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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.

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1. Lewinsky 8/6/98 GJ at 31-32, 39-40; DB Photos 0004 (photo of dress).
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2. FBI Lab Report, 8/3/98.
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3. OIC letter to David Kendall, 7/31/98 (1st letter of day).
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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.
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5. FBI Observation Report (White House), 8/3/98.
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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).
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7. FBI Lab Report, 8/17/98, at 2.
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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.
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9. Ex. ML-7 to Lewinsky 8/6/98 GJ.
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10. Lewinsky 8/26/98 Depo. at 5-6; Lewinsky 8/6/98 GJ at 27-28.
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11. Lewinsky 8/26/98 Depo. at 69.
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12. Lewinsky 8/6/98 GJ at 59-60, 87; Lewinsky 8/20/98 GJ at 82; Lewinsky 8/24/98 Int. at 8.
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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.
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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.
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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.
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16. Catherine Davis 3/17/98 GJ at 21-22.
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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.
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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").
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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.
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21. Clinton 1/17/98 Depo. at 54.
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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.
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23. Clinton 8/17/98 GJ at 10, 79, 81.
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24. Clinton 8/17/98 GJ at 10.
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25. Clinton 8/17/98 GJ at 31, 10. See also id. at 38-39.
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26. Clinton 8/17/98 GJ at 10, 92-93.
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27. Clinton 8/17/98 GJ at 22.
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28. Clinton 8/17/98 GJ at 10, 12, 93-96.
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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.
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30. Clinton 8/17/98 GJ at 15, 93, 100, 102.
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31. Clinton 8/17/98 GJ at 151.
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32. Clinton 8/17/98 GJ at 168.
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33. Clinton 8/17/98 GJ at 102-105, 167-68.
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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").
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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.
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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.
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37. Lewinsky 8/6/98 GJ at 35; Lewinsky 7/27/98 Int. at 2.
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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.
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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).
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40. Lewinsky 8/6/98 GJ at 38-39. See also Lewinsky 8/20/98 GJ at 24.
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41. Lewinsky 8/6/98 GJ at 19-20, 38-39; Ungvari 3/19/98 GJ at 23-24.
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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.
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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.
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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.
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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.
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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.
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47. Lewinsky 8/6/98 GJ at 18.
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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.
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49. Lewinsky 7/27/98 Int. at 6.
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50. Lewinsky 8/26/98 Depo. at 55-57; Lewinsky 7/27/98 Int. at 6.
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51. Marcia Lewis 2/11/98 GJ at 7-8.
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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.
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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.
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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.
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55. Lewinsky 8/6/98 GJ at 52-53.
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56. Lewinsky 8/6/98 GJ at 52.
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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.
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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.
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59. Lewinsky 8/20/98 GJ at 55.
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60. Lewinsky 8/6/98 GJ at 23.
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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).
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62. Lewinsky 7/30/98 Int. at 15.
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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.
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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.
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65. Lewinsky 8/6/98 GJ at 67-69.
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66. Lewinsky 8/6/98 GJ at 74-75.
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67. Lewinsky 8/6/98 GJ at 114.
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68. Clinton 8/17/98 GJ at 10.
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69. Clinton 8/17/98 GJ at 47, 51.
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70. Clinton 8/17/98 GJ at 47, 124.
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71. Lewinsky 8/6/98 GJ at 25-26.
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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!").
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73. V006-DC-00000167; V006-DC-00000181 (gift record and donor information); V006-DC-00003646 (correspondence history).
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74. V006-DC-00000157 - 158 (gift record and donor information).
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75. Lewinsky 8/11/98 Int. at 2; V006-DC-00000178 (autographed photo).
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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.
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77. MSL-55-DC-0177.
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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.
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79. Lewinsky 8/26/98 Depo. at 5-6 & Ex. ML-7.
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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.
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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.
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82. Lewinsky 8/6/98 GJ at 236.
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83. Clinton 8/17/98 GJ at 47. See also id. at33-36, 43-46.
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84. Lewinsky 8/6/98 GJ at 26.
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85. Lewinsky 8/6/98 GJ at 189.
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86. Lewinsky 8/6/98 GJ at 26-27.
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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.
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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.
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89. Lewinsky 8/6/98 GJ at 78, 97-101; Lewinsky 7/27/98 Int. at 3.
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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).
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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.
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92. Lewinsky 8/6/98 GJ at 234.
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93. Clinton 8/17/98 GJ at 38.
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94. Clinton 8/17/98 GJ at 38, 119. See also id. at 80, 119, 136, 153.
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95. Clinton 8/17/98 GJ at 37.
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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.
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97. Lewinsky 8/6/98 GJ at 53-54.
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98. Lewinsky 8/6/98 GJ at 54.
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99. Lewinsky 8/6/98 GJ at 54-55; Lewinsky 7/30/98 Int. at 10.
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100. Lewinsky 8/6/98 GJ at 54-55.
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101. Lewinsky 8/6/98 GJ at 18, 53-54.
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102. Lewinsky 8/6/98 GJ at 18-19; Lewinsky 2/1/98 Statement at 1.
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103. Lewinsky 8/20/98 GJ at 105; Lewinsky 2/1/98 Statement at 1.
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104. Lewinsky 8/20/98 GJ at 22.
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105. Lewinsky 2/1/98 Statement at 4; Lewinsky 8/6/98 GJ at 123, 233.
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106. Clinton 1/17/98 Depo. at 50-51, 68.
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107. Clinton 8/17/98 GJ at 118-19.
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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").
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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.
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110. Lewinsky 8/6/98 GJ at 18. See also Lewinsky 8/20/98 GJ at 7, 22.
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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).
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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.
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113. Lewinsky 7/31/98 Int. at 4.
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114. Lewinsky 8/4/98 Int. at 4.
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115. Lewinsky 8/6/98 GJ at 36. See also Lewinsky 7/31/98 Int. at 4.
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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.
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117. Lewinsky 8/6/98 GJ at 56. See also Lewinsky 7/31/98 Int. at 3.
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118. Lewinsky 7/31/98 Int. at 3.
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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.
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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.").
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121. Lewinsky 8/6/98 GJ at 56.
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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.
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123. Lewinsky 8/24/98 Int. at 8.
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124. Clinton 8/17/98 GJ at 50. See also id. at 130-131.
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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.
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126. T30 at 41.
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127. T30 at 41.
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128. T30 at 41-42.
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129. T22 at 12.
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130. T22 at 12.
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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).
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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).
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133. Lewinsky 8/3/98 Int. at 2.
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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).
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135. Lewinsky 8/26/98 Depo. at 60.
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136. Lewinsky 8/6/98 GJ at 10.
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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).
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138. Lewinsky 8/26/98 Depo. at 16-17 & Ex. ML-7.
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139. Finerman 3/18/98 Depo. at 10-11; Ungvari 3/19/98 GJ at 15-17.
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140. Facts on File 852, 868 (1995).
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141. Washington Post, 11/20/95 at A19; Los Angeles Times, 11/14/95 at A15; USA Today, 11/17/95 at 4A.
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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.
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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).
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144. Lewinsky 8/6/98 GJ at 11.
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145. Lewinsky 8/3/98 Int. at 2; Barry Toiv 3/11/98 Int. at 1 (job title).
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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.
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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.
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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.
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149. Lewinsky 7/27/98 Int. at 2; Lewinsky 8/24/98 Int. at 5.
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150. Lewinsky 7/30/98 Int. at 5; Lewinsky 8/11/98 Int. at 7; Erbland 2/12/98 GJ at 24-25.
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151. Lewinsky 8/6/98 GJ at 11; Lewinsky 7/27/98 Int. at 2; Lewinsky 7/30/98 Int. at 5.
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152. Lewinsky 8/6/98 GJ at 11; Lewinsky 7/27/98 Int. at 2; Lewinsky 7/30/98 Int. at 5.
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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.
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154. Lewinsky 7/30/98 Int. at 5.
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155. Lewinsky 8/26/98 Depo. at 7.
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156. Lewinsky 8/6/98 GJ at 12; Lewinsky 7/30/98 Int. at 5.
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157. Lewinsky 8/26/98 Depo. at 7.
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158. Lewinsky 8/26/98 Depo. at 7; Lewinsky 8/6/98 GJ at 12, 13.
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159. Lewinsky 8/26/98 Depo. at 8; Lewinsky 7/30/98 Int. at 5.
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160. Lewinsky 8/26/98 Depo. at 7-8.
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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.
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162. Lewinsky 8/6/98 GJ at 12-14; Lewinsky 8/26/98 Depo. at 9-10; Lewinsky 7/30/98 Int. at 6.
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163. Lewinsky 8/26/98 Depo. at 10.
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164. Lewinsky 8/26/98 Depo. at 11.
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165. Lewinsky 9/3/98 Int. at 3; Lewinsky 8/24/98 Int. at 5; Lewinsky 7/30/98 Int. at 6.
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166. Lewinsky 8/6/98 GJ at 11-12; Lewinsky 8/26/98 Depo. at 7.
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167. 1362-DC-00000549 (movement logs).
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168. Lewinsky 7/30/98 Int. at 6.
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169. 1472-DC-00000006 - 08. Starting 11 minutes later, the President talked with other Members of Congress. Id.
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170. 827-DC-00000008 (Epass records).
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171. 1222-DC-00000085 (movement logs).
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172. Lewinsky 8/6/98 GJ at 14. See also Lewinsky 7/30/98 Int. at 6-7.
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173. Lewinsky 8/6/98 GJ at 14-15; Lewinsky 7/30/98 Int. at 7.
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174. Lewinsky 8/6/98 GJ at 15-16.
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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.
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176. Lewinsky 8/6/98 GJ at 16; Lewinsky 8/26/98 GJ at 11-15; Lewinsky 7/30/98 Int. at 7.
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177. Lewinsky 8/26/98 Depo. at 12-13; Lewinsky 7/30/98 Int. at 7.
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178. Lewinsky 8/26/98 Depo. at 12; Lewinsky 7/30/98 Int. at 7.
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179. Lewinsky 7/30/98 Int. at 7.
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180. Lewinsky 8/26/98 Depo. at 13-14.
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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.
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182. Lewinsky 7/30/98 Int. at 7. See also Lewinsky 8/26/98 Depo. at 15.
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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.
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184. Clinton 1/17/98 Depo. at 58.
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185. Clinton 8/17/98 GJ at 31-32.
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186. 827-DC-00000011 (Epass records).
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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).
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188. Lewinsky 8/26/98 Depo. at 15-16; Lewinsky 7/27/98 Int. at 3-4; Lewinsky 7/30/98 Int. at 8.
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189. Lewinsky 8/26/98 Depo. at 16.
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190. Lewinsky 8/26/98 Depo. at 16; Lewinsky 7/27/98 Int. at 3-4; Lewinsky 7/30/98 Int. at 8.
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191. Lewinsky 8/26/98 Depo. at 16.
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192. Lewinsky 8/26/98 Depo. at 16-17. See also Lewinsky 7/30/98 Int. at 8.
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193. Lewinsky 7/27/98 Int. at 3-4; Lewinsky 7/30/98 Int. at 8.
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194. Lewinsky 8/26/98 Depo. at 17. See also Finerman 3/18/98 Depo. at 30-32, 35.
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195. Lewinsky 7/30/98 Int. at 3.
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196. 1222-DC-00000325 (Secret Service duty logs).
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197. Clinton 8/17/98 GJ at 31-32.
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198. Clinton 8/17/98 GJ at 9-10.
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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.
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200. Clinton 8/17/98 GJ at 10.
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201. As noted above, White House entry and exit records are incomplete.
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202. 1222-DC-00000183 (movement logs).
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203. Lewinsky 8/26/98 Depo. at 18. See also Lewinsky 7/30/98 Int. at 2, 8.
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204. Lewinsky 8/26/98 Depo. at 18.
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205. Lewinsky 8/26/98 Depo. at 19.
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206. Lewinsky 8/26/98 Depo. at 19.
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207. Lewinsky 8/26/98 Depo. at 19.
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208. Lewinsky 8/26/98 Depo. at 19.
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209. Lewinsky 8/26/98 Depo. at 20. They engaged in oral-anal contact as well. Id.
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210. Lewinsky 8/26/98 Depo. at 38.
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211. 1222-DC-00000325, 1362-DC-00001171 (Secret Service duty logs).
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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.
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213. Fox 2/17/98 GJ at 31.
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214. Fox 2/17/98 GJ at 60-61, 66-67.
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215. Fox 2/17/98 GJ at 33.
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216. Fox 2/17/98 GJ at 19-20, 42, 49-50.
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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.
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218. 827-DC-00000013 (Epass records).
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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).
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220. Lewinsky 7/30/98 Int. at 9; Lewinsky 8/24/98 Int. at 6.
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221. Lewinsky 8/26/98 Depo. at 22-23.
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222. Lewinsky 8/26/98 Depo. at 23.
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223. Lewinsky 8/26/98 Depo. at 23.
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224. Lewinsky 8/26/98 Depo. at 23-24. See also Lewinsky 7/30/98 Int. at 10.
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225. Lewinsky 8/26/98 Depo. at 24-25.
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226. Lewinsky 8/26/98 Depo. at 25.
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227. Lewinsky 8/26/98 Depo. at 26.
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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).
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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).
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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).
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231. 1222-DC-00000196 (movement logs).
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232. 1506-DC-00000068 (phone logs).
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233. Lewinsky 8/26/98 Depo. at 28-29; Lewinsky 8/24/98 Int. at 6.
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234. Lewinsky 8/26/98 Depo. at 29-30.
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235. Lewinsky 8/26/98 Depo. at 30-31.
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236. Lewinsky 8/26/98 Depo. at 31-32. They engaged in oral-anal contact as well. Id. at 30-31.
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237. Lewinsky 8/26/98 Depo. at 33.
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238. Lewinsky 8/26/98 Depo. at 33-34.
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239. Lewinsky 8/26/98 Depo. at 33.
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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).
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241. 1222-DC-00000197, 1222-DC-00000102 (movement logs).
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242. 1506-DC-00000102 (phone logs).
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243. Lewinsky 7/30/98 Int. at 11; Lewinsky 8/24/98 Int. at 6.
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244. Lewinsky 7/30/98 Int. at 3, 11-12.
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245. Lewinsky 7/30/98 Int. at 3, 11.
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246. Lewinsky 8/6/98 GJ at 24; Lewinsky 7/29/98 Int. at 3.
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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.
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248. Lewinsky 8/24/98 Int. at 6. See also Lewinsky 7/30/98 Int. at 11.
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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.
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250. Garabito 7/30/98 GJ at 25, 30-31.
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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.
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252. 1472-DC-00000017 (call logs).
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253. 1506-DC-00000017 (call logs).
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254. Forbes, 9/22/97 at 2.
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255. Lewinsky 8/6/98 GJ at 90.
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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.
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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).
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258. Ungvari 3/19/98 GJ at 30.
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259. Lewinsky 8/11/98 Int. at 2.
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260. Lewinsky 8/20/98 GJ at 19; Lewinsky 7/30/98 Int. at 12; 845-DC-00000010 - 11 (Tripp notes).
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261. Lewinsky 8/26/98 Depo. at 34-35.
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262. 1222-DC-00000112 (movement logs). The President and 32 guests saw Executive Decision that evening. 1506-DC-00000558 (White House daily diary).
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263. 968-DC-00003459 (Hillary Clinton calendar).
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264. Lewinsky 7/29/98 Int. at 3; Lewinsky 7/30/98 Int. at 12-13.
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265. 827-DC-00000016 (Epass records).
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266. 1222-DC-00000216 - 217; 1222-DC-00000112 - 113 (movement logs).
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267. 1506-DC-00000139 (phone logs).
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268. 968-DC-00003459 (Hillary Clinton calendar). Mrs. Clinton returned that evening. 1506-DC-00000559 (White House diary); 1222-DC-00000041 (Secret Service itinerary).
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269. Lewinsky 8/26/98 Depo. at 35-36.
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270. Lewinsky 8/26/98 Depo. at 36; Lewinsky 7/30/98 Int. at 12.
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271. Lewinsky 8/26/98 Depo. at 38-39.
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272. Lewinsky 8/26/98 Depo. at 37.
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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.
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274. Lewinsky 7/30/98 Int. at 13.
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275. Fox 2/17/98 GJ at 42-43.
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276. Ludtke 6/5/98 Int. at 1-2.
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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.
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278. Lewinsky 8/20/98 GJ at 12.
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279. Bordley 8/13/98 GJ at 9-16.
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280. Bordley 8/13/98 GJ at 20-23, 29.
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281. Bordley 8/13/98 GJ at 25-29.
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282. Ferguson 7/17/98 GJ at 14-17, 27-28; Ferguson 7/23/98 GJ at 14-17, 20.
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283. Ferguson 7/17/98 GJ at 27.
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284. Ferguson 7/17/98 GJ at 27-28; Ferguson 7/23/98 GJ at 20-21.
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285. Ferguson 7/17/98 GJ at 29, 31.
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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.
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287. Byrne 3/13/98 Depo. at 27-28, 46-47, 51-55; Byrne 6/25/98 Depo. at 31.
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288. Lewinsky 8/20/98 GJ at 10-11; Lewinsky 7/31/98 Int. at 6.
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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.
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290. Lewinsky 8/20/98 GJ at 8.
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291. Lieberman 1/30/98 GJ at 41.
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292. Panetta 1/28/98 GJ at 139-42.
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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").
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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.
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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.
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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.
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297. Duncan 2/18/98 GJ at 24.
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298. V006-DC-00001347.
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299. Duncan 2/18/98 GJ at 13-14.
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300. Duncan 2/18/98 GJ at 23, 41.
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301. Duncan 2/18/98 GJ at 8, 23-24.
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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).
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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.
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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.
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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.
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306. Lewinsky 8/26/98 Depo. at 60.
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307. Lewinsky 8/6/98 GJ at 62.
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308. 827-DC-00000016 (Epass records).
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309. 1222-DC-00000219 (movement log).
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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.
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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.
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312. Lewinsky 7/27/98 Int. at 4.
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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.
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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.
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315. Lewinsky 8/6/98 GJ at 64.
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316. Clinton 8/17/98 GJ at 130.
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317. Lewinsky 8/26/98 Depo. at 40.
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318. Lewinsky 8/6/98 GJ at 94-97.
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319. Lewinsky 8/26/98 Depo. at 40-41.
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320. Lewinsky 8/26/98 Depo. at 41.
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321. Lewinsky 8/26/98 Depo. at 41.
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322. Lewinsky 8/6/98 GJ at 20, 95-97; Lewinsky 7/30/98 Int. at 13.
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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.
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324. Lewinsky 8/6/98 GJ at 92; Lewinsky 7/27/98 Int. at 4-5; Lewinsky 7/30/98 Int. at 13.
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325. 1248-DC-00000008 (phone logs).
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326. Lewinsky 8/6/98 GJ at 93, 97.
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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.
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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.
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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).
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330. Muskett 7/21/98 GJ at 9-13.
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331. Muskett 7/21/98 GJ at 22-24.
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332. Muskett 7/21/98 GJ at 25-26, 83.
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333. Muskett 7/21/98 GJ at 27-28, 91-93.
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334. Muskett 7/21/98 GJ at 28, 31-33.
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335. Muskett 7/21/98 GJ at 34-37.
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336. Lewinsky 8/6/98 GJ at 36-37; Lewinsky 7/27/98 Int. at 2.
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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.
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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.
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339. Muskett 7/21/98 GJ at 47-52, 89.
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340. 1506-DC-00000144 (phone logs).
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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.
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342. Lewinsky 8/6/98 GJ at 65; Lewinsky 7/29/98 Int. at 3-4; Lewinsky 8/3/98 Int. at 5.
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343. Lieberman 1/30/98 GJ at 62.
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344. Lieberman 1/30/98 GJ at 62.
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345. Bowles 4/2/98 GJ at 66-67.
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346. Currie 5/7/98 GJ at 49-50.
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347. Jordan 3/3/98 GJ at 64-65.
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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).
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349. Lewinsky 7/29/98 Int. at 1.
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350. Lewinsky 8/6/98 GJ at 66.
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351. Tripp 7/9/98 GJ at 94-98.
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352. Lewinsky 8/6/98 GJ at 28 & Ex. ML-7.
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353. Tripp 7/14/98 GJ at 3-4, 11-12; 845-DC-00000019 (Tripp notes).
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354. Lewinsky 7/29/98 Int. at 4-5.
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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).
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356. 1506-DC-00000275 (call log); 1506-DC-000000638.
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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.
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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).
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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.
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360. T7 at 36.
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361. T7 at 36-37.
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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).
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363. Lewinsky 8/20/98 GJ at 25.
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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).
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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).
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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).
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367. Lewinsky 8/20/98 GJ at 28-31. See also Lewinsky 7/30/98 Int. at 17.
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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).
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369. Newsweek, 8/10/98, cover photo.
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370. Lewinsky 8/11/98 Int. at 2.
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371. Lewinsky 8/20/98 GJ at 26-27.
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372. Lewinsky 7/29/98 Int. at 5.
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373. V006-DC-00000007 (WAVES records); V006-DC-00001855 - 1856 (photos from the reception); V006-DC-00000391 (White House event attendance records).
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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.
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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.
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376. Tripp 7/14/98 GJ at 39-40;845-DC-00000022 (Tripp notes).
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377. 833-DC-00001974 (email to Ms. Tripp).
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378. Currie 5/7/98 GJ at 63.
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379. Currie 5/6/98 GJ at 97-98.
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380. Currie 5/6/98 GJ 14-15.
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381. Currie 5/6/98 GJ at 52-53, 94-96.
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382. 827-DC-00000002, 827-DC-00000018 (Ms. Lewinsky's WAVES records).
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383. Currie 5/6/98 GJ at 57-58.
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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.
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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").
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386. Pape 5/18/98 Int. at 3-4.
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387. Chinery 6/11/98 Depo. at 33.
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388. Chinery 6/11/98 Depo. at 44-45; Chinery 7/23/98 GJ at 49.
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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.
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390. Lewinsky 8/20/98 GJ at 5. See also id. at 14; Lewinsky 8/19/98 Int. at 5.
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391. Currie 5/6/98 GJ at 88-89. See also id. at 184; Currie 5/14/98 GJ at 78.
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392. Currie 5/6/98 GJ at 88-89.
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393. Currie 5/14/98 GJ at 72-74, 91; Currie 1/24/98 Int. at 3.
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394. 837-DC-00000001; 837-DC-00000004; 837-DC-00000006; 837-DC-0000008; 837-DC-00000011; 837-DC-00000014; 837-DC-00000018.
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395. Lewinsky 7/31/98 Int. at 13; Marcia Lewis 2/11/98 GJ at 28-30; T1 at 63-64.
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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.
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397. Currie 5/14/98 GJ at 72-73.
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398. Currie 5/14/98 GJ at 73-74, 86-89; Currie 7/22/98 GJ at 51-52.
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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.
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401. "The President got everything anyone sent him." Currie 5/6/98 GJ at 129.
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402. Currie 5/14/98 GJ at 143-45; Currie 1/24/98 Int. at 8.
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403. Currie 5/6/98 GJ at 157-58.
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404. Currie 5/6/98 GJ at 156; Currie 7/22/98 GJ at 42-43.
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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.
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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.
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407. Currie 7/22/98 GJ at 33-35.
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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.
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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.
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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).
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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.
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412. Currie 5/6/98 GJ at 84-85.
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413. Lewinsky 7/31/98 Int. at 4.
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414. Lewinsky 8/5/98 Int. at 3.
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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).
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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.
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417. Chinery 7/23/98 GJ at 50.
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418. Pape 5/18/98 Int. at 5.
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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.
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420. 827-DC-00000018 (Epass records); Kessinger 2/24/98 Int. at 2.
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421. 833-DC-00001906 (email from Ms. Lewinsky to Ms. Tripp).
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422. V006-DC-00003712.
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423. V006-DC-00003720 (radio address attendance list).
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424. 827-DC-00000018; V006-DC-00000008; V006-DC-00001796.
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425. 1222-DC-00000234; 968-DC-00000073.
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426. 968-DC-00003506.
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427. Lewinsky 8/26/98 Depo. at 45-46, 48-49; Lewinsky 8/6/98 GJ at 30.
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428. Lewinsky 8/6/98 GJ at 45-46.
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429. Lewinsky 8/26/98 Depo. at 46.
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430. Lewinsky 8/6/98 GJ at 30.
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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.
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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.
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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.
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434. Lewinsky 8/26/98 Depo. at 46-47.
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435. Lewinsky 8/26/98 Depo. at 46-47.
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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.
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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.
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438. Lewinsky 8/24/98 Int. at 7; Finerman 3/18/98 Depo. at 22; Raines 1/29/98 GJ at 109.
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439. Lewinsky 8/26/98 Depo. at 47-48. See also Lewinsky 8/6/98 GJ at 31, 38-39.
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440. Lewinsky 8/26/98 Depo. at 47-48. See also Lewinsky 8/6/98 GJ at 31, 38-39.
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441. Lewinsky 7/30/98 Int. at 15.
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442. Lewinsky 8/26/98 Depo. at 48.
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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.
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444. FBI Lab Reports, 8/6/98, 8/17/98.
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445. Clinton 8/17/98 GJ at 55.
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446. Clinton 8/17/98 GJ at 138.
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447. Clinton 8/17/98 GJ at 136-37.
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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.
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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).
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450. Lewinsky 7/30/98 Int. at 16; Lewinsky 8/20/98 GJ at 67-69; Lewinsky 8/24/98 Int. at 7.
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451. Lewinsky 8/26/98 Depo. at 49.
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452. Lewinsky 8/26/98 Depo. at 50.
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453. Lewinsky 8/26/98 Depo. at 50.
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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.
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455. Lewinsky 8/20/98 GJ at 68-69; Lewinsky 8/26/98 Depo. at 50; Lewinsky 7/30/98 Int. at 16.
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456. Lewinsky 7/30/98 Int. at 16.
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457. Clinton 8/17/98 GJ at 10.
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458. Clinton 8/17/98 GJ at 54-55, 137-38.
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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.
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460. Lewinsky 8/6/98 GJ at 67.
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461. Lewinsky 8/6/98 GJ at 66-67; Lewinsky 7/27/98 Int. at 5; Lewinsky 8/5/98 Int. at 2.
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462. Lewinsky 8/6/98 GJ at 86-87.
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463. Lewinsky 8/26/98 Depo. at 62.
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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.").
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465. Lewinsky 8/6/98 GJ at 97-99; Lewinsky 7/27/98 Int. at 3.
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466. Lewinsky 8/6/98 GJ at 87; Lewinsky 7/27/98 Int. at 3.
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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.
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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.
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469. 827-DC-00000018 (Epass records).
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470. 1222-DC-00000242.
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471. 968-DC-00003533.
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472. Lewinsky 8/4/98 Int. at 2-3.
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473. Lewinsky 8/6/98 GJ at 24-25, 101.
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474. Lewinsky 8/4/98 Int. at 2; Lewinsky 7/31/98 Int. at 16.
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475. Lewinsky 8/4/98 Int. at 2-3.
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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).
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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.
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478. Clinton v. Jones, 117 S. Ct. 1636 (1997).
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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.
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480. Currie 5/6/98 GJ at 45; Currie 5/14/98 GJ at 146.
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481. Currie 5/14/98 GJ at 146.
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482. Currie GJ 5/14/98 at 121; Currie GJ 5/6/98 at 13, 81.
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483. Currie 5/7/98 GJ at 43-44.
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484. Currie 5/7/98 GJ at 68.
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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.
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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.
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487. 827-DC-00000018 (Epass records); V006-DC-00000008 (WAVES records); Scott GJ 3/19/98 at 17.
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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).
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489. Scott 3/19/98 GJ at 52. See also Scott 3/26/98 GJ at 16-17.
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490. Scott 3/19/98 GJ at 74.
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491. Scott 3/19/98 GJ at 87.
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492. 833-DC-00001070.
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493. Currie 5/7/98 GJ at 35; see id. at 39.
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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.
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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.
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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).
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497. Lewinsky 7/29/98 Int. at 8.
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498. Lewinsky 8/6/98 GJ at 68, 87; Lewinsky 7/29/98 Int. at 7-8; Lewinsky 8/11/98 Int. at 6.
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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.
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500. Lewinsky 8/6/98 GJ at 68-69, 87-89. See also Lewinsky 8/26/98 Depo. at 62-63.
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501. Lewinsky 8/6/98 GJ at 68, 87; Lewinsky 7/29/98 Int. at 7-8; Lewinsky 8/11/98 Int. at 6.
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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.
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503. Clinton 8/17/98 GJ at 124.
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504. Lewinsky 8/6/98 GJ at 69. See also Lewinsky 7/29/98 Int. at 8.
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505. Lewinsky 8/6/98 GJ at 69. See also Lewinsky 7/29/98 Int. at 7.
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506. 827-DC-00000018.
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507. V006-DC-00002140; V006-DC-00002214.
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508. Lewinsky 8/6/98 GJ at 75. See also Lewinsky 7/29/98 Int. at 8; Lewinsky 8/4/98 Int. at 4.
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509. Lewinsky 7/29/98 Int. at 8-9.
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510. Lewinsky 8/26/98 Depo. at 54-55; Lewinsky 7/27/98 Int. at 3.
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511. Lewinsky 8/26/98 Depo. at 55-56.
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512. Lewinsky 8/26/98 Depo. at 56-57. See also Lewinsky 7/28/98 Int. at 6.
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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).
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514. Lewinsky 8/6/98 GJ at 72. See also Lewinsky 8/4/98 Int. at 4.
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515. Lewinsky 8/6/98 GJ at 70-71; Tripp 7/14/98 GJ at 107-116.
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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.
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517. Lewinsky 8/6/98 GJ at 71.
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518. Lewinsky 8/6/98 GJ at 73-74; Lewinsky 7/29/98 Int. at 7.
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519. Lewinsky 7/29/98 Int. at 7; Lewinsky 8/11/98 Int. at 5.
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520. Lewinsky 8/6/98 GJ at 73; Lewinsky 7/29/98 Int. at 7.
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521. 968-DC-00003546.
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522. Lewinsky 8/6/98 GJ at 75.
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523. 827-DC-00000018; see also Steven Pape 5/18/98 Depo. at 3.
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524. V006-DC-00002142 (movement logs).
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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.
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526. Lewinsky 8/6/98 GJ at 76.
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527. 1222-DC-00000251 (movement logs).
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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).
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529. Lewinsky 8/6/98 GJ at 76-77.
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530. Lewinsky 8/6/98 GJ at 77.
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531. Lewinsky 8/6/98 GJ at 77-78; Tripp 7/16/98 GJ at 12.
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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.
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533. Lewinsky 8/6/98 GJ at 78-79.
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534. 968-DC-00003550.
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535. Lewinsky 8/6/98 GJ at 79; Tripp 7/16/98 at 12.
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536. Lewinsky 8/6/98 GJ at 79-80.
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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.
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538. Scott 3/19/98 GJ at 64-72.
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539. Lewinsky 7/31/98 Int. at 9.
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540. Lewinsky 2/1/98 Statement at 2.
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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.
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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.
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543. 827-DC-00000018 (Epass records); V006-DC-00000008 (WAVES records); V006-DC-00001770 (WAVES request).
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544. 1222-DC-00000254 (movement logs).
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545. 968-DC-00003556 (phone logs).
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546. Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7; Lewinsky 8/24/98 Int. at 6.
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547. Newsweek, 8/11/97 at 30.
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548. 845-DC-00000190 (letter); Tripp 7/16/98 GJ at 85-88.
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549. T30 at 166. Ms. Tripp responded: "Oh, God. He thinks I screwed him in the article. I'm dead." Id.
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550. V006-DC-00000008 (WAVES records).
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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).
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552. 968-DC-00003558.
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553. 968-DC-00002947.
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554. Lewinsky 8/26/98 Depo. at 52. See also Lewinsky 8/20/98 GJ at 70.
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555. Lewinsky 8/20/98 GJ at 70; Lewinsky 8/26/98 Depo. at 51-53.
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556. Lewinsky 8/26/98 Depo. at 52.
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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).
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558. 1051-DC-00000003 (Pentagon phone records).
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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).
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560. 1037-DC-00000086 - 87, 1037-DC-00000167, 1037-DC-00000255 - 256, 1037-DC-00000258 - 259 (email to Catherine Davis) (spelling and punctuation corrected).
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561. Scott 3/26/98 GJ at 142.
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562. Lewinsky 8/4/98 Int. at 5.
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563. MSL-DC-00001052 (spelling and punctuation corrected).
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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.
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565. 1037-DC-00000038 - 040; 1037-DC-00000167 - 169 (email to Catherine Davis).
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566. Lewinsky 8/6/98 GJ at27-28 & Ex. ML-7.
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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.
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568. Lewinsky 7/29/98 Int. at 16; Lewinsky 8/4/98 Int. at 5.
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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.
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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.
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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.
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572. Bowles 4/2/98 GJ at 12, 65-73.
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573. Bowles 4/2/98 GJ at 67-68.
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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.
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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.
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576. Lewinsky 7/31/98 Int. at 10.
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577. Lewinsky 8/13/98 Int. at 1.
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578. MSL-55-DC-0178 (spelling and punctuation corrected).
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579. Lewinsky 8/4/98 Int. at 2-3.
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580. T1 at 28.
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581. T1 at 24.
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582. T1 at 61.
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583. T1 at 25.
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584. T13 at 19.
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585. MSL-55-DC-00000001 (letter); 837-DC-00000001 (courier receipts); T1 at 97.
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586. MSL-55-DC-00000001.
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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.
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588. T13 at 20.
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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).
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590. T8 at 30.
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591. T8 at 30.
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592. T8 at 33.
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593. Lewinsky 7/31/98 Int. at 10; Lewinsky 7/27/98 Int. at 5.
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594. Lewinsky 7/31/98 Int. at 10.
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595. Lewinsky 7/31/98 Int. at 10.
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596. Lewinsky 7/31/98 Int. at 11.
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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).
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598. 952-DC-00000060 (movement logs).
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599. Lewinsky 8/6/98 GJ at 27-28 & Exh. ML-7.
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600. Lewinsky 8/6/98 GJ at 104; Lewinsky 8/13/98 Int. at 2-3; T2 at 5.
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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.
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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.
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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.
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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.
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605. T2 at 10-11.
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606. T2 at 11-12.
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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.
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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.
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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.
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610. DB-DC-00000027.
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611. T7 at 26.
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612. T7 at 30.
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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.
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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.
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615. T2 at 26-27.
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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.
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617. Lewinsky 8/13/98 Int. at 4; Lewinsky 8/26/98 Depo. at 61-63.
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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.
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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.
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620. Podesta 2/5/98 GJ at 45; Richardson 4/30/98 Depo. at 32.
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621. Richardson 4/30/98 Depo. at 160-61; Clinton 1/17/98 Depo. at 73.
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622. Richardson 4/30/98 Depo. at 26.
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623. Watkins 5/27/98 Depo. at 11-12, 18.
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624. Podesta 2/5/98 GJ at 46.
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625. 828-DC-00000012 (faxed copy of Ms. Lewinsky's resume, produced by the U.N.); Currie 5/6/98 GJ at 174.
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626. 828-DC-00000004 (U.N. phone records).
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627. Lewinsky 8/13/98 Int. at 3.
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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.
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629. Lewinsky 7/27/98 Int. at 5.
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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.
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631. Lewinsky 8/13/98 Int. at 3-4.
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632. Lewinsky 8/13/98 Int. at 4.
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633. Lewinsky 8/13/98 Int. at 4. See also Lewinsky 7/31/98 Int. at 12.
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634. Lewinsky 8/26/98 Depo. at 64-65; Lewinsky 7/31/98 Int. at 13.
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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).
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636. Lewinsky 7/31/98 Int. at 13. See also Lewinsky 8/26/98 Depo. at 65.
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637. Clinton 1/17/98 Depo. at 74.
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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).
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639. Richardson 4/30/98 Depo. at 68; Cooper 1/27/98 Int. at 1-2.
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640. Richardson 4/30/98 Depo. at 39; Sutphen 5/27/98 Depo. at 15-16; Cooper 1/27/98 Int. at 2.
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641. The draft was retrieved from Ms. Lewinsky's computer in the course of a consensual search on January 22, 1998.
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642. MSL-55-DC-0179 (punctuation added)(italics in original).
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643. MSL-55-DC-0179.
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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).
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645. Lewinsky 8/13/98 Int. at 4-5; Lewinsky 7/31/98 Int. at 14; Lewinsky 7/27/98 Int. at 5.
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646. 828-DC-00000003.
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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.
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648. Sutphen 5/27/98 Depo. at 26.
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649. Richardson 4/30/98 Depo. at 90-91; Sutphen 5/27/98 Depo. at 21-23.
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650. Lewinsky 8/26/98 Depo. at 65-66; Lewinsky 8/13/98 Int. at 4.
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651. Currie 5/6/98 GJ at 174-75, 181; Currie 5/14/98 GJ at 65-66.
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652. Clinton 1/17/98 Depo. at 73.
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653. Sutphen 5/27/98 Depo. at 32-33; Lewinsky 8/13/98 Int. at 5.
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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).
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655. Lewinsky 7/27/98 Int. at 5; Sutphen 5/27/98 Depo. at 38; 1013-DC-00000095 (toll records for Debra Finerman).
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656. 921-DC-00000101 - 118 (Second Set of Interrogatories from Plaintiff to Defendant Clinton).
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657. V002-DC-00000016; V002-DC-00000020-21.
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658. See supra at IX.B. See also Lewinsky 8/6/98 GJ at 104; Lewinsky 7/31/98 Int. at 11-12.
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659. MSL-55-DC-0179.
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660. Lewinsky 7/31/98 Int. at 14.
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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).
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662. T2 at 11-12. See also Lewinsky 7/31/98 Int. at 11.
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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").
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664. Currie 5/6/98 GJ at 169-70, 176-78, 182-83, 198.
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665. Clinton 1/17/98 Depo. at 81.
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666. Clinton 1/17/98 Depo. at 82.
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667. 1178-DC-00000011 (call logs).
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668. Lewinsky 7/31/98 Int. at 14.
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669. Lewinsky 7/31/98 Int. at 14-15.
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670. Lewinsky 8/13/98 Int. at 3.
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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).
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672. 1037-DC-00000017 (email retrieved from Catherine Davis's computer).
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673. Jordan 3/3/98 GJ at 13.
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674. V004-DC-00000135 (Akin, Gump phone records).
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675. Jordan 5/5/98 GJ at 54.
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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).
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677. Jordan 5/5/98 GJ at 34.
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678. 833-DC-00000980 (letter retrieved from Ms. Lewinsky's Pentagon computer)(spelling corrected).
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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.
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680. Jordan 3/3/98 GJ at 50.
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681. Jordan 5/5/98 GJ at 26-30, 34.
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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.
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683. 1037-DC-00000318 (email retrieved from Catherine Davis's computer).
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684. Lewinsky 8/13/98 Int. at 5.
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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).
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686. 837-DC-00000008(courier receipt).
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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).
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688. DB-DC-00000022.
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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.
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690. 1037-DC-00000318 (email retrieved from Catherine Davis's computer).
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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.
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692. MSL-1249-DC-0140; Lewinsky 8/13/98 Int. at 6.
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693. 1037-DC-00000318 (email retrieved from Catherine Davis's computer).
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694. Lewinsky 8/13/98 Int. at 6; 1234-DC-00000050 (movement log); 986-DC-00003799 (Kearney Diary).
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695. Lewinsky 8/13/98 Int. at 6.
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696. Lewinsky 8/13/98 Int. at 6; 1037-DC-00000318 (email to Catherine Davis).
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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).
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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).
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699. 1037-DC-00000318 (email to Catherine Davis).
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700. Lewinsky 8/13/98 Int. at 6.
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701. OIC 8/27/98 Memo.
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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.
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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.
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704. Lewinsky 8/6/98 GJ at 105.
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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.)
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706. MSL-1249-DC-0140 (spelling and punctuation corrected).
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707. MSL-1249-DC-0139 (spelling and punctuation corrected).
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708. 849-DC-00000128.
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709. 849-DC-00000121-37
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710. See infra at Section XI.F. See also Lewinsky 8/6/98 GJ at 121-26.
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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.
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712. 833-DC-00003207 (Travel Voucher DOD).
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713. Lewinsky 8/6/98 GJ at 107; Lewinsky 7/31/98 Int. at 1.
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714. V006-DC-00000521 (guest list); VOO6-DC-00001859 (photograph of Ms. Lewinsky and the President at the reception).
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715. Lewinsky 7/31/98 Int. at 1.
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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.
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717. MSL-55-DC-0177 (punctuation corrected).
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718. MSL-55-DC-0177 (punctuation corrected).
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719. MSL-DC-55-0177 (punctuation corrected).
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720. MSL-55-DC-0177 (punctuation corrected).
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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).
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722. Lewinsky 8/6/98 GJ at 111-12.
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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.
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724. Lewinsky 8/6/98 GJ at 110-11; Niedzwiecki 7/30/98 GJ at 13-14.
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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.
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726. Tyler 7/28/98 GJ at 40; Chinery 7/23/98 GJ at 8.
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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.).
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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.
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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.
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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.
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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.
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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.
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733. Lewinsky 8/6/98 GJ at 113.
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734. Lewinsky 8/6/98 GJ at 113-14.
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735. Lewinsky 8/6/98 GJ at 114.
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736. Lewinsky 8/6/98 GJ at 114.
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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.
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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.
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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.
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740. Lewinsky 8/6/98 GJ at 115.
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741. 1037-DC-00000011 (spelling corrected).
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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.
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743. Purdie 7/23/98 GJ at 32; Purdie 7/17/98 GJ at 3.
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744. Purdie 7/17/98 GJ at 6; Bryan Hall 7/23/98 GJ at 31-32; Chinery 7/23/98 GJ at 21.
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745. Porter 8/13/98 GJ at 12.
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746. Niedzwiecki 7/30/98 GJ at 30-31.
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747. Niedzwiecki 7/30/98 GJ at 31, 44. See also Niedzwiecki 8/5/98 GJ at 4-6 (text of Niedzwiecki notes).
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748. Purdie 7/23/98 GJ at 35.
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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.
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750. O'Malley 9/8/98 Depo. at 22, 40-41.
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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.
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752. Clinton 8/17/98 GJ at 86.
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753. Clinton 8/17/98 GJ at 88-89.
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754. Clinton 8/17/98 GJ at 89-90.
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755. Clinton 8/17/98 GJ at 91-92.
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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.
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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.
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758. Lindsey 3/12/98 GJ at 65.
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759. 964-DC-00000862 (Presidential mail notes).
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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.
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761. WAVES records reflect that Mr. Jordan entered the White House at 5:21 p.m. on Sunday, December 7. 1178-DC-00000026.
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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.
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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).
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764. Jordan 3/3/98 GJ at 41-42.
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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.
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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.
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767. Lewinsky 8/6/98 GJ at 119.
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768. Lewinsky 8/6/98 GJ at 120.
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769. Lewinsky 8/6/98 GJ at 120.
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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.
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771. Lewinsky 8/6/98 GJ at 120.
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772. Jordan 3/3/98 GJ at 154.
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773. Jordan 3/3/98 GJ at 64-65.
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774. Jordan 3/3/98 GJ at 65.
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775. Jordan 3/3/98 GJ at 65.
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776. 1414-DC-00001534 - 46 (Plaintiff's Second Request for Production of Documents and Things).
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777. Lewinsky 8/6/98 GJ at 121-26.
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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).
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779. Lewinsky 8/6/98 GJ at 122-23.
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780. Lewinsky 8/6/98 GJ at 123.
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781. Lewinsky 2/1/98 Statement at 4.
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782. Lewinsky 8/6/98 GJ at 123.
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783. Lewinsky 2/1/98 Statement at 4.
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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.
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785. Lewinsky 8/6/98 GJ at 232.
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786. Lewinsky 8/6/98 GJ at 126.
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787. Lewinsky 8/6/98 GJ at 126.
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788. Clinton 8/17/98 GJ at 116.
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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.
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790. Clinton 8/17/98 GJ at 119-20.
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791. Clinton 8/17/98 GJ at 119-20.
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792. Clinton 8/17/98 GJ at 120.
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793. Halperin 1/26/98 Int. at 2.
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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.
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795. Schick 1/29/98 Int. at 2.
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796. Lewinsky 8/6/98 GJ at 128; Harte 4/17/98 Int. at 1.
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797. 902-DC-000000135 - 138 (Lewinsky subpoena).
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798. 902-DC-000000137.
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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.
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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.
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801. V004-DC-00000172 (Akin, Gump visitor logs).
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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.
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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.
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804. Lewinsky 8/6/98 GJ at 131.
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805. Jordan 5/5/98 GJ at 140, 152-53.
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806. Jordan 5/5/98 GJ at 145.
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807. Jordan 5/5/98 GJ at 145.
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808. Jordan 5/5/98 GJ at 147.
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809. Jordan 5/5/98 GJ at 147.
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810. Jordan 3/3/98 GJ at 102.
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811. Jordan 3/3/98 GJ at 103.
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812. Lewinsky 8/6/98 GJ at 131-32.
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813. Lewinsky 8/6/98 GJ at 132.
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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.
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815. Lewinsky 8/6/98 GJ at 133.
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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.
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817. Jordan 3/3/98 GJ at 123.
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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.
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819. Jordan 3/3/98 GJ at 126.
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820. Jordan 3/3/98 GJ at 122-24. See also Lewinsky 8/6/98 GJ at 133-35.
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821. Lewinsky 8/6/98 GJ at 134.
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822. Lewinsky 8/6/98 GJ at 134.
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823. Lewinsky 8/6/98 GJ at 135. According to Ms. Lewinsky, Mr. Jordan responded, "I don't hug men." Id.
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824. Jordan 3/3/98 GJ at 167-8.
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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.
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826. Jordan 3/3/98 GJ at 173-74.
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827. Jordan 3/3/98 GJ at 170.
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828. Jordan 3/3/98 GJ at 171.
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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.
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830. Clinton 8/17/98 GJ at 64.
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831. Clinton 8/17/98 GJ at 65-66.
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832. Jordan 3/3/98 GJ at 164-66, 183-84.
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833. Lewinsky 8/6/98 GJ at 138.
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834. Lewinsky 8/6/98 GJ at 138.
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835. Lewinsky 8/6/98 GJ at 138-39.
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836. Lewinsky 8/6/98 GJ at 139.
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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.
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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.
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839. Jordan 3/3/98 GJ at 153.
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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).
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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.
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842. Carter 6/18/98 GJ at 158-60, 15, 75.
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843. According to Mr. Carter's bill, he met with Ms. Lewinsky for 1.1 hours. 902-DC-00000037.
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844. Lewinsky 8/6/98 GJ at 146; Carter 6/18/98 GJ at 25.
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845. Lewinsky 8/6/98 GJ at 146-47; Carter 6/18/98 GJ at 25.
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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.
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847. Lewinsky 8/6/98 GJ at 147.
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848. Lewinsky 8/6/98 GJ at 147.
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849. Carter 6/18/98 GJ at 29-30; 902-DC-00000038.
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850. Carter 6/18/98 GJ at 39.
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851. Carter 6/18/98 GJ at 42-43.
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852. V002-DC-000000052 - 54 (President Clinton's Supplemental Responses to Plaintiff's Second Set of Interrogatories); 1414-DC-00000512 - 17 (same).
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853. Lewinsky 8/6/98 GJ at 149.
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854. Lewinsky 8/6/98 GJ at 149.
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855. V0006-DC-00000009 (WAVES records).
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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.
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857. Lewinsky 8/26/98 Depo. at 53.
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858. Lewinsky 8/6/98 GJ at 151.
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859. Lewinsky 8/6/98 GJ at 151-52.
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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.
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861. Lewinsky 8/20/98 GJ at 66.
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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.
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863. Lewinsky 8/6/98 GJ at 152.
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864. Lewinsky 8/6/98 GJ at 152. See also Lewinsky 8/20/98 GJ at 66.
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865. Lewinsky 8/6/98 GJ at 168.
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866. Clinton 1/17/98 Depo. at 68.
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867. Clinton 8/17/98 GJ at 33.
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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.
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869. Clinton 8/17/98 GJ at 39.
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870. Catherine Davis 3/17/98 GJ at 77-79.
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871. Lewinsky 8/6/98 GJ at 154-55.
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872. Lewinsky 8/6/98 GJ at 155.
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873. Lewinsky 8/6/98 GJ at 155-56.
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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.
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875. Lewinsky 8/6/98 GJ at 158-59.
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876. Lewinsky 8/6/98 GJ at 159.
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877. Lewinsky 8/6/98 GJ at 159. See also Lewinsky 8/1/98 Int. at 12.
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878. Lewinsky 2/1/98 Statement at 7 (punctuation corrected).
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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.
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880. Currie 5/6/98 GJ at 105-06.
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881. Currie 5/6/98 GJ at 126.
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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.
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883. Currie 5/6/98 GJ at 107-08. See also Currie 1/27/98 GJ at 57-58.
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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.
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885. Currie 5/6/98 GJ at 106-07.
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886. Clinton 8/17/98 GJ at 51.
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887. Clinton 8/17/98 GJ at 115.
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888. Clinton 8/17/98 GJ at 46.
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889. Lewinsky 8/6/98 GJ at 186. Ms. Tripp, like Ms. Lewinsky, had been subpoenaed in the Jones case.
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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).
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891. Lewinsky 8/6/98 GJ at 186-89.
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892. Lewinsky 8/6/98 GJ at 187.
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893. Lewinsky 8/6/98 GJ at 187.
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894. Lewinsky 8/6/98 GJ at 188; 8/26/98 Int. at 2; 8/1/98 Int. at 13.
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895. Lewinsky 8/1/98 Int. at 13.
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896. Lewinsky 8/6/98 GJ at 190.
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897. Lewinsky 8/6/98 GJ at 190-91.
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898. Lewinsky 8/2/98 Int. at 1.
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899. 902-DC-00000232 (Mr. Carter's day-planner); 902-DC-00000037 (Mr. Carter's bill).
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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.
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901. Lewinsky 8/6/98 GJ at 192-93.
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902. Carter 6/18/98 GJ at 67-68; Lewinsky 8/6/98 GJ at 194, 199.
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903. Lewinsky 8/6/98 GJ at 195.
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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.").
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905. Lewinsky 8/6/98 GJ at 196.
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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.").
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907. Lewinsky 8/6/98 GJ at 197.
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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.").
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909. Clinton 8/17/98 GJ at 126
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910. Clinton 8/17/98 GJ at 129.
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911. Lewinsky 9/3/98 Int. at 2.
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912. Lewinsky 8/6/98 GJ at 198.
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913. Lewinsky 8/6/98 GJ at 198.
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914. Clinton 8/17/98 GJ at 48-49.
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915. Clinton 8/17/98 GJ at 50.
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916. Clinton 8/17/98 GJ at 127, 49-50.
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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.
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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.").
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919. Lewinsky 8/6/98 GJ at 194-95.
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920. Lewinsky 8/6/98 GJ at 202.
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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.
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922. 849-DC-00000634-35 (emphasis added).
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923. Lewinsky 8/6/98 GJ at 202.
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924. 849-DC-00000635.
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925. Lewinsky 8/6/98 GJ at 202.
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926. Jordan 3/5/98 GJ at 11.
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927. Jordan 3/5/98 GJ at 11.
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928. See Telephone Calls, Table 35. Catalogs of relevant phone calls are included in Appendix G as a Phone Log, Tables 1 through 50.
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929. Carter 6/18/98 GJ at 76-77, 92-93.
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930. 902-DC-00000030 (Mr. Carter's bill to Ms. Lewinsky).
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931. Jordan 5/5/98 GJ at 210, 214.
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932. Jordan 5/5/98 GJ at 218-20.
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933. 902-DC-00000232 (Mr. Carter's day-planner).
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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."
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935. Carter 6/18/98 GJ at 108.
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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.
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937. See Telephone Calls, Table 36.
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938. Jordan 3/5/98 GJ at 24-26.
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939. Jordan 5/5/98 GJ at 223-25.
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940. Jordan 5/5/98 GJ at 225.
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941. Jordan 5/5/98 GJ at 226.
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942. Clinton 1/17/98 Depo. at 72.
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943. Clinton 8/17/98 GJ at 74.
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944. Clinton 8/17/98 GJ at 75.
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945. Durnan 3/27/98 Int. at 1.
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946. Durnan 3/27/98 Int. at 2.
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947. Durnan 3/27/98 Int. at 2.
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948. Lewinsky 8/6/98 GJ at 206.
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949. Lewinsky 8/6/98 GJ at 207-08.
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950. See Telephone Calls, Table 37, Call 6.
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951. Jordan 5/5/98 GJ at 230.
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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.
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953. Perelman 4/23/98 Depo. at 10.
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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.
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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.
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956. Lewinsky 8/6/98 GJ at 209.
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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.
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958. Jordan 5/28/98 GJ at 19.
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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.
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960. Seidman 4/23/98 Depo. at 37-38.
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961. Lewinsky 8/6/98 GJ at 210.
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962. Lewinsky 8/6/98 GJ at 210.
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963. Jordan 5/28/98 GJ at 30.
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964. Jordan 5/28/98 at 39.
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965. Jordan 5/28/98 GJ at 59. Mr. Jordan added that the President's response was one of "appreciation, gratitude." Id.
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966. 921-DC-00000770-72 (Clerk's minutes of in-camera hearing).
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967. Sheldon 4/34/98 Depo. at 22.
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968. Lewinsky 8/6/98 GJ at 214.
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969. Lewinsky 8/6/98 GJ at 215.
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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.
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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.
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972. Bowles 4/2/98 GJ at 78.
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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.
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974. Podesta 6/16/98 GJ at 24; Hilley 2/11/98 Int. at 2.
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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.
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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.
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977. 830-DC-00000007.
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978. Clinton 8/17/98 GJ at 111-13.
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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.
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980. T30 at 61.
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981. T30 at 114.
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982. T30 at 169-70.
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983. Lewinsky 8/6/98 GJ at 223-25; GJ Ex. ML-5.
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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.
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985. Currie 5/6/98 GJ at 120-21.
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986. Currie 5/6/98 GJ at 130.
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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.
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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).
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989. Jordan 3/5/98 GJ at 71.
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990. Jordan 3/5/98 GJ at 71.
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991. T22 at 12.
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992. T22 at 12-13.
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993. Ungvari 3/19/98 GJ at 61.
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994. V0002-DC-00000093-116 (President Clinton's Responses to Plaintiff's Second Set of Requests).
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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.
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996. 921-DC-00000775 - 778.
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997. Carter 6/18/98 GJ at 123.
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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.
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999. Clinton 1/17/98 Depo. at 1 (849-DC-00000352 et seq.).
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1000. Clinton 1/17/98 Depo. at 1-2.
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1001. Clinton 1/17/98 Depo. at 10.
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1002. Clinton 1/17/98 Depo. at 22-23; 849-DC-00000586 (Clinton Depo. Ex. 1).
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1003. Clinton 1/17/98 Depo. at 54.
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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.
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1005. Clinton 1/17/98 Depo. at 53-56.
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1006. Clinton 1/17/98 Depo. at 50-51, 58-59.
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1007. Clinton 1/17/98 Depo. at 52-53, 59.
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1008. Clinton 1/17/98 Depo. at 59.
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1009. Clinton 1/17/98 Depo. at 62-64.
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1010. Clinton 1/17/98 Depo. at 75-77.
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1011. Clinton 1/17/98 Depo. at 75-76.
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1012. Clinton 1/17/98 Depo. at 75.
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1013. Clinton 1/17/98 Depo. at 68.
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1014. Clinton 1/17/98 Depo. at 68-71.
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1015. Clinton 1/17/98 Depo. at 72, 79-83.
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1016. Clinton 1/17/98 Depo. at 78.
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1017. Clinton 1/17/98 Depo. at 212-13.
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1018. Podesta 6/16/98 GJ at 62.
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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.
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1020. Lindsey 2/19/98 GJ at 14-15.
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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.
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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.
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1023. Currie 1/27/98 GJ at 70.
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1024. Currie 1/27/98 GJ at 67.
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1025. Currie 1/27/98 GJ at 76.
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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.
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1027. Currie 1/27/98 GJ at 70.
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1028. Currie 1/27/98 GJ at 73 ("[M]y impression was that he was just making statements.").
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1029. Currie 1/24/98 Int. at 6-7. The President repeated these statements to Ms. Currie a few days later. See infra.
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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.
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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.
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1032. Currie 1/27/98 GJ at 71, 75.
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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.
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1034. Currie 1/27/98 GJ at 32-33; 36-38.
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1035. Currie 7/22/98 GJ at 12, 15-6; Currie 1/27/98 GJ at 76.
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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.
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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.
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1038. Currie 1/27/98 GJ at 75.
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1039. Currie 1/27/98 GJ at 83.
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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.
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1041. Clinton 8/17/98 GJ at 57.
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1042. Clinton 8/17/98 GJ at 132.
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1043. Clinton 8/17/98 GJ at 55.
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1044. Clinton 8/17/98 GJ at 141.
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1045. Clinton 8/17/98 GJ at 55.
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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.").
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1047. Clinton 8/17/98 GJ at 38.
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1048. Clinton 8/17/98 GJ at 57-58, 132.
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1049. Clinton 8/17/98 GJ at 133.
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1050. Clinton 8/17/98 GJ at 133.
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1051. Clinton 8/17/98 GJ at 135.
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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.
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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.
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1054. Currie 5/7/98 GJ at 99-100.
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1055. Telephone Calls, Table 47, Call 11. See also Currie 7/22/98 GJ at 161-62.
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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.
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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.
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1058. Currie 7/22/98 GJ at 157-59; 164-66.
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1059. Jordan 6/9/98 GJ at 17. See also Telephone Calls, Table 48 (831-DC-00000009) (Ms. Lewinsky's pager records).
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1060. Jordan 6/9/98 GJ at 38-39.
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1061. Carter 6/18/98 GJ at 146.
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1062. Jordan 6/9/98 GJ at 54-55.
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1063. Schmidt, Baker, and Locy, "Clinton Accused of Urging Aide To Lie," Wash. Post, Jan. 21, 1998, at A1.
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1064. Podesta 6/23/98 GJ at 12.
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1065. See Telephone Calls, Table 50.
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1066. Mr. Bennett was apparently referring to Ms. Lewinsky's affidavit.
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1067. Clinton Accused at A1.
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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.
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1069. Currie 5/7/98 GJ at 112-14.
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1070. Lindsey 8/28/98 GJ at 90. Mr. Lindsey, citing privileges, refused to testify about the substance of this conversation.
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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.
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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.
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1073. White House Press Conference (Mike McCurry), Jan. 21, 1998.
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1074. Lindsey 8/28/98 GJ at 11-12.
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1075. Bowles 4/2/98 GJ at 84. See also Podesta 6/16/98 GJ at 85-86.
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1076. Ickes 6/10/98 GJ at 73.
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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.
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1078. Currie 1/27/98 GJ at 80-81.
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1079. Currie 1/27/98 GJ at 81.
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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.
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1081. Blumenthal 2/26/98 GJ at 19.
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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.
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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.
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1084. Blumenthal 6/4/98 GJ at 49.
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1085. Blumenthal 6/4/98 GJ at 50.
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1086. Blumenthal 6/4/98 GJ at 49-50; Blumenthal 6/25/98 GJ at 15, 51.
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1087. Podesta 6/16/98 GJ at 92.
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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.
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1089. Clinton 8/17/98 GJ at 101-09.
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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.
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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.")
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1092. Clinton 8/17/98 GJ at 107.
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1093. Clinton 8/17/98 GJ at 107.
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1094. Broadcast on "All Things Considered" on National Public Radio, 5:07 p.m., Wednesday, January 21, 1998.
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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.
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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.
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1097. Roll Call, Inc., January 22, 1998; transcript of press conference.
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1098. "All Things Considered," January 21, 1998.
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1099. "The News Hour," January 21, 1998.
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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.
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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.
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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.
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1103. Morris 8/18/98 GJ at 14.
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1104. Mr. Morris testified that he interpreted the "something" to be sexual in nature. Morris 8/18/98 GJ at 94.
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1105. Morris 8/18/98 GJ at 14.
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1106. Morris 8/18/98 GJ at 15.
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1107. Morris 8/18/98 GJ at 15-16.
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1108. Morris 8/18/98 GJ at 17.
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1109. Morris 8/18/98 GJ at 28.
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1110. Morris 8/18/98 GJ at 30.
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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.
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1112. Morris 8/18/98 GJ at 35.
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1113. Thomason 8/11/98 GJ at 6.
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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.
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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.
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1116. Thomason 8/11/98 GJ at 15.
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1117. Thomason 8/11/98 GJ at 27.
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1118. Schmidt and Baker, "Ex-Intern Rejected Immunity Offer in Probe," Wash. Post, Jan. 24, 1998, at A1.
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1119. Schmidt and Baker, "Ex-Intern Rejected Immunity Offer," at A1.
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1120. Larry King Weekend, Jan. 24, 1998, Transcript No. 98012400V42.
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1121. In fact, the President did draw a distinction between "is" and "was." See Clinton 8/17/98 GJ at 59.
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1122. Larry King Weekend, Jan. 24, 1998, Transcript No. 98012400V42.
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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.").
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