207.254.7.125 writes:
http://www.house.gov/reform/neg/reports/whodb/depositions/arnold.html
Archived:
http://web.archive.org/web/20010116182000/http://www.house.gov/reform/neg/reports/whodb/depositions/arnold.html
RPTS COCHRAN
DCMN KRISTOFFERSEN
EXECUTIVE SESSION
COMMITTEE ON GOVERNMENT REFORM AND OVERSIGHT
U.S. HOUSE OF REPRESENTATIVES
WASHINGTON, D.C.
DEPOSITION OF: TRUMAN ARNOLD
Friday, July 18, 1997
Washington, D.C.
The deposition in the above matter was held in Room 2203, Rayburn House Office Building, commencing at 10:10 a.m.
Appearances:
Staff Present for the Government Reform and Oversight Committee: Barbara Comstock, Chief Investigative Counsel; J. Keith Ausbrook, Senior Counsel; Jay Apperson, Special Counsel; Jennifer Swartz, Majority staff; Kenneth Ballen, Minority Chief Investigative Counsel; Matthew H. Joseph, Minority Counsel; Kristin Amerling, Minority Counsel.
For MR. ARNOLD:
RICHARD BEN-VENISTE, ESQ.
Weil, Gotshal & Manges, LLP
1615 L Street, N.W., Suite 700
Washington, D.C. 20036
HOLLY LOISEAU, ESQ.
Weil, Gotshal & Manges, LLP
1615 L Street, N.W., Suite 700
Washington, D.C. 20036
DAMON YOUNG, ESQ.
Young & Pickett
P.O. Box 1897
Texarkana, Texas 75504
Also present: Representative Turner.
Ms. Comstock. Good morning. We will go on the record here for the deposition of Truman Arnold. On behalf of the members of the Committee on Government Reform and Oversight, I appreciate and thank you for appearing here today.
This proceeding is known as a deposition. The person transcribing this proceeding is a House reporter and notary public. I will now request that the reporter place you under oath.
THEREUPON,
TRUMAN ARNOLD,
a witness, was called for examination by Counsel, and after having been first duly sworn, was examined and testified as follows:
Ms. Comstock. I would like to note for the record those who are present at the beginning of this deposition. I am Barbara Comstock, the designated Majority counsel for the committee. I am accompanied today by Jennifer Swartz, who is also with the Majority staff. Ken Ballen is the designated Minority counsel for the committee, and he is accompanied by --
Mr. Ballen. Matthew Joseph.
Ms. Comstock. And other Minority staff present.
The deponent is represented by Damon Young and Richard Ben-Veniste, who is also accompanied by Holly Loiseau. And Congressman Jim Turner is also present here this morning.
Although this proceeding is being held in a somewhat informal atmosphere, because you have been placed under oath, your testimony here today has the same force and effect as if you were testifying before the committee.
If I ask you about conversations you have had in the past and you are unable to recall the exact words used in the conversation, you may state that you are unable to recall those exact words, and then you may give me the gist of the substance of any such conversation to the best of your recollection.
If you recall only part of a conversation or only part of an event, please give me your best recollection of those events and parts of conversations that you recall.
If I ask you whether you have any information about a particular subject and you have overheard other persons conversing with each other regarding it or have seen correspondence or documentation regarding it, please tell me that you do have such information and indicate the source, either a conversation or documentation or otherwise, from which you have derived such knowledge.
Before we begin the questioning, I would like to give you some background this morning about the investigation and your appearance here. Pursuant to its authority under House Rules X and XI of the House of Representatives, the committee is engaged in a review of possible political fund-raising improprieties, possible violations of law, and related matters under the committee's jurisdiction.
Pages 2 through 4 of House Report 105-139 summarize the investigation as of June 19, 1997, and encompass any new matters which arise either directly or indirectly in the course of the investigation. Also, pages 4 through 11 of the report explain the background of the investigation. All questions related either directly or indirectly to these issues or questions which have a tendency to make the existence of any pertinent fact more or less probable than it would be without the evidence are proper.
The committee has been granted specific authorization to conduct this deposition pursuant to House Resolution 167, which passed the full House on June 20, 1997. Committee Rule XX outlines the ground rules for the deposition.
Majority and Minority counsel will ask you questions regarding the subject matter of the investigation. Minority counsel will ask questions after Majority counsel has finished, and then questioning will continue in rounds.
Members of Congress who wish to ask questions will be afforded immediate opportunity to ask their questions at any time. When they are finished, committee counsel will then resume questioning.
Pursuant to the committee's rules, you are allowed to have an attorney present to advise you of your rights. Any objection raised during the course of the deposition shall be stated for the record.
If the witness is instructed not to answer a question or otherwise refuses to answer a question, Majority and Minority counsel will confer to determine whether the objection is proper. If Majority and Minority counsel agree that a question is proper, the witness will be asked to answer a question. If an objection is not withdrawn, the chairman or a Member designated by the chairman may decide whether the objection is proper.
This deposition is considered as taken in executive session of the committee, which means it may not be made public without the consent of the committee, pursuant to clause 2(k)(7) of House Rule XI. You are asked to abide by the rules of the House and not discuss this with anyone, other than your attorney, about this deposition and the issues and questions raised during this proceeding.
Finally, no later than 5 days after your testimony is transcribed and you have been notified that your transcript is available, you may submit suggested changes to the chairman. The transcript will be available for your review or your counsel's review at the committee office. If you need other arrangements, we can make those accordingly.
Mr. Young. I think we discussed that. It was my understanding we would make other arrangements.
Mr. Ben-Veniste. I understand you are willing to send us the transcript, since Mr. Arnold does not live in this area, so that he will not have to come here to review it.
Ms. Comstock. Right. The way we do that, since it is in executive session, we ask that you review it and sign an affidavit that you send it back without any copies being made to the committee, so that all the copies of it are maintained in the committee premises.
The Witness. Okay.
Mr. Young. That is agreed.
Ms. Comstock. Committee staff may make any typographical and technical changes requested by you. I may add, that will get us beyond the 5 days, and that is fine also, as we previously discussed.
Substantive changes, modifications, clarifications, or amendments to the deposition transcript submitted by you must be accompanied by a letter requesting the changes and a statement of your reasons for each proposed change. A letter requesting any substantive changes, modifications, clarifications, or amendments must be signed by you. Any substantive changes, modifications, clarifications, or amendments shall be included as an appendix to the transcript, conditioned upon your signing of the transcript.
Do you understand everything we have gone over so far?
The Witness. Yes.
Ms. Comstock. Do you have any questions about anything we have gone over so far?
Mr. Ben-Veniste. I would like to make a statement, if that is all right. First of all, Mr. Arnold is appearing here voluntarily without subpoena, and we appreciate your accommodating Mr. Arnold's schedule in doing that within the parameters of the time frame that you had requested.
I have a question, because I didn't catch it while you were reading the material you went through as to the jurisdiction of the committee and what you were looking into. I heard you mention fund-raising, but could you go back over that, please?
Ms. Comstock. Actually, I referred to a Rules report which encompasses a number of the areas of the report -- of the investigation, I am sorry. This is the House Rules Committee Report 105-139 that was referred to in the opening.
Mr. Ben-Veniste. And the subject matter into which you are inquiring?
Ms. Comstock. Do you want me to read through that?
Mr. Ben-Veniste. You summarized it in your prepared remarks, and I just didn't catch it all. If you would just go back over that, I would appreciate it.
Ms. Comstock. Possible political fund-raising improprieties, possible violations of laws and related matters within the committee's jurisdiction, and then the House committee report outlines a number of those areas to date which are summarized in House Committee Report 105-139.
Mr. Ben-Veniste. Okay. Could you point me to that, the highlighted section?
Ms. Comstock. It begins here on page 2 and goes through page 4, and then the background goes through page 4 through 11.
Mr. Ben-Veniste. Just the areas of possible illegalities. Okay.
Ms. Comstock. I just wanted to go through a few more ground rules also. If you don't understand a question, please say so, and I will repeat it or rephrase it so you do understand the question.
Do you understand that you should tell me if you do not understand the questions that I ask?
The Witness. Yes.
BY MS. COMSTOCK:
Q The reporter will be taking down everything we say and will make a written record of the deposition. You must give verbal, audible answers, because the reporter cannot record what a nod of the head or other gesture may mean. Do you understand that?
A Yes.
Q Thank you. If you can't hear me, please say so, and I will repeat the question or have the court reporter read the question to you. Do you understand that?
A Yes.
Q If you don't know the answer to the question, please say so. We are not asking for mere speculation or guesses. Please wait until I finish each question before answering, and I will wait until you finish your answer before I ask the next question. Do you understand this will help the reporter make a clear record because he cannot take down what we are both saying at the same time?
A Yes.
Q Your testimony is being taken under oath as if in court. Do you understand that if you answer a question, it will be assumed that you understood the question and the answer was intended to be responsive to it?
A Yes.
Q And as your counsel noted earlier, you are here voluntarily today; is that correct?
A Yes.
Q Do you have any questions before we begin?
A No.
Ms. Comstock. Congressman, did you want to have some questions this morning?
Mr. Turner. No, not at this time. Thank you.
BY MS. COMSTOCK:
Q Okay, if you could please state your name for the record?
A I am Truman Arnold.
Q Okay. And give us your home address.
A I live at [redacted]
Q Could you give us your work history from college forward?
A I graduated from college at Lamar University in Beaumont and was employed by Conoco in Houston, and after spending 3-1/2 years with Conoco, I formed my own oil business back home in Texarkana, and since that time I have had the same job, February 1964; I have been president and CEO of a private family company, the Truman Arnold Company.
Q Could you describe what your current position with that entails?
A I get to sign all the notes personally, twice. And we had a petroleum distribution company, wholesale marketing company, that operates in about 26 States in the Southeast. It also embraces seven general aviation facilities, known as fixed-base operations in the aviation industry, and have a chain of convenience stores that were sold in 1989, and since that time have been fairly active in investments, passive investments within the company.
Q Do you have any foreign business?
A No.
Q Do you have any government contracts?
A Yes.
Q Could you describe those?
A In the aviation business, we have government contracts at each airport facility that are bid to provide fuel, government fuel, to any government facilities passing through. We sell under contract to governmental entities on a bid basis in the States that we operate in. I don't know specifically; we bid them virtually daily or weekly, and they are public-bid type contracts.
Q Do you have any other government contracts?
A Federal Government contracts?
Q Yes, sir.
A I believe just in the sale of fuel would be the only ones that we have.
Q Do you have any business with Mexico or any partnerships?
A No.
Q How many employees do you have?
A We presently have approximately 300.
Q Can you estimate what percent of your business is government contract related?
A It varies, depending upon the contracts. They are usually short-term. But I would think on an annual basis it would be less than 2 or 3 percent. And that number may be 5. I am not sure what the number is. It is not what you would call significant. The total volume of the company is about 600 million in sales, and I would think that the sales would be less than $30 million on an annual basis, but I am not positive of that.
Q When did you first become involved in the Clinton-Gore campaign?
A It would have been maybe October of '91.
Q Could you tell us how you became involved?
A The President called me, and I have a second home in California, and he called me in California and asked if I would help him raise money in Texas, that he was considering a run for the Presidency. I agreed to participate with him at that time.
Q Did you know the President, President Clinton, prior to that?
A Yes.
Q When had you first met?
A It would have been when he was running for Attorney General, maybe like he was 28 years old. That would have been -- that would be 22 years ago, 22 and a half. He would have been --
Q In '78?
A '77-78, yes, when he was running for Attorney General. I think he was 26 years old or something; 27, 28 maybe.
Q And did you do fund-raising for him in that campaign?
A I participated. I was not a fund-raiser, but we had a mutual friend in Mr. McLarty. Mack McLarty and his family are lifetime acquaintances and friends of mine. And Mr. McLarty asked me to contribute to his campaign.
Q And you said you knew Mr. McLarty as a lifetime friend?
A Yes.
Q Your families were friends?
A Yes. Texarkana is 30 miles from Hope, Arkansas. Mack is 10 years younger than I am, but I knew his father. They were acquaintances and business associates.
Q And did you work with Mr. McLarty in any business deals over the years in the oil business?
A No. We sold them fuel. They were a car dealer and truck leasing business, so we did some business with them and they did some business with us, and it was just a business friendship, I guess you would call it.
Q And after the Attorney General campaign, did you continue to assist Mr. Clinton with any fund-raising over the years?
A Yes.
Q Can you describe that generally?
A Mostly contributed, helped to raise money in our region of the State for him, joined in with the local political operatives in our area and within the State to help him.
Q Would you work in the State when you --
A Just unofficially, just as a businessman and a volunteer.
Q You have a home in Arkansas?
A In Texas. Texarkana is a border city, so the route that I gave you is a Texas address, but the State line runs through -- it is a ranch, and the State line runs through the middle. So half of the ranch is in Texas and half is in Arkansas. I graduated from Texas High, and my wife graduated from Arkansas High. So it is a border city. You can't tell where the State line stops and starts.
Q Who did you work with in 1992 when you were working on fund-raising?
A I evolved into being the finance chairman for Texas for the campaign, and Gary Morrow was the State chairman.
Q Was he who you reported to?
A Mr. Morrow, yes. I was, as I say, a volunteer, so I worked closely with Mr. McLarty and Mr. Lindsey and my Arkansas friends.
Q If you could just give us generally some of the Arkansas friends that you worked with and that you have known over the years from your work with the Clinton campaign?
A How much time do we have? Arkansas is a small State, you know, and there may be 200 names in Arkansas that I would recognize that have been involved with the President through the years.
Q Why don't I go through a list and you tell me if you know them. It might be helpful.
A Okay.
Q Do you know Mr. Lindsey?
A Yes.
Q How long have you known him for?
A 20 years, maybe 15. Since he graduated from college and was on Senator Pryor's staff. I knew him at that time.
Q Marsha Scott?
A I have known Marsha, I have known her by reputation for a long time. I have known her socially since '92, the '92 campaign.
Q Mark Middleton?
A Since the '92 campaign.
Q William Kennedy?
A I just knew Mr. Kennedy casually, very casually.
Q Bill Burton?
A Since '92 -- well, really longer than that. He is from Texarkana. I may have known Bill for 15 years.
Q Nancy Hernreich?
A I have known Nancy for as long as she has been with Mr. Clinton, which I think is maybe 15 years. She was in the Governor's office.
Q The others I want to ask you about who are not Arkansas related, do you know Mr. Erskine Bowles?
A Yes.
Q How long have you known him?
A Since the '92 campaign.
Q John Emerson?
A Since the '92 campaign.
Q Harold Ickes?
A Since '95. 1995.
Q Were you involved in the Clinton Inaugural in 1993, in planning that in any way?
A No.
Q Were you involved in contributing or providing funds to the Inaugural?
A I was a contributor.
Q Did you raise help raise any money?
A It would have been within the context of the DNC and the Texas fund-raising. I don't recall raising money specifically for the Inaugural, but as a contributor to the DNC, part of that came within the benefits of the Inaugural. So I guess you could say -- maybe you could say that that is active in the Inaugural. I didn't have a specific position. I didn't raise money specifically for the Inauguration.
Q How long have you known Mr. Hubbell for?
A I have known of Mr. Hubbell since he was at the University of Arkansas and playing football there. I have known of him, his name. I met him through the years. That would be 25 years, 20 years -- over 20 years.
Q Can you describe your relationship with him over the years?
A Meeting him at political functions, knowing him politically, I guess you would say, up until '92 and '93. And then we became social friends and political friends.
Q Can you generally describe the nature of those social contacts?
A Just political events, social events in other peoples' homes, social functions in Washington.
Q And you have a home here in Washington?
A I did at one time, but I don't any more.
Q Okay. What time frame did you have your home here?
A I believe the House was bought in March, maybe March of '93, and was sold in maybe June or July of '95.
Q Did you have business in Washington at that time?
A With President Clinton's election, I was in Washington a lot at the time, and I was appointed to the National Petroleum Council by the Secretary of Energy, and that required some time to be here. And my wife was appointed to the Kennedy Center Board, and it was a part of our charity and required some time here. We were in and out of here a lot and bought the House for convenience.
Q Could you just tell me what the National Petroleum Council does?
A It is a quasi-governmental agency that is self-supporting, appointed by the Secretary of Energy, that consists of the major chief executive officers of, I believe, 250 petroleum companies represented, of all cross-sections of the energy industry, in an advisory capacity to the Secretary of Energy.
Q How often does it meet?
A It meets, I believe, twice a year, unless there are functional committees working. It meets spring and fall, and then if there are functional committees or studies under way, it would meet as needed.
Q Do you receive documents or records as part of that?
A Usually it is involved in studies, a requested agenda that the Secretary of Energy would put together for internal energy studies. One of the active once I was involved in was the 1990 Oil Pollution Act and the impact on the industry and the economy and the Nation as a whole.
Generally the Secretary of Energy, there's ongoing studies at the behest of the Secretary of Energy.
Q Did you receive copies of those studies?
A Yes.
Q And what would be your function in receiving those?
A As a member of the committee or a member of the working committee, the study committee, you were preparing the study. I was a part of preparing the study, and they are widely distributed, public information. They are distributed to all Members of Congress and the administration. Everything is public information. There is no proprietary information that the Council is involved in.
Q In the spring of 1993, in the first months of the administration, did you meet often with people at the White House?
A I would come and go. How often would be, I think you would probably have a log. I was in and out of the White House fairly regularly.
Q Who were the people that you would usually meet with?
A Usually people in Mr. McLarty's office, Mr. Burton, Mr. Middleton.
Q And for what purpose would you meet with them?
A I had evolved in an unofficial capacity as a liaison between the State of Texas and the administration for political appointments. Normally that is a function that the senior Senator performs and his staff performs, but with Senator Bentsen going on the Cabinet and a Republican Senator from Texas, we were left without a Republican Senator, and the dean of the congressional delegation later was defeated. So there wasn't anyone to carry the Texas mail, so I would sort of come in and ask about the appointments and keep a progress report for the Governor and for the chairman, the dean of the Texas delegation.
Mr. Ben-Veniste. I think you may have misspoke. "Left without a Democratic Senator," I think you meant to say. I think you said "Republican Senator."
The Witness. Okay. I didn't have a Senator. I didn't have a Senator left. Thank you.
BY MS. COMSTOCK:
Q Did you speak with them about any energy matters or petroleum matters?
A No.
Q Any other business matters that you had?
A Never of a personal nature, no.
Q During the spring of 1993, did you have any occasion to talk with Mr. Hubbell about any legal problems in his law firm in 1993?
A No.
Q During his confirmation process for associate attorney general, did you ever hear of any problems that he had related to the Rose Law Firm?
A I never discussed any with him.
Q Did you ever hear from any other source?
A Only what was in the press.
Q All right. I am referring to 1993.
A Yes, I think there was some press during that time. Whatever was in the press I knew. I knew of nothing other than what I read in the paper.
Q When did you first -- do you recall generally when you first heard of Mr. Hubbell having a dispute with his former law partners at the Rose Law Firm?
A I don't recall. Whatever public information there was on it.
Q So the first time you heard about it was in press reports?
A Yes.
Q Did you talk to him about that at any time after the press report?
A No.
Q Did you talk --
A Not during that time I didn't.
Q Did you talk with anyone at the White House about --
Mr. Ballen. Excuse me, Counsel. What time frame?
The Witness. 1993.
BY MS. COMSTOCK:
Q I am talking about now actually when you first learned that he did have some problems, which you pinpoint as when there were press accounts. I guess maybe we should move into 1994. March of 1994 is when he actually announced his resignation. I believe there were press reports prior to that time.
A Yes.
Q But at that time, so in the spring of 1994, did you speak with anybody at the White House about Mr. Hubbell's legal problems?
A My first discussion would have been --
Mr. Ben-Veniste. The question was with respect to legal problems.
The Witness. Yes.
The Witness. Would have been mid-to-late March of '94.
BY MS. COMSTOCK:
Q And what were the circumstances of those conversations?
A Mr. McLarty called me about Mr. Hubbell and said that he would be stepping down, and as a friend, could I put his name on the street, he is going to be opening a legal practice and consulting practice in Washington. He was choosing to stay in Washington, and if I knew of any Texas friends that might need counsel or consulting work in Texas, that he was available. And he said at that time that he was resigning because of the billing dispute, and he needed time to clarify that and clean his personal problems up so as not to bring any embarrassment to the President.
So within the context of legal with the White House, that is the first discussion I ever had with anyone about his legal, his Rose Law Firm.
Q Do you recall if that conversation was before or after Mr. Hubbell publicly announced he was resigning?
A It would have been within the same time. I don't know whether it was rumored in the paper whether it was officially done, but it was pretty much common knowledge during that time. It was on the street. It was in the press that he was leaving. Now, I don't remember when he officially resigned, what the dates were.
Q Did Mr. McLarty mention to you any other people who he had asked to help Mr. Hubbell?
A He said -- I believe he said, I think I will call Vernon, and I am calling some others. He may have mentioned Vernon's name at the time, or maybe I later learned it. But that is the only one.
Q Did he mention Mr. Mickey Kantor assisting?
A No.
Q Did he mention Harold Ickes assisting Mr. Hubbell at any time?
A No.
Q What did Mr. McLarty tell you about, if anything, about Mr. Hubbell's problems?
A Our conversation was just about as long as I have related to you, what I have already said.
Q Did Mr. McLarty mention any conversations that he had with the President about Mr. Hubbell's situation?
A No.
Q Did you ask him any questions about the situation?
A No, other than just I get a lot of referrals for jobs in my business and make referrals, so I just considered it as a referral and character reference for someone starting a practice here.
Q What exactly did he tell you that Mr. Hubbell wanted to do in the shop that he was opening up?
A We didn't get into that. He said, "If you want to talk to Web, you can talk to Web about it."
Q Did Mr. McLarty mention whether he spoke with anyone else at the White House about Mr. Hubbell?
A No.
Q Did he mention whether he talked with the First Lady --
A No.
Q -- about helping Mr. Hubbell?
A No.
Q Did he ever mention to you any meeting that there had been at the White House about discussing helping Mr. Hubbell?
A No.
Q Other than Vernon Jordan, then you were not aware of any other people that Mr. McLarty spoke to about helping Mr. Hubbell?
Mr. Ben-Veniste. To be clear about it, the testimony was, he said he would or might be calling Mr. Jordan. He didn't say in that conversation that he had done so.
BY MS. COMSTOCK:
Q Right. Did he mention anybody else? Did Mr. McLarty mention anybody else that he was going to --
A No.
Q Following this conversation, what was the next thing that you did, if anything, to follow up on the conversation with Mr. McLarty?
A As I talked to my friends, I would just put his name out to people who might have a need or I thought might have a need or an interest in a lobbyist or a consultant or an attorney in Washington whose business interests might be appropriate for him.
Ms. Comstock. I am showing the witness EOP 020325, a March 30th, 1994, letter to Mack McLarty from Webster Hubbell, and attached is a bio of Mr. Hubbell, which is 20326. I have another copy from your production that is a little different of this. I will give you both of them so you can look at both of them.
The Witness. Okay.
Mr. Ben-Veniste. Off the record.
[Discussion off the record.]
Ms. Comstock. Another copy of the same letter, March 30, 1994, is marked TA(H) 000001 through 2, which was produced by Mr. Arnold's attorneys.
Mr. Ballen. Can the Minority have a copy of that as well, please?
BY MS. COMSTOCK:
Q Do you recognize these letters?
A Yes.
Q What I am going to refer to is the one you produced, TA(H) 1 through 2. When you spoke with Mr. McLarty, did you ask him to provide you with that information?
A Yes, I obviously said, "Mack, send me a resume and I will put it on the street."
Q Did Mr. Hubbell call you during this time frame, in March of 1994?
A I am not sure when we first talked. It would have been subsequent to this, maybe early April. It seems that we had a conversation. I think I probably called him.
Ms. Comstock. We will make TA(H)1 Deposition Exhibit Number 1.
[Arnold Deposition Exhibit No. 1
was marked for identification.]
BY MS. COMSTOCK:
Q Earlier you said you spoke with some people about Mr. Hubbell. Did you share this biography with anybody?
A Yes, I would have probably -- some of them knew him. If asked, I think I may have sent it to one or two people. I don't recall. But I had it on file if they asked for it or needed it, or I probably offered, if you want it or need it. I may have sent it to others. I am not sure.
Q Did Mr. McLarty call you at any time after that initial conversation in March or so and prior to receiving this letter?
A I have talked with Mr. McLarty fairly frequent, maybe once or twice a week, maybe two or three or four times, maybe every day. He never called me specifically about anything with Web. He never called me to ask about progress or report back. There wasn't anything of that nature.
Q Did you ever discuss -- why don't we go back to, who did you discuss providing assistance to Mr. Hubbell to?
A There were a number of people just in the course of everyday conversations, because I talked to a lot of folks. So the ones I specifically remember are Mr. Rapoport, Mr. Reaud, Mr. Conn, who ultimately retained him, I think the record reflects. I talked to some others. I talked to two others who did not retain him.
Q And who was that?
A Total Petroleum and the First Commercial Bank of Little Rock, First Commercial Corporation.
Q And do you recall what you talked to Mr. Rapoport about?
A The same thing that I just stated: Web is going to stay in Washington, he is starting a legal practice and going to do some lobbying and consulting; if you have a need for Washington counsel or lobbying, he will be available. And I pretty much said the same thing, and they would say: What can he do? And I would say: Well, that is really between you and him as to what he can do. I think he wants to work on a retainer of some type. And somewhere along the way in the conversation, I had retained him, and I related they would ask for what are you going to do, and I related my relationship with him.
Q Okay. Did you tell them how much he was charging for a retainer?
A I told him what my arrangement was with him.
Q Okay. And that was?
A It was $3,000 a month for 6 months, a retainer of $18,000.
Q And what did you hire Mr. Hubbell to do specifically?
A To consult, to lobby, just to be available for what need I may have.
Q Who was he going to be lobbying?
A At that time it was unknown, whatever my company needs might be or my region of the State might be.
Q Would it be agency officials or Congress?
A He told me that he could lobby anyone but Justice under the terms of his resignation, the Government regulations on lobbying and access, whatever that is. I am not a lawyer, so I don't understand the terminology, other than the fact he said he could do anything but lobby Justice.
Q Did you have any specific tasks that you had in mind when you hired him to work on?
A We had some things that were important to our region, highways, major government projects that I thought might be helpful, river projects. I didn't know what would evolve.
Q Are you aware of any meetings that he had on any of those subjects that you have just identified?
A No, nothing evolved that I needed, either fortunately or unfortunately.
Q So you are not aware of him doing any work then for the retainer?
A I never asked him after that time. We never had anything to come up, and then his situation became such that, after about 4 to 5 months, that I would have been hesitant to have asked him for anything.
Q And why is that?
A Well, with all the public information about his possible indictment and his own personal situation accelerating, the public knowledge and the press, whatever is in the press. I think sometime after July and August, he became much more visible and his problems became larger.
Q How did you arrive at the $18,000 figure?
A I think he probably set the number. I asked him, and he set the number as a nominal fee to be available, and then if anything that I had would occupy more of his time or monopolize his time, we would have changed the structure.
Q Okay. From the production that we got from you pursuant to the subpoena the committee issued, you had no documents reflecting any work that Mr. Hubbell did; is that correct?
A That is correct.
Q Did he ever give you any phone reports or anything or discuss with you any possibilities of any work you might see for your company?
A It would have been something I would have asked of him, and so he didn't bring it up and I didn't mention it. I would see him during this period of time socially. He was a social friend, he and his wife are social friends of ours, but there wasn't anything that came up that I needed it for. There were a couple of possibilities, but they didn't come about.
Q Did you ever talk with him about what the possibilities were or what you envisioned him doing?
A Just in general, but I never asked him to do anything about them.
Mr. Ben-Veniste. Can we have a moment?
[Discussion off the record.]
BY MS. COMSTOCK:
Q Can you describe the -- strike that.
I am showing the witness TA(H) 5 which was produced to the committee by Mr. Arnold. It is a check request form for Web Hubbell for $18,000 for legal fees dated April 20, 1994.
A Yes.
Q Did you make this request, or somebody at your company?
A Yes.
Q And what had you told Mr. Hubbell about how you were going to be paying him?
A I think he mentioned the $3,000 a month, and rather than just write a check each month, when I met with him I just paid the whole amount up front.
Q And did you personally give him this initial retainer of $18,000?
A I am not sure whether it was mailed or whether I personally gave it to him. I don't remember.
Ms. Comstock. Okay. This will be Deposition Exhibit Number 2.
[Arnold Deposition Exhibit No. 2
was marked for identification.]
BY MS. COMSTOCK:
Q You said you had spent some time at social occasions with Mr. Hubbell during this 6 months where he was on retainer.
A Yes.
Q Did he ever discuss with you any of his building legal problem?
A No.
Q Did he ever discuss with you anything having to do with the Rose Law Firm?
A As these problems that I have alluded to earlier escalated in the press, I am not sure of the exact time frame, but it was late summer. He had told me earlier that it was just an internal billing dispute, that they were going to be able to resolve it with no problems. And then at some point in there, maybe -- as I say, it was in the paper, so the time line would be public information -- he said that his problems had escalated and it looked like he would not be able to resolve the dispute with the Rose firm.
Q Did he say why he wouldn't be able to resolve it?
A We didn't get into any details.
Q Were you aware of his having any conversation with the President about them?
A No.
Q Or the First Lady?
A No.
Q Mr. McLarty?
A No.
Q Or Bruce Lindsey?
A No.
Q Any other White House officials?
A No.
Q Were you aware of him talking with the President or First Lady's attorneys about these matters?
A No. And the lines get a little blurred, Ms. Counsel. At some point in time he discussed with me the options of defending himself or pleading. So some discussions came about, but my recollection is after our retainer and professional relationship had run out. So I am not being evasive; it was just the lines blurred as to exactly when some of these conversations took place.
I knew his problems escalated at some point in time, and my best recollection is that would have been in August or September. I know I didn't retain him again. My retainer would have run out somewhere around October. So at some time during late August, the public information was escalating, September, October, and then maybe I only learned of his indictment. I saw it on CNN, I think, around Thanksgiving. So I am not sure when I learned all of this information, but as his problems were escalating. We did discuss it, very infrequently discussed it.
Q So was there any discussion of extending the retainer prior to that information --
A No.
Q -- coming out publicly?
A No. If anything, any business, had evolved prior to that, we would have been happy to have extended it. Maybe I should add, until we knew of his criminal wrongdoing, we would have extended it.
RPTS WRIGHT
DCMN GALLACHER
Q What was your reaction to that when you learned of his plea in December of '94?
A I was shocked.
Q Did you discuss that with him?
A His discussion with me was that that was his best option, and that he didn't have the resources to defend himself, and that he thought for his family this was his best option, that the matter was far less than what he was pleading to.
Q Did you have any discussions with anybody at the White House about his plea?
A I don't remember any with anyone.
Q You never discussed it with Mr. McLarty?
A No. I think everyone was saddened -- only that -- I had no specific discussion with him. If somebody said, well, it's really bad about Webster, sorry to hear this about Webster, that type of situation, that may have happened with somebody, or Mr. Middleton, but that would have been the only one.
Q Did you ever discuss with Mr. Hubbell his cooperation with Mr. Starr or what he was doing in those months?
A No.
Q Why don't I return to the individuals you mentioned, the other individuals you said you talked to about hiring Mr. Hubbell. You mentioned Mr. Rapoport --
Mr. Ben-Veniste. Excuse me, Miss Comstock. I don't want to be picky, but for accuracy sake, these are people whom Mr. Arnold said he called about Mr. Hubbell.
Ms. Comstock. Yes, I'm sorry.
BY MS. COMSTOCK:
Q Mr. Rapoport was an overnight guest at the White House at or around early April of '94. Do you know if you met with him when he was here in D.C. to discuss Mr. Hubbell or if you talked with him on the phone?
A I talked to Mr. Rapoport sometimes every day, sometimes once a week. He makes a lot of phone calls. We talk to each other about a lot of things. He is a good friend and a very honorable man. And I didn't -- there is nothing in my record. I don't think I knew that he spent the night. It didn't surprise me he stayed over at the White House, he was a good friend of the President, but there wasn't any connection with anything with Mr. Hubbell. And after I spoke to Mr. Rapoport about Mr. Hubbell, well, then, whatever he did and they did was their own business; I never knew what the relationship was after that.
Q Okay. He has been reported to have said that you told him, we need to help Webb. Is that generally accurate as to what you said to him?
A It could have been. That is something he would say to me. He would call and say, hey, we have somebody coming down, we need to help. I don't know that that would be my words. It doesn't sound like -- I may have said, hey, Webb is available if you need anything. Mine is not one of aggressively -- mine is an approach to here is what is out there and, you know, it is not a personal favor to me to do anything. I don't think I ever said, we need to help, that may be his characterization of the conversation, but I would have said Webb has a family to support and he is trying to start a practice, and if you have a need or if you know of anyone who may have a need, no different than a personal recommendation for anyone that would be a friend.
Q And did you tell Mr. Rapoport how much you were paying Mr. Hubbell?
A He probably asked. I don't remember telling. Unless he asked me, I wouldn't have told him because I didn't know, you know, what his needs might be or what his interests may be with Mr. Hubbell. He probably asked me, you know, what are you doing, what are you going to do, and I would have told him.
Q And are you aware of any needs that he had for Mr. Hubbell, any kind of work that he was thinking of having Mr. Hubbell do?
A No. Mr. Rapoport has a very large business, an active business, and I never discussed his personal relationship, what his needs with Mr. Hubbell may have been or what his arrangement was.
Q Did there come a time when you learned that he had retained Mr. Hubbell?
A I think he told me he had retained him at a subsequent time, but I didn't know what the business arrangement was.
Q Do you have any knowledge of any of the work that Mr. Hubbell did for Mr. Rapoport?
A No.
Q And you mentioned you also talked with Mr. Reaud?
A Correct.
Q Okay. And it is Wayne Reaud. Can you just tell us about him, who he is, and how you came to speak with him?
A He is a longtime friend that I served on the Board of Regents with at Lamar University and had been an active supporter of democratic candidates, a good friend of Congressman -- then Chairman Jack Brooks, and had been active in the State political campaign. He is a very prominent lawyer in Beaumont.
Q Did you ever have Mr. Reaud meet with Mr. Hubbell?
A Yes.
Q Can you describe the circumstances of the meeting?
A I talked to Mr. Reaud and Mr. Conn, so the conversations are very closely paralleled. I think that is another name you may recall. And Mr. Reaud wanted to meet with him personally, and he wanted to meet with him in Washington, and I told him -- he said, who else is considering him, who else has hired Webb, and I said, I think B. has, and he said, well, why don't we meet, the four of us meet with Webb, I would like to talk to him personally before I retain him, and why don't the four of us meet sometime at your convenience and his? And he said, I have got some different ideas about business opportunities and things that I may need. So we later met in Washington with Mr. Hubbell and discussed those opportunities.
Q When you said "the four of us meet," who was the four?
A Mr. Rapoport, Mr. Reaud, Mr. Conn, and myself.
Q And do you recall generally when that meeting occurred?
A I think we have got some documents produced. That would have been in July.
Q So that was the July 28 meeting.
A Was that July 28? Okay.
Q Before we move onto that, I would just like to show the witness, this is a document we received from Mr. Reaud, which is a message, Bate stamped number 21, from documents produced by Wayne Reaud, R-E-A-U-D?
A That is correct.
Q And it looks like the date is difficult to read on this. We thought it was April. It appears to be -- over on the right-hand side?
A Looks like 4/18.
Q That is our best reading of it. But this document is difficult to read, as the record will reflect. I will make this Deposition Exhibit 3. This refers to a lunch on Thursday for Mr. Arnold and Hubbell, at the 116 Club, and it has mention, Ms. Reaud, Anita Arnold, Suzie Hubbell.
[Arnold Deposition Exhibit No. 3
was marked for identification.]
BY MS. COMSTOCK:
Q Do you know anything about a lunch in this time frame, April of '94?
A I think I probably called Mr. Reaud and invited him. It sounds like my secretary may have called and invited he and his wife to join us for lunch. I think there was a luncheon with Mr. Hubbell where I retained him officially on maybe April the 21st. My best guess is that I called and invited him because he said he would like to meet with him personally, to talk about retaining him, and that would have been within the time frame, 3 or 4 days before the meeting, because I think there is something in the record where I had lunch with Mr. Hubbell on the 21st at the 116 Club, and that is about the time that I retained him. So the notes that were made by his secretary or him would have been about them joining us for lunch. And I subsequently, Mr. Hubbell and I, I think had lunch at the 116 on that date. I believe that is what our time line shows.
Q Okay. Could you describe what conversations you had, the four of you had -- I'm sorry, in this luncheon when Mr. Reaud was there? Do you recall generally what the conversation was?
A He didn't come.
Q Oh, okay. I'm sorry.
A He was invited, he was responding. My guess is that he was responding to the invitation for lunch, and that showed where we called to invite him and it's a note that was made, so when he returned the call, they didn't come. It wasn't until July the 28th, I believe, or whatever that date was that we met at the luncheon with Mr. Rapoport and Mr. Conn and Mr. Morgan. It was the first time that I think that I met with Mr. Reaud and Mr. Hubbell.
Q Okay. So there was no discussions in between, then, this April time frame and July with Mr. Reaud and Mr. Hubbell, to your knowledge?
A He may have been talking to Mr. Hubbell, I don't know, and I was talking to Mr. Reaud who may have said that, you know, we still need to get together, because he was encouraging a luncheon or a meeting with all of us together in Washington.
Q Mr. Hubbell was encouraging?
A Mr. Reaud.
Q Mr. Reaud was encouraging?
A And I think in the meantime there may have been some telephone conversations between he -- the two of them. It seems that maybe Wayne said, I talked to Webb, I called him and I told him I am interested in retaining him but I want to sit down and talk to him, I want to work the deal out face to face.
Q Okay. And do you know what his interests were, what the deal would be?
A Only later what came out of the luncheon and the meeting, and we had the lunch with the spouses, and then we went to a business meeting in Mr. Hubbell's office.
Q This is the July 28 luncheon?
A This was the end of July.
Q Okay. Why don't we move to the July 28 luncheon then, if you can tell us what occurred at that luncheon?
A Mr. Reaud had wanted the meeting, and I found the time, or we worked out a time when Mr. Rapoport was going to be here, and Mr. Conn and I believe Mr. Morgan, one of his partners in his firm, came with their spouses, and we had a luncheon with the spouses at the Willard and then we adjourned, the man adjourned and went to Mr. Hubbell's office to discuss things of joint interest.
Q And what were those matters?
A Mr. Reaud thought there was some business opportunities that, you know, that we were venture capitalists because everyone in the room was, you know, of some substance, and all were entrepreneurs, so everybody had had some experience in venture capital and so he was talking about potential. I think the general discussion could be characterized as saying, you know, we could capitalize a business venture if you can come across it. It is not uncommon for lawyers, particularly in Washington, to be deal makers, and it was an opportunity if Webb came across something, to put -- if he had a deal he could put together, we could all share in or have a joint interest in or capitalize or underwrite it, we had -- there was an appetite within the group if something came up.
Q Do you know, what kind of deal were you talking about?
A General. Business opportunities of any type.
Q Did Mr. Hubbell tell you anything about any Asian business deals he was working on?
A No.
Q At that time, on July 28, 1994, or thereabouts, do you have any knowledge of Mr. Hubbell working for the Lippo Group or any affiliate of the Lippo Group?
A No.
Q Did he ever mention anything about any Asian business or potentially that being a market where you all could look?
A No.
Q Okay. Were you looking at domestic venture capital deals then?
A Whatever. It didn't matter. It was a philosophical discussion.
Q And at that time, did Mr. Reaud then retain Mr. Hubbell?
A I think that is correct, he and Mr. Conn retained him at that time.
Q And were they retaining him to find some kind of venture capital deal for him?
A As a part of the overall -- I think Mr. Conn may have wanted him to do some lobbying for him. Mr. Reaud was interested in and had talked about opening an office in Washington, so the only thing that we talked about as a group is what Webb could do. There was lengthy discussion about that, what he could do, and then what collectively he might do for all of us and then each person had their own individual needs and discussion with him either earlier or later than that.
Q Was there any discussion about the amount of the retainer at that meeting, the July 28th meeting?
A No, not that I know of.
Q At any time did you learn how much they had retained him for?
A I think Mr. Reaud and Mr. Conn may have said we made the same deal with him that you did. And, I mean, Mr. Rapoport had already retained him.
Q Were there other related events surrounding the July 28, 1994, this luncheon meeting that were involved with this trip?
A Yes, we completed a number of social activities in the city by having been here and the number of friends that we had, and so we did a lot of entertaining as well, and we had a social event that evening in our home, with our Washington friends and our Texas friends.
Q I am going to show the witness TA(H)34, which was -- were these the invitees of the July 28 luncheon, or --
A That is correct.
Q Or the attendees?
A I think that would have been the attendees. I am not sure. They are the people -- I know all of these people attended. No, that is not correct. I don't believe Mrs. Morgan came. She could have. I know all of the men were in attendance. These are the Texas friends: Mr. Conn, Mr. Rapoport, Mr. Reaud, Mr. Morgan.
Mr. Ben-Veniste. There is a typo with respect to Mr. Conn's spelling, too. It should be Conn, the same as Mrs. Conn.
Ms. Comstock. Yes.
The Witness. I know Mrs. Conn was there. I know Mrs. Rapoport was there. I know Mrs. Reaud was there. I don't remember, Mrs. Morgan may have been, and my wife, Anita, was there.
BY MS. COMSTOCK:
Q And who is Glen Morgan?
A He is a partner in, I believe, the firm is called Reaud Morgan. The law firm is Reaud Morgan. It is Mr. Reaud's law partner.
Q Okay. Was anybody talking with Mr. Morgan about retaining Mr. Hubbell?
A His partner. He came because I think the discussion about the potential for opening an office in Washington.
Q I will make that Deposition Exhibit 4.
[Arnold Deposition Exhibit No. 4
was marked for identification.]
Ms. Comstock. This is TA(H)33. And it is a Thursday, July 28, 1994, agenda.
Mr. Ben-Veniste. Was there an Exhibit 3? Did you mean to make --
Ms. Comstock. Exhibit 3 was the phone message.
Mr. Ben-Veniste. I don't think you actually moved in Exhibit 3. Maybe it is my mistake.
Ms. Comstock. Okay. Sorry.
BY MS. COMSTOCK:
Q Okay. This Thursday, July 28, 1994, agenda reflects an 11 a.m. coffee at your home. Did that occur on that day?
A I don't think that their schedule provided for that. I think they came in later. I don't remember that. I think the meeting, that was scratched.
Q And then the 12 noon luncheon at the White House, can you tell us what that refers to?
A This is a preliminary schedule where the ladies were going to have -- I think this may have been my wife's schedule. The ladies were going to have lunch at the White House and the men were going to the Willard, and this was a -- this changed. There was no luncheon at the White House. This could have gone out a week before to the ladies so they know how to dress and whatever, and then the schedule changed, and the meeting ended up -- the ladies were going to the White House, to the White House mess, as I recall, and it didn't work out, and so they joined the men at the Willard.
There was no mention of the Willard here on this one. You can't tell the sequence on this or when it was typed. There is another one or two I think showing maybe what happened.
Q And do you know, when this was being considered a luncheon at the White House, do you know who the point of contact was at the White House that this was being arranged through?
A That was something my wife would have called about. That is something I am not sure on. She was putting together the ladies' social schedule.
Q And she would have called the White House?
A She may have.
Q Do you know if Mr. Hubbell was trying to arrange anything for a luncheon at the White House?
A No, no. We didn't need him to arrange anything.
Q And this agenda reflects a 7 p.m. dinner at your home?
A Uh-huh.
Q Did that occur?
A Yes.
Q I will make that Deposition Exhibit 5. That is TA(H)33.
[Arnold Deposition Exhibit No. 5
was marked for identification.]
BY MS. COMSTOCK:
Q Do you know if Mr. Rapoport was here for some other events during that time?
A He could have been. I don't have any knowledge. He comes to Washington frequently.
Q We have a number of different versions that you provided to us for the July 28 guest list. If I show you the various versions, would you know which one was the final?
A Perhaps. I think I may.
Q We have two different confirms?
A Okay.
Q TA(H)25 and 31. Do you recall which one of these ended up being the final confirmation list?
Mr. Ben-Veniste. As opposed to who actually came? It may be different.
Ms. Comstock. That, too. Thank you.
The Witness. Sometimes people confirm and don't come. It is just a social thing that is constantly evolving in Washington.
Mr. Ben-Veniste. If you remember.
The Witness. And there may have been another one.
Just from memory, on the shorter list, I am sure Mr. Moores was not there and there could have been others that came that aren't on this list. It seems to me like there were some spouses that may have come. I know Mrs. Hubbell had not come. She was not there. And I think that there are some other ladies that didn't come, maybe Mrs. Pryor. But that is just from memory. I know this one did not.
BY MS. COMSTOCK:
Q The witness is referring to --
A The longer list that has the McLartys and the Jordans, and then Hernreich and Brooks. I am almost positive they didn't come. Because they called later and said they wouldn't be able to make it.
Q And what was the purpose of this dinner, this social function?
A Purely social. These were friends of ours who had invited us. We had been in most all of their homes and been guests of theirs in Washington and back in Texas, people that were social friends of ours here.
Q Okay. I will make TA(H)25 Deposition Exhibit 6. And TA(H)31 Deposition Exhibit 7.
[Arnold Deposition Exhibit No. 6
was marked for identification.]
[Arnold Deposition Exhibit No. 7
was marked for identification.]
BY MS. COMSTOCK:
Q Do you recall at this dinner if anyone discussed generally Mr. Hubbell's --
Mr. Ben-Veniste. I'm sorry, which was No. 7?
The Witness. Is that the longer list or the shorter list?
Ms. Comstock. No. 25 was Exhibit 6, and No. 31 was Exhibit 7.
The Witness. And could we clarify the styling of this? This was an internal thing. That is styled "Hubbell Dinner"; this not not a Hubbell dinner. This was some that -- just for filing purposes was done that way.
BY MS. COMSTOCK:
Q That was my next question. So the reference to a "Hubbell dinner" was just a shorthand way for your secretary?
A Yes, it was just for filing. I testified to that in front of the grand jury.
Mr. Ben-Veniste. Don't talk about the numerous other invitations you have had to tell this and other stories, but simply refer, if you would, to your recollection of what actually happened. They don't want to know what happened in the grand jury.
The Witness. The invitation that was sent makes no reference to Mr. Hubbell. It was social and I think that substantiates -- there is a copy of an invitation that was sent for dinner that evening that relates the scope of that dinner.
Ms. Comstock. That is TA(H)24, just for the record, which was also produced by Mr. Arnold.
Mr. Ben-Veniste. If you want to see when an invitation did go out honoring somebody, you might look at TA(H) many zeros 9. There is a dinner honoring Senator and Mrs. Pryor.
BY MS. COMSTOCK:
Q In this dinner on the 28th, was there any discussion of Mr. Hubbell's situation?
A No.
Q Okay.
A Purely social.
Q You mentioned two other groups that you had contacted regarding Mr. -- or possibly hiring or talking to Mr. Hubbell, Total Petroleum and First Commercial Bank.
Can you tell me who at Total Petroleum you contacted?
A The CEO, Mr. Gary Jones.
Q And what did you discuss with him?
A He discussed it with his management team and called me back at some time later. Just as a point of information, it wasn't necessary, we were maybe discussing another matter, and he said, you know, we will be more than happy to use Mr. Hubbell if we have a specific need, but it is not our practice to put attorneys on retainer, and that was the same story at First Commercial.
Q And was Mr. Hubbell insisting upon being on retainer? He wouldn't work by the hour?
A I think that he would. I don't know that, you know, I don't know that. The only discussion I had with him, and when they asked me what my arrangement was with him, I told them. It's just that they didn't put on retainer but they appreciated the referral or reference and if they had a need, they would sure call me.
Q And who did you speak with at First Commercial Bank?
A Mr. Barnett Grace, G-R-A-C-E.
Q And what did you discuss with him?
A The same thing.
Q And what did he tell you?
A His response was the same, that the practice of the company was not to put attorneys on retainer, but to hire them for a specific need, and if the company had an interest or need in Washington, they would be more than happy to discuss it with him.
Q Do you know a Doctor Holly, who is in or around, from Waco, Texas, area?
A Spell that, please.
Q H-O-L-L-Y.
A I don't believe so.
Q Do you know if Mr. Reaud ever talked to Mr. Holly about anything ever to do with getting Mr. Hubbell work or employment?
A I don't know. I don't know.
Q In the summer of '94, did Mr. Hubbell ever tell you about any trips he was taking overseas?
A I heard somewhere along the way that he was making a trip, he and his wife were going on a trip.
Q And what did you hear?
A I found out -- either she shared it with my wife or they may have shared it after the fact.
Q And where was that trip to?
A I really don't remember. I remember talking about playing golf, and he and I played golf together and he talked about playing golf there.
Q Do you know if this trip had anything to do with any work Mr. Hubbell was doing?
A I didn't ask and he didn't share, no.
Q Did he tell you about a trip to Greece that he took sometime in 1994?
A It seemed like they took a vacation, a sailing vacation or something. I don't remember. I remember laughing because he is a pretty big guy and they were on a fairly small boat and he slept on the deck, I think, most of the time. The cabin wouldn't hold him. Only within that context, it was a vacation kind of thing.
Q And did there come a time when you learned of a trip to Jakarta that he took any time in 1994?
A Just from what I have read since the time.
Q Your only knowledge of the trip to Jakarta is from press accounts?
A Yes.
Q In the past year or so?
A I never had any discussion with Mr. Hubbell about that.
Q Did you know a David Waters?
A Yes.
Q And who is Mr. Waters?
A Mr. Waters was my vice president of aviation and chief pilot.
Q So some of the events where Mr. Waters is there, he is there because he is with you on business?
A Yes.
Q You mentioned that you had golfed with Mr. Hubbell during this time. Did you ever golf with Mr. Hubbell and the President during this time that you had Mr. Hubbell on retainer?
A I think there was one time that we played together.
Q Do you recall when that was?
A It would have been in maybe July. I am not sure what the record reflects. I don't remember specific times. It seems like it was early July.
Q Okay. Do you recall any of the discussions that you had on that outing?
A Golf.
Q Did Mr. Hubbell or the President raise anything having to do with Mr. Hubbell's legal problems?
A No, not to my knowledge. I didn't hear any, and there was no discussion that I was privileged to.
Q Do you recall who the fourth person was, did you have a foursome?
A I think Congressman Beryl Anthony was in the foursome. I believe that is correct.
Q During this time, in 1994, when you had him on retainer, did you ever hear anybody from the White House refer to Mr. Hubbell's inability to get work with law firms in D.C., having trouble getting work?
A No.
Q Did you hear anybody say anything to the effect that law firms wouldn't touch him?
A No.
Q Okay. The President has indicated that he thinks he may have talked to you at some point or known of your hiring Mr. Hubbell. Do you recall any conversations you had with the President about that?
A No, we never discussed the hiring of Mr. Hubbell.
Q Are you aware of anybody else who may have discussed your hiring with the President?
A I have read Mr. Rapoport may have told him or Mr. Rapoport told him that he hired him and my name may have come up in the context of his and Mr. Rapoport's conversation. But that is something I read in the news accounting of it, but the President and I never discussed that relationship.
Q Have you had any discussions with anybody in the White House Counsel's Office about your hiring Mr. Hubbell?
A No.
Q Have you had occasion to stay overnight at the White House?
A Yes.
Q Do you recall how many times?
A Once my wife and I were there, in I think maybe the spring of '93.
Q Were you aware of any efforts to ever get anybody to raise money to be able to stay at the White House?
A No.
Q Did anyone ever talk to you about allowing people to stay at the White House for any certain contributions?
A No.
Q Other than the people that you spoke to about assisting Mr. Hubbell, were you aware of any other employers or consulting arrangements that Mr. Hubbell had?
A No.
Q Okay.
A Was I aware at the time? I have later read, but not at the time.
Q I am talking in 1994?
A In 1994, while he was under retainer, under the retainer with my company and me, I know of no other clients.
Q Okay.
Mr. Ben-Veniste. Other than the ones you have mentioned.
The Witness. Other than the ones that have been mentioned. I knew about Mr. Moores. We haven't talked about Mr. Moores, I don't think. I knew he had retained him on a specific issue, but that is the only other one that I was aware of.
BY MS. COMSTOCK:
Q Can you describe your knowledge of Mr. Moores' hiring of Mr. Hubbell?
A Mr. Moores is a friend of mine from Houston, who also was my neighbor in California, and he was discussing the billing of a hangar at the Monterey Airport and was having some problems getting it permitted and felt he was being excluded for competitive reasons, and I had limited knowledge of the FAA and my dealing with them and knew that no one could have an exclusive contract on an airport, and that there was a way with the FAA to proceed with that, and he said, you know, I think I will just get me a Washington lawyer and give it a whirl, and he said, do you have anyone you would recommend, and I said, well, Mr. Hubbell, as someone who is available, and from that point, I don't know what their relationship was. I think the deal came undone.
In the meantime, Mr. Moores bought the Padres and that seemed to occupy -- take his interest off of building a hangar at Monterey, but that is -- other than those that were mentioned, Mr. Conn, Mr. Rapoport, Mr. Reaud, Mr. Moores, and myself, I was not aware of any other clients that Mr. Hubbell had.
Q Okay. I think you have already testified you did not know anything about the Lippo companies or any of the affiliates.
A That is correct.
Q Do you have any knowledge of any telecommunication work he did for anybody?
A No.
Q Either for Sprint or Pacific Telesis?
A No.
Q Do you know Jack Williams?
A Jack Williams, yes.
Q And how do you know Mr. Williams?
A He is from Texarkana and I have known him all of my life and his wife, ex-wife.
Q Did you ever talk to Mr. Williams about hiring Mr. Hubbell?
A No.
Q Did there come a time when you learned he had hired Mr. Hubbell?
A Mr. Williams?
Q Or referred him?
A No, not to my knowledge. I have heard recently that there was some discussion, but that is only very recently, but I don't have any knowledge. I didn't have any knowledge at the time and I have a very limited knowledge now.
Q So in 1994, you knew nothing about Jack Williams assisting Mr. Hubbell in any way to find work?
A No.
Q Do you know Michael Berman?
A I know who he is. I don't know him personally.
Q Were you aware of any assistance Mr. Berman was providing to help Mr. Hubbell find work?
A Only what I have read since then, but at the time, no, I didn't know of any involvement.
Q Were you aware of Mr. Hubbell doing any work for a Los Angeles airport commission?
A No.
Q Do you know John Phillips?
A No.
Q Do you know Ron Pearlman?
A Yes.
Q Were you aware of any efforts by Mr. Pearlman or his associates to help Mr. Hubbell?
A Well, what I have read since then, but I wasn't aware of any at that time.
Q Do you know Eli Broad?
A I just know who Mr. Broad is.
Q Were you aware of any assistance Mr. Brod was providing --
A No.
Q -- for Mr. Hubbell?
A No.
Q Did you ever discuss with Mr. Hubbell his writing of a book?
A There was some general discussion that he was going to write it. He thought he would write a book.
Q What did he tell you about that?
A He was just going to do his memoirs. He thought it would be something to occupy his time while he was away.
Q Did you ever discuss with him any legal defense funds that he established?
A No.
Q Were you aware of legal defense funds established by or for Mr. Hubbell?
A At that time, I was not. I have read about it since, but we never discussed it.
Ms. Comstock. Can we take a brief recess, 5 minutes.
[Brief Recess.]
RPTS PETTY
DCMN GALLACHER
BY MS. COMSTOCK:
Q Okay. We can go back on the record. Mr. Arnold, you were a DNC trustee; is that correct?
A Was or am? I have been, yes.
Q Okay. Can you tell us when you first became a DNC trustee and what that means?
A Probably would be '92, '92, and it's a terminology used for a level of giving, no different than the RNC's team 100 or Eagles. Just terminology for levels of giving.
Q All right. And how much did you give in '92 to DNC?
A I can't remember specifically. I don't know specifically what it was. I don't have that.
Q Did there come a time when you became involved with the DNC finance office?
A Yes.
Q Could you describe how that came about?
A The -- I had done, been finance chairman in Texas, as we discussed previously, and the President called -- I guess I saw Don Fowler at the AT&T golf tournament in -- it would have been '95, January, February '95, and he asked if I could consider being finance chairman. And I told him that I had a better deal at Pebble Beach, and he said what would I take. And I said, there is only one person that could move me out of what I was doing, that would be the man, the President. We were just laughing. And about 3 days later President Clinton called and said, I need you, and I said, I am on vacation, what do you want me to do? He said, I would like for you to be finance chairman of the DNC. So we had a light discussion, and I said, how long have I got to think about it, and he said, if you will accept, you can finish your vacation, but if you say no I would like for you to fly to Washington tomorrow. So at his personal request I accepted it in I guess late February, early March of 1995.
Q And how long did you stay in that position?
A Until Labor Day, I guess, September. September of '95.
Q And can you describe what you did during that time frame?
A Well, the finance chairman, the President's charge and challenge to me was to raise the money and make sure that it was spent frugally. The budget was already established and we discussed the parameters of the budget. That's basically the finance chairman's job, is to meet the budget expectations that have been established.
Q Who did you report to?
A I guess organizationally, the finance chairman. Senators Dodd and Fowler were the official, general chairman and the chairman. I have forgotten what the terminology was at the time. So I guess organizationally I would have reported to them.
Q Were there others you reported to?
A I communicated with, but I didn't, quote, report to. But I was a volunteer, unpaid and no expenses. I didn't -- I never was reimbursed or asked to be reimbursed. So I don't know. In the organizational structure, I guess, you had to be confirmed by the executive committee of the Democratic Party or ratify, so I guess you would report to the chairman of the party.
Q Did you also report informally or discuss in some manner with Mr. Ickes fund-raising matters?
A Yes.
Q And can you describe what those contacts were?
A With Mr. Ickes was primarily scheduling.
Q Scheduling?
A Scheduling of events around the President's time. I met with Mr. Ickes or would meet at the White House on scheduling matters.
Q And did you provide Mr. Ickes with finance information or spreadsheets or anything like that?
A Not directly. I didn't have any communication directly other than verbal and scheduling with Mr. Ickes.
Q Were you aware of others that were in touch with Mr. Ickes from the DNC?
A I would assume Mr. Fowler kept him informed to the extent that he requested to be.
Q Who reported to you in the structure of the finance office?
A The finance chairman, director of finance reported directly to me, Mr. Sullivan, and then his staff.
Q And who were his senior staff?
A There were three deputies and then the working staff.
Q And who were they?
A Mr. David Mercer, Mr. Ari Swiller, and Ms. Erica Payne. Three deputies.
Q And did you work with those three, also?
A Yes.
Q And could you describe generally what your contact with Mr. Sullivan and his deputies was?
A Primarily about upcoming events and fund-raising for those events, who would attend and how much money was being raised and delegating the responsibility to one of the deputies for coordinating, supervising, and the specific events.
Q And how often would you meet with them?
A I was here frequently. Would spend 3 to 4 days, maybe gone for a week and spend a full week, whatever time was required. But I was in and out. I was probably here 60, 70 percent of my time, or involved in the DNC activities 60, 70 percent of my time.
Q And how often did you have meetings with Mr. Ickes or anybody -- with Mr. Ickes?
A It's rather general. They were scheduling meetings that happened weekly at the White House and sometimes I would attend. I may have met with him 6, 8, 10, I don't know, maybe more than that, maybe less than that, attended a meeting that he would chair.
Q And can you describe who else was at the meetings that he was chairing?
A The people who would normally attend from the DNC, who were invited to attend would be the chairman, the finance chairman, the finance director. So there would be Mr. Fowler or Mr. Dodd, maybe both, Mr. Sullivan and myself. And rarely did all of us meet there. Someone was always there to represent the DNC at those scheduled meetings.
Q Were you aware of any efforts to provide access to the White House by -- to big dollar donors?
A Restate that, please.
Q Are you aware of any efforts at the White House to reward good dollar DNC donors with access to the White House for overnights or access to the White House or coffee?
Mr. Ben-Veniste. I would object to the form of the question. The idea of people who had made contributions, political contributions also be invited to the White House is a totally common occurrence, to my knowledge, for decades. Maybe it's the way you phrased your question.
BY MS. COMSTOCK:
Q Were you aware in the area of fund-raising efforts to provide people with access to the White House?
A We attempted to recognize and acknowledge people's work and their efforts by trying to include them in White House events when they asked.
Q Were you aware of providing people with access to White House officials in any particular policy areas?
A No.
Q Recently, in the past several months it has come to light about the White House overnights and the President's efforts to have $50,000 and $100,000 donors spend the night at the White House. Did you ever hear any discussion of those efforts?
A Never had any discussion. Never asked for anyone to spend or was never involved in anyone's overnight stay.
Q Did you ever facilitate anyone having access to Air Force One or getting a ride on Air Force One?
A I did. Mr. Reaud went down. He was interested in aircraft, has an airplane, said sometime, if it is ever possible for me to ride on Air Force One I would like to. And I arranged for that from Dallas to Los Angeles. He had hosted an event in Dallas and we were going to another event in Los Angeles, and he went on that particular leg. And the DNC reimbursed for his portion of travel.
Q To your knowledge, was Mr. Reaud asked to reimbursed for Air Force One?
A No, the DNC would have done that. The DNC is allocated a certain portion of Air Force One, and I was on it and my wife and he, so the DNC would have picked up the tab for whatever our pro rata expense would have been, is my understanding of the policy on Air Force One.
Q Okay. So the DNC -- when you would travel, you also travelled on Air Force One; is that correct?
A Yes.
Q And so when you would travel, the DNC would pick up a portion of your costs for travel?
A I personally paid the portion of my wife's travel.
Q And to your knowledge --
A The DNC paid for my travel.
Q And to your knowledge, the DNC also picked up Mr. Rio's costs?
A Yes, that's my understanding. I remember it cost $75,000 to take off and land Air Force One. I am in the aircraft business and I always thought it was a pretty nice ticket.
Q Now, you said your wife is on the Kennedy Center board; is that correct?
A Yes.
Mr. Ben-Veniste. Excuse me just a minute.
(Attorney conferred with the witness.)
Mr. Ben-Veniste. Sorry.
BY MS. COMSTOCK:
Q Okay. I think the question pending was, you had mentioned that your wife is on the Kennedy Center board; is that correct?
A Yes.
Q Were you aware of donors being provided with access to the Presidential Kennedy Center box?
A No.
Q You were not? You or your wife were not involved in any of those efforts?
A No. She could have -- we have invited people and she could have gotten, but no one made a request of me for tickets to the Presidential box.
Q This is a document from the DNC, DNC 3089636, and it's an August 15, 1995, memo to Truman Arnold from Richard Sullivan regarding the Sun Oil Corporation. I will let the witness review the document.
The Witness. Yes.
Mr. Ben-Veniste. Do you have another copy?
BY MS. COMSTOCK:
Q Do you recall receiving this memo?
A I don't recall it specifically, but I obviously did.
Q Okay. The memo says that Sun Oil Corp. of Philadelphia, Pennsylvania, contributed 65,000 last year and is going to do the same this year. It goes on to say, quote, the Washington representative Albert Knoll asked us to get their CEO, Robert Campbell, included in any White House or administration energy meetings.
Do you recall getting Mr. Campbell involved --
A I never took any action, to my memory. This is just a source of information, but this is August the 15th and I don't think I was in Washington after that time very much, maybe a day or two or maybe early in September. But I never took any action on it.
Q Okay. Do you know Albert Knoll?
A I just know him by his position. I don't know him personally.
Q Or Robert Campbell?
A No.
Q Do you have any knowledge of anybody at any time getting a meeting involving energy meetings because of donations they gave to the DNC?
A No.
Ms. Comstock. I will make that Deposition Exhibit 8.
[Arnold Deposition Exhibit No. 8
was marked for identification.]
BY MS. COMSTOCK:
Q This is DNC --
Mr. Ben-Veniste. Excuse me, could you read back that last question.
(The reporter read back as requested.)
BY MS. COMSTOCK:
Q DNC 3089651, it's a document from the Democratic National Committee, an August 17, 1995, memo to Truman Arnold from Richard Sullivan re Douglas Horne. There's an attached August 17th, 1995, letter to David Strauss from Richard Sullivan.
Do you recall receiving this memo?
Mr. Ben-Veniste. Just let me take a look at it. I am trying to catch up.
Mr. Ben-Veniste. Go ahead.
BY MS. COMSTOCK:
Q Do you recall receiving this memo?
A Vaguely, yes.
Q Do you know Douglas Horne?
A Yes, I do.
Q And who is he?
A Pardon me?
Q Who is Mr. Horne?
A Mr. Horne is a businessman in Tennessee.
Q And how do you know him?
A I met him at one of the -- I believe at the Southeastern Economic Conference in Atlanta.
Q And had you solicited any funds from Mr. Horne?
A In fact, he volunteered to me. He said he was interested in becoming a trustee and I explained the trustee program and he sent his check in. He was a friend of, a longtime friend and supporter in Tennessee of the Vice President.
Q Do you know if he had any meeting with Mr. McLarty about DOE funding?
A No, I don't.
Q Do you know what Oak Ridge is?
A Oak Ridge is a government installation at Tennessee, and he had an interest in the well-being of his State and whatever government funding that was going to affect that particular region. But only in that context.
Q Did Mr. Sullivan ever talk to you about setting up time of meetings --
A No.
Q -- with Mr. McLarty or Mr. Horne?
A I think this is the first time I have ever seen Mr. Sullivan's letter. It was August the 17th. I don't recall ever seeing it. I don't know. I could have.
Ms. Comstock. Make that Deposition Exhibit 9.
[Arnold Deposition Exhibit No. 9
was marked for identification.]
BY MS. COMSTOCK:
Q What was your understanding of what the White House coffees were utilized for?
A They were a -- two, for recognition, inclusion, to energize workers and supporters.
Q Were you ever provided with spreadsheets that showed the amount of money that was intended to be raised from coffees?
A No.
Q Have you since, since you left your post as DNC finance chairman, become aware of such spreadsheets?
A Only --
Q In the past months?
A That's very broad, it seems to me.
Mr. Ben-Veniste. Aware of, you mean from the newspapers?
Ms. Comstock. Yes, from news accounts.
Mr. Ben-Veniste. If your question relates only to spreadsheets or whether in fact there was some discussion or documents relating to anticipated contributions, I guess in that general sense you can answer. If your question is whether he actually saw a spreadsheet?
BY MS. COMSTOCK:
Q I am asking at the time when you were serving at the DNC if you were ever provided with spreadsheets showing that coffees were going to raise a certain amount of money?
A No.
Mr. Ben-Veniste. He answered that.
BY MS. COMSTOCK:
Q And since that time, have you seen such documentation or come to know of such documentation?
Mr. Ballen. Those are two questions
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