THE COURT: Mr. McDaniel?
MR. McDANIEL (attorney for Susan McDougal): Yes, Your Honor.
THE COURT: Do you need a break?
MR. McDANIEL: I'm not going to be very long, Your Honor. At your will, we can either proceed or at the conclusion of my questioning, I will defer.
THE COURT: All right. Why don't you proceed?
MR. McDANIEL: Thank you, Your Honor.
Good afternoon, Mr. President.
MR. CLINTON: Good afternoon, Mr. McDaniel.
MR. McDANIEL: We have been introduced, and I'm Bobby McDaniel, and along with Jennifer Horan, the federal public defender, represent Susan McDougal. And in that regard, I would like to ask you, do you know Susan?
MR. CLINTON: I do.
MR. McDANIEL: Can you tell us, sir, when and how did you meet Susan?
MR. CLINTON: I met Susan through her relationship with Jim, I met them before they married, and if my memory serves me right, I think he taught a course at Ouachita University in Arkadelphia, and I believe she was a student there, I think that's how they met. But anyway, we met, therefore, it would have been somewhere either in the late '60s or the early '70s, some time in that area.
MR. McDANIEL: All right, sir. To get right to the point, Mr. President -
MR. CLINTON: And let me -
MR. McDANIEL: All right, sir.
MR. CLINTON: Also, they invited me to their wedding, I remember that, it was outside out in west Little Rock some place, or west of Little Rock some place, and I remember being there.
MR. McDANIEL: All right, sir. And as I say, to get right to the point, Mr. President, did you ever request David Hale to make a loan to Susan McDougal?
MR. CLINTON: No, sir, I did not.
MR. McDANIEL: Mr. President, did you ever in any way try to pressure David Hale directly or indirectly, to make a loan to Susan McDougal?
MR. CLINTON: I did not pressure David Hale to do that.
MR. McDANIEL: All right, sir. And I want to focus for a minute on a time frame late 1985, early 1986, and again, we represent separate defendants, and it may be cumulative, but bear with me, I will be brief. Were you aware of any alleged agreement whereby - involving Susan McDougal and David Hale, involving loans that would be made with Madison Guaranty in exchange for loans being made for David Hale's company? Did you have any knowledge of any such agreement, if it existed?
MR. CLINTON: If it did exist, I didn't know anything about it.
MR. McDANIEL: Mr. President, likewise, in reference to that same time frame, early '85 - late '85, early '86, were you aware of any alleged agreement involving Jim Guy Tucker, Jim McDougal, David Hale, or Susan McDougal, involving Madison Guaranty loans in exchange for loans from David Hale's company?
MR. CLINTON: No, sir.
MR. McDANIEL: Were you aware in 1986 that on April 3rd, 1986 David Hale's small business investment company, Capital Management Services, made a $300,000 loan to Susan McDougal doing business as Master Marketing? Were you aware of that in 1986?
MR. CLINTON: No, Mr. McDaniel, I was not.
MR. McDANIEL: Mr. President, did you ever discuss a $300,000 loan to Susan McDougal with David Hale in any way?
MR. CLINTON: I did not.
MR. McDANIEL: Mr. President, did you urge David Hale to make any such loan?
MR. CLINTON: No.
MR. McDANIEL: Did you ever discuss a $300,000 loan to Susan McDougal from David Hale with Jim McDougal?
MR. CLINTON: No.
MR. McDANIEL: Did you ever discuss a $300,000 loan to Susan McDougal from David Hale with Susan McDougal?
MR. CLINTON: I did not.
MR. McDANIEL: Did you receive any of the proceeds from a $300,000 loan made to Susan McDougal by David Hale's company?
MR. CLINTON: I did not receive any proceeds, sir.
MR. McDANIEL: When, if you know, did you first become aware that Susan McDougal did receive a $300,000 loan from David Hale's company, if you know?
MR. CLINTON: I believe it was when it broke in the press, when there were reports in the press, whenever that was, when was it, '92, '93, whenever.
MR. McDANIEL: Okay. MR. McDANIEL: But I didn't know anything about it before then.
MR. McDANIEL: Mr. President, in 1986, were you aware that Jim and Susan McDougal were buying land in south Pulaski County from International Paper Realty Company for a project, real estate development project, later to be known as Lorance Heights? Were you aware of that in 1986?
MR. CLINTON: No, sir. The only thing I knew about was what I testified, I stopped in on 145th Street at Mr. McDougal's office, in a suit, it is too far to jog, and that's all I know. I don't know where they got that property, I didn't know if they had any other property, I don't know where they got that.
MR. McDANIEL: All right, sir. And were you aware in 1986, for a few months' period of time during that year, that Lorance Heights property was held in the name of Whitewater Development Company? Were you aware of that in 1986?
MR. CLINTON: No, sir. In 1986, I did not know that.
MR. McDANIEL: Were you aware, also, in 1986 that later in that year the Lorance Heights land was transferred out of Whitewater Development Company into another McDougal company? Were you aware of that, its going on?
MR. CLINTON: No, sir. Since I didn't know it was ever in there in the first place, when it left, I was not aware of that, either.
MR. McDANIEL: All right, sir. And did you know in 1986 how the McDougals financed the purchase of the land later known as Lorance Heights?
MR. CLINTON: No, sir, I did not.
MR. McDANIEL: Did you know in 1986 where the McDougals got the funds for the down payment for this land from International Paper?
MR. CLINTON: No.
MR. McDANIEL: Were you aware that in the late 1980s there was litigation involving the McDougals and International Paper Company whereby International Paper eventually took back this land?
MR. CLINTON: No, sir.
MR. McDANIEL: When did you -
MR. CLINTON: I don't remember knowing about that, either, in the 1980s. I don't believe I knew anything about that.
MR. McDANIEL: When did you first find out, if you know, that Whitewater Development Company briefly held title to this land known as Lorance Heights?
MR. CLINTON: When that information appeared in the press, whenever that was. It was either in late - in '92 or '93, sometime in that time frame, that information appeared in public, and that's how I became aware of it.
MR. McDANIEL: Your Honor, as has previously occurred, and to Mr. President a thank you. I have no further questions.
FORWARD: Cross-Examination by the Prosecutor, Ray Jahn