Filegate Bill Clinton aided and abetted by Hillary Gore Reno Brown conduct or plan designed to delay impede and obstruct the investigation of bribery, Cover up conceal and protect those responsible, Conceal the existence and scope of other unlawful covert activities, December 1998

                       "IMPEACHMENT OF PRESIDENT
                        WILLIAM JEFFERSON CLINTON

                               __________

                         THE EVIDENTIARY RECORD
                         PURSUANT TO S. RES. 16
                               VOLUME VII


Transcript of October 5, 1998 presentations of David Schippers and Abbe 
 Lowell, and debate on H. Res. 581, beginning an impeachment inquiry. 
               Committee Print, Ser. No. 8, December 1998"

"Mr. Barr. Mr. Chairman, I also ask unanimous consent to 
insert the Judicial Watch Interim Report dated September 28, 
1998.
    Mr. Hyde. Without objection."

"Judicial Watch Interim Report on Crimes and Other Offenses Committed by 
 President Bill Clinton Warranting His Impeachment and Removal from 
 Elected Office"

"INTRODUCTION

 The President, Vice President and all civil officers of the United 
States, shall be removed from office on Impeachment for, and conviction 
of, treason, bribery, or other high crimes and misdemeanors.
 United States Constitution, Article II, Section 4

 In his conduct of the office of President of the United States, 
William Jefferson Clinton, in violation of his constitutional oath 
faithfully to execute the office of President of the United States and, 
to the best of his ability, preserve, protect, and defend the 
Constitution of the United States, and in violation of his 
constitutional duty to take care that the laws be faithfully executed, 
has prevented, obstructed, and impeded the administration of justice, 
in that:
 Beginning around the Fall of 1994, William Jefferson Clinton, 
 his agents and subordinates engaged in bribery through the sale 
 of taxpayer-financed trade mission seats in exchange for 
 campaign contributions. Subsequent thereto, President Bill 
 Clinton, using the powers of his high office, engaged 
 personally and through his close agents and subordinates, in a 
 course of conduct or plan designed to delay, impede and 
 obstruct the investigation of such bribery; to cover up, 
 conceal and protect those responsible; and to conceal the 
 existence and scope of other unlawful covert activities.
 Throughout his terms of office, William Jefferson Clinton has 
repeatedly engaged, personally and through his close subordinates and 
agents, in conduct violating the constitutional rights of citizens, 
breaching the national security, impairing the due and proper 
administration of justice, and the conduct of lawful inquiries, or 
contravening the laws governing agencies of the executive branch and 
the purposes of these agencies.
 In all of this, William Jefferson Clinton has acted in a manner 
contrary to his trust as President and subversive of constitutional 
government, to the great prejudice of the cause of law and justice, and 
to the manifest injury of the people of the United States.
 Wherefore, William Jefferson Clinton, by such conduct, warrants 
impeachment and trial, and removal from office.(1)
 Judicial Watch, Inc. respectfully submits to the United 
States Congress its Interim Report on Crimes and Other Offenses 
Committed by President Bill Clinton Warranting His Impeachment and 
Removal from Elected Office.
 As the United States House of Representatives considers whether to 
launch impeachment proceedings against President William Jefferson 
Clinton over his conduct relating to the Paula Jones sexual harassment 
lawsuit and resulting criminal grand jury investigations, we ask that 
it also consider this additional evidence, developed over the last 
several years through Judicial Watch's civil lawsuits, Freedom of 
Information Act requests, and other investigations of government 
corruption.(2)
 Judicial Watch has uncovered evidence that President Clinton and 
his agents have violated a number of federal laws relating to bribery, 
campaign fundraising, the theft of government services, privacy, 
corruption of federal law enforcement, abuse and misuse of federal 
agencies (including the Internal Revenue Service), perjury, civil 
rights violations, obstruction of justice, graft and likely breaches of 
national security.
 The evidence uncovered by Judicial Watch overwhelmingly indicates 
that President Clinton condoned, directed and effected this 
lawbreaking. It also shows that he was aided and abetted by, among 
others, Hillary Rodham Clinton, Vice President Albert Gore, late 
Commerce Secretary Ronald Brown, Attorney General Janet Reno, and other 
key White House personnel, including Leon Panetta, John Podesta, Harold 
Ickes, Bruce Lindsey, Bernard Nussbaum, and Labor Secretary Alexis 
Herman.
 For example, Judicial Watch has uncovered key evidence in the 
massive political espionage, witness tampering and intimidation 
operation popularly known as ``Filegate.'' In ``Filegate,'' the Clinton 
White House, the Federal Bureau of Investigation (``FBI''), Hillary 
Rodham Clinton, former White House Counsel Bernard Nussbaum, and 
Clinton appointees Craig Livingstone and Anthony Marceca, illegally 
obtained and misused the FBI files of former Reagan and Bush 
Administration staffers and others to gain sensitive information on 
perceived political opponents and material witnesses for use in its 
smear campaigns. Judicial Watch represents the victims of ``Filegate'' 
in a civil lawsuit.
 The ``Filegate'' political espionage, witness tampering and 
intimidation operation, a horrendous violation of the Privacy Act and 
other laws, continues to this day. It represents the means by which the 
Clintons defend the various scandals which threaten their hold on 
power. The evidence indicates that the Clinton Administration, with the 
direct knowledge and participation of the President, continues to 
illegally compile, maintain and disseminate sensitive information on 
perceived adversaries from confidential government files. Contrary to 
previous Clinton Administration explanations, Judicial Watch discovered 
that it was a high-level Clinton political appointee who illegally 
ordered the release of Linda Tripp's confidential information from her 
Pentagon file in a clear effort to intimidate her from telling what she 
knew of Clinton White House illegal activities, and to destroy her 
credibility. Judicial Watch also uncovered evidence indicating that 
President Clinton authorized the illegal release of Kathleen Willey's 
letters, stored in a White House filing system subject to the Privacy 
Act, in an effort to intimidate and smear her. Like Ms. Tripp, Ms. 
Willey is a material witness in on-going criminal grand jury 
investigations and civil lawsuits.
 Part of the pattern of ``Filegate'' is President Clinton's use of 
private investigators, the Reno Justice Department, the FBI, the IRS, 
and political operatives such as James Carville to obstruct justice, 
silence witnesses and intimidate investigators. For example, Judicial 
Watch has uncovered evidence that President Clinton personally 
participated in this operation by threatening ``to destroy,'' and then 
defaming one witness, Dolly Kyle Browning, if she dared to tell the 
truth about their 30-year friendship and sexual relationship.
 President Clinton's political appointee and former IRS Commissioner 
Margaret Milner Richardson also illegally used the IRS to audit public 
interest groups thought to be hostile to the Clinton Administration, 
including the Western Journalism Center.
 Through discovery in its civil lawsuit against the Clinton Commerce 
Department, Judicial Watch also has found evidence that President 
Clinton condoned and participated in a scheme, conceived by First Lady 
Hillary Rodham Clinton and approved by the President, to sell seats on 
U.S. Department of Commerce trade missions in exchange for political 
contributions. Bribery is specifically highlighted in the U.S. 
Constitution as an offense warranting impeachment.
 In President Clinton's push to sell taxpayer-financed government 
services to raise money for his political operations, national security 
likely was breached by his Commerce Department appointees and those 
involved in his fundraising scheme, such as John Huang. While Judicial 
Watch is at an interim stage of investigation in this sensitive area, 
the breaches of national security uncovered at the Clinton Commerce 
Department raise real questions of treasonous activities by the 
President and members of his Administration.
 To cover-up this illegal fundraising and likely national security 
breaches, President Clinton's top two staffers, then-Chief of Staff 
Leon Panetta and Deputy Chief of Staff John Podesta, ordered late 
Commerce Secretary Ron Brown to obstruct justice and defy federal Court 
orders. The evidence also indicates that Secretary Brown personally 
consulted with President Clinton in furtherance of this cover-up.
 In addition to the illegal sale of taxpayer-financed services, such 
as seats on government trade missions, for political contributions, the 
President and Mrs. Clinton have illegally solicited and received monies 
directly from private citizens and others. The creation and use of 
legal defense funds is not only prohibited under federal law, but they 
have proved to be a means whereby lobbyists, influence peddlers and 
foreign powers have tried to influence the Administration, contrary to 
U.S. national security interests.
 This President's Administration has also misused government lawyers 
to obstruct investigations into his wrongdoing. His Commerce Department 
lawyers obstructed Court-ordered discovery into the illegal sale of 
taxpayer-financed trade mission seats for political contributions. His 
Justice Department lawyers threatened investigators with criminal 
prosecution, timed the indictment of a major whistle-blower witness to 
try to force her into silence, and consistently obstructed Court 
processes to cover-up Clinton-appointee wrongdoing, perjury and 
destruction of evidence.
 In sum, Judicial Watch has uncovered a pattern of conduct by this 
President and his agents that indicates he has run, in effect, a 
criminal enterprise from the White House to obtain and maintain hold on 
the Office of the President of the United States. Indeed, he is likely 
in violation of the Racketeering Influenced and Corrupt Organizations 
Act (RICO), a charge recently filed against him by Dolly Kyle Browning 
in federal court.(3) This pervasive corruption, flowing from 
the Oval Office, is the common thread throughout the various ``high 
crimes and misdemeanors'' outlined in this interim report.


part i
 FILEGATE
 Crimes and Other Offenses Relating to the Misuse of FBI and other 
 Government Files that Warrant Impeachment and Removal from Office of 
 President Bill Clinton
I. Introduction.
 Judicial Watch has been investigating the misuse of information in 
government files since September 1996, when it filed a class-action 
lawsuit on behalf of eight (8) former Reagan and Bush Administration 
appointees and employees whose FBI background investigation files were 
improperly obtained by the Clinton White House. That lawsuit is pending 
before The Honorable Royce C. Lamberth of the U.S. District Court for 
the District of Columbia.(4)
 In the course of its investigation, Judicial Watch has uncovered 
substantial evidence of unlawful misuses of information in government 
files, abuses of power and violations of the Privacy Act. The 
substantial evidence uncovered by Judicial Watch's investigation links 
key presidential advisors such as James Carville, Harold Ickes, Lanny 
Davis, Kenneth Bacon and even the President himself, to this unlawful 
conduct. The obvious purpose behind the unlawful misuse of this 
information is to discredit, if not destroy, perceived adversaries and 
critics of the President.
 Importantly, the evidence uncovered during the course of Judicial 
Watch's investigation, which still continues, goes beyond acquisition 
of the over 900 FBI background investigation files on former Reagan and 
Bush Administration appointees and employees. It also includes evidence 
of misuse of information in government files, and attempts to discredit 
or destroy the credibility of key witnesses in Independent Counsel 
Kenneth W. Starr's investigation of the Monica Lewinsky matter, 
including Ms. Linda R. Tripp and Ms. Kathleen Willey, if not Judge 
Starr himself. It also includes attempts to discredit and destroy 
congressional adversaries and other perceived opponents. At times, 
information in government files is released directly to the media by 
Clinton Administration officials. Other times, information is leaked to 
members of the media, such as The New Yorker magazine's Jane Mayer, 
Salon Magazine and Geraldo Rivera, so that it can be disseminated to 
the public without it being associated directly with, or coming from, 
the Clinton Administration.
 Most recently, this tactic of attempting to discredit and destroy 
the credibility of perceived adversaries has manifested itself in 
revelations about the personal lives of Speaker Newt Gingrich, House 
Judiciary Chairman Henry Hyde, and Representatives Dan Burton and Helen 
Chenoweth, coupled with threats broadcast by Roger Clinton and 
published in Salon Magazine and other publications and news outlets. 
For example, in what can only be described as a thinly-veiled threat 
against perceived adversaries and other critics of the President, Salon 
Magazine has ``reported'' that:
 [D]ie-hard Clinton loyalists are spreading the word that a long-
ignored but fearsome tactic has now resurfaced as an element in the 
president's survival strategy: The threat of exposing the sexual 
improprieties of Republican critics, both in Congress and beyond, 
should they demand impeachment hearings in the House.(5)
 Jonathon Broder, the editor of Salon ``reports'' ``one close ally 
of the president'' as saying that ``[t]he Republicans with skeletons in 
their closets must assume everything is known and will come out. So the 
question is: Do they really want to go there?''(6) ``Sources 
in the Clinton camp say they are focusing their attention not only on 
issues of marital infidelity but also on issues of character,'' 
according to Mr. Broder.(7) Mr. Broder ``reports'' that his 
``sources'' say ``among those under scrutiny'' are House Speaker Newt 
Gingrich, House Majority Leader Richard Armey, Chairman Dan Burton of 
the House Government Reform and Oversight Committee and Chairman Henry 
Hyde of the House Judiciary Committee.(8)
 Salon is not alone in reporting details of Clinton's sexual 
scorched-earth plan. Insight Magazine reports that:

 [It] has learned from a variety of sources--lawmakers and 
 Hill staffers, journalists and dirt-diggers themselves--of 
 several active gumshoe probes into GOP figures, including a 
 governor suspected of a series of office romances and a House 
 member. An entrapment bid was launched recently on a prominent 
 Republican senator, claim private investigators. It 
 failed.(9)

 As further revealed by Insight, one Democratic member of Congress, 
who had the courage to call for President Clinton's resignation, was 
subsequently hit by the Clinton ``smear machine:''
 Clinton aides also demonstrated their readiness to play dirty in 
the last week of August when they ``reminded'' TV talk-show hosts of 
the highly dubious ``controversy'' surrounding Pennsylvania Democratic 
Representative Paul McHale's military record. The White House prompt--
McHale was said to have misrepresented what medals he'd been awarded--
was apparent punishment for the Pennsylvanian calling on the president 
to resign. It was so clearly dishonest that even Geraldo Rivera 
apologized for picking it up from a source close to the White 
House.(10)
 Representatives Burton and Gingrich were hit about a month after 
Salon's ``scorched-earth'' article. Faced with imminent publication of 
details about his family life, Chairman Dan Burton, who is conducting 
campaign finance investigations of President Clinton, recently was 
forced to admit, in the face of an imminent smear campaign against him, 
that in the early 1980s he fathered a child out of wedlock and provided 
continuing child support payments to the mother.(11) Salon 
itself recently committed an act of self-fulfilling prophecy by 
publishing articles detailing allegations about the sex lives of House 
Speaker Newt Gingrich(12) and House Judiciary Chairman Henry 
Hyde.(13)
 Thus, as more revelations about the Lewinsky matter become public 
and the President comes under increasing threat of impeachment and 
possible indictment, the White House and its allies are increasingly 
resorting to scorched-earth tactics to avoid impeachment or 
resignation. Indeed, given the Clintons' proclivities for controversy, 
if not scandal, it is likely that they ordered the gathering of FBI 
files and other information early on in their Administration for later 
use--whenever it became necessary.
II. Applicability of the Privacy Act.
 Judicial Watch's ``Filegate'' lawsuit is premised on common law 
invasion of privacy claims and the Privacy Act, a federal law enacted 
in 1974 as a result of misuse of information in government files and 
other abuses of power during the Nixon Administration.
 The protections afforded by the Privacy Act take effect whenever a 
federal agency maintains a ``system of records'' containing information 
on individuals ``from which information is retrieved by the name of the 
individual or by some identifying number, symbol or other identifying 
particular assigned to the individual.'' 5 U.S.C. Sec. 552a(a)(5). 
Importantly, agencies must ``maintain in its records only such 
information about an individual as is relevant and necessary to 
accomplish a purpose of the agency required to be accomplished by 
statute or by executive order of the President.'' 5 U.S.C. 
Sec. 552a(e)(1). They also must maintain only information that is 
accurate, timely and complete. 5 U.S.C. Sec. 552a(e)(5). Agencies are 
specifically prohibited from maintaining records that describe ``how 
any individual exercises rights guaranteed by the First Amendment, 
unless expressly authorized by statute or by the individual about whom 
the record is maintained or unless pertinent to and within the scope of 
an authorized law enforcement activity.'' (14) 5 U.S.C. 
Sec. 552a(e)(7).
 Each agency maintaining records on individuals must publish, at 
least annually in the Federal Register, notice of the existence of each 
system of records it maintains. By law, this notice must also include 
information about the system, including its name and location of the 
system, categories of individuals on whom records are maintained in the 
system, categories of documents maintained in the system, each routine 
use of records contained in the system, policies and practices 
regarding storage, retrievability, access controls, retention and 
disposal, the title and business address of the official who is 
responsible for the system of records, procedures whereby an individual 
can be notified at his request if the system contains a record 
pertaining to him, procedures whereby an individual can be notified at 
his request how he can gain access to any record pertaining to him 
contained in the system and how he can contest its contents, and 
categories of sources of records in the system. 5 U.S.C. 
Sec. 552a(e)(4).
 There is to be no disclosure of any record about individuals 
maintained in a system of records ``except pursuant to a written 
request by, or with the prior written consent of,'' the subject. 5 
U.S.C. Sec. 552a(b). Importantly, a disclosure need not be public to be 
unlawful; an ``intra-agency'' disclosure may also violate the Privacy 
Act where the disclosure is made to officers or employees who have no 
need for the record in the performance of their official duties. Parks 
v. Internal Revenue Service, 618 F.2d 677 680-81 & n.1 (10th Cir. 
1980); 5 U.S.C. Sec. 552a(b)(1).
 There are limited exceptions to this general rule of non-
disclosure, the most important of which is the ``routine use'' 
exception. 5 U.S.C. Sec. 552a(a)(7). Each type of ``routine use'' must, 
however, be published at least annually in the Federal Register. 5 
U.S.C. Sec. 552a(e)(4)(D). Agencies are required to keep an accounting 
of disclosures. 5 U.S.C. Sec. 552a(c).
 Finally, the Privacy Act provides for civil and criminal sanctions. 
Any officer or employee who willfully discloses subject material in any 
manner to a person or agency not entitled to receive it, shall be 
guilty of a crime and fined not more than $5,000. 5 U.S.C. 
Sec. 552a(i)(1). Any officer or employee of any agency who willfully 
maintains a system of records without meeting the notice requirements 
of subsection (e)(4) also shall be guilty of a crime and fined not more 
than $5,000. 5 U.S.C. Sec. 552a(i)(2).
 FBI background investigation files, such as those at issue in 
``Filegate,'' are admittedly maintained in a system of records by the 
FBI. Consequently, it cannot be questioned that they are covered by the 
Privacy Act. In fact, the FBI admitted as much in Judicial Watch's 
lawsuit. In response to the lawsuit, however, the Clinton White House 
claimed that the Privacy Act did not apply to it. In a Memorandum and 
Order dated June 12, 1997, the Court rejected this claim and confirmed 
that the Privacy Act did, in fact, apply to the White 
House.(15) However, the Privacy Act also makes clear that 
any time a federal official maintains records on individuals that can 
be accessed by reference to an individual's name, the protections of 
the Privacy Act come into play. It does not matter what information is 
stored in the file. To release anything from a covered file--even a 
press clipping--violates the Privacy Act.(16)
III. Factual Background.
 The origins of the Clinton White House's misuse of information in 
government files predate 1993. Former presidential advisor Dick Morris 
admitted that the 1992 Clinton campaign used private investigators, at 
U.S. taxpayers' expense, to obtain private and embarrassing information 
to coerce and extort the silence of women sexually involved with 
President Clinton while he was Governor of Arkansas. The effort was run 
by Betsy Wright, who, at crucial and relevant times, Secret Service 
logs show later visited Craig Livingstone, one of the key players in 
``Filegate,'' at odd hours in the White House.(7)
 Unknown to the public, in 1993 the Clinton White House obtained the 
FBI files of Billy Dale, the former head of the White House Travel 
Office, and Barney Brasseux, a White House Travel Office 
employee.(18) Apparently, these FBI files were obtained by 
the Clinton White House shortly after Mr. Dale, a twenty-year veteran 
of the White House Travel Office, Mr. Brasseux, and several other 
employees of the White House Travel Office were fired by the Clinton 
White House to allow their replacement with personal friends of the 
President and Hillary Rodham Clinton. Mr. Dale was subsequently 
indicted on trumped-up charges of fraud. Later, Mr. Dale was completely 
exonerated of any wrong-doing. He even received an award of attorneys' 
fees for having to defend himself against the baseless charges brought 
against him. It is likely that the reason for indicting Mr. Dale was to 
avoid the appearance that he was fired simply to allow the Clintons to 
bring their personal friends into the White House Travel Office. It is 
also likely that the reason Mr. Dale's and Mr. Brasseux's FBI files 
were obtained was to try to find damaging information about them to 
avoid the appearance of political cronyism in firing them.
 About this same time, numerous press reports were circulating about 
illegal drug use and improper sexual conduct among White House 
staffers. Apparently to counter these and possibly other charges, or to 
retaliate against Reagan and Bush Administration appointees and 
employees for the release of information about President Clinton's 
passport during the 1992 election, the Clinton White House also 
obtained over 900 FBI background investigation files on former Reagan 
and Bush Administration appointees and employees. Surely, this 
information could also be very useful to discredit and destroy 
perceived adversaries, or simply to intimidate them. Among the FBI 
files unlawfully obtained by the Clinton White House were those of some 
prominent individuals, such as former Bush Secretary of State James A. 
Baker (who, not coincidentally, had been involved in the Clinton 
passport controversy), former Bush Press Secretary Marlin 
Fitzwater,(19) Kenneth Duberstein and Tony Blankley, a 
former aide to Speaker Newt Gingrich.(20) The FBI file of 
Ms. Linda R. Tripp, a Bush Administration ``hold-over'' who was 
apparently perceived to be a potential threat at that time, was also 
obtained. Ms. Tripp would later be transferred to the Department of 
Defense and suffer yet another violation of her Privacy Act rights.
 The evidence shows that the Clinton White House knowingly requested 
the FBI files of Republicans ``who were no longer working there.'' 
(21) Mari Anderson, Craig Livingstone's assistant, testified 
to Judicial Watch that she, Livingstone and Anthony Marceca were aware 
that Republicans, such as James Baker and Marlin Fitzwater, no longer 
had access to the White House, but that their FBI files were obtained 
anyway.(22) Anderson also testified that Livingstone 
regularly left their office with FBI files in tow.(23) A 
log, which was to have chronicled any removal of the FBI files to other 
areas in the White House, mysteriously developed a six-month gap, 
reminiscent of the eighteen-minute gap in Richard Nixon's oval office 
tapes.(24)
 While working for Clinton White House Counsel Bernard Nussbaum, 
whose name appears on the requisition forms for the FBI files, Ms. 
Tripp was in a bird's-eye view position to witness the unlawful conduct 
that would later become known as ``Filegate.'' In discussions with 
Judicial Watch, Ms. Tripp admitted to having witnessed FBI files on 
former Reagan and Bush Administration appointees and employees 
``stacked up to the ceiling'' in Assistant White House Counsel William 
Kennedy's office.(25) As reported by Ms. Lucianne Goldberg, 
Ms. Tripp's literary agent and friend, Ms. Tripp also ``witnessed a 
White House secretary loading up FBI files on a computer'' in the White 
House Counsel's Office.(26) Ms. Tripp also told Tony Snow, a 
nationally-syndicated columnist for The Detroit News and commentator 
for the Fox News Channel, that:

 [S]he was shaken by White House dishonesty during 
 investigations of Vince Foster's death, Filegate, Travelgate, 
 and reports of drug abuse among administration employees. 
 ``It's chilling,'' she says, ``to watch high government 
 officials lie under oath.(27)

(Emphasis added). Finally, Ms. Tripp reportedly saw a document 
evidencing Mrs. Clinton's direct involvement in the firings at the 
White House Travel Office.(28)
 In the course of Ms. Paula Corbin Jones' sexual harassment lawsuit, 
President Clinton, through his lawyers, David Kendall, Esq. of Williams 
& Connolly and Robert Bennett, Esq. of Skadden, Arps, Slate, Meagher & 
Flom, hired Terry Lenzoer's private investigation firm, Investigative 
Group International, Inc. (``IGI''), apparently to obtain information 
for use in that lawsuit and elsewhere.(29) Lenzner and IGI 
were later retained to provide similar services for other matters 
involving the President, including the Lewinsky matter. When Judicial 
Watch deposed Lenzner on March 13, 1998, he revealed that Larry Potts, 
a disgraced senior FBI official who allegedly gave the ``shoot on 
sight'' orders at the Ruby Ridge massacre, is ``virtually a partner'' 
of his in running IGI.(30) In addition, Lenzner testified 
that Howard Shapiro, Esq., the former General Counsel of the FBI who 
also left the Bureau in disgrace because of the ``Filegate'' matter, 
serves as IGI's principal attorney.(31) Indeed, Lenzner, a 
former Department of Justice lawyer, has worked closely with the FBI. 
Thus, Lenzner, Potts and Shapiro all had close ties to FBI personnel 
and were in a position to solicit information from inside the FBI. 
Significantly, on March 3, 1998, FBI Director Louis Freeh issued a 
warning to all FBI personnel against providing information to FBI 
alumni and others about the various investigations involving the 
President.(32) Obviously, Director Freeh must have been 
concerned that information in FBI files had been and was being leaked 
to individuals with close ties to the FBI such as Lenzner, Potts and 
Shapiro.
 At his deposition, Lenzner confirmed that he had investigated 
perceived Clinton adversaries, including members of the media, public 
interest groups and even members of the judiciary.(33) 
However, he selectively invoked the ``work product'' doctrine to avoid 
having to answer specific questions about who IGI had 
investigated.(34) Hiding behind the ``skirts'' of David 
Kendall and Robert Bennett, Lenzner asserted the ``work product'' 
doctrine in response to some questions, but tellingly failed to do so 
in response to others. For example, Lenzner testified that he had not 
been asked or retained to investigate Kathleen Willey, but refused to 
state whether he had been retained to investigate Linda Tripp:

 Plaintiffs' Counsel: Have you been approached or retained to 
 investigate . . . Kathleen Willey?
 Lenzner: No.
 Plaintiffs' Counsel: Linda Tripp?
 Lenzner's Counsel: Same privileged objections. Same 
 instruction.
 Lenzner: I will accept my instruction on that.(35)

 The clear implication behind this selective invocation of the work-
product doctrine, however disingenuous those invocations are, was that 
Lenzner, in fact, has been investigating these perceived adversaries of 
the President. A report in the San Francisco Examiner directly linked 
Lenzner to the recent dissemination of private information smearing 
House Judiciary Committee Chairman Henry Hyde.(36) Rather 
than let his private investigators, Lenzner and Potts, answer questions 
in Judicial Watch's ``Filegate'' lawsuit, incredibly, the President has 
sought to intervene personally to prevent this 
questioning.(37)
 When the most recent Clinton scandal involving Ms. Lewinsky broke 
in late January 1998, the Clinton White House again reverted to 
releasing information in government files--and threatening further 
releases--in order to silence and discredit its perceived adversaries. 
During a February 8, 1998 interview, George Stephanopoulos, a former 
top adviser to and continuing confidante of President Clinton, and 
other top advisors in the White House, told a national television 
audience on ABC's This Week with Sam Donaldson and Cokie Roberts that 
there is an ``Ellen Rometsch'' strategy by ``White House allies'' to 
attack perceived adversaries of the Clinton Administration:

 Sam Donaldson: We know what the White House tactics are. I 
 mean, they've been almost open about it. Attack the press--and 
 perhaps with good reason--attack the [I]ndependent [C]ounsel--
 perhaps for some good reason--and stonewall on the central 
 issue, which is the President of the United States. And if he 
 has nothing to hide, why is he hiding?
 George Stephanopoulos: I agree with that. And there's a 
 different, long-term strategy, which I think would be far more 
 explosive. White House allies are already starting to whisper 
 about what I'll call the Ellen Roemech (sic) strategy. . . . 
 She was a girlfriend of John F. Kennedy, who also happened to 
 be an East German spy. And Robert Kennedy was charged with 
 getting her out of the country and also getting John Edgar 
 Hoover to go to the Congress and say, don't you investigate 
 this, because if you do, we're going to open up everybody's 
 closets. And I think that in the long run, they have a 
 deterrent strategy on getting a lot of . . . [FBI files].
 Sam Donaldson: Are you suggesting for a moment that what 
 they're beginning to say is that if you investigate this too 
 much, we'll put all your dirty linen right on the table? Every 
 member of the Senate? Every member of the press corp?
 George Stephanopoulos: Absolutely. The President said he 
 would never resign, and I think some around him are willing to 
 take everybody down with him.(38)

 Historically, the ``Ellen Rometsch'' strategy refers to the late 
FBI Director J. Edgar Hoover's and Attorney General Robert F. Kennedy's 
successful efforts to collect and use FBI files to blackmail Republican 
members of Congress to prevent an investigation into President John F. 
Kennedy's affair with an East German spy, Ellen 
Rometsch.(39) Judicial Watch deposed Stephanopoulos to learn 
the identities of the ``White House allies'' about which he spoke on 
ABC's This Week.(40) However, Stephanopoulos asserted his 
privilege as a ``journalist'' not to reveal confidential 
sources.(41) Judicial Watch recently filed a motion with the 
Court to try again to compel Stephanopoulos to release this 
information.
 Pursuant to this ``Ellen Rometsch'' strategy, the Clinton 
Administration apparently orchestrated the release of confidential 
information from Ms. Tripp's Department of Defense (``DOD'') personnel 
file. On March 23, 1998, The New Yorker magazine published an article 
by Jane Mayer stating that Ms. Tripp had failed to disclose information 
about a twenty-year old arrest on a security clearance 
form.(42) As such, forms are themselves confidential, 
Privacy Act records. Questions thus arose concerning how Ms. Mayer had 
obtained this information. In a March 17, 1998 article entitled 
``Bill's Secret Police,'' Dick Morris questioned the release of this 
information and the implications it had for the Clinton 
Administration's claim that ``Filegate'' was an innocent bureaucratic 
mistake:

 [N]o journalist questioned how Tripp's confidential file 
 ended up in The New Yorker. Instead, all the papers dutifully 
 reported on her arrest and her lack of candor in disclosing it. 
 . . . The White House secret police have struck again. 
 Desperate to discredit Linda Tripp, President Clinton's most 
 damning accuser, the president's men are most likely the ones 
 who delved into confidential Pentagon files to dig up and dish 
 out dirt on Tripp. . . . The release of the Tripp file lends a 
 new credibility to the Republican allegations that the White 
 House's possession of confidential FBI files on GOP leaders and 
 potential adversaries was no ``mistakes'' as the president's 
 men piously claimed. Is Linda Tripp the latest victim of a file 
 dump?(43)(Emphasis added.)

 Accordingly, Judicial Watch began an inquiry into the circumstances 
behind the release of this information, as it was obviously relevant to 
its ``Filegate'' investigation.
 On April 30, 1998, Judicial Watch deposed Clifford Bernath. 
Bernath, Principal Deputy Assistant to the Secretary of Defense for 
Public Affairs, had been publicly portrayed by the Clinton 
Administration as the ``career'' Department of Defense official 
responsible for having released the confidential information in Ms. 
Tripp's personnel file to reporter Jane Mayer. The Clinton 
Administration also portrayed Bernath as having acted alone. At his 
deposition, however, Bernath testified that he was directed to obtain 
and release the information by his superior, Kenneth Bacon, Assistant 
Secretary of Defense for Public Affairs, a Clinton political 
appointee.(44) Bernath testified he told Mayer that Bacon 
``has made it clear it's [the release of the Tripp information] a 
priority,''(45) because Mayer ``was on deadline and whenever 
a reporter is on deadline, we call that a priority.''(46) As 
the Court later noted, Bernath's revelation that he was told to release 
the Tripp information by a Clinton political appointee was understood 
by the Court as conflicting with the Clinton Justice Department's 
statements to the Court that the release was made by a career 
official.(47)
 Judicial Watch then deposed Bacon on May 15, 1998. Bacon testified 
that Mayer initially contacted him about obtaining the information from 
Ms. Tripp's personnel file,(48) and that he then told 
Bernath to search the file to find out whether Ms. Tripp had disclosed 
information about her twenty-year old arrest on her security clearance 
form.(49) Bacon also testified that he ``was very aware of 
what Mr. Bernath was doing and . . . did nothing to stop 
it.''(50) Thus, it was a Clinton Administration political 
appointee, not a career civil servant, who was at the heart of this 
obvious violation of Ms. Tripp's privacy rights.
 This stands in marked contrast to Secretary of Defense William 
Cohen's public statements that Bernath had acted on his own in 
releasing the information.(51) Although Secretary Cohen said 
the release of Ms. Tripp's information was ``certainly inappropriate, 
if not illegal,''(52) neither Secretary Cohen nor the White 
House told the public about the involvement of Bacon or 
others.(53) Secretary Cohen said Bernath ``was responding to 
an inquiry from the press'' without mentioning that a Clinton political 
appointee, Bacon, had directed Bernath to do so.(54) Bacon 
testified that, after Secretary Cohen made his statement on Fox News 
Sunday, he told the Secretary that the statement should be 
corrected.(55) Yet Bacon testified that he was unaware of 
Secretary Cohen ever correcting his statement; nor was he aware of 
either the Department of Defense or the Clinton Administration ever 
acknowledging publicly he was involved in the release of information in 
Ms. Tripp's confidential personnel file.(56) When Judicial 
Watch questioned Bacon about Secretary Cohen's involvement in the 
matter, Clinton Justice Department lawyers instructed him not to 
answer.(57) Judicial Watch has moved the Court to compel 
answers.
 Judicial Watch also learned that, after Bernath's role in the 
release of information in Ms. Tripp's confidential personnel file 
became known publicly, Bernath apparently attempted to destroy evidence 
of his wrong-doing. Specifically, Bernath testified that between April 
1-10, 1998, he deleted all of the files on his computer's hard 
drive.(58) Yet Bacon testified that, by March 17 or 18, 
Bernath told him he ``had asked for a legal review'' of the 
circumstances behind the release.(59) This was confirmed by 
a March 18, 1998 New York Post article in which Pentagon spokesman Lt. 
Col. Dick Bridges is quoted as stating that Bernath had ``requested a 
Pentagon inquiry to examine the propriety of his 
actions.''(60) Therefore, Bernath had deleted potential 
evidence from his computer at a time when he obviously knew that his 
role in the release of information in Ms. Tripp's confidential 
personnel file would be investigated, if it was not being investigated 
already. In commenting on Bernath's deletion of files on his computer, 
the Court stated that ``cause for concern should exist when an upper-
level government employee completely deletes his hard drive when this 
hard drive may have information relevant to an ongoing criminal 
investigation, let alone the instant case,''(61) and ``it is 
highly unusual and suspect for such an action to have been undertaken 
by Bernath when matters relating to Tripp are being investigated by the 
Office of the Independent Counsel.''(62)
 Judicial Watch also discovered that after information in Ms. 
Tripp's confidential personnel file was released, Bernath was given a 
new job at higher pay with, ironically, responsibility for teaching 
about the Privacy Act. Bacon testified that ``sometime during the week 
of March 16th,''(63) he selected Bernath to run the American 
Forces Information Service, which entitled Bernath to grade and pay 
increase.(64) It is reported that in his new job, Bernath 
``has direct control over the Fort Meade school that teaches privacy 
regulations to public affairs officers.''(65) Bacon 
testified that ``I offered him that job because I thought he was the 
best of the three candidates.''(66) It appears far more 
likely that Bernath was being rewarded for his improper conduct.
 Throughout this controversy surrounding the release of information 
in Ms. Tripp's confidential, Department of Defense personnel file, an 
unknown factor was whether there had been White House involvement in 
the release. The key role of Bacon, a political appointee, made that 
link very likely. Judicial Watch then uncovered the release of a list 
of over 1,000 individuals whose FBI background files were unlawfully 
obtained by the Clinton White House.(67) Among the names on 
the list was Ms. Tripp. Consequently, her FBI background file also had 
been obtained by the Clinton White House. As an FBI background 
investigation file would likely contain information on prior arrests, 
this would seem to answer the question of how Jane Mayer, a former 
colleague of Sidney Blumenthal and close friend of the Clintons, knew 
to ask Bacon the precise question of whether Ms. Tripp had disclosed 
any arrests on her security clearance form. Finally, when Judicial 
Watch deposed Clinton advisor Harold Ickes on May 21, 1998, it also 
learned that Ickes had dinner with Bacon and discussed Ms. Tripp and 
Ms. Lewinsky during the period leading up to the release of the 
information in Ms. Tripp's confidential personnel file. This indicates 
a direct link between the Clinton White House and the release of 
information in Ms. Tripp's confidential personnel file in violation of 
her Privacy Act rights, obviously in an attempt discredit and 
intimidate her. Importantly, Ms. Tripp's FBI file was obtained about 
one (1) year after she began to work in the White House Counsel's 
Office Bernard Nussbaum. Did the White House know then that Ms. Tripp 
had the potential to be a whistleblower and thus began gathering 
information to use against her, if necessary? At a press conference on 
the courthouse steps on July 29, 1998, after her Starr grand jury 
testimony, she stated:

 As a result of simply trying to earn a living, I became aware 
 between 1993 and 1997 of actions by high government officials 
 that may have been against the law. For that period of nearly 
 five years, the things I witnessed concerning several different 
 subjects [at the White House] made me increasingly fearful that 
 this information was dangerous, very dangerous, to 
 possess.(68)

 It also appears that, soon after the Lewinsky story became public, 
the White House Counsel's Office requested information from White House 
files on Ms. Tripp, Ms. Willey and Ms. Lewinsky. On June 30, 1998, 
Judicial Watch deposed Terry Good, Director of the White House Office 
of Records Management (``ORM''). Mr. Good testified that, upon request 
of the White House Counsel's office, his office searched its computer 
database for records concerning Ms. Tripp, Ms. Willey and Ms. Lewinsky, 
and retrieved records on all three (3) individuals.(69)
 With regard to Ms. Tripp, Good testified as follows:

 Q: Has any office of the White House or person made a request 
 with regard to information or documentation concerning Linda 
 Tripp?
 A: I believe the counsel's office probably did, yes.
 Q: Who made that request?
 A: I do not know.
 Q: What was that request about?
 A: Again, if I don't remember the request, I can't tell you 
 what it was about. All I can say is it probably was about 
 anything and everything that we might have in our files 
 relating to Linda Tripp.'' (70)
 At about that same time, Representative Gerald Solomon wrote a 
letter to President Clinton asking whether anyone had pulled Ms. 
Tripp's White House files. However, Representative Solomon did not 
receive a response.(71) Representative Solomon cited Good's 
deposition and the President's failure to respond in a recent letter to 
Independent Counsel Kenneth Starr, referring to the matter as a 
``potential obstruction of a Congressional investigation'' and 
``intimidation of a federal witness.'' (72)
 With regard to Ms. Willey, a witness in the Lewinsky investigation, 
evidence indicates that President Clinton was directly involved in the 
violation of her Privacy Act rights in an effort to discredit her and 
harm her reputation. In testifying before the Lewinsky investigation 
grand jury, Ms. Willey accused President Clinton of making an improper 
sexual advance towards her in the White House. Ms. Willey then repeated 
these accusations during a March 15, 1998 television appearance on ``60 
Minutes.'' At his deposition, Good testified that, in response to a 
request from the White House Counsel's Office, ORM searched its files 
for documents concerning Ms. Willey and obtained a handwritten 
letter(s) Ms. Willey wrote to the President.(73) The 
letter(s) was then provided to the White House Counsel's Office, as 
were documents concerning Ms. Tripp and Ms. Lewinsky.(74) 
The letter(s) was then released to the media.(75)
 According to White House Press Secretary Mike McCurry, ``I'm sure 
the President knew that we were putting the letters out and I'm sure 
that he approved.'' (76) In fact, James Carville was forced 
to admit at his March 16, 1998 deposition in Judicial Watch's 
``Filegate'' investigation that President Clinton sought his advice 
about Ms. Willey's letters prior to their release:

 Q: When was the last time you talked to the President?
 A: Saturday.
 Q: Was that in person or by phone?
 A: By phone.
 Q: Who called who?
 A: The President called me.
 Q: And how long was the conversation?
 A: Not very long. Maybe five minutes or so.
 Q: What was discussed?
 * * *
 A: He said that there were some--there was a Kathleen Willey, 
 and what he said was there was some letters that she had 
 written, and they were--his lawyers were considering--I think 
 were considering about making them public, and what did I think 
 about it?
 Q: And what did you tell him?
 A: I'm not sure if I know what's in there, but if it was 
 something that was past the time that she made this allegation, 
 it was probably a pretty good idea.
 Q: Did he ask you to help make them public?
 A: No, sir.(77)

 Former White House Chief of Staff Thomas ``Mack'' McLarty also 
testified in Judicial Watch's ``Filegate'' case that he and the 
President discussed Willey's credibility ``a day or two'' after her 
interview on ``60 Minutes'':

 A: . . . After her ``60 Minutes'' interview, I believe the 
 President commented to me that he thought a mutual friend had 
 made a remark about her credibility was not that high in 
 Richmond. I didn't know the mutual friend. He thought I did. . 
 . .
 Q: Who is the mutual friend?
 A: I don't recall his name. I didn't know him. I think the 
 President thought I did know him, and I just don't--I don't 
 remember who it was. I didn't know the person.(78)

 During his grand jury testimony, the President admitted that Ms. 
Willey's letters were taken from White House files.(79) He 
also admitted that he authorized their release,(80) and 
testified that the letters ``shattered Kathleen Willey's credibility.'' 
(81) Thus, the Good, Carville and McLarty depositions, and 
the President's grand jury testimony directly implicate President 
Clinton in this violation of Ms. Willey's Privacy Act rights in order 
to discredit and harm her reputation, and thereby undermine the 
accusations she had made against the President.
 Carville appears to have played a significant, if not central role 
in misusing information in government files against perceived 
adversaries of the President.(82) When Judicial Watch 
subpoenaed Carville to appear for a deposition in its ``Filegate'' 
investigation, it also required him to produce documents in his 
possession, custody and control.(83) After a prolonged Court 
fight over obtaining the required documents, Carville finally gave in 
and produced voluminous quantities of information in his possession and 
in the possession of his business entity, Education and Information 
Project, Inc. (``EIP''). Included among the documents produced to 
Judicial Watch were facsimiles to Carville from the White House--the 
Chief of Staffs Office the White House Counsel's Office in particular--
enclosing documents on perceived adversaries of the President. These 
documents included information on Independent Counsel Kenneth Starr, 
former FBI Agent Gary Aldrich, philanthropist Richard M. Scaife and 
Republican strategist Donald Sipple.(84) The White House 
Chief of Staffs Office even faxed excerpts from Sipple's divorce 
proceedings to Carville.(85)
 Judicial Watch's review of documents and other materials provided 
by Carville and EIP revealed evidence of other likely attempts to 
destroy and obstruct members of the staff of the Independent Counsel, 
and Judicial Watch has delivered to the Court tape recordings made by 
James Carville in this regard. These Carville tape recordings show that 
Carville was probing into the sexual and personal backgrounds of 
investigators. As the tape recordings evidence potential obstruction of 
justice and other criminality, Judicial Watch informed the Independent 
Counsel of their existence. The Independent Counsel has yet to issue a 
subpoena for the tape recordings.
 Also included among the documents Judicial Watch subpoenaed from 
Carville and EIP was an EIP ``target list'' identifying Independent 
Counsel Kenneth Starr, Speaker Newt Gingrich (indeed, in the September 
27, 1998 edition of NBC's ``Meet the Press,'' Carville admitted he was 
targeting Gingrich), Representative Dan Burton, Senator Fred Thompson 
and former Secretary of Education Bill Bennett as ``Individuals to 
Target'' for ``expos[ing] the motives and methods behind Republican 
partisan attacks against the President and the Democratic 
Party.''(86) At his deposition, Carville also was forced to 
admit that he stays in regular contact with David Kendall, who hired 
Terry Lenzner as the President's private investigator.(87) 
Moreover, former Carville aides and employees--Tom Janenda and Glen 
Weiner--are now staffing the White House opposition research 
office.(88) Based on all of the direct and circumstantial 
evidence obtained thus far, as well as Carville's own repeated threats 
to destroy Clinton adversaries, he appears to be the ``ringleader'' of 
President Clinton's smear operations--in violation of the Privacy Act 
and other laws.
 Carville is apparently not the only Clinton advisor or aide 
misusing information in government files against perceived adversaries 
of the President. Lanny Davis, a ``Special Counsel to the President,'' 
testified at his deposition in Judicial Watch's ``Filegate'' 
investigation that he was hired by the Clinton White House Counsel's 
office and worked closely with that office.(89) That office, 
which helped to orchestrate the unlawful transfer of hundreds of FBI 
files, and, according to Linda Tripp, loaded them onto White House 
computers, is at the very center of egregious violations of privacy 
rights and other unlawful conduct.
 Davis' testimony shows, at the very least, that he unlawfully 
maintained a system of records on notable Clinton adversaries without 
fulfilling the proper notice requirements as mandated by the Privacy 
Act. Davis testified that during his tenure at the Clinton White House, 
he personally maintained files containing information about prominent 
Clinton adversaries, such as Judge Kenneth Starr,(90) 
Senator Fred Thompson,(91) Representative Dan 
Burton,(92) Senator Henry Hyde,(93) Monica 
Lewinsky,(94) Kathleen Willey,(95) and David 
Hale.(96) Davis also maintained files containing information 
about Larry Lawrence, Roger Tamraz, Doris Matsui, Webster Hubbell, Nora 
and Gene Lum, John Huang, Pauline Kachanalak, Johnny Chung, and Charlie 
Trie.(97) Many of these files were identified, either in 
whole or in part, by the individual's name, such as ``Starr,'' ``Monica 
Lewinsky,'' ``Kathleen Willey'' and ``John Huang.''(98) 
Davis also testified that he was ``eclectic'' in his judgment as to 
what to put in such files, and that he would generally include any 
document that he might need to use at some point.(99) Such 
documents included public statements and stories by the 
media.(100) Yet, Davis admitted that the media ``frequently 
does not'' publish accurate information, undoubtedly thanks to his 
assistance.(101)
 Davis admitted that he maintained these files so that he could 
disseminate information to the media and thus help them write ``good'' 
and ``bad'' stories.(102) Yet before Davis released 
information from any of these files to the media, he never consulted 
with anyone referenced in the materials, never sought their permission, 
and knew of no one at the Clinton White House who did 
so.(103) Davis, Ickes and Carville continue to advise the 
Clinton White House on impeachment and other issues,(104) 
and it is likely that they continue to receive information from 
government files.
 Judicial Watch also plans to question others in the White House 
suspected of participating in these unlawful smear operations such as 
Sidney Blumenthal, Rahm Emanuel, Ann Lewis and Mike McCurry.
 In the course of its investigation, Judicial Watch has uncovered 
evidence of possible crimes involving obstruction of justice and abuse 
of power. During his deposition in Judicial Watch's ``Filegate'' 
investigation, Harold Ickes implicated himself, President Clinton and 
others in possible obstruction of justice in the Independent Counsel's 
``Filegate'' investigation. After it was publicly reported that Dick 
Morris had told Sherry Rowlands that Mrs. Clinton was the 
``mastermind'' of ``Filegate,'' Mr. Morris lamely tried to recant in 
having any independent knowledge of Mrs. Clinton's role. Rather, he 
claimed that his comments were based on polling data which reflected a 
public perception that Mrs. Clinton was behind the ``Filegate'' 
scandal. Consequently, the Independent Counsel staff subpoenaed the 
polling data. At his Judicial Watch deposition, Mr. Ickes testified to 
an effort to delay production of this polling data until after the 1996 
elections.(105)
 Finally, Judicial Watch is submitting this interim report for 
Congress' consideration at this time because it has uncovered 
substantial, additional evidence of unlawful conduct in the Clinton 
Administration, and because it appears that, while Independent Counsel 
Kenneth Starr has been given the responsibility to investigate the 
``Filegate'' matter, unfortunately his efforts apparently have been 
devoted almost exclusively to the Lewinsky and Whitewater 
investigations.
 In fact, it would appear the Independent Counsel's investigation of 
``Filegate'' is still at an early stage, if indeed any real 
investigation is being conducted at all.(106) Key 
``Filegate'' witnesses recently deposed by Judicial Watch have yet to 
be questioned by the Independent Counsel about the matter. Thomas 
``Mack'' McLarty, the White House Chief of Staff during the time period 
the FBI files were obtained unlawfully, incredibly testified that he 
was never questioned about ``Filegate'' before a grand jury:

 Q: But you never answered questions concerning Filegate 
 before a Grand Jury, to the best of your knowledge.
 A: To the best of my knowledge and memory, that is 
 correct.(107)

 Likewise, ORM Director Terry Good, who stored FBI files for Craig 
Livingstone for several months, testified that he has ``never been 
interviewed by anybody'' from the Independent Counsel's 
office.(108) Earlier this year, the Independent Counsel 
staff questioned Defendant Hillary Rodham Clinton for only about nine 
(9) minutes on the subject of ``Filegate.'' According to Mandy 
Grunwald, one of the Clintons' friends and media advisors, even Mrs. 
Clinton remarked about the conduct of the Independent Counsel staff in 
questioning her so briefly. Ms. Grunwald testified that Mrs. Clinton 
thought the Independent Counsel staff ``came to the White House for 
what was very little business.''(109)
 Judicial Watch sought to take the deposition of Ms. Tripp on 
September 4, 1998, but the Independent Counsel intervened to try to 
convince the Court to postpone the deposition temporarily. In light of 
the fact that the Independent Counsel's investigation of ``Filegate'' 
appears to be in its preliminary stages only and that no meaningful 
report will likely be forthcoming any time soon, Judicial Watch hopes 
that the Independent Counsel will withdraw its objection and allow Ms. 
Tripp's deposition to go forward without further delay. Judicial Watch 
believes that it is important for the American public to learn what Ms. 
Tripp witnessed while working in the Clinton White House precisely 
because the Independent Counsel's report on ``Filegate'' will not be 
issued any time soon--particularly since Judicial Watch depositions 
confirm that its investigation is seemingly still in an infant state.
 It is also important that the full facts of ``Filegate'' be made 
public at this time because the ``Filegate'' strategy of misusing 
information in government files concerns not just the unlawful 
acquisition of FBI files of former Reagan and Bush Administration 
appointees and employees, but is part of a continuing campaign to smear 
witnesses and obstruct justice in the numerous on-going investigations 
of the President. By smearing, or at least threatening to smear its 
perceived adversaries and critics, the Administration hopes to 
intimidate them and gain their silence. This reaction is most typified 
by the response to Pennsylvania Representative Paul McHale's recent 
call for President Clinton's resignation. When Representative McHale 
subsequently appeared on Rivera Live,(110) one of the prime 
mouthpieces of the President, he was confronted with claims that he had 
misrepresented his military credentials. This type of information 
concerning military credentials would almost surely have come from 
government files, and Judicial Watch will seek discovery on this 
matter. The misuse of information, obstruction of justice and abuse of 
power apparently has become the last line of defense for a severely 
weakened Administration. Judicial Watch is thus providing these 
preliminary results from its ``Filegate'' investigation so that 
Congress can be fully informed at this critical time as it considers 
the future of the Clinton Presidency.(111)"

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