The following material was submitted by independent counsel Kenneth Starr with his report to the House on President Clinton. This document provided by Federal News Service. Editor's Note: Some of the language in these documents is sexually explicit.

So, I basically – I don't think I paid any attention to it because it appeared to me that that was something that had no reference to the facts that they admitted they were asking me about.

Q: So, if I can be clear, Mr. President, was it your understanding back in January that the definition, now marked as Grand Jury Exhibit 2, only included consensual sexual activity?

PRESIDENT CLINTON: No. My understanding – let me go back and say it. My understanding – I'll tell you what it did include. My understanding was, what I was giving to you, was that what was covered in those first two lines was any direct contact by the person being deposed with those parts of another person's body, if the contact was done with an intent to arouse or gratify. That's what I believed it meant. That's what I believed it meant then reading it. That's what I believe it means today.

Q: I'm just trying to understand, Mr. President. You indicated that you put the definition in the context of a sexual harassment case.

PRESIDENT CLINTON: No, no. I think it was not in the context of sexual harassment. I just reread those four pages, which obviously the grand jury doesn't have. But there was some reference to the fact that this definition apparently bore some, had some connection to some definition in another context, and that this was being used not in that context, not necessarily in the context of sexual harassment.

So, I would think that this "causes" would be, would mean to force someone to do something. That's what I read it. That's the only point I'm trying to make. Therefore, I did not believe that anyone had ever suggested that I had forced anyone to do anything, and that – and I did not do that. And so that could not have had any bearing on any questions related to Ms. Lewinsky.

Q: I suppose, since you have now read portions of the transcript again, that you were reminded that you did not ask for any clarification of the terms. Is that correct? Of the definition?

PRESIDENT CLINTON: No, sir. I thought it was a rather – when I read it, I thought it was a rather strange definition. But it was the one the Judge decided on and I was bound by it. So, I took it.

Q: During the deposition, you remember that Ms. Lewinsky's name came up and you were asked several questions about her. Do you remember that?

PRESIDENT CLINTON: Yes, sir, I do.

Q: During those – or before those questions actually got started, your attorney, Mr. Bennett, objected to any questions about Ms. Lewinsky, and he represented to Judge Wright, who was presiding – that was unusual, wasn't it, that a federal judge would come and actually – in your experience – that a federal judge would come and preside at a deposition?

MR. KENDALL: Mr. Bittman, excuse me. Could you identify the transcript page upon which Mr. Bennett objected to all testimony about Ms. Lewinsky before it got started?

MR. BITTMAN: The objection, this quote that I'm referring to, is going to begin at page 54 of the deposition.

MR. KENDALL: That is into the testimony though, after the testimony about Ms. Lewinsky has begun, is it not?

BY MR. BITTMAN:

Q: Mr. President, is it unusual for a federal judge preside over a civil deposition?

PRESIDENT CLINTON: I think it is, but this was an unusual case. I believe I know why she did it.

Q: Your attorney, Mr. Bennett, objected to the questions about Ms. Lewinsky, didn't he?

PRESIDENT CLINTON: What page is that on, sir?

Q: Page 54, where he questions whether the attorneys for Ms. Jones had a good faith basis to ask some of the questions that they were posing to you. His objections actually begin on page 53.

Since, as the President pointed out that the grand jurors correctly do not have a copy of the deposition, I will read the portion that I am referring to. And this begins at line 1 on page 54.

"I question the good faith of counsel, the innuendo in the question. Counsel is fully aware that Ms. Lewinsky has filed, has an affidavit which they are in possession of saying that there is absolutely no sex of any kind in any manner, shape or form, with President Clinton".

PRESIDENT CLINTON: Where is that?

Q: That is on page 54, Mr. President, beginning at line 1, about midway through line 1.

PRESIDENT CLINTON: Well, actually, in the present tense that is an accurate statement. That was an, that was an accurate statement, if – I don't – I think what Mr. Bennett was concerned about, if I – maybe it would be helpful to you and to the grand jurors, quite apart from these comments, if I could tell you what his state of mind was, what my state of mind was, and why I think the Judge was there in the first place.

If you don't want me to do it, I won't. But I think it will help to explain a lot of this.

Q: Well, we are interested, and I know from the questions that we've received from the grand jurors they are interested in knowing what was going on in your mind when you were reading Grand Jury Exhibit 2, and what you understood that definition to include.

Our question goes to whether – and you were familiar, and what Mr. Bennett was referring to obviously is Ms. Lewinsky's affidavit. And we will have that marked, Mr. President, as Grand Jury Exhibit WJC-4.

(Grand Jury Exhibit WJC-4 was marked for identification.)

BY MR. BITTMAN:

Q: And you remember that Ms. Lewinsky's affidavit said that she had had no sexual relationship with you. Do you remember that?

PRESIDENT CLINTON: I do.

Q: And do you remember in the deposition that Mr. Bennett asked you about that. This is at the end of the – towards the end of the deposition. And you indicated, he asked you whether the statement that Ms. Lewinsky made in her affidavit was –

PRESIDENT CLINTON: Truthful.

Q: – true. And you indicated that it was absolutely correct.

PRESIDENT CLINTON: I did. And at the time that she made the statement, and indeed to the present day because, as far as I know, she was never deposed since the Judge ruled she would not be permitted to testify in a case the Judge ruled had no merit; that is, this case we're talking about.

I believe at the time that she filled out this affidavit, if she believed that the definition of sexual relationship was two people having intercourse, then this is accurate. And I believe that is the definition that most ordinary Americans would give it.

If you said Jane and Harry have a sexual relationship, and you're not talking about people being drawn into a lawsuit and being given definitions, and then a great effort to trick them in some way, but you are just talking about people in ordinary conversations, I'll bet the grand jurors, if they were talking about two people they know, and said they have a sexual relationship, they meant they were sleeping together; they meant they were having intercourse together.

So, I'm not at all sure that this affidavit is not true and was not true in Ms. Lewinsky's mind at the time she swore it out.

PRESIDENT CLINTON: I didn't talk to her about her definition. I did not know what was in this affidavit before it was filled out specifically. I did not know what words were used specifically before it was filled out, or what meaning she gave to them. But I'm just telling you that it's certainly true what she says here, that we didn't have – there was no employment, no benefit in exchange, there was nothing having anything to do with sexual harassment. And if she defined sexual relationship in the way I think most Americans do, meaning intercourse, then she told the truth.

Q: My question –

PRESIDENT CLINTON: And that depends on what was in her mind. I don't know what was in her mind. You'll have to ask her that.

Q: But you indicated before that you were aware of what she intended by the term "sexual relationship".

PRESIDENT CLINTON: No, sir. I said I thought that this could be a truthful affidavit. And when I read it, since that's the way I would define it, since – keep in mind, she was not, she was not bound by this sexual relations definition, which is highly unusual; I think anybody would admit that. When she used a different term, sexual relationship, if she meant by that what most people mean by it, then that is not an untruthful statement.

Q: So, your definition of sexual relationship is intercourse only, is that correct?

PRESIDENT CLINTON: No, not necessarily intercourse only. But it would include intercourse. I believe, I believe that the common understanding of the term, if you say two people are having a sexual relationship, most people believe that includes intercourse. So, if that's what Ms. Lewinsky thought, then this is a truthful affidavit. I don't know what was in her mind. But if that's what she thought, the affidavit is true.

Q: What else would sexual relationship include besides intercourse?

PRESIDENT CLINTON: Well, that – I think – let me answer what I said before. I think most people when they use that term include sexual relationships and whatever other sexual contact is involved in a particular relationship. But they think it includes intercourse as well. And I would have thought so. Before I got into this case and heard all I've heard, and seen all I've seen, I would have thought that that's what nearly everybody thought it meant.

Q: Well, I ask, Mr. President, because your attorney, using the very document, Grand Jury Exhibit 4, WJC-4, represented to Judge Wright that his understanding of the meaning of that affidavit, which you've indicated you thought Ms. Lewinsky thought was, she was referring just to intercourse, he says to Judge Wright that it meant absolutely no sex of any kind in any manner, shape or form.

PRESIDENT CLINTON: Well, let me say this. I didn't have any discussion obviously at this moment with Mr. Bennett. I'm not even sure I paid much attention to what he was saying. I was thinking, I was ready to get on with my testimony here and they were having these constant discussions all through the deposition. But that statement in the present tense, at least, is not inaccurate, if that's what Mr. Bennett meant. That is, at the time that he said that, and for some time before, that would be a completely accurate statement.

Now, I don't believe that he was – I don't know what he meant. You'd have to talk to him, because I just wasn't involved in this, and I didn't pay much attention to what was being said. I was just waiting for them to get back to me. So, I can't comment on, or be held responsible for, whatever he said about that, I don't think.

Q: Well, if you – do you agree with me that if he mislead Judge Wright in some way that you would have corrected the record and said, excuse me, Mr. Bennett, think the Judge is getting a misimpression by what you're saying?

PRESIDENT CLINTON: Mr. Bennett was representing me. I wasn't representing him. And I wasn't even paying much attention to this conversation, which is why, when you started asking me about this, I asked to see the deposition, I was focusing on my answers to the questions. And I've told you what I believe about this deposition, which I believe to be true. And it's obvious, and I think by your questions you have betrayed that the Jones lawyers' strategy in this case had nothing to do with uncovering or proving sexual harassment.

By the time this discovery started, they knew they had a bad case on the law and they knew what our evidence was. They knew they had a lousy case on the facts. And so their strategy, since they were being funded by my political opponents, was to have this dragnet of discovery. They wanted to cover everybody. And they convinced the Judge, because she gave them strict orders not to leak, that they should be treated like other plaintiffs in other civil cases, and how could they ever know whether there had been any sexual harassment, unless they first knew whether there had been any sex.

And so, with that broad mandate limited by time and employment in the federal or state government, they proceeded to cross the country and try to turn up whatever they could; not because they thought it would help their case. By the time they did this discovery, they knew what this deal was in their case, and they knew what was going to happen. And Judge Wright subsequently threw it out. What they –

Q: With all respect, Mister –

PRESIDENT CLINTON: Now, let me finish, Mr. Bennett [sic]. I mean, you brought this up. Excuse me, Mr. Bittman. What they wanted to do, and what they did do, and what they had done by the time I showed up here, was to find any negative information they could on me, whether it was true or not; get it in a deposition; and then leak it, even though it was illegal to do so. It happened repeatedly. The Judge gave them orders.

One of the reasons she was sitting in that deposition was because she was trying to make sure that it didn't get out of hand. But that was their strategy, and they did a good job of it, and they got away with it. I've been subject to quite a lot of illegal leaking, and they had a very determined deliberate strategy, because their real goal was to hurt me. When they knew they couldn't win the lawsuit, they thought, well, maybe we can pummel him. Maybe they thought I'd settle. Maybe they just thought they would get some political advantage out of it. But that's what was going on here.

Now, I'm trying to be honest with you, and it hurts me. And I'm trying to tell you the truth about what happened between Ms. Lewinsky and me. But that does not change the fact that the real reason they were zeroing in on anybody was to try to get any person in there, no matter how uninvolved with Paula Jones, no matter how uninvolved with sexual harassment, so they could hurt me politically. That's what was going on. Because by then, by this time, this thing had been going on a long time. They knew what our evidence was. They knew what the law was in the circuit in which we were bringing this case. And so they just thought they would take a wrecking ball to me and see if they could do some damage.

Q: Judge Wright had ruled that the attorneys in the Jones case were permitted to ask you certain questions, didn't she?

PRESIDENT CLINTON: She certainly did. And they asked them and I did my best to answer them. I'm just trying to tell –

Q: And was it your responsibility –

PRESIDENT CLINTON: – you what my state of mind was.

Q: – to answer those questions truthfully, Mr. President?

PRESIDENT CLINTON: It was.

Q: And was –

PRESIDENT CLINTON: But it was not my responsibility, in the face of their repeated illegal leaking, it was not my responsibility to volunteer a lot of information. There are many cases in this deposition where I gave – and keep in mind, I prepared, I treated them, frankly, with respect. I prepared very well for this deposition on the Jones matters. I prepared very well on that. I did not know that Linda Tripp had been involved in the preparation of this deposition, or that all of you –

Q: Do you know that now?

PRESIDENT CLINTON: No, I don't. I just know that – what I read in the papers about it. But I had no way of knowing that they would ask me all these detailed questions. I did the best I could to answer them.

Q: Did you prepare –

PRESIDENT CLINTON: But in this deposition, Mr. Bittman, I was doing my best to be truthful. I was not trying to be particularly helpful to them, and I didn't think I had an obligation to be particularly helpful to them to further a – when I knew that there was no evidence here of sexual harassment, and I knew what they wanted to do was to leak this, even though it was unlawful to do so. That's –

Q: Did you believe, Mr. President –

PRESIDENT CLINTON: – what I knew.

Q: – that you had an obligation to make sure that the presiding federal judge was on board and had the correct facts? Did you believe that was your obligation?

PRESIDENT CLINTON: Sir, I was trying to answer my testimony, I was thinking about my testimony. I don't believe I ever even focused on what Mr. Bennett said in the exact words he did until I started reading this transcript carefully for this hearing. That moment, that whole argument just passed me by. I was a witness. I was trying to focus on what I said and how I said it.

And, believe me, I knew what the purpose of the deposition was. And, sure enough, by the way, it did all leak, just like I knew it would.

Q: Let me ask you, Mr. President, you indicate in your statement that you were alone with Ms. Lewinsky. Is that right?

PRESIDENT CLINTON: Yes, sir.

Q: How many times were you alone with Ms. Lewinsky?

PRESIDENT CLINTON: Let me begin with the correct answer. I don't know for sure. But if you would like me to give an educated guess, I will do that, but I do not know for sure. And I will tell you what I think, based on what I remember. But I can't be held to a specific time, because I don't have records of all of it.

Q: How many times do you think?

PRESIDENT CLINTON: Well, there are two different periods here. There's the period when she worked in the White House until April of '96. And then there's the period when she came back to visit me from February '97 until late December '97.

Based on our records – let's start with the records, where we have the best records and the closest in time. Based on our records, between February and December, it appears to me that at least I could have seen her approximately nine times. Although I do not believe I saw her quite that many times, at least it could have happened.

There were – we think there were nine or 10 times when she was in, in the White House when I was in the Oval Office when I could have seen her. I do not believe I saw her that many times, but I could have.

Now, we have no records for the time when she was an employee at the White House, because we have no records of that for any of the employees at the White House, unless there was some formally scheduled meeting that was on the, on the calendar for the day.

I remember – I'll tell you what I remember. I remember meeting her, or having my first real conversation with her during the government shutdown in November of '95, when she – as I explained in my deposition, during the government shutdown, the – most federal employees were actually prohibited from coming to work, even in the White House. Most people in the White House couldn't come to work. The Chief of Staff could come to work. My National Security Advisor could come to work. I could.

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