Until June 11, 1980, I had not met with or talked to Billy Carter, although we may have been introduced to one another at a State dinner in December 1979.

On the afternoon of June 11, I received a telephone message from Dr. [Zbigniew] Brzezinski asking if I could come to his office. When I arrived he was meeting with Billy Carter and he introduced me. I cannot recall everything that was said, but the substance was as follows. Dr. Brzezinski said he had asked me to join the meeting as soon as he had heard from Billy Carter about its subject. Billy Carter said he had been interviewed that morning by a Justice Department lawyer or lawyers conducting an investigation under the Foreign Agents Registration Act. He said he had been asked to describe every contact he had had with anyone in the White House concerning Libya. He said that before giving a full answer he wanted to consult Dr. Brzezinski about whether there was any national security objection to describing to the Justice Department his efforts to arrange a November 1979 meeting at Dr. Brzezinski's request with Ali Houderi, the highest Libyan official in Washington, for the purpose of requesting the government of Libya to urge the authorities in Iran to release the hostages. This meeting and its aftermath are described in Dr. Brzezinski's statement.

This was my first knowledge of these events. I asked Dr. Brzezinski whether he saw any national security objection to Billy Carter's disclosure to the department of his role in this meeting and the arrangements preceding it. He said he saw no objection. I agreed. We then advised Billy Carter that he could inform the department. I added that, as his lawyer had probably informed him, he had a legal obligation to respond fully to the department's questions. At that point he said he did not have a lawyer advising him on this matter. I expressed surprise, and stated my opinion that it was of critical importance for anyone being interrogated by law enforcement officals about a possible violation of law to retain his own lawyer to advise him as to his rights and duties and to represent him in the matter. I asked if he had a regular lawyer whom he might consult in the matter. He said his regular lawyer practiced in Americus, Ga. and would not be experienced in matters of this type. He asked if I had any suggestions. I recommended four or five lawyers in Washington, including Steven Pollak and Henry Ruth of the firm of Shea & Gardner.

I mentioned that Mr. Pollak and Mr. Ruth had advised Hamilton Jordan on the cocaine-use charge last fall. Billy Carter indicated a preference for Mr. Pollak and Mr. Ruth and asked if I could introduce him. I then took him upstairs to my office and put in a call to Mr. Pollak. . . . Within a few minutes he called back and after a brief explanation I introduced him over the telephone to Billy Carter. They made an appointment to meet later that afternoon, and immediately thereafter Billy Carter left my office. I have not seen or talked to him since.

At no time until after the complaint and consent judgment were filed in court did I have any contact or communication with the attorney general or anyone else in the Department of Justice concerning its investigation of Billy Carter or the disposition of the matter.

On June 12 I telephoned Mr. Pollak to inqure whether he was representing Billy Carter. He said he was. I asked whether he or Mr. Ruth or Billy Carter had advised the Justice Department of the November 1979 meeting with Dr. Brzezinski and a Libyan official . . . My reason for raising this matter with Mr. Pollak was that, having heard from Billy Carter on June 11 that the Department of Justice was inquiring into any contact between Billy Carter and the White House about Libya, I wanted to be sure that Justice was informed about the November 1979 meeting.

At some time on June 12 or 13, at the close of a larger meeting on another subject, I informed the president of my meeting with Dr. Brzezinski and Billy Carter on June 11, my recommendation to Billy Carter that he obtain counsel, and the fact that he had retained Mr. Pollak and Mr. Ruth. I had no further communication with the president concerning Billy Carter until June 26.

On June 17, 1980, I met with the president and the attorney general to discuss a number of proposed judicial appointments. At the end of this discussion, the attorney general said he had some other matters to take up privately with the president and I left. I did not learn of the subject matter of this conversation until the evening of July 24, when .. the president read me his note of it. . . .

On June 26 I called Mr. Pollak . . . Mr. Ruth told me that the department was insisting that Billy Carter file a registration statement and was setting a deadline at close of business on June 27. He also told me that the department had been informed of the November 1979 meeting and had expressed no interest. Based on this conversation, I wrote a memorandum which I sent to the president that evening.

On Monday, June 30, I called Mr. Ruth to inquire what had happened to the deadline. He replied that the deadline had been extended to the close of business on Tuesday, July 1. He told me that Billy Carter was still considering whether or not to file a registration statement. Mr. Ruth said he was unwilling to predict whether Billy Carter would. I said I was reflecting on whether to suggest to the president that, if he thought it would be useful, he might call his brother and urge him to register in his own interest and make a full disclosure as the department was insisting. Mr. Ruth said he had no advice on whether such a call should be made. On the basis of this conversation I wrote . . . to the president on the morning on July 1.

Later that morning the president informed me that he had called his brother, who seemed to be receptive, and that the call may have done some good . . . On the morning of July 11 Anchorage time (five hours behind Washington time) I called my office and found that Mr. Pollak and Mr. Ruth were trying to reach me. When I telephoned them they told me they were in the final stages of negotiations with the department concerning the filing of a complaint, consent judgment, and registration statement. They said that before filing the registration statement they wanted to corroborate Billy Carter's statement to them that he had never discussed any specific U.S. policy or action toward Libya with the president. They asked if I had checked or could check this point with the president. I said that from my earlier conversations with the president I felt sure this was correct, but that I would try to check again. . . . I then talked with the president on Sapelo Island [Ga.]. He confirmed to me that Billy Carter had never discussed with him any specific U.S. policy or action toward Libya. I then called back Mr. Ruth and confirmed my earlier statement. . . .

He . . . said that the court papers would include a disclosure of two substantial payments to Billy Carter, one in January 1980 of $20,000 and one in April 1980 of $200,000. He said the payments were loans, but that there was no documentation for the loans . . . I said this was the first I had known of any such payments. I said I felt sure the president had not known about them. I asked [Jody] Powell to inform [the president] by the time the court papers were actually filed and a White House comment might be requested . . .

Later on the 14th, I had occasion to call the attorney general on an unrelated matter. . . . After we disposed of our other business, I mentioned to him that the complaint and judgment in the Billy Carter case had been filed that morning. I said that I had just advised the White House press office, if it were questioned on the point, that I believed there had been no contact between the Justice Department and the White House in either direction concerning the conduct of the investigation. He confirmed that this was correct. . . .

On the evening of the 24th, the president called me and said he had just been through [his personal notes] and wanted to read some of them to me. He read several to me and then came to one relating to a conversation he said he had completely forgotten. He then read to me the note of the attorney general's June 17 conversation with him about Billy. He asked me to review this and the other notes the next morning and to show the June 17 note to the attorney general, so that his recollection could be checked as well. It was implicit in our discussion that prompt disclosure of the conversation would be made.

Later that evening Mrs. Cutler and I attended a dinner at the Austrian Embassy. The attorney general was present. During that evening I took the attorney general aside and told him what the president had said to me about just having found and read a note of the June 17 conversation which the president had forgotten. The attorney general immediately confirmed that there had been such a conversation and described it substantially as the president had in the note he read to me. . . .