1. Oi A Of the f act: that-- 4 Q That your off ice had requested and received Bis. 5 for individuals who at that time in fact were not current.

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1 175 t 1 House, or anyone else, for that matter, learning of that. 2 fact? 3 A Of the f act: that-- 4 Q That your off ice had requested and received Bis 5 for individuals who at that time in fact were not current. 6 passholders? 7 A No.. 8 Q Are you familiar with the security tracking 9 system? 10 A Yes. 11 Q We've had prior witnesses tell us a little bit 12 about it, so I.don't think we need to go into the.details, ( 13 but r ao have one question, which is: Do you know whether 14 the holdover employees' information would have been entered 15 into the security tracking system? 16 A At the time that we had that informa ion inputted- 17 Q Which would have been- can you tell us when? 18 A The summer of '94, I believe.it was. 19 Q Okay. :20 A The information--if I remember correctly-- 21 Q Are you sure it's '94? 22 A Whenever Erin Bertucci was an intern in the 23 office. 24 Q Okay. We can check that. 25 A That's when it was. lllf M:lN co..cc. 50 C Suc. N.E. 'Wuletan, O.C «:2. w.. i; Oi3267

2 176 l Q That's when you first started filling in the 2 security tracking system. 3 A That computer system. 4 Q That had been all wiped out. 5 A Yes, it was completely bl nk. 6 Q Okay. So whenever this person was in the office, 7 okay. 8 A Yes. Well, I take that back. It was not 9 completely blank. It was completely blank as far as the 10 White House end of it was concerned. The Chuck Easley 11 Off ice of Adminis tration security tracking system had no t 12 been wiped out. That was still current. 13 The system, the way that we had Erin do it, was 'to 14 simply take ea ch drawer and each file in that drawer from A 15 to z -- and Tony kept.his updates and Nancy kept her updates 16 separate --from A to Z were to be put into that security 17 tracking system. And the poor girl had to sit in front of 18 the computer from the time she got there to the time she 19 left, or at least she was supposed to sit in. front of the 20 computer and put this inforiation in. 21. Q So would individuals inyolved with Project Update,. 22 would their files have been inputted or not?. 23 A Their files should not have been inputted. Their,,,.. 24 i 25 files should have been separate. Now, if one or two of them had been inputted, I'm not aware of it....m ll'tq CO., INC. :S7 C Su=. N.E. w. o.c ll _

3 177 :t l. Q Okay. We'll end where we started. I started the 2 whole thing by asking you about your background. We got up 3 to the White House, and then we ve been mucking around in 4 all that stuff for several hours now. s Can you tell us--you de cribed us you've been 6 involved in events, including the Olympics. Can yo tell us 7 what your employment or other activity has been since the 8 Olympic Committee involvement? 9 A I haven't had time to look 'for another job since 10 the Olympics ended. I didn't end with the Olympics until 11 the 11th of August, and everybody started calling me 1.2 thereafter. 13 Q Okay. So at the present moment,.you're not 14 employed? 15 A At the present moment, that would be correct. 16 MR. HIRSHLA: I' have no further questio ns. 1.7 David, do you? 18 MR. SCHAZER: No. l9 MR. HIRSHL: Thanks very \lluch for taking the 20 time to come and speak with us. I think w can go off the 2J. record now. 22 (Whereupon, at 6:20 p.m., the deposition was 23 concluded.] *-.B ca IN ')7 C Se. N.E. "'iat. 0.C. loooz t:z

4 CERTIFICATE OF NOTARY PUBLIC I, DONALD J. JACOBSEN, the offcer before whom the foregoing deposrtion-was.. taken, do hereby testify that the witness whose testiony appears in the foregoing deposition was duly swo by me; that the testimony of said witn_ess was taken by me stenograpbically and thereafter reduced to tyewriti : g under my direction; that said deposition is a tre record of the testimony given by said witness; that I am neither counsel for, related to, nor em ployed by and of the parties to the action in which this deposition was taken; and further, th at I an not a relative or _employee of ariy a orney or counsel employed by the parties hereto nor 'financially or otherwise interested in the outcome of the action. Notary Public in and for the District of Columbia My commission expires: November 30, '0

5 ....,.._.. _,,,.,. MERAOM FOR Mr. Qi l liam B:. c=obos, BU:din. M4lla..g'er ' Uh ite House Field Office, General Services Administration FROt: D: Craig Livingstone Director t;ite Souse Personnel Securit1 I Backgound Re-Investigations - Please review thi s list of CSA.employees, and advise this office of their current s tus, with the ite Bouse. If they have left the ite Souse, it would be very helpful if you would provi de the date of separation. Of tho se subjects whose last backgound investigation was in , ple.se provide them with an SF-86 packet to be completed and returned to this office. LA BI ACCS BARIL, MICHAEL PHILIP 8/17/88 G BEE, JAMS EDQARD 6 /24 /88 G BROW, JAMES 3/11 /88 G \. INGRIED MARNE S/16/89 c FORTIN, CRESENCIO OBISCO 9/30/87 c GREN, EVA BARMON 8/ 12 / 88 c.tac DARRELL CLEVELAND 12/22/88. c I.IS, ALN LEROY 8/24/88 G MClNZIE., OQEN CORLE 717/88 G SPENCER, DANA I IAH 10/20l80 G 'r, ARTE START c '1I'r, GEVA.. 9/4/89 a VILtINS, SEILA MAIE 12/7/88 a VII.. t.aymond MAURICE 8/17/88 c YINCATE, STVEN ANR.t; 9/15/89 G 11m mnm11001mmimm H CGE l.. Cl Ar'i::', "" P'S OP XHIBIT 1.1. I 111/1f''.: OJ nc- 129z o 1-a.2I1

6 TO: Bob Manzanares, N. M: o. Craig Livingstone, Dir ctor White House Security SUB.ECT: Background Investigations and Re-Investigations Please review this list of NSC related subj ects, and advise this office of the statu, with NS. If they ave left NSC, it would be helpful for our files to contain the da te of seperation. Of those subjects whose last background investigation was in i9as, please have them fill out an SF-86 packet. LAT BI: AGENCY ADDIS, Scot.Alan 7 Oct 1987 N-RM 397 ANDRE, Timothy Duane 9 Jun l.988 N BAKE, Kyle Duane (FBI STATE BI SEN TO HER 9/10/93} N., I BALDWIN, John S. 10/30/83 N BARRY, Kevin Gerard 8 Mar 1988 N ELLA, Ra1ph Carter Listed in the Book Pg l. N ITG, \ William Frederick 11. Dec 1987 N...,INSKI, C:::harlene Co nstance 1.6 Aug 1988 N. ''..... BRIGGS, Everett Ellis No date N. BRINTNALL, Clarke Mccurdy 24 Aug 1988 N BROOKS, Linton Forrestall 2.9 Jul 1988 N BROOME, Richard Earl 29 Jul 1988 N. BROWNE, Barbara Eicher 24 Nov 1986 N BUN H, Susan Grant 27 Oct 1986 N CHERS, Charles Wade 4 May l.987.n CHES, Snadra Lea. 6 Oct l.988 N CHES, Lance William J Apr l.986 N CHELLIS, Craig Sanford No Date N CHILDRESS, Richard Thomas 23 Sep N -. ffalt I roft4<: J; PAGE l. \ Q) ;fxo '17 tjt:i

1 o 13 2.o J. 1 THE WIT ESS: Uh-huh. MR. SCHAZER: To your knowledge, was that done ;LO. 11 THE WITNESS: To my knowledge, ye s.

1 o 13 2.o J. 1 THE WIT ESS: Uh-huh. MR. SCHAZER: To your knowledge, was that done ;LO. 11 THE WITNESS: To my knowledge, ye s. 10 1 THE WIT ESS: Uh-huh..2 MR. SCHZER: nd there was some sort of attempt 3 to segregate out of all.these files that had been requested, 4 all the backgrounds that had been requested? Was there 5 effort