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 Narrative Footnotes From independent counsel Kenneth Starr's report to the House on President Clinton. Some of the language in these documents is sexually explicit.
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.
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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.
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.
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.
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.
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).
| ||
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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).
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.
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).
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.
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.
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 |