I. Nature of President Clinton's

                     Relationship with Monica Lewinsky

A. Introduction

This Referral presents substantial and credible information that President
Clinton criminally obstructed the judicial process, first in a sexual
harassment lawsuit in which he was the defendant and then in a grand jury
investigation. The opening section of the Narrative provides an overview of
the object of the President's cover-up, the sexual relationship between the
President and Ms. Lewinsky. Subsequent sections recount the evolution of
the relationship chronologically, including the sexual contacts, the
President's efforts to get Ms. Lewinsky a job, Ms. Lewinsky's subpoena in
Jones v. Clinton, the role of Vernon Jordan, the President's discussions
with Ms. Lewinsky about her affidavit and deposition, the President's
deposition testimony in Jones, the President's attempts to coach a
potential witness in the harassment case, the President's false and
misleading statements to aides and to the American public after the
Lewinsky story became public, and, finally, the President's testimony
before a federal grand jury.

B. Evidence Establishing Nature of Relationship

1. Physical Evidence

Physical evidence conclusively establishes that the President and Ms.
Lewinsky had a sexual relationship. After reaching an immunity and
cooperation agreement with the Office of the Independent Counsel on July
28, 1998, Ms. Lewinsky turned over a navy blue dress that she said she had
worn during a sexual encounter with the President on February 28, 1997.
According to Ms. Lewinsky, she noticed stains on the garment the next time
she took it from her closet. From their location, she surmised that the
stains were the President's semen.(1)

Initial tests revealed that the stains are in fact semen.(2) Based on that
result, the OIC asked the President for a blood sample.(3) After requesting
and being given assurances that the OIC had an evidentiary basis for making
the request, the President agreed.(4) In the White House Map Room on August
3, 1998, the White House Physician drew a vial of blood from the President
in the presence of an FBI agent and an OIC attorney.(5) By conducting the
two standard DNA comparison tests, the FBI Laboratory concluded that the
President was the source of the DNA obtained from the dress.(6) According
to the more sensitive RFLP test, the genetic markers on the semen, which
match the President's DNA, are characteristic of one out of 7.87 trillion
Caucasians.(7)

In addition to the dress, Ms. Lewinsky provided what she said were
answering machine tapes containing brief messages from the President, as
well as several gifts that the President had given her.

2. Ms. Lewinsky's Statements

Ms. Lewinsky was extensively debriefed about her relationship with the
President. For the initial evaluation of her credibility, she submitted to
a detailed "proffer" interview on July 27, 1998.(8) After entering into a
cooperation agreement, she was questioned over the course of approximately
15 days. She also provided testimony under oath on three occasions: twice
before the grand jury, and, because of the personal and sensitive nature of
particular topics, once in a deposition. In addition, Ms. Lewinsky worked
with prosecutors and investigators to create an 11-page chart that
chronologically lists her contacts with President Clinton, including
meetings, phone calls, gifts, and messages.(9) Ms. Lewinsky twice verified
the accuracy of the chart under oath.(10)

In the evaluation of experienced prosecutors and investigators, Ms.
Lewinsky has provided truthful information. She has not falsely inculpated
the President. Harming him, she has testified, is "the last thing in the
world I want to do."(11)

Moreover, the OIC's immunity and cooperation agreement with Ms. Lewinsky
includes safeguards crafted to ensure that she tells the truth.
Court-ordered immunity and written immunity agreements often provide that
the witness can be prosecuted only for false statements made during the
period of cooperation, and not for the underlying offense. The OIC's
agreement goes further, providing that Ms. Lewinsky will lose her immunity
altogether if the government can prove to a federal district judge -- by a
preponderance of the evidence, not the higher standard of beyond a
reasonable doubt -- that she lied. Moreover, the agreement provides that,
in the course of such a prosecution, the United States could introduce into
evidence the statements made by Ms. Lewinsky during her cooperation. Since
Ms. Lewinsky acknowledged in her proffer interview and in debriefings that
she violated the law, she has a strong incentive to tell the truth: If she
did not, it would be relatively straightforward to void the immunity
agreement and prosecute her, using her own admissions against her.

3. Ms. Lewinsky's Confidants

Between 1995 and 1998, Ms. Lewinsky confided in 11 people about her
relationship with the President. All have been questioned by the OIC, most
before a federal grand jury: Andrew Bleiler, Catherine Allday Davis, Neysa
Erbland, Kathleen Estep, Deborah Finerman, Dr. Irene Kassorla, Marcia
Lewis, Ashley Raines, Linda Tripp, Natalie Ungvari, and Dale Young.(12) Ms.
Lewinsky told most of these confidants about events in her relationship
with the President as they occurred, sometimes in considerable detail.

Some of Ms. Lewinsky's statements about the relationship were
contemporaneously memorialized. These include deleted email recovered from
her home computer and her Pentagon computer, email messages retained by two
of the recipients, tape recordings of some of Ms. Lewinsky's conversations
with Ms. Tripp, and notes taken by Ms. Tripp during some of their
conversations. The Tripp notes, which have been extensively corroborated,
refer specifically to places, dates, and times of physical contacts between
the President and Ms. Lewinsky.(13)

Everyone in whom Ms. Lewinsky confided in detail believed she was telling
the truth about her relationship with the President. Ms. Lewinsky told her
psychologist, Dr. Irene Kassorla, about the affair shortly after it began.
Thereafter, she related details of sexual encounters soon after they
occurred (sometimes calling from her White House office).(14) Ms. Lewinsky
showed no indications of delusional thinking, according to Dr. Kassorla,
and Dr. Kassorla had no doubts whatsoever about the truth of what Ms.
Lewinsky told her.(15) Ms. Lewinsky's friend Catherine Allday Davis
testified that she believed Ms. Lewinsky's accounts of the sexual
relationship with the President because "I trusted in the way she had
confided in me on other things in her life. . . . I just trusted the
relationship, so I trusted her."(16) Dale Young, a friend in whom Ms.
Lewinsky confided starting in mid-1996, testified:

[I]f she was going to lie to me, she would have said to me, "Oh, he calls
me all the time. He does wonderful things. He can't wait to see me." . . .
[S]he would have embellished the story. You know, she wouldn't be telling
me, "He told me he'd call me, I waited home all weekend and I didn't do
anything and he didn't call and then he didn't call for two weeks."(17)

4. Documents

In addition to her remarks and email to friends, Ms. Lewinsky wrote a
number of documents, including letters and draft letters to the President.
Among these documents are (i) papers found in a consensual search of her
apartment; (ii) papers that Ms. Lewinsky turned over pursuant to her
cooperation agreement, including a calendar with dates circled when she met
or talked by telephone with the President in 1996 and 1997; and (iii) files
recovered from Ms. Lewinsky's computers at home and at the Pentagon.

5. Consistency and Corroboration

The details of Ms. Lewinsky's many statements have been checked,
cross-checked, and corroborated. When negotiations with Ms. Lewinsky in
January and February 1998 did not culminate in an agreement, the OIC
proceeded with a comprehensive investigation, which generated a great deal
of probative evidence.

In July and August 1998, circumstances brought more direct and compelling
evidence to the investigation. After the courts rejected a novel privilege
claim, Secret Service officers and agents testified about their
observations of the President and Ms. Lewinsky in the White House. Ms.
Lewinsky agreed to submit to a proffer interview (previous negotiations had
deadlocked over her refusal to do so), and, after assessing her credibility
in that session, the OIC entered into a cooperation agreement with her.
Pursuant to the cooperation agreement, Ms. Lewinsky turned over the dress
that proved to bear traces of the President's semen. And the President, who
had spurned six invitations to testify, finally agreed to provide his
account to the grand jury. In that sworn testimony, he acknowledged
"inappropriate intimate contact" with Ms. Lewinsky.

Because of the fashion in which the investigation had unfolded, in sum, a
massive quantity of evidence was available to test and verify Ms.
Lewinsky's statements during her proffer interview and her later
cooperation. Consequently, Ms. Lewinsky's statements have been corroborated
to a remarkable degree. Her detailed statements to the grand jury and the
OIC in 1998 are consistent with statements to her confidants dating back to
1995, documents that she created, and physical evidence.(18) Moreover, her
accounts generally match the testimony of White House staff members; the
testimony of Secret Service agents and officers; and White House records
showing Ms. Lewinsky's entries and exits, the President's whereabouts, and
the President's telephone calls.

C. Sexual Contacts

1. The President's Accounts

a. Jones Testimony

In the Jones deposition on January 17, 1998, the President denied having
had "a sexual affair," "sexual relations," or "a sexual relationship" with
Ms. Lewinsky.(19) He noted that "[t]here are no curtains on the Oval
Office, there are no curtains on my private office, there are no curtains
or blinds that can close [on] the windows in my private dining room," and
added: "I have done everything I could to avoid the kind of questions you
are asking me here today. . . ."(20)

During the deposition, the President's attorney, Robert Bennett, sought to
limit questioning about Ms. Lewinsky. Mr. Bennett told Judge Susan Webber
Wright that Ms. Lewinsky had executed "an affidavit which [Ms. Jones's
lawyers] are in possession of saying that there is absolutely no sex of any
kind in any manner, shape or form, with President Clinton." In a subsequent
colloquy with Judge Wright, Mr. Bennett declared that as a result of
"preparation of [President Clinton] for this deposition, the witness is
fully aware of Ms. Lewinsky's affidavit."(21) The President did not dispute
his legal representative's assertion that the President and Ms. Lewinsky
had had "absolutely no sex of any kind in any manner, shape or form," nor
did he dispute the implication that Ms. Lewinsky's affidavit, in denying "a
sexual relationship," meant that there was "absolutely no sex of any kind
in any manner, shape or form." In subsequent questioning by his attorney,
President Clinton testified under oath that Ms. Lewinsky's affidavit was
"absolutely true."(22)

b. Grand Jury Testimony

Testifying before the grand jury on August 17, 1998, seven months after his
Jones deposition, the President acknowledged "inappropriate intimate
contact" with Ms. Lewinsky but maintained that his January deposition
testimony was accurate.(23) In his account, "what began as a friendship
[with Ms. Lewinsky] came to include this conduct."(24) He said he
remembered "meeting her, or having my first real conversation with her
during the government shutdown in November of '95." According to the
President, the inappropriate contact occurred later (after Ms. Lewinsky's
internship had ended), "in early 1996 and once in early 1997."(25)

The President refused to answer questions about the precise nature of his
intimate contacts with Ms. Lewinsky, but he did explain his earlier
denials.(26) As to his denial in the Jones deposition that he and Ms.
Lewinsky had had a "sexual relationship," the President maintained that
there can be no sexual relationship without sexual intercourse, regardless
of what other sexual activities may transpire. He stated that "most
ordinary Americans" would embrace this distinction.(27)

The President also maintained that none of his sexual contacts with Ms.
Lewinsky constituted "sexual relations" within a specific definition used
in the Jones deposition.(28) Under that definition:

[A] person engages in "sexual relations" when the person knowingly engages
in or causes -- (1) contact with the genitalia, anus, groin, breast, inner
thigh, or buttocks of any person with an intent to arouse or gratify the
sexual desire of any person . . . . "Contact" means intentional touching,
either directly or through clothing.(29)

According to what the President testified was his understanding, this
definition "covers contact by the person being deposed with the enumerated
areas, if the contact is done with an intent to arouse or gratify," but it
does not cover oral sex performed on the person being deposed.(30) He
testified:

[I]f the deponent is the person who has oral sex performed on him, then the
contact is with -- not with anything on that list, but with the lips of
another person. It seems to be self-evident that that's what it is. . . .
Let me remind you, sir, I read this carefully.(31)

In the President's view, "any person, reasonable person" would recognize
that oral sex performed on the deponent falls outside the definition.(32)

If Ms. Lewinsky performed oral sex on the President, then -- under this
interpretation -- she engaged in sexual relations but he did not. The
President refused to answer whether Ms. Lewinsky in fact had performed oral
sex on him.(33) He did testify that direct contact with Ms. Lewinsky's
breasts or genitalia would fall within the definition, and he denied having
had any such contact.(34)

2. Ms. Lewinsky's Account

In his grand jury testimony, the President relied heavily on a particular
interpretation of "sexual relations" as defined in the Jones deposition.
Beyond insisting that his conduct did not fall within the Jones definition,
he refused to answer questions about the nature of his physical contact
with Ms. Lewinsky, thus placing the grand jury in the position of having to
accept his conclusion without being able to explore the underlying facts.
This strategy -- evidently an effort to account for possible traces of the
President's semen on Ms. Lewinsky's clothing without undermining his
position that he did not lie in the Jones deposition -- mandates that this
Referral set forth evidence of an explicit nature that otherwise would be
omitted.

In light of the President's testimony, Ms. Lewinsky's accounts of their
sexual encounters are indispensable for two reasons. First, the detail and
consistency of these accounts tend to bolster Ms. Lewinsky's credibility.
Second, and particularly important, Ms. Lewinsky contradicts the President
on a key issue. According to Ms. Lewinsky, the President touched her
breasts and genitalia -- which means that his conduct met the Jones
definition of sexual relations even under his theory. On these matters, the
evidence of the President's perjury cannot be presented without specific,
explicit, and possibly offensive descriptions of sexual encounters.

According to Ms. Lewinsky, she and the President had ten sexual encounters,
eight while she worked at the White House and two thereafter.(35) The
sexual encounters generally occurred in or near the private study off the
Oval Office -- most often in the windowless hallway outside the study.(36)
During many of their sexual encounters, the President stood leaning against
the doorway of the bathroom across from the study, which, he told Ms.
Lewinsky, eased his sore back.(37)

Ms. Lewinsky testified that her physical relationship with the President
included oral sex but not sexual intercourse.(38) According to Ms.
Lewinsky, she performed oral sex on the President; he never performed oral
sex on her.(39) Initially, according to Ms. Lewinsky, the President would
not let her perform oral sex to completion. In Ms. Lewinsky's
understanding, his refusal was related to "trust and not knowing me well
enough."(40) During their last two sexual encounters, both in 1997, he did
ejaculate.(41)

According to Ms. Lewinsky, she performed oral sex on the President on nine
occasions. On all nine of those occasions, the President fondled and kissed
her bare breasts. He touched her genitals, both through her underwear and
directly, bringing her to orgasm on two occasions. On one occasion, the
President inserted a cigar into her vagina. On another occasion, she and
the President had brief genital-to-genital contact.(42)

Whereas the President testified that "what began as a friendship came to
include [intimate contact]," Ms. Lewinsky explained that the relationship
moved in the opposite direction: "[T]he emotional and friendship aspects .
. . developed after the beginning of our sexual relationship."(43)

D. Emotional Attachment

As the relationship developed over time, Ms. Lewinsky grew emotionally
attached to President Clinton. She testified: "I never expected to fall in
love with the President. I was surprised that I did."(44) Ms. Lewinsky told
him of her feelings.(45) At times, she believed that he loved her too.(46)
They were physically affectionate: "A lot of hugging, holding hands
sometimes. He always used to push the hair out of my face."(47) She called
him "Handsome"; on occasion, he called her "Sweetie," "Baby," or sometimes
"Dear."(48) He told her that he enjoyed talking to her -- she recalled his
saying that the two of them were "emotive and full of fire," and she made
him feel young.(49) He said he wished he could spend more time with
her.(50)

Ms. Lewinsky told confidants of the emotional underpinnings of the
relationship as it evolved. According to her mother, Marcia Lewis, the
President once told Ms. Lewinsky that she "had been hurt a lot or something
by different men and that he would be her friend or he would help her, not
hurt her."(51) According to Ms. Lewinsky's friend Neysa Erbland, President
Clinton once confided in Ms. Lewinsky that he was uncertain whether he
would remain married after he left the White House. He said in essence,
"[W]ho knows what will happen four years from now when I am out of office?"
Ms. Lewinsky thought, according to Ms. Erbland, that "maybe she will be his
wife."(52)

E. Conversations and Phone Messages

Ms. Lewinsky testified that she and the President "enjoyed talking to each
other and being with each other." In her recollection, "We would tell
jokes. We would talk about our childhoods. Talk about current events. I was
always giving him my stupid ideas about what I thought should be done in
the administration or different views on things."(53) One of Ms. Lewinsky's
friends testified that, in her understanding, "[The President] would talk
about his childhood and growing up, and [Ms. Lewinsky] would relay stories
about her childhood and growing up. I guess normal conversations that you
would have with someone that you're getting to know."(54)

The longer conversations often occurred after their sexual contact. Ms.
Lewinsky testified: "[W]hen I was working there [at the White House] . . .
we'd start in the back [in or near the private study] and we'd talk and
that was where we were physically intimate, and we'd usually end up, kind
of the pillow talk of it, I guess, . . . sitting in the Oval Office . . .
."(55) During several meetings when they were not sexually intimate, they
talked in the Oval Office or in the area of the study.(56)

Along with face-to-face meetings, according to Ms. Lewinsky, she spoke on
the telephone with the President approximately 50 times, often after 10
p.m. and sometimes well after midnight.(57) The President placed the calls
himself or, during working hours, had his secretary, Betty Currie, do so;
Ms. Lewinsky could not telephone him directly, though she sometimes reached
him through Ms. Currie.(58) Ms. Lewinsky testified: "[W]e spent hours on
the phone talking."(59) Their telephone conversations were "[s]imilar to
what we discussed in person, just how we were doing. A lot of discussions
about my job, when I was trying to come back to the White House and then
once I decided to move to New York. . . . We talked about everything under
the sun."(60) On 10 to 15 occasions, she and the President had phone
sex.(61) After phone sex late one night, the President fell asleep
mid-conversation.(62)

On four occasions, the President left very brief messages on Ms. Lewinsky's
answering machine, though he told her that he did not like doing so because
(in her recollection) he "felt it was a little unsafe."(63) She saved his
messages and played the tapes for several confidants, who said they
believed that the voice was the President's.(64)

By phone and in person, according to Ms. Lewinsky, she and the President
sometimes had arguments. On a number of occasions in 1997, she complained
that he had not brought her back from the Pentagon to work in the White
House, as he had promised to do after the election.(65) In a face-to-face
meeting on July 4, 1997, the President reprimanded her for a letter she had
sent him that obliquely threatened to disclose their relationship.(66)
During an argument on December 6, 1997, according to Ms. Lewinsky, the
President said that "he had never been treated as poorly by anyone else as
I treated him," and added that "he spent more time with me than anyone else
in the world, aside from his family, friends and staff, which I don't know
exactly which category that put me in."(67)

Testifying before the grand jury, the President confirmed that he and Ms.
Lewinsky had had personal conversations, and he acknowledged that their
telephone conversations sometimes included "inappropriate sexual
banter."(68) The President said that Ms. Lewinsky told him about "her
personal life," "her upbringing," and "her job ambitions."(69) After
terminating their intimate relationship in 1997, he said, he tried "to be a
friend to Ms. Lewinsky, to be a counselor to her, to give her good advice,
and to help her."(70)

F. Gifts

Ms. Lewinsky and the President exchanged numerous gifts. By her estimate,
she gave him about 30 items, and he gave her about 18.(71) Ms. Lewinsky's
first gift to him was a matted poem given by her and other White House
interns to commemorate "National Boss Day," October 24, 1995.(72) This was
the only item reflected in White House records that Ms. Lewinsky gave the
President before (in her account) the sexual relationship began, and the
only item that he sent to the archives instead of keeping.(73) On November
20 -- five days after the intimate relationship began, according to Ms.
Lewinsky -- she gave him a necktie, which he chose to keep rather than send
to the archives.(74) According to Ms. Lewinsky, the President telephoned
the night she gave him the tie, then sent her a photo of himself wearing
it.(75) The tie was logged pursuant to White House procedures for gifts to
the President.(76)

In a draft note to the President in December 1997, Ms. Lewinsky wrote that
she was "very particular about presents and could never give them to anyone
else -- they were all bought with you in mind."(77) Many of the 30 or so
gifts that she gave the President reflected his interests in history,
antiques, cigars, and frogs. Ms. Lewinsky gave him, among other things, six
neckties, an antique paperweight showing the White House, a silver tabletop
holder for cigars or cigarettes, a pair of sunglasses, a casual shirt, a
mug emblazoned "Santa Monica," a frog figurine, a letter opener depicting a
frog, several novels, a humorous book of quotations, and several antique
books.(78) He gave her, among other things, a hat pin, two brooches, a
blanket, a marble bear figurine, and a special edition of Walt Whitman's
Leaves of Grass.(79)

Ms. Lewinsky construed it as a sign of affection when the President wore a
necktie or other item of clothing she had given him. She testified: "I used
to say to him that 'I like it when you wear my ties because then I know I'm
close to your heart.' So -- literally and figuratively."(80) The President
was aware of her reaction, according to Ms. Lewinsky, and he would
sometimes wear one of the items to reassure her -- occasionally on the day
they were scheduled to meet or the day after they had met in person or
talked by telephone.(81) The President would sometimes say to her, "Did you
see I wore your tie the other day?"(82)

In his grand jury testimony, the President acknowledged that he had
exchanged a number of gifts with Ms. Lewinsky. After their intimate
relationship ended in 1997, he testified, "[S]he continued to give me
gifts. And I felt that it was a right thing to do to give her gifts
back."(83)

G. Messages

According to Ms. Lewinsky, she sent the President a number of cards and
letters. In some, she expressed anger that he was "not paying enough
attention to me"; in others, she said she missed him; in still others, she
just sent "a funny card that I saw."(84) In early January 1998, she sent
him, along with an antique book about American presidents, "[a]n
embarrassing mushy note."(85) She testified that the President never sent
her any cards or notes other than formal thank-you letters.(86)

Testifying before the grand jury, the President acknowledged having
received cards and notes from Ms. Lewinsky that were "somewhat intimate"
and "quite affectionate," even after the intimate relationship ended.(87)

H. Secrecy

1. Mutual Understanding

Both Ms. Lewinsky and the President testified that they took steps to
maintain the secrecy of the relationship. According to Ms. Lewinsky, the
President from the outset stressed the importance of keeping the
relationship secret. In her handwritten statement to this Office, Ms.
Lewinsky wrote that "the President told Ms. L to deny a relationship, if
ever asked about it. He also said something to the effect of if the two
people who are involved say it didn't happen -- it didn't happen."(88)
According to Ms. Lewinsky, the President sometimes asked if she had told
anyone about their sexual relationship or about the gifts they had
exchanged; she (falsely) assured him that she had not.(89) She told him
that "I would always deny it, I would always protect him," and he responded
approvingly.(90) The two of them had, in her words, "a mutual
understanding" that they would "keep this private, so that meant deny it
and . . . take whatever appropriate steps needed to be taken."(91) When she
and the President both were subpoenaed to testify in the Jones case, Ms.
Lewinsky anticipated that "as we had on every other occasion and every
other instance of this relationship, we would deny it."(92)

In his grand jury testimony, the President confirmed his efforts to keep
their liaisons secret.(93) He said he did not want the facts of their
relationship to be disclosed "in any context," and added: "I certainly
didn't want this to come out, if I could help it. And I was concerned about
that. I was embarrassed about it. I knew it was wrong."(94) Asked if he
wanted to avoid having the facts come out through Ms. Lewinsky's testimony
in Jones, he said: "Well, I did not want her to have to testify and go
through that. And, of course, I didn't want her to do that, of course
not."(95)

2. Cover Stories

For her visits to see the President, according to Ms. Lewinsky, "[T]here
was always some sort of a cover."(96) When visiting the President while she
worked at the White House, she generally planned to tell anyone who asked
(including Secret Service officers and agents) that she was delivering
papers to the President.(97) Ms. Lewinsky explained that this artifice may
have originated when "I got there kind of saying, 'Oh, gee, here are your
letters,' wink, wink, wink, and him saying, 'Okay, that's good.'"(98) To
back up her stories, she generally carried a folder on these visits.(99)
(In truth, according to Ms. Lewinsky, her job never required her to deliver
papers to the President.(100)) On a few occasions during her White House
employment, Ms. Lewinsky and the President arranged to bump into each other
in the hallway; he then would invite her to accompany him to the Oval
Office.(101) Later, after she left the White House and started working at
the Pentagon, Ms. Lewinsky relied on Ms. Currie to arrange times when she
could see the President. The cover story for those visits was that Ms.
Lewinsky was coming to see Ms. Currie, not the President.(102)

While the President did not expressly instruct her to lie, according to Ms.
Lewinsky, he did suggest misleading cover stories.(103) And, when she
assured him that she planned to lie about the relationship, he responded
approvingly. On the frequent occasions when Ms. Lewinsky promised that she
would "always deny" the relationship and "always protect him," for example,
the President responded, in her recollection, "'That's good,' or --
something affirmative. . . . [N]ot -- 'Don't deny it.'"(104)

Once she was named as a possible witness in the Jones case, according to
Ms. Lewinsky, the President reminded her of the cover stories. After
telling her that she was a potential witness, the President suggested that,
if she were subpoenaed, she could file an affidavit to avoid being deposed.
He also told her she could say that, when working at the White House, she
had sometimes delivered letters to him, and, after leaving her White House
job, she had sometimes returned to visit Ms. Currie.(105) (The President's
own testimony in the Jones case mirrors the recommendations he made to Ms.
Lewinsky for her testimony. In his deposition, the President testified that
he saw Ms. Lewinsky "on two or three occasions" during the November 1995
government furlough, "one or two other times when she brought some
documents to me," and "sometime before Christmas" when Ms. Lewinsky "came
by to see Betty."(106))

In his grand jury testimony, the President acknowledged that he and Ms.
Lewinsky "might have talked about what to do in a nonlegal context" to hide
their relationship, and that he "might well have said" that Ms. Lewinsky
should tell people that she was bringing letters to him or coming to visit
Ms. Currie.(107) But he also stated that "I never asked Ms. Lewinsky to
lie."(108)

3. Steps to Avoid Being Seen or Heard

After their first two sexual encounters during the November 1995 government
shutdown, according to Ms. Lewinsky, her encounters with the President
generally occurred on weekends, when fewer people were in the West
Wing.(109) Ms. Lewinsky testified:

He had told me . . . that he was usually around on the weekends and that it
was okay to come see him on the weekends. So he would call and we would
arrange either to bump into each other in the hall or that I would bring
papers to the office.(110)

From some of the President's comments, Ms. Lewinsky gathered that she
should try to avoid being seen by several White House employees, including
Nancy Hernreich, Deputy Assistant to the President and Director of Oval
Office Operations, and Stephen Goodin, the President's personal aide.(111)

Out of concern about being seen, the sexual encounters most often occurred
in the windowless hallway outside the study.(112) According to Ms.
Lewinsky, the President was concerned that the two of them might be spotted
through a White House window. When they were in the study together in the
evenings, he sometimes turned out the light.(113) Once, when she spotted a
gardener outside the study window, they left the room.(114) Ms. Lewinsky
testified that, on December 28, 1997, "when I was getting my Christmas
kiss" in the doorway to the study, the President was "looking out the
window with his eyes wide open while he was kissing me and then I got mad
because it wasn't very romantic." He responded, "Well, I was just looking
to see to make sure no one was out there."(115)

Fear of discovery constrained their sexual encounters in several respects,
according to Ms. Lewinsky. The President ordinarily kept the door between
the private hallway and the Oval Office several inches ajar during their
encounters, both so that he could hear if anyone approached and so that
anyone who did approach would be less likely to suspect impropriety.(116)
During their sexual encounters, Ms. Lewinsky testified, "[W]e were both
aware of the volume and sometimes . . . I bit my hand -- so that I wouldn't
make any noise."(117) On one occasion, according to Ms. Lewinsky, the
President put his hand over her mouth during a sexual encounter to keep her
quiet.(118) Concerned that they might be interrupted abruptly, according to
Ms. Lewinsky, the two of them never fully undressed.(119)

While noting that "the door to the hallway was always somewhat open," the
President testified that he did try to keep the intimate relationship
secret: "I did what people do when they do the wrong thing. I tried to do
it where nobody else was looking at it."(120)

4. Ms. Lewinsky's Notes and Letters

The President expressed concern about documents that might hint at an
improper relationship between them, according to Ms. Lewinsky. He cautioned
her about messages she sent:

There were . . . some occasions when I sent him cards or notes that I wrote
things that he deemed too personal to put on paper just in case something
ever happened, if it got lost getting there or someone else opened it. So
there were several times when he remarked to me, you know, you shouldn't
put that on paper.(121)

She said that the President made this point to her in their last
conversation, on January 5, 1998, in reference to what she characterized as
"[a]n embarrassing mushy note" she had sent him.(122) In addition,
according to Ms. Lewinsky, the President expressed concerns about official
records that could establish aspects of their relationship. She said that
on two occasions she asked the President if she could go upstairs to the
Residence with him. No, he said, because a record is kept of everyone who
accompanies him there.(123)

The President testified before the grand jury: "I remember telling her she
should be careful what she wrote, because a lot of it was clearly
inappropriate and would be embarrassing if somebody else read it."(124)

5. Ms. Lewinsky's Evaluation of Their Secrecy Efforts

In two conversations recorded after she was subpoenaed in the Jones case,
Ms. Lewinsky expressed confidence that her relationship with the President
would never be discovered.(125) She believed that no records showed her and
the President alone in the area of the study.(126) Regardless of the
evidence, in any event, she would continue denying the relationship. "If
someone looked in the study window, it's not me," she said.(127) If someone
produced tapes of her telephone calls with the President, she would say
they were fakes.(128)

In another recorded conversation, Ms. Lewinsky said she was especially
comforted by the fact that the President, like her, would be swearing under
oath that "nothing happened."(129) She said:

[T]o tell you the truth, I'm not concerned all that much anymore because I
know I'm not going to get in trouble. I will not get in trouble because you
know what? The story I've signed under -- under oath is what someone else
is saying under oath.(130)

                    II. 1995: Initial Sexual Encounters

Monica Lewinsky began her White House employment as an intern in the Chief
of Staff's office in July 1995. At White House functions in the following
months, she made eye contact with the President. During the November 1995
government shutdown, the President invited her to his private study, where
they kissed. Later that evening, they had a more intimate sexual encounter.
They had another sexual encounter two days later, and a third one on New
Year's Eve.

A. Overview of Monica Lewinsky's White House Employment

Monica Lewinsky worked at the White House, first as an intern and then as
an employee, from July 1995 to April 1996. With the assistance of family
friend Walter Kaye, a prominent contributor to political causes, she
obtained an internship starting in early July, when she was 21 years
old.(131) She was assigned to work on correspondence in the office of Chief
of Staff Leon Panetta in the Old Executive Office Building.(132)

As her internship was winding down, Ms. Lewinsky applied for a paying job
on the White House staff. She interviewed with Timothy Keating, Special
Assistant to the President and Staff Director for Legislative Affairs.(133)
Ms. Lewinsky accepted a position dealing with correspondence in the Office
of Legislative Affairs on November 13, 1995, but did not start the job
(and, thus, continued her internship) until November 26.(134) She remained
a White House employee until April 1996, when -- in her view, because of
her intimate relationship with the President -- she was dismissed from the
White House and transferred to the Pentagon.(135)

B. First Meetings with the President

The month after her White House internship began, Ms. Lewinsky and the
President began what she characterized as "intense flirting."(136) At
departure ceremonies and other events, she made eye contact with him, shook
hands, and introduced herself.(137) When she ran into the President in the
West Wing basement and introduced herself again, according to Ms. Lewinsky,
he responded that he already knew who she was.(138) Ms. Lewinsky told her
aunt that the President "seemed attracted to her or interested in her or
something," and told a visiting friend that "she was attracted to
[President Clinton], she had a big crush on him, and I think she told me
she at some point had gotten his attention, that there was some mutual eye
contact and recognition, mutual acknowledgment."(139)

In the autumn of 1995, an impasse over the budget forced the federal
government to shut down for one week, from Tuesday, November 14, to Monday,
November 20.(140) Only essential federal employees were permitted to work
during the furlough, and the White House staff of 430 shrank to about 90
people for the week. White House interns could continue working because of
their unpaid status, and they took on a wide range of additional
duties.(141)

During the shutdown, Ms. Lewinsky worked in Chief of Staff Panetta's West
Wing office, where she answered phones and ran errands.(142) The President
came to Mr. Panetta's office frequently because of the shutdown, and he
sometimes talked with Ms. Lewinsky.(143) She characterized these encounters
as "continued flirtation."(144) According to Ms. Lewinsky, a Senior Adviser
to the Chief of Staff, Barry Toiv, remarked to her that she was getting a
great deal of "face time" with the President.(145)

C. November 15 Sexual Encounter

Ms. Lewinsky testified that Wednesday, November 15, 1995 -- the second day
of the government shutdown -- marked the beginning of her sexual
relationship with the President.(146) On that date, she entered the White
House at 1:30 p.m., left sometime thereafter (White House records do not
show the time), reentered at 5:07 p.m., and departed at 12:18 a.m. on
November 16.(147) The President was in the Oval Office or the Chief of
Staff's office (where Ms. Lewinsky worked during the furlough) for almost
the identical period that Ms. Lewinsky was in the White House that evening,
from 5:01 p.m. on November 15 to 12:35 a.m. on November 16.(148)

According to Ms. Lewinsky, she and the President made eye contact when he
came to the West Wing to see Mr. Panetta and Deputy Chief of Staff Harold
Ickes, then again later at an informal birthday party for Jennifer
Palmieri, Special Assistant to the Chief of Staff.(149) At one point, Ms.
Lewinsky and the President talked alone in the Chief of Staff's office. In
the course of flirting with him, she raised her jacket in the back and
showed him the straps of her thong underwear, which extended above her
pants.(150)

En route to the restroom at about 8 p.m., she passed George
Stephanopoulos's office. The President was inside alone, and he beckoned
her to enter.(151) She told him that she had a crush on him. He laughed,
then asked if she would like to see his private office.(152) Through a
connecting door in Mr. Stephanopoulos's office, they went through the
President's private dining room toward the study off the Oval Office. Ms.
Lewinsky testified: "We talked briefly and sort of acknowledged that there
had been a chemistry that was there before and that we were both attracted
to each other and then he asked me if he could kiss me." Ms. Lewinsky said
yes. In the windowless hallway adjacent to the study, they kissed.(153)
Before returning to her desk, Ms. Lewinsky wrote down her name and
telephone number for the President.(154)

At about 10 p.m., in Ms. Lewinsky's recollection, she was alone in the
Chief of Staff's office and the President approached.(155) He invited her
to rendezvous again in Mr. Stephanopoulos's office in a few minutes, and
she agreed.(156) (Asked if she knew why the President wanted to meet with
her, Ms. Lewinsky testified: "I had an idea."(157)) They met in Mr.
Stephanopoulos's office and went again to the area of the private
study.(158) This time the lights in the study were off.(159)

According to Ms. Lewinsky, she and the President kissed. She unbuttoned her
jacket; either she unhooked her bra or he lifted her bra up; and he touched
her breasts with his hands and mouth.(160) Ms. Lewinsky testified: "I
believe he took a phone call . . . and so we moved from the hallway into
the back office . . . . [H]e put his hand down my pants and stimulated me
manually in the genital area."(161) While the President continued talking
on the phone (Ms. Lewinsky understood that the caller was a Member of
Congress or a Senator), she performed oral sex on him.(162) He finished his
call, and, a moment later, told Ms. Lewinsky to stop. In her recollection:
"I told him that I wanted . . . to complete that. And he said . . . that he
needed to wait until he trusted me more. And then I think he made a joke .
. . that he hadn't had that in a long time."(163)

Both before and after their sexual contact during that encounter, Ms.
Lewinsky and the President talked.(164) At one point during the
conversation, the President tugged on the pink intern pass hanging from her
neck and said that it might be a problem. Ms. Lewinsky thought that he was
talking about access -- interns were not supposed to be in the West Wing
without an escort -- and, in addition, that he might have discerned some
"impropriety" in a sexual relationship with a White House intern.(165)

White House records corroborate details of Ms. Lewinsky's account. She
testified that her November 15 encounters with the President occurred at
about 8 p.m. and 10 p.m., and that in each case the two of them went from
the Chief of Staff's office to the Oval Office area.(166) Records show that
the President visited the Chief of Staff's office for one minute at 8:12
p.m. and for two minutes at 9:23 p.m., in each case returning to the Oval
Office.(167) She recalled that the President took a telephone call during
their sexual encounter, and she believed that the caller was a Member of
Congress or a Senator.(168) White House records show that after returning
to the Oval Office from the Chief of Staff's office, the President talked
to two Members of Congress: Rep. Jim Chapman from 9:25 p.m. to 9:30 p.m.,
and Rep. John Tanner from 9:31 p.m. to 9:35 p.m.(169)

D. November 17 Sexual Encounter

According to Ms. Lewinsky, she and the President had a second sexual
encounter two days later (still during the government furlough), on Friday,
November 17. She was at the White House until 8:56 p.m., then returned from
9:38 to 10:39 p.m.(170) At 9:45 p.m., a few minutes after Ms. Lewinsky's
reentry, the President went from the Oval Office to the Chief of Staff's
office (where Ms. Lewinsky worked during the furlough) for one minute, then
returned to the Oval Office for 30 minutes. From there, he went back to the
Chief of Staff's office until 10:34 p.m. (approximately when Ms. Lewinsky
left the White House), then went by the Oval Office and the Ground Floor
before retiring to the Residence at 10:40 p.m.(171)

Ms. Lewinsky testified:

We were again working late because it was during the furlough and Jennifer
Palmieri . . . had ordered pizza along with Ms. Currie and Ms. Hernreich.
And when the pizza came, I went down to let them know that the pizza was
there and it was at that point when I walked into Ms. Currie's office that
the President was standing there with some other people discussing
something.

And they all came back to the office and Mr. -- I think it was Mr. Toiv,
somebody accidentally knocked pizza on my jacket, so I went to go use the
restroom to wash it off and as I was coming out of the restroom, the
President was standing in Ms. Currie's doorway and said, "You can come out
this way."(172)

Ms. Lewinsky and the President went into the area of the private study,
according to Ms. Lewinsky. There, either in the hallway or the bathroom,
she and the President kissed. After a few minutes, in Ms. Lewinsky's
recollection, she told him that she needed to get back to her desk. The
President suggested that she bring him some slices of pizza.(173)

A few minutes later, she returned to the Oval Office area with pizza and
told Ms. Currie that the President had requested it. Ms. Lewinsky
testified: "[Ms. Currie] opened the door and said, 'Sir, the girl's here
with the pizza.' He told me to come in. Ms. Currie went back into her
office and then we went into the back study area again."(174) Several
witnesses confirm that when Ms. Lewinsky delivered pizza to the President
that night, the two of them were briefly alone.(175)

Ms. Lewinsky testified that she and the President had a sexual encounter
during this visit.(176) They kissed, and the President touched Ms.
Lewinsky's bare breasts with his hands and mouth.(177) At some point, Ms.
Currie approached the door leading to the hallway, which was ajar, and said
that the President had a telephone call.(178) Ms. Lewinsky recalled that
the caller was a Member of Congress with a nickname.(179) While the
President was on the telephone, according to Ms. Lewinsky, "he unzipped his
pants and exposed himself," and she performed oral sex.(180) Again, he
stopped her before he ejaculated.(181)

During this visit, according to Ms. Lewinsky, the President told her that
he liked her smile and her energy. He also said: "I'm usually around on
weekends, no one else is around, and you can come and see me."(182)

Records corroborate Ms. Lewinsky's recollection that the President took a
call from a Member of Congress with a nickname. While Ms. Lewinsky was at
the White House that evening (9:38 to 10:39 p.m.), the President had one
telephone conversation with a Member of Congress: From 9:53 to 10:14 p.m.,
he spoke with Rep. H.L. "Sonny" Callahan.(183)

In his Jones deposition on January 17, 1998, President Clinton -- who said
he was unable to recall most of his encounters with Ms. Lewinsky -- did
remember her "back there with a pizza" during the government shutdown. He
said, however, that he did not believe that the two of them were
alone.(184) Testifying before the grand jury on August 17, 1998, the
President said that his first "real conversation" with Ms. Lewinsky
occurred during the November 1995 furlough. He testified: "One night she
brought me some pizza. We had some remarks."(185)

E. December 31 Sexual Encounter

According to Ms. Lewinsky, she and the President had their third sexual
encounter on New Year's Eve. Ms. Lewinsky -- by then a member of the staff
of the Office of Legislative Affairs

-- was at the White House on Sunday, December 31, 1995, until 1:16 p.m.;
her time of arrival is not shown.(186) The President was in the Oval Office
area from 12:11 p.m. until about the time that Ms. Lewinsky left, 1:15
p.m., when he went to the Residence.(187)

Sometime between noon and 1 p.m., in Ms. Lewinsky's recollection, she was
in the pantry area of the President's private dining room talking with a
White House steward, Bayani Nelvis. She told Mr. Nelvis that she had
recently smoked her first cigar, and he offered to give her one of the
President's cigars. Just then, the President came down the hallway from the
Oval Office and saw Ms. Lewinsky. The President dispatched Mr. Nelvis to
deliver something to Mr. Panetta.(188)

According to Ms. Lewinsky, she told the President that Mr. Nelvis had
promised her a cigar, and the President gave her one.(189) She told him her
name -- she had the impression that he had forgotten it in the six weeks
since their furlough encounters because, when passing her in the hallway,
he had called her "Kiddo."(190) The President replied that he knew her
name; in fact, he added, having lost the phone number she had given him, he
had tried to find her in the phonebook.(191)

According to Ms. Lewinsky, they moved to the study. "And then . . . we were
kissing and he lifted my sweater and exposed my breasts and was fondling
them with his hands and with his mouth."(192) She performed oral sex.(193)
Once again, he stopped her before he ejaculated because, Ms. Lewinsky
testified, "he didn't know me well enough or he didn't trust me yet."(194)

According to Ms. Lewinsky, a Secret Service officer named Sandy was on duty
in the West Wing that day.(195) Records show that Sandra Verna was on duty
outside the Oval Office from 7 a.m. to 2 p.m.(196)

F. President's Account of 1995 Relationship

As noted, the President testified before the grand jury that on November
17, 1995, Ms. Lewinsky delivered pizza and exchanged "some remarks" with
him, but he never indicated that anything sexual occurred then or at any
other point in 1995.(197) Testifying under oath before the grand jury, the
President said that he engaged in "conduct that was wrong" involving
"inappropriate intimate contact" with Ms. Lewinsky "on certain occasions in
early 1996 and once in early 1997."(198) By implicitly denying any sexual
contact in 1995, the President indicated that he and Ms. Lewinsky had no
sexual involvement while she was an intern.(199) In the President's
testimony, his relationship with Ms. Lewinsky "began as a friendship," then
later "came to include this conduct."(200)

           III. January-March 1996: Continued Sexual Encounters

President Clinton and Ms. Lewinsky had additional sexual encounters near
the Oval Office in 1996. After their sixth sexual encounter, the President
and Ms. Lewinsky had their first lengthy conversation. On President's Day,
February 19, the President terminated their sexual relationship, then
revived it on March 31.

A. January 7 Sexual Encounter

According to Ms. Lewinsky, she and the President had another sexual
encounter on Sunday, January 7, 1996. Although White House records do not
indicate that Ms. Lewinsky was at the White House that day, her testimony
and other evidence indicate that she was there.(201) The President,
according to White House records, was in the Oval Office most of the
afternoon, from 2:13 to 5:49 p.m.(202)

According to Ms. Lewinsky, the President telephoned her early that
afternoon. It was the first time he had called her at home.(203) In her
recollection: "I asked him what he was doing and he said he was going to be
going into the office soon. I said, oh, do you want some company? And he
said, oh, that would be great."(204) Ms. Lewinsky went to her office, and
the President called to arrange their rendezvous:

[W]e made an arrangement that . . . he would have the door to his office
open, and I would pass by the office with some papers and then . . . he
would sort of stop me and invite me in. So, that was exactly what happened.
I passed by and that was actually when I saw [Secret Service Uniformed
Officer] Lew Fox who was on duty outside the Oval Office, and stopped and
spoke with Lew for a few minutes, and then the President came out and said,
oh, hey, Monica . . . come on in . . . . And so we spoke for about 10
minutes in the [Oval] office. We sat on the sofas. Then we went into the
back study and we were intimate in the bathroom.(205)

Ms. Lewinsky testified that during this bathroom encounter, she and the
President kissed, and he touched her bare breasts with his hands and his
mouth.(206) The President "was talking about performing oral sex on me,"
according to Ms. Lewinsky.(207) But she stopped him because she was
menstruating and he did not.(208) Ms. Lewinsky did perform oral sex on
him.(209)

Afterward, she and the President moved to the Oval Office and talked.
According to Ms. Lewinsky: "[H]e was chewing on a cigar. And then he had
the cigar in his hand and he was kind of looking at the cigar in . . . sort
of a naughty way. And so . . . I looked at the cigar and I looked at him
and I said, we can do that, too, some time."(210)

Corroborating aspects of Ms. Lewinsky's recollection, records show that
Officer Fox was posted outside the Oval Office the afternoon of January
7.(211) Officer Fox (who is now retired) testified that he recalled an
incident with Ms. Lewinsky one weekend afternoon when he was on duty by the
Oval Office:(212)

[T]he President of the United States came out, and he asked me, he says,
"Have you seen any young congressional staff members here today?" I said,
"No, sir." He said, "Well, I'm expecting one." He says, "Would you please
let me know when they show up?" And I said, "Yes, sir."(213)

Officer Fox construed the reference to "congressional staff members" to
mean White House staff who worked with Congress -- i.e., staff of the
Legislative Affairs Office, where Ms. Lewinsky worked.(214)

Talking with a Secret Service agent posted in the hallway, Officer Fox
speculated on whom the President was expecting: "I described Ms. Lewinsky,
without mentioning the name, in detail, dark hair -- you know, I gave a
general description of what she looked like."(215) Officer Fox had gotten
to know Ms. Lewinsky during her tenure at the White House, and other agents
had told him that she often spent time with the President.(216)

A short time later, Ms. Lewinsky approached, greeted Officer Fox, and said,
"I have some papers for the President." Officer Fox admitted her to the
Oval Office. The President said: "You can close the door. She'll be here
for a while."(217)

B. January 21 Sexual Encounter

On Sunday, January 21, 1996, according to Ms. Lewinsky, she and the
President had another sexual encounter. Her time of White House entry is
not reflected in records. She left at 3:56 p.m.(218) The President moved
from the Residence to the Oval Office at 3:33 p.m. and remained there until
7:40 p.m.(219)

On that day, according to Ms. Lewinsky, she saw the President in a hallway
by an elevator, and he invited her to the Oval Office.(220) According to
Ms. Lewinsky:

We had . . . had phone sex for the first time the week prior, and I was
feeling a little bit insecure about whether he had liked it or didn't like
it . . . . I didn't know if this was sort of developing into some kind of a
longer-term relationship than what I thought it initially might have been,
that maybe he had some regular girlfriend who was furloughed . . . .(221)

According to Ms. Lewinsky, she questioned the President about his interest
in her. "I asked him why he doesn't ask me any questions about myself, and
. . . is this just about sex . . . or do you have some interest in trying
to get to know me as a person?"(222) The President laughed and said,
according to Ms. Lewinsky, that "he cherishes the time that he had with
me."(223) She considered it "a little bit odd" for him to speak of
cherishing their time together "when I felt like he didn't really even know
me yet."(224)

They continued talking as they went to the hallway by the study. Then, with
Ms. Lewinsky in mid-sentence, "he just started kissing me."(225) He lifted
her top and touched her breasts with his hands and mouth.(226) According to
Ms. Lewinsky, the President "unzipped his pants and sort of exposed
himself," and she performed oral sex.(227)

At one point during the encounter, someone entered the Oval Office. In Ms.
Lewinsky's recollection, "[The President] zipped up real quickly and went
out and came back in . . . . I just remember laughing because he had walked
out there and he was visibly aroused, and I just thought it was
funny."(228)

A short time later, the President got word that his next appointment, a
friend from Arkansas, had arrived.(229) He took Ms. Lewinsky out through
the Oval Office into Ms. Hernreich's office, where he kissed her
goodbye.(230)

C. February 4 Sexual Encounter and Subsequent Phone Calls

On Sunday, February 4, according to Ms. Lewinsky, she and the President had
their sixth sexual encounter and their first lengthy and personal
conversation. The President was in the Oval Office from 3:36 to 7:05
p.m.(231) He had no telephone calls in the Oval Office before 4:45
p.m.(232) Records do not show Ms. Lewinsky's entry or exit.

According to Ms. Lewinsky, the President telephoned her at her desk and
they planned their rendezvous. At her suggestion, they bumped into each
other in the hallway, "because when it happened accidentally, that seemed
to work really well," then walked together to the area of the private
study.(233)

There, according to Ms. Lewinsky, they kissed. She was wearing a long dress
that buttoned from the neck to the ankles. "And he unbuttoned my dress and
he unhooked my bra, and sort of took the dress off my shoulders and . . .
moved the bra . . . . [H]e was looking at me and touching me and telling me
how beautiful I was."(234) He touched her breasts with his hands and his
mouth, and touched her genitals, first through underwear and then
directly.(235) She performed oral sex on him.(236)

After their sexual encounter, the President and Ms. Lewinsky sat and talked
in the Oval Office for about 45 minutes. Ms. Lewinsky thought the President
might be responding to her suggestion during their previous meeting about
"trying to get to know me."(237) It was during that conversation on
February 4, according to Ms. Lewinsky, that their friendship started to
blossom.(238)

When she prepared to depart, according to Ms. Lewinsky, the President
"kissed my arm and told me he'd call me, and then I said, yeah, well,
what's my phone number? And so he recited both my home number and my office
number off the top of his head."(239) The President called her at her desk
later that afternoon and said he had enjoyed their time together.(240)

D. President's Day (February 19) Break-up

According to Ms. Lewinsky, the President terminated their relationship
(only temporarily, as it happened), on Monday, February 19, 1996 --
President's Day. The President was in the Oval Office from 11 a.m. to 2:01
p.m. that day.(241) He had no telephone calls between 12:19 and 12:42
p.m.(242) Records do not reflect Ms. Lewinsky's presence at the White
House.

In Ms. Lewinsky's recollection, the President telephoned her at her
Watergate apartment that day. From the tone of his voice, she could tell
something was wrong. She asked to come see him, but he said he did not know
how long he would be there.(243) Ms. Lewinsky went to the White House, then
walked to the Oval Office sometime between noon and 2 p.m. (the only time
she ever went to the Oval Office uninvited).(244) Ms. Lewinsky recalled
that she was admitted by a tall, slender, Hispanic plainclothes agent on
duty near the door.(245)

The President told her that he no longer felt right about their intimate
relationship, and he had to put a stop to it.(246) Ms. Lewinsky was welcome
to continue coming to visit him, but only as a friend. He hugged her but
would not kiss her.(247) At one point during their conversation, the
President had a call from a sugar grower in Florida whose name, according
to Ms. Lewinsky, was something like "Fanuli." In Ms. Lewinsky's
recollection, the President may have taken or returned the call just as she
was leaving.(248)

Ms. Lewinsky's account is corroborated in two respects. First, Nelson U.
Garabito, a plainclothes Secret Service agent, testified that, on a weekend
or holiday while Ms. Lewinsky worked at the White House (most likely in the
early spring of 1996), Ms. Lewinsky appeared in the area of the Oval Office
carrying a folder and said, "I have these papers for the President."(249)
After knocking, Agent Garabito opened the Oval Office door, told the
President he had a visitor, ushered Ms. Lewinsky in, and closed the door
behind her.(250) When Agent Garabito's shift ended a few minutes later, Ms.
Lewinsky was still in the Oval Office.(251)

Second, concerning Ms. Lewinsky's recollection of a call from a sugar
grower named "Fanuli," the President talked with Alfonso Fanjul of Palm
Beach, Florida, from 12:42 to 1:04 p.m.(252) Mr. Fanjul had telephoned a
few minutes earlier, at 12:24 p.m.(253) The Fanjuls are prominent sugar
growers in Florida.(254)

E. Continuing Contacts

After the break-up on February 19, 1996, according to Ms. Lewinsky, "there
continued to sort of be this flirtation . . . when we'd see each
other."(255) After passing Ms. Lewinsky in a hallway one night in late
February or March, the President telephoned her at home and said he was
disappointed that, because she had already left the White House for the
evening, they could not get together. Ms. Lewinsky testified that the call
"sort of implied to me that he was interested in starting up again."(256)
On March 10, 1996, Ms. Lewinsky took a visiting friend, Natalie Ungvari, to
the White House. They bumped into the President, who said to Ms. Ungvari
when Ms. Lewinsky introduced them: "You must be her friend from
California."(257) Ms. Ungvari was "shocked" that the President knew where
she was from.(258)

Ms. Lewinsky testified that on Friday, March 29, 1996, she was walking down
a hallway when she passed the President, who was wearing the first necktie
she had given him. She asked where he had gotten the tie, and he replied:
"Some girl with style gave it to me."(259) Later, he telephoned her at her
desk and asked if she would like to see a movie. His plan was that she
would position herself in the hallway by the White House Theater at a
certain time, and he would invite her to join him and a group of guests as
they entered. Ms. Lewinsky responded that she did not want people to think
she was lurking around the West Wing uninvited.(260) She asked if they
could arrange a rendezvous over the weekend instead, and he said he would
try.(261) Records confirm that the President spent the evening of March 29
in the White House Theater.(262) Mrs. Clinton was in Athens, Greece.(263)

F. March 31 Sexual Encounter

On Sunday, March 31, 1996, according to Ms. Lewinsky, she and the President
resumed their sexual contact.(264) Ms. Lewinsky was at the White House from
10:21 a.m. to 4:27 p.m. on that day.(265) The President was in the Oval
Office from 3:00 to 5:46 p.m.(266) His only call while in the Oval Office
was from 3:06 to 3:07 p.m.(267) Mrs. Clinton was in Ireland.(268)

According to Ms. Lewinsky, the President telephoned her at her desk and
suggested that she come to the Oval Office on the pretext of delivering
papers to him.(269) She went to the Oval Office and was admitted by a
plainclothes Secret Service agent.(270) In her folder was a gift for the
President, a Hugo Boss necktie.(271)

In the hallway by the study, the President and Ms. Lewinsky kissed. On this
occasion, according to Ms. Lewinsky, "he focused on me pretty exclusively,"
kissing her bare breasts and fondling her genitals.(272) At one point, the
President inserted a cigar into Ms. Lewinsky's vagina, then put the cigar
in his mouth and said: "It tastes good."(273) After they were finished, Ms.
Lewinsky left the Oval Office and walked through the Rose Garden.(274)

          IV. April 1996: Ms. Lewinsky's Transfer to the Pentagon

With White House and Secret Service employees remarking on Ms. Lewinsky's
frequent presence in the West Wing, a deputy chief of staff ordered Ms.
Lewinsky transferred from the White House to the Pentagon. On April 7 --
Easter Sunday -- Ms. Lewinsky told the President of her dismissal. He
promised to bring her back after the election, and they had a sexual
encounter.

A. Earlier Observations of Ms. Lewinsky in the West Wing

Ms. Lewinsky's visits to the Oval Office area had not gone unnoticed.
Officer Fox testified that "it was pretty commonly known that she did
frequent the West Wing on the weekends."(275) Another Secret Service
uniformed officer, William Ludtke III, once saw her exit from the pantry
near the Oval Office; she seemed startled and possibly embarrassed to be
spotted.(276) Officer John Muskett testified that "if the President was
known to be coming into the Diplomatic Reception Room, a lot of times [Ms.
Lewinsky] just happened to be walking down the corridor, you know, maybe
just to see the President."(277) Ms. Lewinsky acknowledged that she tried
to position herself to see the President.(278)

Although they could not date them precisely, Secret Service officers and
agents testified about several occasions when Ms. Lewinsky and the
President were alone in the Oval Office. William C. Bordley, a former
member of the Presidential Protective Detail, testified that in late 1995
or early 1996, he stopped Ms. Lewinsky outside the Oval Office because she
did not have her pass.(279) The President opened the Oval Office door,
indicated to Agent Bordley that Ms. Lewinsky's presence was all right, and
ushered Ms. Lewinsky into the Oval Office.(280) Agent Bordley saw Ms.
Lewinsky leave about half an hour later.(281)

Another former member of the Presidential Protective Detail, Robert C.
Ferguson, testified that one Saturday in winter, the President told him
that he was expecting "some staffers."(282) A short time later, Ms.
Lewinsky arrived and said that "[t]he President needs me."(283) Agent
Ferguson announced Ms. Lewinsky and admitted her to the Oval Office.(284)
About 10 or 15 minutes later, Agent Ferguson rotated to a post on the
Colonnade outside the Oval Office.(285) He glanced through the window into
the Oval Office and saw the President and Ms. Lewinsky go through the door
leading toward the private study.(286)

Deeming her frequent visits to the Oval Office area a "nuisance," one
Secret Service Officer complained to Evelyn Lieberman, the Deputy Chief of
Staff for Operations.(287) Ms. Lieberman was already aware of Ms. Lewinsky.
In December 1995, according to Ms. Lewinsky, Ms. Lieberman chided her for
being in the West Wing and told her that interns are not permitted around
the Oval Office. Ms. Lewinsky (who had begun her Office of Legislative
Affairs job) told Ms. Lieberman that she was not an intern anymore. After
expressing surprise that Ms. Lewinsky had been hired, Ms. Lieberman said
she must have Ms. Lewinsky confused with someone else.(288) Ms. Lieberman
confirmed that she reprimanded Ms. Lewinsky, whom she considered "what we
used to call a 'clutch' . . . always someplace she shouldn't be."(289)

In Ms. Lewinsky's view, some White House staff members seemed to think that
she was to blame for the President's evident interest in her:

[P]eople were wary of his weaknesses, maybe, and . . . they didn't want to
look at him and think that he could be responsible for anything, so it had
to all be my fault . . . I was stalking him or I was making advances
towards him.(290)

B. Decision to Transfer Ms. Lewinsky

Ms. Lieberman testified that, because Ms. Lewinsky was so persistent in her
efforts to be near the President, "I decided to get rid of her."(291) First
she consulted Chief of Staff Panetta. According to Mr. Panetta, Ms.
Lieberman told him about a woman on the staff who was "spending too much
time around the West Wing." Because of "the appearance that it was
creating," Ms. Lieberman proposed to move her out of the White House. Mr.
Panetta -- who testified that he valued Ms. Lieberman's role as "a tough
disciplinarian" and "trusted her judgment" -- replied, "Fine."(292)
Although Ms. Lieberman said she could not recall having heard any rumors
linking the President and Ms. Lewinsky, she acknowledged that "the
President was vulnerable to these kind of rumors . . . yes, yes, that was
one of the reasons" for moving Ms. Lewinsky out of the White House.(293)
Later, in September 1997, Marcia Lewis (Ms. Lewinsky's mother) complained
about her daughter's dismissal to Ms. Lieberman, whom she met at a Voice of
America ceremony. Ms. Lieberman, according to Ms. Lewis, responded by
"saying something about Monica being cursed because she's beautiful." Ms.
Lewis gathered from the remark that Ms. Lieberman, as part of her effort to
protect the President, "would want to have pretty women moved out."(294)

Most people understood that the principal reason for Ms. Lewinsky's
transfer was her habit of hanging around the Oval Office and the West
Wing.(295) In a memo in October 1996, John Hilley, Assistant to the
President and Director of Legislative Affairs, reported that Ms. Lewinsky
had been "got[ten] rid of" in part "because of 'extracurricular
activities'" (a phrase, he maintained in the grand jury, that meant only
that Ms. Lewinsky was often absent from her work station).(296)

White House officials arranged for Ms. Lewinsky to get another job in the
Administration.(297) "Our direction is to make sure she has a job in an
Agency," Patsy Thomasson wrote in an email message on April 9, 1996.(298)
Ms. Thomasson's office (Presidential Personnel) sent Ms. Lewinsky's resume
to Charles Duncan, Special Assistant to the Secretary of Defense and White
House Liaison, and asked him to find a Pentagon opening for her.(299) Mr.
Duncan was told that, though Ms. Lewinsky had performed her duties capably,
she was being dismissed for hanging around the Oval Office too much.(300)
According to Mr. Duncan -- who had received as many as 40 job referrals per
day from the White House -- the White House had never given such an
explanation for a transfer.(301)

C. Ms. Lewinsky's Notification of Her Transfer

On Friday, April 5, 1996, Timothy Keating, Staff Director for Legislative
Affairs, informed Ms. Lewinsky that she would have to leave her White House
job.(302) According to Mr. Keating, he told her that she was not being
fired, merely "being given a different opportunity." In fact, she could
tell people it was a promotion if she cared to do so.(303) Upon hearing of
her dismissal, Ms. Lewinsky burst into tears and asked if there was any way
for her to stay in the White House, even without pay.(304) No, Mr. Keating
said. According to Ms. Lewinsky, "He told me I was too sexy to be working
in the East Wing and that this job at the Pentagon where I'd be writing
press releases was a sexier job."(305)

Ms. Lewinsky was devastated. She felt that she was being transferred simply
because of her relationship with the President.(306) And she feared that
with the loss of her White House job, "I was never going to see the
President again. I mean, my relationship with him would be over."(307)

D. Conversations with the President about Her Transfer

1. Easter Telephone Conversations and Sexual Encounter

On Easter Sunday, April 7, 1996, Ms. Lewinsky told the President of her
dismissal and they had a sexual encounter. Ms. Lewinsky entered the White
House at 4:56 and left at 5:28 p.m.(308) The President was in the Oval
Office all afternoon, from 2:21 to 7:48 p.m.(309)

According to Ms. Lewinsky, the President telephoned her at home that day.
After they spoke of the death of the Commerce Secretary the previous week,
she told him of her dismissal:

I had asked him . . . if he was doing okay with Ron Brown's death, and then
after we talked about that for a little bit I told him that my last day was
Monday. And . . . he seemed really upset and sort of asked me to tell him
what had happened. So I did and I was crying and I asked him if I could
come see him, and he said that that was fine.(310)

At the White House, according to Ms. Lewinsky, she told Secret Service
Officer Muskett that she needed to deliver papers to the President.(311)
Officer Muskett admitted her to the Oval Office, and she and the President
proceeded to the private study.(312)

According to Ms. Lewinsky, the President seemed troubled about her upcoming
departure from the White House:

He told me that he thought that my being transferred had something to do
with him and that he was upset. He said, "Why do they have to take you away
from me? I trust you." And then he told me -- he looked at me and he said,
"I promise you if I win in November I'll bring you back like that."(313)

He also indicated that she could have any job she wanted after the
election.(314) In addition, the President said he would find out why Ms.
Lewinsky was transferred and report back to her.(315)

When asked if he had promised to get Ms. Lewinsky another White House job,
the President told the grand jury:

What I told Ms. Lewinsky was that . . . I would do what I could to see, if
she had a good record at the Pentagon, and she assured me she was doing a
good job and working hard, that I would do my best to see that the fact
that she had been sent away from the Legislative Affairs section did not
keep her from getting a job in the White House, and that is, in fact, what
I tried to do. . . . But I did not tell her I would order someone to hire
her, and I never did, and I wouldn't do that. It wouldn't be right.(316)

Ms. Lewinsky, when asked if the President had said that he would bring her
back to the White House only if she did a good job at the Pentagon,
responded: "No."(317)

After this Easter Sunday conversation, the President and Ms. Lewinsky had a
sexual encounter in the hallway, according to Ms. Lewinsky.(318) She
testified that the President touched her breasts with his mouth and
hands.(319) According to Ms. Lewinsky: "I think he unzipped [his pants] . .
. because it was sort of this running joke that I could never unbutton his
pants, that I just had trouble with it."(320) Ms. Lewinsky performed oral
sex. The President did not ejaculate in her presence.(321)

During this encounter, someone called out from the Oval Office that the
President had a phone call.(322) He went back to the Oval Office for a
moment, then took the call in the study. The President indicated that Ms.
Lewinsky should perform oral sex while he talked on the phone, and she
obliged.(323) The telephone conversation was about politics, and Ms.
Lewinsky thought the caller might be Dick Morris.(324) White House records
confirm that the President had one telephone call during Ms. Lewinsky's
visit: from "Mr. Richard Morris," to whom he talked from 5:11 to 5:20
p.m.(325)

A second interruption occurred a few minutes later, according to Ms.
Lewinsky. She and the President were in the study.(326) Ms. Lewinsky
testified:

Harold Ickes has a very distinct voice and . . . I heard him holler "Mr.
President," and the President looked at me and I looked at him and he
jetted out into the Oval Office and I panicked and . . . thought that maybe
because Harold was so close with the President that they might just wander
back there and the President would assume that I knew to leave.(327)

Ms. Lewinsky testified that she exited hurriedly through the dining room
door.(328) That evening, the President called and asked Ms. Lewinsky why
she had run off. "I told him that I didn't know if he was going to be
coming back . . . . [H]e was a little upset with me that I left."(329)

In addition to the record of the Dick Morris phone call, the testimony of
Secret Service Officer Muskett corroborates Ms. Lewinsky's account. Officer
Muskett was posted near the door to the Oval Office on Easter Sunday.(330)
He testified that Ms. Lewinsky (whom he knew) arrived at about 4:45 p.m.
carrying a manila folder and seeming "a little upset."(331) She told
Officer Muskett that she needed to deliver documents to the President.(332)
Officer Muskett or the plainclothes agent on duty with him opened the door,
and Ms. Lewinsky entered.(333)

About 20 to 25 minutes later, according to Officer Muskett, the telephone
outside the Oval Office rang. The White House operator said that the
President had an important call but he was not picking up.(334) The agent
working alongside Officer Muskett knocked on the door to the Oval Office.
When the President did not respond, the agent entered. The Oval Office was
empty, and the door leading to the study was slightly ajar.(335) (Ms.
Lewinsky testified that the President left the door ajar during their
sexual encounters.(336)) The agent called out, "Mr. President?" There was
no response. The agent stepped into the Oval Office and called out more
loudly, "Mr. President?" This time there was a response from the study
area, according to Officer Muskett: "Huh?" The agent called out that the
President had a phone call, and the President said he would take it.(337)

A few minutes later, according to Officer Muskett, Mr. Ickes approached and
said he needed to see President Clinton. Officer Muskett admitted him
through Ms. Currie's office.(338) Less than a minute after Mr. Ickes
entered Ms. Currie's reception area, according to Officer Muskett, the
pantry or dining room door closed audibly. Officer Muskett stepped down the
hall to check and saw Ms. Lewinsky walking away briskly.(339)

At 5:30 p.m., two minutes after Ms. Lewinsky left the White House, the
President called the office of the person who had decided to transfer Ms.
Lewinsky, Evelyn Lieberman.(340)

2. April 12-13: Telephone Conversations

Ms. Lewinsky testified that the President telephoned her the following
Friday, April 12, 1996, at home. They talked for about 20 minutes.
According to Ms. Lewinsky, the President said he had checked on the reason
for her transfer:

[H]e had come to learn . . . that Evelyn Lieberman had sort of spearheaded
the transfer, and that she thought he was paying too much attention to me
and I was paying too much attention to him and that she didn't necessarily
care what happened after the election but everyone needed to be careful
before the election.(341)

According to Ms. Lewinsky, the President told her to give the Pentagon a
try, and, if she did not like it, he would get her a job on the
campaign.(342)

In the grand jury, Ms. Lieberman testified that the President asked her
directly about Ms. Lewinsky's transfer:

After I had gotten rid of her, when I was in there, during the course of a
conversation, [President Clinton] said, "I got a call about --" I don't
know if he said her name. He said maybe "-- an intern you fired." And she
was evidently very upset about it. He said, "Do you know anything about
this?" I said, "Yes." He said, "Who fired her?" I said, "I did." And he
said, "Oh, okay."(343)

According to Ms. Lieberman, the President did not pursue the matter
further.(344)

Three other witnesses confirm that the President knew why Ms. Lewinsky was
transferred to the Pentagon. In 1997, the President told Chief of Staff
Erskine Bowles "that there was a young woman -- her name was Monica
Lewinsky -- who used to work at the White House; that Evelyn . . . thought
she hung around the Oval Office too much and transferred her to the
Pentagon."(345) According to Betty Currie, the President believed that Ms.
Lewinsky had been unfairly transferred.(346) The President's close friend,
Vernon Jordan, testified that the President said to him in December 1997
that "he knew about [Ms. Lewinsky's] situation, which was that she was
pushed out of the White House."(347)

                V. April-December 1996: No Private Meetings

After Ms. Lewinsky began her Pentagon job on April 16, 1996, she had no
further physical contact with the President for the remainder of the year.
She and the President spoke by phone (and had phone sex) but saw each other
only at public functions. Ms. Lewinsky grew frustrated after the election
because the President did not bring her back to work at the White House.

A. Pentagon Job

On April 16, 1996, Ms. Lewinsky began working at the Pentagon as
Confidential Assistant to the Assistant Secretary of Defense for Public
Affairs.(348)

B. No Physical Contact

According to Ms. Lewinsky, she had no physical contact with the President
for the rest of 1996.(349) "I wasn't alone with him so when I saw him it
was in some sort of event or group setting," she testified.(350)

C. Telephone Conversations

Ms. Lewinsky and the President did talk by telephone, especially in her
first weeks at the new job.(351) By Ms. Lewinsky's estimate, the President
phoned her (sometimes leaving a message) four or five times in the month
after she started working at the Pentagon, then two or three times a month
thereafter for the rest of 1996.(352) During the fall 1996 campaign, the
President sometimes called from trips when Mrs. Clinton was not
accompanying him.(353) During at least seven of the 1996 calls, Ms.
Lewinsky and the President had phone sex.(354)

According to Ms. Lewinsky, the President telephoned her at about 6:30 a.m.
on July 19, the day he was leaving for the 1996 Olympics in Atlanta, and
they had phone sex, after which the President exclaimed, "[G]ood morning!"
and then said: "What a way to start a day."(355) A call log shows that the
President called the White House operator at 12:11 a.m. on July 19 and
asked for a wake-up call at 7 a.m., then at 6:40 a.m., the President called
and said he was already up.(356) In Ms. Lewinsky's recollection, she and
the President also had phone sex on May 21, July 5 or 6, October 22, and
December 2, 1996.(357) On those dates, Mrs. Clinton was in Denver (May 21),
Prague and Budapest (July 5-6), Las Vegas (October 22), and en route to
Bolivia (December 2).(358)

Ms. Lewinsky repeatedly told the President that she disliked her Pentagon
job and wanted to return to the White House.(359) In a recorded
conversation, Ms. Lewinsky recounted one call:

[A] month had passed and -- so he had called one night, and I said, "Well,"
I said, "I'm really unhappy," you know. And [the President] said, "I don't
want to talk about your job tonight. I'll call you this week, and then
we'll talk about it. I want to talk about other things" -- which meant
phone sex.(360)

She expected to talk with him the following weekend, and she was "ready to
broach the idea of . . . going to the campaign," but he did not call.(361)

Ms. Lewinsky and the President also talked about their relationship. During
a phone conversation on September 5, according to Ms. Lewinsky, she told
the President that she wanted to have intercourse with him. He responded
that he could not do so because of the possible consequences. The two of
them argued, and he asked if he should stop calling her. No, she
responded.(362)

D. Public Encounters

During this period, Ms. Lewinsky occasionally saw the President in public.
She testified:

I'm an insecure person . . . and I was insecure about the relationship at
times and thought that he would come to forget me easily and if I hadn't
heard from him . . . it was very difficult for me . . . . [U]sually when
I'd see him, it would kind of prompt him to call me. So I made an effort. I
would go early and stand in the front so I could see him . . . .(363)

On May 2, 1996, Ms. Lewinsky saw the President at a reception for the
Saxophone Club, a political organization.(364) On June 14, Ms. Lewinsky and
her family attended the taping of the President's weekly radio address and
had photos taken with the President.(365) On August 18, Ms. Lewinsky
attended the President's 50th birthday party at Radio City Music Hall, and
she got into a cocktail party for major donors where she saw the
President.(366) According to Ms. Lewinsky, when the President reached past
her at the rope line to shake hands with another guest, she reached out and
touched his crotch in a "playful" fashion.(367) On October 23, according to
Ms. Lewinsky, she talked with the President at a fundraiser for Senate
Democrats.(368) The two were photographed together at the event.(369) The
President was wearing a necktie she had given him, according to Ms.
Lewinsky, and she said to him, "Hey, Handsome -- I like your tie."(370) The
President telephoned her that night. She said she planned to be at the
White House on Pentagon business the next day, and he told her to stop by
the Oval Office. At the White House the next day, Ms. Lewinsky did not see
the President because Ms. Lieberman was nearby.(371) On December 17, Ms.
Lewinsky attended a holiday reception at the White House.(372) A photo
shows her shaking hands with the President.(373)

E. Ms. Lewinsky's Frustrations

Continuing to believe that her relationship with the President was the key
to regaining her White House pass, Ms. Lewinsky hoped that the President
would get her a job immediately after the election. "I kept a calendar with
a countdown until election day," she later wrote in an unsent letter to
him. The letter states:

I was so sure that the weekend after the election you would call me to come
visit and you would kiss me passionately and tell me you couldn't wait to
have me back. You'd ask me where I wanted to work and say something akin to
"Consider it done" and it would be. Instead I didn't hear from you for
weeks and subsequently your phone calls became less frequent.(374)

Ms. Lewinsky grew increasingly frustrated over her relationship with
President Clinton.(375) One friend understood that Ms. Lewinsky complained
to the President about not having seen each other privately for months, and
he replied, "Every day can't be sunshine."(376) In email to another friend
in early 1997, Ms. Lewinsky wrote: "I just don't understand what went
wrong, what happened? How could he do this to me? Why did he keep up
contact with me for so long and now nothing, now when we could be
together?"(377)

              VI. Early 1997: Resumption of Sexual Encounters

In 1997, President Clinton and Ms. Lewinsky had further private meetings,
which now were arranged by Betty Currie, the President's secretary. After
the taping of the President's weekly radio address on February 28, the
President and Ms. Lewinsky had a sexual encounter. On March 24, they had
what proved to be their final sexual encounter. Throughout this period, Ms.
Lewinsky continued to press for a job at the White House, to no avail.

A. Resumption of Meetings with the President

1. Role of Betty Currie

a. Arranging Meetings

In 1997, with the presidential election past, Ms. Lewinsky and the
President resumed their one-on-one meetings and sexual encounters. The
President's secretary, Betty Currie, acted as intermediary.

According to Ms. Currie, Ms. Lewinsky would often call her and say she
wanted to see the President, sometimes to discuss a particular topic.(378)
Ms. Currie would ask President Clinton, and, if he agreed, arrange the
meeting.(379) Ms. Currie also said it was "not unusual" that Ms. Lewinsky
would talk by phone with the President and then call Ms. Currie to set up a
meeting.(380) At times, Ms. Currie placed calls to Ms. Lewinsky for
President Clinton and put him on the line.(381)

The meetings between the President and Ms. Lewinsky often occurred on
weekends.(382) When Ms. Lewinsky would arrive at the White House, Ms.
Currie generally would be the one to authorize her entry and take her to
the West Wing.(383) Ms. Currie acknowledged that she sometimes would come
to the White House for the sole purpose of having Ms. Lewinsky admitted and
bringing her to see the President.(384) According to Ms. Currie, Ms.
Lewinsky and the President were alone together in the Oval Office or the
study for 15 to 20 minutes on multiple occasions.(385)

Secret Service officers and agents took note of Ms. Currie's role. Officer
Steven Pape once observed Ms. Currie come to the White House for the
duration of Ms. Lewinsky's visit, then leave.(386) When calling to alert
the officer at the West Wing lobby that Ms. Lewinsky was en route, Ms.
Currie would sometimes say, "[Y]ou know who it is."(387) On one occasion,
Ms. Currie instructed Officer Brent Chinery to hold Ms. Lewinsky at the
lobby for a few minutes because she needed to move the President to the
study.(388) On another occasion, Ms. Currie told Officer Chinery to have
Ms. Lewinsky held at the gate for 30 to 40 minutes because the President
already had a visitor.(389)

Ms. Lewinsky testified that she once asked the President why Ms. Currie had
to clear her in, and why he could not do so himself. "[H]e said because if
someone comes to see him, there's a list circulated among the staff members
and then everyone would be questioning why I was there to see him."(390)

b. Intermediary for Gifts

Ms. Lewinsky also sent over a number of packages -- six or eight, Ms.
Currie estimated.(391) According to Ms. Currie, Ms. Lewinsky would call and
say she was sending something for the President.(392) The package would
arrive addressed to Ms. Currie.(393) Courier receipts show that Ms.
Lewinsky sent seven packages to the White House between October 7 and
December 8, 1997.(394) Evidence indicates that Ms. Lewinsky on occasion
also dropped parcels off with Ms. Currie or had a family member do so,(395)
and brought gifts to the President when visiting him.(396) Ms. Currie
testified that most packages from Ms. Lewinsky were intended for the
President.(397)

Although Ms. Currie generally opened letters and parcels to the President,
she did not open these packages from Ms. Lewinsky.(398) She testified that
"I made the determination not to open" such letters and packages because "I
felt [they were] probably personal."(399) Instead, she would leave the
package in the President's box, and "[h]e would pick it up."(400) To the
best of her knowledge, such parcels always reached the President.(401)

c. Secrecy

Ms. Currie testified that she suspected impropriety in the President's
relationship with Ms. Lewinsky.(402) She told the grand jury that she "had
concern." In her words: "[H]e was spending a lot of time with a 24-year-old
young lady. I know he has said that young people keep him involved in
what's happening in the world, so I knew that was one reason, but there was
a concern of mine that she was spending more time than most."(403) Ms.
Currie understood that "the majority" of the President's meetings with Ms.
Lewinsky were "more personal in nature as opposed to business."(404)

Ms. Currie also testified that she tried to avoid learning details of the
relationship between the President and Ms. Lewinsky. On one occasion, Ms.
Lewinsky said of herself and the President, "As long as no one saw us --
and no one did -- then nothing happened." Ms. Currie responded: "Don't want
to hear it. Don't say any more. I don't want to hear any more."(405)

Ms. Currie helped keep the relationship secret. When the President wanted
to talk with Ms. Lewinsky, Ms. Currie would dial the call herself rather
than go through White House operators, who keep logs of presidential calls
made through the switchboard.(406) When Ms. Lewinsky phoned and Ms. Currie
put the President on the line, she did not log the call, though the
standard procedure was to note all calls, personal and professional.(407)
According to Secret Service uniformed officers, Ms. Currie sometimes tried
to persuade them to admit Ms. Lewinsky to the White House compound without
making a record of it.(408)

In addition, Ms. Currie avoided writing down or retaining most messages
from Ms. Lewinsky to the President. In response to a grand jury subpoena,
the White House turned over only one note to the President concerning Ms.
Lewinsky -- whereas evidence indicates that Ms. Lewinsky used Ms. Currie to
convey requests and messages to the President on many occasions.(409)

When bringing Ms. Lewinsky in from the White House gate, Ms. Currie said
she sometimes chose a path that would reduce the likelihood of being seen
by two White House employees who disapproved of Ms. Lewinsky: Stephen
Goodin and Nancy Hernreich.(410) Ms. Currie testified that she once brought
Ms. Lewinsky directly to the study, "sneaking her back" via a roundabout
path to avoid running into Mr. Goodin.(411) When Ms. Lewinsky visited the
White House on weekends and at night, being spotted was not a problem -- in
Ms. Currie's words, "there would be no need to sneak" -- so Ms. Lewinsky
would await the President in Ms. Currie's office.(412)

According to Ms. Lewinsky, she once expressed concern about records showing
the President's calls to her, and Ms. Currie told her not to worry.(413)
Ms. Lewinsky also suspected that Ms. Currie was not logging in all of her
gifts to the President.(414) In Ms. Lewinsky's evaluation, many White House
staff members tried to regulate the President's behavior, but Ms. Currie
generally did as he wished.(415)

2. Observations by Secret Service Officers

Officers of the Secret Service Uniformed Division noted Ms. Lewinsky's 1997
visits to the White House. From radio traffic about the President's
movements, several officers observed that the President often would head
for the Oval Office within minutes of Ms. Lewinsky's entry to the complex,
especially on weekends, and some noted that he would return to the
Residence a short time after her departure.(416) "It was just like
clockwork," according to one officer.(417) Concerned about the President's
reputation, another officer suggested putting Ms. Lewinsky on a list of
people who were not to be admitted to the White House. A commander
responded that it was none of their business whom the President chose to
see, and, in any event, nobody would ever find out about Ms. Lewinsky.(418)

B. Valentine's Day Advertisement

On February 14, 1997, the Washington Post published a Valentine's Day "Love
Note" that Ms. Lewinsky had placed. The ad said:

HANDSOME

With love's light wings did

I o'er perch these walls

For stony limits cannot hold love out,

And what love can do that dares love attempt.

-- Romeo and Juliet 2:2

Happy Valentine's Day.

M(419)

C. February 24 Message

On February 24, Ms. Lewinsky visited the White House on Pentagon
business.(420) She went by Ms. Currie's office.(421) Ms. Currie sent a note
to the President -- the only such note turned over by the White House in
response to a grand jury subpoena: "Monica Lewinsky stopped by. Do you want
me to call her?"(422)

D. February 28 Sexual Encounter

According to Ms. Lewinsky, she and the President had a sexual encounter on
Thursday, February 28 -- their first in nearly 11 months. White House
records show that Ms. Lewinsky attended the taping of the President's
weekly radio address on February 28.(423) She was at the White House from
5:48 to 7:07 p.m.(424) The President was in the Roosevelt Room (where the
radio address was taped) from 6:29 to 6:36 p.m., then moved to the Oval
Office, where he remained until 7:24 p.m.(425) He had no telephone calls
while Ms. Lewinsky was in the White House.(426)

Wearing a navy blue dress from the Gap, Ms. Lewinsky attended the radio
address at the President's invitation (relayed by Ms. Currie), then had her
photo taken with the President.(427) Ms. Lewinsky had not been alone with
the President since she had worked at the White House, and, she testified,
"I was really nervous."(428) President Clinton told her to see Ms. Currie
after the photo was taken because he wanted to give her something.(429) "So
I waited a little while for him and then Betty and the President and I went
into the back office," Ms. Lewinsky testified.(430) (She later learned that
the reason Ms. Currie accompanied them was that Stephen Goodin did not want
the President to be alone with Ms. Lewinsky, a view that Mr. Goodin
expressed to the President and Ms. Currie.(431)) Once they had passed from
the Oval Office toward the private study, Ms. Currie said, "I'll be right
back," and walked on to the back pantry or the dining room, where,
according to Ms. Currie, she waited for 15 to 20 minutes while the
President and Ms. Lewinsky were in the study.(432) Ms. Currie (who said she
acted on her own initiative) testified that she accompanied the President
and Ms. Lewinsky out of the Oval Office because "I didn't want any
perceptions, him being alone with someone."(433)

In the study, according to Ms. Lewinsky, the President "started to say
something to me and I was pestering him to kiss me, because . . . it had
been a long time since we had been alone."(434) The President told her to
wait a moment, as he had presents for her.(435) As belated Christmas gifts,
he gave her a hat pin and a special edition of Walt Whitman's Leaves of
Grass.(436)

Ms. Lewinsky described the Whitman book as "the most sentimental gift he
had given me . . . it's beautiful and it meant a lot to me."(437) During
this visit, according to Ms. Lewinsky, the President said he had seen her
Valentine's Day message in the Washington Post, and he talked about his
fondness for "Romeo and Juliet."(438)

Ms. Lewinsky testified that after the President gave her the gifts, they
had a sexual encounter:

[W]e went back over by the bathroom in the hallway, and we kissed. We were
kissing and he unbuttoned my dress and fondled my breasts with my bra on,
and then took them out of my bra and was kissing them and touching them
with his hands and with his mouth.

And then I think I was touching him in his genital area through his pants,
and I think I unbuttoned his shirt and was kissing his chest. And then . .
. I wanted to perform oral sex on him . . . and so I did. And then . . . I
think he heard something, or he heard someone in the office. So, we moved
into the bathroom.

And I continued to perform oral sex and then he pushed me away, kind of as
he always did before he came, and then I stood up and I said . . . I care
about you so much; . . . I don't understand why you won't let me . . . make
you come; it's important to me; I mean, it just doesn't feel complete, it
doesn't seem right.(439)

Ms. Lewinsky testified that she and the President hugged, and "he said he
didn't want to get addicted to me, and he didn't want me to get addicted to
him." They looked at each other for a moment.(440) Then, saying that "I
don't want to disappoint you," the President consented.(441) For the first
time, she performed oral sex through completion.(442)

When Ms. Lewinsky next took the navy blue Gap dress from her closet to wear
it, she noticed stains near one hip and on the chest.(443) FBI Laboratory
tests revealed that the stains are the President's semen.(444)

In his grand jury testimony, the President -- who, because the OIC had
asked him for a blood sample (and had represented that it had ample
evidentiary justification for making such a request), had reason to suspect
that Ms. Lewinsky's dress might bear traces of his semen -- indicated that
he and Ms. Lewinsky had had sexual contact on the day of the radio address.
He testified:

I was sick after it was over and I, I was pleased at that time that it had
been nearly a year since any inappropriate contact had occurred with Ms.
Lewinsky. I promised myself it wasn't going to happen again. The facts are
complicated about what did happen and how it happened. But, nonetheless,
I'm responsible for it.(445)

Later the President added, referring to the evening of the radio address:
"I do believe that I was alone with her from 15 to 20 minutes. I do believe
that things happened then which were inappropriate."(446) He said of the
intimate relationship with Ms. Lewinsky: "I never should have started it,
and I certainly shouldn't have started it back after I resolved not to in
1996."(447)

E. March 29 Sexual Encounter

According to Ms. Lewinsky, she had what proved to be her final sexual
encounter with the President on Saturday, March 29, 1997. Records show that
she was at the White House from 2:03 to 3:16 p.m., admitted by Ms.
Currie.(448) The President was in the Oval Office during this period (he
left shortly after Ms. Lewinsky did, at 3:24 p.m.), and he did not have any
phone calls during her White House visit.(449)

According to Ms. Lewinsky, Ms. Currie arranged the meeting after the
President said by telephone that he had something important to tell her. At
the White House, Ms. Currie took her to the study to await the President.
He came in on crutches, the result of a knee injury in Florida two weeks
earlier.(450)

According to Ms. Lewinsky, their sexual encounter began with a sudden kiss:
"[T]his was another one of those occasions when I was babbling on about
something, and he just kissed me, kind of to shut me up, I think."(451) The
President unbuttoned her blouse and touched her breasts without removing
her bra.(452) "[H]e went to go put his hand down my pants, and then I
unzipped them because it was easier. And I didn't have any panties on. And
so he manually stimulated me."(453) According to Ms. Lewinsky, "I wanted
him to touch my genitals with his genitals," and he did so, lightly and
without penetration.(454) Then Ms. Lewinsky performed oral sex on him,
again until he ejaculated.(455)

According to Ms. Lewinsky, she and the President had a lengthy conversation
that day. He told her that he suspected that a foreign embassy (he did not
specify which one) was tapping his telephones, and he proposed cover
stories. If ever questioned, she should say that the two of them were just
friends. If anyone ever asked about their phone sex, she should say that
they knew their calls were being monitored all along, and the phone sex was
just a put-on.(456)

In his grand jury testimony, the President implicitly denied this
encounter. He acknowledged "inappropriate intimate contact" with Ms.
Lewinsky "on certain occasions in early 1996 and once in early 1997."(457)
The President indicated that "the one occasion in 1997" was the radio
address.(458)

F. Continuing Job Efforts

With the 1996 election past, meanwhile, Ms. Lewinsky had continued striving
to get a job at the White House. She testified that she first broached the
issue in a telephone call with the President in January 1997, and he said
he would speak to Bob Nash, Director of Presidential Personnel.(459) She
understood that Mr. Nash was supposed to "find a position for me to come
back to the White House."(460)

Over the months that followed, Ms. Lewinsky repeatedly asked the President
to get her a White House job. In her recollection, the President replied
that various staff members were working on it, including Mr. Nash and
Marsha Scott, Deputy Assistant to the President and Deputy Director for
Presidential Personnel.(461) According to Ms. Lewinsky, the President told
her:

"Bob Nash is handling it," "Marsha's going to handle it" and "We just sort
of need to be careful." You know, and . . . he would always sort of . . .
validate what I was feeling by telling me something that I don't
necessarily know is true. "Oh, I'll talk to her," "I'll -- you know, I'll
see blah, blah, blah," and it was just "I'll do," "I'll do," "I'll do." And
didn't, didn't, didn't.(462)

Ms. Lewinsky came to wonder if she was being "strung along."(463)

Testifying before the grand jury, the President acknowledged that Ms.
Lewinsky had complained to him about her job situation:

You know, she tried for months and months to get a job back in the White
House, not so much in the West Wing but somewhere in the White House
complex, including the Old Executive Office Building. . . . She very much
wanted to come back. And she interviewed for some jobs but never got one.
She was, from time to time, upset about it.(464)

             VII. May 1997: Termination of Sexual Relationship

In May 1997, amid indications that Ms. Lewinsky had been indiscreet,
President Clinton terminated the sexual relationship.

A. Questions about Ms. Lewinsky's Discretion

In April or May 1997, according to Ms. Lewinsky, the President asked if she
had told her mother about their intimate relationship. She responded: "No.
Of course not."(465) (In truth, she had told her mother.(466)) The
President indicated that Ms. Lewinsky's mother possibly had said something
about the nature of the relationship to Walter Kaye, who had mentioned it
to Marsha Scott, who in turn had alerted the President.(467)

Corroborating Ms. Lewinsky's account, Mr. Kaye testified that he told Ms.
Lewinsky's aunt, Debra Finerman, that he understood that "her niece was
very aggressive," a remark that angered Ms. Finerman. Ms. Finerman told Mr.
Kaye that the President was the true aggressor: He was telephoning Ms.
Lewinsky late at night. Ms. Finerman, in Mr. Kaye's recollection,
attributed this information to Marcia Lewis, Ms. Lewinsky's mother (and Ms.
Finerman's sister). Mr. Kaye -- who had disbelieved stories he had heard
from Democratic National Committee people about an affair between Ms.
Lewinsky and the President -- testified that he was "shocked" to hear of
the late-night phone calls.(468)

B. May 24: Break-up

On Saturday, May 24, 1997, according to Ms. Lewinsky, the President ended
their intimate relationship. Ms. Lewinsky was at the White House that day
from 12:21 to 1:54 p.m.(469) The President was in the Oval Office during
most of this period, from 11:59 a.m. to 1:47 p.m.(470) He did not have any
telephone calls.(471)

According to Ms. Lewinsky, she got a call from Ms. Currie at about 11 a.m.
that day, inviting her to come to the White House at about 1 p.m. Ms.
Lewinsky arrived wearing a straw hat with the hat pin the President had
given her, and bringing gifts for him, including a puzzle and a Banana
Republic shirt. She gave him the gifts in the dining room, and they moved
to the area of the study.(472)

According to Ms. Lewinsky, the President explained that they had to end
their intimate relationship.(473) Earlier in his marriage, he told her, he
had had hundreds of affairs; but since turning 40, he had made a concerted
effort to be faithful.(474) He said he was attracted to Ms. Lewinsky,
considered her a great person, and hoped they would remain friends. He
pointed out that he could do a great deal for her. The situation, he
stressed, was not Ms. Lewinsky's fault.(475) Ms. Lewinsky, weeping, tried
to persuade the President not to end the sexual relationship, but he was
unyielding, then and subsequently.(476) Although she and the President
kissed and hugged thereafter, according to Ms. Lewinsky, the sexual
relationship was over.(477)

Three days after this meeting, on May 27, 1997, the Supreme Court
unanimously rejected President Clinton's claim that the Constitution
immunized him from civil lawsuits. The Court ordered the sexual harassment
case Jones v. Clinton to proceed.(478)

          VIII. June-October 1997: Continuing Meetings and Calls

Ms. Lewinsky tried to return to the White House staff and to revive her
sexual relationship with the President, but she failed at both.

A. Continuing Job Efforts

Although Ms. Lewinsky was not offered another White House job, some
testimony indicates that the President tried to get her one.

According to Betty Currie, the President instructed her and Marsha Scott to
help Ms. Lewinsky find a White House job.(479) Ms. Currie testified that
she resisted the request, because her opinion of Ms. Lewinsky had shifted
over time. At first, she testified, she considered Ms. Lewinsky "a friend"
who "had been wronged" and had been "maligned improperly."(480) But
"[l]ater on, I considered her as a pain in the neck, more or less."(481)
The change of heart resulted in part from Ms. Currie's many phone calls in
1997 from Ms. Lewinsky, who was often distraught and sometimes in tears
over her inability to get in touch with the President.(482) Deeming her "a
little bit pushy," Ms. Currie argued against bringing Ms. Lewinsky back to
work at the White House, but the President told her and Ms. Scott, in Ms.
Currie's words, "to still pursue her coming back."(483) Indeed, according
to Ms. Currie, the President "was pushing us hard" on the matter.(484) To
the best of Ms. Currie's recollection, it was the only time the President
instructed her to try to get someone a White House job.(485)

According to Ms. Lewinsky, the President told her to talk with Ms. Scott
about a White House job in spring 1997.(486) On June 16, she met with Ms.
Scott.(487) The meeting did not go as Ms. Lewinsky anticipated. She later
recounted in an email message:

There is most certainly a disconnect on what [the President] said he told
her and how she acted. She didn't even know what my title or my job was . .
. . She didn't have any job openings to offer. Instead, she made me go over
what happened when I had to leave (who told me), and then proceeded to
confirm the Evelyn [Lieberman] story about my "inappropriate behavior."
Then she asked me: with such nasty women there and people gossiping about
me, why did I want to come back? I was so upset. I really did not feel it
was her place to question me about that. Later on, I said something about
being told I could come back after November and she wanted to know who told
me that! So I have placed a call to him but I don't know what is going to
happen.

Ms. Lewinsky added that she was inclined "to walk away from it all," but
acknowledged that "I'm always saying this and then I change my mind."(488)

Though she characterized her recollection as "all jumbled," Ms. Scott
corroborated much of Ms. Lewinsky's account.(489) Ms. Scott said that at
some point she did ask Ms. Lewinsky why she wanted to return to the White
House.(490) Ms. Scott also said that she was unaware of Ms. Lewinsky's job
title before their meeting.(491)

Over the next three weeks, Ms. Lewinsky tried repeatedly, without success,
to talk with the President about her job quest. In a draft of a letter to
Ms. Currie, she wrote that the President "said to me that he had told [Ms.
Scott] I had gotten a bum deal, and I should get a good job in the West
Wing," but Ms. Scott did not seem eager to arrange for Ms. Lewinsky's
return. Ms. Lewinsky wrote:

I was surprised that she would question his judgment and not just do what
he asked of her. Is it possible that, in fact, he did not tell her that?
Does he really not want me back in the complex? He has not responded to my
note, nor has he called me. Do you know what is going on? If so, are you
able to share it with me?(492)

Ms. Currie testified to "a vague recollection" of having seen this
letter.(493)

On June 29, 1997, Ms. Lewinsky wrote several notes. In a draft letter to
Ms. Scott, Ms. Lewinsky wrote that "our last conversation was very
upsetting to me," and added:

Marsha, I was told that I could come back after the election. I knew why I
had to leave last year by mid-April, and I have been beyond patient since
then. I do not think it is fair to . . . be told by the person whom I was
told would get me a job that there is nothing for me and she doesn't really
hear about positions [in] the complex anyway. I know that in your eyes I am
just a hindrance -- a woman who doesn't have a certain someone's best
interests at heart, but please trust me when I say I do.(494)

Ms. Lewinsky also drafted a note to the President pleading for a brief
meeting the following Tuesday. Referring to her inability to get in touch
with him, she wrote: "Please do not do this to me. I feel disposable, used
and insignificant. I understand your hands are tied, but I want to talk to
you and look at some options."(495) Around this time, Ms. Lewinsky told a
friend that she was considering moving to another city or country.(496)

B. July 3 Letter

"[V]ery frustrated" over her inability to get in touch with the President
to discuss her job situation, Ms. Lewinsky wrote him a peevish letter on
July 3, 1997.(497) Opening "Dear Sir," the letter took the President to
task for breaking his promise to get her another White House job.(498) Ms.
Lewinsky also obliquely threatened to disclose their relationship. If she
was not going to return to work at the White House, she wrote, then she
would "need to explain to my parents exactly why that wasn't happening."
Some explanation was necessary because she had told her parents that she
would be brought back after the election.(499) (Ms. Lewinsky testified that
she would not actually have told her father about the relationship -- she
had already told her mother -- but she wanted to remind the President that
she had "left the White House like a good girl in April of '96," whereas
other people might have threatened disclosure in order to retain the
job.(500))

Ms. Lewinsky also raised the possibility of a job outside Washington. If
returning to the White House was impossible, she asked in this letter,
could he get her a job at the United Nations in New York?(501) It was the
first time that she had told the President that she was considering
moving.(502)

Although not questioned about this particular letter, the President
testified that he believed Ms. Lewinsky might disclose their intimate
relationship once he stopped it. He testified:

After I terminated the improper contact with her, she wanted to come in
more than she did. She got angry when she didn't get in sometimes. I knew
that that might make her more likely to speak, and I still did it because I
had to limit the contact.(503)

After receiving the July 3 letter, though, the President agreed to see Ms.
Lewinsky. In her account, Ms. Currie called that afternoon and told her to
come to the White House at 9 a.m. the next day.(504)

C. July 4 Meeting

On Friday, July 4, 1997, Ms. Lewinsky had what she characterized as a "very
emotional" visit with the President.(505) Records show that Ms. Lewinsky
entered the White House at 8:51 a.m.; no exit time is recorded.(506) Logs
indicate that the President was in the Oval Office from 8:40 until after 11
a.m.(507)

In Ms. Lewinsky's recollection, their meeting began contentiously, with the
President scolding her: "[I]t's illegal to threaten the President of the
United States."(508) He then told her that he had not read her July 3
letter beyond the "Dear Sir" line; he surmised that it was threatening
because Ms. Currie looked upset when she brought it to him. (Ms. Lewinsky
suspected that he actually had read the whole thing.)(509) Ms. Lewinsky
complained about his failure to get her a White House job after her long
wait. Although the President claimed he wanted to be her friend, she said,
he was not acting like it. Ms. Lewinsky began weeping, and the President
hugged her. While they hugged, she spotted a gardener outside the study
window, and they moved into the hallway by the bathroom.(510)

There, the President was "the most affectionate with me he'd ever been,"
Ms. Lewinsky testified. He stroked her arm, toyed with her hair, kissed her
on the neck, praised her intellect and beauty.(511) In Ms. Lewinsky's
recollection:

[H]e remarked . . . that he wished he had more time for me. And so I said,
well, maybe you will have more time in three years. And I was . . .
thinking just when he wasn't President, he was going to have more time on
his hands. And he said, well, I don't know, I might be alone in three
years. And then I said something about . . . us sort of being together. I
think I kind of said, oh, I think we'd be a good team, or something like
that. And he . . . jokingly said, well, what are we going to do when I'm 75
and I have to pee 25 times a day? And . . . I told him that we'd deal with
that. . . .(512)

Ms. Lewinsky testified that "I left that day sort of emotionally stunned,"
for "I just knew he was in love with me."(513)

Just before leaving, according to Ms. Lewinsky, she told the President
"that I wanted to talk to him about something serious and that while I
didn't want to be the one to talk about this with him, I thought it was
important he know."(514) She informed him that Newsweek was working on an
article about Kathleen Willey, a former White House volunteer who claimed
that the President had sexually harassed her during a private meeting in
the Oval Office on November 23, 1993. (Ms. Lewinsky knew of the article
from Ms. Tripp, who had worked at the White House at the time of the
alleged incident and had heard about the incident from Ms. Willey. Michael
Isikoff of Newsweek had talked with Ms. Tripp about the episode in March
1997 and again shortly before July 4, and Ms. Tripp had subsequently
related the Isikoff conversations to Ms. Lewinsky.(515)) Ms. Lewinsky told
the President what she had learned from Ms. Tripp (whom she did not name),
including the fact that Ms. Tripp had tried to get in touch with Deputy
White House Counsel Bruce Lindsey, who had not returned her calls.(516)

Ms. Lewinsky testified about why she conveyed this information to the
President: "I was concerned that the President had no idea this was going
on and that this woman was going to be another Paula Jones and he didn't
really need that."(517) She understood that Ms. Willey was looking for a
job, and she thought that the President might be able to "make this go
away" by finding her a job.(518)

The President responded that the harassment allegation was ludicrous,
because he would never approach a small-breasted woman like Ms.
Willey.(519) He further said that, during the previous week, Ms. Willey had
called Nancy Hernreich to warn that a reporter was working on a story about
Ms. Willey and the President; Ms. Willey wondered how she could get out of
it.(520)

According to Ms. Lewinsky, the President had no telephone calls during her
time with him. At 10:19 a.m., probably after her departure (her exit time
is not shown on logs), he placed two calls, both potentially follow-ups to
the conversation about the Newsweek article. First, he spoke with Bruce
Lindsey for three minutes, then with Nancy Hernreich for 11 minutes.(521)

D. July 14-15 Discussions of Linda Tripp

On the evening of Monday, July 14, 1997, just after Ms. Lewinsky had
returned from an overseas trip, the President had her come to the White
House to discuss Linda Tripp and Newsweek.(522) Ms. Lewinsky entered the
White House at 9:34 p.m. and exited at 11:22 p.m.(523) The President was in
the Oval Office area from 9:28 to 11:25 p.m.(524)

Ms. Lewinsky testified that, at around 7:30 p.m. that evening, Ms. Currie
telephoned and said that the President wanted to talk to her or see her. At
about 8:30 or 9:00 p.m., Ms. Currie called again and asked Ms. Lewinsky to
come to the White House.(525)

Ms. Lewinsky testified that the President met her in Ms. Currie's office,
then took her into Ms. Hernreich's office.(526) (Records show that seven
minutes after Ms. Lewinsky's entry to the White House complex, the
President left the Oval Office for the appointment secretary's
office.)(527) According to Ms. Lewinsky:

It was an unusual meeting . . . . It was very distant and very cold. . . .
[A]t one point he asked me if the woman that I had mentioned on July 4th
was Linda Tripp. And I hesitated and then answered yes, and he talked about
that there was some issue . . . to do with Kathleen Willey and that, as he
called it, that there was something on the Sludge Report, that there had
been some information.(528)

The President told Ms. Lewinsky that Ms. Willey had called the White House
again, this time to report that Mr. Isikoff somehow knew of her earlier
White House call.(529) The President wondered if Ms. Lewinsky had mentioned
the Willey call to Ms. Tripp, who in turn might have told Mr. Isikoff. Ms.
Lewinsky acknowledged that she had done so. Ms. Lewinsky testified: "[H]e
was concerned about Linda, and I reassured him. He asked me if I trusted
her, and I said yes."(530) The President asked Ms. Lewinsky to try to
persuade Ms. Tripp to call Mr. Lindsey.(531) The President, according to
Ms. Lewinsky, also asked if she had confided anything about their
relationship to Ms. Tripp. Ms. Lewinsky said (falsely) that she had
not.(532)

The President left to participate in a conference call, which Ms. Lewinsky
understood was with his attorneys, while Ms. Lewinsky sat with Ms.
Currie.(533) According to White House records, at 10:03 p.m. the President
participated in a 51-minute conference call with Robert Bennett, his
private attorney in the Jones case, and Charles Ruff, White House Counsel.
Immediately after completing that call, the President had a six-minute
phone conversation with Bruce Lindsey.(534)

Afterward, the President returned and told Ms. Lewinsky, in her
recollection, to notify Ms. Currie the following day, "without getting into
details with her, even mentioning names with her," whether Ms. Lewinsky had
"'mission-accomplished' . . . with Linda."(535)

The next day, according to Ms. Lewinsky, she did talk with Ms. Tripp, then
called Ms. Currie and said she needed to talk with the President. He called
her that evening. She told him "that I had tried to talk to Linda and that
she didn't seem very receptive to trying to get in touch with Bruce Lindsey
again, but that I would continue to try."(536) The President was in a sour
mood, according to Ms. Lewinsky, and their conversation was brief.(537)

E. July 16 Meeting with Marsha Scott

On July 16, 1997, Ms. Lewinsky met again with Ms. Scott about returning to
the White House.(538) Ms. Scott said she would try to detail Ms. Lewinsky
from the Pentagon to Ms. Scott's office on a temporary basis, according to
Ms. Lewinsky.(539) In that way, Ms. Scott said, Ms. Lewinsky could prove
herself. Ms. Scott also said that "they had to be careful and protect [the
President]."(540) Both Ms. Scott and Ms. Currie confirmed that Ms. Scott
talked with Ms. Lewinsky about the possibility of being detailed to work at
the White House.(541) Ms. Scott testified that she tried to arrange the
detail on her own, without any direction from the President; Ms. Currie,
however, testified that the President instructed her and Ms. Scott to try
to get Ms. Lewinsky a job.(542)

F. July 24 Meeting

On Thursday, July 24, 1997, the day after her 24th birthday, Ms. Lewinsky
visited the White House from 6:04 to 6:26 p.m., admitted by Ms.
Currie.(543) The President was in the Oval Office when she arrived; he
moved to the study at 6:14 p.m. and remained there until her
departure.(544) He had no telephone calls during Ms. Lewinsky's visit.(545)

According to Ms. Lewinsky, she went to the White House to pick up a
photograph from Ms. Currie, who said the President might be available for a
quick meeting. Ms. Currie put Ms. Lewinsky in the Cabinet Room while the
President finished another meeting, then took her to see him. They chatted
for five to ten minutes, and the President gave Ms. Lewinsky, as a birthday
present, an antique pin.(546)

G. Newsweek Article and Its Aftermath

Newsweek published the Kathleen Willey story in its August 11, 1997,
edition (which appeared a week before the cover date). The article quoted
Ms. Tripp as saying that Ms. Willey, after leaving the Oval Office on the
day of the President's alleged advances, looked "disheveled," "flustered,
happy, and joyful." The article also quoted Robert Bennett as saying that
Ms. Tripp was "not to be believed."(547)

After the article appeared, Ms. Tripp wrote a letter to Newsweek charging
that she had been misquoted, but the magazine did not publish it.(548) Ms.
Lewinsky subsequently told the President about Ms. Tripp's letter. He
replied, Ms. Lewinsky said in a recorded conversation, "Well, that's good
because it sure seemed like she screwed me from that article."(549)

H. August 16 Meeting

On Saturday, August 16, 1997, Ms. Lewinsky tried, unsuccessfully, to resume
her sexual relationship with the President. She visited the White House on
that day from 9:02 to 10:20 a.m.(550) The President moved from the
Residence to the Oval Office at 9:20 a.m. and remained in the Oval Office
until 10:03 a.m.(551) After a one-minute call to Betty Currie at her desk
at 9:18 a.m., evidently from the Residence, the President had no calls
while Ms. Lewinsky was at the White House.(552) The next day he left for a
vacation on Martha's Vineyard.(553)

Ms. Lewinsky testified that she brought birthday gifts for the President
(his birthday is August 19):

I had set up in his back office, I had brought an apple square and put a
candle and had put his birthday presents out. And after he came back in and
I sang happy birthday and he got his presents, I asked him . . . if we
could share a birthday kiss in honor of our birthdays, because mine had
been just a few weeks before. So, he said that that was okay and we could
kind of bend the rules that day. And so . . . we kissed.(554)

Ms. Lewinsky touched the President's genitals through his pants and moved
to perform oral sex, but the President rebuffed her.(555) In her
recollection: "[H]e said, I'm trying not to do this and I'm trying to be
good. . . . [H]e got visibly upset. And so . . . I hugged him and I told
him I was sorry and not to be upset."(556) Later, in a draft note to
"Handsome," Ms. Lewinsky referred to this visit: "It was awful when I saw
you for your birthday in August. You were so distant that I missed you as I
was holding you in my arms."(557)

I. Continuing Job Efforts

Ms. Lewinsky and Ms. Scott talked by phone on September 3, 1997, for 47
minutes.(558) According to notes that Ms. Lewinsky wrote to two friends,
Ms. Scott told her that the detail slot in her office had been
eliminated.(559) Ms. Lewinsky told one friend:

So for now, there isn't any place for me to be detailed. So I should be
PATIENT. I told her I was very upset and disappointed (even though I really
didn't want to work for her) and then she and I got into it. She didn't
understand why I wanted to come back when there were still people there who
would give me a hard time and that it isn't the right political climate for
me to come back. . . . She asked me why I kept pushing the envelope on
coming back there -- after all, I had the experience of being there
already. So it's over. I don't know what I will do now but I can't wait any
more and I can't go through all of this crap anymore. In some ways I hope I
never hear from him again because he'll just lead me on because he doesn't
have the balls to tell me the truth.(560)

Ms. Scott testified that "[t]he gist" of Ms. Lewinsky's email message
describing the conversation "fits with what I remember telling her."(561)

Ms. Lewinsky expressed her escalating frustration in a note to the
President that she drafted (but did not send).(562) She wrote:

I believe the time has finally come for me to throw in the towel. My
conversation with Marsha left me disappointed, frustrated, sad and angry. I
can't help but wonder if you knew she wouldn't be able to detail me over
there when I last saw you. Maybe that would explain your coldness. The only
explanation I can reason for your not bringing me back is that you just
plain didn't want to enough or care about me enough.

Ms. Lewinsky went on to discuss other women rumored to be involved with the
President who enjoy "golden positions," above criticism, "because they have
your approval." She continued: "I just loved you -- wanted to spend time
with you, kiss you, listen to you laugh -- and I wanted you to love me
back." She closed: "As I said in my last letter to you I've waited long
enough. You and Marsha win. I give up. You let me down, but I

shouldn't have trusted you in the first place.(563)

Ms. Lewinsky continued trying to discuss her situation with the President.
On Friday, September 12, 1997, she arrived at the White House without an
appointment, called Ms. Currie, and had a long wait at the gate. When Ms.
Currie came to meet her, Ms. Lewinsky was crying. Ms. Currie explained that
sometimes the President's hands are tied -- but, she said, she had gotten
his authorization to ask John Podesta, the Deputy Chief of Staff, to help
Ms. Lewinsky return to work at the White House.(564)

J. Black Dog Gifts

Before the President had left for vacation, Ms. Lewinsky had sent a note
asking if he could bring her a T-shirt from the Black Dog, a popular
Vineyard restaurant.(565) In early September, Ms. Currie gave several Black
Dog items to Ms. Lewinsky.(566) In an email message to Catherine Davis, Ms.
Lewinsky wrote: "Well, I found out from Betty yesterday that he not only
brought me a t-shirt, he got me 2 t-shirts, a hat and a dress!!!! Even
though he's a big schmuck, that is surprisingly sweet -- even that he
remembered!"(567)

K. Lucy Mercer Letter and Involvement of Chief of Staff

A letter dated September 30, 1997, styled as an official memo, was found in
Ms. Lewinsky's apartment. According to Ms. Lewinsky, she sent this letter
or a similar one to the President.(568) Addressed to "Handsome" and bearing
the subject line "The New Deal," the faux memo proposed a visit that
evening after "everyone else goes home." Ms. Lewinsky wrote: "You will show
me that you will let me visit you sans a crisis, and I will be on my best
behavior and not stressed out when I come (to see you, that is)." She
closed with an allusion to a woman rumored to have been involved with an
earlier President: "Oh, and Handsome, remember FDR would never have turned
down a visit with Lucy Mercer!"(569)

Ms. Lewinsky did not visit the White House the night of September 30, but
the President called her late the night of September 30 or October 1.(570)
According to Ms. Lewinsky, he may have mentioned during this call that he
would get Erskine Bowles to help her find a White House job.(571)

At around this time, the President did ask the White House Chief of Staff
to help in the job search. Mr. Bowles testified about a conversation with
the President in the Oval Office: "He told me that there was a young woman
-- her name was Monica Lewinsky -- who used to work at the White House;
that Evelyn . . . thought she hung around the Oval Office too much and
transferred her to the Pentagon."(572) The President asked Mr. Bowles to
try to find Ms. Lewinsky a job in the Old Executive Office Building.(573)
Mr. Bowles assigned his deputy, John Podesta, to handle it.(574)

L. News of Job Search Failure

On October 6, 1997, according to Ms. Lewinsky, she was told that she would
never work at the White House again. Ms. Tripp conveyed the news, which she
indicated had come from a friend on the White House staff. Ms. Lewinsky
testified:

Linda Tripp called me at work on October 6th and told me that her friend
Kate in the NSC . . . had heard rumors about me and that I would never work
in the White House again . . . . [Kate's] advice to me was "get out of
town."(575)

For Ms. Lewinsky, who had previously considered moving to New York, this
call was the "straw that broke the camel's back."(576) She was
enraged.(577)

In a note she drafted (but did not send), Ms. Lewinsky expressed her
frustration. She wrote:

Any normal person would have walked away from this and said, "He doesn't
call me, he doesn't want to see me -- screw it. It doesn't matter." I can't
let go of you. . . . I want to be a source of pleasure and laughter and
energy to you. I want to make you smile.

She went on to relate that she had heard second-hand from a White House
employee "that I was 'after the President' and would never be allowed to
work [in] the complex." Ms. Lewinsky said she could only conclude "that all
you have promised me is an empty promise. . . . I am once again totally
humiliated. It is very clear that there is no way I am going to be brought
back." She closed the note: "I will never do anything to hurt you. I am
simply not that kind of person. Moreover, I love you."(578)

When terminating their sexual relationship on May 24, the President had
told Ms. Lewinsky that he hoped they would remain friends, for he could do
a great deal for her.(579) Now, having learned that he could not (or would
not) get her a White House job, Ms. Lewinsky decided to ask him for a job
in New York, perhaps at the United Nations -- a possibility that she had
mentioned to him in passing over the summer. On the afternoon of October 6,
Ms. Lewinsky spoke of this plan to Ms. Currie, who quoted the President as
having said earlier: "Oh, that's no problem. We can place her in the UN
like that."(580)

In a recorded conversation later on October 6, Ms. Lewinsky said she wanted
two things from the President. The first was contrition: He needed to
"acknowledge . . . that he helped fuck up my life."(581) The second was a
job, one that she could obtain without much effort: "I don't want to have
to work for this position . . . . I just want it to be given to me."(582)
Ms. Lewinsky decided to write the President a note proposing that the two
of them "get together and work on some way that I can come out of this
situation not feeling the way I do."(583) After composing the letter, she
said: "I want him to feel a little guilty, and I hope that this letter did
that."(584)

In this letter, which was sent via courier on October 7, Ms. Lewinsky said
she understood that she would never be given a White House job, and she
asked for a prompt meeting to discuss her job situation.(585) She went on
to advance a specific request:

I'd like to ask you to help me secure a position in NY beginning 1
December. I would be very grateful, and I am hoping this is a solution for
both of us. I want you to know that it has always been and remains more
important to me to have you in my life than to come back. . . . Please
don't let me down.(586)

                        IX. October-November 1997:

                         United Nations' Job Offer

Having learned that she would not be able to return to the White House, Ms.
Lewinsky sought the President's help in finding a job in New York City. The
President offered to place her at the United Nations. After initial
enthusiasm, Ms. Lewinsky cooled on the idea of working at the U.N., and she
prodded the President to get her a job in the private sector.

A. October 10: Telephone Conversation

According to Ms. Lewinsky, the President telephoned her at approximately
2:00 to 2:30 a.m. on Friday, October 10.(587) They spent much of the
hour-and-a-half call arguing. "[H]e got so mad at me, he must have been
purple," she later recalled.(588)

According to Ms. Lewinsky, the President said: "If I had known what kind of
person you really were, I wouldn't have gotten involved with you."(589) He
reminded Ms. Lewinsky that she had earlier promised, "[i]f you just want to
stop doing this, I'll

. . . be no trouble."(590) Ms. Lewinsky said she challenged the President:
"[T]ell me . . . when I've caused you trouble."(591) The President
responded, "I've never worried about you. I've never been worried you would
do something to hurt me."(592)

When the conversation shifted to her job search, Ms. Lewinsky complained
that the President had not done enough to help her. He responded that, on
the contrary, he was eager to help.(593) The President said that he
regretted Ms. Lewinsky's transfer to the Pentagon and assured her that he
would not have permitted it had he foreseen the difficulty in returning her
to the White House.(594) Ms. Lewinsky told him that she wanted a job in New
York by the end of October, and the President promised to do what he
could.(595)

B. October 11 Meeting

At approximately 8:30 a.m. on Saturday, October 11, according to Ms.
Lewinsky, Ms. Currie called and told her that the President wished to see
her.(596) Ms. Lewinsky entered the White House at 9:36 a.m. and departed at
10:54 a.m.(597) The President entered the Oval Office at 9:52 a.m.(598)

Ms. Lewinsky met with the President in the study, and they discussed her
job search.(599) Ms. Lewinsky told the President that she wanted to pursue
jobs in the private sector, and he told her to prepare a list of New York
companies that interested her.(600) Ms. Lewinsky asked the President
whether Vernon Jordan, a well-known Washington attorney who she knew was a
close friend of the President and had many business contacts, might help
her find a job.(601) According to Ms. Lewinsky, the President was receptive
to the idea.(602)

In a recorded conversation, Ms. Lewinsky said that, at the end of the
October 11 meeting, she and the President joined Ms. Currie in the Oval
Office. The President grabbed Ms. Lewinsky's arm and kissed her on the
forehead.(603) He told her: "I talked to Erskine [Bowles] about . . .
trying to get John Hilley to give you . . . a good recommendation for your
work here."(604)

Later, Ms. Lewinsky and Ms. Tripp discussed their concerns about the
President's involvement in Ms. Lewinsky's job search. Specifically, Ms.
Lewinsky was nervous about involving the President's Chief of Staff:

Ms. Lewinsky: Well, see, I don't really think -- I'm going to tell him that
I don't think Erskine should have anything to do with this. I don't think
anybody who works there should.

Ms. Tripp: I don't see how that's -- how that's a problem.

Ms. Lewinsky: Because look at what happened with Webb Hubbell.(605)

Ms. Lewinsky preferred that Vernon Jordan assist her in her job search:

Ms. Tripp: Well, I don't remember during the Webb Hubbell thing, was Vernon
mentioned?

Ms. Lewinsky: Yeah, but there's a big difference. I think somebody could
construe, okay? Somebody could construe or say, "Well, they gave her a job
to shut her up. They made her happy. . . . And he [Mr. Bowles] works for
the government and shouldn't have done that." And with the other one [Mr.
Jordan] you can't say that.(606)

C. October 16-17: The "Wish List"

On October 16, Ms. Lewinsky sent the President a packet, which included
what she called a "wish list" describing the types of jobs that interested
her in New York City.(607) The note began: My dream had been to work in
Communications or Strategic Planning at the White House. I am open to any
suggestions that you may have on work that is similar to that or may
intrigue me. The most important things to me are that I am engaged and
interested in my work, I am not someone's administrative/ executive
assistant, and my salary can provide me a comfortable living in NY.(608)

She identified five public relations firms where she would like to
work.(609) Ms. Lewinsky concluded by saying of the United Nations:

I do not have any interest in working there. As a result of what happened
in April '96, I have already spent a year and a half at an agency in which
I have no interest. I want a job where I feel challenged, engaged, and
interested. I don't think the UN is the right place for me.(610)

In a recorded conversation, Ms. Lewinsky said she wanted the President to
take her list seriously and not ask her to settle for a U.N. job.(611) She
said she hoped "that if he starts to pick a bone with me and the U.N., he
sure as hell doesn't do it on the phone. . . . I don't want to start
getting into a screaming match with him on the phone."(612)

In addition to the "wish list," Ms. Lewinsky said she enclosed in the
packet a pair of sunglasses and "a lot of things in a little envelope,"
including some jokes, a card, and a postcard.(613) She said that she had
written on the card: "Wasn't I right that my hugs are better in person than
in cards?"(614) The postcard featured a "very erotic" Egon Schiele
painting.(615) Ms. Lewinsky also enclosed a note with her thoughts on
education reform.(616)

Ms. Lewinsky testified that she felt that the President owed her a job for
several reasons: Her relationship with him was the reason she had been
transferred out of the White House; he had promised her a job and so far
had done nothing to help her find one; and she had left the White House
"quietly," without making an issue of her relationship with the
President.(617)

D. The President Creates Options

At some point around this time in the fall of 1997, Ms. Currie asked John
Podesta, the Deputy Chief of Staff, to help Ms. Lewinsky find a job in New
York.(618) Mr. Podesta testified that, during a Presidential trip to Latin
America, he approached then-U.N. Ambassador William Richardson while aboard
Air Force One and asked the Ambassador to consider a former White House
intern for a position at the U.N.(619) At the time, Mr. Podesta could not
recall the intern's name.(620) Ambassador Richardson and the President both
testified that they never discussed Ms. Lewinsky with each other.(621)

Ambassador Richardson returned from Latin America on Sunday, October
19.(622) Within a few days, his Executive Assistant, Isabelle Watkins,
called Mr. Podesta's secretary and asked whether "she knew anything about a
resume that John was going to send us."(623) Mr. Podesta's secretary knew
nothing about it and asked Mr. Podesta what to do; he instructed her to
call Ms. Currie.(624) At 3:09 p.m. on October 21, Ms. Currie faxed Ms.
Lewinsky's resume to the United Nations.(625)

At 7:01 p.m., a six-minute call was placed to Ms. Lewinsky's apartment from
a U.N. telephone number identified in State Department records as
"Ambassador Richardson's line."(626) Ms. Lewinsky testified that she spoke
to Ambassador Richardson. A woman called, Ms. Lewinsky testified, and said,
"[H]old for Ambassador Richardson."(627) Then the Ambassador himself came
on the line: "I remember, because I was shocked and I was . . . very
nervous."(628) The purpose of the call was to schedule a job interview at a
Watergate apartment the following week.(629) At odds with Ms. Lewinsky, the
Ambassador and Ms. Watkins both testified that Ms. Watkins, not the
Ambassador, spoke with Ms. Lewinsky.(630)

A few days later, according to Ms. Lewinsky, the President called her. She
had been upset because no one at the White House had prepared her for the
Ambassador's recent call and because she did not want the White House to
railroad her into taking the U.N. job.(631) She reiterated that she was
eager to pursue other opportunities, especially in the private sector.(632)
The President reassured her, promising that a U.N. position was just one of
many options.(633)

Ms. Lewinsky spoke to the President again one week later. Ms. Lewinsky
testified that she told Ms. Currie to ask the President to call her to
assuage her nervousness before the U.N. interview.(634)

According to Ms. Lewinsky, on October 30, the night before the interview,
the President did call. She characterized the conversation as a "pep talk":
"[H]e was trying to kind of build my confidence and reassure me."(635) The
President told her to call Ms. Currie after the interview.(636)In his Jones
deposition, the President indicated that he learned of her interview with
Ambassador Richardson not from Ms. Lewinsky herself but from Ms.
Currie.(637)

E. The U.N. Interview and Job Offer

On Friday morning, October 31, Ambassador Richardson and two of his
assistants, Mona Sutphen and Rebecca Cooper, interviewed Ms. Lewinsky at
the Watergate.(638) According to Ambassador Richardson, he "listen[ed]
while Mona and Rebecca were interviewing her."(639) Neither Ambassador
Richardson nor any of his staff made inquiries, before or after the
interview, about Ms. Lewinsky's prior work performance.(640)

On Sunday, November 2, Ms. Lewinsky drafted a letter to Ms. Currie asking
what to do in the event she received an offer from the U.N.(641) She wrote:

I became a bit nervous this weekend when I realized that Amb. Richardson
said his staff would be in touch with me this week. As you know, the UN is
supposed to be my back-up, but because VJ [Vernon Jordan] has been out of
town, this is my only option right now. What should I say to Richardson's
people this week when they call?(642)

Ms. Lewinsky asked Ms. Currie to speak to the President about her problem:
"If you feel it's appropriate, maybe you could ask 'the big guy' what he
wants me to do. Ahhhhh . . . anxiety!!!!!"(643) Ms. Lewinsky also mentioned
the President's promise to involve Vernon Jordan in her job search:

I don't think I told you that in my conversation last Thursday night with
him that he said that he would ask you to set up a meeting between VJ and
myself, once VJ got back. I assume he'll mention this to you at some point
-- hopefully sooner rather than later!(644)

Before Ms. Lewinsky sent this letter, in her recollection, she received an
offer from the U.N.(645) Phone records reflect that, at 11:02 a.m. on
November 3, a three-minute call was placed to Ms. Lewinsky from the U.N.
line identified in State Department records as Ambassador
Richardson's.(646) Ms. Lewinsky stated that she believes she spoke to
Ambassador Richardson, who extended her a job offer.(647)

According to his assistant, Ambassador Richardson made the decision to hire
Ms. Lewinsky. Ms. Sutphen testified:

I said, are you sure; and he said, yeah, yeah, I'm sure, why. And I said .
. . are you sure, though you don't want to talk to anyone else . . . . And
he said, no, no, I think it's fine; why don't you go ahead and give her an
offer?(648)

Ambassador Richardson and Ms. Sutphen both testified that Ms. Sutphen, not
the Ambassador, extended the job offer to Ms. Lewinsky. They recalled that
the offer was made a week or 10 days after the interview, though Ms.
Sutphen, when shown the phone records, testified that the November 3 call
to Ms. Lewinsky probably was the job offer.(649)

Ms. Lewinsky testified that she told Ms. Currie about the offer and she
probably also told the President directly.(650) Ms. Currie first testified
that she had "probably" told the President about Ms. Lewinsky's U.N. offer,
then testified that she had in fact told him, then testified that she could
not remember, though she acknowledged that the President was interested in
Ms. Lewinsky's getting a job.(651)

When the President was asked in the Jones deposition whether he knew that
Ms. Lewinsky had received the offer of a job at the U.N., he testified: "I
know that she interviewed for one. I don't know if she was offered one or
not."(652)

F. The U.N. Job Offer Declined

Three weeks after she received an offer, on November 24, Ms. Lewinsky
called Ms. Sutphen and asked for more time to consider the offer because
she wanted to pursue possibilities in the private sector.(653) Ms. Sutphen
told Ambassador Richardson, who, according to Ms. Sutphen, said the delay
would be fine.(654) Over a month later, on January 5, 1998, Ms. Lewinsky
finally turned down the job.(655)

                   X. November 1997: Growing Frustration

Ms. Lewinsky met with Vernon Jordan, who promised to help her find a job in
New York. November proved, however, to be a month of inactivity with
respect to both Ms. Lewinsky's job search and her relationship with the
President. Mr. Jordan did not meet with Ms. Lewinsky again, nor did he
contact anyone in New York City on her behalf. Ms. Lewinsky became
increasingly anxious about her inability to see the President. Except for a
momentary encounter in mid-November, Ms. Lewinsky did not meet with the
President between October 11 and December 5.

A. Interrogatories Answered

On November 3, 1997, the President answered Paula Jones's Second Set of
Interrogatories. Two of those interrogatories asked the President to list
any woman other than his wife with whom he had "had," "proposed having," or
"sought to have" sexual relations during the time that he was Attorney
General of Arkansas, Governor of Arkansas, and President of the United
States.(656) President Clinton objected to the scope and relevance of both
interrogatories and refused to answer them.(657)

B. First Vernon Jordan Meeting

In mid-October, the President had agreed to involve Vernon Jordan in Ms.
Lewinsky's job search.(658) In a draft letter to Ms. Currie dated November
2, Ms. Lewinsky wrote that the President had "said he would ask you to set
up a meeting between VJ and myself."(659) According to Ms. Lewinsky, on
November 3 or November 4, Ms. Currie told her to call Vernon Jordan's
secretary to arrange a meeting.(660) Ms. Currie said she had spoken with
Mr. Jordan and he was expecting Ms. Lewinsky's call.(661) In Ms. Lewinsky's
account, Ms. Currie sought Mr. Jordan's aid at the President's
direction.(662) Mr. Jordan likewise testified that, in his understanding,
the President was behind Ms. Currie's request.(663)

Ms. Currie testified at various points that she contacted Mr. Jordan on her
own initiative; that the President "probably" talked with her about Ms.
Lewinsky's New York job hunt; and that she could not recall whether the
President was involved.(664) In his Jones deposition, the President was
asked whether he did anything to facilitate a meeting between Mr. Jordan
and Ms. Lewinsky. He testified:

I can tell you what my memory is. My memory is that Vernon said something
to me about her coming in, Betty had called and asked if he [Mr. Jordan]
would see her [Ms. Lewinsky]. . . . I'm sure if he said something to me
about it I said something positive about it. I wouldn't have said anything
negative about it.(665)

When pressed, the President testified that he did not think that he was the
"precipitating force" in arranging the meeting between Mr. Jordan and Ms.
Lewinsky.(666)

At 8:50 a.m. on November 5, Mr. Jordan spoke with the President by
telephone for five minutes.(667) Later that morning, Mr. Jordan and Ms.
Lewinsky met in his office for about twenty minutes.(668) She told him that
she intended to move to New York, and she named several companies where she
hoped to work.(669) She showed him the "wish list" that she had sent the
President on October 16.(670) Mr. Jordan said that he had spoken with the
President about her and that she came "highly recommended."(671) Concerning
her job search, Mr. Jordan said: "We're in business."(672)

In the course of the day, Mr. Jordan placed four calls to Ms. Hernreich
(whom he acknowledged calling when he wished to speak to the
President(673)) and one to Ms. Currie.(674) Mr. Jordan testified that he
could not remember the calls, but "[i]t is entirely possible" that they
concerned Monica Lewinsky.(675)

Mr. Jordan also visited the White House and met with the President at 2:00
p.m. that day.(676) Again, Mr. Jordan testified that he had "no
recollection" of the substance of his conversation with the President.(677)

On November 6, the day after meeting with Mr. Jordan, Ms. Lewinsky wrote
him a thank-you letter: "It made me happy to know that our friend has such
a wonderful confidant in you."(678) Also on November 6, Ms. Lewinsky wrote
in an email to a friend that she expected to hear from Mr. Jordan "later
next week."(679) The evidence indicates, though, that Mr. Jordan took no
steps to help Ms. Lewinsky until early December, after she appeared on the
witness list in the Jones case.

Mr. Jordan initially testified that he had "no recollection of having met
with Ms. Lewinsky on November 5."(680) When shown documentary evidence
demonstrating that his first meeting with Ms. Lewinsky occurred in early
November, he acknowledged that an early November meeting was "entirely
possible."(681) Mr. Jordan's failure to remember his November meeting with
Ms. Lewinsky may indicate the low priority he attached to it at the time.

C. November 13: The Zedillo Visit

On Thursday, November 13, while Ernesto Zedillo, the President of Mexico,
was in the White House, Ms. Lewinsky met very briefly with President
Clinton in the private study.(682) Ms. Lewinsky's visit, which she
described in an email as a "hysterical escapade," was the culmination of
days of phone calls and notes to Ms. Currie and the President.(683)

Over the course of the week that preceded November 13, Ms. Lewinsky made
several attempts to arrange a visit with the President. On Monday, November
10, in addition to making frequent calls to Ms. Currie, she sent the
President a note asking for a meeting.(684)

She hoped to see him on Tuesday, November 11 (Veterans Day), but he did not
respond.(685) By courier,(686) she sent the President another note:

I asked you three weeks ago to please be sensitive to what I am going
through right now and to keep in contact with me, and yet I'm still left
writing notes in vain. I am not a moron. I know that what is going on in
the world takes precedence, but I don't think what I have asked you for is
unreasonable.(687)

She added: "This is so hard for me. I am trying to deal with so much
emotionally, and I have nobody to talk to about it. I need you right now
not as president, but as a man. PLEASE be my friend."(688)

That evening, November 12, according to Ms. Lewinsky, the President called
and invited her to the White House the following day.(689) In an email to a
friend, Ms. Lewinsky wrote that she and the President "talked for almost an
hour."(690) She added: "[H]e thought [N]ancy [Hernreich] (one of the
meanies) would be out for a few hours on Thursday and I could come see him
then."(691)

The following morning, November 13, Ms. Lewinsky tried to arrange a visit
with the President. She called repeatedly but suspected that Ms. Currie was
not telling the President of her calls.(692) Around noon, Ms. Currie told
Ms. Lewinsky that the President had left to play golf. Ms. Lewinsky, in her
own words, "went ballistic."(693)

After the President returned from the Army-Navy Golf Course in the late
afternoon, Ms. Lewinsky told Ms. Currie that she was coming to the White
House to give him some gifts.(694) Ms. Currie suggested that Ms. Lewinsky
wait in Ms. Currie's car in the White House parking lot. Ms. Lewinsky went
to the White House only to find that the doors to Ms. Currie's car were
locked. Ms. Lewinsky waited in the rain.(695)

Ms. Currie eventually met her in the parking lot, and, in Ms. Lewinsky's
words, they made a "bee-line" into the White House, sneaking up the back
stairs to avoid other White House employees, particularly Presidential aide
Stephen Goodin.(696) Ms. Lewinsky left two small gifts for the President
with Ms. Currie, then waited alone for about half an hour in the Oval
Office study.(697) In the study, Ms. Lewinsky saw several gifts she had
given the President, including Oy Vey! The Things They Say: A Guide to
Jewish Wit, Nicholson Baker's novel Vox, and a letter opener decorated with
a frog.(698)

The President finally joined Ms. Lewinsky in the study, where they were
alone for only a minute or two.(699) Ms. Lewinsky gave him an antique
paperweight in the shape of the White House.(700) She also showed him an
email describing the effect of chewing Altoid mints before performing oral
sex. Ms. Lewinsky was chewing Altoids at the time, but the President
replied that he did not have enough time for oral sex.(701) They kissed,
and the President rushed off for a State Dinner with President
Zedillo.(702)

D. November 14-December 4: Inability to See the President

After this brief November 13 meeting, Ms. Lewinsky did not see the
President again until the first week in December. Hoping to arrange a
longer rendezvous, she sent the President several notes, as well as a
cassette on which she recorded a message.(703)

Along with her chagrin over not seeing the President, Ms. Lewinsky was
frustrated that her job search had apparently stalled. A few days before
Thanksgiving, she complained to Ms. Currie that she had not heard from Mr.
Jordan.(704) Ms. Currie arranged for her to speak with him "before
Thanksgiving," while Ms. Lewinsky was in Los Angeles. Mr. Jordan told her
to call him the following week to arrange another meeting.(705)

In draft letters to the President, which were recovered from her Pentagon
computer, Ms. Lewinsky reflected on the change in their relationship:
"[B]oth professionally and personally, . . . our personal relationship
changing has caused me more pain. Do you realize that?"(706) She asked for
the President's understanding: "I don't want you to think that I am not
grateful for what you are doing for me now -- I'd probably be in a mental
institute without it -- but I am consumed with this disappointment,
frustration, and anger." Ms. Lewinsky rued the brevity of her November 13
visit with the President: "All you . . . . ever have to do to pacify me is
see me and hold me," she wrote. "Maybe that's asking too much."(707)

                         XI. December 5-18, 1997:

                      The Witness List and Job Search

On Friday, December 5, Paula Jones's attorneys faxed a list of their
potential witnesses -- including Ms. Lewinsky -- to the President's
personal attorneys. The following day, President Clinton saw Ms. Lewinsky
in an unscheduled visit and then discussed the Jones case with his
attorneys and Deputy White House Counsel Bruce Lindsey. A few days later,
Ms. Lewinsky met with Mr. Jordan at his office, and he arranged interviews
for Ms. Lewinsky at three companies. In the middle of the night on December
17, the President called and informed Ms. Lewinsky that she was on the
witness list and that she might have to testify under oath in the Jones
case.

A. December 5: The Witness List

On Friday December 5, 1997, attorneys for Paula Jones identified Ms.
Lewinsky as a potential witness in Ms. Jones's sexual harassment case.(708)
At 5:40 p.m., they faxed their witness list to the President's attorney,
Robert Bennett.(709) Ms. Lewinsky, however, would not learn of her
potential involvement in the Jones case for twelve more days, when the
President informed her.(710)

President Clinton was asked in the grand jury when he learned that Ms.
Lewinsky's name was on the witness list. The President responded: "I
believe that I found out late in the afternoon on the sixth."(711)

B. December 5: Christmas Party at the White House

On Friday, December 5, Ms. Lewinsky returned from Department of Defense
travel in Europe.(712) She asked Ms. Currie if the President could see her
the next day, but Ms. Currie said he was busy meeting with his
lawyers.(713) In the late afternoon, she attended a Christmas party at the
White House with a Defense Department colleague.(714) Ms. Lewinsky
exchanged a few words with the President in the reception line.(715)

The Christmas reception encounter heightened Ms. Lewinsky's frustration. On
the evening of December 5, she drafted an anguished letter to the
President.(716) "[Y]ou want me out of your life," she wrote. "I guess the
signs have been made clear for awhile -- not wanting to see me and rarely
calling. I used to think it was you putting up walls."(717) She had
purchased several gifts for him, and, she wrote, "I wanted to give them to
you in person, but that is obviously not going to happen."(718) Ms.
Lewinsky reminded the President of his words during their October 10
telephone argument:

I will never forget what you said that night we fought on the phone -- if
you had known what I was really like you would never have gotten involved
with me. I'm sure you're not the first person to have felt that way about
me. I am sorry that this has been such a bad experience.(719)

She concluded the letter: "I knew it would hurt to say goodbye to you; I
just never thought it would have to be on paper. Take care."(720)

C. December 6: The Northwest Gate Incident

1. Initial Visit and Rejection

On the morning of Saturday, December 6, Ms. Lewinsky went to the White
House to deliver the letter and gifts to the President. The gifts included
a sterling silver antique cigar holder, a tie, a mug, a "Hugs and Kisses"
box, and an antique book about Theodore Roosevelt.(721) Ms. Lewinsky
planned to leave the parcel with Ms. Currie, who had told Ms. Lewinsky that
the President would be busy with his lawyers and unable to see her.(722)

Ms. Lewinsky arrived at the White House at approximately 10:00 a.m. She
told the Secret Service uniformed officers at the Northwest Gate that she
had gifts to drop off for the President, but that Ms. Currie did not know
she was coming.(723) Ms. Lewinsky and the officers made several calls in an
attempt to locate Ms. Currie.(724) The officers eventually invited Ms.
Lewinsky inside the guard booth.(725) When Ms. Currie learned that Ms.
Lewinsky was at the Northwest Gate, she sent word that the President
"already had a guest in the [O]val," so the officers should have Ms.
Lewinsky wait there for about 40 minutes.(726)

While Ms. Lewinsky was waiting, one officer mentioned that Eleanor Mondale
was in the White House.(727) Ms. Lewinsky correctly surmised that the
President was meeting with Ms. Mondale, rather than his lawyers, and she
was "livid."(728) She stormed away, called and berated Ms. Currie from a
pay phone, and then returned to her Watergate apartment.(729)

Hands shaking and almost crying, Ms. Currie informed several Secret Service
officers that the President was "irate" that someone had disclosed to Ms.
Lewinsky whom he was meeting with.(730) Ms. Currie told Sergeant Keith
Williams, a supervisory uniformed Secret Service Officer, that if he
"didn't find out what was going on, someone could be fired."(731) She also
told Captain Jeffrey Purdie, the Secret Service watch commander for the
uniformed division at the time, that the President was "so upset he wants
somebody fired over this."(732)

2. Ms. Lewinsky Returns to the White House

From her apartment, Ms. Lewinsky reached the President on the phone.(733)
According to Ms. Lewinsky, the President was angry that she had "made a
stink" and said that "it was none of my business . . . what he was
doing."(734)

Then, to Ms. Lewinsky's surprise, the President invited her to visit
him.(735) She testified that "none of the other times that we had really
fought on the phone did it end up resulting in a visit that day."(736)
WAVES records reflect that Ms. Lewinsky was cleared to enter the White
House at 12:52 p.m. and exited at 1:36 p.m.(737)

During their meeting, Ms. Lewinsky told the President that Mr. Jordan had
done nothing to help her find a job.(738) The President responded, "Oh,
I'll talk to him. I'll get on it."(739)

Ms. Lewinsky testified that, overall, she had a "really nice" and
"affectionate" visit with the President.(740) In an email to a friend a few
days later, she wrote that, although "things have been crazy with the
creep, . . . I did have a wonderful visit with him on Saturday. When he
doesn't put his walls up, it is always heavenly."(741)

3. "Whatever Just Happened Didn't Happen"

Later that day (December 6), the uniformed Secret Service officers at the
Northwest Gate were told that no one would be fired -- so long as they
remained quiet. According to Sergeant Williams, Ms. Currie said that, if
the officers did not "tell a lot of people what had happened, then nothing
would happen."(742)

The President told Captain Jeffrey Purdie, the Secret Service watch
commander for the uniformed division at the time, "I hope you use your
discretion."(743) Captain Purdie interpreted the President's remark to mean
that Captain Purdie "wasn't going to say anything," and he in turn told all
of the officers involved not to discuss the incident.(744) One officer
recalled that Captain Purdie told him and other officers, "Whatever just
happened didn't happen."(745) Captain Purdie told another officer, "I was
just in the Oval Office with the President and he wants somebody's ass out
here. . . . As far as you're concerned, . . . [t]his never happened."(746)
In response, that officer, who considered the Northwest Gate incident a
"major event," "just shook [his] head" and "started making a set of [his]
own notes" in order to document the incident.(747)

Captain Purdie recommended to his supervisor, Deputy Chief Charles
O'Malley, that "no paperwork be generated" regarding the Northwest Gate
incident because "Ms. Currie was satisfied with the way things were
handled."(748) According to Captain Purdie, Deputy Chief O'Malley agreed,
and no record of the incident was made.(749) Deputy Chief O'Malley
testified that the meeting between the President and Captain Purdie was the
only occasion he could recall in fourteen years at the White House where a
President directly addressed a job performance issue with a uniformed
division supervisor.(750)

The President was questioned in the grand jury about the incident at the
Northwest Gate. He testified that he knew that Ms. Lewinsky had become
upset upon learning that Ms. Mondale was in the White House "to see us that
day."(751) He testified: "As I remember, I had some other work to do that
morning. . . . "(752) The President said that the disclosure of information
that day was "inappropriate" and "a mistake," but he could not recall
whether he wanted a Secret Service officer fired or gave any such
orders.(753) He thought that the officers "were . . . told not to let it
happen again, and I think that's the way it should have been handled."(754)
When asked if he told Captain Purdie that he hoped that he could count on
his discretion, the President stated, "I don't remember anything I said to
him in that regard."(755)

According to Ms. Lewinsky, the President later indicated to her that he had
concerns about the discretion of the Secret Service uniformed officers. On
December 28 she asked how Paula Jones's attorneys could have known enough
to place her on the witness list. The President replied that the source
might be Linda Tripp or "the uniformed officers."(756)

D. The President Confers with His Lawyers

Deputy Counsel Bruce Lindsey testified that he met with the President and
the President's personal attorney, Robert Bennett, at around 5:00 p.m. on
December 6 to discuss the Jones case.(757) According to Mr. Lindsey, it was
"likely" that he learned about Ms. Lewinsky's appearance on the witness
list in that meeting.(758)

Earlier in the day, at around 12:00 p.m. (after Ms. Lewinsky stormed away
from the Northwest Gate but before she returned and saw the President), Mr.
Lindsey had received a page: "Call Betty ASAP."(759) Mr. Lindsey testified
that he did not recall the page, nor did he know, at the time, that Ms.
Lewinsky had visited the White House.(760)

E. Second Jordan Meeting

The next day (Sunday, December 7), Mr. Jordan visited the White House and
met with the President.(761) Mr. Jordan testified that he was "fairly
certain" that he did not discuss the Jones suit or Ms. Lewinsky.(762)

On Thursday, December 11, Ms. Lewinsky had her second meeting with Mr.
Jordan.(763) Ms. Lewinsky testified that they discussed her job search, and
Mr. Jordan told her to send letters to three business contacts that he
provided her. Mr. Jordan noted that Ms. Lewinsky was anxious to get a job
as quickly as possible, and he took action.(764) In the course of the day,
Mr. Jordan placed calls on her behalf to Peter Georgescu, Chairman and
Chief Executive Officer at Young & Rubicam; Richard Halperin, Executive
Vice President and Special Counsel to the Chairman of MacAndrews & Forbes
Holdings, Inc. (majority stockholder of Revlon); and Ursula Fairbairn,
Executive Vice-President, Human Resources and Quality, of American
Express.(765) Mr. Jordan told Ms. Lewinsky to keep him informed of the
progress of her job search.(766)

At one point in the conversation, according to Ms. Lewinsky, Mr. Jordan
said, "[Y]ou're a friend of the President."(767) This prompted Ms. Lewinsky
to reveal that she "didn't really look at him as the President"; rather,
she "reacted to him more as a man and got angry at him like a man and just
a regular person."(768) When Mr. Jordan asked why Ms. Lewinsky got angry at
the President, she replied that she became upset "when he doesn't call me
enough or see me enough."(769) Ms. Lewinsky testified that Mr. Jordan
advised her to take her frustrations out on him rather than the
President.(770) According to Ms. Lewinsky, Mr. Jordan summed up the
situation: "You're in love, that's what your problem is."(771)

Mr. Jordan recalled a similar conversation, in which Ms. Lewinsky
complained that the President did not see her enough, although he thought
it took place during a meeting eight days later. He testified that he felt
the need to remind Ms. Lewinsky that the President is the "leader of the
free world" and has competing obligations.(772)

Mr. Jordan is "certain" that he had a conversation with the President about
Ms. Lewinsky at some point after this December 11 meeting.(773) He told the
President that he would be trying to get Ms. Lewinsky a job in New
York.(774) Mr. Jordan testified that the President "was aware that people
were trying to get jobs for her, that Podesta was trying to help her, that
Bill Richardson was trying to help her, but that she really wanted to work
in the private sector."(775)

F. Early Morning Phone Call

On December 15, 1997, Paula Jones's lawyers served President Clinton with
her second set of document requests by overnight mail. These requests asked
the President to "produce documents that related to communications between
the President and Monica Lewisky" [sic].(776) This was the first Paula
Jones discovery request to refer to Monica Lewinsky by name.

Ms. Lewinsky testified that in the early-morning hours of December 17, at
roughly 2:00 or 2:30 a.m., she received a call from the President.(777) The
call lasted about half an hour.(778)

The President gave Ms. Lewinsky two items of news: Ms. Currie's brother had
died in a car accident, and Ms. Lewinsky's name had appeared on the witness
list in the Jones case.(779) According to Ms. Lewinsky, the President said
"it broke his heart" to see her name on the witness list.(780) The
President told her that she would not necessarily be subpoenaed; if she
were, he "suggested she could sign an affidavit to try to satisfy [Ms.
Jones's] inquiry and not be deposed."(781)

The President told Ms. Lewinsky to contact Ms. Currie in the event she were
subpoenaed.(782) He also reviewed one of their established cover stories.
He told Ms. Lewinsky that she "should say she visited the [White House] to
see Ms. Currie and, on occasion when working at the [White House], she
brought him letters when no one else was around."(783) The President's
advice "was . . . instantly familiar to [Ms. Lewinsky]."(784) She testified
that the President's use of this "misleading" story amounted to a
continuation of their pre-existing pattern.(785)

Later in the conversation, according to Ms. Lewinsky, the President said he
would try to get Ms. Currie to come in over the weekend so that Ms.
Lewinsky could visit and he could give her several Christmas presents.(786)
Ms. Lewinsky replied that, since Ms. Currie's brother had just died,
perhaps they should "let Betty be."(787)

In his grand jury appearance, the President was questioned about the
December 17 phone call. He testified that, although he could not rule it
out, he did not remember such a call.(788) The President was also asked
whether in this conversation, or a conversation before Ms. Lewinsky's name
came up in the Jones case, he instructed her to say that she was coming to
bring letters. The President answered: "I might well have said that."(789)

But when asked whether he ever said anything along these lines after Ms.
Lewinsky had been identified on the witness list, the President answered:
"I don't recall whether I might have done something like that."(790) He
speculated that he might have suggested this explanation in the context of
a call from a reporter.(791) Nonetheless, he testified, in the context of
the Jones case, "I never asked her to lie."(792)

G. Job Interviews

On December 18, Ms. Lewinsky had two job interviews in New York City. At
MacAndrews & Forbes, she met with Executive Vice President and Special
Counsel to the Chairman Richard Halperin, who viewed the interview as "an
accommodation for Vernon Jordan."(793) At Burson-Marstellar, she
interviewed with Celia Berk, Managing Director of Human Resources.(794) A
few days later, on December 23, Ms. Lewinsky interviewed in Washington,
D.C., with Thomas Schick, Executive Vice President, Corporate Affairs and
Communications, of American Express.(795)

                 XII. December 19, 1997 - January 4, 1998:

                               The Subpoena

Ms. Lewinsky was served with a subpoena in the Jones case on Friday,
December 19. She immediately called Mr. Jordan, and he invited her to his
office. Mr. Jordan spoke with the President that afternoon and again that
evening. He told the President that he had met with Ms. Lewinsky, that she
had been subpoenaed, and that he planned to obtain an attorney for her. On
Sunday, December 28, the President met with Ms. Lewinsky, who expressed
concern about the subpoena's demand for the gifts he had given her. Later
that day, Ms. Currie drove to Ms. Lewinsky's apartment and collected a box
containing some of the subpoenaed gifts. Ms. Currie took the box home and
hid it under her bed.

A. December 19: Ms. Lewinsky Is Subpoenaed

On Friday, December 19, 1997, sometime between 3:00 p.m. and 4:00 p.m., Ms.
Lewinsky was served with a subpoena at her Pentagon office.(796) The
subpoena commanded her to appear for a deposition in Washington, D.C., at
9:30 a.m. on January 23, 1998.(797) The subpoena also required the
production of certain documents and gifts. Among the items that Ms.
Lewinsky was required to produce were "each and every gift including, but
not limited to, any and all dresses, accessories, and jewelry, and/or hat
pins given to you by, or on behalf of, Defendant Clinton," as well as
"[e]very document constituting or containing communications between you and
Defendant Clinton, including letters, cards, notes, memoranda, and all
telephone records."(798)

Ms. Lewinsky testified that, after being served with the subpoena, she
"burst into tears," and then telephoned Mr. Jordan from a pay phone at the
Pentagon.(799) Mr. Jordan confirmed Ms. Lewinsky's account; he said he
tried to reassure Ms. Lewinsky: "[C]ome and talk to me and I will see what
I can do about finding you counsel."(800)

According to records maintained by Mr. Jordan's law firm, Ms. Lewinsky
arrived at his office at 4:47 p.m.(801) White House phone records show
that, at 4:57 p.m., the President telephoned Mr. Jordan; the two men spoke
from 5:01 p.m. to 5:05 p.m.(802) At 5:06 p.m., Mr. Jordan placed a
two-minute call to a Washington, D.C., attorney named Francis Carter.(803)

Ms. Lewinsky and Mr. Jordan gave somewhat different accounts of their
meeting that day. According to Ms. Lewinsky, shortly after her arrival, Mr.
Jordan received a phone call, and she stepped out of his office. A few
minutes later, Ms. Lewinsky was invited back in, and Mr. Jordan called Mr.
Carter.(804)

Mr. Jordan testified that he spoke to the President before Ms. Lewinsky
ever entered his office.(805) He told the President: "Monica Lewinsky
called me up. She's upset. She's gotten a subpoena. She is coming to see me
about this subpoena. I'm confident that she needs a lawyer, and I will try
to get her a lawyer."(806) Mr. Jordan told the President that the lawyer he
had in mind was Francis Carter.(807) According to Mr. Jordan, the President
asked him: "You think he's a good lawyer?" Mr. Jordan responded that he
was.(808) Mr. Jordan testified that informing the President of Ms.
Lewinsky's subpoena "was the purpose of [his] call."(809)

According to Mr. Jordan, when Ms. Lewinsky entered his office, "[H]er
emotional state was obviously one of dishevelment and she was quite upset.
She was crying. She was -- she was highly emotional, to say the
least."(810) She showed him the subpoena as soon as she entered.(811)

Ms. Lewinsky also testified that she discussed the subpoena with Mr.
Jordan.(812) She told him that she found the specific reference to a hat
pin alarming -- how could the Jones's attorneys have known about it?(813)
Mr. Jordan told her it was "a standard subpoena."(814) When he indicated to
Ms. Lewinsky that he would be seeing the President that night, Ms. Lewinsky
told him "to please make sure that he told the President" about her
subpoena.(815)

At some point, according to Mr. Jordan, Ms. Lewinsky asked him about the
future of the Clintons' marriage.(816) Because Ms. Lewinsky seemed
"mesmerized" by President Clinton,(817) he "asked her directly had there
been any sexual relationship between [her] and the President."(818) Mr.
Jordan explained, "You didn't have to be Einstein to know that that was a
question that had to be asked by me at that particular time, because
heretofore this discussion was about a job. The subpoena changed the
circumstances."(819) Ms. Lewinsky said she had not had a sexual
relationship with the President.(820)

Ms. Lewinsky testified, however, that at this time she assumed that Mr.
Jordan knew "with a wink and a nod that [she] was having a relationship
with the President."(821) She therefore interpreted Mr. Jordan's questions
as "What are you going to say?" rather than "What are the [actual] answers
. . .?"(822) When the meeting ended, she "asked [Mr. Jordan] if he would
give the President a hug."(823)

That evening, Mr. Jordan visited the President at the White House.
According to Mr. Jordan, the two met alone in the Residence and talked for
about ten minutes.(824) He testified:

I told him that Monica Lewinsky had been subpoenaed, came to me with a
subpoena. I told him that I was concerned by her fascination, her being
taken with him. I told him how emotional she was about having gotten the
subpoena. I told him what she said to me about whether or not he was going
to leave the First Lady at the end of the term.(825)

Mr. Jordan asked the President "[t]he one question that I wanted
answered."(826) That question was, "Mr. President, have you had sexual
relations with Monica Lewinsky?" The President told Mr. Jordan, "No,
never."(827)

Mr. Jordan told the President: "I'm trying to help her get a job and I'm
going to continue to do that. I'm going to get her counsel and I'm going to
try to be helpful to her as much as I possibly can, both with the lawyer,
and I've already done what I could about the job, and I think you ought to
know that."(828) Mr. Jordan testified: "He thanked me for telling him.
Thanked me for my efforts to get her a job and thanked me for getting her a
lawyer."(829)

In his grand jury testimony, the President recalled that he met with Mr.
Jordan on December 19; however, he testified that his memory of that
meeting was somewhat vague:

I do not remember exactly what the nature of the conversation was. I do
remember that I told him that there was no sexual relationship between me
and Monica Lewinsky, which was true. And that -- then all I remember for
the rest is that he said he had referred her to a lawyer, and I believe it
was Mr. Carter.(830)

Asked whether he recalled that Mr. Jordan told him that Ms. Lewinsky
appeared fixated on him and hoped that he would leave Mrs. Clinton, the
President testified: "I recall him saying he thought that she was upset
with -- somewhat fixated on me, that she acknowledged that she was not
having a sexual relationship with me, and that she did not want to be
[brought] into that Jones lawsuit."(831)

B. December 22: Meeting with Vernon Jordan

Mr. Jordan arranged for Ms. Lewinsky to meet with attorney Francis Carter
at 11:00 a.m. on Monday, December 22.(832) On that morning, according to
Ms. Lewinsky, she called Mr. Jordan and asked to meet before they went to
Mr. Carter's office.(833) She testified: "I was a little concerned. I
thought maybe [Mr. Jordan] didn't really understand . . . what it was that
was happening here with me being subpoenaed and what this really
meant."(834) She also wanted to find out whether he had in fact told the
President of her subpoena. Mr. Jordan said that he had.(835) Ms. Lewinsky
also told Mr. Jordan that she was worried that someone might have been
eavesdropping on her telephone conversations with the President.(836) When
Mr. Jordan asked why she thought that would be of concern, Ms. Lewinsky
said, "Well, we've had phone sex."(837)

Ms. Lewinsky testified that she brought some of her gifts from the
President, showed them to Mr. Jordan, and implied that these items were not
all of the gifts that the President had given her.(838) Mr. Jordan, in
contrast, testified that Ms. Lewinsky never showed him any gifts from the
President.(839)

C. December 22: First Meeting with Francis Carter

Mr. Jordan drove Ms. Lewinsky to Mr. Carter's office.(840) There, he
introduced Ms. Lewinsky to Mr. Carter, explaining that she needed not only
a lawyer but a "counselor."(841) Mr. Carter testified that, after the
initial referral, he expected to have no further contact with Mr. Jordan
about Ms. Lewinsky or her case.(842)

Mr. Carter and Ms. Lewinsky then met for approximately an hour.(843) She
explained that she did not want to be drawn into the Jones case and would
strongly prefer not to be deposed.(844) He said that he would try to
persuade Paula Jones's attorneys not to depose her.(845) Ms. Lewinsky
testified that she suggested filing an affidavit to avert a
deposition.(846)

According to Ms. Lewinsky, she asked Mr. Carter to get in touch with the
President's personal attorney, Robert Bennett, just "to let him know that I
had been subpoenaed in this case."(847) She wanted to make clear that she
was "align[ing] [her]self with the President's side."(848) Mr. Carter
testified that, while Ms. Lewinsky was in his office, he placed a call to
Mr. Bennett to arrange a meeting.(849)

On the morning of Tuesday, December 23, Mr. Carter met for an hour with two
of the President's personal attorneys, Mr. Bennett and Katherine
Sexton.(850) The President's attorneys told Mr. Carter that other witnesses
had filed motions to quash their subpoenas, and they offered legal research
to support such a motion.(851)

D. December 23: Clinton Denials to Paula Jones

Throughout the sexual harassment case, Ms. Jones's attorneys attempted to
obtain information about President Clinton's sexual relationships with any
woman other than his wife. On December 11, 1997, the judge overseeing the
Jones case, Susan Webber Wright, ruled that the President had to answer a
written interrogatory naming every state and federal employee since 1986
with whom he had sexual relations or with whom he had proposed to have
sexual relations. On December 23, 1997, the President answered the
interrogatory: "None."(852)

E. December 28: Final Meeting with the President

A day or two after Christmas, Ms. Lewinsky called Ms. Currie and told her
that the President had mentioned that he had presents for her.(853) Ms.
Currie called back and told her to come to the White House at 8:30 a.m. on
Sunday, December 28.(854)

That morning, Ms. Lewinsky met with the President in the Oval Office. WAVES
records reflect that the visit was requested by Ms. Currie and that Ms.
Lewinsky entered the White House at 8:16 a.m.(855)

After she arrived at the Oval Office, she, the President, and Ms. Currie
played with Buddy, the President's dog, and chatted. Then, the President
took her to the study and gave her several Christmas presents: a marble
bear's head, a Rockettes blanket, a Black Dog stuffed animal, a small box
of chocolates, a pair of joke sunglasses, and a pin with a New York skyline
on it.(856)

Ms. Lewinsky testified that, during this visit, she and the President had a
"passionate" and "physically intimate" kiss.(857)

Ms. Lewinsky and the President also talked about the Jones case.(858) In
Ms. Lewinsky's account, she asked the President "how he thought [she] got
put on the witness list."(859) He speculated that Linda Tripp or one of the
uniformed Secret Service officers had told the Jones attorneys about
her.(860) When Ms. Lewinsky mentioned her anxiety about the subpoena's
reference to a hat pin, he said "that sort of bothered [him], too."(861) He
asked whether she had told anyone about the hat pin, and she assured him
that she had not.(862)

At some point in the conversation, Ms. Lewinsky told the President,
"[M]aybe I should put the gifts away outside my house somewhere or give
them to someone, maybe Betty."(863) Ms. Lewinsky recalled that the
President responded either "I don't know" or "Let me think about
that."(864)

When Ms. Lewinsky was asked whether she thought it odd for the President to
give her gifts under the circumstances (with a subpoena requiring the
production of all his gifts), she testified that she did not think of it at
the time, but she did note some hesitancy on the President's part:

[H]e had hesitated very briefly right before I left that day in kind of
packaging . . . all my stuff back up . . . I don't think he said anything
that indicated this to me, but I thought to myself, "I wonder if he's
thinking he shouldn't give these to me to take out." But he did.(865)

When asked in the Jones deposition about his last meeting with Ms.
Lewinsky, the President remembered only that she stopped by "[p]robably
sometime before Christmas" and he "stuck [his] head out [of the office],
said hello to her."(866) The deposition occurred three weeks after this
December 28 meeting with Ms. Lewinsky.

In the grand jury, the President acknowledged "talking with Ms. Lewinsky
about her testimony, or about the prospect that she might have to give
testimony. And she, she talked to me about that."(867) He maintained,
however, that they did not discuss Ms. Lewinsky's subpoena: "[S]he was
upset. She -- well, she -- we -- she didn't -- we didn't talk about a
subpoena. But she was upset."(868) In the President's recollection, Ms.
Lewinsky said she knew nothing about sexual harassment; why did she have to
testify? According to the President, "I explained to her that it was a
political lawsuit. They wanted to get whatever they could under oath that
was damaging to me."(869)

Ms. Lewinsky's friend, Catherine Allday Davis, testified about a
conversation with Ms. Lewinsky on January 3, 1998. Ms. Lewinsky told Ms.
Davis that she had met with the President and discussed the Jones case a
few days earlier. Ms. Davis testified that Ms. Lewinsky and the President
had "noted [that] there was no evidence" of their relationship.(870)

E. December 28: Concealment of Gifts

In the afternoon of December 28, a few hours after Ms. Lewinsky's White
House visit, Ms. Currie drove to Ms. Lewinsky's Watergate apartment and
collected a box containing the President's gifts. Ms. Currie then took the
box home and hid it under her bed. Ms. Lewinsky, Ms. Currie, and the
President were all questioned as to why Ms. Currie retrieved the box of
gifts from Ms. Lewinsky.

According to Ms. Lewinsky, the transfer originated in a phone call from Ms.
Currie that afternoon. Ms. Lewinsky testified that Ms. Currie said, "I
understand you have something to give me," or, "The President said you have
something to give me."(871) Ms. Lewinsky understood that Ms. Currie was
alluding to the gifts.(872) Ms. Currie said that she would stop by Ms.
Lewinsky's apartment and pick up the items.(873) Ms. Lewinsky testified
that she put many, but not all, of her gifts from the President into a box.
Ms. Currie drove by her apartment and picked it up.(874)

Ms. Lewinsky was concerned because the gifts were under subpoena; she did
not throw them away, however, because "they meant a lot to [her]."(875) The
reason she gave the gifts to Ms. Currie, and not to one of her friends or
her mother, was "a little bit of an assurance to the President . . . that
everything was okay."(876) She felt that, because the gifts were with Ms.
Currie, they were within the President's control: "Not that [the gifts]
were going to be in his possession, but that he would understand whatever
it was I gave to Betty and that that might make him feel a little bit
better."(877)

Ms. Lewinsky's account of the events of December 28 in her sworn statement
of February 1, 1998, corroborates her later grand jury testimony:

"Ms. L . . . asked if she should put away (outside her home) the gifts he
had given her or, maybe, give them to someone else. Ms. Currie called Ms. L
later that afternoon as said that the Pres. had told her Ms. L. wanted her
to hold onto something for her. Ms. L boxed up most of the gifts she had
received and gave them to Ms. Currie. It is unknown if Ms. Currie knew the
contents of the box."(878)

Ms. Currie's testimony was somewhat at odds with Ms. Lewinsky's. Though her
overall recollection was hazy, Ms. Currie believed that Ms. Lewinsky had
called her and raised the idea of the gifts transfer.(879) Ms. Currie was
asked about the President's involvement in the transfer:

Q: And did the President know you were holding these things for Monica?

BC: I don't know. I don't know.

Q: Didn't he say to you that Monica had something for you to hold?

BC: I don't remember that. I don't.

Q: Did you ever talk to the President and tell him you had this box from
Monica?

BC: I don't remember that either.

Q: Do you think it happened, though?

BC: I don't know. I don't know.(880)

When asked whether a statement by Ms. Lewinsky indicating that Ms. Currie
had in fact spoken to the President about the gift transfer would be false,
Ms. Currie replied: "Then she may remember better than I. I don't
remember."(881)

According to Ms. Currie, Ms. Lewinsky said that she was uncomfortable
retaining the gifts herself because "people were asking questions" about
them.(882) Ms. Currie said she drove to Ms. Lewinsky's residence after
work, collected the box, brought it home, and put it under her bed.(883)
Written on the top of the box were the words "Please do not throw
away!!!"(884) Ms. Currie testified that she knew that the box contained
gifts from the President.(885)

For his part, the President testified that he never asked Ms. Currie to
collect a box of gifts from Ms. Lewinsky.(886) He said that he had no
knowledge that Ms. Currie had held those items "until that was made
public."(887)

The President testified that he has no distinct recollection of discussing
the gifts with Ms. Lewinsky on December 28: "[M]y memory is that on some
day in December, and I'm sorry I don't remember when it was, she said,
well, what if they ask me about the gifts you have given me. And I said,
well, if you get a request to produce those, you have to give them whatever
you have."(888)

D. December 31: Breakfast with Vernon Jordan

Ms. Lewinsky testified that in late December 1997 she realized that she
needed to "come up with some sort of strategy as to [what to do] if Linda
Tripp" divulged what she knew.(889) On December 30, Ms. Lewinsky telephoned
Mr. Jordan's office and conveyed either directly to him or through one of
his secretaries that she was concernedabout the Jones case.(890)

The following day, Ms. Lewinsky and Mr. Jordan had breakfast together at
the Park Hyatt Hotel.(891) According to Ms. Lewinsky, she told Mr. Jordan
that a friend of hers, Linda Tripp, was involved in the Jones case. She
told Mr. Jordan: "I used to trust [Ms. Tripp], but I didn't trust her any
more."(892) Ms. Lewinsky said that Ms. Tripp might have seen some notes in
her apartment. Mr. Jordan asked: "Notes from the President to you?" Ms.
Lewinsky responded: "No, notes from me to the President." According to Ms.
Lewinsky, Mr. Jordan said: "Go home and make sure they're not there." Ms.
Lewinsky testified that she understood that Mr. Jordan was advising her to
"throw . . . away" any copies or drafts of notes that she had sent to the
President.(893)

After breakfast, Mr. Jordan gave Ms. Lewinsky a ride back to his
office.(894) When Ms. Lewinsky returned home to her apartment that day, she
discarded approximately 50 draft notes to the President.(895)

E. January 4: The Final Gift

On Sunday, January 4, 1998, Ms. Lewinsky called Ms. Currie at home and told
her that she wanted to drop off a gift for the President.(896) Ms. Currie
invited Ms. Lewinsky to her home, and Ms. Lewinsky gave her the
package.(897) The package contained a book entitled The Presidents of the
United States and a love note inspired by the movie Titanic.(898)

                     XIII. January 5-January 16, 1998:

                               The Affidavit

On January 5, 1998, Ms. Lewinsky's attorney, Francis Carter, drafted an
affidavit for Ms. Lewinsky in an attempt to avert her deposition. She spoke
with the President that evening. On January 6, Ms. Lewinsky talked to Mr.
Jordan about the affidavit, which denied any sexual relations between her
and the President. On January 7, Ms. Lewinsky signed the affidavit. On
January 8, she interviewed for a job in New York City. After the interview
went poorly, Mr. Jordan placed a phone call to the company's chairman on
her behalf, and Ms. Lewinsky was given a second interview. The following
week, after Ms. Lewinsky told Ms. Currie that she would need a reference
from the White House, the President asked Chief of Staff Erskine Bowles to
arrange one.

A. January 5: Francis Carter Meeting

At 3:00 p.m. on Monday, January 5, 1998, Ms. Lewinsky met with Mr. Carter
at his office for approximately one hour.(899)

Ms. Lewinsky testified that Mr. Carter described what a deposition was like
and "threw out a bunch of different questions."(900) The questions that
most concerned her related to the circumstances of her departure from the
White House.(901)

Mr. Carter told Ms. Lewinsky that he would draft an affidavit for her to
sign in hopes of averting her deposition. They arranged for Ms. Lewinsky to
pick up a draft of the affidavit the next day.(902)

B. January 5: Call from the President

After her meeting with Mr. Carter, Ms. Lewinsky sent word via Ms. Currie
that she needed to speak to the President about an important matter.(903)
Specifically, Ms. Lewinsky told Ms. Currie she was anxious about something
she needed to sign.(904)

A few hours later, according to Ms. Lewinsky, the President returned her
call.(905) She mentioned an affidavit she would be signing and asked if he
wanted to see it. According to Ms. Lewinsky, the President responded that
he did not, as he had already seen about fifteen others.(906) Ms. Lewinsky
testified that she told the President that she was troubled by potential
questions about her transfer from the White House to the Pentagon. She was
concerned that "people at the White House who didn't like [her]" might
contradict her and "get [her] in trouble."(907) The President, according to
Ms. Lewinsky, advised her: "[Y]ou could always say that the people in
Legislative Affairs got it [the Pentagon job] for you or helped you get
it."(908)

The President acknowledged in the grand jury that he was aware that Ms.
Lewinsky had signed an affidavit in early January, but had no specific
recollection of a conversation with her in that time period.(909) He
testified that he did not recall telling Ms. Lewinsky that she could say,
if asked, that persons in the Legislative Affairs Office of the White House
had helped her obtain the job at the Pentagon.(910)

According to Ms. Lewinsky, she and the President also briefly discussed an
antique book that she had dropped off with Ms. Currie the day before. With
the book, she enclosed a letter telling the President that she wanted to
have sexual intercourse with him at least once.(911) In their phone
conversation, Ms. Lewinsky told the President, "I shouldn't have written
some of those things in the note."(912) She testified that the President
agreed.(913)

Although the President had testified in the Jones case that any personal
messages from Ms. Lewinsky to him had been "unremarkable," he told the
grand jury that he had received "quite affectionate" messages from Ms.
Lewinsky, even after their intimate relationship ended.(914) The President
testified that he cautioned Ms. Lewinsky about such messages: "I remember
telling her she should be careful what she wrote, because a lot of it was
clearly inappropriate and would be embarrassing if somebody else read it. I
don't remember when I said that. I don't remember whether it was in '96 or
when it was."(915) The President did remember the antique book Ms. Lewinsky
had given him, but said he did not recall a romantic note enclosed with
it.(916)

C. January 6: The Draft Affidavit

According to Ms. Lewinsky, in the afternoon of January 6, 1998, she visited
Mr. Carter's office and picked up a draft of the affidavit.(917) Later that
day, according to Ms. Lewinsky, she and Mr. Jordan discussed the draft by
telephone.(918) Ms. Lewinsky testified that having Mr. Jordan review the
affidavit was like getting it "blessed" by the President.(919) Ms. Lewinsky
testified that she told Mr. Jordan that she was worried about a sentence
that implied that she had been alone with the President and thus might
incline Paula Jones's attorneys to question her.(920) She eventually
deleted it.(921)

In addition, Paragraph 8 of the draft affidavit provided in part:

I have never had a sexual relationship with the President. . . . The
occasions that I saw the President, with crowds of other people, after I
left my employment at the White House in April, 1996 related to official
receptions, formal functions or events related to the U.S. Department of
Defense, where I was working at the time.(922)

Deeming the reference to "crowds" "too far out of the realm of
possibility,"(923) Ms. Lewinsky deleted the underscored phrase and wrote
the following sentence at the end of this paragraph: "There were other
people present on all of these occasions."(924) She discussed this proposed
sentence, as well as her general anxiety about Paragraph 8, with Mr.
Jordan.(925)

When questioned in the grand jury, Mr. Jordan acknowledged that Ms.
Lewinsky called him with concerns about the affidavit,(926) but maintained
that he told her to speak with her attorney.(927)

Phone records for January 6 show that Mr. Jordan had a number of contacts
with Ms. Lewinsky, the President, and Mr. Carter. Less than thirty minutes
after Mr. Jordan spoke by phone to Ms. Lewinsky, he talked with the
President for thirteen minutes. Immediately after this call, at 4:33 p.m.,
Mr. Jordan called Mr. Carter. Less than an hour later, Mr. Jordan placed a
four-minute call to the main White House number. Over the course of the
day, Mr. Jordan called a White House number twice, Ms. Lewinsky three
times, and Mr. Carter four times.(928)

Mr. Carter testified that his phone conversations with Mr. Jordan this day
and the next "likely" related to Ms. Lewinsky and his litigation strategy
for her.(929) In fact, Mr. Carter billed Ms. Lewinsky for time for
"[t]elephone conference with Atty Jordan."(930)

When questioned in the grand jury, Mr. Jordan testified that he could not
specifically remember the January 6 calls. He said he "assumed" that he
talked with Ms. Lewinsky about her job search, and he believed that he
called Mr. Carter to see "how he was dealing with this highly emotional
lady."(931) He said that he might have talked with the President about Ms.
Lewinsky, but he maintained that "there [was] no connection" between his
13-minute conversation with the President and the call he placed
immediately thereafter to Mr. Carter.(932)

D. January 7: Ms. Lewinsky Signs Affidavit

Ms. Lewinsky set an appointment with Mr. Carter to finalize the affidavit
for 10 a.m. on January 7, 1998.(933) She signed the affidavit; however, she
acknowledged in the grand jury that statements in it were false.(934) Mr.
Carter indicated to her that he "intend[ed] to hold onto this until after I
talk to plaintiff's lawyers." He told her to "keep in touch," and said:
"Good luck on your job search."(935)

According to Mr. Jordan, Ms. Lewinsky came to his office on January 7 and
showed him the signed affidavit.(936) Over the course of the day, Mr.
Jordan placed three calls of significant duration to the White House.(937)
He testified: "I knew the President was concerned about the affidavit and
whether it was signed or not."(938) When asked whether the President
understood that the affidavit denied a sexual relationship, Mr. Jordan
testified: "I think that's a reasonable assumption."(939) According to Mr.
Jordan, when he informed the President that Ms. Lewinsky had signed the
affidavit, the President said, "Fine, good."(940) Mr. Jordan said he was
continuing to work on her job, and the President responded, "Good."(941)

Ten days after this conversation, in the Jones deposition, President
Clinton was asked whether he knew that Ms. Lewinsky had met with Vernon
Jordan and talked about the Jones case. He answered:

I knew he met with her. I think Betty suggested that he meet with her.
Anyway, he met with her. I, I thought that he talked to her about something
else. I didn't know that -- I thought he had given her some advice about
her move to New York. Seems like that's what Betty said.(942)

In his grand jury appearance, however, President Clinton testified that Mr.
Jordan informed "us" on January 7 that Ms. Lewinsky had signed an affidavit
to be used in connection with the Jones case.(943) The President defended
his deposition testimony by stating:

[M]y impression was that, at the time, I was focused on the meetings. I
believe the meetings he had were meetings about her moving to New York and
getting a job.

I knew at some point that she had told him that she needed some help,
because she had gotten a subpoena. I'm not sure I know whether she did that
in a meeting or a phone call. And I was not, I was not focused on that. I
know that, I know Vernon helped her get a lawyer, Mr. Carter. And I, I
believe that he did it after she had called him, but I'm not sure. But I
knew that the main source of their meetings was about her move to New York
and her getting a job.(944)

E. January 8: The Perelman Call

The day after she signed the affidavit, January 8, 1998, Ms. Lewinsky
interviewed in New York with Jaymie Durnan, Senior Vice President and
Special Assistant to the Chairman at MacAndrews & Forbes Holdings, Inc.
(MFH).(945) Mr. Durnan testified that, although impressive, Ms. Lewinsky
was not suited for any MFH opening.(946) He told her that he would pass on
her resume to Revlon, an MFH company.(947) Ms. Lewinsky called Mr. Jordan
and reported that she felt that the interview had gone "very poorly."(948)
Mr. Jordan indicated in response that "he'd call the chairman."(949)

At 4:54 p.m., Mr. Jordan called Ronald Perelman, chairman and chief
executive officer of MFH.(950) Mr. Jordan told the grand jury with respect
to Mr. Perelman, one "[c]an't get any higher -- or any richer."(951) Asked
why he chose to call Mr. Perelman, Mr. Jordan responded: "I have spent a
good part of my life learning institutions and people, and, in that
process, I have learned how to make things happen. And the call to Ronald
Perelman was a call to make things happen, if they could happen."(952)

According to Mr. Perelman, Mr. Jordan spoke of "this bright young girl, who
I think is terrific," and said that he wanted "to make sure somebody takes
a look at her."(953) Mr. Perelman testified that, in the roughly twelve
years that Mr. Jordan had been on Revlon's Board of Directors, he did not
recall Mr. Jordan ever calling to recommend someone.(954)

After he spoke with Mr. Perelman, Mr. Jordan telephoned Ms. Lewinsky and
told her, "I'm doing the best I can to help you out."(955) Ms. Lewinsky
soon received a call from Revlon, inviting her to another interview.(956)

Over the course of January 8, Mr. Jordan placed three calls to the White
House -- twice to a number at the White House Counsel's Office, once to the
main White House number.(957) As to the Counsel's Office calls, Mr. Jordan
speculated that he was trying to reach Cheryl Mills, Deputy White House
Counsel, to express his "frustration" about Ms. Lewinsky.(958) According to
Mr. Jordan, Ms. Mills knew who Ms. Lewinsky was: "[T]hat was no secret, I
don't think, around the White House, that I was helping Monica
Lewinsky."(959)

F. January 9: "Mission Accomplished"

On the morning of Friday, January 9, 1998, Ms. Lewinsky interviewed with
Allyn Seidman, Senior Vice President of MFH, and two individuals at
Revlon.(960) Ms. Lewinsky testified that the interviews went well and that
Ms. Seidman called her back that day and "informally offered [her] a
position, and [she] informally accepted."(961)

Ms. Lewinsky then called Mr. Jordan and relayed the good news.(962) When
shown records of a seven-minute call at 4:14 p.m., Mr. Jordan testified: "I
have to assume that if she got the job and we have a seven-minute
conversation and the day before I had talked to the chairman [Ronald
Perelman], I have to assume the Jordan magic worked."(963)

According to Mr. Jordan, he believed that he notified Ms. Currie and the
President as soon as he learned that Ms. Lewinsky had obtained an offer: "I
am certain that at some point in time I told Betty Currie, 'Mission
accomplished.'"(964) Mr. Jordan testified that he also told the President
directly that, "'Monica Lewinsky's going to work for Revlon,' and his
response was, 'Thank you very much.'"(965)

G. January 12: Pre-Trial Hearing in Jones Case

On January 12, 1998, Judge Wright held a hearing in the Jones case to
discuss pre-trial issues, including the President's upcoming
deposition.(966) At that hearing, Judge Wright required Ms. Jones's counsel
to list all the witnesses that they planned to call at trial. Ms. Jones's
witness list named many women, among them Ms. Lewinsky, to support her
theory that the President had a pattern of rewarding women based on their
willingness to engage in sexual relations with him. At the hearing, Judge
Wright indicated that she would permit Ms. Jones to call as witnesses some
of the women she listed in support of her case.

H. January 13: References from the White House

On Tuesday, January 13, 1998, Jennifer Sheldon, Manager of Corporate
Staffing of Revlon, called Ms. Lewinsky and formally extended her a
position as a public relations administrator. Asked whether this was a
relatively quick hiring process, Ms. Sheldon responded, "In totality of how
long open positions normally stay open, yes. This was pretty fast."(967)
Ms. Sheldon told Ms. Lewinsky that she needed to send her some
references.(968)

According to Ms. Lewinsky, she then called Ms. Currie because she was
"concerned that if I put [Mr. Hilley] down as a reference, he might not say
flattering things about me."(969) At 11:11 a.m. on January 13, Ms. Currie
paged Ms. Lewinsky and left the following message: "Will know something
this afternoon. Kay."(970)

That day, January 13, the President talked with Chief of Staff Erskine
Bowles about a reference for Ms. Lewinsky.(971) The President told Mr.
Bowles that Ms. Lewinsky "had found a job in the . . . private sector, and
she had listed John Hilley as a reference, and could we see if he could
recommend her, if asked." Mr. Bowles assured the President that Mr. Hilley
would give Ms. Lewinsky a recommendation commensurate with her job
performance.(972)

Thereafter, Mr. Bowles took the President's request to Mr. Podesta, the
Deputy Chief of Staff, who in turn spoke with Mr. Hilley.(973) Mr. Hilley
responded that, because he did not know Ms. Lewinsky personally, he would
have his office write a recommendation.(974) It would be a generic letter,
simply confirming the dates of employment, because of the less than
favorable circumstances surrounding Ms. Lewinsky's departure from the White
House.(975)

Ms. Lewinsky testified that Ms. Currie called later that day and told her
that "Mr. Podesta took care of it and everything would be fine with Mr.
Hilley."(976) At 11:17 a.m. the next day, Wednesday, January 14, Ms.
Lewinsky faxed her acceptance to Revlon and listed John Hilley and her
Defense Department supervisor as references.(977)

The President was asked in the grand jury whether he ever spoke to Mr.
Bowles about obtaining a reference from Mr. Hilley for Ms. Lewinsky. He
testified that he did, at Ms. Lewinsky's request, although he thought he
had done so earlier than January 13 or 14.(978)

I. January 13: Final Jordan Meeting

According to Ms. Lewinsky, on Tuesday, January 13, she stopped by Mr.
Jordan's office to drop off some thank-you gifts for helping her find a
job. Ms. Lewinsky offered to show him a copy of her signed affidavit in the
Jones case, but he indicated that he did not need to see it.(979)

J. January 13-14: Lewinsky-Tripp Conversation and Talking Points

In a face-to-face conversation on January 13, Ms. Lewinsky told Linda
Tripp: "This is what my lawyer taught me. You really don't -- you don't
very often say 'no' unless you really need to. The best is, 'Well, not that
I recall, not that I really remember. Might have, but I don't really
remember.'"(980) Ms. Lewinsky said that, if asked in a deposition, "Were
you ever alone with the President?" she could say, "Um, it's possible I may
have taken a letter on the weekend, but, you know -- I might have, but I
don't really. . . ."(981)

Ms. Lewinsky and Ms. Tripp then discussed the situation:

Ms. Lewinsky: I don't think the way that man thinks, I don't think he
thinks of lying under oath. . . .

Ms. Tripp: Yes, he is because he's the one who said, "Deny, deny, deny." Of
course he knows.

Ms. Lewinsky: Right. But it's -- hard to explain this. It's like -- (sigh)

Ms. Tripp: You know what I mean. I mean, I don't know -- do I think he is
consciously --

Ms. Lewinsky: If-- if -- if I said, if somebody said to him, "Is Monica
lying under oath," he would say yes. But when he on his own thinks about
it, he doesn't think about it in those terms. Okay?

Ms. Tripp: Probably.

Ms. Lewinsky: Okay? He thinks of it as, "We're safe. We're being smart."
Okay? "We're being smart, we're being safe, it's good for everybody."(982)

On January 14, Ms. Lewinsky gave Ms. Tripp a three-page document regarding
"points to make in [Ms. Tripp's] affidavit."(983) Ms. Lewinsky testified
that she wrote the document herself, although some of the ideas may have
been inspired by conversations with Ms. Tripp.(984)

K. January 15: The Isikoff Call

In the grand jury, Betty Currie testified that on Thursday, January 15,
1998, she received a telephone call from Michael Isikoff of Newsweek, who
inquired about courier receipts reflecting items sent by Ms. Lewinsky to
the White House.(985)

Ms. Currie called Mr. Jordan and asked for guidance in responding to Mr.
Isikoff's inquiry because, in her words, she had a "comfort level with
Vernon."(986) After Ms. Currie arranged to meet with Mr. Jordan at his
office,(987) Ms. Lewinsky drove her there.(988)

Mr. Jordan confirmed in the grand jury that Ms. Currie expressed concern
about a call from Mr. Isikoff.(989) He invited her to his office but
advised her to "talk to Mike McCurry and Bruce Lindsey . . . because I
cannot give you that advice."(990)

In a recorded conversation that day, January 15, Ms. Lewinsky encouraged
Ms. Tripp not to disclose her (Lewinsky's) relationship with the President.
Ms. Lewinsky tried to persuade Ms. Tripp to lie by telling her that others
planned to lie: "I'm not concerned all that much anymore because I'm not
going to get in trouble because you know what? The story I've signed . . .
under oath is what someone else is saying under oath." When Ms. Tripp
asked, "Who?" Ms. Lewinsky responded: "He will," referring to the
President.(991) Ms. Lewinsky stated that she did not think the President
would "slip up" at his deposition because she was not a "big issue" like
Gennifer Flowers and Paula Jones. In contrast, she regarded herself as
nothing more than "rumor and innuendo."(992)

One of Ms. Lewinsky's friends, Natalie Ungvari, testified that, when Ms.
Lewinsky was implicated in the Jones case, "it seemed to me that Monica was
just confident everybody would say the right thing, that everything would
be orchestrated to come out a secret."(993)

L. January 15-16: Developments in the Jones Law Suit

On January 15, 1998, President Clinton's counsel served Ms. Jones's
attorneys with the President's responses to Ms. Jones's document
requests.(994) One of the requests specifically sought all documents
reflecting communications between the President and Monica Lewinsky.(995)
President Clinton objected to the scope of this request, but,
notwithstanding his objection, he stated that he did not have any
responsive documents.

Also on January 15, Mr. Carter drafted a motion to quash the subpoena
issued by Paula Jones's attorneys to Ms. Lewinsky. Attached to the motion
was Ms. Lewinsky's signed affidavit.(996) At the request of Katherine
Sexton, one of the President's personal attorneys, Mr. Carter faxed a copy
of the affidavit to her law offices. Mr. Carter testified that he asked Ms.
Sexton why she needed the affidavit that day:

I said, "Well, Katie, you're going to get it tomorrow because I'm filing
it, and it's going to be attached as an exhibit to the motion." She said,
"Well, but you've already provided it to the other side, so can I get a
copy" -- words to that effect. I said, "I have no problem." And so I faxed
it to her.(997)

On January 16, 1998, Mr. Carter arranged for the overnight delivery of the
motion to quash and the accompanying affidavit to Judge Susan Webber
Wright's law clerk and Paula Jones's attorneys.(998)

                      XIV. January 17, 1998-Present:

                       The Deposition and Afterward

The President was asked a number of questions about Ms. Lewinsky during his
January 17, 1998, deposition in the Jones case. In sworn testimony, the
President denied having a sexual affair or sexual relations with her. That
evening, the President called Ms. Currie and asked her to meet him the
following day to discuss Ms. Lewinsky. After allegations that the President
had an affair with a White House intern became public, the President
emphatically denied the reports to aides and to the American public.

A. January 17: The Deposition

On Saturday, January 17, 1998, the President testified under oath at a
deposition in the Jones case.(999) Judge Susan Webber Wright traveled from
Little Rock, Arkansas, to preside at the deposition in Washington,
D.C.(1000)

Prior to any questions, Judge Wright reminded the parties about her
standing Protective Order. She specifically stated: "[I]f anyone reveals
anything whatsoever about this deposition,

. . . it will be in violation of the Protective Order. This includes the
questions that were asked, . . . You may acknowledge that [the deposition]
took place, but that is it."(1001) Judge Wright accepted the following
definition of the term "sexual relations:"

For the purposes of this deposition, a person engages in "sexual relations"
when the person knowingly engages in or causes . . . contact with the
genitalia, anus, groin, breast, inner thigh, or buttocks of any person with
an intent to arouse or gratify the sexual desire of any person . . . .
"Contact" means intentional touching, either directly or through
clothing.(1002)

After the President had answered a few questions about Ms. Lewinsky, his
attorney, Robert Bennett, urged Judge Wright to limit further inquiries.
Mr. Bennett stated that Ms. Lewinsky had executed an affidavit "saying that
there is absolutely no sex of any kind of any manner, shape or form, with
President Clinton."(1003) When Judge Wright cautioned Mr. Bennett not to
make remarks that "could be arguably coaching the witness," Mr. Bennett
represented to Judge Wright: "In preparation of the witness for this
deposition, the witness is fully aware of Ms. Lewinsky's affidavit, so I
have not told him a single thing he doesn't know . . . ."(1004) President
Clinton, who was presentwhen Mr. Bennett made his objection, did not
contradict his attorney's comment. Rejecting Mr. Bennett's argument, Judge
Wright permitted the questioning about Ms. Lewinsky to continue.(1005)

Over the course of extensive questioning, the President testified that he
had seen Ms. Lewinsky "on two or three occasions" during the government
shutdown in the fall of 1995, including one occasion when she brought pizza
to him, and one or two other occasions when she delivered documents to
him.(1006) He could not recall whether he had been alone with Ms. Lewinsky
on such occasions, although he acknowledged that it was possible.(1007) The
President further testified that he could not remember the subject of any
conversations with Ms. Lewinsky.(1008)

President Clinton recalled that he received only a couple of unremarkable
personal messages from Ms. Lewinsky, and he could not recall ever having
received a cassette tape from her.(1009) He received presents from her
"[o]nce or twice" -- a book or two and a tie.(1010) The President
originally testified that he could not recall any gifts he might have given
her; later in the deposition, however, he remembered that some merchandise
he had purchased from a Martha's Vineyard restaurant might have reached her
through Ms. Currie.(1011) The President stated that he might have given Ms.
Lewinsky a hat pin, though he could not recall for certain.(1012)

The President testified that his last conversation with Ms. Lewinsky had
been before Christmas, when she had visited the White House to see Ms.
Currie. The President stated: "I stuck my head out, said hello to
her."(1013) He said it was also possible that, during that encounter, he
had joked with Ms. Lewinsky that the plaintiff's attorneys were going to
subpoena "every woman I ever talked to" and Ms. Lewinsky "would
qualify."(1014)

The President testified that he was unaware that Mr. Jordan had talked with
Ms. Lewinsky about the Jones case, in which she had also been subpoenaed to
testify at a deposition.(1015)

The President emphatically denied having had sexual relations with Ms.
Lewinsky.(1016)

At the conclusion of the deposition, Judge Wright said: "Before [the
President] leaves, I want to remind him, as the witness in this matter, and
everyone else in the room, that this case is subject to a Protective Order
regarding all discovery, . . . and . . . all parties present, including . .
. the witness are not to say anything whatsoever about the questions they
were asked, the substance of the deposition, . . . any details, . . . and
this is extremely important to this Court."(1017)

Sometime after the President's deposition, Mr. Podesta saw Bruce Lindsey,
Deputy White House Counsel, at the White House and inquired how the
deposition went. According to Mr. Podesta, Mr. Lindsey said that the
President had been asked about Monica Lewinsky.(1018) Mr. Lindsey testified
that, during a break in the President's deposition, the President had told
him that Ms. Lewinsky's name had come up.(1019)

That same evening, Mr. Lindsey met with the President in the Oval Office,
where they discussed the deposition.(1020) Mr. Lindsey, relying on the
attorney-client, presidential communication, deliberative process, and
work-product privileges, declined to say what specifically was discussed at
this meeting.

B. The President Meets with Ms. Currie

Soon after the deposition, the President called Ms. Currie and asked her to
come to the White House the next day.(1021) Ms. Currie acknowledged that,
"It's rare for [the President] to ask me to come in on Sunday."(1022) The
President wanted to discuss Ms. Lewinsky's White House visits.(1023)

At approximately 5:00 p.m. on Sunday, January 18, 1998, Ms. Currie met with
the President.(1024) The meeting took place at her desk outside the Oval
Office. According to Ms. Currie, the President appeared "concerned."(1025)
He told Ms. Currie that, during his deposition the previous day, he had
been asked questions about Monica Lewinsky.(1026) Ms. Currie testified: "I
think he said, 'There are several things you may want to know.'"(1027) He
proceeded to make a series of statements,(1028) one right after the
other:(1029)

   * "You were always there when she was there, right?"
   * "We were never really alone."
   * "Monica [Lewinsky] came on to me, and I never touched her, right?"
   * "You can see and hear everything, right?"(1030)

Ms. Currie testified that, based on his demeanor and the way he made the
statements, the President wanted her to agree with them.(1031)

Ms. Currie testified that she did, in fact, agree with the President when
he said, "You were always there when she was there, right?"(1032) Before
the grand jury, however, Ms. Currie acknowledged the possibility that Ms.
Lewinsky could have visited the President when she was not at the White
House.(1033)

With respect to whether the President was "never really alone" with Ms.
Lewinsky, Ms. Currie testified that there were several occasions when the
President and Ms. Lewinsky were either in the Oval Office or in the study
without anyone else present.(1034)

Ms. Currie explained that she did not consider the President and Ms.
Lewinsky to be "alone" on such occasions because she was at her desk
outside the Oval Office; accordingly, they were all together in the same
"general area."(1035) Ms. Currie testified that "the President, for all
intents and purposes, is never alone. There's always somebody around
him."(1036)

As to whether Ms. Lewinsky "came on" to him, Ms. Currie testified that she
"would have no reason to know" whether Ms. Lewinsky ever "came on" to the
President because Ms. Currie was not present all the time.(1037) Finally,
as to whether she "could see and hear everything," Ms. Currie testified
that she should not have agreed with the President.(1038) She testified
that when the President and Ms. Lewinsky were alone together in the study,
while Ms. Currie was at her desk, she could "hear nothing."(1039)

The President also made the following statement during their January 18,
1998 meeting, according to Ms. Currie: "[Monica Lewinsky] wanted to have
sex with me, but I told her I couldn't do that."(1040)

When the President was questioned about this meeting with Ms. Currie in the
grand jury, he testified that he recalled the conversation, but he denied
that he was "trying to get Betty Currie to say something that was
untruthful."(1041) Rather, the President testified that he asked a "series
of questions" in an effort to quickly "refresh [his] memory."(1042) The
President explained: "I wanted to establish . . . that Betty was there at
all other times in the complex, and I wanted to know what Betty's memory
was about what she heard, what she could hear . . . . [a]nd I was trying to
figure [it] out . . . in a hurry because I knew something was up."(1043)

In his grand jury testimony, the President acknowledged that, "in
fairness," Ms. Currie "may have felt some ambivalence about how to react"
to his statements.(1044) The President maintained that he was trying to
establish that Ms. Currie was "always there," and could see and hear
everything.(1045) At the same time, he acknowledged that he had always
tried to prevent Ms. Currie from learning about his relationship with Ms.
Lewinsky.(1046) "[I] did what people do when they do the wrong thing. I
tried to do it where nobody else was looking at it."(1047)

The President was also asked about his statement that Ms. Currie was always
in the Oval Office when Ms. Lewinsky visited. He explained that he may have
intended the term "Oval Office" to include the entire Oval Office
complex.(1048) The President further explained, "I was talking about 1997.
I was never, ever trying to get Betty Currie to claim that on the occasions
when Monica Lewinsky was there when she wasn't anywhere around, that she
was."(1049) When asked whether he restricted his remarks to the year 1997,
the President responded, "Well, I don't recall whether I did or not, but .
. . I assumed [Ms. Currie] knew what I was talking about."(1050)

When questioned about his statement to Ms. Currie, "you

could see and hear everything," the President responded:

My memory of that was that, that she had the ability to hear what was going
on if she came in the Oval Office from her office. And a lot of times, you
know, when I was in the Oval Office, she just had the door open to her
office. Then there was -- the door was never completely closed to the hall.
So, I think there was -- I'm not entirely sure what I meant by that, but I
could have meant that she generally would be able to hear conversations,
even if she couldn't see them. And I think that's what I meant.(1051)

Finally, when asked about his statement to Ms. Currie that "Monica came on
to me and I never touched her," the President refused to answer.(1052)

C. January 18-19: Attempts to Reach Ms. Lewinsky

In the wake of her Sunday afternoon session, Ms. Currie paged Ms. Lewinsky
four times.(1053) She testified that the President "may have asked me to
call [Ms. Lewinsky] to see what she knew or where she was or what was
happening."(1054) Later that evening, at 11:02 p.m., the President called
Ms. Currie to ask whether she had spoken to Ms. Lewinsky.(1055)

Over a two-hour span the next morning, Monday, January 19, 1998, Ms. Currie
made eight unsuccessful attempts to contact Ms. Lewinsky, by either pager
or telephone.(1056) After speaking with the President to let him know that
she was unable to reach Ms. Lewinsky, Ms. Currie again paged her.(1057) The
purpose of these calls, according to Ms. Currie, was to tell Ms. Lewinsky
that her name had been mentioned in the President's deposition.(1058)

Mr. Jordan also tried unsuccessfully to reach Ms. Lewinsky that
morning.(1059) That afternoon, Mr. Jordan met with the President in the
Oval Office.(1060) Later, Ms. Lewinsky's attorney, Frank Carter, called Mr.
Jordan and told him that Ms. Lewinsky had obtained new counsel, William
Ginsburg and Nathaniel Speights.(1061) Mr. Jordan passed this information
on to the President that evening in a seven-minute phone
conversation.(1062)

D. January 20-22: Lewinsky Story Breaks

After the publication of an article alleging a sexual relationship with Ms.
Lewinsky, President Clinton conferred with his attorneys and issued a
number of denials to his aides and to the American public.

1. "Clinton Accused"

On Wednesday, January 21, 1998, the Washington Post published a story
entitled "Clinton Accused of Urging Aide to Lie; Starr Probes Whether
President Told Woman to Deny Alleged Affair to Jones's Lawyers."(1063) The
White House learned the essentials of the Post story on the night of
January 20, 1998.(1064)

President Clinton placed a number of phone calls that night and the
following morning.(1065) From 12:08 a.m. to 12:39 a.m., he spoke with his
personal attorney, Robert Bennett. Mr. Bennett would be quoted in the Post
article as saying, "The President adamantly denies he ever had a
relationship with Ms. Lewinsky and she has confirmed the truth of
that."(1066) He added: "This story seems ridiculous and I frankly smell a
rat."(1067)

Immediately after his call to Mr. Bennett, President Clinton called Deputy
White House Counsel Bruce Lindsey; they spoke for about half an hour, until
1:10 a.m.(1068)

At 1:16 a.m., the President called Ms. Currie at home and spoke to her for
20 minutes. Ms. Currie testified that the President was concerned that her
name was mentioned in the Post article.(1069) Soon after this call, the
President called Mr. Lindsey.(1070)

A few hours later, at approximately 6:30 a.m., the President called Mr.
Jordan in New York City to tell him, according to Mr. Jordan, that the Post
story was untrue.(1071) From 7:14 a.m. to 7:22 a.m., the President spoke
again with Mr. Lindsey.(1072)

Responding to the Post story that day, the White House issued a statement,
personally approved by the President, declaring that he was "outraged by
these allegations" and that "he has never had an improper relationship with
this woman." White House spokesperson Mike McCurry said that the statement
"was prepared by the Counsel's office, and I reviewed it with the President
to make sure that it reflected what he wanted me to say . . . He looked at
it, and he said fine. . . . It was prepared in consultation between the
lawyers and the President. The Counsel's Office gave it to me. I wanted to,
of course, verify that that's exactly what the President wanted me to
say."(1073)

2. Denials to Aides

According to Mr. Lindsey, the remainder of the morning was spent in a
series of meetings about the Lewinsky matter, including preparing the
President for anticipated Lewinsky-related questions in three previously
scheduled media interviews.(1074) At these meetings, President Clinton
denied the allegations to several of his top aides.

The President met with Chief of Staff Erskine Bowles, along with his two
deputies, John Podesta and Sylvia Matthews. According to Mr. Bowles, the
President told them, "I want you to know I did not have sexual
relationships with this woman, Monica Lewinsky. I did not ask anybody to
lie. And when the facts come out, you'll understand."(1075) The President
made a similar denial that morning to Harold Ickes, his former Deputy Chief
of Staff.(1076) The President also discussed the matter with Ms. Currie for
a second time.(1077) According to Ms. Currie, the President called her into
the Oval Office and gave a "sort of a recapitulation of what we had talked
about on Sunday -- you know, 'I was never alone with her' -- that sort of
thing."(1078) The President spoke with the same tone and demeanor that he
used during his previous session with her.(1079) Ms. Currie testified that
the President may have mentioned that she might be asked about
Ms. Lewinsky.(1080)

Later that day, the President summoned Sidney Blumenthal to the Oval
Office. They spoke for about 30 minutes.(1081) The President said to Mr.
Blumenthal, "I haven't done anything wrong."(1082) Mr. Blumenthal testified
that the President told him, "Monica Lewinsky came on to me and made a
sexual demand on me." The President said that he "rebuffed her."(1083) The
President also told Mr. Blumenthal that Ms. Lewinsky had "threatened him.
She said that she would tell people they'd had an affair, that she was
known as the stalker among her peers, and that she hated it and if she had
an affair or said she had an affair then she wouldn't be the stalker any
more."(1084) Mr. Blumenthal then asked the President whether he and Ms.
Lewinsky were alone when she threatened him. The President responded,
"Well, I was within eyesight or earshot of someone."(1085)

According to Mr. Blumenthal, the President complained: "I feel like a
character in a novel. I feel like somebody who is surrounded by an
oppressive force that is creating a lie about me and I can't get the truth
out. I feel like the character in the novel Darkness at Noon."(1086)

Soon thereafter, in the course of a meeting about the progress of the
President's State of the Union address, the President made a second denial
of the allegations to Mr. Podesta.(1087) Mr. Podesta testified:

[H]e said to me that he had never had sex with her, and that -- and that he
never asked -- you know, he repeated the denial, but he was extremely
explicit in saying he never had sex with her . . . . Well, I think he said
-- he said that -- there was some spate of, you know, what sex acts were
counted, and he said that he had never had sex with her in any way
whatsoever -- that they had not had oral sex.(1088)

The President was asked during his grand jury appearance whether he
recalled denying a sexual relationship with Ms. Lewinsky to his senior
aides and advisors, including Mr. Bowles, Mr. Podesta, Mr. Blumenthal, Mr.
Ickes, and Mr. Jordan.(1089) The President did not recall specific details
but did remember the following:

I met with certain people, and [to] a few of them I said I didn't have sex
with Monica Lewinsky, or I didn't have an affair with her or something like
that. I had a very careful thing I said, and I tried not to say anything
else . . . . I remember that I issued a number of denials to people that I
thought needed to hear them, but I tried to be careful and to be accurate.

                                   * * *

And I believe, sir, that -- you'll have to ask them what they thought. But
I was using those terms in the normal way people use them.(1090)

The President testified that he had said "things that were true about this
relationship. That I used -- in the language I used, I said, there's
nothing going on between us. That was true.(1091) I said I did not have sex
with her as I defined it. That was true."(1092) The President qualified
this answer, however: "I said things that were true. They may have been
misleading, and if they were I have to take responsibility for it, and I'm
sorry."(1093)

3. Initial Denials to the American Public

On the afternoon of January 21, the President made his first of a series of
previously scheduled media appearances. In an interview on National Public
Radio's "All Things Considered," the following colloquy took place:

Q: Mr. President, . . . . [m]any Americans woke up to the news today that
the Whitewater independent counsel is investigating an allegation that
you . . . encouraged a young woman to lie to lawyers in the Paula Jones
civil suit. Is there any truth to that allegation?

WJC: No, sir, there's not. It's just not true.

Q: Is there any truth to the allegation of an affair between you and the
young woman?

WJC: No. That's not true either. . . . The charges are not true. And I
haven't asked anybody to lie.(1094)

That evening, the President appeared on the PBS program "The News Hour with
Jim Lehrer." He was asked again whether the allegation of an affair with a
White House intern was true. The President replied, "That is not true. That
is not true. I did not ask anyone to tell anything other than the truth.
There is no improper relationship. And I intend to cooperate with this
inquiry. But that is not true." When asked to define what he meant by the
term "improper relationship," the President answered, "Well, I think you
know what it means. It means that there is not a sexual relationship, an
improper sexual relationship, or any other kind of improper
relationship."(1095)

The following morning, on January 22, 1998, the President again denied he
had done anything improper. Speaking at a televised White House photo
opportunity with Palestinian Authority Chairman Yasser Arafat, the
President stated: "[T]he allegations are false, and I would never ask
anybody to do anything other than tell the truth. That is false."(1096)

The President also gave an interview to Roll Call that day. He stated:
"[T]he relationship was not improper, and I think that's important enough
to say. . . . But let me answer -- it is not an improper relationship and I
know what the word means. . . . The relationship was not sexual. And I know
what you mean, and the answer is no."(1097)

At each of these interviews, the President pledged he would cooperate fully
with the investigation. On NPR, the President stated: "I have told people
that I would cooperate in the investigation, and I expect to cooperate with
it. I don't know any more about it, really, than you do. But I will
cooperate. . . . I'm doing my best to cooperate with the
investigation."(1098) To Mr. Lehrer, he said: "[W]e are doing the best to
cooperate here, but we don't know much yet. . . . I think it's important
that we cooperate, I will cooperate, but I want to focus on the work at
hand."(1099)

In his photo opportunity with Mr. Arafat, the President stated:

[T]he American people have a right to get answers. We are working very hard
to comply, get all the requests for information up here. And we will give
you as many answers as we can, as soon as we can, at the appropriate time,
consistent with our obligation to also cooperate with the investigations.
And that's not a dodge; that's really what I've -- I've talked with our
people. I want to do that. I'd like for you to have more rather than less,
sooner rather than later. So we will work through it as quickly as we can
and get all those questions out there to you."(1100)

Finally, in his Roll Call interview, the President vowed: "I'm going to
cooperate with this investigation. . . . And I'll cooperate."(1101)

4. "We Just Have To Win"

Amidst the flurry of press activity on January 21, 1998, the President's
former political consultant, Dick Morris, read the Post story and called
the President.(1102) According to Mr. Morris, he told the President, "You
poor son of a bitch. I've just read what's going on."(1103) The President
responded, Mr. Morris recalled, "Oh, God. This is just awful. . . . I
didn't do what they said I did, but I did do something. I mean, with this
girl, I didn't do what they said, but I did . . . do something(1104). . . .
And I may have done enough so that I don't know if I can prove my
innocence. . . . There may be gifts. I gave her gifts, . . . . [a]nd there
may be messages on her phone answering machine."(1105)

Mr. Morris assured the President, "[t]here's a great capacity for
forgiveness in this country and you should consider tapping into it."(1106)
The President said, "But what about the legal thing? You know, the legal
thing? You know, Starr and perjury and all. . . . You know, ever since the
election, I've tried to shut myself down. I've tried to shut my body down,
sexually, I mean. . . . But sometimes I slipped up and with this girl I
just slipped up."(1107)

Mr. Morris suggested that he take a poll on the voters' willingness to
forgive confessed adultery. The President agreed.(1108)

Mr. Morris telephoned the President later that evening with the poll
results, which showed that the voters were "willing to forgive [the
President] for adultery, but not for perjury or obstruction of
justice[.]"(1109) When Mr. Morris explained that the poll results suggested
that the President should not go public with a confession or explanation,
he replied, "Well, we just have to win, then."(1110)

The President had a follow-up conversation with Mr. Morris during the
evening of January 22, 1998, when Mr. Morris was considering holding a
press conference to "blast Monica Lewinsky 'out of the water.'"(1111) The
President told Mr. Morris to "be careful". According to Mr. Morris, the
President warned him not to "be too hard on [Ms. Lewinsky] because there's
some slight chance that she may not be cooperating with Starr and we don't
want to alienate her by anything we're going to put out."(1112)

Meanwhile, in California, the President's good friend and Hollywood
producer, Harry Thomason, had seen the President's interview with Jim
Lehrer on televison.(1113) Mr. Thomason, who had occasionally advised the
President on matters relating to the media, traveled to Washington, D.C.,
and met with him the next day.(1114) Mr. Thomason told the President that
"the press seemed to be saying that [the President's comments were] weak"
and that he, Mr. Thomason, "thought his response wasn't as strong as it
could have been."(1115) Mr. Thomason recommended that the President "should
explain it so there's no doubt in anybody's mind that nothing
happened."(1116) The President agreed: "You know, you're right. I should be
more forceful than that."(1117)

In the ensuing days, the President, through his Cabinet, issued a number of
firm denials. On January 23, 1998, the President started a Cabinet meeting
by saying the allegations were untrue.(1118) Afterward, several Cabinet
members appeared outside the White House. Madeline Albright, Secretary of
State, said: "I believe that the allegations are completely untrue." The
others agreed. "I'll second that, definitely," Commerce Secretary William
Daley said. Secretary of Education Richard Riley and Secretary of Health
and Human Services Donna Shalala concurred.(1119)

The next day, Ann Lewis, White House Communications Director, publicly
announced that "those of us who have wanted to go out and speak on behalf
of the president" had been given the green light by the President's legal
team.(1120) She reported that the President answered the allegations
"directly" by denying any improper relationship. She believed that, in
issuing his public denials, the President was not "splitting hairs,
defining what is a sexual relationship, talking about 'is' rather than
was.(1121) You know, I always thought, perhaps I was naive, since I've come
to Washington, when you said a sexual relationship, everybody knew what
that meant." Ms. Lewis expressly said that the term includes "oral
sex."(1122)

* * *

On Monday, January 26, 1998, in remarks in the Roosevelt Room in the White
House, President Clinton gave his last public statement for several months
on the Lewinsky matter. At an event promoting after-school health care, the
President denied the allegations in the strongest terms: "I want to say one
thing to the American people. I want you to listen to me. I'm going to say
this again: I did not have sexual relations with that woman, Miss Lewinsky.
I never told anybody to lie, not a single time. Never. These allegations
are false."(1123)

1. Lewinsky 8/6/98 GJ at 31-32, 39-40; DB Photos 0004 (photo of dress).

2. FBI Lab Report, 8/3/98.

3. OIC letter to David Kendall, 7/31/98 (1st letter of day).

4. Kendall letter to OIC, 7/31/98; OIC letter to Kendall, 7/31/98 (2d
letter of day); Kendall letter to OIC, 8/3/98; OIC letter to Kendall,
8/3/98.

5. FBI Observation Report (White House), 8/3/98.

6. FBI Lab Reports, 8/6/98 & 8/17/98. The FBI Laboratory performed
polymerase chain reaction analysis (PCR) and restriction fragment length
polymorphisim analysis (RFLP). RFLP, which requires a larger sample, is the
more precise method. United States v. Hicks, 103 F.3d 837, 844-847 (9th
Cir. 1996).

7. FBI Lab Report, 8/17/98, at 2.

8. Lewinsky 7/27/98 Int. During earlier negotiations with this Office, Ms.
Lewinsky provided a 10-page handwritten proffer statement summarizing her
dealings with the President and other matters under investigation. Lewinsky
2/1/98 Statement. Ms. Lewinsky later confirmed the accuracy of the
statement in grand jury testimony. Lewinsky 8/20/98 GJ at 62-63. The
negotiations in January and February 1998 (which produced the written
proffer) did not result in a cooperation agreement because Ms. Lewinsky
declined to submit to a face-to-face proffer interview, which the OIC
deemed essential because of her perjurious Jones affidavit, her efforts to
persuade Linda Tripp to commit perjury, her assertion in a recorded
conversation that she had been brought up to regard lying as necessary, and
her forgery of a letter while in college. In July 1998, Ms. Lewinsky agreed
to submit to a face-to-face interview, and the parties were able to reach
an agreement.

9. Ex. ML-7 to Lewinsky 8/6/98 GJ.

10. Lewinsky 8/26/98 Depo. at 5-6; Lewinsky 8/6/98 GJ at 27-28.

11. Lewinsky 8/26/98 Depo. at 69.

12. Lewinsky 8/6/98 GJ at 59-60, 87; Lewinsky 8/20/98 GJ at 82; Lewinsky
8/24/98 Int. at 8.

13. Ms. Tripp testified that she took notes on two occasions. Tripp 6/30/98
GJ at 141-42; Tripp 7/7/98 GJ at 153-54; Tripp 7/16/98 GJ at 112-13.

14. Kassorla 8/28/98 Int. at 2-3. Ms. Lewinsky (who voluntarily waived
therapist-patient privilege) consulted Dr. Kassorla in person from 1992 to
1993 and by telephone thereafter. Id. at 1. Anticipating that the White
House might fire Ms. Lewinsky in order to protect the President, Dr.
Kassorla cautioned her patient that workplace romances are generally
ill-advised. Id. at 2.

15. Kassorla 8/28/98 Int. at 2, 4. Ms. Lewinsky also consulted another
counselor, Kathleen Estep, three times in November 1996. While diagnosing
Ms. Lewinsky as suffering from depression and low self-esteem, Ms. Estep
considered her self-aware, credible, insightful, introspective, relatively
stable, and not delusional. Estep 8/23/98 Int. at 1-4.

16. Catherine Davis 3/17/98 GJ at 21-22.

17. Young 6/23/98 GJ at 40. See also Catherine Davis 3/17/98 GJ at 73;
Erbland 2/12/98 GJ at 25 ("I never had any reason to think she would lie to
me. I never knew of her to lie to me before and we talked about our
boyfriends and, you know, sexual relationships throughout our friendship
and I never knew her as a liar."); Finerman 3/18/98 Depo. at 113-16
(characterizing Ms. Lewinsky as trustworthy and honest); Raines 1/29/98 GJ
at 87 ("I have no reason to believe that [Ms. Lewinsky's statements] were
lies or made up."); Tripp 7/29/98 GJ at 187 ("There were so many reasons
why I believed her. She just had way too much detail. She had detail that
none of us could really conceivably have if you had not been exposed in a
situation that she claimed to be."); Ungvari 3/19/98 GJ at 19 ("[s]he's
never lied to me before"); id. at 21, 61-62; Young 6/23/98 GJ at 38-40.

18. Ms. Lewinsky testified that she has "always been a date-oriented
person." Lewinsky 8/6/98 GJ at 28. See also Tripp 6/30/98 GJ at 141-42 (Ms.
Lewinsky "had a photographic memory for the entire relationship").

19. Clinton 1/17/98 Depo. at 78, 204. The transcript of this deposition
testimony appears in Document Supp. A. For reasons of privacy, the OIC has
redacted the names of three women from the transcript. The OIC will provide
an unredacted transcript if the House of Representatives so requests.

20. Clinton 1/17/98 Depo. at 57.

21. Clinton 1/17/98 Depo. at 54.

22. Clinton 1/17/98 Depo. at 204. Beyond his denial of a sexual
relationship with Ms. Lewinsky, the President testified that he could not
recall many details of their encounters. He said he could not specifically
remember whether he had ever been alone with Ms. Lewinsky, or any of their
in-person conversations, or any notes or messages she had sent him, or an
audiocassette she had sent him, or any specific gifts he had given her.
Alone together: Clinton 1/17/98 Depo. at 52-53, 56-59. Conversations: Id.
at 59. Cards and letters: Id. at 62. Audiocassette: Id. at 63-64. Gifts
from the President to Ms. Lewinsky: Id. at 75. When asked about their last
conversation, the President referred to a December encounter when, he said,
Ms. Lewinsky had been visiting his secretary and he had "stuck [his] head
out" to say hello. Id. at 68. He did not mention a private meeting with Ms.
Lewinsky on December 28, 1997, or a telephone conversation with her on
January 5, 1998. Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7; Clinton 8/17/98 GJ
at 34-36, 126-28.

23. Clinton 8/17/98 GJ at 10, 79, 81.

24. Clinton 8/17/98 GJ at 10.

25. Clinton 8/17/98 GJ at 31, 10. See also id. at 38-39.

26. Clinton 8/17/98 GJ at 10, 92-93.

27. Clinton 8/17/98 GJ at 22.

28. Clinton 8/17/98 GJ at 10, 12, 93-96.

29. 849-DC-00000586. The definition mirrors a federal criminal statute, 18
U.S.C. § 2246(3). The ellipsis in the quotation omits two paragraphs of the
definition that Judge Wright ruled inapplicable. Clinton 1/17/98 Depo. at
21-22. The President testified that he considered the definition "rather
strange," and at one point he spoke of "people being drawn into a lawsuit
and being given definitions, and then a great effort to trick them in some
way." Clinton 8/17/98 GJ at 19, 22. He acknowledged, however, that the
definition "was the one the Judge decided on and I was bound by it."
Clinton 8/17/98 GJ at 19.

30. Clinton 8/17/98 GJ at 15, 93, 100, 102.

31. Clinton 8/17/98 GJ at 151.

32. Clinton 8/17/98 GJ at 168.

33. Clinton 8/17/98 GJ at 102-105, 167-68.

34. Clinton 8/17/98 GJ at 95-96, 100, 110, 139. The President did not
always specify that the contact had to be direct. Id. at 15 ("[m]y
understanding of the definition is it covers contact by the person being
deposed with the enumerated areas, if the contact is done with an intent to
arouse or gratify"); id. at 16 (definition covers "[a]ny contact with the
areas there mentioned").

35. Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7. These numbers include occasions
when one or both of them had direct contact with the other's genitals, but
not occasions when they merely kissed. On the timing of some of their
sexual encounters, Ms. Lewinsky's testimony is at odds with the
President's. According to Ms. Lewinsky, she and the President had three
sexual encounters in 1995 (the President said he recalled none) and two
sexual encounters in 1997 (not one, as the President testified). Lewinsky
8/6/98 GJ at 27-28 & Ex. ML-7; Lewinsky 8/26/98 Depo. at 6; Clinton 8/17/98
GJ at 9-10. The President's account omits the two 1995 encounters when Ms.
Lewinsky was an intern (as well as one 1995 encounter when she worked on
the White House staff), and it treats the 1997 encounter that produced the
semen-stained dress as a single aberration.

36. Lewinsky 8/6/98 GJ at 34-36; Lewinsky 8/20/98 GJ at 17; Lewinsky
7/27/98 Int. at 2; Lewinsky 7/31/98 Int. at 4; Catherine Davis 3/17/98 GJ
at 16; Erbland 2/12/98 GJ at 27-28, 43-44; Finerman 3/18/98 Depo. at 32;
Kassorla 8/28/98 Int. at 2; Raines 1/29/98 GJ at 32-33; Tripp 7/2/98 GJ at
54, 101; Tripp 7/7/98 GJ at 171; Ungvari 3/19/98 GJ at 19, 25.

37. Lewinsky 8/6/98 GJ at 35; Lewinsky 7/27/98 Int. at 2.

38. Lewinsky 8/6/98 GJ at 12, 21; Lewinsky 2/1/98 Statement at 1. See also
Andrew Bleiler 1/28/98 Int. at 3; Catherine Davis 3/17/98 GJ at 21;
Kassorla 8/28/98 Int. at 2; Tripp 7/2/98 GJ at 100, 104-107; Ungvari
3/19/98 GJ at 23.

39. Lewinsky 8/6/98 GJ at 19; Catherine Davis 3/17/98 GJ at 20; Erbland
2/12/98 GJ at 29, 44; Ungvari 3/19/98 GJ at 20; Young 6/23/98 GJ at 37-38;
but see Raines 1/29/98 GJ at 43 (testifying that she was "pretty sure" that
Ms. Lewinsky spoke of reciprocal oral sex); Tripp GJ 7/2/98 at 101
(testifying that she understood that, on rare occasions, the President
reciprocated).

40. Lewinsky 8/6/98 GJ at 38-39. See also Lewinsky 8/20/98 GJ at 24.

41. Lewinsky 8/6/98 GJ at 19-20, 38-39; Ungvari 3/19/98 GJ at 23-24.

42. Lewinsky 7/30/98 Int. at 5-13, 15-16; Lewinsky 8/6/98 GJ at 19-21;
Lewinsky 8/20/98 GJ at 31-32, 40, 67-69; Lewinsky 8/26/98 Depo. at 20,
30-31, 50; Andrew Bleiler 1/28/98 Int. at 3; Catherine Davis 3/17/98 GJ at
20-21, 169; Erbland 2/12/98 GJ at 29, 43-45; Estep 8/23/98 Int. at 2;
Kassorla 8/28/98 Int. at 2; Ungvari 3/19/98 GJ at 23-24.

43. Clinton 8/17/98 GJ at 10; Lewinsky 8/26/98 Depo. at 5. In Ms.
Lewinsky's recollection, the friendship started to develop following their
sixth sexual encounter, when the President sat down and talked with her for
about 45 minutes after she had complained that he was making no effort to
get to know her. Lewinsky 8/26/98 Depo. at 23, 33-34.

44. Lewinsky 8/20/98 GJ at 59. See also id. at 52; Lewinsky 8/6/98 GJ at
168. After the President's August 1998 speech acknowledging improper
conduct with Ms. Lewinsky, she testified that she was no longer certain of
her feelings because, in her view, he had depicted their relationship as "a
service contract, that all I did was perform oral sex on him and that
that's all that this relationship was. And it was a lot more than that to
me . . . ." Lewinsky 8/20/98 GJ at 54. See also id. at 53-56, 102-104.

45. MSL-55-DC-0178 (document retrieved from Ms. Lewinsky's home computer);
Catherine Davis 3/17/98 GJ at 147; Erbland 2/12/98 GJ at 92.

46. Lewinsky 8/20/98 GJ at 52; T1 at 101. See also Marcia Lewis 2/11/98 GJ
at 7; Catherine Davis 3/17/98 GJ at 182.

47. Lewinsky 8/6/98 GJ at 18.

48. Lewinsky 7/27/98 Int. at 6; Currie 5/7/98 GJ at 60; Catherine Davis
3/17/98 GJ at 27; Raines 1/29/98 GJ at 53; Ungvari 3/19/98 GJ at 45; Young
6/23/98 GJ at 47; 1037-DC-00000042 (email from Ms. Lewinsky: "Jeez, I hate
being called 'dear.' The creep calls me that sometimes. It's an old person
saying!") (spelling and punctuation corrected). When angry, Ms. Lewinsky
referred to the President as "creep" or "big creep." Lewinsky 8/4/98 Int.
at 8; Marcia Lewis 2/11/98 GJ at 17; Raines 1/29/98 GJ at 52; Ungvari
3/19/98 GJ at 45.

49. Lewinsky 7/27/98 Int. at 6.

50. Lewinsky 8/26/98 Depo. at 55-57; Lewinsky 7/27/98 Int. at 6.

51. Marcia Lewis 2/11/98 GJ at 7-8.

52. Erbland 2/12/98 GJ at 84. See also Lewinsky 8/26/98 Depo. at 56-57;
Catherine Davis 3/17/98 GJ at 166-67. In late 1997, Ms. Lewinsky asked
Vernon Jordan whether he believed that the Clintons would remain married.
Lewinsky 2/1/98 Statement at 8; Jordan 3/3/98 GJ at 150.

53. Lewinsky 8/6/98 GJ at 17. See also Lewinsky 8/26/98 Depo. at 24;
Lewinsky 8/24/98 Int. at 6; Tripp 7/7/98 GJ at 172.

54. Raines 1/29/98 GJ at 39. See also Catherine Davis 3/17/98 GJ at 18;
Finerman 3/18/98 Depo. 47-49; Raines 1/29/98 GJ at 47-48; Tripp 7/14/98 GJ
at 77, 79-81.

55. Lewinsky 8/6/98 GJ at 52-53.

56. Lewinsky 8/6/98 GJ at 52.

57. Lewinsky 8/6/98 GJ at 21-23; Lewinsky 7/27/98 Int. at 2. See also
Catherine Davis 3/17/98 GJ at 36; Erbland 2/12/98 GJ at 38-39, 43; Finerman
3/18/98 Depo. at 26-29, 110, 116-17; Raines GJ at 51; Tripp 7/7/98 GJ at
62-63, 65-66; Ungvari 3/19/98 GJ at 81.

58. Lewinsky 8/6/98 GJ at 44; Lewinsky 8/24/98 Int. at 5; Currie 5/14/98 GJ
at 131-32, 136, 141; Currie 7/22/98 GJ at 35, 77.

59. Lewinsky 8/20/98 GJ at 55.

60. Lewinsky 8/6/98 GJ at 23.

61. Lewinsky 8/6/98 GJ at 23-24; Lewinsky 7/27/98 Int. at 2. See also
Catherine Davis 3/17/98 GJ at 36-37; Erbland 2/12/98 GJ at 38-39; Raines
1/29/98 GJ at 51; Ungvari 3/19/98 GJ at 81. Ms. Lewinsky gave the President
a novel about phone sex, Vox by Nicholson Baker. Lewinsky 7/27/98 Int. at
13; 1361-DC-00000030 (White House list of books in private study, including
Vox).

62. Lewinsky 7/30/98 Int. at 15.

63. Lewinsky 8/6/98 GJ at 23; Lewinsky 8/20/98 GJ at 6. The messages, on
tapes that Ms. Lewinsky turned over to the OIC, are as follows: "Aw,
shucks." "Hey." "Come on. It's me." "Sorry I missed you." Lewinsky 8/6/98
GJ at 22-23; Lewinsky 7/29/98 Int. at 3, 5; Lewinsky 8/3/98 Int. at 6.

64. Lewinsky 8/6/98 GJ at 22-23; Catherine Davis 3/17/98 GJ at 28-29;
Erbland 2/12/98 GJ at 49; Kassorla 8/28/98 Int. at 4; Raines 1/29/98 GJ at
89; Tripp 7/2/98 GJ at 89; Tripp 7/9/98 GJ at 95-97, 104-105; Ungvari
3/19/98 GJ at 31-33.

65. Lewinsky 8/6/98 GJ at 67-69.

66. Lewinsky 8/6/98 GJ at 74-75.

67. Lewinsky 8/6/98 GJ at 114.

68. Clinton 8/17/98 GJ at 10.

69. Clinton 8/17/98 GJ at 47, 51.

70. Clinton 8/17/98 GJ at 47, 124.

71. Lewinsky 8/6/98 GJ at 25-26.

72. Lewinsky 7/27/98 Int. at 12. See also MSL-55-DC-0184 - 186 (eight-line
poem recovered from Ms. Lewinsky's home computer that refers to President
as "the Boss with whom we're all smitten" and wishes him "Happy National
Boss Day!").

73. V006-DC-00000167; V006-DC-00000181 (gift record and donor information);
V006-DC-00003646 (correspondence history).

74. V006-DC-00000157 - 158 (gift record and donor information).

75. Lewinsky 8/11/98 Int. at 2; V006-DC-00000178 (autographed photo).

76. Few of Ms. Lewinsky's subsequent gifts were logged. Of the roughly 30
gifts (including several antiques) that, in her account, she gave the
President, White House records show only the matted poem from interns, two
or three neckties (records conflict), and a T-shirt. V006-DC-00000157;
V006-DC-00000162; V006-DC-00000167; V006-DC-00000180; V006-DC-00000181;
V006-DC-00003714; V006-DC-00003715.

77. MSL-55-DC-0177.

78. Lewinsky 8/26/98 Depo. at 5-6 & Ex. ML-7. In response to a January 20,
1998, subpoena seeking "any and all gifts . . . to or from Monica Lewinsky
. . . including

. . . any tie, mug, paperweight, book, or other article," the President
turned over a necktie, two antique books, a mug, and a silver standing
holder for cigars or cigarettes. Subpoena V002; V002-DC-00000001;
V002-DC-00000469.A subpoena dated July 17, 1998, identified specific gifts,
including Vox, a novel about phone sex by Nicholson Baker that, according
to Ms. Lewinsky, she gave the President in March 1997. Lewinsky 8/6/98 GJ
at 183-84; Lewinsky 7/27/98 Int. at 13; Subpoena D1415. The President did
not produce Vox in response to either subpoena, though his attorney
represented that "the President has complied with [the] grand jury
subpoenas." David Kendall Letter to OIC, 8/31/98. Vox, however, does appear
on an October 1997 list of books in the President's private study, and Ms.
Lewinsky saw it in the study on November 13, 1997. 1361-DC-00000030;
Lewinsky 8/6/98 GJ at 183-84.

79. Lewinsky 8/26/98 Depo. at 5-6 & Ex. ML-7.

80. Lewinsky 8/20/98 GJ at 36. See also Lewinsky 8/6/98 GJ at 236;
Catherine Davis 3/17/98 GJ at 153.

81. Lewinsky 8/6/98 GJ at 236; Lewinsky 8/20/98 GJ at 36; Lewinsky 8/3/98
Int. at 8; Lewinsky 8/11/98 Int. at 2-3. For example, one day after the
President and Ms. Lewinsky talked by telephone on February 7, 1996, and one
day after they talked on August 4, 1996, he wore a necktie she had given
him. Lewinsky 8/5/98 Int. at 1; Lewinsky 8/11/98 Int. at 2-3.

82. Lewinsky 8/6/98 GJ at 236.

83. Clinton 8/17/98 GJ at 47. See also id. at33-36, 43-46.

84. Lewinsky 8/6/98 GJ at 26.

85. Lewinsky 8/6/98 GJ at 189.

86. Lewinsky 8/6/98 GJ at 26-27.

87. Clinton 8/17/98 GJ at 48-49. In the Jones deposition, in contrast, the
President was asked if he remembered anything written in Ms. Lewinsky's
notes or cards to him. He testified: "No. Sometimes, you know, just either
small talk or happy birthday or sometimes, you know, a suggestion about how
to get more young people involved in some project I was working on. Nothing
remarkable. I don't remember anything particular about it." Clinton 1/17/98
Depo. at 62.

88. Lewinsky 2/1/98 Statement at 10. See also Lewinsky 8/20/98 GJ at 62-63;
Lewinsky 8/6/98 GJ at 141-42, 178-79. Ms. Lewinsky once told Betty Currie:
"As long as no one saw us -- and no one did -- then nothing happened."
Currie 1/27/98 GJ at 63-64.

89. Lewinsky 8/6/98 GJ at 78, 97-101; Lewinsky 7/27/98 Int. at 3.

90. Lewinsky 8/20/98 GJ at 22. See also Lewinsky 7/27/98 Int. at 9
(President assumed Ms. Lewinsky's Jones affidavit would be a denial, since
their pattern had been to conceal and deny).

91. Lewinsky 8/20/98 GJ at 4; Lewinsky 8/6/98 GJ at 166-67. See also
Lewinsky 7/27/98 Int. at 9-10, 12.

92. Lewinsky 8/6/98 GJ at 234.

93. Clinton 8/17/98 GJ at 38.

94. Clinton 8/17/98 GJ at 38, 119. See also id. at 80, 119, 136, 153.

95. Clinton 8/17/98 GJ at 37.

96. Lewinsky 8/6/98 GJ at 53-54. See also Lewinsky 7/27/98 Int. at 2, 11;
Lewinsky 8/19/98 Int. at 4; Lewinsky 2/1/98 Statement at 1.

97. Lewinsky 8/6/98 GJ at 53-54.

98. Lewinsky 8/6/98 GJ at 54.

99. Lewinsky 8/6/98 GJ at 54-55; Lewinsky 7/30/98 Int. at 10.

100. Lewinsky 8/6/98 GJ at 54-55.

101. Lewinsky 8/6/98 GJ at 18, 53-54.

102. Lewinsky 8/6/98 GJ at 18-19; Lewinsky 2/1/98 Statement at 1.

103. Lewinsky 8/20/98 GJ at 105; Lewinsky 2/1/98 Statement at 1.

104. Lewinsky 8/20/98 GJ at 22.

105. Lewinsky 2/1/98 Statement at 4; Lewinsky 8/6/98 GJ at 123, 233.

106. Clinton 1/17/98 Depo. at 50-51, 68.

107. Clinton 8/17/98 GJ at 118-19.

108. Clinton 8/17/98 GJ at 119. The President did not elaborate on his
understanding of the words "ask[]" or "lie" in that statement. In other
exchanges, he indicated that he construes some words narrowly. Id. at 59
(accuracy of particular statement "depends on what the meaning of the word
'is' is"); id. at 107 ("I have not had sex with her as I defined it"); id.
at 134 ("it depends on how you define alone"); id. ("there were a lot of
times when we were alone, but I never really thought we were").

109. Lewinsky 8/6/98 GJ at 47. Along with weekend visits, Ms. Lewinsky
sometimes saw the President on holidays: New Year's Eve, President's Day,
Easter Sunday, July 4. In November 1997, she grew irritated that the
President did not arrange to see her on Veterans Day. Lewinsky 9/3/98 Int.
at 2.

110. Lewinsky 8/6/98 GJ at 18. See also Lewinsky 8/20/98 GJ at 7, 22.

111. Lewinsky 8/6/98 GJ at 84-85; Lewinsky 8/20/98 GJ at 7. Ms. Lewinsky
told friends about White House people she tried to avoid. Tripp 6/30/98 GJ
at 159-60, 164; Tripp 7/14/98 GJ at 75; T1 at 32; 1037-DC-00000318 (email
from Ms. Lewinsky).

112. Lewinsky 8/6/98 GJ at 34-35; Lewinsky 8/20/98 GJ at 16-17; Lewinsky
7/31/98 Int. at 4. The study is one of the most private rooms in the White
House. Fox 2/17/98 GJ at 76. See also Chinery 7/23/98 GJ at 52; Currie
5/6/98 GJ at 67; Ferguson 7/17/87 GJ at 32, 38; Maes 4/8/98 GJ at 89-90;
Podesta 6/23/98 GJ at 72.

113. Lewinsky 7/31/98 Int. at 4.

114. Lewinsky 8/4/98 Int. at 4.

115. Lewinsky 8/6/98 GJ at 36. See also Lewinsky 7/31/98 Int. at 4.

116. Lewinsky 8/6/98 GJ at 36-37; Lewinsky 7/27/98 Int. at 2. According to
a Secret Service officer who entered the Oval Office when the President and
Ms. Lewinsky were in or near the study, the door leading from the Oval
Office to the hallway was slightly ajar. Muskett 7/21/98 GJ at 36-37, 39.
In his Jones deposition, the President was asked if there are doors at both
ends of the hallway. He responded: "[There] are, and they're always open."
Clinton 1/17/98 Depo. at 59. In early 1998, in the course of denying any
sexual relationship with Ms. Lewinsky, the President repeatedly told Deputy
Chief of Staff John Podesta that "the door was open." Podesta 6/16/98 GJ at
88-89.

117. Lewinsky 8/6/98 GJ at 56. See also Lewinsky 7/31/98 Int. at 3.

118. Lewinsky 7/31/98 Int. at 3.

119. Lewinsky 8/26/98 Depo. at 44-45; Lewinsky 7/30/98 Int. at 9; Lewinsky
7/31/98 Int. at 4. Ms. Lewinsky also testified about various steps she took
on her own to ensure that the relationship remained secret, such as using
different doors to enter and depart the Oval Office area, avoiding the
President at a White House party, and referring to the President as "her"
in pages to Betty Currie. Lewinsky 8/6/98 GJ at 44-45, 57, 218; Lewinsky
8/20/98 GJ at 5-6, 18; Lewinsky 7/29/98 Int. at 2-3.

120. Clinton 8/17/98 GJ at 38. See also id. at 53 (to President's
knowledge, Ms. Currie did not see intimate activity between President and
Ms. Lewinsky); id. at 54 ("I'd have to be an exhibitionist not to have
tried to exclude everyone else.").

121. Lewinsky 8/6/98 GJ at 56.

122. Lewinsky 8/6/98 GJ at 189, 198. See also Lewinsky 8/2/98 Int. at 3.
The President was under a legal obligation to turn this note over to the
Jones attorneys but failed to do so.

123. Lewinsky 8/24/98 Int. at 8.

124. Clinton 8/17/98 GJ at 50. See also id. at 130-131.

125. One of these tapes, T30, is a face-to-face conversation between Ms.
Tripp and Ms. Lewinsky, recorded under FBI auspices. The other, T22, is a
telephone conversation between Ms. Tripp and Ms. Lewinsky, recorded by Ms.
Tripp.

From these and other transcripts of recorded conversations, the OIC has
redacted various brief, irrelevant, and gratuitous passages, mostly
references to Ms. Lewinsky's family members. Most of these redactions are
only a word or two long; others are somewhat longer. The tapes themselves
have not been edited by the OIC, and the OIC will provide unredacted
transcripts if the House of Representatives so requests.

Ms. Tripp produced to the OIC 27 tapes (four of which proved inaudible or
blank) of her telephone conversations with Ms. Lewinsky. Ms. Tripp
testified that she turned over the original recordings. She testified that
she knew nothing about any duplications of the recordings, though others
had access to or control over the tapes at times before they were turned
over. According to a preliminary FBI examination, several of the 23 tapes
containing audible conversations exhibit signs of duplication, and one tape
exhibiting signs of duplication was produced by a recorder that was stopped
and restarted during the recording process. These preliminary results raise
questions about the reliability and authenticity of at least one recording,
which in turn raise questions about the accuracy of Ms. Tripp's testimony
regarding her handling of the tapes. The OIC is continuing to investigate
this matter. This Referral does not quote or rely on any tapes that exhibit
signs of duplication. For a fuller discussion, see Appendix, Tab I.

126. T30 at 41.

127. T30 at 41.

128. T30 at 41-42.

129. T22 at 12.

130. T22 at 12.

131. 828-DC-00000012 (resume); Lewinsky 7/27/98 Int. at 1; Walter Kaye
5/21/98 GJ at 34, 51-52; Marcia Lewis 4/3/98 Depo. at 90; Abramson 2/20/98
Int. at 1; Footlik 3/19/98 Int. at 1; 827-DC-00000003 (White House entry
records for Ms. Lewinsky). President Clinton testified that Mr. Kaye is "a
good friend of mine and a good friend of our administration." Clinton
1/17/98 Depo. at 61. Ms. Lewinsky turned 22 on July 23. 812-DC-00000002
(passport showing birthdate).

132. Lewinsky 8/6/98 GJ at 8; Lewinsky 8/20/98 GJ at 8; Bobowick 2/12/98
Int. at 1; Currie 1/27/98 GJ at 23-24; Panetta 1/28/98 GJ at 121-23;
Palmieri 2/24/98 GJ at 12; V006-DC-00000020 (White House employee data
form).

133. Lewinsky 8/3/98 Int. at 2.

134. Lewinsky 8/3/98 Int. at 2; 828-DC-00000012 (resume); V006-DC-00000225
(employment approval for the Legislative Affairs Office); V006-DC-00000198
(1995 White House intern directory); V006-DC-00002287 (record of Ms.
Lewinsky's transfer).

135. Lewinsky 8/26/98 Depo. at 60.

136. Lewinsky 8/6/98 GJ at 10.

137. Lewinsky 8/6/98 GJ at 9; Lewinsky 7/27/98 Int. at 2; Lewinsky 8/3/98
Int. at 1; V006-DC-00001826 (photo showing President and Ms. Lewinsky).

138. Lewinsky 8/26/98 Depo. at 16-17 & Ex. ML-7.

139. Finerman 3/18/98 Depo. at 10-11; Ungvari 3/19/98 GJ at 15-17.

140. Facts on File 852, 868 (1995).

141. Washington Post, 11/20/95 at A19; Los Angeles Times, 11/14/95 at A15;
USA Today, 11/17/95 at 4A.

142. Lewinsky 8/6/98 GJ at 10-11; Byrne 6/25/98 Depo. at 18; Byrne 7/30/98
GJ at 36; Palmieri 2/24/98 GJ at 16-19; Panetta 1/28/98 GJ at 122.

143. Goodin 2/17/98 GJ at 48-50; Griffin 5/11/98 Int. at 1; Lewinsky 8/6/98
GJ at 10-11; Palmieri 2/24/98 GJ at 20-22; Raines 1/29/98 GJ at 35-36;
V006-DC-00003737 - 3744 (White House photos showing President and Ms.
Lewinsky during furlough).

144. Lewinsky 8/6/98 GJ at 11.

145. Lewinsky 8/3/98 Int. at 2; Barry Toiv 3/11/98 Int. at 1 (job title).

146. Lewinsky 8/6/98 GJ at 10; Lewinsky 7/27/98 Int. at 1-2. She told
others that her physical relationship with the President began during the
November 1995 shutdown. Raines 1/29/98 GJ at 38; Tripp 7/2/98 GJ at 38-39.
To one friend, Ms. Lewinsky specified that the relationship began on
November 15, 1995. Tripp 6/30/98 GJ at 138; Tripp 7/2/98 GJ at 38-39,
80-82.

147. 827-DC-00000008. According to records, it was one of only two times
during Ms. Lewinsky's tenure at the White House that she exited after
midnight. 827-DC-00000003 - 16. (The other post-midnight exit was not
during the furlough; it was the night of December 6-7, 1995.) As the
omission of Ms. Lewinsky's November 15 afternoon exit time illustrates,
White House Epass and WAVES records do not reflect all entries and exits of
staff and visitors. Secret Service Representatives Barry Smith et al.
3/16/98 Int. at 3-5. See also Appendix, Tab I.

148. 1222-DC-00000156, 1222-DC-00000083 - 85 (movement logs). Times are
approximate, as different logs of the President's movements sometimes vary
by a few minutes. With occasional exceptions, these logs do not distinguish
the President's private study from the Oval Office.

149. Lewinsky 7/27/98 Int. at 2; Lewinsky 8/24/98 Int. at 5.

150. Lewinsky 7/30/98 Int. at 5; Lewinsky 8/11/98 Int. at 7; Erbland
2/12/98 GJ at 24-25.

151. Lewinsky 8/6/98 GJ at 11; Lewinsky 7/27/98 Int. at 2; Lewinsky 7/30/98
Int. at 5.

152. Lewinsky 8/6/98 GJ at 11; Lewinsky 7/27/98 Int. at 2; Lewinsky 7/30/98
Int. at 5.

153. Lewinsky 8/6/98 GJ at 11;Lewinsky 8/26/98 Depo. at 7. Ms. Lewinsky
later told confidants that the relationship began with kissing. Catherine
Davis 3/17/98 GJ at 19; Finerman 3/18/98 Depo. at 31-35; Tripp 7/7/98 GJ at
151-52.

154. Lewinsky 7/30/98 Int. at 5.

155. Lewinsky 8/26/98 Depo. at 7.

156. Lewinsky 8/6/98 GJ at 12; Lewinsky 7/30/98 Int. at 5.

157. Lewinsky 8/26/98 Depo. at 7.

158. Lewinsky 8/26/98 Depo. at 7; Lewinsky 8/6/98 GJ at 12, 13.

159. Lewinsky 8/26/98 Depo. at 8; Lewinsky 7/30/98 Int. at 5.

160. Lewinsky 8/26/98 Depo. at 7-8.

161. Lewinsky 8/26/98 Depo. at 8. See also id. at 21. Earlier in the
evening, Ms. Lewinsky had removed her underwear. Lewinsky Int. 9/3/98 at 1.

162. Lewinsky 8/6/98 GJ at 12-14; Lewinsky 8/26/98 Depo. at 9-10; Lewinsky
7/30/98 Int. at 6.

163. Lewinsky 8/26/98 Depo. at 10.

164. Lewinsky 8/26/98 Depo. at 11.

165. Lewinsky 9/3/98 Int. at 3; Lewinsky 8/24/98 Int. at 5; Lewinsky
7/30/98 Int. at 6.

166. Lewinsky 8/6/98 GJ at 11-12; Lewinsky 8/26/98 Depo. at 7.

167. 1362-DC-00000549 (movement logs).

168. Lewinsky 7/30/98 Int. at 6.

169. 1472-DC-00000006 - 08. Starting 11 minutes later, the President talked
with other Members of Congress. Id.

170. 827-DC-00000008 (Epass records).

171. 1222-DC-00000085 (movement logs).

172. Lewinsky 8/6/98 GJ at 14. See also Lewinsky 7/30/98 Int. at 6-7.

173. Lewinsky 8/6/98 GJ at 14-15; Lewinsky 7/30/98 Int. at 7.

174. Lewinsky 8/6/98 GJ at 15-16.

175. In Ms. Currie's recollection, Ms. Lewinsky and the President were
alone together for about 30 seconds. Currie 1/27/98 GJ at 33-34; Currie
5/14/98 GJ at 36-38. Ms. Hernreich testified that when delivering food
during the government shutdown, Ms. Lewinsky was alone with the President
for two to four minutes. Hernreich 2/26/98 GJ at 36-37. See also Hernreich
2/25/98 GJ at 12-17. Other witnesses also remembered Ms. Lewinsky's pizza
delivery during the furlough. Keating 2/25/98 GJ at 31-32; Palmieri 2/24/98
GJ at 20, 53, 62. The President and Ms. Lewinsky (as well as others) appear
in eight White House photographs taken on November 17; in three of them,
the President is eating pizza. V006-DC-00003737 - 3744.

176. Lewinsky 8/6/98 GJ at 16; Lewinsky 8/26/98 GJ at 11-15; Lewinsky
7/30/98 Int. at 7.

177. Lewinsky 8/26/98 Depo. at 12-13; Lewinsky 7/30/98 Int. at 7.

178. Lewinsky 8/26/98 Depo. at 12; Lewinsky 7/30/98 Int. at 7.

179. Lewinsky 7/30/98 Int. at 7.

180. Lewinsky 8/26/98 Depo. at 13-14.

181. Lewinsky 8/26/98 Depo. at 13-14; Lewinsky 7/30/98 Int. at 7. One
friend understood that Ms. Lewinsky and the President kissed when she
brought pizza, and that Ms. Lewinsky performed oral sex on him in a later
encounter. Ungvari 3/19/98 GJ at 18-19, 20, 23. One of Ms. Lewinsky's
counselors understood that the relationship with the President began at a
pizza party. Estep 8/23/98 Int. at 2.

182. Lewinsky 7/30/98 Int. at 7. See also Lewinsky 8/26/98 Depo. at 15.

183. 1472-DC-00000015 (phone logs). Ms. Lewinsky said that this probably
was the name she heard on that date. Lewinsky 8/11/98 Int. at 5. She
testified that she could not recall whether the President was on the
telephone the whole time that she performed oral sex. Lewinsky 8/26/98
Depo. at 14.

184. Clinton 1/17/98 Depo. at 58.

185. Clinton 8/17/98 GJ at 31-32.

186. 827-DC-00000011 (Epass records).

187. 1222-DC-00000179 (movement logs). The President had one telephone call
during this period, from 12:53 to 12:58 p.m. 1506-DC-00000029 (phone logs).

188. Lewinsky 8/26/98 Depo. at 15-16; Lewinsky 7/27/98 Int. at 3-4;
Lewinsky 7/30/98 Int. at 8.

189. Lewinsky 8/26/98 Depo. at 16.

190. Lewinsky 8/26/98 Depo. at 16; Lewinsky 7/27/98 Int. at 3-4; Lewinsky
7/30/98 Int. at 8.

191. Lewinsky 8/26/98 Depo. at 16.

192. Lewinsky 8/26/98 Depo. at 16-17. See also Lewinsky 7/30/98 Int. at 8.

193. Lewinsky 7/27/98 Int. at 3-4; Lewinsky 7/30/98 Int. at 8.

194. Lewinsky 8/26/98 Depo. at 17. See also Finerman 3/18/98 Depo. at
30-32, 35.

195. Lewinsky 7/30/98 Int. at 3.

196. 1222-DC-00000325 (Secret Service duty logs).

197. Clinton 8/17/98 GJ at 31-32.

198. Clinton 8/17/98 GJ at 9-10.

199. Ms. Lewinsky understood that the President may have thought there was
something improper in having a sexual relationship with an intern. Lewinsky
8/24/98 Int. at 5.

200. Clinton 8/17/98 GJ at 10.

201. As noted above, White House entry and exit records are incomplete.

202. 1222-DC-00000183 (movement logs).

203. Lewinsky 8/26/98 Depo. at 18. See also Lewinsky 7/30/98 Int. at 2, 8.

204. Lewinsky 8/26/98 Depo. at 18.

205. Lewinsky 8/26/98 Depo. at 19.

206. Lewinsky 8/26/98 Depo. at 19.

207. Lewinsky 8/26/98 Depo. at 19.

208. Lewinsky 8/26/98 Depo. at 19.

209. Lewinsky 8/26/98 Depo. at 20. They engaged in oral-anal contact as
well. Id.

210. Lewinsky 8/26/98 Depo. at 38.

211. 1222-DC-00000325, 1362-DC-00001171 (Secret Service duty logs).

212. Fox 2/17/98 GJ at 33. Although Mr. Fox believed that the incident
occurred in late 1995, the totality of the evidence suggests that it was on
this date, January 7, 1996.

213. Fox 2/17/98 GJ at 31.

214. Fox 2/17/98 GJ at 60-61, 66-67.

215. Fox 2/17/98 GJ at 33.

216. Fox 2/17/98 GJ at 19-20, 42, 49-50.

217. Fox 2/17/98 GJ at 34-35. Officer Fox testified that the President and
Ms. Lewinsky were alone. Fox 2/17/98 GJ 36-37. His sworn testimony on this
point differs from the public statements of his attorney, who told
reporters that Officer Fox did not know whether the two were alone. Chicago
Tribune, 2/17/98 at 1C.

218. 827-DC-00000013 (Epass records).

219. 1222-DC-00000189 (movement logs). While Ms. Lewinsky was in the White
House, the President had a single phone call, at 3:47 p.m. for one minute.
1506-DC-00000050 (phone logs).

220. Lewinsky 7/30/98 Int. at 9; Lewinsky 8/24/98 Int. at 6.

221. Lewinsky 8/26/98 Depo. at 22-23.

222. Lewinsky 8/26/98 Depo. at 23.

223. Lewinsky 8/26/98 Depo. at 23.

224. Lewinsky 8/26/98 Depo. at 23-24. See also Lewinsky 7/30/98 Int. at 10.

225. Lewinsky 8/26/98 Depo. at 24-25.

226. Lewinsky 8/26/98 Depo. at 25.

227. Lewinsky 8/26/98 Depo. at 26.

228. Lewinsky 8/26/98 Depo. at 26. This interruption may have been
occasioned by the President's one-minute phone call at 3:47 p.m.
1506-DC-00000050 (phone logs).

229. Lewinsky 8/26/98 Depo. at 26-27. Ms. Lewinsky stated that the Blairs
from Arkansas were visiting the President. Lewinsky 7/30/98 Int. at 10.
This is confirmed by a Secret Service itinerary for January 21, 1996, where
Diane Blair is listed as a houseguest. 1222-DC-00000024 (presidential
itinerary).

230. Lewinsky 8/26/98 Depo. at 27-28; Lewinsky 7/30/98 Int. at 10; Tripp
7/7/98 GJ at 124-26, 139-143; Tripp 7/9/98 GJ at 4-5; 845-DC-00000004
(Tripp notes).

231. 1222-DC-00000196 (movement logs).

232. 1506-DC-00000068 (phone logs).

233. Lewinsky 8/26/98 Depo. at 28-29; Lewinsky 8/24/98 Int. at 6.

234. Lewinsky 8/26/98 Depo. at 29-30.

235. Lewinsky 8/26/98 Depo. at 30-31.

236. Lewinsky 8/26/98 Depo. at 31-32. They engaged in oral-anal contact as
well. Id. at 30-31.

237. Lewinsky 8/26/98 Depo. at 33.

238. Lewinsky 8/26/98 Depo. at 33-34.

239. Lewinsky 8/26/98 Depo. at 33.

240. Lewinsky 8/26/98 Depo. at 33-34; Lewinsky 8/24/98 Int. at 6; Tripp
7/7/98 GJ at 169-71; 845-DC-00000006 (Tripp notes).

241. 1222-DC-00000197, 1222-DC-00000102 (movement logs).

242. 1506-DC-00000102 (phone logs).

243. Lewinsky 7/30/98 Int. at 11; Lewinsky 8/24/98 Int. at 6.

244. Lewinsky 7/30/98 Int. at 3, 11-12.

245. Lewinsky 7/30/98 Int. at 3, 11.

246. Lewinsky 8/6/98 GJ at 24; Lewinsky 7/29/98 Int. at 3.

247. Lewinsky 7/30/98 Int. at 11. Ms. Lewinsky later recounted the episode
to several others. Erbland 2/12/98 GJ at 46-47; Finerman 3/18/98 Depo. at
47; Tripp 7/7/98 GJ at 175-76; Ungvari 3/19/98 GJ at 80.

248. Lewinsky 8/24/98 Int. at 6. See also Lewinsky 7/30/98 Int. at 11.

249. Garabito 7/30/98 GJ at 16-17, 23-24. According to a colleague, Agent
Garabito is over six feet tall, slender, and Hispanic. OIC Memo of
Interview with Special Agent Thomas M. Powers, 9/7/98.

250. Garabito 7/30/98 GJ at 25, 30-31.

251. Garabito 7/30/98 GJ at 32. Agent Garabito later recounted the incident
to Larry L. Cockell, the head of the Presidential Protective Division of
the Secret Service. The OIC learned of the episode from Agent Cockell's
testimony. Cockell 7/23/98 GJ at 25-26.

252. 1472-DC-00000017 (call logs).

253. 1506-DC-00000017 (call logs).

254. Forbes, 9/22/97 at 2.

255. Lewinsky 8/6/98 GJ at 90.

256. Lewinsky 8/6/98 GJ at 91. See also Lewinsky 8/26/98 Depo. at 34; Tripp
7/7/98 GJ at 179-80. Ms. Lewinsky offered to return to the White House to
see him, but the President said he needed to stay in the Residence because
his daughter was ill. Lewinsky 7/30/98 Int. at 12; Lewinsky 8/24/98 Int. at
6.

257. Ungvari 3/19/98 GJ at 29-31; Lewinsky 8/3/98 Int. at 3; Ungvari
3/18/98 Int. at 4; Verna 6/11/98 Depo. at 10; 845-DC-00000009 (Tripp
notes).

258. Ungvari 3/19/98 GJ at 30.

259. Lewinsky 8/11/98 Int. at 2.

260. Lewinsky 8/20/98 GJ at 19; Lewinsky 7/30/98 Int. at 12;
845-DC-00000010 - 11 (Tripp notes).

261. Lewinsky 8/26/98 Depo. at 34-35.

262. 1222-DC-00000112 (movement logs). The President and 32 guests saw
Executive Decision that evening. 1506-DC-00000558 (White House daily
diary).

263. 968-DC-00003459 (Hillary Clinton calendar).

264. Lewinsky 7/29/98 Int. at 3; Lewinsky 7/30/98 Int. at 12-13.

265. 827-DC-00000016 (Epass records).

266. 1222-DC-00000216 - 217; 1222-DC-00000112 - 113 (movement logs).

267. 1506-DC-00000139 (phone logs).

268. 968-DC-00003459 (Hillary Clinton calendar). Mrs. Clinton returned that
evening. 1506-DC-00000559 (White House diary); 1222-DC-00000041 (Secret
Service itinerary).

269. Lewinsky 8/26/98 Depo. at 35-36.

270. Lewinsky 8/26/98 Depo. at 36; Lewinsky 7/30/98 Int. at 12.

271. Lewinsky 8/26/98 Depo. at 38-39.

272. Lewinsky 8/26/98 Depo. at 37.

273. Lewinsky 7/30/98 Int. at 12-13; Lewinsky 8/26/98 Depo. at 37-38. In
the grand jury, the President declined to answer whether Ms. Lewinsky would
be lying if she said he had used a cigar as a sexual aid with her. Clinton
8/17/98 GJ at 110-11.

274. Lewinsky 7/30/98 Int. at 13.

275. Fox 2/17/98 GJ at 42-43.

276. Ludtke 6/5/98 Int. at 1-2.

277. Muskett 7/21/98 GJ at 124. Others also noted that Ms. Lewinsky spent
time around the West Wing. Byrne 3/13/98 Depo. at 22-25; Byrne 6/25/98
Depo. at 23, 39-44, 55-62, 104-113; Byrne 7/30/98 GJ at 8, 39-40; Hannie
4/6/98 Int. at 2-3; Keating 2/25/98 GJ at 52.

278. Lewinsky 8/20/98 GJ at 12.

279. Bordley 8/13/98 GJ at 9-16.

280. Bordley 8/13/98 GJ at 20-23, 29.

281. Bordley 8/13/98 GJ at 25-29.

282. Ferguson 7/17/98 GJ at 14-17, 27-28; Ferguson 7/23/98 GJ at 14-17, 20.

283. Ferguson 7/17/98 GJ at 27.

284. Ferguson 7/17/98 GJ at 27-28; Ferguson 7/23/98 GJ at 20-21.

285. Ferguson 7/17/98 GJ at 29, 31.

286. Ferguson 7/17/98 GJ at 29. In addition, Officer Lewis Fox and Agent
Nelson Garabito testified about admitting Ms. Lewinsky to the Oval Office
on one occasion each, as recounted above. Fox 2/17/98 GJ at 32-37; Garabito
7/30/98 GJ at 16-32. Officer Fox also saw Ms. Lewinsky exit the Oval Office
on another occasion, but he did not know how long she had been inside. Fox
2/17/98 GJ at 43-46. Officer Gary Byrne also testified about having seen
Ms. Lewinsky in the Oval Office with the President, though some details of
his account varied in different tellings. Byrne 7/30/98 GJ at 7-32; Byrne
7/17/98 GJ at 4-10.

287. Byrne 3/13/98 Depo. at 27-28, 46-47, 51-55; Byrne 6/25/98 Depo. at 31.

288. Lewinsky 8/20/98 GJ at 10-11; Lewinsky 7/31/98 Int. at 6.

289. Lieberman 1/30/98 GJ at 36-37. Ms. Lieberman testified that she
continued to disapprove of Ms. Lewinsky. When she saw Ms. Lewinsky back in
the White House after she no longer worked there, Ms. Lieberman asked Ms.
Currie, "What is she doing here?" She also may have said to Ms. Currie, who
told Ms. Lewinsky that she could watch a presidential helicopter departure,
"What are you -- nuts?" or otherwise "expressed my displeasure." Lieberman
1/30/98 GJ at 50-52.

290. Lewinsky 8/20/98 GJ at 8.

291. Lieberman 1/30/98 GJ at 41.

292. Panetta 1/28/98 GJ at 139-42.

293. Lieberman 1/30/98 GJ at 45. See also Panetta 1/28/98 GJ at 143
(describing precautions taken "to protect the President's office and
protect his integrity," including preventing President from meeting alone
with female acquaintances in circumstances that "could be misinterpreted").

294. Lewis 2/11/98 GJ at 37-40. See also T3 at 15; Lewinsky 7/31/98 Int. at
7. Ms. Lieberman testified that the conversation occurred in September
1997. Lieberman 1/30/98 GJ at 66. In her recollection, the exchange began
with Ms. Lewis coming up to her and saying, "You ruined [Ms. Lewinsky's]
life on the basis of something that she never did." According to Ms.
Lieberman, she made no response, and Ms. Lewis walked away. Later Ms. Lewis
returned and said that she understood what Ms. Lieberman had done and why.
Lieberman 1/30/98 GJ at 64-66.

295. Abramson 2/20/98 Int. at 3; Band 2/25/98 Int. at 2-3; Currie 5/6/98 GJ
at 40-41; Ganong 2/12/98 Int. at 2; Keating 2/25/98 GJ at 73; Panetta
1/28/98 GJ at 139-42.

296. 1089-DC-00000970 (memo from Mr. Hilley to Ms. Lieberman); Hilley
5/19/98 GJ at 34-35, 47-50. Mr. Hilley testified that "extracurricular
activities" -- which applied to Ms. Lewinsky and one of her colleagues who
was also transferred

-- did not refer to anything sexual in nature. Hilley 5/19/98 GJ at 49-50.
See also Byrne 6/25/98 Depo. at 22-25, 27-28, 38, 43, 54-55; Currie 5/14/98
GJ at 19-35; Fox 2/17/98 GJ at 46-48; Maes 5/7/98 GJ at 34-42.

297. Duncan 2/18/98 GJ at 24.

298. V006-DC-00001347.

299. Duncan 2/18/98 GJ at 13-14.

300. Duncan 2/18/98 GJ at 23, 41.

301. Duncan 2/18/98 GJ at 8, 23-24.

302. Lewinsky 8/6/98 GJ at 61. The President was traveling to Oklahoma City
on that day. V006-DC-00000694 (President's schedule); 968-DC-00000841
(same).

303. Keating 2/25/98 GJ at 76. The Pentagon position had a higher salary
than Ms. Lewinsky's White House job. Lewinsky 8/3/98 Int. at 5. Ms.
Lewinsky's supervisor, Jocelyn Jolley, was also transferred that day.
Keating 2/25/98 GJ at 76-79; Lewinsky 8/6/98 GJ at 171. Unlike Ms.
Lewinsky, Ms. Jolley was given a demotion: a temporary job at the General
Services Administration. Jolley 2/24/98 GJ at 36-39; Keating 2/25/98 GJ at
79.

304. Keating 2/25/98 GJ at 78-79; Lewinsky 8/3/98 Int. at 3; Capps 3/23/98
Int. at 2; Fox 2/17/98 GJ at 47; Lynn 8/5/98 GJ at 14-16; Verna 7/21/98 GJ
at 21-23.

305. Lewinsky 8/6/98 GJ at 171. See also Lewinsky 8/3/98 Int. at 3. Ms.
Lewinsky testified that Mr. Keating led her to believe that she could
probably return to work at the White House after the election. Lewinsky
8/3/98 Int. at 4. Mr. Keating testified that he told her that if she
performed well at the Pentagon, "she may be able to get a job back in the
White House. But not now." Keating 2/25/98 GJ at 79.

306. Lewinsky 8/26/98 Depo. at 60.

307. Lewinsky 8/6/98 GJ at 62.

308. 827-DC-00000016 (Epass records).

309. 1222-DC-00000219 (movement log).

310. Lewinsky 8/6/98 GJ at 62. See also Lewinsky 8/26/98 Depo. at 39;
Lewinsky 7/27/98 Int. at 4; Tripp 7/9/98 GJ at 29-30.

311. In Ms. Lewinsky's recollection, Officer Muskett first said he needed
to get Evelyn Lieberman's authorization before admitting Ms. Lewinsky to
the Oval Office, but Ms. Lewinsky talked him out of it. Lewinsky 8/6/98 GJ
at 91; Lewinsky 8/20/98 GJ at 42; Lewinsky 8/26/98 Depo. at 39-40; Lewinsky
7/27/98 Int. at 4; Lewinsky 7/30/98 Int. at 13; Lewinsky 7/31/98 Int. at 6.

312. Lewinsky 7/27/98 Int. at 4.

313. Lewinsky 8/6/98 GJ at 63. See also Lewinsky 8/26/98 Depo. at 40;
Lewinsky 7/30/98 Int. at 13; Erbland 2/12/98 GJ at 37; Tripp 7/9/98 GJ at
31; 833-DC-00001070 (document recovered from Ms. Lewinsky's computer
referring to President's promise to arrange for her return);
MSL-DC-00001052 (another recovered computer file, saying in part: "You
promised you would bring me back after the election with a snap of [your]
fingers."); Lewinsky Statement 2/1/98 at 1 ("he promised to bring her back
to the WH after the election"); Tripp 7/9/98 GJ at 31, 37-38, 42.

314. In a recorded conversation, Ms. Lewinsky recounted part of this
discussion:

[H]e said, "I promise you," you know, something like, "if I win in
November, I'll have you back like that. You can do anything you want. You
can be anything you want." And then I made a joke and I said, "Well, can I
be Assistant to the President for Blow Jobs?" He said, "I'd like that."

T7 at 34-35.

315. Lewinsky 8/6/98 GJ at 64.

316. Clinton 8/17/98 GJ at 130.

317. Lewinsky 8/26/98 Depo. at 40.

318. Lewinsky 8/6/98 GJ at 94-97.

319. Lewinsky 8/26/98 Depo. at 40-41.

320. Lewinsky 8/26/98 Depo. at 41.

321. Lewinsky 8/26/98 Depo. at 41.

322. Lewinsky 8/6/98 GJ at 20, 95-97; Lewinsky 7/30/98 Int. at 13.

323. Lewinsky 8/6/98 GJ at 95; Lewinsky 8/26/98 Depo. at 41-44; Lewinsky
7/27/98 Int. at 4-5; Lewinsky 7/30/98 Int. at 13.

324. Lewinsky 8/6/98 GJ at 92; Lewinsky 7/27/98 Int. at 4-5; Lewinsky
7/30/98 Int. at 13.

325. 1248-DC-00000008 (phone logs).

326. Lewinsky 8/6/98 GJ at 93, 97.

327. Lewinsky 8/6/98 GJ at 93. See also Lewinsky 8/26/98 Depo. at 43;
Lewinsky 7/27/98 Int. at 5; Lewinsky 7/30/98 Int. at 13. Ms. Lewinsky
testified that she did not see Mr. Ickes but recognized his voice. Lewinsky
8/6/98 GJ at 97.

328. Lewinsky 8/6/98 GJ at 93; Lewinsky 8/26/98 Depo. at 45; Lewinsky
7/27/98 Int. at 5; Lewinsky 7/30/98 Int. at 13.

329. Lewinsky 8/6/98 GJ at 94. See also Lewinsky 7/30/98 Int. at 11; Tripp
7/9/98 GJ at 30-36; 845-DC-00000012 - 13 (Tripp notes).

330. Muskett 7/21/98 GJ at 9-13.

331. Muskett 7/21/98 GJ at 22-24.

332. Muskett 7/21/98 GJ at 25-26, 83.

333. Muskett 7/21/98 GJ at 27-28, 91-93.

334. Muskett 7/21/98 GJ at 28, 31-33.

335. Muskett 7/21/98 GJ at 34-37.

336. Lewinsky 8/6/98 GJ at 36-37; Lewinsky 7/27/98 Int. at 2.

337. Muskett 7/21/98 GJ at 36-37, 39-40. Officer Muskett recalled that the
plainclothes agent on duty at the time was Reginald Hightower. Muskett
7/21/98 GJ at 22. While not "100 percent sure" that this incident occurred,
Agent Hightower testified that "it probably did happen." Hightower 7/28/98
GJ at 46-49.

338. Muskett 7/21/98 GJ at 42-46. Mr. Ickes testified that he cannot recall
this incident but cannot rule it out. Ickes 8/5/98 GJ at 58-59.

339. Muskett 7/21/98 GJ at 47-52, 89.

340. 1506-DC-00000144 (phone logs).

341. Lewinsky 8/6/98 GJ at 64-65. See also Lewinsky 2/1/98 Statement at 1;
Lewinsky 7/31/98 Int. at 6-7; Lewinsky 8/3/98 Int. at 5; Tripp 7/9/98 GJ at
72-73; 845-DC-00000014 (Tripp notes); T2 at 17.

342. Lewinsky 8/6/98 GJ at 65; Lewinsky 7/29/98 Int. at 3-4; Lewinsky
8/3/98 Int. at 5.

343. Lieberman 1/30/98 GJ at 62.

344. Lieberman 1/30/98 GJ at 62.

345. Bowles 4/2/98 GJ at 66-67.

346. Currie 5/7/98 GJ at 49-50.

347. Jordan 3/3/98 GJ at 64-65.

348. V006-DC-00002289 (email noting departures of White House employees);
Lewinsky 8/6/98 GJ at 65. According to the job description for the
position:

The incumbent of this Schedule C position will have access to highly
confidential, sensitive and frequently politically controversial
information and must be a person in whom the [Assistant Secretary of
Defense for Public Affairs] has complete trust and confidence.

833-DC-00002880. Ms. Lewinsky held clearance for Sensitive Compartmented
Information. Lewinsky 8/24/98 Int. at 3. According to a regulation:

Sensitive Compartmented Information is information that not only is
classified for national security reasons as Top Secret, Secret, or
Confidential, but also is subject to special access and handling
requirements because it involves or derives from particularly sensitive
intelligence sources and methods.

28 C.F.R. § 17.18(a) (1998).

349. Lewinsky 7/29/98 Int. at 1.

350. Lewinsky 8/6/98 GJ at 66.

351. Tripp 7/9/98 GJ at 94-98.

352. Lewinsky 8/6/98 GJ at 28 & Ex. ML-7.

353. Tripp 7/14/98 GJ at 3-4, 11-12; 845-DC-00000019 (Tripp notes).

354. Lewinsky 7/29/98 Int. at 4-5.

355. Lewinsky 7/30/98 Int. at 14. See also Lewinsky 7/29/98 Int. at 4;
Lewinsky 8/6/98 GJ at 27-28; Tripp 7/9/98 GJ at 118-19 (mistakenly
indicating that this occurred July 15, 1996); 845-DC-00000018 (Tripp
notes).

356. 1506-DC-00000275 (call log); 1506-DC-000000638.

357. Lewinsky 7/29/98 Int. at 4-5; Lewinsky 7/30/98 Int. at 14-15;
845-DC-00000016 - 17 (Tripp notes); 845-DC-00000020 - 22 (same); Tripp
7/9/98 GJ at 102-04, 115-16; Tripp 7/14/98 GJ at 11-12, 35-37.

358. 1506-DC-00000222 (5/21/96); 1506-DC-00000264 (7/5/96);
1506-DC-00000268 (7/6/96); 1506-DC-00000328 (10/22/96); 1506-DC-00000353
(12/2/96) (President's schedules).

359. Lewinsky 7/29/98 Int. at 3; Finerman 3/18/98 Depo. at 49-50; Tripp
7/9/98 GJ at 53, 61-62, 94. Along with talking with the President, Ms.
Lewinsky also contacted former White House colleagues for help returning to
work there. Lewinsky 8/3/98 Int. at 5.

360. T7 at 36.

361. T7 at 36-37.

362. Lewinsky 7/30/98 Int. at 14; Lewinsky 8/6/98 GJ at 21; Erbland 2/12/98
GJ at 30; Tripp 7/14/98 GJ at 4-6; 845-DC-00000020 (Tripp notes).

363. Lewinsky 8/20/98 GJ at 25.

364. Lewinsky 7/29/98 Int. at 3, 16; Tripp 7/9/98 GJ at 99-100;
845-DC-00000015 (Tripp notes). The President was at the Renaissance Hotel
in Washington from 8:40 to 9:25 p.m. that day. 1506-DC-00000188 - 189
(President's schedules).

365. V006-DC-00000534 (radio address guest list); 1222-DC-00000045
(itinerary); V006-DC-00001841 - 1847 (photographs); V006-DC-00003735 (photo
requests); V006-DC-00001865 (videotape).

366. Lewinsky 8/20/98 GJ at 28-31; Lewinsky 7/29/98 Int. at 16; Lewinsky
8/24/98 Int. at 6-7; V006-DC-00000682 (President's schedule for August 18);
V006-DC-00003735 (photo request from Ms. Lewinsky); MSL-DC-0000489 - 490
(event invitation); Tripp 7/9/98 GJ at 125-26; 845-DC-00000019 (Tripp
notes).

367. Lewinsky 8/20/98 GJ at 28-31. See also Lewinsky 7/30/98 Int. at 17.

368. Lewinsky 7/31/98 Int. at 7. Ms. Lewinsky thought that this might have
been October 23 or 24. Id. The President was at the Sheraton Washington
Hotel from 6:55 to 8:05 p.m. on October 23. 1506-DC-00000334 - 335
(President's schedule).

369. Newsweek, 8/10/98, cover photo.

370. Lewinsky 8/11/98 Int. at 2.

371. Lewinsky 8/20/98 GJ at 26-27.

372. Lewinsky 7/29/98 Int. at 5.

373. V006-DC-00000007 (WAVES records); V006-DC-00001855 - 1856 (photos from
the reception); V006-DC-00000391 (White House event attendance records).

374. MSL-DC-00001052 (spelling and punctuation corrected). See also
Lewinsky 2/1/98 Statement at 1-2; Tripp 7/14/98 GJ at 32-34. Ms. Lewinsky
did not send this letter. Lewinsky 8/4/98 Int. at 5.

375. Catherine Davis 3/17/98 GJ at 23-24, 27; Finerman 3/18/98 Depo. at 12;
Kassorla 8/28/98 Int. at 4; Raines 1/29/98 GJ at 31-32; Tripp 7/2/98 GJ at
41-43.

376. Tripp 7/14/98 GJ at 39-40;845-DC-00000022 (Tripp notes).

377. 833-DC-00001974 (email to Ms. Tripp).

378. Currie 5/7/98 GJ at 63.

379. Currie 5/6/98 GJ at 97-98.

380. Currie 5/6/98 GJ 14-15.

381. Currie 5/6/98 GJ at 52-53, 94-96.

382. 827-DC-00000002, 827-DC-00000018 (Ms. Lewinsky's WAVES records).

383. Currie 5/6/98 GJ at 57-58.

384. Currie 5/6/98 GJ at 84-85. In a later appearance before the grand
jury, Ms. Currie testified that she could no longer recall any occasions
when she came just to admit Ms. Lewinsky, but she could not rule it out.
Currie 7/22/98 GJ at 24.

385. Currie 1/27/98 GJ at 32-33. See also Currie 5/6/98 GJ at 98; Currie
7/22/98 GJ at 25-26, 41. Ms. Currie subsequently wavered on this point.
Currie 7/22/98 GJ at 14 ("[t]he President, for all intents and purposes, is
never alone"); id. at 15-16 (testifying that President and Ms. Lewinsky, in
study together, were "not alone" so long as Ms. Currie was at her desk);
id. at 25 (agreeing that Ms. Lewinsky and President were alone together);
id. at 131 ("I was always there. And I considered them not to be alone. . .
. I always thought that my presence there meant that they were not
alone."). Cf. Clinton 8/17/98 GJ at 134 ("there were a lot of times when we
were alone, but I never really thought we were").

386. Pape 5/18/98 Int. at 3-4.

387. Chinery 6/11/98 Depo. at 33.

388. Chinery 6/11/98 Depo. at 44-45; Chinery 7/23/98 GJ at 49.

389. Chinery 7/23/98 GJ at 8; Chinery 6/11/98 Depo. at 13-17. For other
Secret Service corroboration of Ms. Currie's role, see Chinery 7/23/98 GJ
at 49-50; Chinery 6/11/98 Depo. at 33, 37, 44; Garabito 7/30/98 GJ at
44-47; Shegogue 8/4/98 GJ at 11, 14-19, 24-27.

390. Lewinsky 8/20/98 GJ at 5. See also id. at 14; Lewinsky 8/19/98 Int. at
5.

391. Currie 5/6/98 GJ at 88-89. See also id. at 184; Currie 5/14/98 GJ at
78.

392. Currie 5/6/98 GJ at 88-89.

393. Currie 5/14/98 GJ at 72-74, 91; Currie 1/24/98 Int. at 3.

394. 837-DC-00000001; 837-DC-00000004; 837-DC-00000006; 837-DC-0000008;
837-DC-00000011; 837-DC-00000014; 837-DC-00000018.

395. Lewinsky 7/31/98 Int. at 13; Marcia Lewis 2/11/98 GJ at 28-30; T1 at
63-64.

396. Dragotta 8/13/98 GJ at 10-11; Janney 8/13/98 GJ at 7, 9-11, 14;
Niedzwiecki 7/30/98 GJ at 12-13, 20-21; Pape 8/5/98 GJ at 24; Keith
Williams 7/23/98 GJ at 14.

397. Currie 5/14/98 GJ at 72-73.

398. Currie 5/14/98 GJ at 73-74, 86-89; Currie 7/22/98 GJ at 51-52.

399. Currie 5/14/98 GJ at 88-89. See also id. at 91; Currie 7/22/98 GJ at
49-50 (testifying that she did not open sealed cards from Ms. Lewinsky to
President but "may have read" unsealed ones).

400. Currie 5/6/98 GJ at 88-89. See also Currie 5/14/98 GJ at 78.

401. "The President got everything anyone sent him." Currie 5/6/98 GJ at
129.

402. Currie 5/14/98 GJ at 143-45; Currie 1/24/98 Int. at 8.

403. Currie 5/6/98 GJ at 157-58.

404. Currie 5/6/98 GJ at 156; Currie 7/22/98 GJ at 42-43.

405. Currie 1/27/98 GJ at 63-64. See also Currie 5/6/98 GJ at 164; Currie
7/22/98 GJ at 31-33. According to Ms. Lewinsky, the President at one point
told her similarly that "if the two people who are involved [in a
relationship] say it didn't happen -- it didn't happen." Lewinsky 2/1/98
Statement at 10, ¶ 11.

406. Currie 5/14/98 GJ at 131-43. Ms. Currie testified: "I think . . . what
I was trying to do was allow the President to have personal and private
phone calls if he wanted to. And the appearance of any impropriety, I
didn't want to have it." Id. at 141.

407. Currie 7/22/98 GJ at 33-35.

408. Dragotta 8/13/98 GJ at 8-10; Pape 8/5/98 GJ at 17-18. Asked if she had
tried to persuade officers not to log in Ms. Lewinsky's visits, Ms. Currie
testified: "I hope I didn't. I can't imagine -- and I can't imagine that it
could be." Currie 7/22/98 GJ at 115. None of the Uniformed Division
officers interviewed by the OIC acknowledged having permitted Ms. Lewinsky
to enter the White House without proper clearance. However, as noted
elsewhere, there is clear evidence that Ms. Lewinsky was in the White House
on days for which no records show her entry or exit.

409. V006-DC-00003712 (2/24/97 message). Records show seven calls from Ms.
Lewinsky's line to Ms. Currie's line on December 5, 1997, for example, and
six calls the following day. 1216-DC-00000022.

410. Currie 5/6/98 GJ at 16-17, 20-21, 68-70, 73-74, 85-86; Currie 5/7/98
GJ at 8. See also 1037-DC-00000341 (email).

411. Currie 5/6/98 GJ at 73-74, 85-86. Ms. Currie later said that "I don't
want the impression of sneaking, but it's just that I brought her in
without anyone seeing her." Id. at 156. Ms. Lewinsky confirmed that Ms.
Currie helped her avoid Mr. Goodin and others. Lewinsky 8/20/98 GJ at 15;
Lewinsky 7/27/98 Int. at 4; Lewinsky 8/3/98 Int. at 5; Lewinsky 8/24/98
Int. at 7.

412. Currie 5/6/98 GJ at 84-85.

413. Lewinsky 7/31/98 Int. at 4.

414. Lewinsky 8/5/98 Int. at 3.

415. Lewinsky 7/31/98 Int. at 5. Ms. Lewinsky told confidants about Ms.
Currie's role. Catherine Davis 3/17/98 GJ at 17, 33, 37-38; Erbland 2/12/98
GJ at 43; Finerman 3/18/98 Depo. at 39-40; Raines 1/29/98 GJ at 49; Ungvari
3/19/98 GJ at 38-40; 1037-DC-00000337 - 338 (email from Ms. Lewinsky);
1037-DC-00000001 - 02 (card from Ms. Lewinsky).

416. Carbonetti 6/16/98 Int. at 2; Chinery 6/11/98 Depo. at 39-40; Janney
5/27/98 Int. at 2; LaDow 5/27/98 Int. at 3; Ludtke 6/5/98 Int. at 2; Pape
8/5/98 GJ at 23-24; Pape 5/18/98 Int. at 3-6.

417. Chinery 7/23/98 GJ at 50.

418. Pape 5/18/98 Int. at 5.

419. Washington Post, 2/14/97, "Love Notes" at 44 (824-DC-00000013 - 14).
See also 1078-DC-00000002. A copy of the ad was found in the box of gifts
and other items that Ms. Lewinsky, after being subpoenaed in the Jones
case, gave Ms. Currie for safekeeping. 824-DC-00000013 - 14; Lewinsky
8/20/98 GJ at 71-72. Ms. Lewinsky told several people about the ad.
Catherine Davis 3/17/98 GJ at 28; Finerman 3/18/98 Depo. at 22-23; Marcia
Lewis 2/10/98 GJ at 59-61; Raines 1/29/98 GJ at 109. In email on February
13, she said she planned to check her telephone messages from London (where
she would be on Valentine's Day) "in the hopes that the creep will call and
say 'Thank you for my love note. I love you. Will you run away with me?'
What do ya think the likelihood of that happening is?" 833-DC-00001934. On
February 19, she wrote in an email that the President had not left any
message for her on Valentine's Day. 833-DC-00009446.

420. 827-DC-00000018 (Epass records); Kessinger 2/24/98 Int. at 2.

421. 833-DC-00001906 (email from Ms. Lewinsky to Ms. Tripp).

422. V006-DC-00003712.

423. V006-DC-00003720 (radio address attendance list).

424. 827-DC-00000018; V006-DC-00000008; V006-DC-00001796.

425. 1222-DC-00000234; 968-DC-00000073.

426. 968-DC-00003506.

427. Lewinsky 8/26/98 Depo. at 45-46, 48-49; Lewinsky 8/6/98 GJ at 30.

428. Lewinsky 8/6/98 GJ at 45-46.

429. Lewinsky 8/26/98 Depo. at 46.

430. Lewinsky 8/6/98 GJ at 30.

431. Lewinsky 8/6/98 GJ at 30-31, 46-47; Lewinsky 7/30/98 Int. at 15;
Lewinsky 7/31/98 Int. at 5. Mr. Goodin and Ms. Currie confirmed that Ms.
Lewinsky stayed behind and talked with the President after the radio
address. Currie 1/27/98 GJ at 34; Goodin 2/17/98 GJ at 52, 55. Mr. Goodin
testified that he approached the President and "basically offer[ed] to
chase her away because I didn't know if that was a good use of his time,"
but the President replied that "she's a friend of a political supporter."
Goodin 2/17/98 GJ at 56. Nancy Hernreich, who was not present at the radio
address, testified that Mr. Goodin told her about Ms. Lewinsky's presence
there on the following work day. Hernreich 2/26/98 GJ at 5-9.

432. Currie 7/22/98 GJ at 130-31; Currie 1/27/98 GJ at 34-35; Lewinsky
8/6/98 GJ at 31; Lewinsky 7/30/98 Int. at 15.

433. Currie 7/22/98 GJ at 131. Ms. Currie also maintained that the
President and Ms. Lewinsky were "[n]ever out of eyesight." Id. at 135. The
President, however, acknowledged "inappropriate intimate contact" with Ms.
Lewinsky on February 28 and testified that, to the best of his knowledge,
Ms. Currie never witnessed any such encounters between himself and Ms.
Lewinsky. Clinton 8/17/98 GJ at 10, 53-54.

434. Lewinsky 8/26/98 Depo. at 46-47.

435. Lewinsky 8/26/98 Depo. at 46-47.

436. Lewinsky 8/26/98 Depo. at 47; Lewinsky 8/6/98 GJ at 31. Ms. Currie
testified that the President later asked her, "Did Monica show you the hat
pin I gave her?" Currie 5/6/98 GJ at 142.

437. Lewinsky 8/6/98 GJ at 156. See also Lewinsky 8/20/98 GJ at 72;
Lewinsky 8/26/98 Depo. at 47; Currie 5/6/98 GJ at 101-102; Catherine Davis
3/17/98 GJ 30-31; Erbland 2/12/98 GJ at 40-41; Finerman 3/18/98 Depo. at
15-16; Marcia Lewis 2/10/98 GJ at 51-52; Raines 1/29/98 GJ at 53-55.

A draft of Ms. Lewinsky's thank-you note (to "Dear Mr. P") was found in her
apartment. It says in part:

All of my life, everyone has always said that I am a difficult person for
whom to shop, and yet, you managed to choose two absolutely perfect
presents! A little phrase (with only eight letters) like "thank you" simply
cannot begin to express what I feel for what you have given me. Art &
poetry are gifts to my soul!

I just love the hat pin. It is vibrant, unique and a beautiful piece of
art. My only hope is that I have a hat fit to adorn it (ahhh, I see another
excuse to go shopping)! I know that I am bound to receive compliments on
it.

I have only read excerpts from "Leaves of Grass" before -- never in its
entirety or in such a beautifully bound edition. Like Shakespeare,
Whitman's writings are so timeless. I find solace in works from the past
that remain profound and somehow always poignant. Whitman is so rich that
one must read him like one tastes a fine wine or good cigar -- take it in,
roll it in your mouth, and savor it!

I hope you know how very grateful I am for these gifts, especially your
gift of friendship. I will treasure them all . . . always.

MSL-DC-00000621 - 622 (emphasis in original) (ellipsis in original). Ms.
Lewinsky said she sent a version of this letter to the President and
enclosed a necktie. Lewinsky 8/4/98 Int. at 5.

438. Lewinsky 8/24/98 Int. at 7; Finerman 3/18/98 Depo. at 22; Raines
1/29/98 GJ at 109.

439. Lewinsky 8/26/98 Depo. at 47-48. See also Lewinsky 8/6/98 GJ at 31,
38-39.

440. Lewinsky 8/26/98 Depo. at 47-48. See also Lewinsky 8/6/98 GJ at 31,
38-39.

441. Lewinsky 7/30/98 Int. at 15.

442. Lewinsky 8/26/98 Depo. at 48.

443. Lewinsky 8/6/98 GJ at 32, 39-40. Ms. Lewinsky testified that she did
not keep the soiled dress as a souvenir. She said she does not ordinarily
clean her clothes until she is ready to wear them again. "I was going to
clean it. I was going to wear it again." Lewinsky 8/6/98 GJ at 41. She also
testified that she was not certain that the stains were semen. She had
dined out after the radio address, "[s]o it could be spinach dip or
something." Lewinsky 8/6/98 GJ at 40. See also Lewinsky 7/29/98 Int. at 17.

444. FBI Lab Reports, 8/6/98, 8/17/98.

445. Clinton 8/17/98 GJ at 55.

446. Clinton 8/17/98 GJ at 138.

447. Clinton 8/17/98 GJ at 136-37.

448. V006-DC-00000008 (WAVES records); V006-DC-00001792 (WAVES request).
Phone records indicate that Ms. Lewinsky called Ms. Currie for one minute
at 8:37 a.m. that day. 1014-DC-00000022.

449. 968-DC-00000236 (presidential diary); V006-DC-00002130 (movement log);
968-DC-00003510 (phone log). Mrs. Clinton was in Africa. 968-DC-00003843
(schedule).

450. Lewinsky 7/30/98 Int. at 16; Lewinsky 8/20/98 GJ at 67-69; Lewinsky
8/24/98 Int. at 7.

451. Lewinsky 8/26/98 Depo. at 49.

452. Lewinsky 8/26/98 Depo. at 50.

453. Lewinsky 8/26/98 Depo. at 50.

454. Lewinsky 8/26/98 Depo. at 51. See also Lewinsky 8/20/98 GJ at 68-69;
Lewinsky 7/30/98 Int. at 16. Ms. Lewinsky testified that their genitals
only briefly touched: "[W]e sort of had tried to do that, but because he's
so tall and he couldn't bend because of his knee, it didn't really work."
Lewinsky 8/26/98 Depo. at 51.

455. Lewinsky 8/20/98 GJ at 68-69; Lewinsky 8/26/98 Depo. at 50; Lewinsky
7/30/98 Int. at 16.

456. Lewinsky 7/30/98 Int. at 16.

457. Clinton 8/17/98 GJ at 10.

458. Clinton 8/17/98 GJ at 54-55, 137-38.

459. Lewinsky 8/6/98 GJ at 66; Lewinsky 7/27/98 Int. at 5; Lewinsky 7/31/98
Int. at 8; Lewinsky 2/1/98 Statement at 1-2; MSL-DC-00001052; T1 at 38. Mr.
Nash said he had never heard of Ms. Lewinsky before January 1998. Nash
3/19/98 Int. at 1; Nash 9/2/98 Int. at 1.

460. Lewinsky 8/6/98 GJ at 67.

461. Lewinsky 8/6/98 GJ at 66-67; Lewinsky 7/27/98 Int. at 5; Lewinsky
8/5/98 Int. at 2.

462. Lewinsky 8/6/98 GJ at 86-87.

463. Lewinsky 8/26/98 Depo. at 62.

464. Clinton 8/17/98 GJ at 113-14. Later the President said: "I didn't
order her to be hired at the White House. I could have done so. I wouldn't
do it." Id. at 124. But see Scott 3/19/98 GJ at 76 ("When Mr. Bowles came
in, one of the agreements that I think he got from the President was that
he would control the hiring within the White House and that no Assistant to
the President would be forced to take people within their shop that they
did not want and were not qualified.").

465. Lewinsky 8/6/98 GJ at 97-99; Lewinsky 7/27/98 Int. at 3.

466. Lewinsky 8/6/98 GJ at 87; Lewinsky 7/27/98 Int. at 3.

467. Lewinsky 8/6/98 GJ at 98-99; Lewinsky 7/27/98 Int. at 3. See also
Lewinsky 9/3/98 Int. at 1.

468. Kaye 5/21/98 GJ at 103-108. Ms. Finerman testified that she did have a
conversation along these lines with Mr. Kaye. Finerman 3/18/98 Depo. at
52-57. Mr. Kaye testified that he could not recall having discussed Ms.
Lewinsky with Ms. Scott. Kaye 5/21/98 GJ at 44. Ms. Scott testified that
she could not recall talking to Mr. Kaye about Ms. Lewinsky in this period,
or talking to him about phone calls between Ms. Lewinsky and the President
at any time. Scott 3/31/98 GJ at 53.

469. 827-DC-00000018 (Epass records).

470. 1222-DC-00000242.

471. 968-DC-00003533.

472. Lewinsky 8/4/98 Int. at 2-3.

473. Lewinsky 8/6/98 GJ at 24-25, 101.

474. Lewinsky 8/4/98 Int. at 2; Lewinsky 7/31/98 Int. at 16.

475. Lewinsky 8/4/98 Int. at 2-3.

476. Lewinsky 8/4/98 Int. at 3. Ms. Lewinsky later told confidants about
the May 24 break-up. Catherine Davis 3/17/98 GJ at 133-35; Erbland 2/12/98
GJ at 46-47; Kassorla 8/28/98 Int. at 4; Raines 1/29/98 GJ at 58-59; Tripp
7/14/98 GJ at 78-84; Ungvari 3/19/98 GJ at 80. Dr. Kassorla, Ms. Lewinsky's
therapist, told Ms. Lewinsky that the President's statement sounded
rehearsed and insincere. Kassorla 8/28/98 Int. at 4.

A fragment of a deleted file recovered from Ms. Lewinsky's home computer
apparently refers to the President's May 24 announcement:

. . . cannot do anything but accept that. However, I also cannot ignore
what we have shared together. I don't care what you say, but if you were
100% fulfilled in your marriage I never would have seen that raw, intense
sexuality that I saw a few times -- watching your mouth on my breast or
looking in your eyes while you explored the depth of my sex. Instead, it
would have been a routine encounter void of anything but a sexual release.
I do not want you to breach your moral standard . . . .

MSL-55-DC-0094; MSL-55-DC-0124 (spelling and punctuation corrected).

477. Lewinsky 8/6/98 GJ at 25. See also Lewinsky 7/27/98 Int. at 3
(birthday kiss 8/16/97; Christmas kiss 12/28/97); id. at 7 (President told
her that Christmas kiss was permissible). Ms. Lewinsky tried to initiate
genital contact with the President on August 16, 1997, but he rebuffed her.
Lewinsky 8/20/98 GJ at 70.

478. Clinton v. Jones, 117 S. Ct. 1636 (1997).

479. Currie 5/6/98 GJ at 31-33; Currie 5/7/98 GJ at 44, 68; Currie 5/14/98
GJ at 6-8, 148. Ms. Currie was uncertain when this occurred. Currie 5/6/98
GJ at 31.

480. Currie 5/6/98 GJ at 45; Currie 5/14/98 GJ at 146.

481. Currie 5/14/98 GJ at 146.

482. Currie GJ 5/14/98 at 121; Currie GJ 5/6/98 at 13, 81.

483. Currie 5/7/98 GJ at 43-44.

484. Currie 5/7/98 GJ at 68.

485. Currie 5/7/98 GJ at 69. Contrary to Ms. Currie's testimony, Ms. Scott
testified that the President never asked her to help Ms. Lewinsky, though
they may have discussed it. In

Ms. Scott's account, she met with Ms. Lewinsky as a favor to Ms. Currie.
Scott 3/19/98 GJ at 20, 32, 37, 78-79, 84-85; Scott 3/26/98 GJ at 13, 15;
Scott 3/31/98 GJ at 43-44. For his part, the President testified that he
talked with Ms. Scott about bringing Ms. Lewinsky back to work at the White
House, though he did not order her to hire Ms. Lewinsky. Clinton 8/17/98 GJ
at 130.

486. Lewinsky 8/6/98 GJ at 67; Lewinsky 8/24/98 Int. at 7. Ms. Lewinsky
also tried to get a White House job through other avenues. She applied for
a position at the National Security Council and had interviews there on May
1 and June 11. Lewinsky 7/27/98 Int. at 5; Bailey 5/26/98 GJ at 23; Dimel
2/18/98 Int. at 1; Friedrich 7/17/98 Int. at 1; Stott 2/27/98 Int. at 2;
V006-DC-00000008 (WAVES records); 827-DC-00000018 (Epass records);
833-DC-00001876 (Tripp email regarding a job announcement);
V006-DC-00000221 - 224 (Dimel documents). She was not chosen for the job.
V006-DC-00000223 - 224 (Dimel letter). She also pursued a job in the White
House press office. Lewinsky 7/27/98 Int. at 5. At one point Ms. Lewinsky
told the President that she had applied for these jobs, and he responded
that he needed to know in advance if he was to help her. Lewinsky 7/27/98
Int. at 5.

487. 827-DC-00000018 (Epass records); V006-DC-00000008 (WAVES records);
Scott GJ 3/19/98 at 17.

488. 1037-DC-00000265- 266 (spelling and punctuation corrected). See also
Finerman 3/18/98 Depo. at 50-51 (recounting this meeting); Tripp 7/14/98 GJ
at 89-91 (recounting this meeting).

489. Scott 3/19/98 GJ at 52. See also Scott 3/26/98 GJ at 16-17.

490. Scott 3/19/98 GJ at 74.

491. Scott 3/19/98 GJ at 87.

492. 833-DC-00001070.

493. Currie 5/7/98 GJ at 35; see id. at 39.

494. MSL-DC-00001176 - 1177. A revised version of the letter was also found
in Ms. Lewinsky's apartment. MSL-DC-00001192. Consistent with a statement
in the draft, Ms. Scott testified that "I don't hear about White House
jobs." Scott 3/19/98 GJ at 90. Ms. Scott also testified that she recalled
only a short thank-you note after her June 16 meeting with Ms. Lewinsky,
though she did receive a "real pissy letter" from Ms. Lewinsky at some
point, which she threw away. Scott 3/19/98 GJ at 77; Scott 3/26/98 GJ at
18.

495. MSL-DC-00001227 (emphasis in original). Ms. Lewinsky sent a version of
the note. Lewinsky 8/4/98 Int. at 6. Records indicate that Ms. Lewinsky was
in Madrid the following week and in Los Angeles later in the month.
MSL-DC-00001221; 852-DC-00000035; 929-DC-00000056; 852-DC-00000037.

496. 1037-DC-00000103, 1037-DC-00000280, 1037-DC-00000296 (email from
Catherine Davis to Ms. Lewinsky referring to "[y]our idea about working in
another city or country") (multiple copies of same message).

497. Lewinsky 7/29/98 Int. at 8.

498. Lewinsky 8/6/98 GJ at 68, 87; Lewinsky 7/29/98 Int. at 7-8; Lewinsky
8/11/98 Int. at 6.

499. Lewinsky 8/6/98 GJ at 68, 87. See also Lewinsky 7/29/98 Int. at 7-8;
Lewinsky 8/11/98 Int. at 6.

500. Lewinsky 8/6/98 GJ at 68-69, 87-89. See also Lewinsky 8/26/98 Depo. at
62-63.

501. Lewinsky 8/6/98 GJ at 68, 87; Lewinsky 7/29/98 Int. at 7-8; Lewinsky
8/11/98 Int. at 6.

502. Lewinsky 7/29/98 Int. at 8; Lewinsky 8/13/98 Int. at 1. Ms. Lewinsky
said she thought of the United Nations because a former Pentagon colleague
worked there and liked it. Lewinsky 8/13/98 Int. at 1.

503. Clinton 8/17/98 GJ at 124.

504. Lewinsky 8/6/98 GJ at 69. See also Lewinsky 7/29/98 Int. at 8.

505. Lewinsky 8/6/98 GJ at 69. See also Lewinsky 7/29/98 Int. at 7.

506. 827-DC-00000018.

507. V006-DC-00002140; V006-DC-00002214.

508. Lewinsky 8/6/98 GJ at 75. See also Lewinsky 7/29/98 Int. at 8;
Lewinsky 8/4/98 Int. at 4.

509. Lewinsky 7/29/98 Int. at 8-9.

510. Lewinsky 8/26/98 Depo. at 54-55; Lewinsky 7/27/98 Int. at 3.

511. Lewinsky 8/26/98 Depo. at 55-56.

512. Lewinsky 8/26/98 Depo. at 56-57. See also Lewinsky 7/28/98 Int. at 6.

513. Lewinsky 8/26/98 Depo. at 56-57. See also Catherine Davis 3/17/98 GJ
at 180; Tripp 7/7/98 GJ at 55-56; 845-DC-00000193 (Tripp notes).

514. Lewinsky 8/6/98 GJ at 72. See also Lewinsky 8/4/98 Int. at 4.

515. Lewinsky 8/6/98 GJ at 70-71; Tripp 7/14/98 GJ at 107-116.

516. Lewinsky GJ 8/6/98 at 72, 77; Lewinsky 302 7/29/98 at 7. According to
Ms. Tripp, she had tried to alert Mr. Lindsey about the contact from Mr.
Isikoff, but Mr. Lindsey, with whom she had worked at the White House, did
not return her calls and pages. Ms. Tripp testified that she tried to reach
him because "he was one of the protectors" of the President. Tripp 7/14/98
GJ at 111. Mr. Lindsey testified that he returned a page from Ms. Tripp,
but not until July or August. Lindsey 2/18/98 GJ at 132-33.

517. Lewinsky 8/6/98 GJ at 71.

518. Lewinsky 8/6/98 GJ at 73-74; Lewinsky 7/29/98 Int. at 7.

519. Lewinsky 7/29/98 Int. at 7; Lewinsky 8/11/98 Int. at 5.

520. Lewinsky 8/6/98 GJ at 73; Lewinsky 7/29/98 Int. at 7.

521. 968-DC-00003546.

522. Lewinsky 8/6/98 GJ at 75.

523. 827-DC-00000018; see also Steven Pape 5/18/98 Depo. at 3.

524. V006-DC-00002142 (movement logs).

525. Lewinsky 8/6/98 GJ at 75-76; Lewinsky 7/29/98 Int. at 9. Ms. Currie
did not recall Ms. Lewinsky's visit of July 14. Currie 7/22/98 GJ at 81.

526. Lewinsky 8/6/98 GJ at 76.

527. 1222-DC-00000251 (movement logs).

528. Lewinsky 8/6/98 GJ at 76. The President was referring to the Drudge
Report, carried on the Internet, which had reported on July 4 (the day of
Ms. Lewinsky's previous White House visit) that Michael Isikoff of Newsweek
was "hot on the trail" of a story involving "a federal employee sexually
propositioned by the President on federal property." Drudge Report 7/4/97.
See also Washington Post, 8/11/97 at D1 (on Drudge Report's scoop of
Newsweek).

529. Lewinsky 8/6/98 GJ at 76-77.

530. Lewinsky 8/6/98 GJ at 77.

531. Lewinsky 8/6/98 GJ at 77-78; Tripp 7/16/98 GJ at 12.

532. Lewinsky 8/6/98 GJ at 78; Lewinsky 7/27/98 Int. at 3; Lewinsky 7/29/98
Int. at 10; Tripp 7/14/98 GJ at 117-19; Tripp 7/16/98 GJ at 9.

533. Lewinsky 8/6/98 GJ at 78-79.

534. 968-DC-00003550.

535. Lewinsky 8/6/98 GJ at 79; Tripp 7/16/98 at 12.

536. Lewinsky 8/6/98 GJ at 79-80.

537. Lewinsky 7/29/98 Int. at 10-11. Subsequently, Ms. Tripp did call Mr.
Lindsey. He urged her to contact Robert Bennett, but she never did so.
Lindsey 3/12/98 GJ at 3, 13; Lindsey 2/18/98 GJ at 132-40; Tripp 7/16/98 GJ
at 12-14, 54-67, 75-80; Lewinsky 7/29/98 Int. at 11; T29 at 16;
880-DC-0000002 - 8.

538. Scott 3/19/98 GJ at 64-72.

539. Lewinsky 7/31/98 Int. at 9.

540. Lewinsky 2/1/98 Statement at 2.

541. Scott 3/26/98 GJ at 18-21; Currie 5/7/98 GJ at 68. Ms. Lewinsky also
conferred with her supervisor, Kenneth Bacon, about being detailed back to
the White House. He gave his approval and sent a letter recommending her.
Bailey 2/6/98 Int. at 3; Bacon 2/26/98 Int. at 2-3; 1012-DC-00000001;
MSL-DC-00001230.

542. Scott 3/19/98 GJ at 78-79; Scott 3/26/98 GJ at 13-15; Scott 3/31/98 GJ
at 43-44; Currie 5/7/98 GJ at 68.

543. 827-DC-00000018 (Epass records); V006-DC-00000008 (WAVES records);
V006-DC-00001770 (WAVES request).

544. 1222-DC-00000254 (movement logs).

545. 968-DC-00003556 (phone logs).

546. Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7; Lewinsky 8/24/98 Int. at 6.

547. Newsweek, 8/11/97 at 30.

548. 845-DC-00000190 (letter); Tripp 7/16/98 GJ at 85-88.

549. T30 at 166. Ms. Tripp responded: "Oh, God. He thinks I screwed him in
the article. I'm dead." Id.

550. V006-DC-00000008 (WAVES records).

551. V006-DC-00002146 (movement logs). Secret Service Officer Steven Pape
testified about Ms. Lewinsky's August 16 visit. When Ms. Lewinsky entered
the complex through the Southwest Gate, Officer Pape, who was familiar with
Ms. Lewinsky's visits, predicted to another officer that the President
would move to the Oval Office shortly. Officer Pape's prediction proved
accurate: The President moved to the Oval Office, according to records, 18
minutes after Ms. Lewinsky entered the White House. Pape 8/5/98 GJ at
20-24; Myrick 8/13/98 GJ at 5-9; V006-DC-00002146 (movement logs);
V006-DC-00002095 (movement logs); V006-DC-00002147 (movement logs). See
also Shegogue 8/4/98 GJ at 10-11, 14-15, 17-20 (Secret Service officer
recalling that Ms. Currie escorted Ms. Lewinsky into West Wing the day
before President left for Martha's Vineyard).

552. 968-DC-00003558.

553. 968-DC-00002947.

554. Lewinsky 8/26/98 Depo. at 52. See also Lewinsky 8/20/98 GJ at 70.

555. Lewinsky 8/20/98 GJ at 70; Lewinsky 8/26/98 Depo. at 51-53.

556. Lewinsky 8/26/98 Depo. at 52.

557. DB-DC-00000022 (note dated 11/12/97). Ms. Lewinsky said that she sent
this or a similar note to the President. Lewinsky 7/31/98 Int. at 2. See
also 1037-DC-00000583 (email to Catherine Davis).

558. 1051-DC-00000003 (Pentagon phone records).

559. 1037-DC-00000086 - 87, 1037-DC-00000167, 1037-DC-00000255 - 256,
1037-DC-00000258 - 259 (email to Catherine Davis); 1318-DC-00000001 (card
to Dale Young).

560. 1037-DC-00000086 - 87, 1037-DC-00000167, 1037-DC-00000255 - 256,
1037-DC-00000258 - 259 (email to Catherine Davis) (spelling and punctuation
corrected).

561. Scott 3/26/98 GJ at 142.

562. Lewinsky 8/4/98 Int. at 5.

563. MSL-DC-00001052 (spelling and punctuation corrected).

564. Lewinsky 8/3/98 Int. at 6-7; Lewinsky 8/11/98 Int. at 5. See also
1037-DC-00000168 (email recounting episode). In mid or late September,
according to Ms. Lewinsky, Ms. Currie told Ms. Lewinsky that she had spoken
with Mr. Podesta. Lewinsky 7/31/98 Int. at 9; Lewinsky 8/13/98 Int. at 2;
Lewinsky 2/1/98 Statement at 2. (Ms. Lewinsky thought that the President
was having Ms. Currie do the "legwork" of getting her a job out of concern
about appearances. Lewinsky 8/13/98 Int. at 3.) Mr. Podesta testified that
he told Ms. Currie to have Ms. Lewinsky call him. Podesta 2/5/98 GJ at 35;
Podesta 6/16/98 GJ at 12-19. Ms. Currie testified that she does not
remember getting that response from Mr. Podesta, and, if she had gotten it,
she would have passed it on to Ms. Lewinsky. Currie 5/14/98 GJ at 149-51.
According to Ms. Lewinsky, Ms. Currie mentioned Mr. Podesta to her in
September 1997, but never told her to call him. Lewinsky 8/24/98 Int. at 7.
Subsequently, Ms. Currie asked Mr. Podesta to help Ms. Lewinsky get a New
York job. Lewinsky 2/1/98 Statement at 2-3; Podesta 2/5/98 GJ at 40-43;
Podesta 6/16/98 GJ at 13.

565. 1037-DC-00000038 - 040; 1037-DC-00000167 - 169 (email to Catherine
Davis).

566. Lewinsky 8/6/98 GJ at27-28 & Ex. ML-7.

567. 1037-DC-00000038, 1037-DC-00000040, 1037-DC-00000167 - 169. Ms.
Lewinsky told several people about the gifts. Catherine Davis 3/17/98 GJ at
31-32, 109-111; Erbland 2/12/98 GJ at 39-42; Finerman 3/18/98 Depo. at
14-15; Raines 1/29/98 GJ at 53-55; Tripp 7/16/98 GJ at 119-120;
845-DC-00000193 (Tripp notes). According to the President and Ms. Currie,
he gave the Black Dog items to Ms. Currie to distribute as she wished; he
did not bring them specifically for Ms. Lewinsky. Clinton 1/17/98 Depo. at
75-76; Currie 5/7/98 GJ at 73-78. Ms. Currie acknowledged, though, that in
presenting the items to Ms. Lewinsky, she might have implied that President
Clinton had gotten them especially for her. Currie 5/7/98 GJ at 78.

568. Lewinsky 7/29/98 Int. at 16; Lewinsky 8/4/98 Int. at 5.

569. MSL-DC-00001050. Beneath the text of the document, at the bottom of
the page, Ms. Lewinsky added: "JUST A REMINDER TO THROW THIS AWAY AND NOT
SEND IT BACK TO THE STAFF SECRETARY!" Id. The statement that Ms. Lewinsky
and the President had not spent time together in six weeks evidently refers
to her August 16 visit, before his vacation.

570. Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7. On September 30, the President
signed, under penalty of perjury, interrogatory responses in the sexual
harassment case, answering Ms. Jones's allegations against him.
V002-DC-00000008 - 15.

571. Lewinsky 8/13/98 Int. at 1. In email, Ms. Lewinsky indicated that it
was Ms. Currie who told her that the President was going to talk to the
Chief of Staff. 1037-DC-00000168.

572. Bowles 4/2/98 GJ at 12, 65-73.

573. Bowles 4/2/98 GJ at 67-68.

574. Bowles 4/2/98 GJ at 70, 74-75. Mr. Bowles placed this incident in late
summer or early fall of 1997. Bowles 4/2/98 GJ at 65-66. Mr. Podesta's
account largely matches Mr. Bowles's, except that Mr. Podesta placed the
incident in late spring or summer of 1997; he understood that Ms. Lewinsky
wanted a job in the White House or an agency; and he recalled being told by
Mr. Bowles that Ms. Lewinsky, according to the President, "thought that she
hadn't been treated fairly" in being transferred to the Pentagon. Podesta
2/5/98 GJ at 21-22.

575. Lewinsky 8/6/98 GJ at 102. See also Lewinsky GJ 8/6/98 at 102;
Lewinsky 7/29/98 Int. at 13; Lewinsky 7/31/98 Int. at 9; Tripp 7/28/98 GJ
at 110-111, 125-26. Ms. Tripp's friend Kate Friedrich, however, has denied
having made the remarks that Ms. Tripp attributed to her. Friedrich 7/17/98
Int. at 1.

576. Lewinsky 7/31/98 Int. at 10.

577. Lewinsky 8/13/98 Int. at 1.

578. MSL-55-DC-0178 (spelling and punctuation corrected).

579. Lewinsky 8/4/98 Int. at 2-3.

580. T1 at 28.

581. T1 at 24.

582. T1 at 61.

583. T1 at 25.

584. T13 at 19.

585. MSL-55-DC-00000001 (letter); 837-DC-00000001 (courier receipts); T1 at
97.

586. MSL-55-DC-00000001.

587. Lewinsky 8/6/98 GJ at 103; Lewinsky 7/31/98 Int. at 10. See also
Lewinsky 7/29/98 Int. at 6; Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7.

588. T13 at 20.

589. T8 at 30. See also Lewinsky 7/31/98 Int. at 10. See also
MSL-55-DC-0177 (draft letter from Ms. Lewinsky to the President referring
to this remark); DB-DC-00000017 (another draft of same letter).

590. T8 at 30.

591. T8 at 30.

592. T8 at 33.

593. Lewinsky 7/31/98 Int. at 10; Lewinsky 7/27/98 Int. at 5.

594. Lewinsky 7/31/98 Int. at 10.

595. Lewinsky 7/31/98 Int. at 10.

596. Lewinsky 7/31/98 Int. at 11.

597. 827-DC-00000018 (Epass records). Ms. Lewinsky's aunt, Debra Finerman,
wrote in a note that "Monica was called by Betty to come at 9:30 this a.m."
MSL-DC-00000456 (document found in Ms. Lewinsky's apartment in the course
of a consensual search on January 22, 1998).

598. 952-DC-00000060 (movement logs).

599. Lewinsky 8/6/98 GJ at 27-28 & Exh. ML-7.

600. Lewinsky 8/6/98 GJ at 104; Lewinsky 8/13/98 Int. at 2-3; T2 at 5.

601. Lewinsky 8/6/98 GJ at 104; Lewinsky 7/31/98 Int. at 11-12. Ms.
Lewinsky was not certain whether it was during the October 11 visit or
their October 10 phone conversation that she first asked the President to
speak to Mr. Jordan on her behalf. Lewinsky 8/6/98 GJ at 104.

602. Lewinsky 8/6/98 GJ at 104; Lewinsky 7/31/98 Int. at 11-12. Ms.
Lewinsky later said that the President assured her that he would call her
and give "a report." T13 at 17-18.

603. T2 at 14. In the grand jury, Ms. Currie was shown a transcript of this
recorded conversation and acknowledged that the meeting described by Ms.
Lewinsky "probably happened." Currie 5/6/98 GJ at 187.

604. T2 at 14. Although it is unclear whether the President spoke with Mr.
Bowles about a recommendation for Ms. Lewinsky in October, there is
evidence he did so on January 13, 1998. See infra at Section XIII.H.

605. T2 at 10-11.

606. T2 at 11-12.

607. Lewinsky 7/31/98 Int. at 12. Ms. Lewinsky produced a draft of this
document to the OIC on July 31, 1998. Lewinsky 7/31/98 Int. at 3. See also
Lewinsky 8/13/98 Int. at 3.

608. DB-DC-00000027 (punctuation corrected) (emphasis in original). Ms.
Lewinsky produced a draft of this document to the OIC on July 31, 1998.
Lewinsky 7/31/98 GJ at 3.

609. DB-DC-00000027. Ms. Lewinsky also indicated that she would consider a
job at one of the networks; she mentioned "Kaplan," and added that "CNN has
a NY office." DB-DC-00000027. In a recorded conversation, Ms. Lewinsky said
that she had told the President about her interest in television during
their October 11 meeting. The President had responded, "The only one I know
in a network is Kaplan, . . . but his job is in Atlanta." T2 at 6. See also
Lewinsky 7/31/98 Int. at 11. CNN President Rick Kaplan is a friend of the
President.

610. DB-DC-00000027.

611. T7 at 26.

612. T7 at 30.

613. T2 at 21-27. See also Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7; Lewinsky
8/11/98 Int. at 4.

614. T2 at 23. In her description, the card was "kind of cartoony" and
said: "This is a test of the emergency insanity system." T2 at 21. See also
Lewinsky 8/13/98 Int at 3.

615. T2 at 26-27.

616. T2 at 27-30. Ms. Lewinsky asked Ms. Currie to leave the packet under
the President's desk. T2 at 3. In a recorded conversation on October 17,
Ms. Lewinsky indicated that Ms. Currie had received the package. T13 at 33.

617. Lewinsky 8/13/98 Int. at 4; Lewinsky 8/26/98 Depo. at 61-63.

618. Podesta 2/5/98 GJ at 40-41. See also Lewinsky 7/31/98 Int. at 10. As
previously discussed, Ms. Currie had earlier asked Mr. Podesta to help Ms.
Lewinsky obtain a White House job.

619. Podesta 2/5/98 GJ at 40-45; Richardson 4/30/98 Depo. at 28. On Sunday,
October 12, 1997, the President traveled to Latin America for one week.
United States President, Weekly Compilations of Presidential Documents at
1608, 1609, 1653. On that trip, the President was accompanied by, among
others, then-U.N. Ambassador William Richardson and the Deputy Chief of
Staff, John Podesta. Richardson 4/30/98 Depo. at 28-29; Podesta 2/5/98 GJ
at 44. Ambassador Richardson recalled that Mr. Podesta had first made the
request prior to the trip to Latin America. Richardson 4/30/98 Depo. at 28.

620. Podesta 2/5/98 GJ at 45; Richardson 4/30/98 Depo. at 32.

621. Richardson 4/30/98 Depo. at 160-61; Clinton 1/17/98 Depo. at 73.

622. Richardson 4/30/98 Depo. at 26.

623. Watkins 5/27/98 Depo. at 11-12, 18.

624. Podesta 2/5/98 GJ at 46.

625. 828-DC-00000012 (faxed copy of Ms. Lewinsky's resume, produced by the
U.N.); Currie 5/6/98 GJ at 174.

626. 828-DC-00000004 (U.N. phone records).

627. Lewinsky 8/13/98 Int. at 3.

628. Lewinsky 8/26/98 Depo. at 63-64. See also Lewinsky 8/26/98 Depo. at
63-64; Lewinsky 7/31/98 Int. at 12; Lewinsky 7/27/98 Int. at 5.

629. Lewinsky 7/27/98 Int. at 5.

630. Richardson 4/30/98 Depo. at 47-48; Watkins 5/27/98 Depo. at 27-29. Ms.
Watkins further testified that she often placed calls from the Ambassador's
line. Watkins 5/27/98 Depo. at 37-38.

631. Lewinsky 8/13/98 Int. at 3-4.

632. Lewinsky 8/13/98 Int. at 4.

633. Lewinsky 8/13/98 Int. at 4. See also Lewinsky 7/31/98 Int. at 12.

634. Lewinsky 8/26/98 Depo. at 64-65; Lewinsky 7/31/98 Int. at 13.

635. Lewinsky 8/26/98 Depo. at 65. Ms. Lewinsky wrote an email to her
friend Catherine Allday Davis: "It was nice; the big creep called Thursday
night to give me a pep talk because I was so afraid I'd sound like an
idiot." 1037-DC-00000022 (spelling corrected).

636. Lewinsky 7/31/98 Int. at 13. See also Lewinsky 8/26/98 Depo. at 65.

637. Clinton 1/17/98 Depo. at 74.

638. 828-DC-00000023 (Ambassador Richardson's diary reflecting 7:30 a.m.
meeting with Monica Lewinsky). See also Ambassador Richardson 4/30/98 Depo.
at 66-68; Sutphen 5/27/98 Depo. at 7; Cooper 1/27/98 Int. at 1-2; Lewinsky
7/31/98 Int. at 13-14. After meeting with Ms. Lewinsky, Ambassador
Richardson spent the remainder of the day meeting individually with
Senators and Members of Congress. 828-DC-00000023 (Ambassador Richardson's
itinerary for October 31).

639. Richardson 4/30/98 Depo. at 68; Cooper 1/27/98 Int. at 1-2.

640. Richardson 4/30/98 Depo. at 39; Sutphen 5/27/98 Depo. at 15-16; Cooper
1/27/98 Int. at 2.

641. The draft was retrieved from Ms. Lewinsky's computer in the course of
a consensual search on January 22, 1998.

642. MSL-55-DC-0179 (punctuation added)(italics in original).

643. MSL-55-DC-0179.

644. MSL-55-DC-0179. Ms. Lewinsky concluded the letter, "I was pleased the
UN interview went well, but I'm afraid it will be like being at the
Pentagon in NY. . . YUCK!" MSL-55-DC-0179 (ellipsis in original).

645. Lewinsky 8/13/98 Int. at 4-5; Lewinsky 7/31/98 Int. at 14; Lewinsky
7/27/98 Int. at 5.

646. 828-DC-00000003.

647. Lewinsky 8/26/98 Depo. at 67; Lewinsky 7/27/98 Int. at 5; Lewinsky
7/31/98 Int. at 14; Lewinsky 8/13/98 Int. at 5.

According to Ambassador Richardson, the position offered to Ms. Lewinsky
was not newly created. He testified that he intended to expand an open
position in the U.N.'s Washington office and move it to New York.
Richardson 4/30/98 Depo. at 39-40. Although Ambassador Richardson did not
recall whether this opening was publicized, he testified that it would be
common for the office not to post Schedule C (political appointment)
positions. Richardson 4/30/98 Depo. at 71-72. Peter Aronsohn, who filled
the position Ms. Lewinsky was offered, characterized the job as a "new
position." Aronsohn 8/27/98 Int. at 2.

648. Sutphen 5/27/98 Depo. at 26.

649. Richardson 4/30/98 Depo. at 90-91; Sutphen 5/27/98 Depo. at 21-23.

650. Lewinsky 8/26/98 Depo. at 65-66; Lewinsky 8/13/98 Int. at 4.

651. Currie 5/6/98 GJ at 174-75, 181; Currie 5/14/98 GJ at 65-66.

652. Clinton 1/17/98 Depo. at 73.

653. Sutphen 5/27/98 Depo. at 32-33; Lewinsky 8/13/98 Int. at 5.

654. Sutphen 5/27/98 Depo. at 33. See also Richardson 4/30/98 Depo. at
110-11 (recalling Ms. Lewinsky's request for additional time to consider
the offer).

655. Lewinsky 7/27/98 Int. at 5; Sutphen 5/27/98 Depo. at 38;
1013-DC-00000095 (toll records for Debra Finerman).

656. 921-DC-00000101 - 118 (Second Set of Interrogatories from Plaintiff to
Defendant Clinton).

657. V002-DC-00000016; V002-DC-00000020-21.

658. See supra at IX.B. See also Lewinsky 8/6/98 GJ at 104; Lewinsky
7/31/98 Int. at 11-12.

659. MSL-55-DC-0179.

660. Lewinsky 7/31/98 Int. at 14.

661. Lewinsky 7/31/98 Int. at 14. Phone records reflect that on November 4
at 3:54 p.m., Ms. Lewinsky placed a three-and-a-half-minute call to Mr.
Jordan's office; at 4:09 p.m., Mr. Jordan placed a one-minute call to Ms.
Currie; and at 4:38 p.m., Mr. Jordan placed a one-minute call to Ms.
Currie.833-DC-00017875 (Ms Lewinsky's phone records); V004-DC-00000134
(Akin, Gump phone records).

662. T2 at 11-12. See also Lewinsky 7/31/98 Int. at 11.

663. Jordan 5/5/98 GJ at 47 (Mr. Jordan testified that he believed the
President had told Ms. Currie to "[c]all Vernon and ask Vernon to help
her").

664. Currie 5/6/98 GJ at 169-70, 176-78, 182-83, 198.

665. Clinton 1/17/98 Depo. at 81.

666. Clinton 1/17/98 Depo. at 82.

667. 1178-DC-00000011 (call logs).

668. Lewinsky 7/31/98 Int. at 14.

669. Lewinsky 7/31/98 Int. at 14-15.

670. Lewinsky 8/13/98 Int. at 3.

671. Lewinsky 8/6/98 GJ at 106; Lewinsky 7/31/98 Int. at 14-15; Lewinsky
7/27/98 Int. at 8, 10. Ms. Lewinsky later quoted the remark in email to a
friend. 1037-DC-00000017 (email to Catherine Davis).

672. 1037-DC-00000017 (email retrieved from Catherine Davis's computer).

673. Jordan 3/3/98 GJ at 13.

674. V004-DC-00000135 (Akin, Gump phone records).

675. Jordan 5/5/98 GJ at 54.

676. 1178-DC-00000026 (WAVES record). Ms. Lewinsky would learn of the
meeting between the President and Mr. Jordan. In email to a friend dated
November 6, Ms. Lewinsky wrote that Mr. Jordan had "[seen] the big creep
yesterday afternoon." 1037-DC-00000017 (spelling corrected) (email to
Catherine Davis).

677. Jordan 5/5/98 GJ at 34.

678. 833-DC-00000980 (letter retrieved from Ms. Lewinsky's Pentagon
computer)(spelling corrected).

679. 1037-DC-00000017 (email retrieved from Catherine Davis's computer).
Ms. Lewinsky wrote that she was "a little nervous to do the whole name of
the BF. His first name is Vernon." Id. According to her aunt, Debra
Finerman, Ms. Lewinsky used the code name "Gwen" when discussing Mr. Jordan
because "he's an important person" and Ms. Lewinsky "always had the feeling
somebody was listening in" on their phone conversations, they did not want
an eavesdropper to know that Mr. Jordan was helping her find a job.
Finerman 3/18/98 Depo. at 60. See also Lewinsky 8/5/98 Int. at 3; Lewinksy
8/3/98 Int. at 9.

680. Jordan 3/3/98 GJ at 50.

681. Jordan 5/5/98 GJ at 26-30, 34.

682. Epass records reflect that Ms. Lewinsky entered the White House at
6:20 p.m., admitted by Ms. Currie. 827-DC-00000018. Secret Service Movement
logs show that the President entered the State Floor at 5:23 and moved to
the Oval Office at 6:34. V006-DC-00002156.

683. 1037-DC-00000318 (email retrieved from Catherine Davis's computer).

684. Lewinsky 8/13/98 Int. at 5.

685. Lewinsky 8/13/98 Int. at 5. Many of Ms. Lewinsky's previous visits
with the President had occurred on holidays. See, e.g., Lewinsky 7/30/98
Int. at 3, 13, 17 (describing visits on New Year's Eve, Presidents' Day,
Easter Sunday, and July 4).

686. 837-DC-00000008(courier receipt).

687. DB-DC-00000022. Ms. Lewinsky produced a draft of this letter to the
OIC on July 31, 1998. See also Lewinsky 7/31/98 Int. at 1 (confirming that
she delivered a substantially similar note).

688. DB-DC-00000022.

689. Lewinsky 8/13/98 Int. at 5-6. On November 12, 1997, the President
responded to Paula Jones's Third Set of Interrogatories. In response to an
interrogatory that asked the President to provide information about all
individuals who have discoverable and relevant information regarding the
disputed facts at issue in the case, the President provided a list of names
that did not include Ms. Lewinsky. 849-DC-0000090 - 97.

690. 1037-DC-00000318 (email retrieved from Catherine Davis's computer).

691. 1037-DC-00000318 (spelling corrected). Lewinsky 8/13/98 Int. at 6. On
November 13, Ms. Hernreich was testifying before Congress. Walsh,
"Democratic Donor Chung Invokes 5th Amendment; House Members Informally
Interview Businessman Edward Walsh," Washington Post, November 15, 1997, at
A6.

692. MSL-1249-DC-0140; Lewinsky 8/13/98 Int. at 6.

693. 1037-DC-00000318 (email retrieved from Catherine Davis's computer).

694. Lewinsky 8/13/98 Int. at 6; 1234-DC-00000050 (movement log);
986-DC-00003799 (Kearney Diary).

695. Lewinsky 8/13/98 Int. at 6.

696. Lewinsky 8/13/98 Int. at 6; 1037-DC-00000318 (email to Catherine
Davis).

697. In a note to the President the next week, Ms. Lewinsky would write of
the gifts: "I forgot to tell you: . . . The Gingko Blowjoba or whatever it
is called and the Zinc lozenges were from me." MSL-55-DC-0140 (spelling and
grammar corrected).

698. Lewinsky 8/6/98 GJ at 183-85; Lewinsky 8/2/98 Int. at 4. Ms. Lewinsky
also saw a clipping of the Valentine's Day ad she had placed in the
Washington Post on the President's desk. Lewinsky 8/6/98 GJ at 183-84. In a
document composed soon after this visit, Ms. Lewinsky wrote: "When I was
hiding out in your office for a half-hour, I noticed you had the new Sarah
McLachlan CD. I have it, too, and it's wonderful. Whenever I listen to song
#5 I think of you. That song and Billie Holiday's version of 'I'll be
Seeing You' are guaranteed to put me to tears when it comes to you!"
MSL-1249-DC-0140-41 (deleted file from Ms. Lewinsky's home computer)
(spelling and grammar corrected).

699. 1037-DC-00000318 (email to Catherine Davis).

700. Lewinsky 8/13/98 Int. at 6.

701. OIC 8/27/98 Memo.

702. 968-DC-00000187 (presidential schedule); 968-DC-00000303 (Kearney
Diary). Ms. Currie initially testified that she could not recall Ms.
Lewinsky's November 13 visit. Currie 5/6/98 GJ at 12, 15. After viewing
documentary evidence, she recalled that this was the only time she
surreptitiously escorted Ms. Lewinsky into the White House. Id. at 85.

703. Lewinsky 8/11/98 Int. at 1; Lewinsky 7/31/98 Int. at 1-2;
837-DC-00000011 (courier receipt); MSL-1249-DC-0140-41 (document recovered
from Ms. Lewinsky's home computer).

On November 17, 1997, the President responded to Paula Jones's First Set of
Requests for Production of Documents and Things. One request sought
documents sent to President Clinton by any woman (other than Mrs. Clinton)
with whom President Clinton had sexual relations. V002-DC-00000056 - 92.
President Clinton objected to this request as one designed "solely to
harass, embarrass, and humiliate the President and the Office he occupies."
V002-DC-00000075. Nonetheless, the President answered that he did not have
any documents responsive to that request.

704. Lewinsky 8/6/98 GJ at 105.

705. Lewinsky 8/6/98 GJ at 105. Phone and pager records corroborate these
contacts. 1205-DC-00000016; V004-DC-00000143; 831-DC-00000011. (Note that
Ms. Lewinsky's pager records reflect Pacific Time; throughout this
referral, time has been adjusted to Eastern Standard Time.)

706. MSL-1249-DC-0140 (spelling and punctuation corrected).

707. MSL-1249-DC-0139 (spelling and punctuation corrected).

708. 849-DC-00000128.

709. 849-DC-00000121-37

710. See infra at Section XI.F. See also Lewinsky 8/6/98 GJ at 121-26.

711. Clinton 8/17/98 GJ at 84-85. In his Jones deposition, the President
acknowledged that he may have heard of the witness list before he actually
saw it. Clinton 1/17/98 Depo. at 70.

712. 833-DC-00003207 (Travel Voucher DOD).

713. Lewinsky 8/6/98 GJ at 107; Lewinsky 7/31/98 Int. at 1.

714. V006-DC-00000521 (guest list); VOO6-DC-00001859 (photograph of Ms.
Lewinsky and the President at the reception).

715. Lewinsky 7/31/98 Int. at 1.

716. Lewinsky 7/31/98 Int. at 2; MSL-55-DC-0177. The wording of the letter
resembles, in part, a message on a cassette found during the consensual
search of Ms. Lewinsky's apartment: "Hi. [Sniffling, crying.] I was so sad
seeing you last night. I was so angry with you that once again you had
rejected me. . . . I wanted to feel the warmth of you and the smell of you
and the touch of you. And it made me sad. And I -- you confuse me so much.
I mean I [sigh]. I thought I -- I thought I fell in love with this person
that -- that I really felt was such a good -- such a good person, such a
good heart, someone who's had a life with a lot of experiences." See
Document Supplement B, Tab 36.

717. MSL-55-DC-0177 (punctuation corrected).

718. MSL-55-DC-0177 (punctuation corrected).

719. MSL-DC-55-0177 (punctuation corrected).

720. MSL-55-DC-0177 (punctuation corrected).

721. Lewinsky 8/6/98 GJ at 108-09; Lewinsky 8/6/98 GJ at 27-29 & Exh. ML-7.
The cigar holder, the tie, the mug, and the book have been produced to the
OIC. V002-PHOTOS-0011 (holder, tie, and book); V002-PHOTOS-0005 (mug).

722. Lewinsky 8/6/98 GJ at 111-12.

723. Bryan Hall 5/21 98 Int. at 2; Bryan Hall 7/23/98 GJ at 10-11, 15-16;
Niedzwiecki 7/30/98 GJ at 12-13; Lewinsky 8/6/98 GJ at 109-11.

724. Lewinsky 8/6/98 GJ at 110-11; Niedzwiecki 7/30/98 GJ at 13-14.

725. Byran Hall 7/23/98 GJ at 12-13; Niedzwiecki 7/30/98 GJ at 13, 15.
Officer Hall recognized Ms. Lewinsky from a previous occasion, when she was
greeted by, and delivered something to, Ms. Currie. Byran Hall 7/23/98 GJ
at 6-10.

726. Tyler 7/28/98 GJ at 40; Chinery 7/23/98 GJ at 8.

727. Lewinsky 8/6/98 GJ at 111-12. Ms. Mondale recalled visiting the
President that morning. Mondale 7/16/98 Int. at 1. See also 843-DC-00000004
(Epass records reflect that Ms. Mondale entered the White House at 9:33
a.m.).

728. Lewinsky 8/6/98 GJ at 111-12. See also Currie 7/22/98 GJ at 88-89. Ms.
Lewinsky suspected that Ms. Mondale was romantically involved with the
President. Lewinsky 8/6/98 GJ at 111-12.

729. Lewinsky 8/6/98 GJ at 112-13. Ms. Currie testified that Ms. Lewinsky
angrily told her: "'You had lied to me, that the President is in the
office, and he's meeting with someone.' And I said, 'Yeah, you're right.'
She was not too happy about it, and words were exchanged." Currie 1/27/98
GJ at 37.

730. Keith Williams 7/23/98 GJ at 24. See also Chinery 7/23/98 GJ at 10;
Purdie 7/23/98 GJ at 13.

731. Keith Williams 7/23/98 GJ at 12. Some testimony indicates that the
President directly told Sergeant Williams about the Northwest Gate
incident. Three officers testified that Sergeant Williams told them that
the President had spoken to him and had indicated that he wanted the
officer responsible for the disclosure of information fired. Niedzwiecki
7/30/98 GJ at 29, 37; Byran Hall 7/23/98 GJ at 25-26; Porter 8/13/98 GJ at
16-18. For example, Officer Niedzwiecki testified that soon after the
incident, Sergeant Williams came to the Northwest Gate and said, "[t]he
President wants somebody's job." Niedzwiecki 7/30/98 GJ at 29. Sergeant
Williams testified, however, that the President did not speak to him
directly about the incident. Keith Williams 7/23/98 GJ at 31-32. According
to Sergeant Williams, when he met alone with Ms. Currie, he noticed that
the door leading to the Oval Office was at first shut but then was cracked
open. Keith Williams 7/23/98 GJ at 22, 30. Sergeant Williams testified that
he heard what he assumed to be a male voice coming from within the Oval
Office saying "[t]his person needs to be fired." Keith Williams 7/30/98 GJ
at 10-11. Sergeant Williams told the officers at the gate that he spoke to
the President only to get their attention. Keith Williams 7/30/98 GJ at
16-17. However, Sergeant Williams also told the supervisor who replaced him
that afternoon that the President had spoken to him directly about the
incident at the Northwest Gate. Deardoff 9/3/98 Depo. at 8-9.

732. Purdie 7/23/98 GJ at 13, 18-19. Captain Purdie testified that he
thought that the remedy of firing was "out of proportion to the incident .
. . [e]specially without doing an investigation or a fact-finding mission."
Purdie 7/23/98 GJ at 19.

733. Lewinsky 8/6/98 GJ at 113.

734. Lewinsky 8/6/98 GJ at 113-14.

735. Lewinsky 8/6/98 GJ at 114.

736. Lewinsky 8/6/98 GJ at 114.

737. 827-DC-00000018. Secret Service logs reflect that the President was in
the area of the Oval Office throughout this period. V006-DC-00002158.

738. Lewinsky 8/6/98 GJ at 115-16. Specifically, Ms. Lewinsky told the
President "that I was supposed to get in touch with Mr. Jordan the previous
week and that things didn't work out and that nothing had really happened
yet." Id.

739. Lewinsky 8/6/98 GJ at 116. The President also told Ms. Lewinsky that
he had already gotten a Christmas present for her and that he would give
that to her during another visit. Lewinsky 8/1/98 Int. at 2.

740. Lewinsky 8/6/98 GJ at 115.

741. 1037-DC-00000011 (spelling corrected).

742. Keith Williams 7/23/98 GJ at 25. Ms. Currie confirmed that she told an
officer, "Okay. Fine. This never happened." However, she testified that she
said this so that no officer would get in trouble. Currie 7/22/98 GJ at
91-92.

When Ms. Currie left work that day, she stopped by a Secret Service post
and told an officer that "she spoke to the President . . . and . . . they
decided that the incident never happened, they weren't going to pursue . .
. discipline actions against them, that they just wanted it to go away."
Chinery 7/23/98 GJ at 22-23. Later that week, Ms. Currie told that officer
to inform one of his supervisors "that everything was okay and just to keep
quiet about it." Keith Williams 7/23/98 GJ at 27-28.

743. Purdie 7/23/98 GJ at 32; Purdie 7/17/98 GJ at 3.

744. Purdie 7/17/98 GJ at 6; Bryan Hall 7/23/98 GJ at 31-32; Chinery
7/23/98 GJ at 21.

745. Porter 8/13/98 GJ at 12.

746. Niedzwiecki 7/30/98 GJ at 30-31.

747. Niedzwiecki 7/30/98 GJ at 31, 44. See also Niedzwiecki 8/5/98 GJ at
4-6 (text of Niedzwiecki notes).

748. Purdie 7/23/98 GJ at 35.

749. Purdie 7/23/98 GJ at 34-36. While Deputy Chief O'Malley testified that
Captain Purdie notified him of the incident, Deputy Chief O'Malley did not
recall Captain Purdie discussing with him, at any time, a decision not to
generate an incident report or a memorandum. Charles O'Malley 9/8/98 Depo.
at 44, 47-48.

750. O'Malley 9/8/98 Depo. at 22, 40-41.

751. Clinton 8/17/98 GJ at 84-85, 87. Ms. Mondale stated that she met with
the President alone in the Oval Office study that day. Mondale 7/16/98 Int.
at 1.

752. Clinton 8/17/98 GJ at 86.

753. Clinton 8/17/98 GJ at 88-89.

754. Clinton 8/17/98 GJ at 89-90.

755. Clinton 8/17/98 GJ at 91-92.

756. Lewinsky 8/6/98 GJ at 151-52; Lewinsky 2/1/98 Statement at 6. On
December 23, Paula Jones's attorneys issued a subpoena to the Secret
Service.

757. Lindsey 3/12/98 GJ at 64-66; Lindsey 2/19/98 GJ at 9-10. WAVES records
reflect that Robert Bennett entered the White House at 4:39 p.m. on
Saturday, December 6. 1407-DC-00000005.

758. Lindsey 3/12/98 GJ at 65.

759. 964-DC-00000862 (Presidential mail notes).

760. Lindsey 3/12/98 GJ at 63-64. Mr. Lindsey refused to answer questions
about his December 6 meeting with the President, claiming attorney-client
privilege and Executive (presidential communications) Privilege. Id. at 66.
The U.S. District Court for the District of Columbia rejected Mr. Lindsey's
claim of privilege, In re Grand Jury Proceedings, 5 F. Supp.2d 21 (D.D.C.
1998), and the Court of Appeals denied Mr. Lindsey's appeal, In re Lindsey,
148 F.3d 1100 (D.C. Cir. 1998). A petition for Supreme Court review is
pending.

761. WAVES records reflect that Mr. Jordan entered the White House at 5:21
p.m. on Sunday, December 7. 1178-DC-00000026.

762. Jordan 5/5/98 GJ at 83. He later testified that the conversation was
"[a]bsolutely not" about Ms. Lewinsky. Jordan 5/5/98 GJ at 116.

763. V004-DC-00000171 (Akin, Gump visitor records) (recording visit of
"Malensky"). Ms. Lewinsky recalled arranging the meeting on December 8 or
9. Lewinsky 8/1/98 Int. at 3. See also 833-DC-00017886 (reflecting Ms.
Lewinsky's call to Mr. Jordan on December 8).

On December 8, Ms. Lewinsky sent Mr. Jordan a hat, a box of chocolates, and
a note gently reminding him of his promise to help her find a job. Lewinsky
7/31/98 Int. at 15. She also sent the President a note and some peach
candies. Lewinsky 8/1/98 Int. at 2; Lewinsky 8/1/98 Int. at 2;
837-DC-00000017; 837-DC-00000020 (courier receipts).

764. Jordan 3/3/98 GJ at 41-42.

765. V004-DC-00000148 (Akin, Gump phone records). See also Jordan 3/3/98 GJ
at 54, 62-63, 70.

Mr. Halperin testified that Mr. Jordan had told him that Ms. Lewinsky "was
a bright young woman who was energetic and enthusiastic and . . .
encouraged me to meet with her." Halperin 4/23/98 GJ at 13. Similarly, Ms.
Fairbairn stated that Mr. Jordan had told her that he "would like to send
[her] a resume of a talented young lady and see if she matches up with any
company openings." Fairbairn 1/29/98 Int. at 1. Mr. Georgescu, however,
stated that Mr. Jordan "did not engage in a 'sales pitch' about [Ms.]
Lewinsky." Georgescu 3/25/98 Int. at 2.

766. Lewinsky 8/6/98 GJ at 121. Ms. Lewinsky left the meeting with Mr.
Jordan on December 8 with the impression that Mr. Jordan was going to get
her a job. Lewinsky 8/1/98 Int. at 4.

767. Lewinsky 8/6/98 GJ at 119.

768. Lewinsky 8/6/98 GJ at 120.

769. Lewinsky 8/6/98 GJ at 120.

770. Lewinsky 8/6/98 GJ at 120. In her handwritten proffer, Ms. Lewinsky
gave a very similar account of her second meeting with Mr. Jordan: "Ms. L.
met again with Mr. Jordan in the beginning of December '97, at which time
he provided Ms. L. with a list of three people to contact and suggested
language to use in her letters to them. At some point, Mr. Jordan remarked
something about Ms. L. being a friend of the Pres. of the United States.
Ms. L. responded that she never really saw him as "the President"; she
spoke to him like a normal man and even got angry with him like a normal
man. Mr. Jordan asked what Ms. L. got angry about. Ms. L. replied that the
Pres. doesn't see or call her enough. Mr. Jordan said Ms. L. should take
her frustrations out on him -- not the President." Lewinsky 2/1/98
Statement at 3-4.

771. Lewinsky 8/6/98 GJ at 120.

772. Jordan 3/3/98 GJ at 154.

773. Jordan 3/3/98 GJ at 64-65.

774. Jordan 3/3/98 GJ at 65.

775. Jordan 3/3/98 GJ at 65.

776. 1414-DC-00001534 - 46 (Plaintiff's Second Request for Production of
Documents and Things).

777. Lewinsky 8/6/98 GJ at 121-26.

778. Lewinsky 8/6/98 GJ at 126. Ms. Lewinsky testified that the call came
as a surprise because Mrs. Clinton was in town. Id. at 122. See also
968-DC-00003479 (Mrs. Clinton's schedule reflects that she was in
Washington, D.C. on December 17).

779. Lewinsky 8/6/98 GJ at 122-23.

780. Lewinsky 8/6/98 GJ at 123.

781. Lewinsky 2/1/98 Statement at 4.

782. Lewinsky 8/6/98 GJ at 123.

783. Lewinsky 2/1/98 Statement at 4.

784. Lewinsky 8/6/98 GJ at 123-24. Ms. Lewinsky testified that, "on
[s]everal occasions," they had resolved to use this cover story to conceal
their relationship. Id.

785. Lewinsky 8/6/98 GJ at 232.

786. Lewinsky 8/6/98 GJ at 126.

787. Lewinsky 8/6/98 GJ at 126.

788. Clinton 8/17/98 GJ at 116.

789. Clinton 8/17/98 GJ at 119. The President himself gave this explanation
of Ms. Lewinsky's visits to the Oval Office at his Jones deposition.
Clinton 1/17/98 Depo. at 50-51.

790. Clinton 8/17/98 GJ at 119-20.

791. Clinton 8/17/98 GJ at 119-20.

792. Clinton 8/17/98 GJ at 120.

793. Halperin 1/26/98 Int. at 2.

794. Berk 3/31/98 Int. at 1-2. In her proffer, Ms. Lewinsky stated that,
during the week following her December 11 meeting with Mr. Jordan, she "had
two interviews in NY in response to her letters." Lewinsky 2/1/98 Statement
at 4.

795. Schick 1/29/98 Int. at 2.

796. Lewinsky 8/6/98 GJ at 128; Harte 4/17/98 Int. at 1.

797. 902-DC-000000135 - 138 (Lewinsky subpoena).

798. 902-DC-000000137.

799. Lewinsky 8/6/98 GJ at 128-29; Lewinsky 7/27/98 Int. at 6; 8/1/98 Int.
at 6-7. In the late-night December 17 call, the President told Ms. Lewinsky
that, if she were subpoenaed, she should call Ms. Currie. Ms. Lewinsky did
not do so on December 19 because Ms. Currie's brother had recently died and
Ms. Lewinsky did not want to bother her. Lewinsky 8/6/98 GJ at 126.

800. Jordan 3/3/98 GJ at 92-93. Mr. Jordan said that he did not contemplate
representing Ms. Lewinsky himself because "I represent companies. I don't
represent individuals." Jordan 3/3/98 GJ at 101.

801. V004-DC-00000172 (Akin, Gump visitor logs).

802. V004-DC-00000151 (Akin, Gump telephone records, indicating the call
ended at 5:05 p.m.); 1178-DC-00000014 (Presidential call logs, reflecting
the call ended at 5:08 p.m.). Presidential call logs are recorded by hand,
and thus are likely to be less accurate. The President may have been
returning a call that Mr. Jordan had placed at 3:51 p.m.

803. Lewinsky 8/6/98 GJ at 131; V004-DC-00000151 (Akin, Gump telephone
records). Mr. Jordan asked whether he could bring a potential client to Mr.
Carter's office on Monday morning. Jordan 5/5/98 GJ at 135-136; Carter
6/18/98 GJ at 7-8.

804. Lewinsky 8/6/98 GJ at 131.

805. Jordan 5/5/98 GJ at 140, 152-53.

806. Jordan 5/5/98 GJ at 145.

807. Jordan 5/5/98 GJ at 145.

808. Jordan 5/5/98 GJ at 147.

809. Jordan 5/5/98 GJ at 147.

810. Jordan 3/3/98 GJ at 102.

811. Jordan 3/3/98 GJ at 103.

812. Lewinsky 8/6/98 GJ at 131-32.

813. Lewinsky 8/6/98 GJ at 132.

814. Lewinsky 8/6/98 GJ at 132. In her handwritten proffer, Ms. Lewinsky
described her meeting with Mr. Jordan that afternoon: "Ms. L expressed
anxiety with respect to her subpoena requesting production of any gifts
from the Pres., specifically citing hat pins which the Pres. had in fact
given her. Mr. Jordan allayed her concerns by telling her it was standard
language." Lewinsky 2/1/98 Statement at 5.

815. Lewinsky 8/6/98 GJ at 133.

816. Jordan 3/3/98 GJ at 150. Ms. Lewinsky confirmed that she had such a
conversation with Mr. Jordan, although she believed it took place after a
breakfast meeting on December 31. Lewinsky 8/6/98 GJ at 188; Lewinsky
2/1/98 Statement at 8.

817. Jordan 3/3/98 GJ at 123.

818. Jordan 3/3/98 GJ at 122. He also said: "I did not get graphic, I did
not get specific, I didn't ask her if they kissed, I didn't ask if they
caressed, all of which, as I understand it, is a part of the act of sex."
Id. at 130.

819. Jordan 3/3/98 GJ at 126.

820. Jordan 3/3/98 GJ at 122-24. See also Lewinsky 8/6/98 GJ at 133-35.

821. Lewinsky 8/6/98 GJ at 134.

822. Lewinsky 8/6/98 GJ at 134.

823. Lewinsky 8/6/98 GJ at 135. According to Ms. Lewinsky, Mr. Jordan
responded, "I don't hug men." Id.

824. Jordan 3/3/98 GJ at 167-8.

825. Jordan 3/3/98 GJ at 169. According to Mr. Jordan, the President
listened with "some amazement" when Mr. Jordan recounted the conversation.
Id. at 170.

826. Jordan 3/3/98 GJ at 173-74.

827. Jordan 3/3/98 GJ at 170.

828. Jordan 3/3/98 GJ at 171.

829. Jordan 3/3/98 GJ at 172. In the days that followed, Mr. Jordan
informed the President that he had succeeded in engaging Francis Carter to
represent Ms. Lewinsky. Jordan 3/5/98 GJ at 27.

830. Clinton 8/17/98 GJ at 64.

831. Clinton 8/17/98 GJ at 65-66.

832. Jordan 3/3/98 GJ at 164-66, 183-84.

833. Lewinsky 8/6/98 GJ at 138.

834. Lewinsky 8/6/98 GJ at 138.

835. Lewinsky 8/6/98 GJ at 138-39.

836. Lewinsky 8/6/98 GJ at 139.

837. Lewinsky 8/6/98 GJ at 139. Mr. Jordan asked what "phone sex" was.
Lewinsky 8/6/98 GJ at 139. Ms. Lewinsky stated that she may have explained
it this way: "He's taking care of business on one end and I'm taking care
of business on another." Lewinsky 8/6/98 GJ at 143.

838. Lewinsky 8/6/98 GJ at 139-140. In her proffer, Ms. Lewinsky wrote that
she "showed Mr. Jordan the items she was producing in response to the
subpoena. Ms. L believes she made it clear that this was not everything she
had that could respond to the subpoena, but she thought it was enough to
satisfy." Lewinsky 2/1/98 Statement at 6.

839. Jordan 3/3/98 GJ at 153.

840. The diaries of both Mr. Carter and Mr. Jordan reflect an 11:00 a.m.
appointment on December 22, 1997. 902-DC-00000231 (Mr. Carter's diary) and
1034-DC-00000103 (Mr. Jordan's diary).

841. Carter 6/18/98 GJ at 12, 14. According to Mr. Carter, although Mr.
Jordan had previously referred clients to him, Mr. Jordan had never
personally driven them to his office. Id. at 160-61.

842. Carter 6/18/98 GJ at 158-60, 15, 75.

843. According to Mr. Carter's bill, he met with Ms. Lewinsky for 1.1
hours. 902-DC-00000037.

844. Lewinsky 8/6/98 GJ at 146; Carter 6/18/98 GJ at 25.

845. Lewinsky 8/6/98 GJ at 146-47; Carter 6/18/98 GJ at 25.

846. Lewinsky 8/6/98 GJ at 146. Somewhat at odds with Ms. Lewinsky, Mr.
Carter testified, "I thought I needed to develop an affidavit recounting
what she said to me." Carter 6/18/98 GJ at 65.

847. Lewinsky 8/6/98 GJ at 147.

848. Lewinsky 8/6/98 GJ at 147.

849. Carter 6/18/98 GJ at 29-30; 902-DC-00000038.

850. Carter 6/18/98 GJ at 39.

851. Carter 6/18/98 GJ at 42-43.

852. V002-DC-000000052 - 54 (President Clinton's Supplemental Responses to
Plaintiff's Second Set of Interrogatories); 1414-DC-00000512 - 17 (same).

853. Lewinsky 8/6/98 GJ at 149.

854. Lewinsky 8/6/98 GJ at 149.

855. V0006-DC-00000009 (WAVES records).

856. Lewinsky 8/6/98 GJ at 150-51. In his grand jury testimony, the
President recalled giving her many of these gifts and acknowledged that it
was "probably true" that these were more gifts than he had ever given her
in a single day. Clinton 8/17/98 GJ at 36.

857. Lewinsky 8/26/98 Depo. at 53.

858. Lewinsky 8/6/98 GJ at 151.

859. Lewinsky 8/6/98 GJ at 151-52.

860. Lewinsky 8/6/98 GJ at 152. In her handwritten statement of February 1,
1998, Ms. Lewinsky wrote: "Ms. L. asked [the President] how he thought the
attorneys for Paula Jones found out about her. He thought it was probably
'that woman from the summer . . . with Kathleen Willey' (Linda Tripp) who
lead [sic] them to Ms. L or possibly the uniformed agents. He shared Ms.
L's concern about the hat pin. He asked Ms. L if she had told anyone that
he had given it to her and she replied 'no.'" Lewinsky 2/1/98 Statement at
6.

861. Lewinsky 8/20/98 GJ at 66.

862. Lewinsky 8/6/98 GJ at 152. Ms. Lewinsky acknowledged in the grand jury
that she had in fact told others about the hat pin. Lewinsky 8/6/98 GJ at
152.

863. Lewinsky 8/6/98 GJ at 152.

864. Lewinsky 8/6/98 GJ at 152. See also Lewinsky 8/20/98 GJ at 66.

865. Lewinsky 8/6/98 GJ at 168.

866. Clinton 1/17/98 Depo. at 68.

867. Clinton 8/17/98 GJ at 33.

868. Clinton 8/17/98 GJ at 39. He further testified that he did not
remember that Ms. Lewinsky's subpoena specifically called for a hat pin.
Clinton 8/17/98 GJ at 45.

869. Clinton 8/17/98 GJ at 39.

870. Catherine Davis 3/17/98 GJ at 77-79.

871. Lewinsky 8/6/98 GJ at 154-55.

872. Lewinsky 8/6/98 GJ at 155.

873. Lewinsky 8/6/98 GJ at 155-56.

874. Lewinsky 8/6/98 GJ at 156-58. Ms. Currie could remember only one other
occasion in which she had driven to Ms. Lewinsky's Watergate apartment.
Currie 5/6/98 GJ at 108.

875. Lewinsky 8/6/98 GJ at 158-59.

876. Lewinsky 8/6/98 GJ at 159.

877. Lewinsky 8/6/98 GJ at 159. See also Lewinsky 8/1/98 Int. at 12.

878. Lewinsky 2/1/98 Statement at 7 (punctuation corrected).

879. Ms. Currie stated, at various times, that the transfer occurred
sometime in late December 1997 or early January 1998. Currie 1/24/98 Int.
at 3; Currie 1/27/98 GJ at 56-57; Currie 5/6/98 GJ at 103-07.

880. Currie 5/6/98 GJ at 105-06.

881. Currie 5/6/98 GJ at 126.

882. Currie 1/27/98 GJ at 58. In her first grand jury appearance in
January, Ms. Currie was asked whether she knew who had been asking the
questions about the gifts. She testified: "Sir, no, I don't." Id. In a May
grand jury appearance, Ms. Currie responded to a similar question by saying
that she understood that Newsweek reporter Michael Isikoff (who had earlier
written about Kathleen Willey) was asking about the gifts. Currie 5/6/98 GJ
at 107, 114, 120. Ms. Lewinsky testified that she never spoke to Mr.
Isikoff. Lewinsky 8/24/98 Int. at 9.

883. Currie 5/6/98 GJ at 107-08. See also Currie 1/27/98 GJ at 57-58.

884. Currie 5/6/98 GJ at 110. When the OIC later obtained the box from Ms.
Currie by subpoena, it contained various items that the President had given
to Ms. Lewinsky, including (a) a hat pin; (b) a brooch; (c) an official
copy of the 1996 State of the Union Address inscribed "To Monica Lewinsky
with best wishes, Bill Clinton"; (d) a photograph of the President in the
Oval Office with a handwritten note, "To Monica -- Thanks for the tie Bill
Clinton"; (e) a photograph of the President and Ms. Lewinsky inscribed "To
Monica -- Happy Birthday! Bill Clinton 7-23-97"; (f) a sun dress, two
t-shirts, and a baseball cap with a Black Dog logo on them; and (g) a
facsimile copy of a Valentine's Day message to "Handsome" that Ms. Lewinsky
placed in the Washington Post in 1996.

885. Currie 5/6/98 GJ at 106-07.

886. Clinton 8/17/98 GJ at 51.

887. Clinton 8/17/98 GJ at 115.

888. Clinton 8/17/98 GJ at 46.

889. Lewinsky 8/6/98 GJ at 186. Ms. Tripp, like Ms. Lewinsky, had been
subpoenaed in the Jones case.

890. Lewinsky 8/6/98 GJ at 186-87. Although Mr. Jordan testified that he
never had breakfast with Ms. Lewinsky, see Jordan 3/5/98 GJ at 60, there is
strong circumstantial evidence supporting Ms. Lewinsky's testimony that she
had breakfast with Mr. Jordan on December 31. Compare Lewinsky 8/6/98 GJ at
187-89 (describing breakfast) with 916-DC-00000003 (Park Hyatt receipt
reflecting breakfast as described by Ms. Lewinsky).

891. Lewinsky 8/6/98 GJ at 186-89.

892. Lewinsky 8/6/98 GJ at 187.

893. Lewinsky 8/6/98 GJ at 187.

894. Lewinsky 8/6/98 GJ at 188; 8/26/98 Int. at 2; 8/1/98 Int. at 13.

895. Lewinsky 8/1/98 Int. at 13.

896. Lewinsky 8/6/98 GJ at 190.

897. Lewinsky 8/6/98 GJ at 190-91.

898. Lewinsky 8/2/98 Int. at 1.

899. 902-DC-00000232 (Mr. Carter's day-planner); 902-DC-00000037 (Mr.
Carter's bill).

900. Lewinsky 8/6/98 GJ at 192. Mr. Carter agreed that, during one of his
meetings with Ms. Lewinsky, he asked her sample questions. Carter 6/18/98
GJ at 110-12.

901. Lewinsky 8/6/98 GJ at 192-93.

902. Carter 6/18/98 GJ at 67-68; Lewinsky 8/6/98 GJ at 194, 199.

903. Lewinsky 8/6/98 GJ at 195.

904. Lewinsky 8/6/98 GJ at 195; Lewinsky 8/2/98 Int. at 3; Lewinsky 2/1/98
Statement at 9 ("That evening Ms. L placed a phone call to Ms. Currie
asking her to tell the Pres. that she wanted to speak with him before she
signed something the next day. He returned Ms. L's call a few hours
later.").

905. Lewinsky 8/6/98 GJ at 196.

906. Lewinsky 8/2/98 Int. at 3. See also Lewinsky 2/1/98 Statement at 9
("The Pres. told Ms. L. not to worry about the affidavit as he had seen 15
others.").

907. Lewinsky 8/6/98 GJ at 197.

908. Lewinsky 8/6/98 GJ at 197; Lewinsky 2/1/98 Statement at 9 ("Ms. L told
him Mr. Carter had asked some sample questions that might be asked of her
in the deposition and she didn't know how to answer them.").

909. Clinton 8/17/98 GJ at 126

910. Clinton 8/17/98 GJ at 129.

911. Lewinsky 9/3/98 Int. at 2.

912. Lewinsky 8/6/98 GJ at 198.

913. Lewinsky 8/6/98 GJ at 198.

914. Clinton 8/17/98 GJ at 48-49.

915. Clinton 8/17/98 GJ at 50.

916. Clinton 8/17/98 GJ at 127, 49-50.

917. Lewinsky 8/6/98 GJ at 199-200; Carter 6/18/98 GJ at 70-73. A draft
copy of the affidavit, with minor revisions, was found in Ms. Lewinsky's
apartment in the course of a consensual search on January 22, 1998.

918. Lewinsky 8/6/98 GJ at 200; Lewinsky 2/1/98 Statement at 6 ("After Ms.
L received a draft of the affidavit, she called Mr. Jordan to ask that he
look it over before she sign it. He instructed her to drop off a copy at
his office. They spoke later by phone about the affidavit agreeing to make
some changes.").

919. Lewinsky 8/6/98 GJ at 194-95.

920. Lewinsky 8/6/98 GJ at 202.

921. As originally drafted, Paragraph 6 of the affidavit stated: "In the
course of my employment at the White House, I met with the President on
several occasions. I do not recall ever being alone with the President,
although it is possible that while working in the White House Office of
Legislative Affairs I may have presented him with a letter for his
signature while no one else was present. This would only have lasted a few
minutes and would not have been a private meeting, that is, not behind
closed doors." 849-DC-00000634 (emphasis added). Ms. Lewinsky deleted the
underlined sentence.

922. 849-DC-00000634-35 (emphasis added).

923. Lewinsky 8/6/98 GJ at 202.

924. 849-DC-00000635.

925. Lewinsky 8/6/98 GJ at 202.

926. Jordan 3/5/98 GJ at 11.

927. Jordan 3/5/98 GJ at 11.

928. See Telephone Calls, Table 35. Catalogs of relevant phone calls are
included in Appendix G as a Phone Log, Tables 1 through 50.

929. Carter 6/18/98 GJ at 76-77, 92-93.

930. 902-DC-00000030 (Mr. Carter's bill to Ms. Lewinsky).

931. Jordan 5/5/98 GJ at 210, 214.

932. Jordan 5/5/98 GJ at 218-20.

933. 902-DC-00000232 (Mr. Carter's day-planner).

934. Lewinsky 8/6/98 GJ at 204-05. As to the sentence, "I have never had a
sexual relationship with the President," she testified that this was not
true. She was also asked about the statement that other persons were
present on the occasions she met with the President. She termed this
paragraph "misleading," explaining: "[I]t doesn't say the only occasions,
but it's misleading in that one reading it would assume that the only
occasions on which I saw the President were those listed."

935. Carter 6/18/98 GJ at 108.

936. Jordan 5/5/98 GJ at 222. See also Jordan 3/3/98 GJ at 192; Jordan
3/5/98 GJ at 11; Jordan 5/28/98 GJ at 62. Ms. Lewinsky testified that she
told Mr. Jordan on January 6, that she would be signing an affidavit the
next day. On January 13, she showed him a copy. Lewinsky 8/6/98 GJ at 200,
220.

937. See Telephone Calls, Table 36.

938. Jordan 3/5/98 GJ at 24-26.

939. Jordan 5/5/98 GJ at 223-25.

940. Jordan 5/5/98 GJ at 225.

941. Jordan 5/5/98 GJ at 226.

942. Clinton 1/17/98 Depo. at 72.

943. Clinton 8/17/98 GJ at 74.

944. Clinton 8/17/98 GJ at 75.

945. Durnan 3/27/98 Int. at 1.

946. Durnan 3/27/98 Int. at 2.

947. Durnan 3/27/98 Int. at 2.

948. Lewinsky 8/6/98 GJ at 206.

949. Lewinsky 8/6/98 GJ at 207-08.

950. See Telephone Calls, Table 37, Call 6.

951. Jordan 5/5/98 GJ at 230.

952. Jordan 5/5/98 GJ at 231. Asked whether he had ever spoken with Mr.
Perelman in the past in the context of a job referral, Mr. Jordan could
remember three persons for whom he had made referrals: David Dinkins, the
former Mayor of New York City; an attorney at Mr. Jordan's law firm who
"was good and they actually stole her away from Akin Gump because she was
so good"; and a graduate of the Harvard Business School who was considered
for the top position at Marvel Comics. Jordan 3/5/98 GJ at 56-58.

953. Perelman 4/23/98 Depo. at 10.

954. Perelman 4/23/98 Depo. at 11.In his testimony before the House
Government and Reform Oversight Committee, Mr. Jordan testified that he
helped former Associate Attorney General Webster Hubbell be retained by
Revlon by introducing him to Howard Gittes, Vice Chairman and Chief
Administrative Officer at MacAndrews & Forbes. Mr. Jordan initially
testified that he "certainly" also spoke with Mr. Perelman about retaining
Mr. Hubbell. He then testified that "it was entirely possible" that Mr.
Perelman was present on April 6, 1994, when Mr. Jordan accompanied Mr.
Hubbell to the New York offices of MacAndrews & Forbes to introduce Mr.
Hubbell to Mr. Gittes, General Counsel Barry Schwartz, and Richard
Halperin, who was in charge of government relations. Jordan 7/24/97 House
of Representatives at 35-37. As stated in the text, Mr. Perelman does not
remember Mr. Jordan ever contacting him regarding Mr. Hubbell.

955. Jordan 5/5/98 GJ at 232. Ms. Lewinsky similarly testified that Mr.
Jordan called her back that evening and told her "not to worry." Lewinsky
8/6/98 GJ at 209.

956. Lewinsky 8/6/98 GJ at 209.

957. See Telephone Calls, Table 37. In addition, Mr. Jordan placed a
two-minute call to a number at the White House Counsel's office from his
limousine at 6:39 p.m.

958. Jordan 5/28/98 GJ at 19.

959. Jordan 5/28/98 GJ at 20-21. Ms. Mills does not recall having any
discussions with Mr. Jordan about Ms. Lewinsky prior to January 17, 1998.
Indeed, she had no recollection of hearing Ms. Lewinsky's name prior to
January 17. Mills 8/11/98 GJ at 10-11.

960. Seidman 4/23/98 Depo. at 37-38.

961. Lewinsky 8/6/98 GJ at 210.

962. Lewinsky 8/6/98 GJ at 210.

963. Jordan 5/28/98 GJ at 30.

964. Jordan 5/28/98 at 39.

965. Jordan 5/28/98 GJ at 59. Mr. Jordan added that the President's
response was one of "appreciation, gratitude." Id.

966. 921-DC-00000770-72 (Clerk's minutes of in-camera hearing).

967. Sheldon 4/34/98 Depo. at 22.

968. Lewinsky 8/6/98 GJ at 214.

969. Lewinsky 8/6/98 GJ at 215.

970. 831-DC-00000010. At some point, Ms. Currie and Ms. Lewinsky decided
that they would use a code name -- Kay -- when leaving messages for each
other. Currie 7/22/98 GJ at 175; Lewinsky 8/6/98 GJ at 215-17.

971. Bowles 4/2/98 GJ at 78-79. Mr. Bowles placed this conversation with
the President at some time between January 4 and January 20. Bowles 4/2/98
GJ at 78. Mr. Podesta recalled that Mr. Bowles passed this request on to
him "three or four days before the President's deposition" -- that is,
January 13 or January 14, though Mr. Podesta did not know who had
originated the request. Podesta 6/16/98 GJ at 21-22.

972. Bowles 4/2/98 GJ at 78.

973. Bowles 4/2/98 GJ at 78-79; Podesta 6/16/98 GJ at 24-28; Hilley 2/11/98
Int. at 2; Hilley 5/26/98 GJ at 7-11.

974. Podesta 6/16/98 GJ at 24; Hilley 2/11/98 Int. at 2.

975. Hilley 2/11/98 Int. at 2; Hilley 5/26/98 GJ at 10-11; Hilley 5/19/98
GJ at 74-76. In the grand jury, Mr. Hilley testified: "At this time, I
don't recall that piece of the conversation [dealing with Ms. Lewinsky's
leaving Legislative Affairs under less than favorable circumstances] with
John Podesta." Id. at 76.

976. Lewinsky 8/6/98 GJ at 215. At 2:20 p.m., Ms. Currie paged Ms. Lewinsky
again: "Please call me. Kay." 831-DC-00000010. In the grand jury, Ms.
Currie stated that she could not remember whether the January 13
page-messages to Ms. Lewinsky involved attempts to notify her of the status
of the President's efforts to secure a letter of recommendation for her.
Currie 7/22/98 GJ at 147-48.

977. 830-DC-00000007.

978. Clinton 8/17/98 GJ at 111-13.

979. Lewinsky 8/6/98 GJ at 220-21. Mr. Jordan traveled to Florida in the
early afternoon. 1034-DC-00000109 (Mr. Jordan's day-planner). Soon after
arriving in Florida, he called Ms. Hernreich's line at the White House. See
Telephone Calls, Table 42. Later that evening, he spoke with the President
for nearly four minutes. 1064-DC-00000008 (Mr. Jordan's hotel bill). In the
grand jury, Mr. Jordan testified that it is "not inconceivable" that they
mentioned Ms. Lewinsky. Jordan 5/28/98 GJ at 69.

980. T30 at 61.

981. T30 at 114.

982. T30 at 169-70.

983. Lewinsky 8/6/98 GJ at 223-25; GJ Ex. ML-5.

984. Lewinsky 8/6/98 GJ at 223-37. Ms. Tripp, in contrast, testified that
she believed Ms. Lewinsky received assistance in drafting the talking
points. Tripp 7/29/98 GJ at 167, 171-172.

985. Currie 5/6/98 GJ at 120-21.

986. Currie 5/6/98 GJ at 130.

987. Akin, Gump records reflect that at some time this day Ms. Currie left
a message for Mr. Jordan. The message slip listed the name of the caller as
"Betty/Potus." The message was: "Kind of important."V005-DC-00000058.

988. Lewinsky 8/6/98 GJ at 229. Ms. Currie had immediately informed Ms.
Lewinsky of Mr. Isikoff's call. 831-DC-00000008 (Ms. Lewinsky's pager
records).

989. Jordan 3/5/98 GJ at 71.

990. Jordan 3/5/98 GJ at 71.

991. T22 at 12.

992. T22 at 12-13.

993. Ungvari 3/19/98 GJ at 61.

994. V0002-DC-00000093-116 (President Clinton's Responses to Plaintiff's
Second Set of Requests).

995. 1441-DC-00001534-46 (Second Set of Requests From Plaintiff to
Defendant Clinton for Production of Documents). Ms. Lewinsky's name was
misspelled on the document request as Ms. Lewisky.

996. 921-DC-00000775 - 778.

997. Carter 6/18/98 GJ at 123.

998. 921-DC-00000775. Although the motion (and affidavit) reached the
Judge's chambers on January 17, the file stamp date was January 20, 1998.

999. Clinton 1/17/98 Depo. at 1 (849-DC-00000352 et seq.).

1000. Clinton 1/17/98 Depo. at 1-2.

1001. Clinton 1/17/98 Depo. at 10.

1002. Clinton 1/17/98 Depo. at 22-23; 849-DC-00000586 (Clinton Depo. Ex.
1).

1003. Clinton 1/17/98 Depo. at 54.

1004. Clinton 1/17/98 Depo. at 54. In addition, as previously indicated,
Mr. Jordan believes he informed President Clinton on January 7 that Ms.
Lewinsky had signed an affidavit denying that there had been a sexual
relationship. Jordan 5/5/98 GJ at 223-25.

1005. Clinton 1/17/98 Depo. at 53-56.

1006. Clinton 1/17/98 Depo. at 50-51, 58-59.

1007. Clinton 1/17/98 Depo. at 52-53, 59.

1008. Clinton 1/17/98 Depo. at 59.

1009. Clinton 1/17/98 Depo. at 62-64.

1010. Clinton 1/17/98 Depo. at 75-77.

1011. Clinton 1/17/98 Depo. at 75-76.

1012. Clinton 1/17/98 Depo. at 75.

1013. Clinton 1/17/98 Depo. at 68.

1014. Clinton 1/17/98 Depo. at 68-71.

1015. Clinton 1/17/98 Depo. at 72, 79-83.

1016. Clinton 1/17/98 Depo. at 78.

1017. Clinton 1/17/98 Depo. at 212-13.

1018. Podesta 6/16/98 GJ at 62.

1019. Lindsey 2/19/98 GJ at 12-13. Mr. Lindsey refused to reveal the
content of these conversations with the President, citing the presidential
communication, deliberative process, and attorney-client privileges, both
officially and privately, as well as the attorney work product doctrine.
Id. at 13.

1020. Lindsey 2/19/98 GJ at 14-15.

1021. See Telephone Table 46, Call 4; Currie 1/27/98 GJ at 65-66; Currie
5/7/98 GJ at 79-85; Currie 7/22/98 GJ at 154. See also Currie 1/24/98 Int.
at 5-6 ("CURRIE advised that sometime late that evening, she received a
telephone call from CLINTON. CURRIE advised that CLINTON said he and CURRIE
needed to talk. CURRIE advised it was too late to do anything that evening,
so she and CLINTON agreed to meet at the White House at 5 p.m. the
following day, Sunday, January 18, 1998."). Presidential call logs reflect
that the President attempted to call Ms. Currie at 7:02 p.m. on January 17,
1998, and that he spoke to her for two minutes at 7:13 p.m.
1248-DC-00000307.

1022. Currie 5/7/98 GJ at 91. Also that evening, the President called Mr.
Jordan, who testified that they did not discuss the afternoon deposition.
See Telephone Table 46, Call 2; Jordan 5/28/98 GJ at 94-95.

1023. Currie 1/27/98 GJ at 70.

1024. Currie 1/27/98 GJ at 67.

1025. Currie 1/27/98 GJ at 76.

1026. Currie 1/27/98 GJ at 70, 76; 7/22/98 GJ at 6, 22. Presidential call
logs reflect that the President called Ms. Currie before their meeting and
spoke to her from 1:11 p.m. to 1:14 p.m. on January 18. 1248-DC-00000313.

1027. Currie 1/27/98 GJ at 70.

1028. Currie 1/27/98 GJ at 73 ("[M]y impression was that he was just making
statements.").

1029. Currie 1/24/98 Int. at 6-7. The President repeated these statements
to Ms. Currie a few days later. See infra.

1030. Currie 1/27/98 GJ at 71-74; 7/22/98 GJ at 6-7, 10-11, 79. See also
Clinton 8/17/98 GJ at 55-57. According to Ms. Currie, the way the President
phrased the inquiries made them sound like both questions and statements at
the same time. Currie 1/24/98 Int. at 6.

1031. Currie 1/27/98 GJ at 74-75. Ms. Currie's testimony that the President
wanted her to agree with his statements shifted somewhat between her first
grand jury appearance and her last, which occurred five months later. On
January 27, 1998, nine days after her conversation with the President, Ms.
Currie testified that she understood from the President's questions that he
wanted her to agree with him. Currie 1/27/98 GJ at 72-76. By July 22, 1998,
however, Ms. Currie claimed that although the President stated "right?" at
the end of the statements, Ms. Currie understood that she could agree or
disagree with them. Currie 7/22/98 GJ at 23. Ms. Currie indicated during
her first grand jury appearance that her memory about the events was
"getting worse by the minute." Currie 1/27/98 GJ at 71. Later, Ms. Currie
acknowledged that "closer to the event my recollection would be better."
Currie 7/22/98 GJ at 182-183.

1032. Currie 1/27/98 GJ at 71, 75.

1033. Currie 7/22/98 GJ at 65-66. Indeed, she testified that, at some point
after January 18, she heard that Ms. Lewinsky visited the Oval Office on
Saturdays, one of her days off. Currie 7/22/98 GJ at 65-66.

1034. Currie 1/27/98 GJ at 32-33; 36-38.

1035. Currie 7/22/98 GJ at 12, 15-6; Currie 1/27/98 GJ at 76.

1036. Currie 7/22/98 GJ at 14. The President, apparently, had a similar
understanding of "alone." Before the grand jury, the President explained
that "when I said, we were never alone, right . . . I meant that she [Ms.
Currie] was always in the Oval Office complex, in that complex, while
Monica was there." Clinton 8/17/98 GJ at 132.

Elsewhere in her testimony, Ms. Currie appeared to have a different
understanding of "alone." She testified that, on one occasion, because
others observed Ms. Lewinsky in the Oval Office complex, Ms. Currie
accompanied Ms. Lewinsky into the Oval Office, where the President was
working. Ms. Currie explained that she waited in the dining room while Ms.
Lewinsky and the President met in the study so "[t]hey would not be alone."
Currie 7/22/98 GJ at 130. See also Clinton 8/17/98 GJ at 56 ("I asked her
specifically . . . to remain in the dining room, Betty, while I met with
Monica in my study."). Ms. Currie testified that she did not want people
who had observed Ms. Lewinsky enter the Oval Office to think that she and
the President were "alone." Currie 7/22/98 GJ at 132.

1037. Currie 7/22/98 GJ at 79. Ms. Currie testified: "The way the question
was phrased to me at the time, I answered, 'Right.' It seemed to me that
was the correct answer for me to give . . . the '[c]ome on to me,' I
considered that more of a statement as opposed to a question." Id. at 80.

1038. Currie 1/27/98 GJ at 75.

1039. Currie 1/27/98 GJ at 83.

1040. Currie 1/27/98 GJ at 72-73; 7/22/98 GJ at 7, 10-11. Ms. Currie
testified that the President made this statement in a way that did not
invite her agreement. Rather, "I would call it a statement, sir." Currie
1/27/98 GJ at 73.

1041. Clinton 8/17/98 GJ at 57.

1042. Clinton 8/17/98 GJ at 132.

1043. Clinton 8/17/98 GJ at 55.

1044. Clinton 8/17/98 GJ at 141.

1045. Clinton 8/17/98 GJ at 55.

1046. Clinton 8/17/98 GJ at 135-36 ("As far as I know, she is unaware of
what happened on the, on the occasions when I saw her in 1996 when
something improper happened. And she was unaware of the one time that I
recall in 1997 when something happened.").

1047. Clinton 8/17/98 GJ at 38.

1048. Clinton 8/17/98 GJ at 57-58, 132.

1049. Clinton 8/17/98 GJ at 133.

1050. Clinton 8/17/98 GJ at 133.

1051. Clinton 8/17/98 GJ at 135.

1052. Clinton 8/17/98 GJ at 139. The President referred to a statement he
delivered in the beginning of his grand jury appearance: "[B]ecause of
privacy considerations affecting my family, myself, and others, and in an
effort to preserve the dignity of the office I hold, this is all I will say
about the specifics of these particular matters." Clinton 8/17/98 GJ at 10.

1053. At 5:12 p.m., Ms. Currie paged Ms. Lewinsky, leaving the message:
"Please call Kay at home." At 6:22 p.m., Ms. Currie paged Ms. Lewinsky:
"Please call Kay at home." At 7:06 p.m., Ms. Currie paged Ms. Lewinsky:
"Please call Kay at home." At 8:28 p.m., Ms. Currie paged Ms. Lewinsky:
"Call Kay." 831-DC-00000008 (Ms. Lewinsky's pager records) (Ms. Lewinsky's
pager recorded calls in Pacific time). See also Currie 5/7/98 GJ at 96-97;
7/22/98 GJ at 156, 158.

1054. Currie 5/7/98 GJ at 99-100.

1055. Telephone Calls, Table 47, Call 11. See also Currie 7/22/98 GJ at
161-62.

1056. See Telephone Calls, Table 48. At 7:02 a.m. she paged Ms. Lewinsky,
leaving the message: "Please call Kay at home at 8:00 this morning." At
8:08 a.m., Ms. Currie paged Ms. Lewinsky again. After calling Ms.
Lewinsky's home number at 8:29 a.m., Ms. Currie paged Ms. Lewinsky again at
8:33 a.m. Four minutes later, Ms. Currie paged yet again, leaving the
message: "Please call Kay at home. It's a social call. Thank you." (Ms.
Currie testified that these calls were, in fact, not of a social nature.
Currie 7/22/98 GJ at 161). Receiving no response, Ms. Currie paged Ms.
Lewinsky again at 8:41 a.m. She then placed a one-minute call to the
President. Currie 5/7/98 GJ at 104-05; 7/22/98 GJ at 160-62.

1057. Currie 7/22/98 GJ at 162-63. This time, Ms. Currie left a more urgent
message: "Please call Kay re: family emergency." 831-DC-00000009 (Ms.
Lewinsky's pager records). See Telephone Calls, Table 48, Call 7.

1058. Currie 7/22/98 GJ at 157-59; 164-66.

1059. Jordan 6/9/98 GJ at 17. See also Telephone Calls, Table 48
(831-DC-00000009) (Ms. Lewinsky's pager records).

1060. Jordan 6/9/98 GJ at 38-39.

1061. Carter 6/18/98 GJ at 146.

1062. Jordan 6/9/98 GJ at 54-55.

1063. Schmidt, Baker, and Locy, "Clinton Accused of Urging Aide To Lie,"
Wash. Post, Jan. 21, 1998, at A1.

1064. Podesta 6/23/98 GJ at 12.

1065. See Telephone Calls, Table 50.

1066. Mr. Bennett was apparently referring to Ms. Lewinsky's affidavit.

1067. Clinton Accused at A1.

1068. Mr. Lindsey, on instructions from the President, see Lindsey 8/28/98
GJ at 23, has invoked the presidential communication privilege, the
deliberative process privilege, the governmental attorney-client privilege,
and President Clinton's personal attorney-client privilege with regard to
conversations with the President and has thus refused to disclose what the
President said to him on January 21. Lindsey 2/19/98 GJ at 42. Mr. Lindsey
has testified, however, that based on the President's public statements and
statements made to others in Lindsey's presence, the President misled him
about the nature of his relationship with Ms. Lewinsky. Lindsey 8/28/98 GJ
at 93-96, 101.

1069. Currie 5/7/98 GJ at 112-14.

1070. Lindsey 8/28/98 GJ at 90. Mr. Lindsey, citing privileges, refused to
testify about the substance of this conversation.

1071. 1034-DC-00000111 (Mr. Jordan's calendar). See also Jordan 3/5/98 GJ
at 79 (St. Regis Hotel), 160-61 (New York), 179 (the President's phone
call); Jordan 6/9/98 GJ at 76.

1072. See Telephone Calls, Table 50, Call 6. See also Lindsey 8/28/98 GJ at
90. Mr. Lindsey asserted privileges over this conversation as well.

1073. White House Press Conference (Mike McCurry), Jan. 21, 1998.

1074. Lindsey 8/28/98 GJ at 11-12.

1075. Bowles 4/2/98 GJ at 84. See also Podesta 6/16/98 GJ at 85-86.

1076. Ickes 6/10/98 GJ at 73.

1077. Ms. Currie could not recall whether the President called her into the
Oval Office to discuss Ms. Lewinsky on Tuesday, January 20, or Wednesday,
January 21. Currie 1/27/98 GJ at 80-81.

1078. Currie 1/27/98 GJ at 80-81.

1079. Currie 1/27/98 GJ at 81.

1080. Currie 1/24/98 Int. at 8. The President did not specifically recall
this second conversation with Ms. Currie, but did not dispute that it took
place: "I do not remember how many times I talked to Betty Currie or when.
I don't. I can't possibly remember that. I do remember when I first heard
about this story breaking, trying to ascertain what the facts were, trying
to ascertain what Betty's perception was." Clinton 8/17/98 GJ at 141-42.

1081. Blumenthal 2/26/98 GJ at 19.

1082. Blumenthal 6/4/98 GJ at 48-49. When later asked how he interpreted
the President's statement, "I haven't done anything wrong," Mr. Blumenthal
stated, "My understanding was that the accusations against him which
appeared in the press that day were false, that he had not done anything
wrong. . . . He had not had a sexual relationship with her, and had not
sought to obstruct justice or suborn perjury." Blumenthal 6/25/98 GJ at 26.

1083. Blumenthal 6/4/98 GJ at 49. The President said, "I've gone down that
road before, I've caused pain for a lot of people and I'm not going to do
that again." Blumenthal 6/4/98 GJ at 49. Mr. Blumenthal "understood [this
statement] to mean that he had had an adulterous relationship in the past,
which is something he made very plain to the American people in his "60
Minutes" interview with the First Lady, which is how he introduced himself
to the public . . . . And it's been very well known." Blumenthal 6/25/98 GJ
at 32.

1084. Blumenthal 6/4/98 GJ at 49.

1085. Blumenthal 6/4/98 GJ at 50.

1086. Blumenthal 6/4/98 GJ at 49-50; Blumenthal 6/25/98 GJ at 15, 51.

1087. Podesta 6/16/98 GJ at 92.

1088. Podesta 6/16/98 GJ at 92. The President made another misleading
statement about his relationship with Ms. Lewinsky to Mr. Podesta a few
weeks later. According to Mr. Podesta, "[h]e said to me that after she [Ms.
Lewinsky] left [the White House], that when she had come by, she came by to
see Betty, and that he -- when she was there either Betty was with them --
either that she was with Betty when he saw her or that he saw her in the
Oval Office with the door open and Betty was around -- and Betty was out at
her desk." Podesta 6/16/98 GJ at 88.

1089. Clinton 8/17/98 GJ at 101-09.

1090. Clinton 8/17/98/ GJ at 101, 106. The President was asked specifically
whether he denied telling Mr. Podesta that he did not have any kind of sex
whatsoever, including oral sex, with Ms. Lewinsky. The President responded:
"I'm not saying that anybody who had a contrary memory is wrong. I do not
remember." Clinton 8/17/98 GJ at 105.

1091. In claiming that this statement was true, the President was
apparently relying on the same tense-based distinction he made during the
Jones deposition. See Clinton 8/17/98 GJ at 59-61 ("It depends on what the
meaning of the word 'is' is. If the -- if he -- if 'is' means is and never
has been, that is not -- that is one thing. If it means there is none, that
was a completely true statement. . . . Now, if someone had asked me on that
day, are you having any kind of sexual relations with Ms. Lewinsky, that
is, asked me a question in the present tense, I would have said no. And it
would have been completely true.")

1092. Clinton 8/17/98 GJ at 107.

1093. Clinton 8/17/98 GJ at 107.

1094. Broadcast on "All Things Considered" on National Public Radio, 5:07
p.m., Wednesday, January 21, 1998.

1095. "The News Hour with Jim Lehrer," PBS, interview with President Bill
Clinton by Jim Lehrer, Wednesday, January 21, 1998. As evidenced by his
grand jury testimony, the President is attentive to matters of verb tense.
Clinton 8/17/98 GJ at 59.

1096. Televised Remarks by President Clinton at Photo Opportunity at the
White House with Palestinian Authority Chairman Yasser Arafat, January 22,
1998, 10:22 a.m.

1097. Roll Call, Inc., January 22, 1998; transcript of press conference.

1098. "All Things Considered," January 21, 1998.

1099. "The News Hour," January 21, 1998.

1100. Televised Remarks By President Clinton at Photo Opportunity at the
White House with Palestinian Authority Chairman Yasser Arafat, January 22,
1998, 10:22 a.m.

1101. Roll Call, Inc., January 22, 1998. President Clinton was extended
invitations to appear before the grand jury and give his testimony on:
January 28, 1998; February 4, 1998; February 9, 1998; February 21, 1998;
March 2, 1998; and March 13, 1998. He declined all of these invitations. On
July 16, 1998, the grand jury issued the President a subpoena. The
President promptly moved for a postponement of two weeks in which to
respond. At a hearing on the President's motion, Chief Judge Norma Holloway
Johnson stated, "What we need to do is to move forward and move forward
expeditiously. . . . [A]pparently the grand jury has determined that [they]
need to hear from the [President]." In re Grand Jury Proceedings, Misc. No.
98-267, July 28, 1998, at pp. 27-28. Before Judge Johnson ruled, the
President's attorneys negotiated the terms of the President's appearance.

1102. Morris 8/18/98 GJ at 6, 10, 12. Mr. Morris was questioned after the
President's grand jury appearance on August 17, 1998; accordingly, the OIC
never had an opportunity to question the President about this conversation.

1103. Morris 8/18/98 GJ at 14.

1104. Mr. Morris testified that he interpreted the "something" to be sexual
in nature. Morris 8/18/98 GJ at 94.

1105. Morris 8/18/98 GJ at 14.

1106. Morris 8/18/98 GJ at 15.

1107. Morris 8/18/98 GJ at 15-16.

1108. Morris 8/18/98 GJ at 17.

1109. Morris 8/18/98 GJ at 28.

1110. Morris 8/18/98 GJ at 30.

1111. Morris 8/18/98 GJ at 34. Mr. Morris believed that Ms. Lewinsky's
credibility was in question based on a claim by a USA Today reporter that
there was an occasion when the President and Mr. Morris spoke on the
telephone while they each were involved in a sexual encounter. The
President was reportedly "having sex" with Ms. Lewinsky while Mr. Morris
was allegedly involved with a prostitute at the Jefferson Hotel. Morris
8/18/98 GJ at 32, 34.

1112. Morris 8/18/98 GJ at 35.

1113. Thomason 8/11/98 GJ at 6.

1114. Although Mr. Thomason originally offered to stay with the President
for a "couple of days," he stayed at the White House Residence for 34 days.
Thomason 8/11/98 GJ at 6, 10. Mr. Thomason testified that while "not
particularly an expert in media matters . . . my wife and I seem to have a
feel of what the rest of America is thinking. . . ." Thomason 8/11/98 GJ at
24.

1115. Thomason 8/11/98 GJ at 15-16. Mr. Thomason said he "went on the
assumption that [the allegations] were not true," but he never asked the
President because he talked to his attorney, Robert Bennett (also the
President's personal attorney), who advised him "to make sure you don't ask
questions that will get you subpoenaed." Id. at 22, 27. Mr. Thomason also
testified he did not ask the President whether the denial was true because
"I wanted it to be true and I felt it not to be true." Id. at 32-33.

1116. Thomason 8/11/98 GJ at 15.

1117. Thomason 8/11/98 GJ at 27.

1118. Schmidt and Baker, "Ex-Intern Rejected Immunity Offer in Probe,"
Wash. Post, Jan. 24, 1998, at A1.

1119. Schmidt and Baker, "Ex-Intern Rejected Immunity Offer," at A1.

1120. Larry King Weekend, Jan. 24, 1998, Transcript No. 98012400V42.

1121. In fact, the President did draw a distinction between "is" and "was."
See Clinton 8/17/98 GJ at 59.

1122. Larry King Weekend, Jan. 24, 1998, Transcript No. 98012400V42.

1123. Televised Remarks by President Clinton at the White House Education
News Conference, Monday, January 26, 1998, 10:00 a.m. See Chi. Tribune,
Jan. 27, 1998, at 1 ("A defiant President Clinton wagged his finger at the
cameras and thumped the lectern Monday as he insisted he did not have sex
with a young White House intern or ask her to deny it under oath.").