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In the view of the Subcommittee, the real story of Ed
Rogers' involvement in the BCCI scandal has yet to
be fully revealed. Rogers, a former White House
Political Director, left his position at the White House
in early August 1991 to start the political consulting
firm of Rogers and Barbour in Washington D.C. By the
end of August Rogers, who had only briefly practiced
law, was offered a $600,000 contract with Kamal

Rogers was deposed by the Subcommittee in March

1992. His account of how he received the contract
with Adham, who he consulted before accepting
Adham as a client, and his relationship to Adham
after withdrawing from the contract, are all called
into question by his telephone logs, documents
provided to the Subcommittee and interviews
conducted by the Subcommittee.

Initial Contacts
Rogers described to the Subcommittee the events
leading up to his representation of Kamal Adham.
According to Rogers, in mid-August after he left the
White House, a friend of his, the General Manager at
the Grand Hotel, Samir Darwisch, called him to tell
him that "his friend Moussa Raphael was in town
looking for lawyers and asked me if I would please
come by the hotel and meet him."(1) Rogers stated
that he knew Darwish from "being around the hotel
and events at the hotel."(2) Rogers said while at the
White House he went to the hotel "once every couple
of weeks." He also explained that the Hotel's owner,
Joe Yazbek, had been to the White House, to discuss
"events in Lebanon" with then White House Chief of
Staff, John Sununu. At some point Rogers learned
that Moussa Raphael was the lawyer for the Mr.
Yazbek's business interests.

Rogers says that when Darwish first called him he did

not mention the name Kamal Adham, but Rogers was
nonetheless sufficiently interested by Darwish's
invitation that he met with Raphael that same night
at the Grand Hotel. According to Rogers, Raphael
"provided a general overview of what was doing here
on behalf of the sheik, in order to organize the
sheik's legal affairs." The general overview included
"the problems that were relevant to the sheik, or First
American, BCCI," and, testified Rogers, at some point
Raphael "must have" identified Plato Cacheris as the
criminal defense lawyer for Adham.(3) In his testimony
Rogers did not indicate whether Raphael discussed
the Sheik's financial affairs in the United States.

After meeting with Raphael, Rogers discussed the

possibility of representing Adham with his partner,
former political director of the Reagan White House,
Haley Barbour. They decided, however, that before
accepting the account, Rogers should get more
information on Adham.

Rogers has provided at least three different accounts

of whom he consulted before accepting the Adham
account. In his letter to White House Counsel Boyden
Gray on October 28, Rogers stated, "Prior to agreeing
to represent Mr. Adham, I made inquiries about him
among former government officials and people in the
private sector who have had dealings in Saudi
Arabia. Invariably those who knew or knew of Mr.
Adham said he was a man of stature and prestige in
the region and that he had the respect of Americans
who had dealt with him in the past."(4)

On December 18, 1991, Rogers was contacted by

Subcommittee staff concerning prospective
testimony to the Subcommittee. During the
conversation, Rogers indicated that he "checked out
Adham with a guy who does business in the Middle
East, checked him out with a widely respected former
government official, and finally talked to two other
former government officials." Rogers claimed that
each of these contacts urged him to take the
account, noting that with his experience he would
not be getting offers from non-controversial entities
like "Quaker Oats."(5)

In his deposition with the Subcommittee, Rogers

indicated that he only contacted Sam Bamieh, a
businessman and Sandra Charles, a mid-level former
NSC and Defense Department staffer. Rogers
explained the discrepancies in the following way:
"Perhaps as I prepared that [his letter to Boyden
Gray] I used those two people as plural, but I don't
have any recollection of talking to other people."(6)

Sam Bamieh
Although there is some difference of opinion between
Rogers and White House Counsel Boyden Gray as to
exactly when in early August Rogers left the White
House, Rogers' office phone logs at Rogers and
Barbour indicate that on August 5th, he placed a
phone call to Mr. Sam Bamieh at Intertrade Group in
San Mateo, California. According to Mr. Gray, Rogers
officially left the White House on August 6, the day
after phone records show Rogers called Bamieh.

Sam Bamieh is someone whom Rogers has indicated

that he spoke with concerning the advisability of
taking on the Adham account. Bamieh is a well know
Palestinian-American businessman with strong ties to
the Republican party and to various individuals in the
Middle East, including the Saudi Royal family.
According to press reports, in the late 1970's Bamieh
financed the trip of Ruth Carter Stapleton, President
Carter's sister, to the Middle East. During the 1980's
Bamieh testified on several occasions before the US
Congress on issues related to the Middle East.(7)

According to Rogers he met Bamieh during the 1988

campaign because "he was a friend of Lee Atwater's
who I worked for."(8) Rogers told subcommittee staff
that while he was at the White House he spoke on
the telephone to Bamieh on a regular basis,
indicating "There was no pattern to it, but monthly."(9)

However, shortly after he left the White House,

Rogers was in frequent contact in with Bamieh
placing calls to him on August 5,13,14,15,16,26,28
and attending a party at his house in San Mateo,
California on August 27 which Bamieh hosted for
Adnan Khashoggi.

Rogers could not explain his frequent contact with

Bamieh, other than to say that he and Bamieh were
friends and "It would not be unusual for him to
call."(10) Rogers did not say why he was calling Bamieh
on such a regular basis. According to Bamieh, who
was interviewed on the telephone by staff on two
separate occasions, he wanted Rogers to come to
work for him. But in his deposition, Rogers stated
that he could not recall discussing possible
representation of Bamieh and said that neither was
he "soliciting business."

Rogers meeting with Khashoggi at a party hosted by

Bamieh is of particular interest to the Subcommittee
because of Khashoggi's ties in the Middle East,
including reported business dealings with Adham,
and his role in BCCI. Khashoggi had accounts with
BCCI in France and used those accounts to move
millions of dollars for financing US arms sales to Iran.

The Subcommittee learned of the Bamieh party for

Khashoggi from Bamieh: Mr Rogers did not offer this
information at his pre-deposition interview by
Subcommittee staff. When asked under oath, Rogers
told the Subcommittee that at Bamieh's party he
only engaged in "social chit-chat" with Khashoggi
and did not discuss Adham.(11) He described his
conversation as "just a few polite moments -- a
couple of minutes at the most."(12) Rogers testified
that "there were several other people" at the party.(13)
In fact, besides Rogers and his wife, Bamieh invited
only a dozen people to meet Khashoggi.(14) Bamieh
also contradicted Rogers when he told Subcommittee
staff that Rogers did discuss Adham with Khashoggi.
Moreover, Bamieh claims that when Rogers first
called him to discuss Adham, Bamieh told him that
representing Adham "would be a political mistake",
but he promised to find out more about the Sheik.
When asked with whom he checked, Bamieh said

Sandra Charles
The other person with whom Rogers claims to have
discussed Kamal Adham was Sandra Charles, a
former staffer on the National Security Council who
left the White House at approximately the same time
Rogers did in order to work for the International
Planing and Analysis Center, a consulting firm
headed by Frank Carlucci, the former Deputy Director
of the CIA and Secretary of Defense. Like Bamieh,
Charles had a background in the Middle East.(16)

Charles checked her calendars and told the

Subcommittee that she first talked to Rogers on
August 26 when he indicated that he was being
considered as one of a team of advisors to Sheik
Kamal Adham. She told Subcommittee staff that
Rogers identified Adham to her as a "former chief of
Saudi intelligence."(17) (Rogers can not remember
from whom or when he learned that Adham was a
former chief of Saudi intelligence) Charles told
Rogers that she didn't know much about Adham, but
that she would try to gather information and report
back to him. According to Charles, she then called "a
Saudi diplomatic source at the embassy" who
confirmed that Adham was a former head of Saudi
intelligence, that he was related by marriage to the
former king, and that he was a wealthy businessman.
Her source also told her that Adham had a very
close relationship to Sadat and that he was man of
great status in the Middle East.(19)

According to Rogers, he later asked Charles to set up

a meeting for him with Frank Carlucci to discuss
whether or not Mr. Carlucci's firm could act as
"financial advisors" to Sheik Adham. The meeting
took place on October 7, 1991 and, according to
Rogers, Carlucci told him "[w]e don't manage
finances. We don't manage people's money. We do
things on a deal-by-deal basis."(20) That, testified
Rogers, was the extent of the meeting.

Rogers' Trips To the Middle East

Rogers did not ultimately decide to accept the
Adham account until he and Haley Barbour actually
met with Adham. On August 31, the two political
operatives flew to Jeddah where, according to
Rogers, they had three days of meetings with the
Sheik's legal and financial advisors. Although he had
dinner with Adham one evening, Rogers implied to
the Subcommittee that the trip was all work: he
never discussed his friend Sam Bamieh or his
acquaintance Adnan Khashoggi with the Sheik.
According to Rogers, near the end of their three day
stay, Adham made him an offer. In his deposition,
Rogers explained why he believes he was hired:

Mr. Pilcher. [Office of Senator Brown] When you go to

talk to somebody ....How do you sell yourself. What is
it that you say about your firm that is interesting?

Mr. Rogers. That we are two lawyers. I am of counsel

to a 120 person firm that provides a broad array of

Mr. Pilcher. What do you consider your personal

specialty? When you say broad array of experience,
what expertise in particular o you have?

Mr. Rogers. Managing other people's affairs.

Managing other people's problems, managing other
people's business.

Mr. Pilcher. My mother-in-law is like that, but what do

you mean exactly by it?

Mr. Rogers. When people present me with a problem,

I like to think that they can turn their back on it. They
can tell me what the problem is and they'll know that
I'll know how to go about my business to organize
their affairs and do things on their behalf.

Mr. Pilcher. When this particular case was brought to

you, what specific problem did you see that you
thought you might be able to solve?

Mr. Rogers. An organizational problem. A large

business concern that needed a lot of different kinds
of representation.

Mr. Pilcher. Meaning BCCI?

Mr. Rogers. Meaning Sheik Adham, not BCCI.

Rogers' counsel in the deposition explained to

Subcommittee staff that "[i]t's hard for him to say
what he was doing since it had a very short life."(21)
Nevertheless, the Subcommittee finds it odd that Mr.
Rogers who represented Sheik Adham for over two
months and met with him and his advisors for
several days at a time in the Middle East, could be so
vague about his duties.

After Rogers returned to the United States, he wrote

Sheik Adham thanking him for the opportunity to join
his legal team. One week later he received a
$136,000 down payment on his $600,000 contract.
And ten days later he registered with the Justice
Department as a foreign agent, indicating that his
work on behalf of Adham might "border on political."
In his deposition, Rogers acknowledged that his
representation of Sheik Adham related to "the Sheik's
problems with the Feds."(22) Moreover, Rogers
provided the Subcommittee with copies of letters
written by Cacheris concerning the investigations
being conducted by the US Federal Reserve and the
Manhattan District Attorney's Office.(23) Rogers
received these letters only days before flying to Cairo
to meet with the Sheik. These events appear to
contradict other Rogers testimony that his
agreement with Sheik Adham specified that "matters
regarding criminal investigations didn't come to me
for any type of management participation."(24)

Rogers had two more meetings with the Adham legal

and financial team. At the end of September he flew
to Cairo, stopping over in London at the Four Seasons
--Inn on the Park, where BCCI regularly hosted
important clients. Rogers would not discuss with the
Subcommittee the substance of any of his meetings
in Cairo with Adham or his "legal or financial
advisors" citing attorney-client privilege.
Rogers flew to Cairo with Plato Cacheris, the
prominent Washington criminal defense attorney for
Sheik Adham. By this time, of course, both the Justice
Department and the Manhattan District Attorney had
communicated with Adham their concern over his
involvement with BCCI, particularly as it related to
the Sheik's "holdings" in First American Bank. With no
background in business, in criminal law, or in any
facet of the law for that matter, the 33 year old
Rogers must have accompanied Cacheris for one
reason only: his political skills and access.

Rogers returned to the Middle East one more time to

meet with the Sheik in mid-October in Jeddah. On
this trip, Rogers met briefly on two occasions with
David Eisenberg of the Justice Department. According
to Rogers, "[h]e [Eisenberg] came into the room to
meet with the Sheik. I walked out and we shook
hands."(25) Rogers testified that he met Eisenberg the
next morning in a "virtual identical encounter."(26)
Robert Mueller, the Assistant Attorney General,
provided a similar account of events several months
earlier in testimony before the Subcommittee.(27)

Rogers Resigns Account -- The White House

On October 23, the story of Rogers's representation
of Adham was reported in the press. Two days later,
President Bush, in a press conference, said that he
didn't know what Ed Rogers "is selling," and that "he
didn't know anything about the man."(28) From the
President's comments it was unclear whether or not
he was referring to Rogers or Adham, but, in fact, he
appears to know both men reasonably well. In his
deposition, Rogers testified that he sat in on
meetings with the President "on numerous
occasions."(29) In an interview with the Middle East
News Network, Kamal Adham, who was head of Saudi
intelligence during the same years that President
Bush headed the CIA, stated:

[t]here was a period of overlap, but whatever the

case it is not possible for a President to say that. The
next day, nobody mentioned the White House
spokesman came out and said that the President
knows Mr. Adham and he did not like what was
written in the papers..."(30)
Shortly thereafter Rogers reportedly resigned the
Adham account, writing to Boyden Gray:
I registered [with the Justice Department] out of an
abundance of caution. The ethics atmosphere at the
Bush White House was to go the extra mile to assure
that no one could ever say any ethics requirement
was violated or avoided. I followed this philosophy
and registered, as I did not want anyone to say that I
should have registered but did not do so.
Unfortunately, going beyond the requirements of the
law has resulted in an embarrassing spate of stories
for my client, the Administration and me.(31)

Responding to Congressman's Charles Schumer's call

for an investigation of the matter, Counsel Gray
purported to mount an inquiry. However, Gray never
met with Rogers. Instead, two of Grays's assistants,
with whom Rogers was "friendly" called him on the
telephone two times each to discuss the matter.(32)
According to Rogers, the conversations lasted ten to
fifteen minutes each. On November 1, 1991, Gray
wrote Congressman Schumer that "Mr. Rogers was
not responsible for and did not participate in any
matters concerning to BCCI at the White House."(33)
The question, however, is not only whether Rogers
had access to information on BCCI at the White
House, but whether or not he began the process of
negotiating his contract with Adham while he was at
the White House. On this point, Rogers provided
conflicting and confusing testimony:

Mr. McKean. [staff of Senator John Kerry] He [Moussa

Raphael] was here in March. Did you meet with him
Mr. Rogers. Mr. Raphael?
Mr. McKean. Yes.
Mr. Rogers. Yes.
Mr. McKean. You met with in March of 1991?
Mr. Rogers. Oh,no, I'm sorry. I thought you meant --
this is March now.
Mr. McKean. Right.
Mr. Rogers. No, I thought you meant -- I have met
with him since this whole thing blew up.(34)
Later in the deposition Rogers also denied having
met with Raphael in March, 1992 and after the
deposition his counsel wrote the Subcommittee
indicating that "Mr. Rogers did not meet with Mr.
Raphael in March 1991 or in March 1992."(35) Hotel
records indicate that Raphael stayed at the Grand
Hotel in March 1991, but not in March 1992. It seems
plausible that Rogers could have met Raphael in
March 1991: Rogers told the Subcommittee that he
gave his notice to the White House in January and
Adham needed help as the Federal Reserve Board
had just issued a cease and desist order to First
American concerning its status vis a vis BCCI. The
most logical time for Adham to have sought political
influence and access was March 1991.(36)

Continued Contacts
Rogers ostensibly resigned the Adham account in
October, although he will not reveal whether or not
he returned his retainer to Sheik Adham. Rogers'
counsel has told the Subcommittee that Rogers' fees
are a confidential matter.(37)

During the month of November 1991 Rogers

continued to work on the Adham account in so far as
he provided assistance to other lawyers for Adham
who assumed his responsibilities. He also continued
to meet with Moussa Raphael. According to Rogers:

"I met with him to finalize and hand over matters we

were working on, specifically on the trust, then I met
with him one more time subsequently to that, just -- I
dropped by the Grand Hotel to say hello. He asked
me to. He was worried about me."(38)

Subsequent to Rogers' deposition, his lawyer wrote

the Subcommittee that the last time his client met
with Mr. Raphael was in December 1991, or January
of this year. However, as recently as April, the
Subcommittee has learned that Raphael was calling
Rogers' office.(39)

Ed Rogers is not a major player in the BCCI scandal,

but his involvement with Sheik Adham is illustrative
of how the bank tried to buy influence in order to
ameliorate its problems. Rogers is neither an
experienced businessman nor a prominent lawyer:
rather, he is political operative who achieved
significant political influence and access by the age
of 33, and who sought to "cash in" on those political
skills. The story he provided to the Subcommittee of
how he came to represent one the most important
figures in the BCCI scandal is shallow and
unconvincing, but the greater failing and more
worrisome aspect in the Rogers affair may be that of
the White House inquiry. The columnist William
Saffire predicted in November 1991 that the Boyden
Gray, charged by the President to investigate the
Rogers affair, would "pass along the denials and the
White House whitewash will continue."(40) There is
nothing in the record that suggests Mr. Saffire's
assessment was inaccurate.
1. S. Hrg. 102-350 Pt.4, p.935. Subcommittee staff
met with Darwish and talked to him on the
telephone. His account of how Moussa Raphael met
Rogers is essentiaally the same as Rogers' account.
According to Darwish, Raphael asked the hotel
executive if he knew any good lawyers," and Darwish
recommended Rogers. Despite the similarlity of
accounts, the Subcommittee is skeptical of his story:
Rogers had virtually no legal experience and Moussa
Raphael was well acquainted with Adham's criminal
lawyer, Plato Cacheris, who presumedly had better
contacts in Washington's legal establishment than
the general manager of the Grand Hotel.
2. Rogers told the Subcommittee that there
Republican political events at the Grand Hotel.
Darwish told the Subcommittee that he knew Senate
Majority leader George Mitchell well (Senator Mitchell
is of Lebanese extraction), but that he did not know
and, in fact, had never even met Governor Sununu
(also of Lebanese extraction).
3. Id. p.935.
4. Letter to C. Boyden Gray, Counsel to the President,
from Ed Rogers, October 28, 1991.
5. Memo to Files, From Jonathan M Winer,
Conversation with Ed Rogers, December 18, 1991.
6. S. Hrg. 102-350, pt. 5,p.944.
7. According to press reports, in 1987, Bamieh told
the House Foreign Affairs Subcommittee on Africa the
-- In November 1981, prince Fahd, who later became
the king, told Bamieh that he was pleased Congress
had agreed to sell AWACS surveillance planes to the
kingdom. In exchange for AWACS, Fahd said, "We will
help you guys fight anti-communist movements,"
according to Bamieh.
--In 1983 [Prince] Bandar asked Bamieh if he would
go into business with Richard V. Secord and Albert
Hakim to bid on a security project at a Saudi airport.
Secord and Hakim were key figures in the plan to
channel money from the sale of US weapons to Iran
to the Contra rebels fighting Nicaragua's leftist
government. The business relationship was never
cemented because the three never got the contract.
-- In 1983, Saudi officials asked Bamieh to funnel
money to Morocco for the training of UNITA guerrillas.
The Saudis said former CIA Director William Casey
was aware of the plan, Bamieh said.
-- In February 1984, Bandar approached Bamieh in
Cannes, France, asking him to set up an offshore
company that would supply goods and services to
anti-communist movements and oil to South Africa.
Bandar aid he declined, even though Bandar said,
"Don't worry about the legalities" because Casey was
discussing the matter with King Fahd.
Another newspaper article reported on Bamieh's
statements about the Iran Contra affair:
An American businessman with extensive ties to
Saudi Arabia's royal family contends King Fahd was
the chief financier of Iran's secret US weapons
purchases in 1985 and 1986.

Sam Bamieh, a naturalized American citizen, said in

an interview with United Press International Tuesday
that Fahd was hoping to gain favor with Ayatollah
Ruhollah Khomeini to ward off possible threats to
Saudi security.
Investigators of the Iran-Contra scandal have
concluded Iran paid about $30 million for the arms,
at prices double or triple the Pentagon's cost, and
about $3.5 million of the profits were diverted to the
Nicaraguan Contra rebels.
The reason they paid those high prices was because
the money wasn't theirs," he said of the Iranians.
Bamieh, of San Mateo, California, said he based his
assertion that Fahd paid for the arms on statements
made to him by confidants of Fahd and international
arms dealer Adnan Khashoggi and on dealings and
on dealings made in his presence by Khashoggi.
Khashoggi, a Saudi Arabian who investigators have
found played a significant role in financing the early
US arms shipments to Iran, was serving as Fahd's
emissary in the deals, Bamieh said.
Finally, Bamieh is quoted in the press on the CIA's
involvement in an assassination attempt of a high
ranking Lebanese official:
Top secret CIA reports in 1985, conflicting with author
Bob Woodward's recent assertions, said Syria
masterminded an assassination attempt against a
radical Moslem leader without agency cooperation,
U.S. intelligence officials say.
But California businessman Sam Bamieh, who
describes himself as a former close friend of Saudi
King Fahd, said he has evidence of reports of Syria's
involvement were part of a Saudi cover story and
that Woodward's report in his new book is largely
Woodward, an assistant managing editor at the
Washington Post, described the unsuccessful attempt
to kill Hezbolah leader Sheik Fadahllah, whose
organization bombed several American facilities in
Lebanon in his book, "Veil: The Secret Wars of the CIA
in 1981-1987."
8. S. Hrg. 102-350, pt. 5. p.937.
9. Id. p.938.
10. Id. p.941.
11. Id. p.939.
12. Id. p.945.
13. Id. p.939.
14. Invitation list. 8/27/91. Provided by Sam Bamieh.
15. telephone interview with Mr. Bamieh, 2/10/92.
Bamieh also told staff that he had met Adham on two
occassions: once in 1975 for about ten minutes and
then again in December, 1991. According to Bamieh
he was staying at the Hilton in Cairo when Adham
called and asked for a meeting. According to Bamieh,
Adham "wanted to get things off his chest."
16. According to a recent article in the New York
The Bush Administration today confirmed reports
that Saudi Arabia engaged in unauthorized transfers
of American made military equipment to Iraq, Syria
and Bangladesh.
Administration officials said, however, that they had
brought these unauthorized transfers to the attention
of both Saudi Arabia and the Congress, as required
by law, and had been told by the Saudis that the
shipments were "inadvertent."
Sandra Charles, the former director of Middle East
and South Asia affairs at the Defense Department in
1986, and she recalled that the Saudis had gone out
of their way to alert Washington about the
inadvertent. Other officials, though, say it was
American military officials in Saudi Arabia who first
detected the transfer.
"It was a small number," Miss Charles said. "It was
not considered significant. The bombs were in a
warehouse with equipment for other countries."
She said she not recall whether Washington pressed
Riyadh to get the bombs back, adding, "It just didn't
seem very consequential at the time.

17. telephone conversation with Sandra Charles,

18. Id.
19. telephone conversation with Sandy Charles,
20. S. Hrg. 102-250, pt. 5. p.943.
21. Id. p.950.
22. Id. p.942. When asked if he was discussing his
representation of Sheik Adham with Mr. Bamieh,
Rogers replied, "Never, I wouldn't have discussed any
matters relating to the Sheik's problems with the
23. see letter to John Moscow, Deputy Chief
Investigations, New York Country District Attorney's
Office, from Plato Cacheris, September 25, 1991 and
letter to J. Virgil Mattingly, General Counsel, Federal
Reserve from Plato Cacheris, September 26, 1991.
24. S. Hrg. 102-250. pt. 5. p. 950.
25. Id. p.943.
26. Id.
27. S. Hrg. 102-350. pt.3. p.800.
28. Transcript, White House Press Conference,
President Bush, 10/25/91.
29. S. Hrg. 102-350. pt. 5. p.933.
30. "A Victim of Operation Overkill by West, Says
Adham." Middle East News Network, 1/18/92.
31. letter to C. Boyden Gray, Counsel to the
President, from Ed Rogers, October 28, 1991.
32. Id. p.946.
33. letter to Congressman Charles Schumer from C.
Boyden Gray, Counsel to the President, November 1,
34. Id. p. 941.
35. Id. p.931.
36. William Safire, columnist for the New York Times,
speculated that the relationship arose in another
This same Sununu toady helped organize the
meeting on May 23 that founded the Arab American
Council, an oil backed elite lobbying group scorns
broader-based Arab-American organizations. Mr.
Sununu and the Syrian Ambassador were stars of the
gathering; out of Lebanese contacts made there or
later, I presume, came Mr. Roger's huge contact.
see "BCCI and Sununu", by William Safire, The New
York Times, November 28, 1991, p.25.
It is worth noting that Sam Bamieh is a member of
the Arab-American Council and that Mr. Bamieh
acknowledges contacts with Mr. Sununu when
Sununu was Chief of Staff at the White House and
37. staff conversation with Jonathan Schiller, 8/20/92.
38. Id. p. 941.
39. phone records of Moussa Raphael at The Grand
Hotel, subpoenaed by the Subcommittee.
40. Safire, p.25.