q Did he make any mention of attempting to 

terminate Ms. Tripp from her employment? 

A Did he make any attempt? 

Q Did he make any reference to possibly trying 

to terminate Ms. Tripp? 

A Not that I, not that I recall. 

say, I don't think we got into any detail like that. 

My recollection is that she was in the news at that 

time and I -- my recollection is I said something about 

Linda Tripp working over at the Pentagon and, as best I 

recall, he responded by saying she worked in the Public 

Affairs department. And I think that that was all 

there was of the discussion, very in-passing. 

Q Where did the -- you may have told me this, 

but where did the earlier dinner take place? 

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1 / Mr. Cohen's house. 

2 Q And are you all three mutually friends or is 

3 Mr. Cohen more your acquaintance/friend than 

4 Mr. Bacon's? What's, what's your relationship among 

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the three of you? 

A Well, I've known Mr. Cohen for -- since 1968 

and I've known him quite well. Mr. Bacon I met, to the 

best of my recollection, when I came to work for the 

White House. I don't recall when I first met him, but 

I may have met him through Mr. Cohen, as a matter of 

fact. He used to be -- my recollection is he used to 

work for The Wall Street Journal. 

Q Mr. Bacon that is? 

A Yes. 

Q And Mr. Cohen, professor of law at 

Georgetown? 

A Yes. 

Q All right. Did Mr. Cohen say anything, to 

your recollection that -- anything along the lines of 

Linda Tripp ought to be fired? 

A Did Mr. Cohen? 

Q Yes. 

A No, I don't, I don't recall Mr. Cohen 

expressing any opinion about her. 

Q He had no opinion on Linda Tripp whatsoever? 

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A Not that I recall. 

Q No opinion about whether she could be fired 

or should be fired? 

A As I stated 

any opinion about her 

Q And did you 

A. I did not. 

before, I don't recall him having 

express your opinion about her? 

I don't think I had an opinion. 

Q And as you sit here today, do you have an 

opinion? 

A I have an opinion that's -- I know what she's 

done from reading it in the press. I haven't talked to 

her. 

Q But in your contacts with the media, do you 

try to portray what she has done in a favorable light 

or in an unfavorable light? 

A I try to portray the facts. People can draw 

their own conclusion. 

Q And what facts have you portrayed? 

A I've portrayed the facts that are known in 

the media. 

Q Which ones? 

A Oh, I don't know that. We could spend all 

day here. But basically that she -- according to the 

media, she worked in the White House. She was 

subsequently transferred to the -- or she transferred 

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1 herself, I don't know which, to the Pentagon. That she 

2 ; got to know Ms. Lewinsky, either at the White House or 

3 

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11 A Well, I talk to a lot of media, sometimes 25, 

12 30 on a running basis. So, it's very hard for me to 

at the Pentagon. And it's reported that she taped 

certain conversations that Ms. Lewinsky had with her 

the telephone. And it's also been reported that she 

was wired by Starr and, as a result of that wire, 

recorded conversations. 

Q I see. And in your discussions with the 

media about Ms. Tripp, is that all you do, simply 

portray facts that have already been reported? 

on 

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the media, but basically I stick as much -- close as I 

can to the facts as I know them and as they have been 

reported. 

Q All right. Now, was there anyone else 

present at your first meeting, first dinner at 

Mr. Cohen's house? 

A Not that I 

of his children were 

daughter was there. 

Q Okay. And 

Chinese food? 

recall. I don't recall that any 

there and I don't think my 

was this the one where you had 

A The first one? 

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Q Yes. 

A Yes _ 

Q That's correct? 

A Yes, it is correct. 

Q All right. 

A It was either Chinese or Thai, I forget 

which. Or it may have been Indonesian. 

Q And you had take out brought there to 

Mr. Cohen's house? 

A Well, it was his house. I don't know where 

he got it from. 

Q And you have no recollection, or you do, of 

discussing Linda Tripp in particular with the 

President? 

A I have no recollection of discussing Linda 

Tripp with the President. 

Q Do you think you did and have since forgotten 

about it? 

A No, I have no recollection that I did. 

Q Okay. Have you expressed your opinion 

anyone concerning whether Ms. Tripp's employment 

be terminated? 

A I don't have any -- not that I know of. A f 

to 

should 

don't have an opinion on that, I don't know what the 

rules are governing her employment. 

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since January 

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have you, have you said to any person 

21 of this year I think Linda Tripp ought 

to be terminated for what she did? 

A Not that I recall. 

Q Any words to that effect, if not those exact 

words? 

A Not that I recall. 

Q And that's not the type of thing you would 

forget, though, is it? 

A Well, I don't have the best memory, but most 

people don't have good memories, So, I've given you 

the best of my recollection. 

Q No # but trying to get someone else or asking 

that someone else might be fired, that's kind of a 

important thing, isn't it? 

A Depends on who it is and in what context. 

Q All right. Did you at any point see a 

Form 398 reference Ms. Linda Tripp? 

A No. I don't even know what a Form -- the 

answer is not to my recollection. I don't know what a 

Form 398 is. 

Q Okay. Did anyone from the White House or any 

other source ever send you any sort of a personnel form 

that looked like a standard government form on 

Ms. Tripp? 

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A I am, I am quite sure no one did. I j,ave no 

recollection of seeing any government form on her. 

Q Have you seen any written documentation on 

her otlker than news articles sent to you by any other 

person? 

A Do that again. I'm sorry. 

Q Apart -- putting always aside news articles, 

you know, we're interested in your -- 

A Right. No -- 

Q -- news clipping file, but any other sorts of 

forms, documents, reports, fax sheets, bullet points, 

talking points on Ms. Tripp, again, the time frame from 

January 21 till the present. 

A Not that I recall. I mean, the White House 

fram time to time sends out stuff, but I don't recall 

receiving anything from anyone about Linda Tripp. And 

if 1 did, 3 probably would have kept it. And if I had 

kept it, I would have produced it. 

Q And to your knowledge, you've never seen the 

form where government employees are asked have you ever 

been arrested, detained, convicted, et cetera? 

A Well, I've seen that form in connection with 

myself. 

Q With yourself. But with reference to Linda 

Tripp? 

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A No. 

Q And you're certain of that or you just don't 

remember? 

A Well, 

absolutely dead 

quite confident 

recollection of 

I'm not -- let me say I'm not 

certain about much of anything. I'm 

that I have not. I have no 

seeing any form like that. 

Q All right. Did Jane Mayer Hamilton ever send 

you any personnel forms on Linda Tripp? 

A No, I'm quite sure she did not. 

Q Did she ever fax you anything on a fax 

machine or in hard copy mail other than the article 

that she wrote? 

A I, I have no recollection that she did and 

I'm quite confident that she did 

v Mr. Page is looking at 

think he may want to -- 

not. 

his calendar, so I 

MR. CRANE: Did you want to tell us a date or 

something? 

MR. PAGE: No. 

MR. CRANE: Okay. 

BY MR. CRANE: 

Q Did Ms. Mayer ever tell you that she was 

going to release personnel information concerning Linda 

Tripp publicly, in her article or otherwise? 

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A Well, she told me that she was writing an 

article. She had called me, I don't know when, 

obviously before she wrote the article, and said that 

she was doing an article or thinking about doing an 

article on Ms. Tripp and asked if I knew anything about 

her. I told her that I knew nothing about her other 

than the fact -- other than what I read in the 

newspaper and other than the fact that I had met her, 

as I've testified earlier, while she was working at the 

White House Counsel's Office. So, I was of no -- I had 

virtually no information for her that she didn't 

already know. 

Q Did Ms. Mayer request your assistance in 

finding personnel or security type information about 

Ms. Tripp? 

A No. 

Q Did anyone else within the White House 

indicate to you that they had Ms. Tripp's personnel 

file, had access to it and knew what was in it? 

A Did anyone in the White House indicate? 

Q Yes. 

A No. I'm, I'm confident that no one did. 

BY MR. BARGER: 

Q Did anyone outside the White House? Did 

anyone ever say anything to you to suggest they had 

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access to her personnel file? 

A No. You know, other than -- I mean, my 

problem is I've, I've now merged Ms. Mayer's story and 

the public 

the time. 

talking to 

ity surrounding that with, wit ,h the events of 

But I have no recollection of 

me about her personnel file. 

anybody 

Q What's your understanding of why she called 

you? Since you basically didn't know Linda Tripp, why 

did Ms. Mayer call you to find out what you knew about 

Linda Tripp? 

A You'll have to ask her. 

Q Okay. Do you have any understanding of why 

she called you? 

A I can only speculate. If you want 

speculation, I can give you that. 

Q Sure. 

A Huh? 

Q Please. 

A Typically, journalists call people that they 

know who they think may know something about the 

subject that 

I had worked 

they are currently working on. And since 

in the White House at the time that 

Ms. Tripp worked there, 1 can only speculate that 

Ms. Mayer who, as I said before, I knew, both on a 

social and as a journalist, called me to see if I knew 

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1 anything about her. 

2 BY MR. CRANE: 

3 Q And Ms. Mayer-Hamili,Jn has come to your 

4 ;,office one or two times. Is that accurate, sir? 

5 j A I, I think at the most two is the best of my 

I 

6 1 recollection. 

7; Q All right. And prior to coming to your 

8 / office, you had some telephone conversations with her, 

9 j I take it? 

10 1 A Well, as I said before, I have, I have a, a 

1.1 i social and a -- relationship with her, as well as a 

12 ! relationship with her in her capacity as a journalist 

13 j so, I've talked to Ms. Mayer from time to time. 

14 I 

I Q All right. But when she comes to your 

15 : office, she's coming in her capacity as a journalist. 

/ 

16 1 Is that accurate? 

17 ! A I think in both situations she did. yes 

18 ; t) All right. And my question to you is wny 

19 I would she come to your office if you so very little 

20 I about what's going on in the White House, what's going 

21 j on in the Tripp/Lewinsky matter in general? 

22 ; A As I said -- I tllink I've answered that but 

23 j I'll, I'll answer it again. It's her -- most 

24 i journalists when they first start on a -- working on a 

/ 

25 / story, they start talking to people that they know, 

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that they think might know something about the subject 

matter that they're currently working on or writing 

about. And it was my impression, I mean, you'll have 

to ask her, but it was my impression that she, she 

wanted to come -- she said specifically she was working 

on a story about Linda Tripp and wanted to come over 

and wanted to know if I had time to meet with her. And 

I did and it was a brief meeting. 

(2 All right. And have you learned subsequently 

by any source, second-, third-, fourthhand, hearsay, 

whether any person in the White House provided 

personnel information to Ms. Mayer for her New Yorker 

article? 

A No. 

Q Do you have any, any clue whatsoever as to 

how that personnel information could have gotten into 

Ms. Mayer's hands? 

A I do not. 

BY MR. BARGER: 

Q Did Ms. Mayer, when she either talked to you 

on the phone or met with you in person, say anything to 

you to suggest that she was aware of this, this 

allegation, this fact concerning Linda Tripp's 

background? Specifically, that she may have been 

arrested sometime prior? 

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A She may have. And my problem is all of this 

stuff has merged. There's been so much written about 

it and so many people have talked about it. I can't 

sit here today under oath and say yes or no. She may 

have. I don't recall a specific conversation about it, 

but -- 

Q Okay. 

A -- she could have. 

Q Well, as best you can separate it, when she 

talked to you on the phone or came to your office, what 

if anything would she tell you about what it was she 

was working on with regard to Linda Tripp? In other 

words, what was the story she was working on for Linda 

Tripp? Wllat did she want to write about Linda Tripp? 

A Ily understanding -- best as I can recall, my 

understanding is that she was doing a story on Linda 

Tripp. The New Yorker does those kinds of profiles and 

my understanding, it was basically a profile and that 

she was trying to get background information about 

Ms. Tripp. 

Q Did she say anything -- what did she say to 

you, as best you can recall -- and you said background 

information. Did she say anything to you to suggest 

she had obtained background information from anybody 

else prior to coming to see you? 

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A I don't recall. Most journalists are pretty 

closed-mouth about where they get their information 

from. So, she, she clearly knew something about Linda 

TrippI but where -- what those sources were, she didn't 

tell ;;le and I didn't ask her. 

Q Well, when you say pretty closed-moutll, i.s it 

fair to say that given your extensive experience 

with -- contact with journalists that if, if the 

journalist believes it's in their interest to, you 

know, share a little tidbit with you about having 

gotten some information from another source, whether 

they reveal the source's identity or not, sometimes 

they'll do that? 

A Sometimes they will. 

(2 So, let me go back to my question. Did she 

say anything to you to suggest that -- strike that. 

Let me ask it this way. When she came to you, did you 

have the impression she was coming to you with a clean 

slate, that she knew nothing about Linda Tripp? 

A No, I was certainly not under that 

impression. 

a Did you get the impression from her that she 

had talked to other people to gather information before 

she had come to you? 

A I got the impression -- I was under the 

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impression that she knew something about Linda Tripp. 

How much, I don't know. And I assumed that she had 

talked to other people, but I didn't specifically ask 

her whether she had or whether she had not. 

BY MR. CRANE: 

Q Did she say something to the effect, Mr. 

Ickes, I have information that Linda Tripp's been 

arrested and I want to find out how I can find out how 

she answered questions on personnel files? 

A She may have. I don't -- as I say, as I've 

said -- I've answered this now three times, but I'll 

answer it 

A lot has 

for the fourth time. All of this has merged. 

been discussed, as you all know. There's a 

lot on the public record. 

chattered about this. And 

today under oath, separate 

know now. 

A lot of people have 

I cannot, as I sit here 

what I knew then and what I 

My best recollection is that she was going 

to -- she said that she was going to do a story about 

or a profile, for lack of a better phrase, on 

Ms. Trim?, wondered if I had worked with her. I told 

her that I had and she asked me if she could come over 

and see me and I said yes. I do not know recall any 

specific conversation at that time about arrest 

records. 

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Q so, is it possible that that happened and 

you, you've forgotten about it since then? 

A It is possible. But as I said, I 

any specific recollection. And so much has 

don't have 

happened 

since then I cannot separate one from the other. 

Q All right. 

BY MR. BARGER: 

Q When you say so much has happened since then 

that you do not have a specific recollection of a 

conversation, does that mean that as you understand it 

today that when she came to see you one of the things 

she was looking for was confirmation about this arrest? 

And when you say you can't separate what you knew then 

from what you know now, that suggests to me that what 

YOU know now is that she knew that at the time she came 

to see you. 

A Well, I don't know how you draw that 

inference, but you can draw whatever inference you 

want. I think I've answered the question now five 

times. 

Q Well, regardless of how many times -- 

A Well, I don't have to answer a question more 

than once. 

MR. CRANE: Well, that's -- 

MR. BARGER: We won't debate how many times 

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you have to answer a question. Let me, let me go back 

to -- 

MR. CRANE: While you're thinking, let me 

follow up on this, see if I can phrase the question in 

a different way without asking you the same one, 

Mr. Ickes, because I don't mean to badger you. 

BY MR. CRANE: 

Q But I -- and I agree with what you're saying 

about there's been so much information and lots and 

lots of articles and things have merged. We see the 

same story in different magazines and I think that's 

what you -- is that what you mean when you say that 

information has merged? 

A Yeah. There's been a 

information. There's been many 

and also on the news. 

huge amount of 

stories, many articles, 

Q Right, on all facets of the -- 

A Exactly. 

Q Okay. But to my knowledge, and correct me if 

I'm wrong, there has been no media account that said 

Jane Mayer called you up and said Mr. Ickes, I have 

information that Linda Tripp has been arrested and I 

want you, Harold Ickes, former deputy chief of staff in 

the White House, to help me figure out where in the 

White House her personnel file was. As I understand 

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it, there has been no story on that. Is that, is that 

your understanding? Do you know of any story that -- 

A No, I don't know of any. There may have 

been. There have been a lot of stories written. But I 

don't know of any. 

Q so, it's not like there's some story out 

there that says that that would have merged with your 

knowledge? So that the merger issue simply doesn't 

apply to whether Ms. Mayer-Hamilton said to you I know 

that Linda Tripp was arrested and I want to figure out 

if she fudged on a personnel form. 

A What's the question? 

Q Well, there's no merger on that issue? 

A Well, I don't know. You can characterize it 

whatever you -- whatever way you want. The facts -- 

I'm here to testify about facts. You can characterize 

and draw your own inferences. 

Q Do you know, just generally, any part of the 

White House where personnel files -- when you were 

there, was there somebody who was in charge of records? 

Like, if you had to take annual leave or adjust your 

thrift savings plan, any sort of those -- any of those 

sorts of personnel issues that we federal employees 

deal with, who did you go to? 

A Well, there is a division within the White 

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House itself, the Office of Administration, and there's 

also a separate division, Office of Personnel, headed 

by different people. A lot of my, you know, 

association -- 1 had association with both, but on the 

type of tiling that you're talking about in your 

question I think would be basically handled by the 

Office of 

Q 

A 

Administration. 

And who is in charge of that? 

Different people at different times. During 

the time that I was there, I forget who was there 

initially but after Mr. Panetta became chief of staff, 

which was mid -- early to midsummer of 1994, Jody 

Torkelson became the head of the, for lack of a better 

phrase, department or of Administration. 

Q All right. And during this time frame, 

January to the present, '98, January 21, '98, to the 

present, have you had any conversations with Jody 

Torkelson? 

A Since January? 

Q Yes. 

A I have seen her socially a couple of times. 

Q Has there been 

A There may have 

because of the fact that 

and we all had worked in 

FREE STATE 

any reference of Linda Tripp? 

been some casual reference 

Linda Tripp was in the news 

the White House. I don't 

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remember any specific conversation with her. 

Q Any reference to her personnel file that you 

can remember? 

A Other than it may -- I don't think -- I'm not 

sure that I've seen Jody since Ms. Mayer's article. I 

don't recall any specific conversation with her about 

personnel files. 

Q What about prior to Ms. Mayer's article? 

A What about it? 

Q Conversations with Jody Torkelson before 

then. 

A About? 

Q About Linda Tripp's personnel file. 

A I don't, I don't recall any conversation 

before then. 

Q Okay. Was there another person? You were 

mentioning, I think, two -- one was Office of 

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administrative duties that you were referring to? 

A There's, there's a, again, a unit within the 

White House, the Office of Personnel, White House 

Office of Personnel, which is basically -- it was a 

separate unit from the Office of Administration. 

Q And who is in charge of that? 

A During most of the time that I was there -- I 

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forgot who was the first head of that. I think Bruce 

Lindsey was, if not the head very involved, basically 

running it. And then a man by the name of Bob Nash 

came in and took over and is currently still there.. as 

far as I know. 

Q Bid you have any conversations with Bruce 

Lindsey regarding Linda Tripp's personnel file? 

A Not that I recall, no. 

u And did he ever fax you or send you a copy of 

her personnel file? 

A No, not that 1 -- I have no recollection. As 

I said, as I testified before, I don't think that I 

received anything from the White House on Linda Tripp's 

personnel file. 

Q All right. And that would include Mr. Nash? 

He never sent you anything? 

A Yes, yes. He worked -- he works in the White 

House. 

Q And he's never sent you anything. Is that 

correct? 

A I have no recollection of it, no. 

Q And Mr. Blumenthal, has he ever sent you 

anything relative to Linda Tripp? 

A No, not -- 1 have no recollection of 

receiving anything from Sidney. 

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Q And not her personnel file that you can 

recall? 

A No. 

Q Since the article concerning Linda Tripp's 

arrest was published in The New Yorker, have you had 

any conversations, follow-up conversations with Mr. Ken 

Bacon? 

A You'll have to give me a time frame on that. 

ft I think that -- her article 

early March? 

Q Yeah, about March 13 

it's published, although there 

on it before it actually comes 

was published when, in 

or 14 is the date that 

was some advance press 

out in hard copy. 

A The only conversation that I can recall 

having with Mr. Bacon is I called him the other day at 

the Pentagon to ask him what his recollection was as to 

when the Great Chinese Dinner took place, because I had 

no recollection, and I had been asked that in the -- 

that was cne of the questions asked of me in -- by 

Mr. Klayman in the Judicial Watch deposition, and the 

best I could place it was within the last several 

months. And I called Mr. Bacon and his recollection 

was sometime in mid-February, but I don't have an 

independent recollection of that. 

Q All right. 

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A That's the only time that I recall talking to 

Mr. Bacon. That was the only thing we talked about. 

Q Okay. Just to get the time frame, was the 

Great Chinese Dinner sometime mid-February? 

A Right. And assuming -- I'm, I'm just taking 

everybody's word for that. 

Q Right. And then the Passover dinner -- 

A The Passover dinner -- 

Q -- thereafter? 

A Yeah, I think I saw Mr. Bacon at a restaurant 

in Washington, D.C., and again, I can't for the life of 

me place the time of it. I think it was, it was either 

before or 

Q 

A 

well have 

if it was 

think the 

Mr. Bacon 

briefly. 

after the Passover dinner. 

All right. 

And I thinlc it was -- I think it may have -- 

been after Ms. Mayer's article was published, 

published in early March. So, I think 

sequence was the Great Chinese Dinner, 

in a restaurant, chatted with him very 

I -- I 

saw 

He was going out and I went over just to say 

hello to him. Passover and then the phone call. Those 

are the four, those are the four -- and that's the 

sequence that I recall the contacts being with him. 

Q And what was the name of the restaurant where 

you saw him just in passing? 

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54 

Kincaid's which is on Pennsylvania Avenue in 

Washington, B.C. 

Q Okay. And no substantive discussion 

place concerning Linda Tripp at that time? 

A Not, not that I recall. It was just 

you doing, what's going on. 

took 

hi, how 

Q Okay. When you called Mr. Bacon just the 

other day, did he say anything else about the status of 

either this investigation or any internal 

investigations the Pentagon may be doing? 

A He did not. I just called him and asked him, 

I said, "Ken, you know, a couple journalists have 

called me" -- because Larry Klayman does his fund 

raising by doing a deposition and then he rolls it up 

on the Internet and goes on "Geraldo." So, he had made 

my deposition public and he had been on Gerald0 Rivera 

that same night that he took my deposition, and several 

journalists had gotten a hold of it and -- or heard 

about it and 

have no idea 

took place. 

had called me. And for the life of me, I 

when that dinner, the Great Chinese Dinner 

Q All right. And your follow-up contacts with 

Ms. Mayer since the article was published, is there any 

follow up that you've had with her to talk about how 

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the article was received or the 

violations against Ms. Tripp? 

A I don't -- I probably 

alleged Privacy Act 

have talked to Jane. 

can't remember when or where. And at best, they were 

peripheral. I mean, the article was the article and 

she, you know, I don't recall having any specific 

conversation with her about it. 

Q All right. 

MR. CRANE: I am just about finished. 

Mr. Page or Mr. Barger, did you have anything further 

relative to, to this issue? 

BY MR. CRANE: 

Q Oh, let me just ask you this. I always think 

of something as soon as I say I'm going to finish. Do 

you have any understanding of what the Privacy Act is? 

A No, other than, other than its title and the 

implications of its title. I know nothing about the 

details of the Privacy Act. My assumption is it's -- 

it governs certain kinds of records that are to be kept 

private, but I am certainly -- I'm not even a neophyte 

about it, much less an expert. 

Q During your tenure in the White House as 

deputy, deputy chief of staff and advisor to the 

President, do you know of any 8occasion in which a 

personnel file on an employee was released without 

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their consent? 

A The only thing that I can recall is the, the 

Great FBI File Fuss, and you all know more about that 

than I do probably. At least I hope you do. 

Q All right. 

A But other than that, no, no. 

Q 00 you know of any other occasion, you know, 

putting aside that matter, in which someone went and 

looked at the file of an employee who might be thought 

to be a troublemaker, somebody had a grudge against, 

and get something and then release that information to 

a journalist to sort of dirty them up, if you will? 

A I don't recall. There may have been some 

stuff in newspaper articles, but I don't, I don't have 

any direct knowledge, 

allything in the press 

Q All right. 

and I don't even recall reading 

about it. 

Let me ask you this. To my 

knowledge, and is this accurate, there haven't been any 

Privacy Act scandals, if you will, in this 

Administration until this incident. Is that your 

understanding or is there some that I -- one that I've 

overlooked? 

A That's my understanding, with the exception, 

obviously, of the FBI fuss. 

Q All right. And do you have any knowledge of 

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files it, it protects? 

A No. I know, I know that lawyers make a great 

living out of it but other than that, I know almost 

nothing. 

MR. CRANE: All right, I think I have no 

further questions if Mr. Barger or Mr. Page wanted to 

follow up. 

MR. BARGER: Yeah, I have -- 1 do have some 

questions and I believe Mr. Page has some questions, 

too. 

BY MR. BARGER: 

Q Let me sort of work chronologically 

backwards. The phone call you had with Mr. Bacon, do 

you recall anything else about the conversation other 

than what you've related? In other words, that you 

asked him when the Chinese dinner took place? 

A No, that's -- best my recollection, that's 

all, that's all I wanted to find out. And he's a busy 

person and I'm busy, so it was -- 

Q Did he, did he ask you any questions or say 

anything else to you besides what you had asked him? 

A No. I mean, I may have just because he's a 

friend, said -- you know, I may have said how you doing 

and he typically says okay. But the sole purpose -- it 

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was a very, very short phone call, I would say less 

than a minute. 

B Do you remember when, approximately, the 

phone call was? 

A It was after the Klayman deposition which 

was, what, two weeks ago and -- 

Q Approximately how long after would you 

estimate? 

A I can't remember. I would say four or five 

days following, roughly. 

Q Did you take any notes of your conversation 

with Mr. Bacon? 

A I did not. 

Q If we could just go back, you earlier 

testified -- I'm not saying these exact words but 

basjcally to the effect that you didn't receive 

anything from the White House on her personnel file. 

Let me deal briefly with that topic, just to make sure 

we're covering the universe here. And it may have the 

question was, may have been the question was did you 

receive anything from the White House. I just want to 

make it broader. Did you receive -- as best you 

recall, did you receive any, any documents, any written 

material concerning Linda Tripp from anyone, excluding 

newspaper articles? 

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1 A I think I said in response to that I may 

2 have. From time to time, the White House does send out 

3 so-called talking points. From time to time, very 

4 j infrequently, I have received talking points from the 

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White House. I don't recall receiving anything in 

connection with Linda Tripp. And since I'm a pack rat, 

I generally would have kept something like that and I 

found nothing in my files. So, I guess the short of it 

is I can't guarantee that I didn't receive anything, 

but I don't recall it and I certainly -- I don't have 

it. 

Q As best you recall, you did not? 

A Right. 

Q And you mentioned the White House sending you 

materials on occasion. That actually prompts another 

question. 

A On rare occasion. 

Q And let me limit it to January 1st of '98 to 

the present. 

A Right. 

Q In general, how often would you estimate the 

White House sends you what you call talking points? 

A It's -- 

Q And again, limited to January to the present. 

A Right. I would say no more than three or 

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four times in that period. 

Q When you, when you, when you get it, who, who 

takes the -- who sends it to you? 

White House, it's like -- 

When we use the 

A No, no. No, no, it's a good question. I 

think they're usually distributed by, by the Office of 

Communications which is headed up by Ann Lewis. 

That's, that's my understanding. I mean, I would -- 

Q Are these things that are sent only to you or 

what -- or are these items that are made available to 

the public or -- I mean, what is your understanding of 

who the talking points are to be distributed to? 

A Again, you'd have to ask Ms. Lewis. My 

understanding is that they are distributed to people 

like myself who are talking to the media, to the press 

in connection with these issues. 

MR. BARGER: Is there a knock on the door? I 

thought I heard something. 

GRAND JUROR: No, it's -- 

MR. BARGER: Oh, I'm sorry. Creaky bench? 

I'm sorry. 

Q 

the press 

selective 

BY MR. BARGER: 

And when you say talking to the, talking to 

or the media, I take it that, that this is a 

group to whom the White House distributes the 

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talking points. In other words, I assume they dol)'t 

distribute them to people they perceive to be hostile 

to their interest in talking to the press. Is that 

fair to say? 

A I think not. And the more Grand Juries there 

are, the fewer people that are even willing to take 

anything from the White House. 

Q Because they might get subpoenaed. 

A Well, they might well. 

Q And going back -- 

A They'll need $10,000 in lawyer's fees. 

Q Now, you mentioned lawyers and lawyers' fees. 

Just for the record, you're represented by, I'm sorry, 

Ann -- 

A I'm represented by the law firm of Skadden, 

Arps, and Amy Sabrin is my lawyer. 

Q Is anybody else besides Amy representing you, 

not necessarily just today but in general in your, in 

your appearances? 

A Yes. Robert Bennett, also of that firm, and 

. 

a, another lawyer by the name of Lily Arbab, A-R-B-A-B. 

Q And Mr. Bennett, of course, has some 

notoriety for another client. Fair to say? 

A That's a characterization but I, I might even 

agree with you on that. 

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1/ Q Okay. I know it's a big stretch to -- if you 

2 / agree with that. And that would be the President, 

I 

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3 1 correct? 

A Yes. Yes, he dqes represent the President. 

Q Going back to your meeting with -- 

MR. CRANE: I'm sorry, Mr. Barger, if I could 

just interrupt before we lose that train of thought. 

8 BY MR. CRANE: 

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13 A That's a good question. You'll have to ask 

14 AmY. I, I think she does talk to other lawyers. 

Q On that issue, you're represented by the law 

firm of Skadden, Arps and these three lawyers in 

particular. Do you have or have you consented to a 

joint defense agreement with other witnesses? 

15 1 Whether that -- whether there's a formal joint defense 

16 agreement, I'm not sure. You can ask her. 

17 ’ 

I Q 

Okay. But the attorney/client privilege, as 

18 I'm sure you're aware, protects any confidences which 

19 you may share with Amy Sabrin, Bob Bennett, Lily Arbab. 

20 So, in order for them to, to breach that, share your 

21 confidences with others, they must have your consent. 

22 So, my question to you is have you given them your 

23 consent, expressly or otherwise, yes Ms. Sabrin, yes 

24 Mr. Bennett, share this with anyone whom you please or 

25 with the President, with, with other people? 

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1 A Well, you'll have to -- you would have to ask 

2 her. My best -- they've represented me since early 

3 1994 when I was first subpoenand by the Independent 

4 Counsel, then Mr. Fiske, and I have testified -- I've 

5 received dozens of subpoenas and testified, including 

G today, probably over 20 times in that time period. So, 

7 you will have to -- I, I literally -- I'm not trying to 

a duck the question, I just -- I don't know. We have a 

9 very close relationship and they do on that kind of 

10 thing what they think is best for me. So, you're just 

11 going to have to ask Amy. 

12 Q All right. 

13 MR. CRANE: Mr. Barger. 

14 BY MR. BARGER: 

15 Q Going back to your meeting with Ms. Mayer, I 

16 don't know if you testified to this. Did you testify 

17 approximately how long did the meeting last? This is 

la the in-person meeting. 

19 A I testified that there were -- that I recall 

20 two. They lasted, I think, no more than 10, 15 

21 minutes, as best as I can recall. 

22 Q Those were at your office? 

23 A Yes. 

24 Q Did you take notes when she met with you? 

25 A No. 

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Y When she talked with you over the phone, di.d 

you take notes? 

A No. 

Q Is there any particular reason why you didn't 

take notes? 

A I wasn't eliciting information. She was 

eliciting information from me, and I had precious 

little to give her. 

Q Okay, I'm sorry. She was eliciting 

information from you, you weren't eliciting information 

from her. 

A 

Q 

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know. 

No. 

So, you didn't see the need to take notes. 

Right. 

Do I understand that? 

Yes, that's correct. 

What are you doing today? 

I'm taking notes. 

And we're eliciting information from you? 

Yeah. 

Correct? 

Right. 

In your experience at the White House -a 

But I intend to debrief my attorneys, as you 

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1 Q All right. And they may share it if they 

2 believe it's in your best interest? 

3 A If, if they believe it's in my best interest. 

4 

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8 many of us that it was not a great idea to take notes. 

9 Q Because they might be subpoenaed by -- 

10 A Given -- 

11 Q -- Independent Counsel? 

12 A -- the hundreds of subpoenas that were being 

13 

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15 reduction in taking of notes. 

16 Q And by distinct reduction, that suggests a 

17 conscious decision. Fair to say? 

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21 Q All right. The meeting -- and I'm sorry, and 

22 that's all I'm talking about, on your part. The 

23 

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25 that meeting? 

Q In your experience working at the White 

House, was it ever discussed over the course of time 

whether it was a good idea or bad idea to take notes? 

A Well, I think, I think it came to dawn on 

distributed by Independent Counsel, other agencies, and 

the Congress. So, I think that there was a distinct 

A I think certainly on my part. 

Q Okay. 

A I can't speak for others. 

meeting with the Prestdent that was alluded to or asked 

about earlier in your testimony, did you take notes at 

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A I did not. 

Q And you testified, I believe that the entire 

meeting lasted approximately, I want to say around an 

hour? 

A In that neighborhood, yeah. It was, it was, 

as I say, very early Monday morning. 

Q And this -- and your recollection, at least 

as I understand it, was this, this Monday morning 

meeting was very shortly after the, the Monica Lewinsky 

story broke in the media? 

A Yes. My recollection is that she -- the 

story broke the middle of the prior week. I was in 

California the latter part of that week giving a 

speech. And then when I came back, I went over to see 

the 

I'm 

President. 

Q And when you went over to 

sorry, was that at his request? 

A "es. 

see the President, 

Q And I mean his, I mean was a request made 

personally by him or was it made by somebody 

his behalf? 

A Well, I had talked with him on the 

else on 

telephone 

when I was in California, a very brief conversation, 

and he asked if I would -- if I had time if I would 

meet with him when I got back. And I can't recall 

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whether the -- I think the details of the meeting were 

probably set up through his office. 

Q Prior to the meeting with the President, did 

you talk with Mr. Kanter? 

A Prior to the meeting with the President? 

Q Yes. 

A. I did not. I'm quite sure I didn't. 

Q All right. You testified earlier about there 

was a point in time when you had some conversations 

with Mr. Kanter 

as I understand 

you might take? 

A Yes. 

and you generally discussed, at least 

it, basically what, what kind of role 

Q And that -- as best you recall, that occurred 

after your meeting with the President? 

A I'm quite sure that occurred after the 

meeting. 

Q And I apologize that -- 

A That's all right. 

Q -- I'm not recalling this. Did -- was 

Mr. Kanter present at the meeting with the President? 

A That early Monday morning meeting? 

Q Yes. 

A He was not. 

Q At that meeting with the President, how much 

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would you estimate of the hour's meeting 

with a discussion of the -- I don't know 

call it except the Monica Lewinsky topic 

68 

was taken up 

exactly liow to 

which 

encompasses Linda Tripp, Monica Lewinsky. How much of 

that hour's meeting would you estimate was taken up 

with that sort of current event? 

A Well, it was -- I would say probably about 

half of it. I mean, the President is notorious for 

talking about a lot of different subjects and he -- 

when -- typically, when I've talked to him he focuses 

on a variety of different subjects. But I would say 

it's fair to say that probably half the time was spent 

on a discussion about that current situation. I mean, 

he, he had asked for my assessment of what I thought, 

and so it was back and forth along those lines. 

Q What was -- and it may be implicit in some of 

the answers you've given, but what was, what was your 

purpose in going to the meeting? I mean, was the -- 

was your purpose in going to the meeting because of 

this Monica Lewinsky topic? 

A I went to the meeting because the President 

of the United States asked me to come. 

c1 And as you understood it, the reason he asked 

you to come was because of this breaking -- this story 

that had just broken? 

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1 A That was my assumption, yes. 

2: BY MR. CRANE: 

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Q Okay. Let me just ask you, Mr. Ickes, if 

this is a fair evaluation of the situation in early 

January, after the Lewinsky/Tripp tapes were revealed, 

that the White House was reaching out to its former 

advisors, the best and the brightest, to sort of bring 

them back home, which -- is that accurate or 

inaccurate? 

A Well, you could say for those of us who came 

back home it was not necessarily the best and maybe the 

dumbest. But putting that aside for the moment, I 

don't want to characterize best and brightest because 

that has a whole connotation on its own. But again, 

putting that aside, I, I think it's fair to say that 

the President and the First Lady were, were in contact 

with some of the people that they thought they wanted 

to ask advice of and get their advice -- and get advice 

from. 

Q And that would include 

A It would have included 

Mr. Thomason, and there may have 

you and Mr. Kanter? 

myself, Mr. Kanter, 

been others that I 

don't know about. I hope that, to use your phrase, the 

best and the brightest included a bigger group than 

that. 

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Q And I just have -- I know you've already 

asked this and I don't mean to badger you, but you said 

you're not getting paid in -- essentially, in any way 

shape of form -- 

A No. 

Q -- by the President or by Mr. Kanter? 

A .No. Or by the White House or by -- no. 

Q All right. So, you're doing this essentially 

out of loyalty. Is that correct? Loyalty to the White 

House, loyalty to your friends? 

A I'm doing this because the -- because I have 

been the President's friend for over 25, close to 30 

years. I have a great deal of admiration for him and I 

like him. I worked for him. I think he's done a lot 

of good for the country. And he asked me -- he asked 

my advice and he asked me to work with Mickey on this. 

Q All right. So, is it fair to say you're 

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amongst his most loyal advisors, former advisors, 

supporters, and friends? 

A Well, I, I don't want to characterize myself. 

I mean, that's, that's, that's a characterization which 

you and members of the Grand Jury can draw. I've known 

him for a long time and I have a high regard for him. 

Q Okay. But you -- 

A I consider him my friend. 

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Q YOU consider him your friend and you consider 

yourself a loyal friend of the Presidellt? 

A Yes. 

BY MR. BARGER: 

Q Did you -- and I apologize if you did. Did 

you state who was at this meeting at the White Rouse? 

A Yes, I did. 

Q I'm sorry. Who was -- just for my benefit -- 

A When I first walked into the room there 

was Roger Clinton -- 

Q Oh, that's right. 

A -- who is the President's -- there was 

another fellow there who's a -- he'll kill me if he 

reads this transcript and I don't remember his name. 

He's basically a writer and he lives in Baltimore. I 

cail't remember his name. And Mr. Thomason were there 

when I first walked in. 

U At that particular -- at that meeting, did 

the President say anything about whether Mr. Kanter 

would have a role in handling or participating in or 

dealing with this, this sort of -- this latest crisis 

or controversy involving Monica Lewinsky? 

A Be told me -- the best that I can recall, he 

told me that Mr. Kanter's firm had been retained, that 

Mr. Kanter had a lawyer/client relationship in 

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connection with this situation and that Mr. Kanter and 

his firm would be working on this matter with other 

lawyers that were working on it. 

Q And as I understand, the President then 

suggested or discussed with you or asked you to, to 

talk with Mr. Kanter to see how you might participate 

or, or get invclved. Is that, is that a fair -- 

A Well, I don't know if he suggested. I think 

we -- 1 think I suggested to him that I would talk to 

Mickey. I told the President he had enough lawyers 

cluttering up his life, I didn't -- although I probably 

could have had a lawyer/client relationship, I did not 

see any usefulness to it from his point of view or from 

mine and that 

do that might 

Q And 

I would talk to Mickey about what I could 

be useful. 

I believe at some point you -- I don't 

know if I have the phrasing exactly right, but you 

agreed that you would -- that your role and that you 

spend most of your time talking to reporters or the 

media, but my question has to do with is that something 

you discussed with the President or Mr. Kanter or both? 

A I certainly discussed it with Mr. Kanter. I 

may well have said to the President that that is 

something that I would talk to Mickey about. But 

again, the President and I did not go into gory detail 

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about what I was going to do because I think both of us 

agreed I should talk to Mickey first. 

Q Okay. And as you recall it, the President 

said something to you at that meeting, words to the 

effect I did not have -- tell me, as best you recall, 

the words the President used about describing what he, 

what he didn't do with Ms. Lewinsky. 

A The two things that I recall, the two things 

that he again repeated in public -- had already said 

publicly and repeated in public that same Monday 

morning was that he had not had -- he did not have a -- 

or he had not had a sexual relationship with 

Ms. Lewinsky and that he had done nothing -- now I'm 

paraphrasing -- had done nothing to ask anybody to 

change their story or suborn perjury or obstruct 

justice. 

Q And was that -- was his statement to you 

about that, was that in response to a question you 

asked him or was that something he volunteered to you? 

A I, I don't recall. It was -- look, this 

happened a long time ago. It was, it was very late at 

night. I had just come back from California. Whether 

he volunteered it or whether he asked -- whether I 

asked him specifically, I -- my recollection is he 

volunteered it but I don't know that as a fact. 

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Did you get any sense of why he felt it 

necessary to volunteer that to you? I mean, you just 

said you were a close friend of his for many, many, 

many years. You were a trusted friend. What prompted 

him to feel the necessity to tell you that -- 

A You'll have to ask -- 

Q -- as you understand it? 

A Assuming that I didn't ask him and that it 

came from him voluntarily, you'll have to ask him. I 

can only speculate and my speculation would be that 

this was at that time a very newsworthy, very difficult 

issue. And there was even speculation over the 

weekend, the weekend being the weekend that I talked to 

him, about whether his Presidency could weather this 

and it struck me natural that either I asked him or he 

said it. 

U Well, you used, you used a phrase or in 

answering the question you said basically you'd have to 

ask him. Has -- do you have any reason to believe that 

the President is willing to, to allow us to ask him 

that question? 

A That's something you'll have to ask the 

President. 

Q Well, that's somewhat of a tautology, isn't 

it, to -- 

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A Well, my -- I'm sorry, I interrupted. You 

finish your question. 

Q I apologize. Do you have reason to believe 

that he wants to answer that question if posed by a 

Grand Jury? 

A Which question? 

14 Q The one you said I'd have to ask him. 

15 

16 

A Well, I said that to two questions, one, 

whether he would testify and one -- well, why don't you 

17 1 j ust start over again because I'm now lost on which 

18 question we're talking about. 

19 Q Fair enough. I think I'm sort of lost, too. 

20 Well, I'll just ask it more generically -- 

21 A Okay. 

22 Q -- because, because in, in answering the 

23 question -- and maybe it's just -- it just may be a 

24 mannerism of speaking and perhaps it wasn't really 

25 meant, but you used something to the effect you'd have 

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A Answer those questions before a Grand Jury? 

Q Correct. 

A I have not discussed that with him. I 

consider that part of the legal lawyer/client 

relationship. And so, I have not asked him that, nor 

has he volunteered it to me. 

BY MR. CRANE: 

Q What about with your talks with Mr. Kanter? 

Has he asked you to talk to reporters on the issue of 

whether the President ought to testify before a Grand 

Jury or, or simply answer questions about the 

Lewinsky/Tripp matter? 

A And your question is what? 

Q Has Mr. Kanter given you guidance or a party 

line that this is something that the President should 

answer, will answer? 

A No. 

BY MR. BARGER: 

Q Now, after, after the meeting with the, the 

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with Mr. Kanter? How long after the meeting? The same 

day? 

A I don't think it was the same day, I think it 

was -- because the President was giving the State of 

Union. I don't know where Mickey was. It was -- my 

best recollection, it was within -- it was in that 

week, that week being the week starting the Monday that 

I had the conversation with the President. 

Q Uid you take any notes of your conversation 

with Mr. Kanter? 

A I don't think so. 

Q And as you understood it from Mr. Kanter, 

basically your role would be, I think, to spend your 

time talking to the media? 

A Primarily with the media, some, some with 

supporters. I mean, there were supporters who were -- 

wanted to know what was going on and what the White 

House was saying and trying to sort stuff out. But it 

was basically with the media. 

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A My role -- 1 saw my role as twofold. One, 

the media is just like all the rest of us, they often 

are focused on different stories and then they get -- 

they, they move their focus to another story. And to, 

one, to talk through with them facts, different 

theories, and also to find out what stories they 

working on. 

Q Now, did you attempt to do that with 

were 

Ms. Mayer or did she come to you about this -- about 

the Linda Tripp story? 

A Oh, the Linda Tripp, my best recollection is 

she came to me. I knew very little about Linda Tripp. 

Q And the meeting, would it be fair to say, 

basically you -- 1 believe you covered this earlier, 

but you basically made it known to her that you really 

didn't know much about her, you may have met her at the 

White House but beside that, besides that you really 

had very little information to provide on her. Fair to 

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example, did she ask you who she might be able to go to 

to get more information? 

A I don't think she did. I mean, I, I don't 

recall her asking me. I mean, typically, these 

reporters have lists of people that they're going to go 

to and they know pretty well who they're going to see, 

but I had no information about who Ms. Tripp knew. I 

didn't know who her friends were, I didn't know who 

knew her, I didn't know who talked to her. I knew 

almost nothing about her. 

Q As you understood it, or did you, did you 

understand that part of what Mrs. Mayer-Hamilton was 

looking for was to see if Ms. Tripp had lied on her FBI 

background check about an apparent prior arrest? 

A Again, I think I've answered that three or 

four times but, again, just we can get through this -- 

Q Right. 

R -- I don't recall her -- she may have raised 

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to lawyers of other individuals, witnesses involved in 

the Lewinsky/Tripp matter? 

A Do I? 

Q Yes. 

A No. I think the only -- you mean do I 

actually -- well, let's -- 

Q Other than your own lawyers? 

A I mean, I talk to a lot of, I talk to a lot 

of people and a lot of them include lawyers because 

this town is littered with lawyers. To my knowledge, I 

don't -- with rare exception, I have not talked to 

lawyers who are actually representing witnesses, 

subjects, targets, defendants, call them what you will, 

in connection with this investigation. Not to say I 

haven't talked to some, but with very rare exception. 

Q All right. What aboilt talking with private 

investigators or fact checkers, anyone under the 

general rubric of private investigator? Have you had 

any conversations with anyone like that since 

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8 Q And in particular, just to follow up, to make 

9 a clean record, no talk about finding out background 

10 information about Linda Tripp with Mr. Lenzer? 

11 A No. 

12 Q And have you retained his services? 

13 A Have I personally retained his services? 

14 Q Yes. 

15 A No. 

16 Q Do you know if any other person -- 

17 A Can't, can't afford him. 

18 Q Do you know if any other person has retained 

19 his services reference Lewinsky/Tripp? 

20 A It's been, it's been stated in the press that 

21 the President's lawyers, either Mr. Kendall or 

22 Mr. Bennett or perhaps both, have retained his 

23 services, but in connection with what I don't know. 

24 And I don't even know as a fact whether they've done it 

25 or not. 

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Q What do you talk to him about? 

A I typically talk to him about what's going 

on, how's it look. He's very circumspect and I have no 

reason to believe that he's ever given me any 

information that I didn't -- let me back up. He's 

never given me any information I didn't already know 

from the press, but basically it's -- I call him just 

to check in with him. I've worked with him since 1994 

and consider him a friend. 

Q Okay. In your conversations, what have you 

told him? 

A Nothing, other than, you know, things are 

carrying on. But if you know David Kendall, you know 

that he's circumspect beyond belief and it's nothing 

more than generalities and bordering on pleasantries. 

Q And what have you told him? 

A I have told him on a couple of occasions what 

I was picking up from the press, where they're headed 

or where some of the press is headed, what some of the 

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the wrong phrase because it implies a -- I've worked 

with him because he has represented the President, as 

you know, beginning, 

So, I've worked with 

and have worked with 

regard. 

I think, relatively early in 1994. 

-- that's when I first met David 

him in that connection or in that 

Q You also, in answering a 

Mr. Lenzer, I believe you said you 

question about 

did not personally 

retain Mr. Lenzer, and I just wanted to make sure 

whether, whether the use of the word personally had -- 

I'm saying that would suggest that maybe someone else 

did, directly or indirectly, for your benefit, and I 

just want to sort of cover that base there. And your 

answer was I have not personally retained Mr. Lenzer. 

A Right. 

Q Nave you, directly or indirectly, retained 

Mr. Lenzer or, or the investigative firm for which-he 

works? 

A We're talking about this time period now? 

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A NO. 

Q Has he, has he worked for you, directly or 

indirectly? 

A No, he has not. 

Q And I won't get into the subject matter, but, 

but your answer suggests that at an earlier time you 

may have, directly or indirectly, retained Mr. Lenzer 

or his investigative firm. 

A No, I have not -- 

Q Have you done so? 

A No, I have not. 

BY MH. PAGE: 

Q Mr. Ickes, did you personally get a copy of 

the subpoena that called for you to produce any and all 

documents and things referring or relating to the 

release of Linda Tripp's personnel file, ilicludinq but 

not limited to notes, memos, and any other 

correspondence, but excluding 

press files? 

A That's the subpoena 

newspaper clippings or 

that your colleague 

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to Bob or served on Bob Bennetts office. I mean, you 

guys -- 

Q I represent that that's accurate, 

served on Mr. Bennett. 

A Yeah. And then Ms. Sabrin called 

it was 

me and said 

that I had received yet another subpoena and she faxed 

it over to me. 

Q 

A 

Q 

A 

Q 

records? 

A 

Q 

A 

Q 

have had 

subpoena? 

So, you did personally get a copy -- 

Yes. Yes, I did. 

-- for your own? 

I did. 

And pursuant to that, you searched your 

Yes. 

Is this at your office of Ickes and Enright? 

Yes. 

As well as other locations that you might 

documents or things responsive to the 

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;las been produced. 

Q And the extent of your production today is 

the deposition that you gave to Mr. Klayman, correct, 

on May 21, 1998? 

A Yes. 

Q Your search revealed no other documents or 

items that were responsive to the subpoena? 

A No . 

Q Did you have any items that you came across 

as you searched your files that you debated whether or 

not they were responsive to the subpoena? 

A No. On something like that, I -- my general 

rule is if I think it's debatable, if I think it's 

within shoulder-rubbing distance, I give it to Amy and 

let her make the call. 

Q so, is it safe to say then that there were no 

debatable items as you searched your files at home and 

at work? 

A As -- I did not fi.nd anything in, in my 

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or documents or things that are described that would 

have been turned over to, to other people and may not 

physically be at your, at your office but over whom you 

would exercise control, such as your attorneys. I 

mean, are there records that are called for by the 

subpoena that were not at the location that you 

searched or do you have reason to believe that there 

were records at a different location called for by the 

subpoena? 

A I don't think 

believe that there were 

that -- I have no reason to 

because this whole thing came 

to being long after I left the White House. But my 

attorneys have 50 or 60 boxes of documents and 

Ms. Sabrin would -- 1 would have relied on her to 

search, and I think that she did have somebody conduct 

a search. I have no reason to believe that there was 

anything in those 50 or 60 boxes that pertained to 

Linda Tripp or Monica Lewinsky. 

Q Okay. So, the lawyers had some records in 

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going back to Mr. Bacon briefly. As I understand it, 

you had, I believe, two dinners at which Mr. Bacon was 

present, both at Mr. Cohen's house after the Monica 

Lewinsky topic -- 

A Yes. 

Q -- broke. How many dinners did you have 

Mr. Bacon prior to January of '98? How many times 

you had dinner with Mr. Bacon prior to the Monica 

Lewinsky topic breaking? 

A Probably, at the most, since coming to 

Washington when I first met him, which was early -- 

with 

have 

when 1: first came to Washington -- I came to Washington 

early '94. I don't recall meeting Mr. Bacon -- I may 

have met him a long, long time ago because he's been a 

friend of Cohen's, I think, for a number of years, even 

when he was at The Wall Street Journal. I think I've 

had dinner with him no more than two or three times, at 

the most. 

Q Between '94 and '98? 

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Q 

g

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Seder dinner first, who was at the -- it may not be -- 

who was at the Passover dinner besides Mr. Bacon, 

Mr. Cohen, and yourself? 

A There were a number of people, s3me of whom I 

know or some of whom I recall. Mr. Bacon's wife, my 

1. 

wife, my daughter, Mr. Cohen's children, Mr. Cohen's 

father and mother, Mr. Cohen's brother and his son. 

There were various other creatures there but I can't 

recall. That's -- those are the people that I recal 

Q And on the first dinner, the Chinese or 

possibly Thai food -- 

A It was -- or Indonesian. I don't want to 

be -- on this. It was -- my recollection, it was 

Mr. Bacon, Mr. Cohen, and myself. I do not think any 

of our childrer were there. Nr. Cohen has two 

children. One of his may have been there, I just don't 

recall. 

BY MR. PAGE: 

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paragraphs. O

e paagapas to , doube to 

double Z, triple A to triple Z, quadruple A to 

quadruple I. So, he asked me to bring the kitchen 

sink, virtually all of which was irrelevant. 

Q So, you brought 

A We submitted, I 

documents to Mr. Klayman. 

Q I'm sorry? 

documents -- 

think, some 400 pages of 

A I think we submitted some 400 pages of 

documents to Mr. Klayman. 

Q Earlier, you mentioned your consulting 

business, Ickes and Enright, correct? 

A Yes. 

Q And you said, to paraphrase, that you helped 

people with problems in Washington, D.C. 

A Right. 

Q Correct? 

A Ye5. 

Q Can you tell us what that means? 

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A I got up this morning. I read Mr. Klayman's 

deposition, then I came over here. That's one day in 

my life. 

Q Let's go -- 

A I will then leave here and probably go back 

and have another subpoena. It's, it's quite varied, 

but we represent different clients and -- 

Q Can you give us a representative client that 

you're willing to talk about? 

A Well, we represent the Government of Puerto 

Rico, we represent the Greater Hospital Association of 

New York which represents, I don't know, 170 hospitals 

in New York. We're not the only person that represents 

them here, but we do that. We represent the New York 

City Council. We represent the Crop Protection 

Association that is having -- involved in, in -- with 

the Environmental Protection Association and the 

regulation of pesticides. Those are the kinds of 

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Q 

o, you tod ayouttoy 

that you were out in California the week before the 

Monica Lewinsky -- actually, during the week that the 

Monica Lewinsky -- 

A Yes. 

Q __ story broke, 

A Yes. 

Q And how did you 

Was it through the media? 

correct? 

first learn about the event? 

A I, I'm quite sure it was through the media. 

Here's what I can't recall: I can't recall whether I 

left for California on either, either Wednesday or 

Thursday. My recollection is that this -- the Monica 

Lewinsky thing broke Wednesday, and I can't recall -- 

I'd have to look up to see whether I was in an airplane 

going to California that afternoon or didn't leave 

until.Thursday, but that's -- I found out about it 

through the media is my best recollection. 

Q And you were out there giving a speech? 

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A At Stanford, yes. 

Q So, you're in -- what's that town? 

A Palo Alto. 

Q Palo Alto. And you hear about the Lewinsky 

matter through the media, either television or 

newsprint? 

A That's my best recollection, yeah. It, it 

moved pretty fast. 

b. When you read about that, what's your first 

impression? 

A My first impression was that it was -- it 

could be a very serious situation for the President. 

Q Were you sad? Glad? 

A I didn't know the facts, so I didn't know 

whether I was sad or glad. But I do know, given my 

experience in, in my short tenure in Washington, having 

dealt with a lot of the so-called controversies or 

scandals, whatever word you want to portray, starting 

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serious problem, politically and public relations-wise. 

Q You don't have the facts but you have the 

allegations by virtue of whatever method you learned 

about the event, correct? 

A 

Q 

A 

Q 

A 

Q 

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Q 

A 

Q 

A 

Q 

once you 

A 

What time period 

California, Palo 

Well, I, I -- 

are you talking about? 

Alto -- 

-- the news reporting of this event. 

Yes. 

And what's your reaction to the allegations? 

The allegations are serious allegations. 

Who's the first -- 

Rut they are allegations. 

I'm sorry? 

Rut they were allegations. 

Who was the first person that you spoke with' 

learned of these allegations? 

The first person I spoke with? Probably my 

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partner, Janice Enright. 

Q Was she with you on this speaking engagement 

or was she -- 

A She was. 

Q She was? 

A Yes. 

Q Was she to speak,as well? 

A She was not. We were going to meet people in 

California as well as by doing some speaking. 

Q Do you recall the substance of your 

conversation with Ms. Enright? 

A The substance, I can only have a vague 

recollection that this was a very serious situation. 

And, and obviously, given our collective experience in 

the White House, we knew that this would develop and 

probably develop rapidly and a lot of newspeople would 

be looking into it, as well as possible law enforcement 

people looking into it. 

Q And that's in the latter part of -- just 

after the Lewinsky matter breaks, correct? 

A Yes. 

Q The latter part of 

A Yes. 

Q -- the mid-part of 

it work that you're summoned 

the week -- 

the week? Now, how does 

to the White House that 

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following Konday? 

A The President -- I got a message -- I tllink 

we were on airplanes, we were traveling, and I got a 

message from -- 1 think on our voice mail or pager, I 

forget which. 

Q And do you -- 

A That the, that the White House was -- had -- 

was looking for us and then asked us to call, or asked 

me to call back. 

Q Do you recall who specifically left the voice 

mail? 

A As I say, I don't know whether it was a voice 

mail or a pager. We have both. And it may well have 

been the pager. But in any event, it was from 

President's -- and it was a call either from 

Mrs. Clinton or the President. I'm not saying 

the 

that 

they were the ones that placed the call, but their 

names were left. 

Q The President or Mrs. Clinton? 

A Yes. 

Q Mr. Crane asked earlier about some numbers 

that you had and I believe that we neglected to ask you 

what your beeper number is. Do you 

beeper number is? 

A I'm terrible on numbers. 

know what your 

-and 

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the pin is 0 

Q so, somehow, Mr. Ickes, you learn after the 

publicity surrounding the Lewinsky affair that the 

President or the First Lady want to speak with you, 

correct? 

A Yes. 

(1 And do you reach out for them? 

A When 1 got to San Francisco, I did return the 

call. I don't think that either was available. As I 

say, I forget whether it was the President or the First 

Lady. I know this sounds odd that you would forget 

whether it's either the President or the First Lady, 

but the fact is I don't recall. It was one or the 

other. But my best recollection is that when I called 

back neither were available and I left a message that I 

had called back, and i 

hotel that we would be 

Q Do you reach 

about this news event? 

also left the number of the 

staying in. 

out and speak with anybody else 

A The answer is I don't have a specific 

recollection. I probably did place a call to Doug 

Sosnik who is -- I'm still quite close to who is the -- 

well, he's now counselor to the President in the White 

House. You should add -- now that I raise his name, 

you should add his name to that litany of people that I 

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talk to on a semiregular basis in the White House. 

It's S-O-S-K-I-K. I probably -- I may well have tried 

to reach him. I don't recall who I talked to. My 

recollection is I talked to at least somebody, either 

McCurry or Sosnik or maybe Ann Lewis, in the White 

House just to see what the situation was and what the 

White House was saying. 

Q So, you think that there was actual 

conversation then when you called back, apparently 

after you find out that you can't get a hold of the 

President or the First Lady? 

A Yeah. I, I don't remember a specific 

conversation with a specific person. I find it hard to 

believe that I did not talk to somebody in the White 

House in that -- shortly after we landed. 

Q Well, you have to, it seems, does it not, in 

order to know to go to the White House Monday morning? 

A Well, there are two different sets of phone 

calls I'm talking about. One is the set of phone calls 

responding to the President's or the First Lady's call. 

Then another set of phone calls is did I talk to 

anybody else in the White House outside of the 

President's immediate Oval Office staff. I didn't make 

that distinct. And the answer is I don't recall 

specifically who I talked to or whether I talked to 

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somebody outside of the President's immediate Oval 

Office staff, but I'm confident that I did. I, I find 

it -- 1 can't imagine that I did not talk to somebody, 

and it could have been either Sosnik or McCurry or 

Lewis, Bagala, Rahm Emanuel. 

In addition to that, at some point I made 

contact with the Oval Office staff and I actually 

talked to the President and -- 

Q Long distance? 

A Long distance from California. 

Q And do you know where you are at that time? 

A I'm in Palo Alto, I suspect in the hotel but 

I'm not positive. 

Q So your recollection -- 

A It could have been on a pay phone. 

Q -- so far, to summarize, is while en route 

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out there with your partner, 

A Yes. 

Q Call back in after 

can't get anybody? 

you're beeped? 

landing in San Francisco, 

A Can't get President or First Lady and, and I 

think left a message with the White House, with the 

Oval Office staff that we had returned -- I had 

returned the call. And then subsequently, my best 

recollection is I talked to the President, it was 

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either Friday -- 1 think it was either Thursday or 

Friday, I forget which, you know, I actually had a 

phone conversation. 

Q And is that from the hotel phone booth or 

some other location? 

A As I said, it could have been 

or it could have been from a pay phone, 

which. 

Q Do you remember the substance 

conversation? 

from the hotel 

I don't know 

of the 

A The substance of the conversation, as best I 

can recall, is that this thing has developed. I told 

him that I had read about it and he asked me if I could 

come over and see him. I don't think that he knew when 

he was talking to me where I was. I told him that I 

was in California, that I would be prepared to take the 

next plane back. I was supposed to give a speech but I 

could cancel that. And he said, "NO, give your speech 

and I'd like to see you as soon as possible after you 

get back." And the rest -- and the subsequent -- thus, 

the subsequent meeting with him early Monday morning. 

Q Before this phone call or, I should say, 

before you were beeped, when was the last consulting 

work you had done for the White House? 

A Well, I was never, I was never a consultant 

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for the White House. The last work I had done for the 

White House, I resigned effective January -- about 

January 20th of 1997, after running the Inauguration. 

And then I -- after resigning, I then went back on the 

White House payroll in my capacity as director of the 

Denver Summit of the 8 which was held in Denver in June 

of '97. So, from -- effectively, from early February 

until sometime after June, I was on the White House 

payroll; until about August. 

BY MR. CRANE: 

Q Was that the Summit of Economic Powers? 

A Yes. 

Q I see. 

A Right. We call it -- shorthand, we call it 

the Denver Summit of the 8 because Russia been at it, 

but it was our turn to run that and -- or hold it, and 

I ran it for him. 

Q Why did you resign? It seems -- 

mind my asking, it seems that your -- sort 

if you don't 

of your 

heart and soul is really in the White House. 

A I never said that. 

Q I just said that. 

A Oh, okay. That's your -- okay, that's your 

conclusion. 

Q That was my conclusion. 

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11 A Oh, okay. 

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/ ’ 

Q Your heart and soul was in the White House 

and perhaps -- 

A Hopefully, neither was 

because a new chief of staff was 

well documented. A new chief of 

Erskine Bolls, who basically said 

he wanted to bring in a whole new 

was not included in that team. 

BY MR. PAGE: 

there, but I resigned 

brought in. This is 

staff was brought in, 

in so many words that 

team of people and I 

Q Are you bitter about that? 

A No. 

Q You said earlier that you reviewed your 

deposition this morning when I asked you about the day 

in the life of Mr. Ickes. 

A Urn-hum. 

Q Did you review anything else in preparation 

for your testimony today? 

A No. I met with, I met with my lawyer 

yesterday, 

document. 

in the, in 

deposition. 

but that was the only, that was the only 

Oh, a couple newspaper clips that had been 

The Washinaton Times that were based on this 

Q And your meeting with the President on Monday 

morning, which I represent to you to be probably 

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Monday, January 26th, 1998 -- 

A Okay, whatever, whatever it is it is. 

Q -- which is the first Monday at least, 

Mr. Ickes, and I represent this to you, after the news 

of the Lewinsky matter was published. 

A It was the Monday directly before the Tuesday 

of the State of the Union. 

Q You said lasted about an hour? 

A Urn-hum. 

Q And half of that was devoted to the topic. of 

Monica Lewinsky, in your estimation? 

A Roughly, yeah. I recall talking also about 

the State of the Union, some of the issues the 

President may be raising. That was obviously something 

that he was very focused on. 

Q At the outset of the meeting, Roger Clinton 

is there, Harry Thomason and this writer from Baltimore 

who you don't recall? 

A Whatever the name is. 

Q Is that accurate? 

A Yes. 

Ld Some of that collection of people leave 

during your hour-long meeting with the President? 

A Well, Roger Clinton and the write left 

immediately. I mean, there were pleasantries 

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exchanged, a Coca Cola was drunk, and other than 

pleasantries there was no discussion, as far as I 

recall. They left. Mr. Thomason, as I recall, stayed 

for some part of the meeting and then he left. 

Q And where are you? 

A We are in what is known as the solarium which 

is, I think, it's technically on the fourth floor of 

the White House. I think they typically call it the 

third floor but technically it's the fourth floor. 

Q Excuse my ignorance, but is that in private 

quarters -- 

A Yes, that -- 

R -- of the White House? 

A That's in the private quarters. It's a -- 

there's what I call the ground floor, then there's what 

I call the state floor. That's what most people the 

first floor but it's the state floor. Technically, 

it's the -- it's actually the second floor. Then there 

is the third floor which is called the residence. 

That's where the President and his family live. And 

then there is one more -- there's a floor above that 

where there are a number of guest rooms and there's 

also a solarium that looks out over the South Lawn 

towards the Jefferson Memorial. 

Q So, after Thomason departs, are you alone in 

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the solarium with the President -- 

1(.)5 

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A 

Q 

about the 

A 

I talk to 

Sometimes 

check in. 

Yes. 

-- during the remainder of this meeting? 

Yes. 

Any other conversations with him since then 

Lewinsky matter? 

Generally. I have talked to the President. 

him on, on a very infrequent basis. 

he calls me, sometimes I call him just to 

There -- as I say, I don't have 

lawyer/client relationship, so there are -- there's 

nothing that is discussed other than what has already 

been discussed 100 times in the press. 

Q At that meeting in the solarium, though, on 

what I represent to you which may have been l/26/98, 

you recall that the President said he did not have a 

sexual relationship with Monica Lewinsky, number one, 

correct? 

A Yes. I've testified to that three times now. 

Yes. 

Q And number two, that he had done nothing to 

encourage anybody to change their statement to suborn 

any perjury or to obstruct justice. 

A Yes. 

Q Is that your recollection? 

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A That's my best recollection. 

Q Any other topics discussed with the President 

during your meeting with him on this date in the 

solarium? 

A As I said earlier in response to your earlier 

question, 1 think that -- I don't recall the topics but 

I'm confident we talked about State of the Union. 

That's always a very big speech for the President and 

he devotes a lot of time to it. As I say, I don't 

recall the specific topics but I do recall talking 

about it and talking generally about some of the things 

that he might be saying, he might not be saying. 

Q You've taken some notes during your 

appearance today, correct? 

A Yes. 

Q Would you mind reading those to the Grand 

Jury? 

BY MR. BARGER: 

Q In the interest of time, how many pages would 

you estimate? 

A Well, six. 

Q Without reading them all, could you just -- 

it'll take a fair amount of time, fair to say? 

A It would. 

Q Could you just characterize them for us? 

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1 Generally, what, what's in the notes? 

2 A Generally, what's in the notes are the 

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3 questions you've been asking, not all of them but 

4 questions, the basic questions that you've been asking. 

5 Q For highlight -- 

6 A Yeah. And I will be telling my attorneys. 

7 BY MR. PAGE: 

8 Q That's the purpose in taking the notes? 

9 A Yeah. 

Q 

say, of 

A 

Q 

A 

Q 

A 

Q 

else? 

A 

Q 

A 

To keep a record of -- your record, I should 

what happened in here today? 

Yes. 

And you'll be sharing that with whom? 

My attorneys. 

Which are the ones you previously identified? 

Yes. 

Do you intend to share that with anybody 

I don't know. I haven't decided yet. 

When will you decide? 

When I feel like it. I don't mean to be 

flip, but -- 

BY MR. CRANE: 

Q In your notes, 

any members of the Grand 

do you make any comments about 

Jury I apart from the 

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attorneys? 

P. No. I noted that there are 18 members, I 

think 18 members of the Grand Jury by my count. 

Q Do you further specify who they are or try to 

identify them or anything like that? 

A No. 

Q You just have the number 18? 

A Eighteen Grand Jury. 

Q Anything else? Is it broken down like men, 

women, young, old? 

A No. 

BY MR. PAGE: 

Q You mentioned that you had talken -- you had 

spoken, rather, excuse me, to Mr. Bagala, McCurry, the 

First Lady, Ann Lewis, Lanny Brewer, Lanny Davis. Were 

those discussions since the Monica Lewinsky matter was 

publicized in late January? 

A Yes. 

Q And were they regarding the Monica Lewinsky 

matter? 

A Not, not exclusively, but I would say 

primarily. 

Q Can you tell us the substance of the 

conversations that you've had with the First Lady since 

the Monica Lewinsky matter was made public? 

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A As best I can recall -- first of all, I don't 

talk to her that much. And as I have testified 

earlier, typically I'm calling her just to check in, 

how is she. And it's more of a check in: how are 

things going, you know, how are you and -- I would say 

it's more along the lines of pleasantries. There is 

frustration evidenced by her and by the President about 

what is going on, as you might imagine, but I don't 

recall discussing any particular details with the First 

Lady about this other than just the general atmosphere, 

how it's going, what is it looking like. I may -- 

depending upon what press people I've talked to 

recently, may indicate to her where some of the press 

may be heading. I know that there was at some point a 

discussion about, you know, the wisdom, if you will, of 

exerting executive privilege and there was considerable 

discussion about that in the press and among advisers, 

as you know. And I do recall having specific 

conversations with both him and her about that. 

Q About the wisdom of asserting -- 

A Yes. 

Q -- executive privilege? 

A Right. 

Q Any other topics that you recollect? 

A No. 

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1: Q And so, you're saying that the substance of 

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conclude that there was a sense of frustration? 

A Yes. 

MR. CRANE: I think we're getting 

break for lunch. Are there any -- briefly, 

ready to 

any followup questions from the members of the Grand Jury? 

GRAND JUROR: I did have a few. 

MR. CRANE: Okay, let's see if we can handle 

them quickly, and then if necessary -- find out if it's 

necessary for the witness to come back. 

Madam Foreperson. 

FOREPERSON: Just a few. The talking points, 

were those sent out in hard copy, was it electronic 

mail? How was that information disseminated? 

WITNESS: They -- the few that I got, 

they were damn few, came over the fax, over our 

machines. 

and 

fax 

POREPERSON: What types of information would 

be in a talking point? 

WITNESS: You know, what are, what are the -- 

typically, talking points on these kinds of things are 

what are the main -- what are some of the points to be 

made, what are the main arguments, depending upon what 

the subject is. And this thing has so -- gone on for 

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so long and has so many ramifications and such a great 

case of -- not great in the sense of great, great, but 

a large cast of characters involved that the talking 

points would deal with that. But as I say, they were 

very few and far between. 

FOREPERSON: Would it be safe to say that the 

talking points would basically give you pointers on 

what to say to the media, that kind of thing? 

WITNESS: Yes. They, they -- I think it's 

safe to say that talking points are a combination of 

facts and argument, both. 

FOREPERSON: Any scripting or anything like 

that? 

WITNESS: What? 

FOREPERSON: Scripting as to -- 

WITNESS: No. 

FOREPERSON: -- exactly what you should say? 

WITNESS: No. They're basically facts and 

some -- mostly facts and arguments that the author 

thinks would be useful to whoever's receiving them. 

mentioned 

be a good 

FOREPERSON: Okay. Mr. Lenzer, I think you 

that Mr. Lenzer was a private investigator? 

WITNESS: Terry Lenzer, yes. 

FOREPERSON: Okay. Would you consider him to 

private investigator? 

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expensive 

liever had 

Mr. Bacon 

WITNESS: He has the reputation of being 

and good, but that's his reputation. I've 

him do anything for me. 

FOREPERSON: Okay. Were you aware that 

and Ms. Mayer-Hamilton worked together at The 

Wall Street Journal? 

.WITNESS: I 

both were employed by 

FOREPERSON: 

was aware of that, yes, that they 

The Wall Street Journal. 

I have nothing else. 

GRAND JUROR: I have one short one. You went 

to work at the White House in January of '94? 

WITNESS: In -- yes, in January of '94. 

GRAND JUROR: Were you required in your 

employment at the White House to have a security 

clearance? 

WITNESS: Yes 

GRAND JUROR: 

, I was. 

Can you tell me what form you 

filled out for your background investigation? 

WITNESS: I can't. 

GRAND JUROR: Did you fill out a form? 

WITNESS: Yeah. It was lengthy. 

GRAND JUROR: The flight that you took to 

Palo Alto, were there telephones on the plane? 

WITNESS: I think, much to my frustration, 

there weren't. 

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1 GRAND JUROR: Oh, okay. So that's why you 

2 didn't call until you landed. 

3 WITNESS: Right, right. It's also expensive 

4 calling from the airplanes. 

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GRAND JUROR: Actually, the rates have gone 

down. 

WITNESS: They have? 

GRAND JUROR: Kind of flat rate. 

WITNESS: I'll take your word for it. 

GRAND JUROR: You testified that 

Ms. Mayer-Hamilton was asking you questions about Linda 

Tripp and that you indicated to her on the phone that 

you did not have any information. I'm just curious, 

why did you make an appointment to have her come to 

your office if you didn't 

WITNESS: No, I 

what I testified to. She 

that Jane called me and said that she was doing a story 

on Li ndn Tripp and could she come over, had I worked 

with her in the White House. I said I had. Could she 

know anything? 

think that that's not exactly 

called -- my recollection is 

come over and talk to me. She's a friend of mine, I 

know her, and we made an appointment and she came over. 

It was a very short meeting because I knew very little. 

GRAND JUROR: But if you had already told her 

on the phone you didn't know anything, it's kind of 

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curious that she -- 

WITNESS: No, I didn't, I didn't say that I 

told her on the phone I didn't know anything. I said 

in the meetirlg I told her I didn't know anything. 

GRAND JUROR: But you knew why she was 

coming? 

WITNESS: I knew that she was doing a story 

on Linda Tripp. I knew that I knew some information 

about Linda Tripp. It was very little. I didn't know 

what angle she was working, what she -- where she was 

heading on it. And I think that, you know, once she 

told me she was doing a profile on her, I told her what 

I knew, and I've told you what I told her and it was 

very little. 

GRAND JUROR: So, basically, it was an 

exchange of information. You found out what she wanted 

to know, as well as she found out that you didn't know 

very much? 

WITNESS: If you want to characterize it that 

way, you can characterize it that way. I think I've 

testified to what occurred. 

BY MR. CRANE: 

Q If I can just follow up, and we have asked 

you this a number of times, but you, you have not ever 

seen Linda Tripp's security Form 398, nor released it 

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1 to any person? That's -- 

2 A Certainly not to my knowledge. 

3 Q Okay. Did you ever have occasion to look at 

4 the personnel files of any other person at the Wllite 

5 House and release any of that information? 

6 A The answer is not, not to the best of my 

7 knowledge. I don't recall ever seeing anybody's 

8 personnel files other than my, my own. I'm not even 

9 sure I've seen my own complete personnel file. I had 

10 no interest in it. And I have no recollection of 

l1 I releasing any personnel information. 

12 Q What about going and looking on personnel 

13 files, apart from releasing it? Just going and looking 

14 at personnel files without releasing it? 

15 A I have no recollection of doing it and I'm 

16 confident I didn't. Personnel was not under my 

17 jurisdiction as deputy chief of staff, and the 

18 personnel director reported to -- and the Office of 

19 Administration reported to the other deputy chief of 

20 staff. 

21 Q All right. 

22 GRAND JUROR: I just have one other. During 

23 the time that you had the meeting with the President, 

24 you said about half an hour was spent, roughly. 

25 WITNESS: Urn-hum. 

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GRAND JUROR: Was that toward 

of the meeting, throughout the meeting, 

middle or at the end that you discussed 

Tripp/Monica Lewinsky -- 

11G 

the beginning 

sort of ill the 

the Linda 

WITNESS: My best recollection, it was 

interspersed, you know, the President was going back 

and forth. I think it's fair to say that the outset of 

the meeting was focused primarily on that and then we 

shifted over to State of the Union, and back. I mean, 

it was, it was that kind of a conversation. It wasn't 

tightly structured, one segment and then he cuts it off 

and moves on to another segment. 

MR. CRANE: Yes, Mr. Barger? 

BY MR. BARGER: 

u Following up on the Grand Juror's question, 

was Mr. Thomason present for any of the discussion 

involving 

A 

it. 

Q 

the Monica Lewinsky topic? 

My recollection is that he was for some of 

What was the purpose, as you understood it, 

of his presence? 

A He was, he was staying at the White House at 

the time, and I don't, I don't know what the purpose 

was he was there. And then he left. 

Q No, I don't mean his purpose at -- physically 

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being in the White House. What was his purpose in 

being at the meeting, as you understood? 

A He was there when we walked in. We're all 

friendly, we all know each other, and I worked with 

Harry for -- on a number of projects. I don't know if 

there was -- all I can tell you is that he was there 

and stayed for part of the meeting. 

Q Did he participate in the discussion of, of 

the Monica Lewinsky topic, you know, how to deal with 

it? 

A Not that I recall. I think mostly the 

President -- my recollection is the President and I 

did -- the President did most of the talking but I did 

a lot of the listening. I don't recall Harry saying 

much of anything. He had been, he had 

White House, I think, for several days 

coming in on early Monday morning. 

been at the 

prior to my 

Q His presence at the meeting was not something 

you requested, I take it? 

A No, it was not. 

Q All right. Going back just very briefly, in 

Palo Alto you said it's -- I don't know if you said 

possible but I took it to mean it's possible that you 

may have called the President back from a pay phone. 

If you did so, would that -- would you have used a 

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calling card? 

A Yes, I would have. 

Q Okay. And I don't think -- in the universe 

of things we've bothered you with, I don't think we 

asked for a calling card number. Do you have such a 

critter? 

A .I do. 

Q May we -- may you share that with us, please? 

A Yeah. See, I knew, I knew we'd get around 

here to this. Wait a minute. Let me see if I have it. 

Now, if I get a lot of phone bills -- 

Q You know where to come looking. 

A Boy, you bet. I'm going to come right to 

you. It is w-b 

MR. CRANE: Yes, I believe a Grand Juror over 

here had a question. 

GRAND JUROR: Just for clarification, 

Mr. Klayman is with the Independent Counsel's Office? 

MR. CRANE: No, no. For clarification, he's 

not. 

GRAND JUROR: Who is he? 

MR. CRANE: Mr. Ickes may enlighten us as to 

where Mr. Klayman is. 

WITNESS: Mr. Klayman is the head of an 

crganization called Judicial Watch and he apparently 

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makes sort of a vocation, if not avocation, of suing 

the Clinton Administration. I think he's sued the 

Clinton Administration 18 times. And there's a nice 

little article in today's newspaper about the source of 

some of his funding. Apparently, the Mellon Scaife 

Foundation gave him $500,000 this year. So, he has, as 

it were, an axe to grind. 

GRAND JUROR: It's 550,000. 

WITNESS: Okay, I stand corrected. 

BY MR. BARGER: 

Q I have one last, one last topic. Going back 

to a question Mr. Page asked you earlier that you 

covered, some of your conversations you've had with the 

President subsequent to your meeting, and I believe in, 

in your answers you talked generally about the fact 

that what you discussed did not involve any, any new 

facts that had not already been out in the public 

realm, or at least words to that effect. 

A Yes. 

Q Is that sort of a fair assessment? 

A Yes. 

v My question has to do with, with that topic. 

Even though your conversations -with the President may 

have involved facts that were already in the public 

realm, some of the facts that have come out since that 

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story, the Monica Lewinsky story, broke in mid-January, 

some of the facts that are at least -- or some of these 

factual allegations that are out there in the public 

realm suggest that possibly the President did have a 

sexual relationship with Ms. Lewinsky. So, my question 

has more to do with even if these are facts that are 

out there in the public realm, in any of your 

conversations with the President subsequently did he 

ever discuss whether he had such a relationship? In 

other words, that his answer he had given you 

previously wasn't exactly correct? 

A The answer is no. 

MR. PAGE: Mr. Ickes, on your phone card is 

that World Corn or can you tell us what organization 

issued that card? 

WITNESS: I have to tell you, don't I? I 

don't, I don't have a choice. 

MR. CRANE: I think counsel is being polite. 

WITNESS: Well, he, he did use the word can 

instead of will, but -- so the answer, the answer is 

can I? The answer to that question is yes. Will I? 

UY MR. PAGE: 

Would you? 

Yes. It is -- 1 don't have it on 

. It's an AT&T credit card. 

Q 

A 

actually 

FREE STATE REPORTING, INC. 

Court Reporting Depositions 

D.C. Area (301) 261-1902 

Bait. & Annap. (410) 974-0947 
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Q Thank you. Now, you mentioned during your 

testimony that you've appeared approximately 20 times 

since 1994 before Grand Juries and bodies taking 

testimony, correct? 

A I've given sworn testimony -- this is an 

estimate but I think it's fairly accurate -- in the 

neighborhood of about 20 different times. 

Q With respect to this appearance today, were 

you treated professionally in the arrangements that 

were made to bring you here? 

A Yeah, the cab driver was very pleasant. 

Q And were you treated professionally by the 

representatives of the Office of Independent Counsel in 

arranging your appearance here today? 

A I never dealt with them. Amy Sabrin did and 

she never indicated unhappiness. 

Q And during your appearance here today before 

the Grand Jury, were you treated professionally and 

with due respect? 

A I would say that, yes. 

Q And did the counsel show you respect? 

A I would -- the answer is yes, I was. 

Q Thank you. 

BY MR. CRANE: 

Q And would it be fair to say that I am nicer 

FREE STATE REPORTING, INC. 

Court Reporting Depositions 

D.C. Area (301) 261-1902 

Balt. & Annap. (410) 974-0947 
1588 

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to you thank Mr. Klayman? 

A Well, you at least have a sense of humor. 

That's more than he does. And you also ask relevant 

questions. Ninety percent of his questions are totally 

irrelevant to his case. 

Q All right, on that relatively humorous note, 

I think we must, due to the lateness of the hour, break 

for lunch, and we will discuss with the Foreperson what 

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time we will -- it's now nearly l:OO, so -- 

A You're going to want me back? 

v Let's step out in the hall and speak with Ms. 

Sabrin, but I think that we can probably release you 

with -- let's, let's discuss that out in the hall. 

A Okay. 

FOREPERSON: No further questions? Does 

anyone else have further questions? 

MR. BARGER: No furtner questions by the 

Grand Jurors. 

WITNESS: Okay. Thank you. 

MR. CRANE: May the witness be excused? 

FOREPERSON: Yes. 

(Whereupon, the witness was excused at 

12:55 p.m.) 

FREE STATE REPORTING, INC. 

court Reporting Depositions 

D.C. Area (301) 261-1902 

Bait. & Arirlap. (410) 974-0947 
1589 

I 

333 Cons~ltucion A”e”“e, N.W. 

Washinqtan, D.C. 20001 

Thursday, July 23, ,998 

presence ot * full quorum Of GCdrld Jury 97-2, LIpaneled 

an sewember 19, 1997. ccmencinq at ,:o, p.m., betore: 

SOumOHON WISLHBERG 

DeD”CY I”de!x”de”t Counsel 

Associate Independent Counsel 

Ottice ot Independent Counsel 

1001 Pennsylvania *venue, NOrmveSt 

suite 490 NorOl 

Washinqto". 3.c. 20004 

n rc: Grand Jurv Procccdinm Multi-Page” July 23, 1998 

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PROCEEDINGS 

Whc7eupon. 

IIAROLD M. ICKES 

was called as a witness and. after being first duly SHOD by 

tk Fortzzerson of the Grand Jury, was examined and testified 

as follows: 

EXAMINATION 

MR. WISENBERG: Madame FoxPerson. do we have a 

quorum? 

FOREPERSON: Yes, we do. 

MR. WISENBERG: Are there any unauthorized people 

in the Grand Jury room? 

FOREPERSON: Thex are none. 

BY MR. WISENBERG: I 

Q Could you state your name, please, and spell it. 

A Harold Ickes. It’s H-a-r-o-l-d: Ickes, I-c-k-. 

Q And can you tell us what your occupation is. 

Mr. Ickes. 

A I’m a consultant. 

Q And my name is Sol Wise&erg. I’m an attorney for 

the Office of the Independent Counsel. 

To my left is Ed Page. He’s an attorney for the 

Page ; 

CONTENTS 

WITNESS: 

Harold I(. Ickes 3 

GRAND JURY EXHIBIT: ".rked/Identitied 

15 

:3 Office of Independent Counsel. 

14 To my right is Mary Anne Wirth. She’s an attorney 

S the Oftice of Independent Counsel. 

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This is the Grand Jury reporter, and these are the 

ladies and gcntlcmen of the Grand Jury. 

Do you understand? 

A Yes. 

Q This is a federal Grand Jury impaneied by a 

United States District Court for the District of Columbia 

investigating, among other things, whether or not certain 

individuals may have committed felonies in connection 

with the civil suit known as Jones v. Clinton. Do you 

understand that? 

A Yes. 

Q You’re an attorney, correct? 

A lam. 

Q I’m going to briefly go over your rights and 

responsibilities as a Grand Jury witness, because I know 

you’ve been a Grand Jury witness in the past. 

A (Nodding.) 

Q And let me just say that you understand that you 

have a right -- a privilege against self-incrimination; is 

that correct? 

A Yes. 

Q You don’t have a right to lrave a lawyer in here 

with you, but you have a right to have a lawyer outside. Do 

you understand that? 

A Yes. 
1590 

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I Q Ylk\c gcor counsel hex with you today, crzx:1? 

2 A Id< 

3 (1 Cn:: ‘. ,111 rcil 11s who those pcoplc are. 

1 A One :i Amy Snhrin -- S-a-b-r-i-n -- and tlx 

5 OlhL7 one :< Lily .*\rhnh -- A-r-b-a-b -- of the finn :f 

6 Skaddcn :tTs. 

7 Q And you understand that you took an oath to testify 

8 truthfully. and you’re testifying subject to the penalrics 

9 of perjuq? 

0 A Yes. 

1 MR. WISENBERG: All right. Let me then say that we 

2 can’t always control what happens time-wise in front of the 

3 Grand Jur). We had you scheduled for 1:30. and it didn’t 

4 happen. I bad you scheduled for 3:00, and it didn’t happen. 

5 For 3:30. And we’ll get as much as we can get done today. 

6 I’m going to turn the questioning over to Ed Page. 

I BY LlR. PAGE: 

8 Q Mr. ickes, you have a notepad in front of 

9 you, correct? 

0 A I do. 

1 Q And is it your intent to take notes today? 

2 A It is. 

3 Q And is it your intent to take verbatim notes? 

!4 A I probably can’t write as fast as either you or I 

‘5 tnlk Thp I~<\UPT ic ir will nnt h,= vprhat;m .” w.... . ..v w.._ ..w. .., .- . . . . ..“. .,v ..,. “.-._.. 

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Q And what is your present intent with regard to 

the. notes? 

A My present intent is to retain them and use them 

initiallv ______- - tn debrief mv attnmevs. or hn:efp_v attnmevs nn 

, -- ------- _, _____‘__,_, _- 

, -------,- --- 

what was -wentonhere. 

Q 

A 

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Q 

A 

Q 

Those two that you’ve identified, or others? 

There may be others, but those two, certainly. 

And do you know who the others may be? 

Mr. Bennett may be one. 

And is that Mr. Robert Bennett? 

It is. 

Ofthesanlefirm? 

Yes. 

And also who is the President’s lawyer, correct? 

That’s correct. 

Any another people that you intend to debrief after 

your appearance today -- 

A At this -- 

Q -- with the benefit of your notes? 

A At this point, no. I may come up with people 

later, but I have -- as I sit here right now -- that’s my 

intention right now. 

(Brief interruption to proceedings.) 

BY MR. WISENBERG: 

Q Pardon us, hlr. Ickes. Let me just make a 

Page Ts’ July 23, 1998 

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cr;itcmcnt, so that ~hcre’s no -Isunderstanding. Let rnc tell 

> ou u hat our position is on !!x taking of notes. 

Our position is that I;ndsr the law of this circuit, 

I:“; pcrfcctly proper for you to take notes to the extr)nt 

that it doesn’t disrupt the Grand Jury process. 

But I do want to inform you that we do have the 

right to subpoena those notes or have you read those notes. 

I wanted to let you know that ahcad of time. 

Our position is that those notes are not protected 

under any attorney-client privilege, since they’re taken in 

the Grand Jury here. 

And let me just, on behalf of the Grand Jury, 

state to you that we don’t want to -- I’m not going to 

subpoena them today, but we don’t want you to do anything 

to compromise or destroy the documentary integrity of those 

notes. Do you understand? 

A I do. 

.I” ..,l‘T_\rn_.x_ ..a . 4. 

MK. WI~CNLICKCI: All Il~t. 

BY MR. PAGE: 

!5 

Q Mr. Ickes, can you tell the members of the 

Grand Jury a little bit about your background. 

A I was born in 1939 here in Washington D.C. -- 

or actually in Maryland. Went to school here; worked on 

cattle ranches after high school; went to college; went to 

law rrhnnl 

._.. _..““.. 

Page b 

1 In New York, ran a numba of -- worked in a 

2 political campaigns and practiced law for about 13 or 14 

3 years in New York and then joined the White House staff. 

4 Workd for _I’r&rJe_t Cl;ntgfi’f ” ____ I993 ramnnion- --.r--D-., ____ mn hia -_ 

5 New York campaign; ran the convention for him in 1992; was 

6 the deputy director of? transition in Little Rock under 

7 Warren Christopher, and then went back to New York to 

8 practice law for a year. 

9 And then I joined his administration as deputy 

0 chief of staff in the White House in early January 1994; 

1 worked in that position until January of 1997; and then 

2 rantbe-Iwasthedirectoroftbewhatiscalledtbe 

3 Denva Summit of the Eight in Denver, which was the eight 

4 economic -- large economic powers around the world that bad a 

5 summit; and I am now a consultant. That’s a thumbnail. 

6 Q And you’re full name is - 

7 A Harold, H-a-r-o-l-d. My middle name, which I do 

8 not use, but it’s McEwen, M-c-E-wtn. Ickes, I-c-k-e+ 

9 Q And so you worked at tbe White House from 

0 approximately early of 1994 tbrougb January of ‘977 

1 A Yes. 

2 Q What position did you occupy w&n. you were ti? 

3 A I was assistant to the President and deputy chief 

4 of staff. I 

5 Q Would you tell the members of the Grand Jury what 

Page 5 - Pzzc 8 
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I July 23, 1998 

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kir.8 of things you did as deputy chief of staff. 

:\ My general n-sponsibilitia. wl~~n I first cnn~ 

doun here, was to deal with the President’s health can: 

initiative. which had been introduscd the ywr bcforc IO 

the Congress. 

And th~lp: began an investigation of what we 

generally in the white House call tin Whitewater situation, 

and I was responsible for dealing with that within the 

K’hirc House. 

I had -- my responsibilities also include many of 

the political matters that the White House dealt with, and as 

time progressed, I was - became involved in the President’s 

reelection campaign. 

So it was a mix of dealing with Whitewater and 

related matters, and then dealing w-itb working on a number 

of substantive issues, including the health care bill. 

Q Did you know President Clinton when he was governor 

of Arkansas? 

A I did. 

Q And how was that? 

A I -- my recollection is that Mr. Clinton and I met 

each other in the early 1970s. My recollection is here in 

Washington, D.C. And we kept in touch over the years. 

Q Did you ever assist in any of President Clinton’s 

campaigns in Arkansas when he was then governor, or wanting 

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to be governor? 

A No. 

Q Did you do any campaign work for him in Arkansas? 

A No. 

Q So you met P&dent Clinton in the early 1970s 

and, in effect, stayed in touch? 

A Yes. 

Q What kind of things did you do for President 

Clinton and the administration in your responsibilities with 

dealing with Whitewater? 

A I was - for lack of a better phrase, I was the 

lead person in the chief of staffs offIce. The White House 

is set up so that the -- them’s the President, and then 

there is the chief of staff, who when I first joined the 

administration, was Mr. McLarty. And then in the -- sotnetime 

in the summer of 1994, he resigned as chief of staff, and 

Leon Panetta became chief of staff. 

And there were two deputy chiefs of staff. My 

responsibility was the lead person in the chief of stafTs 

office dealing with issues -- the intemal aspect of 

Whitewater in the White House. 

Q So you worked for both Mack McLarty and 

Leon Panetta? 

A I did. 

Q Any other chief of staffs that you worked for? 

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the person u Lo suczzdcd Mr. I’anetta was hlr. Bowles. I Jic 

not work fo: !.lr. Bnv.%~ 

Q Is it f2.r to s>’ that, during your term of tirvicc: 

at the \ihitc liou.sc. that you worked long hours? 

A It -- thsi’s -- people have different 

charactrriz&~ns. I worked, by my standards, fairly 

long hours, >z. 

Q And c5d you \vork weektnds? 

A TypiLly, I u.ould work part of a wecktznd, yes. 

Q And what part would you typically work? 

A It wotid depend upon -- it would depend upon the 

circumstamzs. Typically, I would be in on Saturdays, 

sometimes on Sundays, and the hours varied greatly. 

Q. And ~XS this catch-up time for you, or what types 

of things did you do on the weekends? 

A Work rhat I hadn’t I accomplished in the 

prior week. 

Q Was there such a thing at the time called overtime 

for you, or N’rTT you free to do as much or as little as you 

thought appropriate? 

A I think it was the latter. There was considerable 

-- there was a lot of work to be done in the White House, 

and I think that those of us who went to work in the 

White House were -- most of us were amazed by how much 

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Page 12 

work there was and the intensity of it and the sweep of 

the issues that came through the White House. 

So thczre was no hard, fast rule. Presumably, you 

had to work at least 40 hours a week, as you were getting 

paid by the taxpayers. I think it’s fair to say that 

virtually evuyone, if not everyone, worked more than 

40 hours a ~xx%* 

Q And would you work late into the evening during the 

week, as well as on the weekends? 

A Well, late is a characterization. I typically 

worked anyw-bere from 7:00 sometimes until 9:00 or 10:00 at 

night, depending, again, upon what the issues were and how 

much work tbezre was to be done. 

Q How was it that you got from where you lived 

at the time that you were working at the White House to 

the White House on a daily basis for your job? 

A By cab. 

Q You&bed? 

A Yes. 

Q And can you tell us where you were living at 

the time. 

A I was living at a rented house at- and --_‘_ 

3 _ I%e exact address is&_! 

4 Q And so you would cab in every day? 

5 A Yes. 
1592 

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Q Would you cab in on weekends, as \vcll? 

A Typically, yes. 

Q Did you have a car at the time? 

A Well, our family has one car, and my wife thought 

that she should u.se it. 

Q So that was your routine practice thtz’? 

A That was -- yeah. Not invariably, but yes. And 

then sometimes, I would hitch a ride with somebody. But I 

would typically take a cab. 

Q And what was your routine practice when the -- when 

the cab drops you off, where do you get dropped off, and 

where do you go? 

A Typically -- well, before Panetta Plaza was created 

-- that is, before they shut down Pennsylvania Avenue -- 

Q That’s called what? 

A That’s -- that’s an inside joke. It’s -- it’s 

-- we call it Panetta -- some of us call it Panetta Plaza 

because Leon Panetta was chief of staff when the decision wa 

made to close off Pennsylvania Avenue. So we -- some of us 

call it Panetta Plaza. That is not its official name. 

Typically, I would get off on Pennsylvania Avenue 

in front of the White House -- in front of the gates that 

lead into the West Wing. 

Once the -- once the Avenue was closed down at 

17th on one end and 15th Street on the other end, typically, 

Page 14 

the cab would leave me off -- I would get out at 17th 

and Pennsylvania. 

Q So on tbe west side of the White House? 

A Again, not invariably, but almost invariably, yes. 

Q And then how do you make your way to your office? 

A Before Pennsylvania Avenue was closed down, I would 

gointbegatethat- it fronts on Pennsylvania Avenue. 

It’s calkd the West - West - it’s called the Northwest 

Gate. It’s the gate that’s quite near where the Old 

Executive Office Building is, altbougb when you througb the 

gate, you’re actually on tbe White House grounds, as opposed 

to the OEOB -- tbe Old Executive Office Building. 

Once Pennsylvania Avenue was closed down, I 

typically went in through the gate at the OEOB. Actually, 

right around the comer -- it’s on 17th Street. And it 

was -- there aTe several gates there, but I would go - 

typically go in -- not invariably, but typically go in the 

gate that is on 17th Street, ncareSt Pennsylvania Avenue. 

Q All right. 

A It depended - it also depended on the time of tbe 

morning, because that gate sometimes wasn’t open, and there 

was a gate towards -- more towards Constitution Avenue which 

was open early in the morning. So it depends when I 

I got there. 

i Q where did you work within the confines of tbc 

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3 And I want to ask you to take a look at what has 

1 now been put in front of you -- the exbibif HI-I - and 

5 study it for a few moments, so that I can ask you some 

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Q And ~vhcz within the West Win_r’? 

A I worked -- initially. I worked in the -- the 

bottom floor of the West Wing. Tk West U’ing has one, two, 

thnx: floors. I worked in the bottom floor. 

And I worked there for. I don’t know. six or eight 

months, and then I subsequently moved up to what is typically 

known as the main floor. hut is actually the second floor, 

from a architectural point of view, into one of the. rooms 

that comprises the chief of staff’s office. There’s two 

-- there arc actually three rmms that comprise the 

chief of staffs office. 

Q Is-it fair to say that wben you moved up to the 

second floor, that you could see outside? 

A Yes. 

Q And before you did that. you couldn’t see outside7 

A In the office I was in, it -- there wue no windows 

in the office I was in. 

Q AU right. We are marking an exhibit now. We’ll 

questions about it. 

Page lr 

BY MR. WISENBERG: 

Q And let me note for the record, h4r. Ickes, this 

purports to be a scheme of a floor in the West Wing on which 

the Oval Oflice is located. You’ll notice there’s some 

preprinting on the map -- do you see that? 

A Yes. 

;? 

Q And then there’s -- somebody has handprinted. Do 

you see that? 

A Yes. 

Q ‘That’s not your handprinting, is it? 

A No. 

Q Okay. 

A You couldn’t read it, if it were. 

Q Thank you. I’m going to leave this with you in 

6 case you need a marker. 

7 A Okay. 

8 BY MR. PAGE: 

9 Q Have you had a chance -- 

0 A I have. 

1 Q -- to look at HI-I? 

2 A Yes. 

3 Q Does it appear to represent the West Wing where you 

4 worked at the White House from January of ‘94 to early ‘97? 

S A Yes. 

Page 15 

\\llitc flousc complex? 

A I worked in the -- f ~vorkti in \\hat’s known as the 

\\‘csI Wing. 

Page 13 - Page16 
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Page 17 Page 1s 

1 Q And on HI-l, is the office that you occupied after 1 BY MR. WISENBERG: 

2 you mo\d to the second floor there? 2 (2 I’ll ncyd to interrupt you for just a second, 

3 A Yes. 3 Mr. l’agc. 1’1~ been informed by the Forclady that wc have t( 

4 Q And where is it? 4 stop for the day. But hcforc we do, I want to ask you -- off 

5 A It’s marked here -- wait a minute. (Examining 5 the topic that Mr. I’agc is on -- three quick but unrelated 

6 document.) It’s Room 108. 6 questions -- I hope tltrw and I hope quick. 

7 Q Room 108? 7 There was a story a few months ago in the 

8 A Yes. 8 newspaper to the effect that Monica Lewinsky had visited 

9 Q All right. Can you put a dot -- I see that you 9 the White House 37 times after she was transferred to 

0 have a blue pen with you. Can you put a dot in Room 108. 10 the Pentagon. 

1 A Do you want this (indicating), or do you want II Did you have anything to do -- not suggesting in 

2 blue pen? 12 and of itself that there would be anything wrong with this -- 

3 Q You can use the red, please. 13 did you have anything to do with leaking or disclosing that 

4 A Okay. 14 story to anybody in the press? 

5 Q And just draw a line off of that, Mr. Ickes. 15 A No. I read it in the press. 

6 A Do you want a dot on it or -- 16 Q In your Grand Jury appearance in Alexandria, you 

7 Q Yeah, I would like a dot in Room 108, and then a 17 mentioned that you sometimes spoke to Lanny Breuer. 

8 line down. 18 A Yes. 

9 A Down here (indicating)? 19 Q Has Lanny Breuer ever discussed with you in any 

0 Q Yes, sir. And then your initials, HI. 20 way, shape, or form the substance of any debriefings he’s 

1 A Okay. 21 done of witnesses or lawyers before this Grand Jury? 

2 Q And today’s date, 1123198. 22 A He has not. He’s tight-lipped beyond belief. 

3 A (Witness complies.) 23 Q Has anybody discussed with you debriefings 

4 Q And that’s your office after your move to the 24 of witnesses who have appeared before this Grand Jury or 

5 second floor, correct? 25 their lawyers? Has anyone discussed of the debriefing of 

Page 18 Page 2( 

1 A Yes. 1 those individuals with you? 

2 Q In relation to that office -- 108 -- where is the 2 A No. 

3 chief of staff? 3 Q Okay. Let me state that I’m very sorry that we had 

4 A The chief of staff’s office is in rmrn -- do you 4 to cut you off so soon after you came in. I understand that 

5 want me to hold it up? 5 you have done some testifying in your time in the last few 

5 Q Yes, sir. 6 years, some of it in front of Grand Juries, and I know that 

7 A It’s Room -- the chief of staff’s office is in 7 some of the bacl@round questions we ask you might be 

a Room 111. 8 repetitive to you. But they haven’t been beard by 

9 Q So right next to you? 9 this Grand Jury. 

1 A Right across. There was a -- 10 A No, I understand. 

I Q Oh, I’m sorry. 11 Q And I’m very sorry that it didn’t work out. Let 

2 A There was what you would call a secretarial suite 12 me ask you that -- we weren’t able to complete you today, 

1 in between, but you would -- but Leon’s office, or Mack’s 13 because I don’t think your testimony would be more than a 

I office was yes, right across, that other room (indicating). 14 couple of hours. 

5 Q So at lirst, Mack McLarty is in there? 15 Int me ask you about your future availability. 

5 A Yes. 16 Would you be available next week or the week after to 

1 Q Then-- 17 complete your testimony? 

$ A Mr. Panetta. 18 A Yes. I’d have to -- I’d have to look at my 

) Q -- Mr. Panetta. 19 calendar, but the answer is yes. 

1 A Yes. 20 MR. WISENBERG: Okay. Sorry to cut you off, 

I Q Of Panetta P\a?a fame. 21 Mr. Page. 

! A Exactly. 22 THE WITNESS: No problem. 

l Q All right. Not lckss Intersection? 23 MR. WISENBERG: Are there any further questions? 

I A Not Ickes -- hopefully, not Ickes Intersection. 24 (No response.) 

- 

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I MR. \\XESBERG: Let me thank you again fx your 

2 pz::ence today. and 1’:: a<k: May the witness he excu&? 

3 FOREPERSOS: Yes. hc may. 

I MR. 1~7ISEKB!ZRG: Let me remind you. ho\rc\cr, to not 

5 61 anything to impa:r ti>c documentary int&ty of tlr r.ctes 

6 ycu’vc been taking. 

I THE WITNESS: I won’t. 

8 MR. WISENBERG: Thank you vrry much. 

9 THE WmEZX Thank you. 

0 FOREPERSOS: Thank you. I appreciate your 

1 patience. 

2 THE NTIXESS: Thank you. 

3 (The witness was excused.) 

4 (Whereupon. at 4:31 p.m., the taking of the 

5 testimony in the presence of a full quorum of the Grand Jury 

6 was concluded.) 

7 l l l l l 

1594 

In t-cc: Grand Jury Proceedings Multi-PancTM 

r 

July 23. 1993 

Page 22 

CERTIFICATE OF REPORTER 

I, Elizabeth J. Walker, the reporter for the 

United States Attorney’s Office, do hereby certify that the 

witness(es ) whose testimony appears in the foregoing pages 

was first duly sworn by the foreperson or the deputy 

foreperson of the Grand Jury when there was a full quorum of 

the Grand Jury present; that the testimony of said 

witne.ss(es ) was taken by me by stenotype and, thereafter, 

reduced to typewritten form; and that the transcript is a 

true record of the testimony given by said witness(a). 

______________________________ 

Elizabeth J. Walker 

Official Renorter 

Page 21 - PaoF 
Harold Ickes, 815198 

Grand Jury 

Page 1 to Page 109 

CONDENSED TRANSCRIPT AND CONCORDANCE 

PREPARED BY: 

OFFICE OF THE INDEPENDENT COUNSEL 

1001 Pennsylvania Avenue, N.W. 

Suite 490-North 

Washington, DC 20004 

Phone: 202-5 14-8688 

FAX: 202-514-8802 
asA 

1596 

Harold Ickes, 815198 Xux(l/l) 

--___.. ___- 

Page 1 

:-I:; XE: -, 

:i‘ GRAND JURY PROCEEDINGS : 

.i 

'r.____--__-_______X 

.:: 

:3: Srand Jury Room No. 3 

:ji ;Inlted States Dlstrlct Court 

.I,’ for the District of Columbia 

._a! 3rd b Constitution, N.W. 

_. . .-*I Washington, D.C. 20001 

..- .--I Wednesday, August 5, 1998 

.-3; The testimony of >X?CL3 ICKES was taken in the 

:14:presence of a full quorum af brand Jury 97-2, lmpaneled on 

::S)Sep:erber 15, 1997, conmer.c:r.g at lo:47 a.m., before: 

:1E] SOLOMON WISENBEaG 

::71 JACKIE M. BENNETT, JR. 

:I31 Deputy Independent Counsel 

::9: MARY ANNE WIRTH 

.^I. 

.--. EDWARD J. PAGE 

^I. 1 

.--, “-,‘1 

.--. 

.‘3’ 

is4j 

::51 

Associate Indepenaez: Counsel 

Office of Indepexent Counsel 

1001 Pennsylvania Xrenue, N.W. 

Sulce 490 North 

Washlnqton, D.C. 23004 

Page 2 

. . PROCEEDINGS 

i S iWhC!E”pO” 

HAROLD ICKES 

i:iwas called as a witness and, after having been first duly 

: 5 1 sworn by the Foreperson of the Grand Jury, was examined and 

I&! testified as follows: 

:73 EXAMINATION 

;9; BY MR. PAGE: 

:91 0 

: 1; I please? 

Good morning. Would you tell us your full name, 

,-1 .--I A Harold Ickes. 

‘.?I Q Mr. Ickes, you appeared here in front of this 

j I; 1 federal grand jury back on Thursday, July 23, 1998. a few 

: : 4 1 weeks agoA cor+?cty 

:15: 

:I61 Q And at that time, we asked questions of ou for 

: 17 I approximately 20 to 30 minutes before we recessed for r he 

: : 3 : day, correct? 

::?I A 

Q 

Approximate1 Yes. 

Before we as 1 ed those questions back then. 

ii ? i I believe I asked you and I explained to you about your 

: I:; understanding of certain constitutional nghts that you have. 

::3; A Yes. 

‘-4’ _- , Q Do you remember that? ‘^i, --> A Yes. 

--_ 

Page 3 

*,. Q And you’ve heard thqse during other appearances 

: I i you’ve map ln;;:?r grand jury settings, correct? 

‘3: 

14: Q Would you like me to review those with you again or 

: 5 ! are you sufficiently aware that you have certain rights here 

: c 1 today? 

.-1 A 

:3j Q 

I think you don’t have to review those. 

All right You have Iwo attorneys outside, in 

i 9: fact. todayAcoyzT 

‘L2j 

. . 

.--> Q And you understand that you can step outside and 

: I: 1 speak with,‘hem,,a! any trme? 

--. 

‘li: 

. in 

--. 

_, .-1. 

..-. 

‘tiR. KZENBERG: Can I butt in? 

MR. PAGE: You may. 

BY MR. WISENBERG: 

Q One thing I neglected to tell you last time, 

I s j Mr. Ickes, was that you are - under the disbnction we 

: : ?: som,etimes use, an Informal distinction in the grand jury, 

: I : : of witness, sub ect. targqt, I have told your attorney that 

: I : ; your statuils t h y2syf a wrtness. Do you understand that? .^,. 

.--: .-<’ 

.--, Q And, of course. we cannot uarantee that it 

‘~4 :an unchan 

w 

eable status. You understand 9 hat? 

.-c1 

.--_ I understand. But in other words, I’m not at 

will 

this 

be 

Page 4 

:: : point neither a sub.ect nor a target. 

: 2 ; Q Rig&. In the informal distinction that IS made 

: 3 I between tp t$y, that is correct. 

Id 

., 

!5j 0 b;;;;%t me also give ou the same admonition about 

(61your note taking today that I did last r. ime. That is, you 

[ 7 1 can take notes as long as it doesn’t disrupt the operation of 

[s I!he grand ury, but since we - our view under the case law 

1911s tha! we c, ave the right to subpoena those notes. Don’t do 

: lolanythlng to alter or destroy the documentary integrity of 

; 111 those note:. 

II?] “__ I .._~___A__~ 

i131 $R. ti%:i%??“~ll right. 

:141 Could I get the name of the other 

I161 

TH!; WITNESS: 

r I 5 1 attorney he$ 

;~?]W~senber 

1. ,~lSEN~E~~enn~;~. This is Ed Page, I’m Sol 

ana tnis IS Jack 

il81 k HE WITNESS: _,Oka 

MR. WISENBERC 

iiz;lndependent Counsel. 

3. vy; 

Thank you. 

e’re all wrth the office of 

[?ll BY MR. PAGE: 

!22] 0 All rioht. Mr. 

1z31Julv 23 

Ickes, when you were here last on 

1998, we hid discussed some topics and briefly 

~24 lthdse dere that you cabbed to work on a daily baiis from’your 

: z 5 I residence in Georgetown. correct? 

Page 5 

worked a lot of hours when you were 

White House from in or about 

throu h the end of January 1997. 

rslHouse. Yes. 

(fhat was the period of time I worked at the White 

Q 

Iiitimeframe. 

And that you worked quite a bit during that 

[:s]weekdays. Yes. 

LI61 Q Is that still what your testimony is? 

[I71 A Yes. Yes. 

1181 0 

[ 191 ou worked 

So would it be safe to characterize that as that 

L 13 

uite a bit durin 

120 1 hief of Sta at the White I-? 

your term of duty as Deputy 

ouse? 

A Well as I said “quite a bit” is a 

iii;characterization. I ihink the f&ts - I’ll testify to the 

rz3lfacts. 

Q 

/z:i Exhibit HI-l, which I represent to you is a diagram of the 

I believe also that I had shown you Grand Jury 

c 11 West W!ng of the White House, the first floor, and had asked 

Page 6 

rz]you some questions about the room numbered 108 on this 

r3ldiagram. 

[41 - A Yes. 

Q Would you take a look at that so I can continue to 

/zlask you some questions about HI-l? 

171 A Iveseenit. 

!81 Q 

igldiagram? 

Okay. Are you familiar with room 108 on that 

1101 A 108? Yes. 

/iiiwas 

Q That was your office correct durin 

: : 3 1 Chle 4

our last offtce I should say when you’were 

of Staff at the’white House. correct? 

&? 

‘FUG that 

A Yes it wan ,-., __, . _. __. 

I151 a And, in fact, on the diagram, you’ve put your 

! 16 Iinitials andAthe $a! 7/23/98, correct? 

I171 

I:81 Q Did your secretary sit within that office or was 

[ ~slyour secretary at another location? 

1201 A I had an assistant who -well, I didn’t have a 

[zllsecretary. I had an assistant who sat in the middle office. 

(221 Q 

1231 A 

All right. What was your assistant’s name? 

Well. I had several assistants. 

i24j 

(251 

Q 

A 

The ‘assistant that i&i ‘i&t mentioned. 

His name was John Su b on. As I say, there was 

OlCStarr 

___- _______ 

Page 1 to Page 6 
1597 

BSA 

Page 7 

l-brold Ickes, 815198 

: ~rotztcn of those asststacrs. but for a large part of 

‘2’th.a: Lme. If not for the complete time. his name was 

.3;Jot- Sutton. 

:4j Cl Did you bcng him with you when you startec working 

! 5 I at t-e White House in ‘943 

:6j A 

:7:pac emplo 

No. He started as an jntem and then graduati to 

!a! d 

ee status, 1s my recollectIon. 

And Mr. Sutton was between your office and -oom 

! 91111 the Chief of Stars office? 

[LOI A Yes. 

Q Were there an other individuals in that room 

iifibetween .~~, vou and the Chief o fy Staff? 

1131 ‘A 

14lthat room. 

There were - yes, there were several people m 

151 Cl 

A 

And whom did they work for? 

The 

:76jfor the Chief of Sta & 

worked for the Chief of Staff. They worked 

18 1 fair to sa 

s ofice. Generally, I think it’s 

19 1 reported r 

that with the exception of Mr. Sutton they 

o Leon Panetta. but both he and I used those staff 

2 0 1 people as a general matter. 

211 Cl 

A 

Were you friends with any of those? 

:?I I knew them. 

,231 Q Did 

: 24 IYOU WI the White x 

ou consider John Sutton a friend by the time 

ouse in - 

[251 A Well. I don1 know what that definition means 

Page 8 Page 11 

I 1 IThat’s a characterization. 

121 Q You don’t know what friend means? 

i31 A That’s a characterization. 

[41 Q 

A 

Well. do you have any friends? 

151 I have some friends yes. 

[61 Q 

A 

So you know what that means, then, to you. 

171 I know what it means to me. 

Q 

iii and the Chief of Staff that you would characterize as a 

And do you have anybody in that office between you 

r101friertd? 

(111 A 

[I21 

[131 AQ 

[I41 

Il.51 A" 

!I61 

;171 AQ 

LiEI 

#frien&" 

:211 

i-7. ,--I 

:231 

:241 

(151 

[11 i , ] 

i;1 L 4 1 mind. 

!5! 

!61 

[71 

19: 

[91 

:I01 t--J 

ill1 Q 

;:2100mct? _ 

Is President Clinton a friend? 

I consider him a friend es. 

Is Leon Panetta a frien ?d ? 

I would consider Leon an acquaintance. 

Is Mrs. Clinton a friend? 

Yes. 

So you have friends within your own definition 

-131 H Yes. 

:i4] Q When you cabbed from your residence in Georgetown 

[ : 5 1 to the White House - 

- 

In that oftice? 

John Sutton or others. 

I would characterize them as acquaintances. 

Acquaintances? 

t&n&mm. 

Not friends? 

Not in my definition of friends. 

WhoaresorneofBut I don’t know what you mean by the word 

Who are some of your friends, Mr. Ickes? 

l~o~at timeframe 

My wife my daughter, my partner, Janice Enright. 

Janice knnght? 

Yes. 

Page 9 

Any other friends? 

I have others, but those are the ones that come to 

::f51 A Just so there’s no question about the fullness of 

: : 7 1 the testimony you asked whether I had a secretary and 

: 18 1 referred to John Sutton. 

I 

I had a special assistant who in 

: I 91 fact sat in my room, but she was not a secretary. 

:701 Q All right. And that penon’s name? 

:2:j t JDa;i$yEbn~t,, E-n:r-j-g-h-t. 

I;; i routine basis? 

e se stt in your room, number 108. on a 

;241 A No. 

i251 Q So Janice Enright and you occupied 108. 

XMAUMI 

Page 10 

;I‘ A Yes 

i:: Q Before you mentioned that name of that special 

[ 3 i aSSISta?t. I was asking you about getting to work on a 

1; j routine bags byc& 

161 Q And I ask you now. what was your routine way of 

[? ! getting Into the White House, the West Win 

[ 9 I could work and get to your desk at room 10 8 

so that you 

? 

l9! A As I think I testified to at our earlier session, 

I 10 I before Pennsylvania Avenue was cut off and Panetta Plaza, 

[ 1 I 1 which we discussed was created. my term, not the official 

I 12 1 term, I would typically come in through what is known as the 

[ 13 1 northwest gate which is a gate that’s on Pennsylvania Avenue 

[ 14 1 to the left of the West Wing as you face the West Win 

[ 151 Pennsytvania Avenue. That was typically how I woul 8 

from 

[ 16; not invariably. but typically. 

come in, 

[17! Q Can you Ive the members of the grand ju 

L 1 e 1 on overview wdh Grand 3 

sort of 

ury HI-1 who were some of the o rher 

I 191 indlvlduats that worked in the West Wing, this office space 

[zolthat’s depicted here. 

[211 A In this whole area? 

1221 Q Just - actual1 from this art on that I’m 

123 1 pointing to here, all right? dich is the E?etty Cirrie’s 

~24 10ffce towards where you were positioned in 108 and 111, 

[251 A And going all the way to - in other words, this 

[z 4 I the second time. 

[251 Q So this office here was the press office? 

Page 12 

[El Q All right. Could you put numbers on each 

I 91 one, two, three, four, five? 

I101 A Okay. 

Cl11 Q Just in the red oen vou’re now holdina. 

of those, 

[I21 A All right. ’ e 

Q And up top here .ust put one throu 

I::ioffices. So McCurry and his sti cr 

rl51Myen, correct? 

and before him &e 

h fivsepress 

1161 A Yes. 

Q 

i:i;the West Wina? 

All right. Who were some of the other occupants of 

il9j A -Well. here you have the lobb in which typically 

[ zo 1 there was a uniformed Secret Service agen Y whose name 

[z 1 I I typically never knew and then there was - sometimes 

I 22 I there was a receptionist sitting there, but typically 

rz3lthere was - even when the rece tionist was there, there 

~24 lwas a Secret Service agent, unl .P onned Secret Service 

[ 2 5 1 agent. 

-~~___.____ 

Page 7 to Page 12 

____ _____. 

OlCStarr 
BSA Harold Ickes, 815198 

1598 

XUZM) 

Page 13 

. > 

- BY MR. WISENBERG: 

i2I Q And that’s the room marked lobb on your map? 

[3: A That’s the room marked lobby. Y&s. 

Q 

I::4 and DOCS? 

And underneath It, somebody has put REC area nun 

Page 16 

That IS the room that’s labeked GS and REC 3 

i. In that rooi a small room. or In the room labelled REC 3 

;: it’s very small. and dunn the time that I worked there, 

4 :Geor 

9 

e Stephanopoulos s, ad two asslstants, typically two 

5: assrs ants, worlong there. 

6: Q In specrhcally you’re sayrng REC number 33 

_. A Yes. 

.a1 Q Now, connected to that IS another otTice. cot-e&? 

[91 A Yes. 

[lOI Q 

A 

Which is labelled on this diagram HI-1 GS. ccmct? 

I’m not following ou. I’m sorry okay. I wasr.? 

I:; !followina the first intro on that. &. Yes. That was 

,_j ~__~~ 

[61 A Yes. 

i’l BY MR. PAGE: 

191 0 

A 

All right. Any other occupants in the West Wing? 

Room 115, room 118 room 117. and room 116 were 

f :iidevoted to the National Security Advisor, the Deputy National 

[ : I 1 Security Advisor and their assistants. 

[I21 Q What about 113? 

A 113 is for lack of a better word, either a 

i ii jsecretarial suite or ati assistant - it was a smallish office 

[ ljlwhere assistants and secretaries for the Vice President sat 

rlsland worked. 

0 And what about these rooms that Mr. Wisenbera 

mber 4. REC room 4 and DCOS here, 

i17j 

[ 1~ 1 mentioned,nu below lobfiy? 

A Durin ‘the time that I worked there, the room 

~&?~indicated DCOS EBi?L. I guess that’s an L, was first used 

I: I 1 by Bruce Lindsey and then my recollection IS that Erskine 

122 1 Bowles when he was made De 

.g 

uty Chief of Staff was moved there 

[23land then when he lefk Mrs. Lie erman. who also was the 

rz41Deputy C hief of Staff when Mr. Bowtes‘ left, worked out of 

izslthat room. 

Page 14 * 

i 2: j positioned there? 

[:?I A Well, in the - 

Q 

Ig:ithe record? 

What room, first of all, are you talking about, for 

I251 A Okay. I’m pointing to the room that’s labelled GS 

Page 15 

[ : land I think REC number 3. 

1-i 

ii! 

Q Right next to 108, your office, correct? 

A Yes. Right. 

;a: Q Give us some direction here. Which way is north, 

; ;; south, east and west on HI-l? 

A That s a good question. My best recollection is 

~7: that north is towards - as you re lookrn out of the West 

[ES 1 Wing - I never know my way around 

city in the world. 

&shington. It’s the most 

19 1 screwed u 

L y best recollection is that north is as 

i :; j looking out of the front, what I would call the fron r 

ou are 

of 

112 ; the West Win 

f i 3: opposite dire 4: 

towards Penns lvania Avenue. South is the 

Ion. East would ‘6, off to this direction, 

I i 4 1 towards the cabinet room. And West would be in the opposite 

i 15 j direction. 

Q So on this diagram, the first floor where you see 

i:;ithis printed up top - 

[18! A Yes. 

[?5i 0 That’s the north side. 

[231 A Yes. 

[?I; Q In your opinion. 

[I?] A In my oprnron. 

Q All right. Let’s talk about, then, that space 

[i:jthat you just talked about that’s just east of your office, 

[25!108. 

ir;jMr. Steihanopoulos’ office. 

[I(! Q During the timeframe you were there. 

[I51 A Yes. 

Q Any other White House staff, secretaries, personal 

! it iassistants or otherwise that we’ve not talked about now tha: 

i 18 Iare positioned in this area of the diagram that we’re talking 

t;glabout. HI-l? 

t:01 A 

0 

You’re counting Secret Service? 

Excluding uniformed division and presidential 

lzi i protective detail just White House staff. 

A l’m just looking. I think that is it. We did 

[g:itouch, I think, the last time I was here on room 111, which 

[251is where the Chief of Staff was situated. 

Page 17 

(11 Q Does he have a personal assistant? 

A Well, it depends on the Chief of Staff. 

i:iMr. Panetta had a number of assistants. I’m not sure how 

t4 lyou use that phrase. There was a woman who sat in this 

[slarea between 111 and 108 who I suppose would qualify as that 

[sldefinition. She was the Person who answered his phone and 

t71placed phone cells for him. et,cetera. 

Q 

ii{complex area that s marked as such on HI-l? 

Anybody posdroned or stationed in this Oval Qffice 

A Well, are ou including - the Oval Oftice complex, 

i :y 1 that’s the dining room 

[ 12 1 in your view or as 

on ry. or does that include other rooms. 

Q As7 

ou’re~usrng,d? 

m 

i ::ito the east of Stephanopoulos office. 

using &Just this room that’s immediately 

A That we referred to as the dining room. To my 

I :zi knowledge, there was no one specificall stationed there. 

( 17 1 The one question I have and - I’m just t X, inking now. 

There was a very small - I recall it tiny - a 

i:t; kitchen service area where the White House stewards would 

t:olwork from and my only question, I can’t remember whether 

1: I 1 that opened up drrectty into the dining room or into the 

rzzlhallway that ran between the dining room and the Oval Office 

rz31And, typically, there was one or two stewards there on.,my 

(24lobservation. It was a faidy regular basis when the President 

1251was present. 

Page 18 

Ill Q 

i:; 

A 

l~oy,p,u know their names? 

Q So is it fair to say, Mr. Ickes,,that you were in 

[ 4 lfairty close proximity to a number of people in the West Wing 

[ 5 1 when you were occupying room 108. 

A Well, agarr i. “fairly close proximity” is a 

~76icharacterization. I think I’ve tesfiid to who was 

1 e 1 there and you 

[g]that -an 

can draw your own condusion as to what 

“. . ..__.... 

Q 

I:y{what you?; 

So you don’t know the answer to that. Is tha! 

1121 

3 saying? 

4 I testifii. sir, to where I sat, where 

i 13 jother people sat and I don’t know whether you’d p” 

ople - 

ca I that 

114 1 close proximity or not. 

1151 0 Well, one of the persons you mentioned was Jar rice 

i i 6 j Enright. correct? 

(171 - A Yes. 

[I81 Q Your special assistant, correct? 

t191 A R‘ ht. 

1201 Q V%o shared the same oftice with you? 

t211 A Mm-hmm. 

[:?I Q Would you consider that to be within close 

I 2 3 I proximitv to you? 

i24j’ - A - I would. 

I251 Q And others outside your office, to a lesser degree, 

OlCStarr 

-.- _~ 

Pagel3toPagel8 
1599 

BSA Harold Icks, 815198 

Page 19 

1 correct? 

A 

Q 

To a lesser degree. 

You had a ohone in VOW OffiCe? 

Page 22 

XYbllll., _-___, 

. A I id * .i .: 

.-. i 

,- 

i3. 

‘i. 

,-. 

. . ^. !--_ 

,I‘. 

‘d HI; many phones? 

A I had - in terms of instruments, three 

Cl Three phones? 

A Yes. 

Cl Did you have a personal computer? 

A I did not. 

Q How were vou able to communicate. if at all. other 

i II i than by phone? 

[:3: A I yelled. Actuali;, I don’t know - I didnY 

[I 4 1 know how to use a computer. ve srnce learned, but I 

[ :z:communicated telephone, by talking to people.personally, in 

[ ; E : meetings or one-on-one, by memo. That’s typically how I 

:; - : communicated. 

115: Q Meetings, memos, in person. 

[?9: A In person. Right. 

(3c: Q On the phone. 

I?:: A Right. 

[1S. 0 

(33 J of January ‘97, 

So you are saying that when you left at the end 

ou still didn’t have a personal computer in 

[:4:your office by w K. eh you could send e-mail or otherwise. 

[15: A I did not have a personal computer. 

Page 20 Page 23 

. 

-_ Q Did Ms. Enright? 

_. 

-. A She did. 

i Q Is the White House West Wing offices, are they 

E i connected by computers where people can send e-mails? 

5: A To my knowledge, yes, they are and people did send 

I: i more than 

A Yes. Typicall the meetings. if they involved 

the President wou Y, dbe either in the Oval Oftice or 

[ 3 1 In what you have labelled, here as the Oval office complex, 

[ 4 lwhich I re$ to,asasz drning room. 

(51 

[61 A And- - 

[71 Q Go ahead. Excuse me. 

[El A No, go ahead. 

Q And where would 

r :i jexclusively w&h the President an a 

our meetings be if ou met 

A T 

perhaps one othe $s 

I:f;or in the Oval Ot# 

pically, they would be either in the Oval Office 

ce complex. On very rare occasion, I was 

113 1 with him in the study, but the study is very small. 

He atso has some books in there, he keeps some golf 

I::;clubs which he sometimes likes to show to people and then on 

[16]the walls in the little hallway that go from the Oval ‘&ice 

[ 17 1 to the dinin 

rlelin wooden #a 

room, he has displays, large disphys, that are 

mes with glass over them of many, man 

[ 191 buttons and memorabilra that sometimes he likes to X 

campaign 

s ow 

16: e-mails. 

Q Was that the only reason, that you were not - or 

il ididn’t know how in your words, to operate a computer, that 

[ 9: you chose not to have one? 

110: A Yes. It would be useless. 

[I:: Q You testified during your last appearance that you 

r 12.followed the Whitewater matter closelv because that was one 

i 13 i of your job;, toyvsnitor that, correct? - 

t;4: 

Q Did you have to interact with people in the West 

ii:; Wing when you were doing that job? 

[:7: A Yes. 

Q And did you generate memos and go see people and 

i i:i talk to them directly when you were doin 

[ 2 G :A I generated, I think, very 1% 

that? 

w memos that I can 

r 2:. recall. Whatever I had has been turned over to mv lawvers. 

jz: j I talked togopIe. rimariv. 

- _ 

i13: So asrcal y have you ever heard,this expression 

; :: : “face time” where you would s end 

[ 2 5: directly, sitting down, talking 

some time wtth the person 

a g out your thoughts, ideas, 

Page 21 

; : bringing people up to date? Is that what you’re sayin ? 

:I A Well, I don’t use that term mvself. but ? would 

13 : talk to peo le and meet with them, yes. _ 

IC‘ 8 And the meetinas that vou had. is it fair and 

i; : accurate tosay that 

[ 6 -at the White House you 

: 7. that we’ve already talke 

;6’ A Yes. 

[3 Q And would that be on more than one occasion? 

[I:- A Yes. ,l,. 

; I I -a 

Q 

I think that’s certainly fair to sa 

Are you familiar with this area Y hat you mentioned 

cou 

P 

le of minutes ago. the area between the Oval ORice 

1: 3 : camp ex and the actual Oval Office as depicted on HI-l? 

1;;: A 

Q 

I’m fairly familiar with it. Yes. 

And what are those areas? You mentioned a service 

[ i 6 : area where some stewards stay? 

A Yes. To the best of 

i ,, ‘bathroom, there is a stewards area, t 

I L 5. short, from the Oval Office itself that ends up in the 

1-p. room or what ou have labelled here as the Oval Office 

i; 1. complex, and Y here IS a small study. 

Q 

ii‘;‘Oval Office? 

Is there a door that separates that area and the 

A There is a door that leads out of - there’s a door 

i g z j between the Oval Office and this area that you have been 

i: ~ referring to Yes. 

(2: 0 Have $0~ ever met or conduced a meeting with 

I 3 ; anvbodv in the studv 

i4l . A Yes.. 

15: 0 

A 

Is that how you are familiar wfzl this area? 

I have - the answer is yes. I’ve met peo le there 

[76iand I’ve conducted meetings there. Or I’ve parhcrpate Cf- 

[e i let me put it this way, I’ve participated in meetings in that 

[glarea. 

Q Can 

1 ii! had there. some of t K 

ou give us an idea of the meetings that you’ve 

e oeoole? 

[l'l ‘A tt would depend on the issue. Sometimes I would 

[ 13! meet with the President alone there, sometimes I have 

114 lmet with the President and the Vice President there. But 

tls:typically, it would be a broader group of peo le 

[161 

[ 17 1 sometimes was briefed in the Oval Office on 

Often when I was there at least tpre+.S;nt 

I 18: issues, sometrmes he was briefed in the Ova Ofhce complex, 

1191 that is. the dining room. Those are the situations that were 

[zolquite typical in my experience. 

Ill1 0 So stud , Oval Office and what’s labelled here the 

rz:lOval Office complex w rch IS real1 the dining room? 

(231 A And thekuestion is! 

Q That’s where you met with and had meetings 

I::; involving the President and others. 

r201people. 

I211 MR. WISENBERG: Can I ask a quick question? 

[2?1 THE WITNESS: Yes. 

1771 BY MR. WISENEERG. ,--, 

Q I ‘ust want to make sure about somethin 

I::lMr. Ickes. Just tj or record purposes, when you refer to t % e 

Page 24 

rllstudy - 

[21 A Yes. 

0 

iii marked study? 

You’re referring to the actual room on the map 

I51 A Yes. 

Q Okay. You were not also meanin 

/; {definition the hallway you’ve been talking about t ! 

to include in that 

at leads 

[ 8 Ifrom the Oval Oftice to both the dining room and the study. 

191 A No. That’s a aood auestion. but. no. When I’m 

[i o j referring toQthe st;ty, it’s the-small ‘room here. 

Ill1 

Cl21 A And Y hats why I said in the hallway that leads 

r13lfrom the oval to the dining room, he has the campai n 

[ 14 1 memorabilia that I referred to and I think there may %a even 

[ 15 1 some books there. I’m not ositive. 

[I61 MR. WtSENBER& Thank you. 

(171 BY MR. PAGE: 

i:iipassin 

Q Among the various ways that we’ve talked about of 

1201 n the 8l 

on information to others with whom ou worked here 

est Wing or acquiring information, I 

[zllmentioned 

&eve you 

L 22 I preference. f hone, in person, memos, meetings. what was your 

1231 A It depended, sir, ve 

~24 1 u 2 ency. Sometimes by memos. r much on the issue and the 

here was a lot on the 

[zslte phone. And sometimes in person. 

Page 19 to Page 24 

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1600 

BSA Harold Ickes, 815198 xyu4Ys) 

Page 25 Page 28 

1:. Q Was there any 

: 2 lexample, with the Chief of Sta f? 

rOtOcol involved in meeting, for 

when you were there? 

:3: A Well - 

Q In other words could you go to him, Mr. Ickes? 

j: i Did he have an ooen door DOI&? 

: : manifested, there would be a list of peopk who would be 

::’ 

,P 

articipating in that meeting with the Presrdent. Sometimes 

3: he President would set that meeting 

::‘ More 

; 5 j presumably v 

it would be the Chief of Staff who 

had 

p~cally. 

alked to the President about setting a 

-6!meeting and deciding upon the individuals that the 

: -; partici ate In the meetrng. so that’s one way. 

p 

Anot K 

wanted to 

! s ! IS the 

er way 

resident would sometimes call ma or Mr. Panetta or 

[ 9; presumably others individually to come down to talk to him 

: : 3 I and then there were times when Leon, much more oflen Leon 

: : : 1 than myseff would need to see him to report back to him on 

[;31something that he had asked us to do or needed to bring 

[ 13 1 information to his attention that we thou ht needed to ba 

114 1 brought to his attention at the time and 9 would either go 

1151 throuch - as I said, throuqh one of those four individuals 

i i 6 j typically. 

[?‘I 0 Well, what happens if the President, as you 

I 1s Itestified. called YOU and said. Hev. come on down. I need fj 

ust 

o 

.~. 

j t: to m self 

A I& had - as far as I was concerned with respect 

1 a ; that i 

it was an open door policy. I tried not to ‘abuse 

e&use I was busy and he was bus 

[ 9; needed to see Leon, I would 

‘lolwas his assistant and ask her 

j 111 he was on the phone, sometimes he had a meeting, so I didn’t 

12 Iwant to just barge in the room unless it was a total 

t13lemergency. 

And she would say he’s either here or he’s not 

I :“5; here he’s free or he’s not free. if it’s urgent okay. if 

[ 16 1 it’s not, could you come back at a different iime. ‘But 

[ 17 1 enerally speaking, I would say that I had quite free access 

[ISI ? o Leon and felt that way and I think that Leon felt the same 

[lglabout me. 

0 Anybody else that there was a protocol, a special 

1 zy i protocol that you had to follow in order to either et 

122 1 mformation or convey it in your job as Deputy C 8. ref of 

[:3lStaff? 

A Well. I think the two people in which there was a 

I:“,; similar protocol would be with respect to the President and 

Page 26 

[I Iwith respect to the Vice President for, I think, fairly 

[ 2 1 obvious reasons. 

Q And why don’t you describe what it was with the 

I:;Vice President. How would YOU access him? What protocol was 

isjthere? 

A The protocol, I would either be summoned or asked 

[76ito meet with him ty ically that would be put on the 

[alschedule my schec! ule, hts J schedule. If I needed to see 

[ 91 the Vice President. which was seldom, I would - either I or 

~IOJMS. Enright sometimes or our assistant that sat in a room 

I I I 1 between the Chief of Staffs office and mv office would call 

i 13 j his scheduler and make an appointment- 

[I31 Q 

[ 14 1 talking about? 

Is his office anywhere in this area that we’ve been 

A Yes. His offtce is unlabeled. It is the office 

i:zithat is between rocm 113 and 116. 

Q All right. Would you mind putting a VP in the red 

t:i; n in that area. And then underneath that, Gore. That’s 

[19] R IS oftice? 

[?Ol A That’s one of his offices. 

[211 Q Did he routinely occupy that when ou were there? 

1221 A I don’t know how much he occupre that office 

i 2; j because he has a 

4 

lar er suite of offices across what is known 

12 4 1 as West Drive in the 8 Id Executive Dffice Building, but he 

12 5 1 was there from time to time. 

Page 27 

(11 Q 

i 2 1 secretary. 

So basically you went through the Vice Presidents 

A Through his secretary and/or scheduler, whatever 

iiiphrase is the best one. 

Q All right. And you mentioned the President as well 

i 2 1 as someone who like the Vice President had a protocol before 

! 7 1 you could access that person, correct? 

[ziT{picallr 

A There was - 

not invariably 

10 !w rch a /east during m 

1 I 1 the Chief of Staff or to 

i: 

but here was a protocol there in 

yes: There was a protocol. 

t 

tenure d would be to go either to 

e scheduler or to Nancy Hemreich 

i?ior Betty Currie. Those were the primary - not necessarily 

131excIusrve. but almost exclusive wavs that I used to aet to 

i 14 j the President. 

Q You said typically but not invariably there was a 

i izi protocol and then you mentioned these four individuals: the 

t 17 ~Chief of Stiff. thMazhh;gleuler. Hemrerch and Curne, correct? 

ilB1 

iizihow it worked. Q Te’l Or wen us 1P 

ically when you accessed these people 

i 2 1 j President. 

o these oeoole to access the . . 

A Well there were - 

izi! comolicated ohrase: 

accessing the President is a 

There were times when the Chief of Staff 

i 5 4 j would - there were times when the President would have a 

1:s lmeeting on his schedule in which certain people would be 

f I ~from your office. 

Page 29 

Q 

I ii 1 President’s called you down. 

And what dolou do if they’re not there and the 

Cl11 A If the President has called me down and they’re not 

rlzlthere. which was very rare, I would go into this - in 

[13]through here-again - 

[IdI Q You’re referring again to - 

ti51 A Yes, I’m sorry. 

Q That’s okay. You’re referring again to the 

i i ! i reception area? 

i:tithe 

A Into the reception area and would then knock on 

- ti he were in the Oval Qffice, sometimes he was out in 

[2olthis reception area number 1. It was not unusual for the 

[ 111 President to be out there. But if he were in the Oval 

[:3lQffice,, the door would either be o en, the door from 

123 1 reception area number 1 would er ? her ba open or closed, 

[ 2 4 1 typically it was closed but not invariably, and if it were 

r~5lclosed. I would knock on the door and open it and tell him 

Page 30 

I 11 that I was there ask him if he wanted ma to come in. 1 Q The door you’re pointin to 

B *, 

if you look at the 

i; i Oval office here on HI-1 and assume or this purpose that 

[ 4 1 it’s a clock that would be the 1:00 door? 

;2 

A Yes. 

r 7 i knock 

Q 

and 

That’s the door that if it was closed, you would 

if it was ooen. vou would iust stand in the 

is j passageway? ’ a 

I 

191 A Mm-hmm. 

Q 

i:Yiwave you in? 

Hoping that President Clinton would see you and 

A Well, no. I would always say if he were - first 

i:;iof all - let me back u His desk that he typkzally sat at 

[ i 4 1 if he were in the Ova P office - he sat in a way that faced 

[ 15 1 this 1:OO door that you’ve referred to. 

ii61 Q All right. 

A So I would either knock on the door or if the door 

i :i i were open, I would say, “Mr. President, I’m here,” something 

!~g]to that effect. 

!201 0 Nothing that imrired either his vision or yours or 

tr:]someone who would s and at t e 1:00 

[zzlwhere he sat at his desk in the Oval 

#sron and look at him 

1231 A 

12 4 I was in the 

Well, it depends. If there were only - if only ha 

room and I were in the door, the answer is there 

t351was nothing to impair you, but sometimes he would ask me to 

OIC-starr Page 26 to Page 36 
ESA 

1601 

Harold Ickes, 815198 XWW - -~__~ 

Page 31 

1 ‘ jcome cwn and there would be a big crowd of people in there 

I? I and so ren vision would be rmoatred. ,-_- -- - 

:31 Q You said typically the door was closed? 

:41 A 

Q 

Typically, it was closed. 

And when you sa 

I z j fully dosed like the doors are to 

closed, I want to ask, do you mean 

: 7 j Do you mean cracked a little bit or 

181 A I mean fully closed. 

!91 Q Full closed and latched, correct? 

A Wel r when you say “latched,” I dont ’ know whether 

i :y i there was a working latch on that door, to tell ou the 

j 12 jtruth. I think - there were certainly door han dLS. 

~131Whether they worked or not - I dont ’ know. I think they 

[ldldid. 

Q Do 

[:zjthat 190 door era 

ou know whether the President would ever leave 

I3 

A 

ed open? 

!I71 He may have. To my knowledge, it was typically 

[ 1s jeither fa~riy fully open, I mean, 

jlsjopen. I mean, it can swing all t Yl 

ou can - theres ’ open and 

e way back and theres ’ a 

j2ojdoorstop on it. But my experience was that it was usually 

r211cl0sed. 

(221 Q And closed in the manner that I have suggested. 

!231 A Ri ht. 

[241 Q Fr%y closed, correct? 

:251 A Mm-hmm. 

Page 32 

[II 

121 

[31 

(41 

151 

Q So door closed, you knock, the door opened - 

A Well, I would o n the door. 

Q Tell me about I-= hat. 

A Tell ou about what? 

Q Thatyou would open the door. Tell me about when 

i 6 j you wouldipen the door., ._ 

171 If the President - If either the President or 

is i Betty Currie or somebody else, it couM have been Leon, it 

loleither to a meetin or to see the resident if there were a 

:; ;co;fkTpXen a( number of yte asked me to go down 

ople ere, I walked in wrth them. 

f the door was closed, I would almost invariably 

::iask either Betty or Nancy Hemreich if I could go in and 

lsjjust wai-in. 

14jtypical rf I knew there was a meeting in there, I would 

If I did not think there was a meetin 

::iwith other people I would typically knock on t R 

in there 

e door or 

:B]SOm&heS Nanc’ would open the door and say, “Mr. President, 

191 Harold is here.” 7 treally did vary depending on 

Q Now what would ou typically do if, as we 

I:: idiscussed a little bitago ’ neither 

-&. - 

ume or Hemreich are 

1;3 1 there and the President has summoned you? 

!24! A That was very infrequent1 but if he asked me to 

[ 25 1 come down, I would go down and typica IY ygo through the 

i 2 0 j circumstances. 

Page 33 

1 I 1 secretarial suite. If the door was open, I would stand in 

;2 Ithe doorway and say, “Mr. President. I m here.” 

:3i lf the door was closed, which was usual as far as 

i17L’ A Ini ’ not sure of the uestion. 

Q Well earlier we ha 1 talked about the President 

j--, I i: / calls. says come on’ down. All right? 

;201 ’ A Mm-hmm. ” 

Q Now I want to move on to a different situation that 

i$ j prompts you to go see the President and that is ou et the 

: 2 3 j Idea or someone plants the idea in your head, 

~24 jsee the President.” What do you do? 

40, &ould go 

i25: A If the person telling me - it would depend on who 

Page 34 

; 11 told me. If Leon told me that the President wanted to see me 

[2 I or the Vice President or somebody of that stature had told me 

[31 that the President wanted to see me. where I had reason to 

[ 4 I believe that the Presrdent communtcated with them, and if 

rs:they indicated to me that the President wanted to see me 

161 immediately, I would 

[: 1 same routine that we 9 

o down and go through basically the 

alked about. 

IBi MR. PAGE: 

[sltake a break right now. 

All right.. Mr. Ickes. were ’ going to 

[lOI Ten minutes? 

Cl11 THE FOREPERSON: Ten minutes. 

MR. WISENBERG: And we will come out - one of us 

i::iwill come out and et ou when were ’ requoromed. 

[141 THE Wt?Nf!SS: Okay. Fine. Thank you. 

[I51 

[?61 

rr excused. Wrtness recalled.) 

R WtSENBERG: Let the record reflect that the 

[ 17 1 witness has reentered the grand jury room. 

1181 Madam Fore 

[I91 THE FOREP&ON: 

rson. do we have a quorum? 

Yes we do. 

[201 MR. WISENBERG: 

j21jpresent in the rand u ‘

THt?FOR&P%f%%: 

Are there any unauthorized persons 

I221 No there are none. 

I231 MR. WISENBERG: 

THE FOREPERSON: 

Thank you. 

I241 

[zslthat you are still under oath. 

Mr. Ickes, Id ’ like to remind you 

Page 35 

[II THE WITNESS: Yes. 

[21 BY MR. PAGE: 

[31 Q All right. Mr. Ickes, I wanted to ask you some 

[ 4 1 additional questions about when 

I 51 whatever reason to visit with the b 

ou found it necessary for 

resident In the Oval 

i6joffice. 

[71 A Ri ht. 

Q &at would ou typicall do when you went to the 

ii;Oval office, reoardless of w K ose rdea If was. that vou talk 

11 o 1 with him or met with him, and you knocked.on the door, 

[ 111 because the door was closed, and no one answered? 

1121 A Well, t guess - the reason Im ’ pausing, Im ’ not 

[ 13 1 sure about the question. tt depends - typically, I would go 

[:4 jin through the secretarial surte and almost invariably either 

il51 there would be somebody in there, either Betty Currie or 

[ 161 Nancy Hemreich or both or sometimes a personal assistant to 

1 I 7 1 the President would be in that office. 

i :ii but typically there would be non-uniformed Secret Service ’ 

And, again, typicalty, but maybe - not invariably 

(20 1 a 

9 

ents outside in that hallway, but if I was asked - 

[21]e1 her asked or instructed or Informed that the President 

[z:jwanted to see me, I woukl 

[23 1 into the secretarial suite an % 

o into - ty 

check wd R. ically. I would go 

124 1 Nancy. 

either Betty or 

Or if they werenY there, with whoever was there. 

1251 Q And what if no one was there - 

Ill 

[21 

Page 36 

Aa Ifnoonewas- - and the door was dosed? 

I31 A Im ’ sorry. 

I41 Q What if no one was there and the door was closed 

[ 5 1 and ou knew that you had either been summoned or that 

!%::Pk,dent? 

ou 

n directed or that it was your own idea to speak w iii 

. ,- - .-- -- _. 

A I would knock on the door and would then open it to 

ii;see if he was there and announce my resence. 

1101 Q What wouki you typical P ydo d you, in the same 

[ 111 situation Ive ’ ust ‘ described, knocked, got no answer and 

[ 12 1 then opened I he door and the President was not within your 

113 J view in the Oval Office? 

1141 A I dont ’ recall that hap 

[lsjthat I would not o in if he werent ’ t r 

ning, but if - I think 

ere. 

[I61 Q l%ats ’ what you think you would, correct? 

Cl71 A Yes. 

[I81 Q 

I 19 I happening? 

And your testimony is that you dont ’ recall that 

[201 A I dont ’ recall that hap ning because typically if 

[21 I I went down - if somebody told me phe ” President wanted to 

[221see me, he would either be there or Nancy would have called 

123 1 me and said that the President wanted to see me. Typically, 

(24 1 he was there. 

[251 Q Okay. Well, Im ’ asking you typically in the 

Page 31 to Page 36 OlCStan 
BSA 

1602 

Harold Ickes, 8/S/98 IMAX”“, 

Page 37 

: :situation Ive ’ described. Bettys ’ not there, Be 

Y 

Cume 

- : that is, Ms. Hernreich. and you go down there 

-I- urpose, or I should sa 

or whatever 

-::p %, residents ’ phone call, b 

at whoevers suggestion, either the 

anettas urging you or your own 

: 5: idea. the door is closed, you knock you now sa 

6: you would open the door and look for the Pres icl 

typically 

ent and 

; 1 :announce 

.-. II 

ours& ahnrmgp in. 

Q And m question was if you didnt ’ see him after 

: i 3 jdoing that, what woul J you do? 

. . . A I would typically leave. I mean, if he werent ’

i? ithere. As I say, I dont ’ recall a time that that occurred, 

: :; 1 but if it did, I would leave if he werent ’ there. 

-4‘ ’ Q 

1 f5 j happening - 

When you say that you cant ’ recall that 

“i. A I mean, sometimes, you know, the President - 

i !i ‘ sometimes the President is out playing golf on the South 

::s:Lawn. 

Q All right. You say now you cannot recall that 

15z: haopening. correct? ;-.: .. .--: -A 

QThats ’ my best recollection. 

p-7, .--! 

::3!did happen? 

So is it fair to say that you can? exclude that it 

.-{I A I cant ’ -there are very few things that I can 

ii 5 j exclude, but, as I say, I dont ’ recall that happening. 

Page 38 

1.. Q 

: I : that vou can 

So 

exclu a 

our testimony is that there are very few things 

e. correct? 

:3; A 

Q 

Most things are possible. 

And so you cannot exclude that under the situation 

[: 1 Ive ’ described you knocked looked in opened the door 

.6; looked into the Oval Office. did not find the President. and 

i 7 i nevertheless walked in? 

A 

: ?; that - you 

I dont ’ recall doing that and I must sa 

know typicall 

: 3 I President of the Unrted ‘ 2 

- you re talking now abou?thMer. Page’ 

tates. its ’ not - if somebody says 

:: jto you that the President wants to see you or if Nan _ or12 lsomebod 

r 

has called or if the President has called, %S- 

: 3 1 its ’ almos - not unthinkable nothings ’ unthinkable, I 

: 4 1 suppose, but it is very hard for me to conceive of a 

: 5; situation when he wouldnt ’ be there. 

~. In other words, if somebody had said to me, “The 

::j President wants to see you,” or if Nancy had called and said 

: 3 : “The Presidents here, wants to see 

J 

ou ” or Be 

.fy ‘

had called 

: 9lor just say that his personal aide ha c&d or tf he 

2: J President himself had called and said, “Come on down,” I 

2; ; assume hes ’ oin to be there. And I dont ’ recall any 

22; instance in w I?. rch a e wasnt. ’

that couldnt ’ be true, and 

ecially on the weekends 

he had a little putting 

Page 39 

. J reen outside on the top end of the South Lawn that he would i;:g out there. 

Q 

; g i Oval Office? 

The President had a bathroom, correct, off of the 

.r. A Yes, he did. 

6‘ ’ Q 

: - ; correct? 

And sometimes YOU were aware he used that bathroom, 

is; A He did use it. Ive ’ seen him when we were in 

;I meetings in the Oval Office when he would aet UD and ao to 

: 1: j the batfiroom and come back. 

-. - 

0 

f f f i Office and 

Sometimes have you not seen him teave the Oval 

: 13; get a refres 3, ment and return? 

o to the pantry area and get a cup of coffee and 

A Ty 

i ::j recollection is tha P 

ically - I dont ’ recall that because my best 

when the President was in the Oval 

: 16 : Office that one of the - a steward was there and he had 

: :: 1 little buttons that he could press and a steward would come 

::l:out. 

Q But you cant, ’ you say, recall that, but on the 

1; i j other hand, you cant ’ exclude the fact that that it may have 

:: 1: happened, can you? 

.--: A I certainly cannot exclude it, but, as I say, I 

{fifdont ’ ever recall the President gettin 

::4 jwere there and when he was there. % 

up when the stewards 

:: 5 1 they were always there. 

y recollection is that 

..- - , 

Page 40 

[I] Q And thats ’ our recollection now. You could have 

! 2 I forgotten. could you not, t Ii e btne that the President left 

[ 3; the Oval Office and walked into the pantry to aet a drink? 

:41 A Yes, I could have. - - 

:5> 

i6j 

Q Same thong with the bathroom, correct? 

A Yes. Yes. 

0 So what happens if you are at the 1:OO door of the 

ii iOval Office. knock, no answer you open the door look in 

[ 91 the Presdents ’ not there, but you belleve him to be in the ’ 

I IO I Oval Office complex, the study, the bathroom or the pantry? 

[ii] What do you ty ically do? 

[ItI A is I sa , Mr. Pa e. I dont ’ think that -that was 

[ 13 1 not a typrl situation &cause ?dpnt ’ recall that 

114 ~occumn It may well have. I cant exclude IL to use your 

rlslphrase, ut I dont ’ recall that. 

[16i I mean, when I went down -when I was called down 

[ 17 1 or summoned down to the Oval Offrce or directed to go to the 

[ 18 I Oval Oftice. the President was there and, as I say, I 

I I 9 I typically would check with either Nancy or Betty. 

I201 BY MR. WISENBERG: 

iz11 0 I think part of the predicate of Mr. Pages ’

I 22 1 question was also if in addition to the things you just 

l231named. berng summoned or told, coming down on your own. 

[24 I Is there any Incident you recall, any time ou recall when 

r251you came down on your own to see the 3 resident and had the 

Page 41 

[ 1 I scenario Mr. Page mentioned: you knock on the door, no 

[2 I response, you, open the door or the door is alread 

[ 3 1 the President Isnt ’ in the Oval Office? Do you cal Y out ha 

open and 

[ 4 1 name or something like that? 

I51 A Ag%n. I dont ’ - I did not impose -the 

[ 61 Presidents a very busy person. I did not impose on him 

[ 7 I unless - in other words. I didnt ’ ao to see the President 

[ 8 1 unless he either had requested my 

! 9 I senior staff had indicated to me tha P 

resence or somebody on the 

110 1 Im ’ not rulin 

he wanted to see me. 

I 111 that he had 9 

out if there were an emergency and I thought 

o know somethin 

[I21 I think the one time 9 hat I recall oi 

t 131 there, it was uite a dramatic time was w 

7l 

It en Tidown e news came 

~14 Ithrough that t e pnme minister of israel had died and I did 

[I 5 1 

IL 

o down on my own, with Tony Lake as a matter of fact, 

cause we knew that the President was there in the Oval 

/:76iOffice complex. It turned out that he was out on his putting 

[ 18 1 green and we went down there on our own. 

[I91 We were not called down there. That was what I 

~20 1 would consider an emergency type situation iven that he 

[211needed to know of that occurrence. And Mr. *P 

[zzldown t 

ake and I walked 

t23jtold us %T 

ther and walked out. Agents were around and they 

at he was on the putting men. We went out, 

[2 4 1 informed him of that and then I wa ik ed 

[25]OfflCZ. 

back with him to his 

Page 42 

171 BY MR. PAGE: 

[El Q 

rsldescribed. 

So sometimes in this example that youve ’ just 

the Secret Service agents might give you some 

[ 1 o 1 information about the whereabouts of the President? 

I111 A 

11238 

[ 1310 % 

ems 

Yes. Typically, again, I - you obviously have had 

in here and they know their routine, but m 

servation was that when the President was in t 1: e Oval 

[ 14 ~Office, his personal security - members of his personal 

r151secyT 

detail were stationed in and around the Oval Office. 

[ 16 ]Typca ly, they had one or two agents in this hallway. I 

~17 jdont ’ know how ou want me to refer to it. but - 

I181 Q dalkwa number l? 

[I91 MR. WISENdERG: 

[2o]on the ma that would help us. 

If you could refer to it how it is 

[211 ?HE WITNESS: Okay. 

1221 .~~. BY MR. PAGE: 

Q 

I::iof the Oval Office? 

Walkway number 2, right outside the 11:00 position 

[?51 A Right. Hallway - yes. Is that walkway? 

OlCStarr Page 37 to Page 42 
1603 

esA Harold Ickes, 8/5/98 XHAXIMI 

Page 43 

0 Yes. 

A Is that the word? 

Q Walkway number 2. 

A Yes Walkwav number 2 - 

i5; Cl 

161 A 

Youre ’ pointing at HI-l, correct? 

Yes Im ‘ pointtn 

[-iwere - my best recollectron is t 8 

at HI-l. And typically, there 

at there were - when the 

[s 1 President was in the Oval Office or in the Oval Office area. 

rslwhich would include, as I use that term. the secretarial area 

~~o;goino all the way down to the - when he was in the West 

i 11 j Wing, let me puf it that wa 

I Z 1 

When the Press J ent was in the West Wrng, his 

non-uniformed 

[ 14 1 he was in this 8 

rsonal security agents were with hrm and if 

al Office area, typicalty. my recollection 

[ I 3 1 is that one or two non-uniformed agents would be here in this 

:lsjwalkway 1 and walkwa 

[:7]this - what you have la ile 

2 and, in addition, agents were In 

lled here, I think, as colonnade, 

[ I 3 :which is this - theres ’ sort of - not sort of, theres ’ a 

[~slsidewalk along the cabinet room and comrng around to part of 

[: o 1 the Oval Office and there were agents stationed there as 

rzljweli. 

Q Now what about on weekends when the staff is - 

If:iBetty Currie and Nancy Hemreich arent ’ present and ou felt 

12 4 1 the need, for whatever reason, to go and try to talk w K h the 

[ 2 3 1 President? 

Page 44 

El1 A 

[zjbut - 

Again, I would - again, I may have forgotten, 

131 0 

[41 A 

May have forgotten what? 

I may have forgotten - let me back up. I was 

~51 using your phrase in the sense that I could have forgotten. 

[ 6 1 You ve asked that several bmes. I do not recall other 

[ 7 1 than - and, again I may have forgotten if I went down on my 

[s 1 own. I did go down when the prime minister died, when we got 

[ 9 1 the news on that. 

'101 But I dont ’ recall as I sit here today 

111 to see the President unless he had - or some %od 

oin; lday 

F~z~notied me that he wanted to see me. Either he called or he 

131 ‘ had the White House switchboard call or he had Nancy, Betty 

'14 ]or his personal aide - and, again, I dont ’ want to say 

131 ‘ invariably, but more often than not, my recollection IS that 

j ~slwhen he was in the Oval Office, even on the weekends, 

was usually with him, either hi personal aide or 

I cannot exclude 

rzsjthat. But - 

[251 0 Can you exclude the possibility - 

Page 45 

r:. L-> A It would have been rare indeed. 

1 ‘“ Q - that after havin 

i;; you occur that you entered into t it 

those facts that I ust ‘ ave 

e Oval OftTce and cl% no ed 

I 4 1 on the door leading to the stud ? 

151 A WouM I o into he Oval Oftice and then do what? 

Q Notwou%g ! 

itlfacts that Ive ’ given you: 

ou Can you exclude, based upon those 

etty Currie not present, 

18 1 Hemreich not present, its a weekend, you knock, no answer, 

10:)s 

!g] ou enter and walk into the Oval Office, looking for the 

resident, and then either call out for hrm or knock on the 

I 11 door to the Oval Office complex, study/bathroom/pantry? 

121 A Mr. Page, I cant ’ exclude that. I find it very 

: 3: difficult to believe. unless there were an emeraencv. mv 

ilijdoing that. 

. . . . 

[I51 MR. WlSENBERG: Can I butt in? 

LIE: MR. PAGE: Yes. 

r:,: BY MR. WISENBERG: i:gi 

i I31somethin 

Q You mentioned the switchboard as an exam le of 

that - as one of the examples that had to do wrt 3 

[zo!others ou 9. srde yourself promptin 

[zl:Do 

x 

ou ever recall an occasion t 

you to see the President. 

ou were notified b the 

[:z]sw chboard on a weekend and r 

[33land see the President? 

prompted you o go In 

:241 A The President had - first of all, the Presidents 

i 25 1 very peripatetic. It was not unusual, either during regular 

Page 46 

: 1 office hours, however defined. or on the weekend, for the 

.r. Presrdent to walk down to the Chief of Staffs office and to 

:; : talk to erther myself or to Leon. He didnt ’ do that 

: 4 .freouently. but rt was not unusual for hrm to do that. 

:. On more than one occasron. I recall working tn my 

ii: office. my desk faced my door. Im ’ now using - let me put m 

;-. 

.? 

lasses on here - In room 108. my desk was situated so tha r ,i. 

_-. - when I was seated at the desk. I faced the door. And I 

; ;: recall on more than one occasion looklng up and there the 

I 1; : President was standing in the doorwa or sometimes he would 

; 1: :say somethin So it was not unusua 

:;z:down this hal l?v 

r for him to be up and 

ay. 

::j: Q But what I meant was do you recall a situation 

~14 ~where the President is presumabty somewhere in the - 

; ;s: somewhere, lets ’ not sa 

: : E :White House, its a wee z 

we dont ’ know where, youre ’ in the 

end, and you et a call from the 

: :-: switchboard. You mentioned the swd .ct board. 

;1g; A Right. 

1191 Q And basically saying something to this effect, not 

: 2 ~1: at all exactly, but as an example. we have a call coming in 

:c-:;for the President and hes ’ not prcking u and its an 

i2Z:rmpottant call, can you go locate him. 

:23: A 

inything like that? 

Again, I cant ’ exclude that. I dont ’ recall that 

[ 2 4 : happening. Ty 

1-3; President - if t R 

ically, my best recollection is that the 

e President wanted somebody, he wouM - I 

-__ _____ 

Page 47 

I; :think that he has some direct dials on his phone, but 

: 2 :typically what would haprn is that, the switchboard would 

i 3 j call me and sa 

[ 4 1 often the swrt dl 

that the resrdent IS lookrng for you because 

board didnt ’ know where I was. 

I201 BY MR. PAGE: 

I2i: Q Did you ever, Mr. Ickes. on a weekend go down the 

:-T: L--_ hallway from your office towards the Oval Office area and in 

I 2 3 J an attempt to see the President in the Oval Office have a 

12 4 : Secret Service agent unlock this door into Betty Curries 

1~3 1 office here that Im ’ pointing at on HI-l? 

Page 48 

i ~z;called me and said that the President wanted to see me or 

: 13 I wanted to know where I was and wanted me to come down and see 

Q Let me just interrupt you for record purposes. 

A Yes. 

Page 43 to Pare 48 OlCStafT 
1604 

BSA Harold Ickes, 815198 XNUMI ’

Page 49 

Q When you sa 

it : again, youre ’ refernng to wal xv4 9 

“a couple of a 

ay 2, correct. 

ents in this hallway,” 

I:’ 

l:sto ‘

A Walkway 2 and walkway 1. Im ’ not sure where one 

;5:do P 

s and the other starts, but if walkway 2 - its ’ hard to 

his. This here. this arrow here is the entrance into the 

ii: secretarial suite. Is that correct? 

i7“ Q 

ieiyou, is the 

Yes. That was the next thing I was going to ask 

door that were ’ referencing that you had 

! 31 unlocked, that you would have them unlock, which is into 

[ lo;whats ’ called reception area 1 on the ma 

[ 1:: indicating that it is at a spot between wal i? 

you appear to be 

[ 12 : called waiting area one. 

way 2 and whats ’

lljl A 

iiriarea 1. 

Oh. waiting area. Im ’ sorry. Thats ’ waiting 

Q Okay. When you said you werent ’ sure whether it 

i:ziwas walkwiy lYois2. ou,meant waiting area 1 or walkway 2? 

II-: T 

0 And its’”~t~ f?i% right near the end of an arrow, 

I:i:where the arrow is going through the letter 0. Is that 

f:clwrrect? 

121 ’ A Yes. 

i22j Q All right. 

A That s the door that I assume on this - this 

j::ifootprint goes into the secretarial office from what you have 

rzs.desrgnated as waiting area 1. 

Page 52 

: 1) call out to the Prestdent trying to find out where he was? 

:2’ 

F7iNO 

A Agatn. I cant ’ exclude it, but I dont ’ recall rt 

j_, .-. 

L41 Q All nght. I want to ask you some follow-u 

i 5 i questions and talk wdh you about early April of 1996 an 8 I 

i 6 1 Want to re resent to you some facts. 

[73 f n early April of 1996, Mr. 

[alabout to visit Washrngton. D.C. 

Ickes. Tony Blair was 

It was an electlon year an: 

[ 91 according to press reports Sidney Blumenthal was handin; :ut 

~101 bumper stickers that said “Dole is 96.” 

On April 3. 1996 a gentleman who you had worked 

I:i;for. Ron Brown, died rnan ’ airplane crash. Jim Guy Tucker 

113 lwas on trial in federal court in Arkansas in a 

[ 14 ]Whitewater-related matter, a matter within your job 

[ ~~ldescription, as youLe testrtied earlier. “Bloodsport,” a 

I 16 I book by James Stuart, had just been released. 

1171 A federal court in Richmond had just released 

i :s 1 a decision denyrng the 7 uest to dela the lawsuit Jones 

[:9!v. Clinton until after Pres ent Clinton eft office. 

7 

rzolAnd a federal court in Richmond had ust ‘ upheld the “dont ’

121 IaskIdont ’ tell policy that bars known c, omosexuals from 

[zzlthe armed services President Clinton was about to take 

;23]a tri 

~24 lfina P ly, the First Lady ha 

to the nuclear safe 

2 

summit in Moscow. And, 

(25lGreece. 

just returned home from Athens. 

Page 50 

1:: Q Okay. 

A That is the door that would - if the President 

Ii;were there, either at night or on the weekend or an other 

[ 4 Jtime and there was no one in what you have call eJ -what 

r5lyou have labelled as reception area 1, which I call the 

[ 5 1 secretarial suite, Be s ‘

rsonal aide is not t 

not there, Nancys ’ not there, 

[7irle. 

3: ‘ ere or somebod 

pically my experience was that this J 

substituting, then 

LB 1 oor going from waiting 

[glarea 1 mto rece tion area 1 was locked. 

[lOi MR. &ISENBERG: 

THE WITNESS: 

Thank YOU. 

And that would be the door - if I 

I :I ! were informed either b the President direct 

~~~~typicall~ through the d’ 3: 

or more 

tte House operator t at the President 

[ 14 jwas in his - what I cell - was in the West Win and wanted 

r15;to see me, then I would go down - and obvious 9 y d I were 

[ lsjthere, I would go down and if that door were locked, I would 

( 17 1 tell the agent who I was, they knew me by then, tell him that 

[ 1s; I just received a call that the President wanted to see me 

r~gland they would unlock the door. This door here. 

[201 BY MR. PAGE: 

Q This door here, Mr. Ickes, on HI-1 leading into the 

I:f 1 hallway to the study and the Oval Office complex/dining room, 

1:; 1 have you ever knocked on that door? 

A I dont ’ recall ever knockin on that door. That 

i::idoor was - during this presidency, that 8 oor was very seldom 

Page 53 

I:! And ust ‘ to make the record clear, I miss 

c, 

oke when 

(2 I I said that t e 8th Circuit was in Richmond. A cr ually, the 

[ 3 J 8th Circuit is in a different city,, but it is accurate to sa 

[ 4 1 that they had just denied Presrdent Clintons ’ request r o 

I 5 I delay the Jones v. Clinton litigation until after he left 

[610ffice. 

[71 Knowin 

[ 3 1 accurate, and tha 

p... .J all that, if my re resentations are 

thus rs In the ml dle of the Whitewater 

[ 91 tna!, which IS a matter within your assignment as Deputy 

[ 1 o I Chief of S;ff. c$~r$? 

[llj 

$;1996? 

Q Do you remember that time of year in early &ril of 

I : : used. 

i2‘ 

Page 51 

Q Im ’ not talkina about the door at 1190. 

i3i 

14: 

15: 

16’ 

A Im ’ sorry. - 

Q Im ’ talking about the door at 990. 

; $t.9&wd1;: 

!3j 

A You mean - okay. I apologize. 

MR. WISENBERG: 

! 3; Office into the hallwa 

J 

The door leadin frrT;he Oval 

that leads from the Oval df 

[ lo:the dining room, the .OO door if the Oval Office were a 

[li:ClOCk. 

THE WITNESS: I cant ’ ever recall a 

ii:jyour phrase, Mr. Page, I cant ’ exdude it complete ? y 

ain to use 

but I 

i 14 Icant ’ ever remember enterin the Oval Office for the first 

[ 15;time on a iven transaction t rough that door. 

[lb; (BY MR. PAGE: p, 

[171 Q Im ’ not saying entering into the Oval Office - 

[l ’

!19: Aa Okay. - in a transaction. Im ’ saying did you ever knock 

~23 ion that door from the Oval Office side - 

I2li A .~~. Oh. from the Oval Office side? I dont ’ recall 

[r::having done so. 

c23: Q But 

r 

ou cant ’ exclude it. 

(24: A No, cant ’ exclude it. 

[?Si Q Did you ever while in any part of the Oval Oftice 

Page 54 

[ 1 lso-called Whitewater, however defined, and I defined it 

[2 1 pretty broadly, as I had been in earty 94. ‘

131 Q But YOU were involved. 

I41 A I was involved, yes. But, as I said, Jane was 

I 5 1 handling it very much on a day-to-day basis and reported to 

r E I me not necessaritv everv dav. 

i7i Q Was it a matter ‘ of interest for ou or Sherbm 

1s 1 that the week before Easter a witness in the &h&water tria 

[ 91 had, as he testitied. mentioned President Clintons ’ alleged 

[ 10 1 involvement? 

[Ill A In? 

I121 Q In Whitewater. 

A I dont ’ recall the specific instance. I think its ’

i :: i fair to say I would have been interested yes and probably 

[lslwould have discussed it with Ms. Sherbume: 

1161 Q And with the President? 

[I71 A I dont ’ know. It would depend ve much on ze 

[ 1s 1 circumstance. There was much that went on in %hitewater and 

[ 191 much that Ms. Sherbume and I discussed that I did not 

[zoldiscuss with the President. 

Q But you cant ’ exclude visiting or discussing wth 

I:: ithe President aspects of Whitewater because it was an ongong 

rzsltrial at the time correct? 

A There were times when I had discussions wrt? the 

i::;President about Whitewater. Yes. 

OK-Starr Page 49 to Page 54 
Page 55 

Q Dunng this timeframe? 

Page 58 

MR. WISENBERG: Pardon us iust a second 

i-‘! 

:i‘ B Pause.) Y MR WISENBERG: .-a _. .._ -..-~ 

14: Q Do 

[5ja PPD, thats ’ the p 7 arnclothes presidential personnel, 

ou recall, Mr. Ickes.,an occasion where either 

[sIpresidential 

~7 jar uniforme 8 

rotective detail, sorry, either a plainclothes 

Secret Service agent ever came to 

[elfor your assistance in an effort to go and 

9 

et the B 

et you or ask 

resrdent 

[slabout a 

g 

articular issue? In other words, he President is 

! 10 1 needed y somebody, but the a ent doesnt ’ feel that he or she 

[ I I 1 has kind of the stature to go do a and they come to get you 

rlcland ’ seek your aid. Do you ever recall that? 

[I31 A I dont ’ recall that. Again, to use Mr. Pages ’

[14 1 

L 

hrase. I cant ’ exclude it but d may well - it may have 

en 

i:zi I findit ’ hard to believe that the non-uniformed 

but I have no recollection of it. And quite frankly 

a 

1; 7 J ever feel that they could not approach the Press 3 

ents would 

ent. 

I mean, they are assrgned to protect him and my 

i :“,! understanding was that they always knew where he was and 

[zolalwa s have access to him, maybe with the exception of the 

121 Ires! J ence. I dont ’ know what the ground rules were in the 

1221 resrdence, but cqrtarnl 

;;:;workrng azump. r 

outstde the residence. That was my 

dont ’ know what the facts are. 

you recall working on Easter Sunday in 1996? 

[SS] A I have no recollection whether I did or not. 

Page 58 

11) conversations with the President. 

Q Are you friends with any members of the United 

I: i States Secret Service, whether uniformed division or 

14 1 protective residential detail? 

I51 Al Not in the terms that you and I discussed earlier. 

[61 Q Are any of those members that Ive ’ just described 

[ 7 1 acquaintances of yours? 

:e1 A Yes. I know them and have worked with them. 

f91 0 Do you know any of them by name? 

[lOI A I do-know some.- 

:11; Q And what are their names, please? 

[I21 A The names that I recall at this point would be Mr 

:13)Carpenter, David Carpenter, who was the head of the 

: 14 1 Presidents personal detail during the election, the 1992 

: :s)election, and for a period of time after he became president, 

i 1 r, 1 was sworn in as president. Lew Mertetti I worked with, know 

;:7 lfairl well and worked with quite closely. I cant ’ remember 

; 1s) his Y ast name, Brian whatever his last name was, who 

: 1g)succeeded Mr. Mertetti as the chief of the detail. I knew 

;20 J Larry Cockell. Those were the primary people. 

i211 The first three were the 

: 22 1 with because as Deputy Chief of .!f 

rimary people I dealt 

taff I was involved in a 

[:3,number of the Presidents trips and therefore related very 

: 34 1 closely with the heads of his personal detail. I knew 

;25 1 others. I cant ’ recall their names as I sit here today, but 

Page 57 

: 11 knew a number of peo le on the detail. 

_.,I Q What a E out acquaintances at a different level, 

:; j people who would work actually in the White House, whether 

i 4 1 members of the uniformed division or the presidential 

: 5; protective detail, stationed in the hallway, for example, 

{E! right outside the Oval Office? 

!! ‘ A I knew a number of the a 

f 9 I aood on names or numbers. but I did 9 r 

ents b sight. I am not 

no know heir - there 

isj%e a number of the agents in the Presidents personal detail 

lolthat I knew on sight, we were on speakin 

? 

acquaintance. hi, 

:I 1 how are you, whats ’ going on, that type o discussion. But I 

12 Iwould be hard pressed to remember names. If you mentioned 

13 1 names, it would probably jog my memory. So thats ’ on his 

il4jpersonal detail. - - - - 

;:51 On the uniformed detail, I knew a number of the 

: 16 1 agents by sight and were they to walk in here today I would 

: :7 1 undoubtedly recognize them. 

i;;;of one uniformed Tnt. 

I cant ’ recall one specific name 

Q So Id you befriend anybody on the uniformed 

: 20 j division or have re ular contact with that person? 

rz:j A We , I wouldnt ’ use the word “befriend.” I knew 

133 j them because they were in - it was a fairly regular detail 

; 2 3 1 which turned over from time to time and there were people who 

j ~4 1 I recognized and was on hi, how are you, good morning, good 

: 3 5 1 evening basis with and that was it. 

Page 59 

Q All right. Assuming that people have said or 

ih 1 records show that you were working, you would have no reason 

r3lto necessarily to doubt that. Is that a fair statement? 

(41 

[51 

Aa Th,year IS this? 

A Well, dependin 

/76ion who said it. The answer is 7 

what the records were or depending 

dont ’ know whether I was 

[ 8 1 workin 

191 Iwoul B 

on Easter Sunday or not. It sounds a little odd that 

be workin on Easter Sunday but maybe. 

Q Ot?rer than the fact that it sounds a little odd, 

i:yl]you have no specific reason to - recollection that 

[lzldrdnt ’ work on Easter Sunday 1996 Is that corre x 

ou 

? 

A No, but to turn it around, I have no recollection 

I::ithat I did, either. 

I151 0 

A 

You cant ’ exclude it, to use Mr. Pages ’ term. 

No. Under that formulation, I cannot exclude it. 

1 :t ;Thats ’ a pretty tou 

0 An % 

h test to meet. 

as I understand your testimony I want to make 

jt89isure Ive ’ got it right, there were occasions on the weekend 

[zolthat you can recall on weekends when you did work during 

(2 1 l our time 

b 

at the White House where when you went to see the 

1221 resident you would have to have agents unlock the door that 

1231 led into what we have called receotion area 1. Is that 

~24jCmrect? 

[251 A I recall that occurring. When, I couldnt ’ even 

[ 1) recall the year, but I do recall it happening on very rare 

Page 60 

[ 2 1 occasions and to the best of my rewllectton, I had been 

[ 3 1 informed that the President wanted to see me. 

[41 Q Okay. And, again, you cant ’ exclude that - as I 

1s 1 understand you, you cant ’ exclude that there might have been 

[ 6 1 an occasion when that scenario happened, going down and 

r 7 1 having that door unlocked, when you didnt ’ necessarily know 

t 8 1 that the President wanted to see you, but that you wanted to 

[ 9 1 see him for whatever reason. 

A Again, as I said, thats ’ a very hard test to meet. 

i :y 1 No. The answer IS I cant ’ definitely exclude it. I find it 

[ 12 ivery hard to believe, that that occurred because typically the 

1131 President - I didnt ’ Impose on the Presidents time. 

[I41 And unless rt were what I considered an ur ent, a 

! Islvery u 

Y 

ent. matter or an eme 

..9 ‘

ency, and I would pu P the 

[:s]death o the lsraelt pnme mlnls er in that category for 

[17)obvrous reasons because the press was going to be - he 

11 e 1 needed to know, at least my vrew was that he needed to know, 

[ 19) I cant ’ think of an instance rn which I would invade the 

[ 20 1 Presidents privacy unless he had asked me to wme down to 

[21lsee him. 

0 And again, its ’ not - as I understand your 

[::;testimony, it would be a 

~241 have a recollection of it, %’ 

piwl or unusual and ou dont ’

ut you cant ’ exclude r hat there 

[zs)might have been a time when the switchboard, White House 

Page 55 to Page 60 OlCStarr 
1606 

esA Harold Ickes, 815198 xMAxlll/lll 

Page 61 

: swrtchboard. was actually trying to locate the President for 

-;.whatever reason and would have asked your assistance. 

:’ A I cant ’ exclude it. On the other hand, I dont ’

j i: recall the switchboard - I was usual 

7 

the one wllin 

: 5 i swdchboard to find out if I could talk o the 

the 

Presiden 9. 

: 6: I wanted to talk to him, or retumin his call. I cant ’

, if 

--:exclude that and I would also porn -7 out that there were - I 

i 3 ;donY know, I think there are one, two - there must be four 

-‘9’ .- ‘ A Yes. 

:20: Q 

.2 I I mes for the President? $jt. 

The political anafyst who has worked at various 

A Yes, I do. 

Q Do you ever recall an occasion when - being 

it:! informed by anybody while you were at the White House that 

: 2 3 j Dick Morns was trying to reach the President? 

Page 64 

Im ’ going to ask ou before we take our lunch, 

.I i before the grand jury ta r, es its lunch break, Mr. Ickes. if 

: 3 I you could ste outside for just a moment. .4‘ THE WITNESS: Yes. You iust want me to stand 

i 5 j outside 

I51 

'7j 

181 

L91 

(101 

I.. 

.-AI 

ii:;taken.) 

:i41 

::5] 

::6] 

;;71 

;:a] 

Cl91 

!201 

:211 

I-‘21 

:231 

:241 

:251 

the door? 

MR. WISENBERG: 

MR. PAGE: Down tl-!?!?lw$~~~~ay, 

MR. WISENBERG: 

THE WITNESS: Oka 

MR. WISENBERG: ET 

THE WITNESS: 

ut the interior hallway. 

Okay. 

(Whereupon, at 12:46 p.m., a luncheon recess was 

l .*.* 

l 

Page 62 

.. 1 A I dont ’ recall that. My understanding was that 

t i j Dick had the private lines to the President, but that s an 

: 3: understanding only. I dont ’ know that as a fact. 

Q Do you ever recall bein told that there was a 

:~!wll an international call for the Pres ent? An urgent 

; 6 f intemational ’ call by anybody? 

t? 

:I ‘ A I dont ’ recall that. No. 

:ei Q You cant ’ exclude that? 

;91 A 

0 

No. I cant ’ exclude it, I just dont ’ recall it. 

:::j And I take it you wnl exclude being told that 

::: j Dick Morris was t 

: 12: situation. pt yzo. x 

ing to reach the,President in an emergency 

ave no recollectron of It? 

::31 

::4j Q Is that - that no will look weird on the 

: 15: transcript, SO no - 

:16; A Im ’ sorry. 

“7j Q Your answer is no, you cant ’ recall it but you 

i I3 j cant ’ exclude it? 

.T 9’ A No. I cant ’ - I cant ’ recall - in other words, 

i 5 0; your question was did an body notii me that there was an 

: 2: 1 rntemational call from DI d(, ‘ Morris, urgent from the 

: 22: President, and the answer is I have no recollection of that, 

.23: but, to use Mr. Paaes ’ very tough formulation. I cant ’

f I 4 i exclude it. 

_ - 

.-;: .--! Q I want to put together some of the various 

Page 63 

: 1: :first but answers and then comes out from the area of the 

: :r j9:OO door. 

How Ion does the rand jury-need for - . 

THE FO\EPERSO8l: Lunch? 

MR. WISENBERG: - lunch today? 

THE FOREPERSON: One hour. 

MR. WISENBERG: Okay. 

olcstarr 

Page 65 

[ll AFTERNOON SESSION 

r21 (159 om.) 

:31Whereupon, ’ 

[41 HAROLD ICKES 

[ 51 was recalled as a witness and, after havin 

[ 6 1 duly sworn by the Foreoerson of the Gran 8 

been previously 

[ 7 1 and test&d hrrther as follows: 

Jurv. was examined 

. 

LB1 EXAMINATION (RESUMED) 

[91 MR. WISENBERG: Let the record reflect that the 

; iolwitness, Mr. Ickes, has reentered the rand jury room. 

!111 Madam Fore rson do we R ave a quorum? 

!121 THE FOREP&SON: Yes we do. 

i131 MR. WISENBERG: 

114 1 present? 

Are there any unauthorized people 

I151 THE FOREPERSON: No, there are not. 

!i6] MR. WISENBERG: Great. 

!I71 THE FOREPERSON: 

[ 1s 1 that you are still under oath. 

Mr. Ickes, Id ’ like to remind you 

!191 THE WITNESS: I remember. 

[20] THE FOREPERSON: Thank you. 

r211 BY MR. PAGE: 

i221 Q Mr. Ickes, before we broke for lunch, Mr. Wrsenberg 

i 2 3 ]was asking you about some events in April of 1996 and I want 

134 1 to ask you a couple of follow-up questions re ardin that 

[251 Do you keep a calendar of your a t& ~vtttes 3 

Page 66 

III 

121 

; yeit keep a calendar? 

[31 A No, I did not keep a calendar. 

i41 Q Did you keep memos or any other kind of I s or 

[ 5 I 

Ii 

aperwork to remind you about what you were to do or wha 3you 

i6j addone? 

:71 A To the extent that I kept any of those, they would 

L 8 ! either be with my current attorneys or, more likely, have 

[ 9 1 been left with the White House. 

Q What kinds of things would have been left at the 

I li;White House that related to your schedule of actiiities as 

I 12 J Deputy Chief of Staff? 

!I31 A Typically, I would have a daily schedule. It was 

i 14 jon a piece of pa 

Q 

r that I did not keep. 

:151 

A 

Y?u mean p, threw d away? 

it76iOr the next day. But I did not have a - other than that 

Yes. After he end of the day I threw it away. 

[ :s 1 that was all that I recall keepin 

: ~sl.stutT in meetin 

I would keep notes a&j 

! 2 o I those were le w 

needed to keep. Man of 

ouse; some were taken & mthe 

(21 IWhite House. Those that are perbnent to this subpoena and 

iz21manY other subpoenas that Ive ’ had over the wurse of the 

. 

: 2 3 1 last four or five years have been turned over to my 

12 4 I attorneys. 

[251 Q Who prepared your daily schedule for you? 

Page 61 to Page 66 
esA 

1607 

Harold Ickes, 8/5/98 XMAX(lYl2) _______ 

Page 67 

. . . A Typic&y John Sutton. To the extent that I had a 

iidaily ‘ schedule prepared. John Sutton would do it. 

:3: h? 

4 :This IS from Q I* Behrn A” 7 

I want to read some things to you. 

the Oval Oftice, Winnin 

13: in the 90s. ’ ” a book that Dick Morns authore 8 

the Presrdency 

D A 

:,: 

Oh. tha! para on of truthfulness? 

Q At 3, 

ts jand retains data a r 

age 164. e wntes, “President Clinton absorbs 

Incredible speeds with pinpoint accuracy 

Island near total recall. He knows endless facts and perfectly 

: 10 1 encodes the exact advrce he gets from each source, down to 

: 1:; the sli htest nuance. He carnes these detarls in hs brain 

;:zlwhile t? e works throu h a dedsion.” 

i;31 In “The Inside s tory.” a book, the author Robert 

; 14 ~Levin wrote that President Clinton, that he has an amazing 

~:s,memory. And at other times, in other books, others have said 

;~slthat he has an excellent memory, a near1 photographic 

f:,~memory, and there have been other simr .? ar comments in either 

:: 2 1 books or magazines. 

::91 As Deoutv Chief of Staff and one who has known 

i ro i President Clinton foi a bng time, whats ’ your view, your 

:ZI lopinion of President Clintons ’ memory? 

A Well. first of all, I would sa 

ii:jthat Dick Morris says shouM be taken wit f: 

that anything 

a huge barrel 

:14 lof salt since his veracity is open to considerable 

;zslquestion 

Page 68 

BY MR. WlSENBERG: 

Q I take it that means that your reference to him as 

was facetious? 

Q So then YOU miaht even agree with Mr. Morris. 

A Iwouklnbt- - 

Q OristhatPage 69 

., 

, _ MR. WISENBERG: 

:: 1 leaving that area? 

Can I ask something? Are you 

:?‘ MR. PAGE: I was about to. 

:4i MR. WISENBERG: 

: s 1 ask a belated uestion. 

I was going to, before you do that, 

:i: BY 8R. WISENBERG: 

Q You also knew him, I think, looking at your 

il i transcript from Virginia, of course you knew him before he 

: 9! was President. 

::o: A Yes. 

Q And did some campaigning with him, I take it? Wrth 

::I the Presidrt. F~ore he was presrdent. C.1‘ 

I--, 

Q Is it fair to say that in the business of 

ii 4 i campaigning that one of the things you need to try to do if 

; :i! youre ’ successful is to remember people? When ou come up 

r:,land meet them in an event, youve ’ seen them be ? ore, to 

; : 2 1 remember when the last time you saw them was? Is that a fair 

: : 3 1 statement? 1-p; A Many politicians would like to have that facility. 

i: y j Some do, some dont. ’

: ~2 1 at rememberin 

The President has a very good facility 

:231 Q %%% going to be my question. How is he at 

:24lthat part ofAthe ame? 

:151 B retty good. 

Page 87 to Page 72 

Page 70 

MR. WISENBERG: Go ahead 

BY MR. PAGE: <-. 

Q Mr. Ickes, have you ever discussed with a member of 

I: ; the meola your having or your allegedty haven 

9 

seen the 

;5:Presrcent fs a coeopromisrng positron wdh ano her woman? 

IE: 

[I ‘ Q And with whom did ou have that discussion? 

I:: A The first discussion 7 hat I recall was in - I 

t 9: think it was the week that - the latter part of the week 

[ 10; that the - for lack of a. better phrase, the Monica Lewrnsky 

11: : srtuabon became publrc, which I think was on a Wednesday or 

112 1 Thursday, mid week. 

MR. WISENBERG: 

j::jWashington Post sto 

Wednesday, January 21st was the 

1151 THE WITNESS: Okay. 111 ’ take your word for it. 

And my best recollection is that two or - at least 

1:76jone, if not two, reporters from, I think. CBS television 

(1s ~called me to say that the 

~1s jseen - I forget all the de Y. 

had good authority that I had 

alls that they described,, but 

(20 1 the essence of the story was that I had seen the President 

[zlland Ms. Lewinsk in a compromising position, as I recall, 

(zlerther in the Ova r Office or one of the rooms adjacent to the 

tzs]Oval Office and that the 

1241. And I said tha Y 3 

were goin to run with that story, 

I had abso utety no recollection of 

[zs]rt and I was pretty sure that I would remember if I had seen 

Page 71 

[ 11 them in a compromising 

[-jstory. ‘ as far as I know. Q 

osition and they decided to run the 

hat was - 

1?1 BY MR PAGE. 

j-1 -. . . .--. 

!41 Q 

A 

Do you know the names of these reporters? 

I think - Scott Pelley was one and he has - Im ’

I: i terrible with names. He has - Ill ’ think of it in a minute, 

[7 :The other person who was assigned and still is assigned to 

1 s 1 cover the White House for CBS. 

Q So you told one or both of these reporters that you 

[:oi ’ had absolutely no recollection of findjng Monica Lewinsky and 

t 1 I 1 the Presidrt rnytsompromrsrng posrtron? 

Cl21 

Q 

I :: 1 reporters or reporter that that 

Does that mean that at the time that pu told those 

r 

ou couldnt ’ exclude it. 

[I51 A Did I tell them hat I couldnt ’ exclude it? 

Q No does it mean that you used the phrase because 

/:!iyou couMnY exclude it at that time? 

LlBl A I told them that I had absolutely no memory of it 

[ 191 and I was confident it didnt ’ happen. But, you know - I 

(zojthink -thats ’ the best that I can recall that I told them. 

Q All ri 

t:f iexclude that having 

ht. 

3, 

As we sit here now today, can you 

A 

appened? 

Again, as I think Ive ’ said before I cant ’ exclude 

I::ialmost anything. Almost an 

:25 1 absolutety no recollection w x” 

hrng IS possible. j have 

atsoever and Im ’ quite confident 

Page 72 

[ 14 1 srt here toda 

I have already testified to what I have said. As I 

8 

I have absolutely no recollection and Im ’

tlslconfident rt rd not happen. 

Q 

i :7” 1 that you know for a fact that it didnt ’ happen corn&t? 

Thats ’ a little bit different however than saying 

A 

I :“,i and my address and sometimes I even forget that, but Ive ’

I know very few things as a fact. I know my name 

[zo~testified to what Ive ’ testified. 

Q So is this an event your findin 

/ii; Monica Lewinsky in a compromising position, 9 

the President and 

1~71fomatteno 

hat you may have 

--:? ‘ =-------A 

[i:ithat I would have. 

I may have. I think it is unlikely beyond belief 

OlCStan 
s!M 

1608 

Harold Ickes, 815198 

Page 73 

::. BY MR. BENNETT: 

.1. Q 

i 5 j alone in the area o the Oval office? 

Didyou ever see the President and Monica Lewinsky 

A I dont ’ think so Mr. Bennett. When I first met 

I :i her it was dunn the overnment shutdown which as I recall 

r 6 1 wai in late 95. ‘ %rd sle was then worki ;n this room 

:7 1 between were my office was and where r Panettas ’ office was 

; s 1 on a volunta basis and thats ’ where I first met her. thats ’

[ 9! where - and x0 m time to time, the President would come down 

:lo!here. 

As I had described earlier hes ’ sort of 

I :: i peripatetic and sometimes he would’ just show u Dunn the 

i 13 1 government shutdown, he would come down to P atk to ed 3l er me 

K 14 1 or Leon more frequently than before. She was working there. 

[IS! My recollection is thats ’ the only time that I saw them 

[ I 6 1 together, but by being together, there was always a group of 

[ 17 1 us in that room. 

After the government shutdown, 1 think she went 

i: E{ back on Mr. Panettas ’ staff at the OEOB and then at some 

[ 20 1 point I understand she became a permanent - or a staff 

t 2 I 1 member and worked - was assigned to the legislative 

r221department a-no as a result of that worked over in the East 

;23]Wing, thus being the West Win?, worked over In the East Wing, 

~24 !and would see her from trme o time coming - walkrng back 

! 25 1 and forth between East Wing and West Wing, which was not 

Page 74 

I: 1 unusual because much of the islative staff did that. 

I21 Q So if I understan ou have no recollection, 

~3lother than what ouve ’ told, us 

[4 1 President rd My. Nya Lewrnsky alone. 

ever having seen the 

LSI 

161 Q 

A 

And you think you would recall if it did happen? 

I71 Well, I dont ’ know if I would recall or not. I 

t s 1 mean, the President - a lot of people see the President, a 

[ 91 lot of people deal with the President but I have no 

101 recollection of seeing them alone. the only time I have a 

I 1: recollection of seeing to 

111 government shutdown w 9, 

ether is, as I said, during the 

en he was in the Chief of Staffs 

1310fflce. 

14) Q Well, do you recall ever seeing the President alone 

:s 1 and Ms. Lewinsky in the vicinity? Or departing or appearing 

I 6 1 to depart from an area in which the President was alone? 

A No. 

Q You dont ’ recall that? 

A No. 

Q Now, I assume - your previous appearance before 

i:P;today in the grand ju 

12: 1 reported that you ha l? 

you were aware of news accounts that 

1231 is, havin 

perhaps made such an observation, that 

12 4 1 you reca 9 I 

seen the President and Monica Lewinsky alone. Do 

those news accounts? 

1253 A Well, I recall the news accounts and that also 

Page 76 

: : : Do you nnow anything - can you shed an 

-1: fashion on the extent of the Presidents ’ r 

light in any 

: jywith Mcnm Lewinsky? 

re abonship 

:;‘ A The extent of my knowledge about - other t& 

: 5 i what Ive ’ read, and I dont ’ have to tell ou how much has 

: 6: been prnted and spoken about since ly ate Janua 

; - ; often d5cuit to separate what youve ’ read and w at you 

T and its ’

: ? 1 know, but my best recollectron IS that I first met 

: 3 1 Ms. Lemnsky to my knowled 

ovemment shutdown in late 8 

e. first met her during the 

;10: 

it 

5. 

;:I] ovember December. 

I forget what month, 

;:21 She worked in this offi between Mr. Panettas ’

: 13 1 office and m office for the duration of the shutdown, which 

: : 4 J I recall was fy ive days, maybe a week, I fo 

r:slAnd I sew the Presrdent on - more often t 7 

et exactly when. 

an he usually did 

: :E! came down there just because we were short staffed and a lz 

:: 7 1 was 

.!s!with Rr. 

orng on. And that is when I saw him in the same room 

i:9i 

i:O] her alone. 

I do not have any recollection of seein 

I do have a recollectiin of her - ma 

:;I J her, I dont ’ even have a distinct recollection of 

;zlthe ofiice where Be 

1231 74 

Currie and - 

MR. WlSE BERG: Nancy Hemreich? _) THE WITNESS: 

is: i office, as you know, off to the side of that, but its ’ In the 

- Nancy are. Nancy has a separate 

Page 77 

best recollection is that that was some time in 

since she was involved in 

In separating out news accounts - 

[I ‘ A 

Q 

I mean congressional correspondence. 

All M. In separating out news accounts and 

ii j media coverage of 7% IS matter, since mid to late January of 

i:c J this year. Im ’ asking for your own particular recollection. 

::l~Agarn, do you have any recollection of having seen Monica 

c ;z 1 Lewinsk 

!:31told us a io 

alone wrth the President. other than what youve ’

ut? Im ’ not aski about work that she did in the 

: 14 ! correspondence unit when % s was an intern. 

:?jl A Right. 

[i6j Q Im ’ asking about having seen her physically aicoe 

[;:lwith the Pydenn.at any tune. 

[lB! 

[I91 Q And, again - 

[291 A I have no recollection. 

121: Q Do you have any recollection of havin 

[ :z! the immediate vicinity or proximity to the President w ii. 

seen her in 

ale he 

iZ31was alone? 

A No. Other than Mr. Bennett than what Ive ’

/:: jdescribed in this situation. I r&an. obvious/y. photos and 

Page 75 Page 78 

; I 1 relates back, I take it, to the conversation that I testified 

; 2 1 to a few moments ago about a conversation I had with Mr. 

i3! Pelley in the latter part of January of this year. 

Q You made a comment I believe at least I think I 

I l j saw press accounts, although you didnt ’ testify at ‘ that time, 

: 6 lwhen asked about those news accounts, you made some 

; 7 ; statements to the media at the time. Do you recall that? 

;s: A I did make some statements to the media. 

151 Q 

: :o 1 as broad1 

I guess I just want to be sure to ask the question 

7 

as possible to give you the opportun’ 

2 

to answer 

i ; 11 as truthfu ly as possrble or to probe 

r 

our rewlie ion as 

; :I 1 fully as possible. And so again. so can be as clear as I 

:: 3; can be, you know the subject that the grand jury is focusing 

:4!on. ‘

i15] A Mm-hmm. 

1161 Q And that is whether the President - generally what 

c :- j the Presid~Ys;n$tronshrp wrth Ms. Lewinsky was. 

:1s1 

Q And evidence of that. And so I wanted to make sure 

i iz i weve ’ plumbed the depths of your knowled e to the fullest 

: 2 I iextent possible, about what you know abou 8, 

: ~2 1 would enli 

%, 

hten us on that topic. 

anything that 

:231 And so your question is? 

:24j Q My question is, I want to give you every 

:15j opportunity to be as accurate on this as possrble. 

[ 11 stuff that have been shown since then, but m own 

:: !observation. outside of photographs and stu 2. 

personal 

lrke that that 

i 31 have been printed - and Im ’ not even sure I saw her in the 

: 4 I secretanal area outside the Oval Office, but the answer is I 

[ 5 I have no recollectiin. 

I61 Q All right. And the news accounts suggestin that 

1: ! evidence or witnesses have provided evidence 

[s]you would 

suggesting 9 ha! 

: 9 1 immedrate 

have made such an observation in the study area 

2 

off the Oval Office would be categorical false? 

i:t;recall. I have absolutely no recollecbon of 

Mr. Bennett, I can only test2 to what? can 

and I think 

[ 12 1 ns ’ something I wouM remember, but I dont ’ have any 

r:j~rewllecbon of seeing her and the President alone in the 

[ 14 ; Oval Oft%~ or in the study area. 

[is] Q And, again, just to cast the question as broadty as 

[I 6 1 bossjble for purposes of accuraQ do yov reca!l seeing the 

[;: 1, resident alone in that area and s. Lewrnsky rn the 

[: 9 1 immedrate vicinity or departing the immediate vicinity of the 

rlsjPresident7 

[231 A Not other than - no recollection other than a 

[ 2 1 I va ue recollection of her maybe being in the secretarial 

~~2]surewhereotherswereatthetime 9 

olcstarr Page 73 to Page 78 
BSA 

1609 

Harold Ickes, 8/5/98 XMAxIlUl4I 

Page 79 

: .ask the people who claim it. 

All right. A moment ago, Mr. Page was asking you 

had witnessed any encounter in which I 

e President was in a compromising position 

s. Lewinsky or others. Is that correct? 

5: A Yes. 

0 All right. You understood the question to be the 

: i President in a compromising position, not limited to Monica 

.jjLewinsky. -’ 

I _ 

.--. A Yes. I think that was his - ...l Q All right. My question is have you heard or been 

i 11 j told by others that they have made such observations? 

:131 A No. 

.. 4’ 0 And in particular, have 

i 15 I members of the news media that they i 

ou heard from an 

ave discussed w ir 

say, 

h you 

: 6: havin made such observations? That is, that the 

3 r 

saw the 

.: -: Press ent In a compromising position and passed hat 

:: 3: information on to you? 

-:q! A Wait a minute. The “they” in your question refers 

:Izlto? 

.-. . 

.--~ 

_ - 

Q Well, lets ’ say members of the media. 

A That members of the media have seen - .--, 

.--, 0 Yes. 

::41 A 

::51position? 

- Ms. Lewinsky and the President in a compromising 

::I 

1 

:3i 

14: .L. .3: 

.o. .-1 

., ‘

.3] 

I91 

Page 80 

Q No, sir. The - 

A Thats ’ wh Im ’ confused on our question. 

,Q No,, not My s. Lewinsky. The b, resrdent In a 

compromrsAng racrnewrth anyone. 

+ - 

Q When we say “compromisin position,” we 

that phrasz pe;vr we should try and de t? ne rt. 

0 How do you understand, when we say 

using 

: 2: “compromising” - - 

., . A Well, I was going to ask you how youre ’ defining it 

fl j because youre ’ using the term. 

13; Q Well, rn a romantic position - an embrace, a 

: 4 1 sexual position. 

:5i A Well. those are two different things. Sexual and 

Page 82 

: I ; this grand ury. ‘

r,- 

,-. A Okay. So the question is whether I have talked to 

: 3 j anyone who claims that the ve ‘ seen the President and 

r 4 I Ms. Lewinskv - Ms. Lewins 1 ;:j v? 

;;r1 

Q. Any woman. . 

A No, I have not. 

171 Q Youve ’ had no conversations with anyone in which 

c 8 1 thev reported to YOU - 

[91 Aa That they have seen - 

1101 - the fact that they have observed the President 

I 11 I in a comoromisina oosition? 

il2i ’ A I h%e no recollection of it. No. 

Cl31 BY MR. PAGE: 

I141 Q 

[ISI A 

And so you cant ’ exclude it havin 

Well, the answer is no. Ive ’ gone 9 

happened. 

hrough how high 

[16]a bar that IS. but I have absolutely no recollection of 

i 17 1 talking to .anybody who has seen the President In a 

osition as Mr. Bennett defined it. 

~:~;wmprom?k!R. ’ BENNETT: 

Q 

I:: i Monica Lewinsky matter broke late Janua 

Let ma ask you this. Youre ’ aware th,at after the 

122 1 indicated, that there came a time in which t x* ea%%$$s ‘

t 23 1 deposition testimon 

d 

in the Paula Jones matter became 

P 

ublic 

(24 ] in some fashion a Peter Baker of the Washington Pos 

[2s 1 reported the purported contents of that deposition. Do you 

Page 83 

! 1 I recall that? 

I21 A The answer is I recall learnin about the 

[ 31 deposition. I dont ’ recall the exact facts an 8. crrcumstancas 

I 4 1 that youve ’ laid out. 

r5ljoumals. 

I think it was reported in various 

Q 

i ;i what, if anythin 

All right. My vestion is tell the grand jury 

[a 1 be reported by R 

you know a out how that deposition came to 

A 

e Washington Post. 

[91 I have no idea. 

1101 Q 

A 

Were you a source of that disclosure? 

ill, .--. I was not. 

I121 Q 

r 13 1 disclosure? 

Do you know who was a source or the source of that 

[I41 A No. 

Cl51 Q 

A 

Have you ever discussed the matter with anyone? 

[I61 Discussed what matter? 

Q 

I :i i the Washington Post? 

The leak of the Presidents ’ deposition testimony to 

A No. In s 

1::; and I had no idea how ir 

cifrc detail? No. I mean it was there 

t2llit there. 

got there, why it got there: who got 

I221 Q 

A 

Did you,discuss it in eneral detail with anyone? 

i::lare ’ a lot of thin s that have been discussed n general 

rink it s fair to say, %r. Bennett, that there 

tzsldetail. I mean, ve ‘ talked to a lot of people over the last 

Page 81 Page 84 

-, A I et ybur ?ireanii-rg. 

2; Q f&w that is what we intend when we use the term 

- ~“wmoromisina oosiiion.” 

--, r A “Right. 

.-3. Q Does that change any of your testimony? 

-. . . .-II_ A No. 

--;- 

: !i i ago. 

Q All right. Now, back to what we had begun a moment 

Have you ever had a conversation with any witnesses, 

: : - j any individuals, in which they described to you having - 

: 3; their havin 

: : 3; position WI il 

observed the President in a compromising 

another woman? 

_” A Bv “witnesses” YOU mean Deople who have been before 

i 2 1 i this grand ury? ‘ - - l’ 

---I 

:;;I 

& 

A 

Have you had a conversation with anyone - 

Oh, wrth anyone? No. I thought you were using 

: 1:: that in a technical term. 

-c. ‘

.--> Q Well, without regard to whether theyve ’ appeared in 

t 1 I six months about this situation and so the fact that it was 

[2 I there, I assume at some point there was probably general 

t 31 discussion and speculation about how it might have gotten 

I 4 1 there, but as far as I was concerned. it was of little 

t 5 1 moment. 

161 Q Tell us everything you can recall about any such 

[7 1 conversation. whether specific or general. 

[El A It would not be specific. It would be general and 

t 91 it would be in the nature, I think I would put it on the 

I 10 1 level of gossip, if 

I lllget there, do you K 

oure ’ talking to reporters, how did it 

r 12 1 anything about lt. 

now anything about it, and nobody knew 

Q 

i::ithis matterwith sir. 

Tell us everyone you can recall having discussed 

A Well that was a long time a 

I :z i could not discuss in’ any detail - Ive ’ talk ec? 

o, Mr. Bennett. I 

to a lot of 

[ 17 I people and a lot of reporters. I could not tell vou 

iis jspecifrcall under oath who I talked to. 

,191 bY MR. WISENBERG~ .--, 

[201 0 ~~l~have>-few@Zions for you, Mr. Ickes. In your 

tzl~appearance in Virginia, you were asked a question about 

t221dtscussions you had had regarding Ms. Lewinskv. but it was 

t23lfrom late January 98 ‘ when fhe sdndal broke,.&1 want to 

[24lask you about any discussions before that penod in time you 

I 2 5 I had about Monica Lewinsky or about anyone you later learned 

--____ 

Page 79 to Page 84 OlCStarr 
BSA 

1610 

Harold Ickes, 8/S/98 xhlAxflul5) 

Page 85 

: : : to be Monrca Lewinsky. Can you tell us about those? Any 

: 2 : discussionr you had. 

:j; Prior to what time period? 

:;1 Q Prior to late January 98, ‘ because the question in 

rj:Virginia of you was, Ill ’ read it to you. “And who 

: 6: s ecifically have ou talked to at the White House regarding 

:-; t&nica Lewinskyy?” 

IE: “Answer: I have talked - is there a time period 

[ 3 1 on this?” 

“Question: From Janua Generally, I will say 

[?5;Building where had been told she was working when she was 

Page 88 

: 1. remember any other details of the Presidents ’ denial on that 

: r : Monday? 

.-, A 

zlgrand ‘ ju$, 

I dont. ’ As I think I testified in that particular 

.slwrth the 

that I did not have a lawyer-client ralabonship 

resident. didnt ’ want one. He had enouah lawvers 

’ 6 i around him without adding one more. And that h< denied to me 

f-j that he had had a sexual relationship. I dont ’ know the 

: s 1 exact phrase. but the word “sexual” was there. And he denied 

: 9: an 

: : ? z de Lobstructton of jushce. And that was the extent of the 11s. I did not have a lawyer-client and didnt ’ - he 

: :; Ididnt ’ go into details and I didnt ’ ask him details. 

I ‘ 1 ‘ Q 

i ij]you for wh 

Did President Clinton ever give any explanation to 

! 14 1 understan J 

Monica Lewinsky had visited hrrn so often? And I 

that that question contains a predicate that you 

; 15 1 might not know if its ’ true or not and that IS that she 

::61visRed him often, but nevertheless thats ’ the question. Did 

: : 7 1 he ever give you any explanation for why Monica Lewinsky had 

: I 9 1 visited hrm or had vrsited the White House so often? 

I191 A He didnt. ’ I dont ’ think that I knew at that 

: 2 o 1 bme - Ive ’ come to team since from news reports that she 

i~llallegedly was in the White House on numerous occasions. 

rz2lWhether she was actually in the White House and who she was 

:?3;seeing in the White House, I have no idea. But the answer, 

:24 lthe short answer, is that the President did not. 

;251 0 At any time, correct? 

Page 86 

i: 1 on Mr. Panettas ’ staff. And I dont ’ recall having any 

~2 Idiscussions about her. I was not dealing with personnel. I 

I 3 1 had a huge number of - a very large number of things that I 

14 lwas concerned about, including the Presidents reelection. 

I51 Q Im ’ not suggesting that It would have been normal 

i 6 I for vou to have a discussion. 

i?j * A Right. 

Iii 

0 Thus wasnt ’ asked before and - 

A No, I understand. 

Q And your answer is you dont ’ recall having any 

i 1 ii discussion about hei. 

I dont ’ recall having any discussion about MO 

She was one of hundreds of interns that work in 

6 ‘ Ai; at 21 and 22, Ill ’ read a portion of the 

nica 

Page 89 

A No. 

.-1 

!61 He did not. 

i71 Q 

I B 1 territory but I fi 

You also mentioned, and this is in the Linda Tripp 

ure 

19 1 Alexandria so II as 

A 

a IT 

oud ’ rather not go back to 

rt to you here - 

!iO] 

::I] Q 

No, no. I want to go back to Alexandria. 

Okay. At one point, you mentioned that you didnt ’

I :z 1 look at Linda Tripps ’ personnel file or know who did while 

I :j 1 ou and she worked at the White House. And my onl 

: : 4 1 Ll r you IS did you look at her personnel file or do you IT 

question 

now 

: I 5 1 who did at any time that you did work at the White House? 

A No. All I know about Linda Tripps ’ personnel file 

1;;; is what Ive ’ read in the ress. 

f!id you ever recommend - you testified in 

recommend firing Linda Tripp after 

ever at any time prior to January 21, 

i22] A 

anybody fire Linda Tripp? 

No. I have no recollection and I am confident that 

:z3ll didnt. ’ I hard1 knew who Linda Tripp was. 

Q $0, said in Vi inia in answer to a uestion that 

If:iyou very rarely talk to lawyers “$ or wrtnesses and w I at I 

Page 87 Page 90 

[I! want to ask you is what lawyers for witnesses in any as 

; 2 ; of the Lewinsky matter, that would certainly include Lin cr 

U 

a 

: 3 1 Tripp. what la ers for witnesses have you talked to? 

:41 A 

:5! Q 

you have a time period on that? 

[6l.bnUa~ 1, 

At an time from - lets ’ say any time from 

1998 unto 7 

A 

the present. 

I think the onl 

iii witnesses - first of all I don’ 7 

lawyer that Ive ’ talked to for 

even know who the la 

: 9 1 are, but I think the only lawyer other than my own tha “r 

ers 

Ive ’

: IO Italked to are David Kendall and if youre ’ using witness in a 

[ 11 I technical sense, he wouldnt ’ even wme withrn that, and Stan 

: 12 1 Brand. And Im ’ not even sure that Stan Brand wmes within 

; 13 1 that, if youre ’ using witness in the technical sense. 

:141 0 I am using witness in the sensa of somebody who - 

: 15 1 using it in the sense of someone who you think has either 

: 16 1 been to the grand ju 

: -3 1 about any aspect of x t

or who has talked to investigators 

e 

A 

Lewinsky matter. 

“81 Well, I know Stan Brand as a - for many, many 

i : 91 years and Ive ’ talked to him on occasion, but I couldnt ’ tell 

I 2 s I ou whether his client has either been interviewed for or 

12: 1 r. esbtied in connection with this grand ju . 

i221 

i23j 

Q And who is it vau unders 7 and hs .’ ckent to be? 

A George Stephano oulos. 

;241 Q Okay. Have you P alked to him about an hrng 

: 2 5 I about - what have you talked to him about with respe CT to 

page 85 to rage 90 
BSA 

1611 

Harold Ickes. 815198 XMAX(lbl6) ’

Dana ai . “3” ” I 

::.Mr. Step-anopoulos and the Lewrnsky matter? _^: A I havent ’ talked to him at all about 

1 i: Mr. Stepanopoulos ’ and the Lewrnsky matter. I called 

: 4 : hrm rece-r:y to find out whether rt was possible to get some 

: 5; of my lega:.fees paid. 

16: Q And what about David Kendall? Whats ’ been the 

: - : nature of your discussions wdh David Kendall with respect to 

[ 3: the Lewrrsxy matter? 

19: A My discussions with him, I call David from time to 

: ; o; time just to see how things are goin 

i :I !conversa+,Ion. Nothina comes from ii 

It is a one-way 

avtd. i:zj Q Youre-the ’ one way, in other words. 

::31 A Yes. 

0 Youre ’ the one imparting information, rather than 

1:: j Mr. Kendall. Is that correct? 

i16j A David doesnt ’ im art information. 

,771 Q Oka!. You test& in Virginia that you had had 

ii 8 i conversahons with he Ftrst Lady, but tha you had discussed 

[ I 9; no detaik with her regarding the Lewinsky matter. And Ill ’

rzojread you a portion of your testimony. 

iii!testifred earlier 

“I dont ’ talk to her that much and,. as I have 

!l;;in, how is she. 9. I s more of a ch 

prcalty l m callxhar Jtu;t$ chea$ _ 

: 24 1 there is frustration evidenced by her and by the President 

;:slabout what is going on, as you might imagrne, but I dont ’

Page 92 

: 11 recall discussing discussing any particular particular details details with the First Lad 

;2 ~about this other than ust the 9eneral 9eneral 

;:;going. ;:;going, what it is it looked like.. 

atmosphere, how X 

!sj f51 

You;tanlddty stand bv that testimonv? tesbmony? 

A Ido: 

i61 ISI Q Since the time of your Alexandria Alexandria appearance, appearance, has 

~7 lshe discussed discussed details details of the Lewrnskv Lewrnskv matter with vou? 

iBI A I dont ’ think - Im ’ trying to recollect: I dont ’

[ 9 1 think that Ive ’ talked to the First Lady since then, unless 

: : o 1 this going away part that I think I testified to in that 

: ;:lgrand jury occurred - but if I testified to it in the rand 

:L21rY* 

then it didnt ’ occur afterwards. I dont ’ think 9, ve 

: 13 1 al ed to her since that grand jury. 

Q But if you did, you havent ’ discussed any details 

iiliof the Lewinsk matter? 

A Well when 

7 

ou say “details ” I dont ’ know what you 

ii76jmean by that. If I did wou d I have discussed 

'i8 ;this on 

119ldetails. 4 

oing situation:! Undoubtedly. Would I 8 

enerally 

ave discussed 

I srncerely doubt it and the fact is I dont ’ think 

1201 Ive ’ talked to her stnce then. 

Q Let me ask a more global question about your 

ii: jdiscussions with the First Lady at any time since January 1 

:2311998, which is has she ever 

:2 4 ; talked about the Presidents ’ % 

rven you an explanation -we’ 

enrals. 

-2c.1 _--, A Right. 

Page 93 

. Q Has she ever given you an explanation for the 

i A i Lewinsky matter? 

:3: A No. 

:4: Q 

: 5: allegations? 

Has she ever denied, generally or specifically, the 

:e: A Ive ’ never asked her and shes ’ never - 

:I ‘ 0 So ou just havent ’ discussed that with her at all. 

:3: A Rik; 

:9: 0 Ol!ay. Did you ever tell anyone at any time to look 

: :o 1 at the personnel files of Linda Tripp? 

-1: ‘ A No. Not - I have no recollection of it. Im ’

1 i2 Iquite confident I didnt. ’ I didnt ’ - you know, Linda Tri 

: :2;was in the White House when I first got there, she le fP 

p 

and I 

: 14 1 never thou ht about her again. 

iI:jfrles? 

a Have you ever received any information from such 

I171 A 

0 I ve got some ues ions. some of which are from the 

iizjgrand jurors. When you woul 

Not to my kn;;?e. 

:zolearlier today that when you wou 

ou testified I believe, 

be at the White House on 

: 2 I I the weekends that I b&eve typically there were people - 

;22 jthere were some people there in thn area thats ’ marked 

; 2 3 1 reception area 1. 

:241 A Yes. I-c. .-il Q Who would typically be there on a weekend? 

Page 94 

I.. A 

iiabout ’ rece 

Wait a minute. Let me just - are you talking 

tion area 1 or waiting area l? 

:j' 

ii. 

a 

A 

I meant to say receptron area, but let me ust ‘ - 

:5:where you are. 

Oh, I see what youre ’ saying. Im ’ sorry. I see 

!6: Q 

iT:area? 

Who would you typically see on a weekend in that 

IBi A If there were people there, it would be - 

rs:typically, It would,be the people who worked there on a 

rlo!regular basis, which wou d include Betty Cume. rf the 

1111 President were there, sometimes his personal aide would be 

[ 12lthere and Nancy Hemreich. 

[13!it would - 

If the President werent ’ there, 

sometimes Betty and Nancy were there together, 

[~cl;sometimes only one of them was there. 

[15i Q All right. Not a different crew. 

[I61 A No, no. lt was - 

117: Q That would typically be there. 

118: A Typicall 

[ 181 basically their persona 7 

. it was the same crew. I mean, this was 

offices. 

(201 Q And you wouldnt ’ always see them there. 

[21; A No. 

[ZZI Q Just sometimes. Is that correct? 

[231 A Just sometimes. 

Q Do you recall ever having a conversation with a 

I::iSecret Service either uniformed or plainclothes agent about 

Page 95 

[ 11 the President not answering the phone? 

[Zl A 

Q 

I have no recollection of that. No. 

i:jin and hes ’ not ickm up. 

Not picking up. In other words, someones ’ calling 

A f?o. T!e -the service knew - the service 

/zimonitors him like a tick oF:b”,. 

171 Q Do you recall having such a conversation with 

[ 8 Ian one, not just Secret Service. about the President is not 

[9;p1 & rng up, is not answenn the phone? 

I101 A Idont ’ recal. ? No. 

Ill? 0 Do you know who Jennifer Palmieri is? 

[I:’ 

I13j 

A I do. 

Q I might be mispronouncing her name. 

[I41 A 

0 

No, no. Youre ’ right on target. 

j:zils that correct? 

She worked, at least at one time, for Leon Panetta. 

[I71 A She did. She worked for Leon throughout the 

[ 1 B I duration - to m 

[lsltenure as Chic ? 

knowfedge. throughout the duration of his 

of Staff. 

[ZOI Q Do you recall that durin the time of this furlough 

[ 2 1 J that youve ’ discussed where ou saw 

1221of the Chief of Staffs office, ;I 

8s. Lewinsky in the area 

o you recall that there was 

[23 1 a birthday celebration of any kind for Ms. Palmieri during 

[zclthat penod? 

[251 A Was there a birthday celebration for Jennifer 

Page 96 

[ 11 Palmieri? 

Q 

I:;together and had cake. 

During that period where people had cake, got 

A 

Izjbirthday, so I 

They had a lot - they celebrated everybodys ’

- rt may well be. tf she had a birthda 

[ 6 lwas probably celebrated. They believed in a lot of 

it 

17 1 celebrabons over there. 

t rrthday 

[RI Q 

[iii 

Im ’ afarty kind of guy, too. 

A What. 

Q 

A Oh. &ell. Im ’ not so L 

Im ’ a arty kind of guy too. 

1111 

Q The uestion is db you s 

i::iprty for Jennifer Pa 7--. mrefl dunng the fur P ough, the budget 

ecifrcally recall a 

[141crlSIS? 

I151 A I dont. ’ tt may well have happened, but I was not 

[16]an observer of birthday parties. 

i:llsaw Ms. 

Q During the time that you have discussed where you 

Lewinsk 

[ 19! office, during the 

in the area around the Chief of Staffs 

Yll rfqugh period, during that time, did you 

[2o]ever go to the Hill as lust part of the negotiations going 

rzllon? 

[221 A 

;;:;furlough 

0, 

During what - Im ’ sorry, during what period? 

During this period that youve ’ Indicated was a 

r 

nod where you saw Ms. Lewinsky in the area of the 

[251Chief of taffs office. 

-__ 

Page 91 to Page 96 0lcstafT 
esA 

1612 

Harold Ickes, 815198 

-~-- 

XMAX(lnlr, 

.-~-~ 

Page 97 

- A Right. .^. Q 

-s:fiveday period. 

During that - I think you mentioned it was a 

Dunn that period, did ou ever - 

:;: A Well, w % atever it was. T !A 

Q 

ats ’ my recollection. 

Did vou ever have occasion to go UD to Caotiol Hill 

<iduring ‘ that period?- 

- 

A I may have. Leon - Im ’ ju@ trying to think who 

i 5 j was the head of legislative then. 

: j:or John Hilley. 

It was either .Pat Griffin 

::: : as head of le 

I think it was Pat Griffin \?ras sbll there 

islative. Leon - Leon basically and whoever 

: :: ; was head of 8. egislative, whether it was Griffin or Hille 

! 141 basically did the Hill work. I may have accompanied r* hem on 

: 13 lone or two occasions. I dont ’ recall and I sort of doubt it. 

0 Okay. So you dont ’ recall it, you doubt it, but 

i il i ou might have been up on the Hill during that period. 

::.-j!hat correct? 

Is 

..-. A 

i : 5 i recollection. 

Yes, I might have. I just dont ’ have any 

i‘ 3, MR. WISENBERG: Let the record reflect that Matv 

is 3 j Anne Wirth of our office has entered the grand jury room. 

BY MR. WISENBERG: 

Have you ever - do 

Page 100 

,-. Q I cant ’ reference it to any particular event, but 

iithe ’ Presmnt - once Ms. Lewinsky started working - and I 

:?: dont ’ know the exact - I dont ’ even know the general date - 

: 4 : over in the East Win 

r? 

I recall seeln 

9 

her from time to time 

:5! walking back and fo h from the Eas Wing to the West Wing 

: 6; and in oroar to do that you walk through what I called the 

: 7 ;ground flwr or the lowest floor of the residence. 

:j. That - in traveling from east to west or west to 

isjeast. she would travel throu 

::s]would go down this colonna % 

h that - first of al!. she 

e where the President walked when 

: 1:; he was 

! 12 Iwalk in 9, 

orng back and forth to the residence to - she would 

hallway, in the residence. which passes right by 

[ : 3 1 the private elevator that goes upstairs to what most people 

: i 4 1 call the state floor, most people adually call it the first 

:: 5 1 floor, but the state floor. and then on up to the second 

: :6lnOOr or the residence. 

..Tj So the answer is to that very broad 

1 Is 1 and that would be one the 

[lg]seen her where the 

;~olbeorcouldbe. 

Q All ri 

I;i; confine it to the Ova 9 office the stud 

ht. Let me confine it to rooms and let me 

::3jthe haltway leading from thi Oval 

the dinin room 

Of&e to the &ing rbom. 

::4jAnd Ill ’ also add the reception area of Betty Currie and 

:zj!Nancy Hemreich. And, again, excluding what youve ’ already 

Page 98 

. . Q Do you remember pizza at all being eaten during 

is i that five-day or whatever day period it was that we re 

;;:talking about. the furlough period where ypu saw, 

; f ! Ms. Lewmsky? Do you ever remember puma being delivered 

. 3: and/or eaten by people? 

A It may well have been. From time to time, when 

! ii Elmieri or sornebo!y el$e in the Chief of Staffsdgtir 

ople were workin late Jennifer would order 

~91would order in food and rf there was enough around, qther 

: ::: people would join in eating it. It wouldnt ’ surpnse me d 

: I: 1 L happened. 

;::; Q You dont ’ remember it, though? 

.jj ‘

,- A No. 

i it i veracity? 

Q 

I dont ’ have a specific memo 

What is her reputation, if you u now, for truth and 

Jennifer Palmieri. 

!i: A I can only tell you what my experience has been, 

; 1-i that she is truthful and I was going to say voracious, is 

:: 3 : known for veracity. 

::3: Q Im ’ going to ask you some questions that might - 

: 2 3; Ill ’ go through them as quickly as I can. The 

::: ; someyhat with some that Mr. Bennett aske 2 

might overlap 

::: jue$on 1s did p, - I 

And my first 

uess youve ’ already talked about - 

::3: ou ve already alked a out seein 

% a _ you think you might 

:: ; : ave seen Ms. Lewinsky in recep ion area 1 in he area of 

:I: : spring 98 ‘ and that you saw her, you think, during the 

Page 101 

:: jtalked about, March 96, ‘ did ou ever see her enter one of 

r:jthose areas and where the 3 

.3! been or was about to be in? 

resident you thought was, had just 

i41 

:51 

; E;;;;yan what Ive ’ testified to? 

i61 A No. I have no recollection of seeing her. 

!71 Q And same question for him. Did you ever see him 

[sjenter one of those rooms where you thought she was, had been 

:Ei]or was about to be? 

i101 A No. I have absolutely no recollection of that. 

[:;I 0 And then did you ever see her leave a room, other 

[ 12 1 than what youve ’ specifically testified to, which are 

I :3 1 basicall 

dy 

innocuous - 

: : 4 ; testifie about, 

at least - innocuous cases youve ’

did you ever see her leave a room where the 

::slPresident had been, where the President was to your 

1161 knowledge. or had been or was about to be in? 

!:7] A Same answer. 

0 Okay. And did you ever - reversing it see him 

i :!?+i leave a room where she had been - where she was, had been or 

i2olwas about to be in? 

!21] A Other than what Ive ’ testified to? 

[22] Q Okay. Yes. I understand. 

[23] 

I;;; 

$ kpitvas a question from me to you. 

A Other than what Ive ’ testified to? 

Page 99 

: : :furlou h period but in the room with other people. Is that 

:::wrre 3 ? 

15: A Yes. 

::‘ Q Did ou ever see Ms. Lewinsky and the President 

: 5 j either in the Oval ok ice stud that ouve ’ identified the 

: 6 :Oval Office dinin room 

% 

the & val &ice itself or this 

-. little hallway that ads from the Oval Office to the dining 

i E j room? Have you ever seen them, with or without other people 

: :-: present, in any of those areas? 

. . -. A I have no recollection of it. You know, I cant ’

i :: i rule it out as an absolute! but I have no recollection of 

: :::seeing her in the oval or In other places other than, as I 

::::said - 

:1;: Q What youve ’ testified to. 

.--. A Yes. 

Q Did you ever see her enter a room or area where the 

i if’ President had been, was or was about to be? Other than what 

; ;; i youve ’ testified to so far. 

. . . A Thats ’ a retty broad question. ,^^. Q Okay. 8 ther than what youve ’ testified to so far, 

ii: i did you ever see her enter a room where the President was, 

; zz :just had been or ou thought was about to be in? 

.-:’ L--. A W& the answer to a very broad question is yes. 

,- ,. .-*. Q All right. ,^_. 

_--_ A And can you reference that to any particular event? 

Page 102 

11: Q Right. Correct. 

;:I A No, I have no recollection. 

[31 Q 

f4lherinagroupof 

what youve ’ testified to was you saw 

where the President mi ht have been 

[ 5 1 during the budge period and you thm 3 you might 

[ 6 1 have seen her in the spring of 98 ‘ in reception area number 

[711. Isthatcorrect? 

LB! A Yes. But I want to make clear, so theres ’ no 

: 91 misunderstanding, during the budget shutdown, she was working 

[ : o 1 there on a fairly consistent basis, on a consistent basis, 

[ 11 lquite Ion 

[121pernltt d 

hours because much of the regular staff was not 

to work, and the President was down in that area on 

: 13 1 several occasions. how many, I dont ’ know, but several 

il4]OCCXiO~. 

Q 

I iz 1 budget pen& 

So it might have been more than once during this 

!171 A 

! : 8 I several times. 

Yes. My recollection is that he was down there 

:191 0 All right. But as far as you know,, theres ’ never 

i -3 1 an occasion that you recall where, for instance, in a 

[ 2 11 p+icular room that you - you ever saw durin 

[zz 1 cns~s, as an example, Monica going into the s 9 

that budget 

iZ3lthought the President might be there. 

udy where you 

[241 A No. I never - I have no recollection of that. 

~251 Q Or the dining room where the President you thougti 

OlCStarr Page 97 to Page 102 
asA 

- 

1613 

Harold Ickes, 815198 Xy*x(lUlI) 

: 1 might be there. 

Page 103 

A No. 

Q Or the Oval Office 

Page 106 

A Not that I know of. 

Q 

-i your memorv? 

Okay. Youre ’ not under any medication that affects 

A No. 

I I 9 I the oress accounts - .--, . 

[ZOI ; Imwithyou. ’ No, noI::;reminds me - 

- somebody could have said, Oh ‘ my gosh, this 

” 

[231 A 

Q 

No, no. Youre ’ ri ht. Right. 

So anything, first % and, secondhand, ei 

I::iabout any kind of a relationship between - any kind 

hteenth-hand 

o 9 

Page 104 

I I I romantic. untoward. sexual relationshio between Monica and 

is j the President? 

131 A No. Other than what Ive ’ read in the press. 

(41 Q Excluding that. 

151 A Yes. 

Q Okay. Youve ’ never heard anything about them 

I;iflirting or being together with each other correct? 

iR1 A Riaht. I mean. aaain. other than what I read in 

;s;the press. - 

.., 

Q Im ’ excluding the press. Did ou ever see or did 

i iylyou hear anything or were you ever told an y&ins, again, it 

r;zlcan be triple hearsay, it can be quadruple heana 

[ I 3 1 time, that led you thank - a 

2. 

ain, were ’ excludrng t xv 

at any 

e 

[ 14 1 press - th.at led you to thrn 

;;;;relatronshX betwg.en them? 

there may have been a 

(171 MR. WtSENBERG: I believe Ive ’ asked all the grand 

~18Ijurors’ questions. 

Cl91 Are there an further? Should we excuse - 

[?Ol THE FOREARSON: Yes. 

MR. WISENBERG: 

i;: i but I will ask 

I think were ’ near the very end, 

ou to ste outside for just a minute. 

:231 

1241 

&~~~~~&G:ok~t the record reflect the witness 

rtness excused. Witness recalled.) 

!25] 

Page 105 

:I: has reentered the 

:?I 

[3j 

;4! MR. WISENBERG: Anv unauthorized oeoole oresent in 

i 5 j the room? 

. . . 

[61 THE FOREPERSON: There are none. 

!7: Mr. Ickes. it is my responsibility to remind you 

) 8 j that you are still under oath. 

[91 THE WITNES: 

(101 BY MR. WtSE 

Ii 1, Q Mr. lckes 

“,:,,g 

~, a few more questions from the grand 

1;; { urors. ‘ Did-you ask Mr. - I think its ’ Pelle 

[ 131 ialked to him, when he called you about t t 

when you 

IS story about you 

1 I 4 1 having witnessed the President in a compromising position, 

i i 5 1 did you ask him who his sources were? 

A Ive ’ been dealin 

/ :7”! I know better than to do that. dl 

with the press for many years. 

e answer is no. I never 

i I 8 j asked him who their sources were. 

0 Oka 

[iilwho talked to you a rl 

And the other reporter, any other reporters 

out this story your answer is the same? 

[ 2 11 You didnt ’ ask them their sources? 

[22; A Thats ’ correct. I did not. 

0 Is there an medical, ph 

ii :i kind that you have that a 4 rl 

sical condition of any 

ects - other t an age, which 

f 2 5 1 affects us all. that atTeds your memory in any way? 

Page 103 to Page 108 

A- Not that I know of. No. 

-T Q Okay. When you worked at the White House, was 

; there an appearance that you and/or others worried about? 

I. ‘ And I mean that in this sense. that because of all the 

i : -stories goin 

:-were circula 9 

back at least to the 92 ‘ campaign that 

ed about the President and women such 

.’ ’ .Gennifer Flowers were you all extra speaal careful to 

as 

_-- 

: 1: : try to avoid situations where it might appear he was 

::z:rn - ou know, in a location with anybody where people 

: 1: cou d make comments? 

:I?- A I think thats ’ a fair statement. Yes. 

..:. Q Okay. This is one of the things you all tried 

: :i to ‘ - one of the thin s that concerned lets say, upper 

: :- -management in the%hite House and$ou tried to avoid 

: : 5 sduatrons where the President was p tn such situations 

.. - .- - -where people could comment. Is that a fair statement? .^_. 

_--. A Yes. Given - 

d 

ou 

.-. 

_-- 

-F 

rimary campaign in 1992 an 

know, ?,@en the campaign, the 

the allega ions about Gennrfer 

::I : lowers and others, the answer is yes. 

--1- Q Did you hear anythrn 

i-i -transferred from the White House to ? 

when Monica Lewinsky got 

:IZ hear anything about that at the time? 

he Pentagon, did you 

Page 107 

. A I dont ’ recall hearin anything about it. I 

!: .dont ’ even know when it happene 8 , other than from what I 

: I -read in the 

:i:bansferred. 

press, but I did not even know she had been 

__. 

.-. Q Did you ever hear her referred to as somebody who 

: E was a c.fut;h or;ostalker prior to the scandal breaking? 

.-. 

:;: Q On many of the questions 

1 i: ou said that you have no recollection. b 

ouve ’ been asked today 

: I I - ra 

UT on some of the 

st questions I was asking you before we broke, we ust ‘

: 1: broke ‘ $ atticularly ones having to do with locations w il ere 

; :z : you d 

: II -about a 

or didnt ’ see Monica and the President and questions 

relationshi 

Y 

and flirting, you were more forceful. 

: : : -We got nos rather han that you didnt ’ recollect. Is there 

: ~5: any reason for that? Do you have a stronger memory on these 

: ; E : hst questions I asked you? 

y.-. 

iIsf 

A No. 

0 You just chose to answer with slightly different - 

: : 5: with different verbiage? .^^. A Well, I dont ’ know. I think Id ’ have to go back 

1:: iand read the record, but I think virtually all of my answers 

:X :are consistent, which is I dont ’ have a recollection. 

r-:- 

,-- Q Okay. You understand, of course, that if you do 

;:: : have a recollection of something but sa 

:ZI : remember, you know that you cant ’ do ill 

that you dont ’

at and that that can 

Page 108 

r : -be penurv. too, if ls ’ a material auestion? :-- _ 

.-. -A Right. 

.-.- 

.-. Q You understand that? 

i4: A Yes, Ido. .i. 

,-. MR. WISENBERG: 

: c : 

87 

oure ’ trying to do an 

r 

And Im ’ not trying to imply that 

at you understand t 

hrng weasely. Im ’ ust ‘ making sure 

:-: at because a lot o I 

.3 been framed in terms of non-recollection. 

your answers have 

:.: i z Again, let me remind YOU - 

i::- 

r,.: i*-. I.-. 

-- 

Are there an other irestions of the witness? 

THE FOREJERSOJ: No there arent. ’

MR. WISENBERG: Let I& remind vou with resoect to 

i: 3 : your notes that our understanding of the case law of this ’ 

: 14 : arcurt is that we are entitled to those notes if we desire 

: : 5 : to have. them, that theyre ’ subject to being subpoenaed, and 

: : 5: youve ’ indicated prevrously that you understand that and I 

; : - : will srmpfy remind you not to do anything to in any way 

; : 5 compromise the documentary integrity of those notes. 

: : 3: understand? 

Do you 

i-f: - THE WITNESS: Yes. 

1;:. MR. WISENBERG: All riaht. If there are no more 

~L^I :questions ma the witness be excus&? 

ci3: THE!FOREPERSON: ‘ Yes he may. 

iT4: MR. WISENBERG: Thankyou ’ very much. 

Itf: THE WITNESS: Thank you. 

-~ 

OlCStarr 
1614 

Harold Ickes, 815198 

Page 109 

THE FOREPERSON: 

of testimony 

ury was 

[ls: 

[19; 

[201 

[?li 

[22! 

[231 

L.241 

[:5: 

XMAxmlY) 

6lCStarr P-9 to Page 109