"No," Walsh answered. "The purpose was to say the allegation was made. The allegation was not correct ... "
Later, after repeatedly asking Walsh how a criminal history would be relevant to Miller's claims of assault, Hoffman asked Walsh whether any evidence had been uncovered suggesting Miller had a record.
"Were you told by a single person that Ms. Miller had a criminal conviction?" Hoffman asked.
"I was told that she had engaged in activities that could be illegal," Walsh said.
"That's not my question," Hoffman responded. "My question is: Did anybody tell you that Ms. Miller had a criminal conviction?"
"Not that I recall," Walsh said. "But some of the issues raised
During the deposition, Walsh also was questioned about a heretofore undisclosed e-mail sent to a television news organization by another campaign official an hour before Walsh's e-mail was sent out. The earlier e-mail, though only three sentences, specifically refers to "the criminal record of Rhonda Miller" and includes an attachment of court records that have no connection to the Miller who accused Schwarzenegger of assault.
It was not until the next day, Walsh said in his deposition, that campaign officials were able to check the court records and determine that they did not relate to the Miller who had made the allegations.
In written responses to questions posed by Miller's attorneys, Schwarzenegger said he had no specific recollection of Miller before the election. Schwarzenegger also said he did not know about Miller's accusations against him until an election eve news conference where she alleged he had assaulted her during the 1991 filming of "Terminator 2" and again in 1994 during the filming of "True Lies."
After Miller's accusations became public, according to the governor's written responses, he had at least one discussion with a campaign communications official about her allegations but did not give anyone on his political staff specific instructions on how to respond to Miller's claims.
Likewise, according to the governor, he had no role in disseminating the controversial e-mail, which recommended that reporters check Miller's name against an Internet database of Los Angeles Criminal Court records.
Hoffman said in an interview Thursday that Walsh's deposition showed that the campaign had committed libel.
