I smiled at her as I shook her hand gently. She had soft hands but a firm handshake. I noticed her thin fingers. I was surprised that while she had probably had a manicure, she wore no nail polish, nothing fancy. 'Yes, ma'am. I know who you are. It's very nice to meet you. I'm sorry we have to meet under these circumstances.'
'So am I.'
She sat back down. She was wearing an expensive dark green suit with a cream-colored silk blouse. She was taller than I had expected. She was probably five- eight. I don't know what I'd expected, probably five-five or so. Her light brown hair was pulled back in a fashionable style, and she looked poised and ready to go.
I pulled out the binders that Rachel had prepared, glanced at my outline, turned to the court reporter, and said, 'Please swear the witness.' The first lady turned toward the court reporter, raised her hand, swore to tell the truth, and turned back to face me.
The first couple of hours of questioning were boring and tedious, by design. I asked her about her background, education, employment, and her work as the first lady. Then about President Adams. I got to hear his whole life's story from childhood to being elected president. In a wrongful-death case, the value of the case is based to a great extent on the earning power of the person who died. Needless to say, a former president has massive earning power, even though few actually take full advantage of it. Aggressively pursuing money is thought to be unseemly for a former president.
The longer he stayed in politics though, the lower his lifetime earnings would be. So if he was likely to get reelected-a point worthy of debate-his earnings would substantially decrease. Only after leaving the presidency would his earnings have dramatically gone up. She might make a claim for book royalties, similar to the $8 million advance that Bill Clinton got for his memoirs, or the $100,000 a pop speaking engagements that Gerald Ford was paid for years. Former presidents could make even more if they served on corporate boards or as advisers to corporations, but most thought that was beneath them. They had lifetime pay at the same salary they earned as president, so anything earned on top of that was simply bonus money. They also had lifetime Secret Service protection and office staff. We tediously covered all that and much more in the deposition.
As we approached lunch, I decided to ask her about the photographs, indirectly. She said she went to all the White House receptions, it was part of her job as first lady. She spoke with everyone, whoever was nearby. She tried to concentrate on the guests of honor, their spouses, assistants, and staff, but talked to numerous people throughout the evening. She liked to circulate and keep the reception flowing and energetic.
'Did you ever have the opportunity to have conversations with Colonel Collins?' I detected a slight hesitation in the first lady's eyes, a sense of danger. Hackett was alerted and stared at me suspiciously. He stopped taking notes.
'Perhaps on occasion, I don't really remember.'
'Well, on December seventeenth, there was a reception for the prime minister of Japan. Do you recall that?'
'Yes.'
'At that reception, at the White House, you spent a good deal of time speaking with Colonel Collins, did you not?'
'I don't really remember that.'
'Do you recall what you were wearing?'
'No, I really don't. My wardrobe is selected by my assistant.'
'Well, regardless of who selected it, do you recall what you were wearing?'
'No, I said I didn't.'
Hackett put up his hand. 'What is the possible relevance of what she was wearing to a reception three months before the accident?'
'You can answer the question.'
'I did.'
'Was the reception loud?'
'Loud?'
'Yes, was there loud music or anything else that would make it difficult to hear others?'
'Not that I recall. I don't recall there being any music at all.'
'Can you explain then how it is that you were whispering in the ear of Colonel Collins on several occasions during that reception?'
She looked shocked. 'I don't remember that being the case. Where'd you hear that?'
'Do you deny it?'
'Deny what?'
'Whispering in Collins's ear during the reception for the prime minister of Japan on December seventeenth.'
'I don't remember doing that and I don't know why I would.
'Did you have any kind of personal relationship with Colonel Collins?'
Hackett yelled, 'This is outrageous! What is the meaning of this?'
'The implications are not as dramatic as you imply, it's a simple question. Did she have any relationship of any kind, even as a fellow coin collector, with Colonel Collins.' I looked back at her. 'Did you?'
'I knew him, as I flew on Marine One many times. When we were in various locations, we would occasionally find ourselves near each other and would converse, but nothing substantial.'
'Did Colonel Collins ever express to you any dislike for the president?'
'No. Absolutely not.'
'Are you aware that he purchased a substantial life insurance policy sixty days before his death?'
'No, I was not.'
'Did you speak with the president on the night of the accident, before he climbed aboard Marine One?'
'Yes, of course.' She shifted uncomfortably in her chair.
Hackett interrupted, 'Is this a good time to stop? It's twelve fifteen and we need to grab lunch if we're going to go beyond the morning.'
Without looking at him I answered, 'We're definitely going to go beyond the morning, and, no, this isn't a good place to stop.'
I asked the first lady, 'You were aware when you spoke with the president that there was a major storm outside, correct?'
'I believe that storm had been going on for a few hours at that point.'
'Did the president tell you why he needed to go to Camp David that night?'
'He said he had an important meeting.'
I paused and waited for her to look at me. 'With whom?'
'I don't know. He didn't say.'
'Did you ask?'
'Yes. I was always asking questions.'
'What did he tell you?'
'He told me it was highly confidential and he couldn't go into it.'
'Have you since determined why he was going to Camp David that evening?'
She looked at Hackett. He said, 'Other than what your counsel may have told you.'
She looked back at me. 'No, nothing other than what my attorney has told me.'
'Did you ask President Adams why it was so important to get there so quickly that he was willing to fly in that storm?'
'Yes, I did. I thought it was unwise to fly.'
'What did he say?'
'He said it was the most important meeting of his presidency.'
I paused and looked at the others in the room, including the Secret Service agents, who were completely expressionless. 'Did he tell you what he meant by that?'
'No.'
'Do you know now?'
She hesitated. 'No.'
21
I SHOULD HAVE noticed that one of Hackett's associates was frantically e-mailing on his BlackBerry during the entire deposition. I actually did notice, but assumed he was taking notes. I was quickly dissuaded of that idea. Several members of the media that had waited in the lobby during the entire procedure pounced on me and asked, 'Did you actually ask the first lady if she was having an affair with the pilot of Marine One? Is that WorldCopter's theory? Do you have any basis for that? Can the first lady sue you for slander?'
I smiled, waved at the press, and walked into the elevator to go down to my car. Several members of the press joined Rachel and me in the elevator, which was particularly awkward and uncomfortable since I didn't say anything. They peppered me with questions throughout the descent. I should have known Hackett would try something like that. He had insisted that the language of the order be extremely specific about how the press was excluded from the deposition in which the room was taken or from any access to the transcript after the deposition. I had expected the testimony to come out somehow. In a case like this, in something this politically volatile, everything will come out. It's just a fact. But I had expected Hackett, or more likely one of his associates, to slip a transcript of the deposition to a reporter, then claim to have no idea how the reporter had gotten it. But with this he had slipped. The press corps, or some of them, had obviously received e-mails from inside the deposition room.
I waited for one of the journalists to step away from the door of my car, then I got in and drove away. As soon as my BlackBerry had reception, my phone rang. It
