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THE IMPEACHMENT TRIAL
Trial Excerpts of Lewinsky Deposition

From the Congressional Record
Friday, February 5, 1999

Following are exceprts of Monica S. Lewinsky's Feb. 1 Senate trial deposition, which were released by Congress today.

SENATOR DeWINE: If not, I will now swear the witness.

Ms. Lewinsky, will you raise your right hand, please?

Whereupon, MONICA S. LEWINSKY was called as a witness and, after having been first duly sworn by Senator DeWine, was examined and testified as follows:

SENATOR DeWINE: The House Managers may now begin your questioning.

MR. BRYANT: Thank you, Senator.

Good morning to all present.

EXAMINATION BY HOUSE MANAGERS

BY MR. BRYANT:

Q. Ms. Lewinsky, welcome back to Washington, and wanted to just gather a few of our friends here to have this deposition now. We do have quite a number of people present, but we--in spite of the numbers, we do want you to feel as comfortable as possible because I think we--everyone present today has an interest in getting to the truth of this matter, and so as best as you can, we would appreciate your answers in a--in a truthful and a fashion that you can recall. I know it's been a long time since some of these events have occurred.

But for the record, would you state your name once again, your full name?

A. Yes. Monica Samille Lewinsky.

Q. And you're a--are you a resident of California?

A. I'm--I'm not sure exactly where I'm a resident now, but I--that's where I'm living right now.

Q. Okay. You--did you grow up there in California?

A. Yes.

Q. I'm not going to go into all that, but I thought just a little bit of background here.

You went to college where?

A. Lewis and Clark, in Portland, Oregon.

Q. And you majored in--majored in?

A. Psychology.

Q. Tell me about your work history, briefly, from the time you left college until, let's say, you started as an intern at the White House.

A. Uh, I wasn't working from the time I--

Q. Okay. Did you--

A. I graduated college in May of '95.

Q. Did you work part time there in--in Oregon with a--with a District Attorney--

A. Uh--

Q. --in his office somewhere?

A. During--I had an internship or a practicum when I was in school. I had two practicums, and one was at the public defender's office and the other was at the Southeast Mental Health Network.

Q. And those were in Portland?

A. Yes.

Q. Okay. What--you received a bachelor of science in psychology?

A. Correct.

Q. Okay. As a part of your duties at the Southeast Health Network, what did you--what did you do in terms of working? Did you have direct contact with people there, patients?

A. Yes, I did. Um, they referred to them as clients there and I worked in what was called the Phoenix Club, which was a socialization area for the clients to--really to just hang out and, um, sort of work on their social skills. So I--

Q. Okay. After your work there, you obviously had occasion to come to work at the White House. How did--how did you come to decide you wanted to come to Washington, and in particular work at the White House?

A. There were a few different factors. My mom's side of the family had moved to Washington during my senior year of college and I wanted--I wasn't ready to go to graduate school yet. So I wanted to get out of Portland, and a friend of our family's had a grandson who had had an internship at the White House and had thought it might be something I'd enjoy doing.

Q. Had you ever worked around--in politics and campaigns or been very active?

A. No.

Q. You had to go through the normal application process of submitting a written application, references, and so forth to--to the White House?

A. Yes.

Q. Did you do that while you were still in Oregon, or were you already in D.C.?

A. No. The application process was while I was a senior in college in Oregon.

Q. Had you ever been to Washington before?

A. Yes.

Q. Obviously, you were accepted, and you started work when?

A. July 10th, 1995.

Q. Where--where were you assigned?

A. The Chief--

Q. Physically, where were you located?

A. Oh, physically?

Q. Yes.

A. Room 93 of the Old Executive Office Building.

Q. Were you designated in any particular manner in terms of--were all interns the same, I guess would be my question?

A. Yes and no. We were all interns, but there were a select group of interns who had blue passes who worked in the White House proper, and most of us worked in the Old Executive Office Building with a pink intern pass.

Q. Now, can you explain to me the significance of a pink pass versus a blue pass?

A. Sure.

Q. Okay. Is it--is it access?

A. Yes.

Q. To what?

A. A blue pass gives you access to anywhere in the White House and a pink intern pass gives you access to the Old Executive Office Building.

Q. Did interns have blue passes?

A. Yes, some.

Q. Some did, and some had pink passes?

A. Correct.

Q. And you had the pink?

A. Correct.

Q. How long was your internship?

A. It was from July 'til the end of August, and then I stayed on for a little while until the 2nd.

Q. Are most interns for the summertime--you do part of the summer or the entire summer?

A. I believe there are interns all year-round at the White House.

Q. Now, you as an intern, you are unpaid.

A. Correct.

Q. And tell--tell me how you came to, uh, through your decisionmaking process, to seek a paid position and stay in Washington.

A. Uh, there were several factors. One is I came to enjoy being at the White House, and I found it to be interesting. I was studying to take the GREs, the entrance exam for graduate school, and needed to get a job. So I--since I had enjoyed my internship, my supervisor at the time, Tracy Beckett, helped me try and secure a position.

Q. Now, you mentioned the pink pass that you had. So you were able to--I don't want to presume--you were able to get into the White House on occasion even with a pink pass?

A. The--do you mean the White House proper, or--

Q. Yes, the White House--

A. --the complex?

Q. Yes. Let me be clear. When I--I tend to say `White House'--I mean the actual building itself. And I know perhaps you think of the whole complex in terms of the whole--

A. I'm sorry. Just to be clear--

Q. Yes.

A. --do you mean the West Wing and the residence and--

Q. Right.

A. --the East Wing when you say the White House?

Q. Right. The White House where the President lives, and works, I guess, right.

A. I'm sorry. Can you repeat the question?

Q. Yes, yes. I mean that White House. As an intern, you had a pink pass that did allow you to have access to that White House where the President was on occasion?

A. No.

Q. Did not. Did you have--did you ever get in there as an intern?

A. Yes.

Q. And under--under what circumstances?

A. It--

Q. Did you have to be accompanied by someone, or--

A. Exactly; someone with a blue pass.

Q. So how did you--once you decided you wanted to stay in Washington and find a paying job, you sought out some help from friends there, people you knew, contacts, and you were--you did--you were successful?

A. Correct.

Q. And you were hired where--where in the White House?

A. In Legislative Affairs.

Q. Now, again, to educate me on this, in that group, in that section, department, you would have worked where, physically?

A. Physically, in the East Wing.

Q. Okay, and as an intern before, you worked in the Old Executive Office Building?

A. Correct.

Q. But you moved about and occasionally would go into the White House, if escorted?

A. Correct.

Q. It takes a while, but I'll get there with you; I'll catch up.

When did you actually--what was your first day on the job with the Legislative Affairs, uh, group?

A. Um, first day on the job was sometime after the furlough. I was hired right before the furlough, but the paperwork hadn't gone through, so first day on the job was some point after the furlough. I don't remember the exact date.

Q. So you remained, uh, on as an intern during the furlough--

A. Correct.

Q. --the Government shutdown period.

A. Correct.

Q. And that was in November of 1995, some date during that?

A. Yes.

Q. Okay. Um, tell me how you, um, began--I guess the--the--we're going to talk about a relationship with the President. Uh, when you first, uh, I guess, saw him, I think there was some indication that you didn't speak to him maybe the first few times you saw him, but you had some eye contact or sort of smiles or--

A. I--I believe I've testified to that in the grand jury pretty extensively.

Q. Uh-huh.

A. Is--is there something more specific?

Q. Well, again, I'm wanting to know times, you know, how soon that occurred and sort of what happened, you know, if you can--you know, there are going to be occasions where you--obviously, you testified extensively in the grand jury, so you're going to obviously repeat things today. We're doing the deposition for the Senators to view, we believe, so it's--

MR. CACHERIS: May I note an objection. The Senators have the complete record, as you know, Mr. Bryant, and she is standing on her testimony that she has given on the occasions that Mr. Stein alluded to at the introduction of this deposition.

MR. BRYANT: Well, I appreciate that, but, uh, if this is going to be the case, we don't even need the deposition, because we're limited to the record and everything is in the record. So I think, uh, to be fair, we're--we're obviously going to have to talk about, uh, some things for 8 hours here, or else we can go home.

THE WITNESS: Sounds good to me.

[Laughter.]

MR. BRYANT: I think we probably all would like to do that.

SENATOR DeWINE: Counsel, are you objecting to the question?

MR. CACHERIS: Yes. I'm objecting to him asking specific questions that are already in the record that--he has said they are limited to the record, and so we accept his, his designation. We're limited to the record.

SENATOR DeWINE: We're going to go off the record for just a moment.

THE VIDEOGRAPHER: We're going off the record at 9:37 a.m.

[Recess.]

THE VIDEOGRAPHER: We are going back on the record at 9:45 a.m.

SENATOR DeWINE: We are now back on the record.

The objection is noted, but it's overruled, and the witness is instructed to answer the question.

Senator Leahy?

SENATOR LEAHY: And I had noted during the break that obviously, the witness has 48 hours to correct her deposition, and would also note that when somebody has testified to some of these things 20 or more times that it is not unusual to have some nuances different, and that could also be reflected in time to correct her testimony.

And I had also noted when we were off the record Mr. Manager Bryant's comment on January 26th, page S992 in the Congressional Record, in which he said: `If our motion is granted, I want to make this very, very clear. At no point will we ask any questions of Monica Lewinsky about her explicit sexual relationship with the President, either in deposition or, if we are permitted on the floor of the Senate, they will not be asked.'

And I should add also, to be fair to Mr. Bryant, another sentence in that: `That, of course, assumes that White House Counsel does not enter into that discussion, and we doubt that they would.' Period, close quote.

SENATOR DeWINE: Let me just add something that I stated to counsel and to Ms. Lewinsky off the record, and I think I will briefly repeat it, and that is that counsel is entitled to an answer to the question, but Ms. Lewinsky certainly can reference previous testimony if she wishes to do that. But counsel is entitled to a new explanation of--of what occurred.

Counsel, you may--why don't you re-ask the question, and we will proceed.

MR. BRYANT: May I, before I do that, ask a procedural question in terms of timekeeping?

SENATOR DeWINE: The time is not counted--any of the time that you have--once there is an objection, none of the time is counted until we rule on the objection and until you then have the opportunity to ask the question again. So the time will start now.

MR. BRYANT: Very good.

BY MR. BRYANT:

Q. Ms. Lewinsky, again, let me--I know this is difficult, but let me apologize that, uh, that it is going to be necessary that I ask you these questions because we're limited to the record and if we--we can't ask you any new questions outside that record, so I have to talk about what's in the record. And I realize you've answered all these questions several times before, but it's, uh--I'm sincere that we really wouldn't need to take your deposition if we couldn't ask you those kinds of questions. So it's not motivated to cause you uncomfort or to make you sit here in Washington when you'd rather be in California. We'll try to get through this as quickly as we can.

But we were talking about when you were first assigned there at the White House and those initial contacts, and I mean, again, when you were--you would see the President. I think you've mentioned you would--there was some mild flirting going on; you would smile or you would make eye contact. It was something of this nature?

A. Yes.

Q. And the first--was the first time you actually spoke to the President or he spoke to you, other than perhaps a hello in the hallway, was that on November the 15th, 1995?

A. Yes.

Q. And that was--that was the day, uh, of the first so-called salacious encounter, the same day?

A. Yes.

Q. Now, when the President gave a statement testifying before the grand jury, he--he described that relationship as what I considered sort of an evolving one. He says: `I regret that what began as a friendship came to include this conduct.' And he goes on to take full responsibility for his actions. But that almost sounds as if this was an evolving--something from a friendship evolving over time to a sexual relationship. That was not the case, was it?

A. I--I can't really comment on how he perceived it. My perception was different.

Q. Okay--

A. But I--I--I mean, I don't feel comfortable saying that he didn't, that he didn't see it that way, or that's wrong; that's how he saw it. I--

Q. But you saw it a different way?

A. Yes.

Q. Now, on November the 15th, had you already accepted this job with Legislative Affairs?

A. Yes.

Q. And, uh, was--that was during the shutdown, so you had no job to go to because the Government was shut down.

A. No. I accepted it on the Friday before the furlough.

Q. And that--

A. But the paperwork hadn't gone through.

Q. Okay. Did, uh--when you first met with the President on November the 15th, did he say anything to you that would indicate that he knew you were an intern?

A. No.

Q. Did he make a comment about your, your pink security badge?

A. Can I ask my counsel a question real quickly, please?

[Witness conferring with counsel.]

MR. CACHERIS: Okay, Mr Bryant.

THE WITNESS: Sorry. It was--that occurred in the second encounter of that evening.

BY MR. BRYANT:

Q. Okay. On November--

A. So, not the first encounter.

Q. On November the 15th, 1995?

A. Correct.

Q. What--do you recall what he said or what he did in regard to the intern pass?

A. He tugged on my pass and said: `This is going to be a problem.'

Q. And what did, uh--did he say anything else about what he meant by `problem'?

A. No.

Q. Tell me about your job at Legislative Affairs. Did that involve going into the White House itself?

A. Yes. My job was in the White House.

Q. You were in one wing, but did that involve going--did it give you access--

A. Yes.

Q. --pretty well throughout the White House?

A. Yes.

Q. What did you do primarily?

A. I worked under Jocelyn Jolly, who supervised the letters that came from the Hill; so the opening of those letters and reading them and vetting them and preparing responses for the President's signature--responding.

Q. Now, you've indicated through counsel at the beginning that you are willing to affirm, otherwise adopt, your sworn testimony of August the 6th and August the 20th, I think, which would be grand jury, and the deposition of August the 26th, 1998.

A. Correct.

Q. So you're saying that that information is accurate, and it is truthful?

A. Yes.

Q. Well, thank you. That--that will save us a little bit of time, but certainly we will ask you some of that information also.

At some point, you were transferred to the Pentagon, to the Department of Defense. When did that occur?

A. I found out I was being transferred on April 5th, 1996.

Q. Did you want to go--

A. No.

Q. --to the Department of Defense? Did you have a discussion with the President about this?

A. Yes.

Q. What was your reaction to being transferred?

A. I started to cry.

Q. Did you talk to anyone else at the White House other than the President about the transfer at that time?

A. Yes.

Q. And who--who was that?

A. I spoke with several people. I--I can't--I know I--I spoke with, uh, Jocelyn about it. I spoke with people with whom I was friendly at the White House. I spoke to Betty, Nancy Hernreich, several people.

Q. Did you--did you find out why you were being transferred?

A. Uh, I was told why I was being transferred by Mr. Keating on Friday, the 5th of April.

Q. And that was why?

A. Uh, he said that the--the Office of Administration, I think it was, was not pleased with the way the correspondence was being handled, and they were, quote-unquote, `blowing up' the Correspondence Office, and that I was being transferred and it had nothing to do with my work.

Q. Did you have any understanding that it might have been other reasons that you were being moved?

A. Not at that point.

Q. Did the--what did the President say about your transfer at that point?

A. He thought it had something to do with our relationship.

Q. What else did he say about--about your transfer, if anything? Did he give you any assurances that you might be back, or--

A. Yes.

Q. Back after what time period?

A. He promised me he'd bring me back after the election.

Q. So this was, again, in early 19--April of 1996, and he was up for reelection--

A. Yes.

Q. --in November of 1996.

A. Yes.

Q. Did you attach any significance to being transferred away before the election and then him assuring you he would bring you back after the election? Did you attach any significance to the election and your having to leave?

A. Emotional significance, yes.

Q. Your emotion? I'm--I'm not sure I follow you. You were--

A. Well, yes, I attached significance to it.

Q. And that was emotional--

A. But that was emotional.

Q. But the reason you both felt--again, I'm not trying to put words in your mouth, but you both felt you were leaving until after the election was because of your
relationship and perhaps people finding out?

A. No. I--I--first, I can only speak for myself. I mean, I, uh, my understanding initially was that it was, um, for work-related issues, but not my work, and I came to understand later that it was having to do with my relationship with the President.

Q. Okay. Did, uh, you have a conversation--and it may be the same one with the President on April the 12th--which determined that Ms. Lieberman maybe spearheaded your transfer because you were paying too much attention--you were all--you were both paying too much attention to each other and she was worried that it was close to election time? And I think you've testified to that, haven't you?

A. Yes.

Q. Okay, good. You started, uh, with the Department of Defense at the Pentagon in mid-April, April the 17th, 1996?

A. Yes.

Q. What did you do there?

A. I was the confidential assistant to Mr. Bacon, who is the Assistant Secretary of Defense for Public Affairs.

Q. Did, uh--after the 1996 election, did you still want to go back to the White House?

A. Yes.

Q. You had not fallen in love with the job at the Pentagon that much?

A. No.

Q. Was that, in fact, a frustrating period of time?

A. Yes. No offense to Mr. Bacon, of course.

Q. I understand; I'm sure he would take none.

I would like--I don't think it's been mentioned, but you helped in preparing a chart which we have listed as one of our exhibits, ML Number 2, which I assume might have a different number for now, but it's a chart of contacts--

A. Right.

Q. --that you had with the President. And do you have a copy of that chart? It--

[Witness conferring with counsel.]

MR. BRYANT: In the--yes, in the record, it's at page 1251.

MR. BURTON: May we have an extra copy for counsel, please?

BY MR. BRYANT:

Q. Have you had occasion to review this document?

A. Yes.

Q. And very--very simply, I would like for you to, uh, if you can, to affirm that document as an accurate representation and a truthful representation of all the contacts that you had with the President from approximately August 9th, 1995 until January of 1998. It includes in-person contacts, telephone calls, gifts and notes exchanged, I think are the categories.

A. Yes. I believe there might have been one or two changes that were made and noted in the grand jury or my deposition, and I adopt those as well.

MR. BRYANT: Okay, good.

I am not going to at this point make her--the information she adopts and affirms exhibits to this deposition. I don't want to clutter it any more unless someone wants to make this an exhibit in terms of your deposition testimony, your grand jury testimony, and now the charts that you have affirmed, so I just want you to specifically affirm it but not make it an exhibit, because it's already a part of the record.

MR. CACHERIS: We defer to the White House.

MS. SELIGMAN: I just wanted to make clear on the record, then, what the app. or sub-cite is of anything we're adopting so that we all know what particular pages it is.

MR. BRYANT: Okay. And that, again, was, I think, page 1251 of--right, of the record.

SENATOR LEAHY: I don't--I don't understand.

MS. MILLS: Can you cite the ending page?

SENATOR DeWINE: Counsel, is that where this appears?

MR. BRYANT: It appears in the record, uh--

SENATOR DeWINE: You need to designate also if you're talking about the Senate record or--I think at this point we'll go off the record.

THE VIDEOGRAPHER: We're going off the record at 10:01 a.m.

[Recess.]

THE VIDEOGRAPHER: We are going back on the record at 10:11 a.m.

SENATOR DeWINE: Let me--we're now back on the record.

Let me advise counsel, the Managers, that they have used 25 minutes so far.

You may resume questioning, and if you could begin by identifying the exhibit for the record, please.

MR. BRYANT: Tom, let me also for clarification purposes--Tom, on the referral to the Senate record, you're saying that the appendices are numbered 3, but the numbers are the same. The page numbers are the same.

MR. GRIFFITH: Yes.

MR. BRYANT: And the supplemental materials are your Volume IV, but, again, the pages are the same.

MR. GRIFFITH: That's our understanding.

MR. BRYANT: Okay. For the record, then, using the Senate volumes, if this is an appendices, Volume III, and the chart that we just alluded to before the break is--appears at pages 116 through 126 of the Senate record, Volume III.

BY MR. BRYANT:

Q. Ms. Lewinsky, did you tell a number of people in varying details about your relationship with the President?

A. Yes.

Q. you tell us who did you tell?

A. Catherine Allday Davis, Neysa Deman Erbland, Natalie Ungvari, Ashley Raines, Linda Tripp, Dr. Kathy Estep, Dr. Irene Kassorla, Andy Bleiler, my mom, my aunt. Who else has been subpoenaed?

Q. Okay. Let me suggest Dale--did you mention Dale Young?

A. Dale Young. I'm sorry.

Q. Thank you.

Now, in the floor presentation, Mr. Craig, who was one of--is one of the counsel for the President, adopted an argument that had been raised in some of the previous hearings, uh, and he adopted this argument in the Senate that--that you have--have or had, I think, both past and present, the incentive to not tell the truth about how the President--this relationship with him because you wanted to avoid--and again, I use the quote from Mr. Craig's argument--the demeaning nature of providing wholly un-reciprocated sex.

Did, uh--did you lie before the grand jury and to your friends about the nature of that relationship with the President--

A. No.

Q. --so as to avoid what Mr. Craig says? Okay, and I'll break it down.

SENATOR DeWINE: Counsel, do you want to just--just rephrase the question?

MR. BRYANT: Okay. We'll break it down into two questions.

BY MR. BRYANT:

Q. Did you not tell the truth before the grand jury as to how the President touched you because of what Mr. Craig alleges as the demeaning nature of the wholly un-reciprocated sex?

MR. CACHERIS: Well, that--may I register an objection, gentlemen? This witness is not here to comment on what some lawyer said on the floor of the Senate. He can ask her direct questions. She will answer them, but what Mr. Craig said or didn't say would have happened after her grand jury testimony. So it's totally inappropriate that he's--

SENATOR DeWINE: Mr. Bryant, why don't you--

MR. CACHERIS: --marrying those two concepts. We object.

SENATOR DeWINE: Mr. Bryant, why don't you just rephrase the question?

MR. BRYANT: Well, we--we have had presented on behalf of the President a defense, an incentive, a reason why she would not tell the truth, and I think she should have the opportunity to respond to that--that allegation.

MR. CACHERIS: We--we don't, uh--

SENATOR LEAHY: Ask her a direct question.

MR. CACHERIS: We welcome you asking her if her testimony was truthful, and she will tell you that it is truthful. We don't have any problem with that. We don't have any brief with what the White House did or didn't do through their counsel. That's their business. We don't represent the White House.

MS. SELIGMAN: So, for the record, I'd like to object to the characterization of what Mr. Craig says, which obviously speaks for itself, but I certainly don't want my silence to be construed as accepting the Manager's characterization of it.

SENATOR DeWINE: Mr. Bryant, why don't you--why don't you ask the question?

MR. BRYANT: Okay.

SENATOR DeWINE: Go ahead and ask your question.

BY MR. BRYANT:

Q. In regard to your testimony at the grand jury about your--your relationship and the physical contact that you have said occurred in some of these, uh, visits with the President, it has been characterized in a way that would give you an excuse not to tell the truth. Did you tell the truth in the grand jury about what actually happened and how the President touched--the President touched you?

A. Yes.

Q. And did you likewise tell the truth to your friends in connection with the same matters?

A. Yes.

Q. Did your relationship with the President involve giving gifts, exchanging gifts?

A. Yes.

Q. And you mentioned earlier that in reference to this chart that it was, uh, subject to certain corrections you've made in later testimony. It was an accurate representation or an accurate compilation of the gifts that, uh, you gave the President and the President gave you. Is that correct?

A. Yes.

Q. Approximately how many gifts did you give the President?

A. I believe I've testified to that number. I don't recall right now.

Q. About 30? Would that be--

A. If that's what I testified to, then I accept that.

Q. That's the number I have, and do you recall how many gifts approximately the President gave you?

A. It would be the same situation.

Q. Okay, and you've previously testified in your grand jury that he gave you about 18 gifts.

A. I accept that.

Q. Okay, good. What types of gifts did you give the President?

A. They varied. I think they're listed on this chart, and I've testified to them.

Q. Okay, and--

MR. CACHERIS: Do you want her to read the list that's on this chart?

MR. BRYANT: No. I was just, again, looking for just a--I think maybe a little broader category, but that's--that's okay. That's an acceptable answer there.

BY MR. BRYANT:

Q. After leaving the White House and going to the Pentagon, did you continue to visit the President?

A. Yes.

Q. How would you--how would you be transported from the Pentagon over to the White House? How did you get there?

A. I drove or took a taxi.

Q. Do you have your own car?

A. No.

Q. Whose--whose car would you drive?

A. Either my mom's or my brother's.

Q. So you did have access to a vehicle?

A. Correct.

Q. Okay. How were these meetings arranged when you would want to go from the Pentagon to the White House? How did--how did these--how were they set up? Did you get an appointment?

[The witness conferring with counsel.]

SENATOR DeWINE: Counsel--if you have to ask counsel, you can stop and ask us--

THE WITNESS: Okay.

SENATOR DeWINE: --to do that.

BY MR. BRYANT:

Q. How were these meetings arranged?

A. Through Ms. Currie.

Q. Would--would you call her and set the meeting up, or would she call you on behalf of the President and set the meeting up?

A. It varied.

Q. Both--both situations occurred?

A. Correct.

Q. Now, Ms. Currie is the President's--that's Betty Currie, we're talking about, the President's secretary?

A. Yes.

Q. Why was this done? Why was that procedure used?

A. It was my understanding that Ms. Currie took care of the President's guests who were coming to see him, making those arrangements.

Q. Was, uh--was this--were these visits done sort of off the record, so to speak, so it wouldn't necessarily be a record?

A. I believe so.

Q. In other words, you wouldn't be shown on Betty Currie's calendar or schedule book for the President?

A. I don't know.

Q. Did--who suggested this type of arrangement for setting up meetings?

A. I believe the President did.

Q. During this time that you were at the Department of Defense at the Pentagon, uh, how--how was it working out about you being transferred back to the White House? How was the job situation coming?

A. Well, I waited until after the election and then spoke with the President about it on several occasions.

Q. And what would he say in response?

A. Various things; `I'm working on it,' usually.

Q. In July, uh, particularly around the--the 3rd and 4th of July, there--there--you wrote the President a letter, I think.

A. Which year?

Q. July of '90--it would have been '97 that you wrote the President a letter expressing some frustrations about the job situation in terms of--is that, uh--can you tell us about that?

A. Yes. I had had a--well, I guess I was--I know I've testified about this, I mean, in the grand jury, but I was feeling at that point that I was getting the runaround on being brought back to the White House. So I sent a letter to the President that was probably the harshest I had sent.

Q. Did you get a response?

A. Sort of.

Q. Would you explain?

A. Um, Betty called me and told me to come to the White House the next morning, on July 4th, at 9:00 a.m.

Q. And what happened when you--I assume you went to the White House on July the 4th. What happened?

A. I know I--I--do you have a specific question? I know I testified, I mean, extensively about this whole day, that whole--

Q. Well, in regards to--let's start with the job.

A. Well, I started crying. We were in the back office and, um--and when the subject matter came up, the President was upset with me and then I began to cry. So--

Q. Did he encourage you about you coming back? Did he make a promise or commitment to you that he would make sure you came back to work at the White House?

A. I don't know that he reaffirmed his promise or commitment. I remember leaving that day thinking that, as usual, he was going to work on it and had a renewed sense of hope.

Q. Did he comment on your letter, the tone of your letter?

A. Yes.

Q. What did he say?

A. He was upset with me and told me it was illegal to threaten the President of the United States.

Q. Did you intend the letter to be interpreted that way?

A. No.

Q. Did you explain why you wrote the letter to him about reminding him that you were a good girl and you left the White House? Did you have that type of conversation?

A. Yes. That's what made me start to cry.

Q. Did you, uh--did you ever explain to him that you didn't intend to threaten him?

A. I believe so.

Q. What was the intent of the letter?

A. First, I felt the letter was going to him as a man and not as President of the United States. Um, second, I think I could see how he could interpret it as a threat, but my intention was to sort of remind him that I had been waiting patiently and what I considered was being a good girl, about having been transferred.

Q. And the threat we're talking about here would not have been interpreted as a threat to do physical injury or bodily injury to him. It was to expose your relationship to the--to your parents--

A. Correct.

Q. --explain to them why you were not going back to the White House--

A. Correct.

Q. --after the election?

And certainly the President did not encourage you
to expose that relationship, did he?

A. I don't believe he made any comment about it at that point.

Q. His only comment about the so-called threat was that it's a---it's--you can't do that, it's against the law to threaten the President?

A. Exactly.

Q. That meeting turned into--I guess you've testified that that meeting did turn into a more positive meeting toward the end. It was not all emotional and accusations being made?

A. Correct.

Q. At some point, uh--well, let me--let me back up and ask this. There was a subsequent meeting on July the 14th, and I believe the President had been out of town and this was the follow-up meeting to the July 4th meeting where you had originally discussed the possibility of a newspaper reporter or a magazine writer, I believe, writing a story about Ms. Willey?

A. Correct.

Q. And you, uh--did you have any instructions from the President, from either of these meetings, about doing something for the President, specifically about having Ms. Tripp call White House counsel--

A. I don't know--

Q. --Mr. Lindsey?

A. --that I'd call them instructions.

Q. Okay. What did he tell you? I don't want to mischaracterize.

A. He asked me if I would try to have Ms. Tripp contact Mr. Lindsey.

Q. Okay, and if you were to be successful in doing that, what were you supposed to do? Were you supposed to contact Ms. Currie, his secretary?

A. Yes.

Q. And what were you supposed to tell her?

A. In an innocuous way that I had been able to convey that to Ms. Tripp or get her to do that.

Q. Now, in--at some point in October of that year, 1997, did your job focus change?

A. Yes.

Q. And how was that? What were you doing?

A. Uh, it really changed on October 6th, 1997, as a result of a conversation with Linda Tripp.

Q. Uh, in that, as I understand, you sort of got secondhand information that you were probably never going back to work at the White House.

A. Correct.

Q. Did you understand what that meant? Did you accept that? And I guess why would you accept it at that point? Why would you give up on the White House?

MR. CACHERIS: Those are three questions, Mr. Bryant. Will you--would you break it down, please?

MR. BRYANT: Well, yeah, it's true.

BY MR. BRYANT:

Q. Do you understand? I guess I'm trying to clarify.

A. Not really. I'm sorry.

Q. Why would you accept at that point in October that you were never going back to the White House?

A. I don't really remember, I mean, what--what--what was going through my mind at that point as to--to answer that question. Is that--

Q. Okay.

A. I'm sorry.

Q. Certainly, if you don't remember, that's a--that's a good answer.

A. Okay.

Q. So you don't recall anything had really changed other than you had heard secondhand that you weren't going to go back. You have no independent recollection of anything else other than what somebody told you that would have changed--

A. My recollection is--

Q. --changed your focus?

A. --that it was this--it was this conversation, what Linda Tripp told me from whom this information was coming, the way it was relayed to me that--that shifted everything that day.

Q. And you didn't feel it was necessary to go back to the President and perhaps confront the President and say, `why am I not coming back, I want to come back?'

A. I mean, I had a discussion with the President, but I had made a decision from that based on that information, and I guess my--my experience of it coming up on a year from the election, having not been brought back, that it probably wasn't going to happen.

Q. But you--you did call the President about that time and then--but the focus had been changed toward perhaps a job in another location.

A. Yes and no. I didn't call him, but I, um--

Q. You called Betty--

A. --but we did have a discussion about that.

Q. You called Betty Currie, his secretary.

A. Yes.

Q. Okay, and then through her, he contacted you and you had a discussion?

A. Yes.

Q. And what did you tell him at that time about the job?

A. I believe I testified to that, so that my testimony is probably more accurate. The gist of it was, um, that I wanted to move to New York and that I was accepting I wasn't going to be able to come back to the White House, and I asked for his help.

Q. Did you bring up Vernon Jordan's name as perhaps somebody that could help you?

A. It's possible it was in that conversation.

Q. What was the President's comments back to you about your deciding to go to New York?

A. I don't remember his exact comments. He was accepting of the concept.

Q. In regards to your--your, uh, decision to search for a job in New York, in your comments to the President, did he ever tell you that that was good, that perhaps the
Jones lawyers could not easily find you in New York?

A. I'm sorry. I don't--I--I--

MR. CACHERIS: Excuse me again, Mr. Bryant. That's a compound question. He could--she could answer it was good, and then she could answer maybe the Jones lawyer couldn't get her, but I think you'd want an answer to each question.

BY MR. BRYANT:

Q. Okay. Let me ask it this way. There has been some reference to that fact throughout the proceedings, and I recall seeing something somewhere in your--your testimony that you said it or he said it. Do you recall anything being said about you going to Washington--to New York and that the effect of that might be that you would be more difficult to find?

A. I believe that might have been mentioned briefly on the 28th of December, but not as a reason to go to New York, but as a possible outcome of being there. Does that--does that make sense?

Q. It does.

A. Okay.

Q. What, uh--what would have been the context of that? And we're jumping ahead to December the 28th, but what would have been the context of that particular conversation about the New York and being perhaps--the result being it might be difficult to find you, or more difficult? What was the context?

A. Um, I--I--if I remember correctly, it came sort of at the tail-end of a very short discussion we had about the Jones case.

Q. At this November the 11th meeting, did the President ask you to prepare a list, sort of a wish list for jobs?

A. I'm sorry. Which--

Q. I'm sorry. Did I say October? We're back to the October the 11th meeting. Did the President ask you to prepare a wish list?

A. Okay. We haven't gone to the October 11th meeting yet. I--I haven't said anything about that meeting yet.

Q. Okay.

A. The phone call was on the 9th.

Q. Okay, and you subsequently had a meeting, then, with the President on the 11th?

A. Correct.

Q. Face--face-to-face meeting?

A. Correct.

Q. And at that meeting, did he suggest you give him a wish list or Betty Currie a wish list?

A. Yes.

Q. Again, I asked a compound question there.

Who did he suggest you give the wish list to?

MR. CACHERIS: We're getting used to that.

MR. BRYANT: I'm getting good. I'm making my own objections now.

[Laughter.]

THE WITNESS: Um, we sustain those. No, I'm sorry.

[Laughter.]

MR. BRYANT: I can do that, too. I'll be doing that in a minute. Overruled. Okay.

THE WITNESS: Um, I--I believe he--he said I should get him a list, and the implication was through Betty.

BY MR. BRYANT:

Q. And obviously you prepared a list of--

A. Correct.

Q. --the people you'd like to work for in New York City.

A. Correct.

Q. And you sent that list--

A. Yes.

Q. --to Betty Currie or to the President?

A. I sent it to Ms. Currie.

Q. And also during this time--and I'm probably going to speed this up a little bit, but, uh, you did interview for the job at the United Nations?

A. Yes.

Q. And, uh--and through a process of several months there, or weeks at least, you did--made an offer to take a job at the United Nations and eventually declined it. Is that correct?

A. Correct.

Q. Did you in early November have the occasion to meet with Vernon Jordan about the job situation?

A. Yes.

Q. And how did you learn about that meeting?

A. I believe I asked Ms. Currie to check on the status of--I guess of finding out if I could have this meeting, and then she let me--she let me know to call Mr. Jordan's secretary?

Q. And you set up an appointment with Mr. Jordan, or did she, Ms. Currie, do that?

A. No. I set up an appointment. I think that was after a phone--well, I guess I don't--I don't know that, so sorry.

Q. But that appointment was November the 5th?

A. Yes.

Q. Prior to going to the meeting with Vernon Jordan, did you tell the President that you had a meeting with Mr. Jordan?

A. I don't think so. I don't remember.

Q. Did you carry any documents or any papers with you to the meeting with Mr. Jordan?

A. Yes.

Q. What were those?

A. My resume and a list of public relations firms in New York.

Q. Did Mr. Jordan ask you why you were there?

A. Yes.

Q. And what did you say?

A. I was hoping to move to New York and that he could assist me in securing a job there.

Q. Did he ask you why you wanted to leave Washington?

A. Yes.

Q. And what was your answer?

A. I gave him the vanilla story of, um, that I--I think I--I don't remember exactly what I said. I--I believe I've testified to this. I think it was something about wanting to get out of Washington.

Q. The vanilla story. You mean sort of an innocuous set of reasons, not really the true reasons you wanted to leave?

A. Yes.

Q. And what were the true reasons you wanted to leave?

A. Because I couldn't go back to the White House.

Q. Did--did you think Mr. Jordan accepted--did you think he would accept that vanilla story, or did you feel like he understood the real story?

A. No, I felt he accepted it.

Q. Did Mr. Jordan tell you during this meeting that he had already spoken with the President?

A. It was--I believe so.

Q. And that you had come highly recommended, I think?

A. Yes.

Q. Did he, Mr. Jordan, review your list of job preferences and suggest anything?

A. Yes.

Q. And what did he suggest?

A. He said the names of the--he looked at the list of public relations firms and I think sort of said, `oh, I've heard of them, I haven't heard of these people, have you heard of so and so,' that I hadn't heard of.

Q. Your meeting lasted about 20 minutes?

A. If that's what I've testified to, then I accept that.

Q. It is, or close to it. I know this is an approximation, but thereabouts. You weren't there all day.

A. I had--well, I don't--I don't remember how long it was right now. I know I've testified to that. So if I said 20 minutes, then--

Q. Did you have a conversation with the President on--about a week later on November the 12th and by telephone?

A. Yes.

Q. And did you indicate there you had spoken with Mr. Jordan about a job?

A. Yes.

Q. After you met with Mr. Jordan, did you--did you have an impression that you would get, uh--get a job, get favorable results in your job search?

A. Yes.

Q. Did anything favorable happen to--in your job search from that November the 5th, 1997, meeting until Thanksgiving?

A. No, but I believe Mr. Jordan was out of town for a week or two.

Q. During the weeks after this November the 5th interview, did you try to contact Mr. Jordan?

A. Yes.

Q. How?

A. First, I sent him a thank-you note for the initial meeting, and I believe I placed some phone calls right before Thanksgiving--maybe a phone call. I don't remember if it was more than one.

Q. What--what happened with respect to the job search, uh, through there, through Thanksgiving? Was there anything? I mean, I know he--you said he was out of down, but did anything, to your knowledge, occur? Could you see any results up to Thanksgiving?

A. From my meeting with Mr. Jordan?

Q. Yes.

A. No.

Q. Did you contact Betty Currie after you received no response from Mr. Jordan?

A. Yes.

Q. And did she page you? I think you were in Los Angeles at the time.

A. Correct.

Q. Okay. What--what did she tell you as a result of that telephone call?

A. She asked me to place a call to Mr. Jordan, which I did.

Q. And this would have been, again, around November the 26th, shortly--well, around Thanksgiving?

A. It was before Thanksgiving.

Q. And I assume you found Mr. Jordan.

A. Yes.

Q. And what did he tell you?

A. That he was working on it.

Q. Did he tell you to call him back?

A. Yes.

Q. Did you indeed call him back

A. I didn't actually get ahold of him; he was out-of-town that day. I think it was December 5th.

Q. Did you try to meet with the President during this time?

A. Yes.

Q. How did you do that?

A. I was a pest. I sent a note to Ms. Currie and asked her to pass it along to the President, requesting that I meet with him.

Q. Were you successful in having a meeting as a result of those efforts?

A. I don't know if it was a result of those efforts, but yes, I ended up having a meeting with the President.

Q. And when would that have been; what day?

A. On the 6th of December 1997.

Q. Again you are going through Betty Currie; is that, again, the standard procedure at that time?

A. Yes.

Q. Did you go--I think you spoke also perhaps to Betty Currie on December the 5th, the day before the meeting--

A. Yes.

Q. --and this was something about attending the President's speech. Was that when that occurred--or the radio address, or something? Does that ring any bells?

A. No.

Q. Did--you did attend the Christmas party that day--

A. Yes.

Q. --and the White House. And you saw the President?

A. Yes.

Q. Just socially, speak to him, and that's it?

A. Yes.

Q. Picture, handshaking, and that?

A. [Nodding head.]

Q. Okay. That's a yes?

A. Yes. Sorry.

Q. Prior to December 6th, 1997, had you purchased a Christmas gift for the President?

A. Yes.

Q. Which was?

A. An antique standing cigar holder.

Q. And had you purchased any other additional gifts for him?

A. Yes.

Q. And what were those?

A. Uh, a Starbucks mug that said `Santa Monica'; a necktie that I got in London; a little box--I call it a `chochki'--from, uh--and an antique book on Theodore Roosevelt.

Q. Was it your intention to, to carry those Christmas presents to the President home that Saturday, December the 6th?

A. If I were to have a meeting with him, yes.

Q. Did you attempt to have a meeting?

A. Yes.

Q. Did you go through Betty Currie?

A. Yes. I sent her the letter to, to give to the President.

Q. And when you went to the White House that day, you also attempted to, to have the meeting through calling Betty Currie and telephoning her; I believe you had to go to--

A. Which day? I'm sorry.

Q. On the 6th.

A. No.

Q. The Saturday.

A. [No response.]

Q. No?

A. I--I attempted to give the presents to Betty, but I didn't call and attempt to have a meeting there--well, I guess I called in the morning, so that's not true--I'm sorry. Yes, I called Ms. Currie in the morning trying to see if I could see the President and apologize.

Q. And--were you--did you see the President, then, on the 6th?

A. Yes, I did.

Q. Tell us about that meeting--that was a long--was that, uh--did you have a telephone conversation with him that day also?

A. Yes.

Q. And that was the long telephone conversation?

A. It--it was.

Q. Okay. I think there has been some indication it
may have been 56 minutes, something approximating an hour-long conversation; does that sound right?

A. Right. That would--that might include some conversation time with Ms. Currie as well.

Q. Okay. Was he interrupted by Ms. Currie--could you tell--did he have to take a break from the telephone call to talk to Ms. Currie, or do you recall any, any--

A. I don't recall that.

Q. --do you recall any breaks to talk to anybody else?

A. I don't recall that. Doesn't mean it didn't happen; I just don't remember it.

Q. What else did you--did you arrange in that telephone conversation, or did he invite you in that telephone conversation to come to the White House that day?

A. Yes, he did.

Q. What happened during, during that conversation in terms of--I understand that it was again an emotional day, some sort of a word fight; is that right?

A. Yes.

Q. Could you tell me--he was, uh--again, to perhaps save some time--he was angry about an earlier incident, and, uh, he felt like you were intruding on his lawyer time?

A. Uh, he was upset that I hadn't accepted that he just couldn't see me that day.

Q. And what was your response to that?

A. Probably not positive. Uh, that's why it was a fight.

Q. Again, I want to be careful that I don't put words in your mouth, but you were dealing with this relationship from an emotional standpoint of wanting to spend time with him--

A. Yes.

Q. --not as President, but as a man?

A. Correct.

Q. And this was at a point when you didn't feel like you were spending enough time with him?

A. Correct.

Q. And he obviously felt he had to do other things, too, talk to lawyers and do those kinds of things--be the President--is that right?

A. Yes.

Q. Okay. Now, was some of this discussion that we term `the fight,' was that over the telephone?

A. Yes. It was all over the telephone.

Q. So by the time you arrived and had the face-to-face meeting with him, that was over?

A. Correct.

Q. Was that during the time that you exchanged--exchanged some of the Christmas presents with him?

A. In--in the meeting?

Q. Yes.

A. Yes. I gave him my Christmas presents.

Q. Did you discuss the job search with him also at that time?

A. I believe I mentioned it.

Q. Did you tell him that, uh, your job search with
Mr. Jordan was not going well?

A. I don't know if I used those words. I don't, I don't remember exactly--

Q. If your grand jury testimony said yes--I mean, words to that effect--that would--you could have used those words if they're in your grand jury--

A. If my grand jury testimony says that--if that's what I said in my grand jury testimony, then I accept that.

Q. I'm not trying to--I'm not trying to trick you.

A. Okay.

Q. Did he make any comment to you about what he might do to aid in your job search at that time, if you recall?

A. I think he--I think he said, oh, let me see about it, let me see what I can do--his usual.

Q. Did, uh, did the President say anything to you at that time about your name appearing on a witness list in the Paula Jones case?

A. No.

Q. Did you later learn that your name had appeared on such a list?

A. Yes.

Q. And did you later learn that that witness list had been faxed to the White House--to the President's lawyers on December the 5th?

A. Much later, as in last year.

Q. Okay. Yes--that's what I mean--later.

A. I, I mean--

Q. Yes.

A. --post this investigation.

Q. Okay. All right. Let's go forward another week or so to December the 11th and a lunch that you had with Vernon Jordan, I believe, in his office.

A. Yes.

Q. How did--how was that meeting set up.

A. Through his secretary.

Q. Did you instigate that, or did he call through his secretary?

A. I don't remember.

Q. What was the purpose of that meeting?

A. Uh, it was to discuss my job situation.

Q. And what, what--how was that discussed?

A. Uh, Mr. Jordan gave me a list of three names and suggested that I contact these people in a letter that I should cc him on, and that's what I did.

Q. Did he ask you to copy him on the letters that you sent out?

A. Yes.

Q. During this meeting, did he make any comments about your status as a friend of the President?

A. Yes.

Q. What--what did he say?

A. In one of his remarks, he said something about me being a friend of the President.

Q. And did you respond?

A. Yes.

Q. How?

A. I said that I didn't, uh--I think I--my grand jury
testimony, I know I talked about this, so it's probably more accurate. My memory right now is I said something about, uh, seeing him more as, uh, a man than as a President, and I treated him accordingly.

Q. Did you express your frustration to Mr. Jordan with, uh, with the President?

A. I expressed that sometimes I had frustrations with him, yes.

Q. And what was his response to you about, uh--after you talked about the President?

A. Uh, he sort of jokingly said to me, You know what your problem is, and don't deny it--you're in love with him. But it was a sort of light-hearted nature.

Q. Did you--did you have a response to that?

A. I probably blushed or giggled or something.

Q. Do you still have feelings for the President?

A. I have mixed feelings.

Q. What, uh--maybe you could tell us a little bit more about what those mixed feelings are.

A. I think what you need to know is that my grand jury testimony is truthful irrespective of whatever those mixed feelings are in my testimony today.

Q. I know in your grand jury you mentioned some of your feelings that you felt after he spoke publicly about the relationship, but let me ask you more about the positive--you said there were mixed feelings. What about--do you still, uh, respect the President, still admire the President?

A. Yes.

Q. Do you still appreciate what he is doing for this country as the President?

A. Yes.

Q. Sometime back in December of 1997, in the morning of December the 17th, did you receive a call from the President?

A. Yes.

Q. What was the purpose of that call? What did you talk about?

A. It was threefold--first, to tell me that Ms. Currie's brother had been killed in a car accident; second, to tell me that my name was on a witness list for the Paula Jones case; and thirdly, he mentioned the Christmas present he had for me.

Q. This telephone call was somewhere in the early morning hours of 2 o'clock to 2:30.

A. Correct.

Q. Did it surprise you that he called you so late?

A. No.

Q. Was this your first notice of your name being on the Paula Jones witness list?

A. Yes.

Q. I realize he, he commented about some other things, but I do want to focus on the witness list.

A. Okay.

Q. Did he say anything to you about how he felt concerning this witness list?

A. He said it broke his heart that, well, that my
name was on the witness list.

Can I take a break, please? I'm sorry.

SENATOR DeWINE: Sure, sure. We'll take a 5-minute break at this point.

THE VIDEOGRAPHER: This marks the end of Videotape Number 1 in the deposition of Monica S. Lewinsky. We are going off the record at 10:56 a.m.

[Recess.]

THE VIDEOGRAPHER: This marks the beginning of Videotape Number 2 in the deposition of Monica S. Lewinsky. The time is 11:10 a.m.

SENATOR DeWINE: We are now back on the record.

I will advise the House Managers that they have used one hour and 8 minutes.

Mr. Bryant, you may proceed.

MR. BRYANT: Thank you.

By MR. BRYANT:

Q. Did--did we get your response? We were talking about the discussion you were having with the President over the telephone, early morning of the December 17th phone call, and he had, uh, mentioned that it broke his heart that you were on that list.

A. Correct.

Q. And I think you were about to comment on that further, and then you need a break.

A. No.

Q. No.

A. I just wanted to be able to focus--I know this is an important date, so I felt I need a few moments to be able to focus on it.

Q. And you're comfortable now with that, with your--you are ready to talk about that?

A. Comfortable, I don't know, but I'm ready to talk about.

Q. Well, I mean comfortable that you can focus on it.

A. Yes, sir.

Q. Good. Now, with this discussion of the fact that your name appeared as a witness, had you--had you been asleep that night when the phone rang?

A. Yes.

Q. So were you wide awake by this point? It's the President calling you, so I guess you're--you wake up.

A. I wouldn't say wide awake.

Q. He expressed to you that your name--you know, again, you talked about some other things--but he told you your name was on the list.

A. Correct.

Q. What was your reaction to that?

A. I was scared.

Q. What other discussion did you have in regard to the fact that your name was on the list? You were scared; he was disappointed, or it broke his heart. What other discussion did you have?

A. Uh, I believe he said that, uh--and these are not necessarily direct quotes, but to the best of my memory, that he said something about that, uh, just because my name was on the list didn't necessarily mean I'd be subpoenaed;
and at some point, I asked him what I should do if I received a subpoena. He said I should, uh, I should let Ms. Currie know. Uh--

Q. Did he say anything about an affidavit?

A. Yes.

Q. What did he say?

A. He said that, uh, that I could possibly file an affidavit if I--if I were subpoenaed, that I could possibly file an affidavit maybe to avoid being deposed.

Q. How did he tell you you would avoid being deposed by filing an affidavit?

A. I don't think he did.

Q. You just accepted that statement?

A. [Nodding head.]

Q. Yes?

A. Yes, yes. Sorry.

Q. Are you, uh--strike that. Did he make any representation to you about what you could say in that affidavit or--

A. No.

Q. What did you understand you would be saying in that affidavit to avoid testifying?

A. Uh, I believe I've testified to this in the grand jury. To the best of my recollection, it was, uh--to my mind came--it was a range of things. I mean, it could either be, uh, something innocuous or could go as far as having to deny the relationship. Not being a lawyer nor having gone to law school, I thought it could be anything.

Q. Did he at that point suggest one version or the other version?

A. No. I didn't even mention that, so there, there wasn't a further discussion--there was no discussion of what would be in an affidavit.

Q. When you say, uh, it would be--it could have been something where the relationship was denied, what was your thinking at that point?

A. I--I--I think I don't understand what you're asking me. I'm sorry.

Q. Well, based on prior relations with the President, the concocted stories and those things like that, did this come to mind? Was there some discussion about that, or did it come to your mind about these stories--the cover stories?

A. Not in connection with the--not in connection with the affidavit.

Q. How would--was there any discussion of how you would accomplish preparing or filing an affidavit at that point?

A. No.

Q. Why--why didn't you want to testify? Why would not you--why would you have wanted to avoid testifying?

A. First of all, I thought it was nobody's business. Second of all, I didn't want to have anything to do with Paula Jones or her case. And--I guess those two reasons.

Q. You--you have already mentioned that you were not a lawyer and you had not been to law school, those kinds of things. Did, uh, did you understand when you--the potential legal problems that you could have caused yourself by
allowing a false affidavit to be filed with the court, in a court proceeding?

A. During what time--I mean--I--can you be--I'm sorry--

Q. At this point, I may ask it again at later points, but the night of the telephone--

A. Are you--are you still referring to December 17th?

Q. The night of the phone call, he's suggesting you could file an affidavit. Did you appreciate the implications of filing a false affidavit with the court?

A. I don't think I necessarily thought at that point it would have to be false, so, no, probably not. I don't--I don't remember having any thoughts like that, so I imagine I would remember something like that, and I don't, but--

Q. Did you know what an affidavit was?

A. Sort of.

Q. Of course, you're talking at that time by telephone to the President, and he's--and he is a lawyer, and he taught law school--I don't know--did you know that? Did you know he was a lawyer?

A. I--I think I knew it, but it wasn't something that was present in my, in my thoughts, as in he's a lawyer, he's telling me, you know, something.

Q. Did the, did the President ever tell you, caution you, that you had to tell the truth in an affidavit?

A. Not that I recall.

Q. It would have been against his interest in that lawsuit for you to have told the truth, would it not?

A. I'm not really comfortable--I mean, I can tell you what would have been in my best interest, but I--

Q. But you didn't file the affidavit for your best interest, did you?

A. Uh, actually, I did.

Q. To avoid testifying.

A. Yes.

Q. But had you testified truthfully, you would have had no--certainly, no legal implications--it may have been embarrassing, but you would have not had any legal problems, would you?

A. That's true.

Q. Did you discuss anything else that night in terms of--I would draw your attention to the cover stories. I have alluded to that earlier, but, uh, did you talk about cover story that night?

A. Yes, sir.

Q. And what was said?

A. Uh, I believe that, uh, the President said something--you can always say you were coming to see Betty or bringing me papers.

Q. I think you've testified that you're sure he said that that night. You are sure he said that that night?

A. Yes.

Q. Now, was that in connection with the affidavit?

A. I don't believe so, no.

Q. Why would he have told you you could always say that?

A. I don't know.

Mr. BURTON: Objection. You're asking her to speculate on someone else's testimony.

MR. BRYANT: Let me make a point here. I've been very patient in trying to get along, but as I alluded to earlier, and I said I am not going to hold a hard line to this, but I don't think the President's--the witness' lawyers ought to be objecting to this testimony. If there's an objection here, it should come from the White House side, nor should they be--

SENATOR DeWINE: Counsel, why don't you rephrase the question?

MR. BRYANT: Do we have a clear ruling on whether they can object?

SENATOR DeWINE: We'll go off the record for a moment.

THE VIDEOGRAPHER: We're going off the record at 11:20 a.m.

[Recess.]

THE VIDEOGRAPHER: We are going back on the record at 11:30 a.m.

SENATOR DeWINE: We are now back on the record.

It's our opinion that counsel for Ms. Lewinsky do have the right to make objections. We would ask them to be as short and concise as humanly possible. So we will now proceed.

Mr. Bryant?

MR. BRYANT: Thank you, Senator.

BY MR. BRYANT:

Q. Let's kind of bring this back together again, and I'll try to ask sharper questions and avoid these objections.

We're at that point that we've got a telephone conversation in the morning with you and the President, and he has among other things mentioned to you that your name is on the Jones witness list. He has also mentioned to you that perhaps you could file an affidavit to avoid possible testifying in that case. Is that right?

A. Correct.

Q. And he has also, I think, now at the point that we were in our questioning, referenced the cover story that you and he had had, that perhaps you could say that you were coming to my office to deliver papers or to see Betty Currie; is that right?

A. Correct. It was from the entire relationship, that story.

Q. Now, when he alluded to that cover story, was that instantly familiar to you?

A. Yes.

Q. You knew what he was talking about?

A. Yes.

Q. And why was this familiar to you?

A. Because it was part of the pattern of the relationship.

Q. Had you actually had to use elements of this cover story in the past?

A. I think so, yes.

Q. Did the President ever tell you what to say if
anyone asked you about telephone conversations that you had had with him?

A. Are we--are we still focused on December 17th?

Q. No, no.

A. Okay.

Q. It did not have to be that night. Did he ever?

A. If I could just--I--I'm pretty date-oriented, so if you could just be more specific with the date. If we're staying on a date or leaving that date, it would just help me. I'm sorry.

Q. Well, my question was phrased did he ever do that, but--

A. Okay.

Q. Well, I--I'm sorry. I'm playing guessing games with you. Was there a conversation on March 29th of 1997 when the President told you he thought perhaps his telephone conversations were being tapped or taped--either way, or both--by a foreign embassy?

A. Yes.

Q. And was there some reference to some sort of cover story there in the event that his line was tapped?

A. Yes.

Q. And what was that?

A. That--I think, if I remember it correctly, it was that we--that he knew that we were sort of engaging in those types of conversations, uh, knowing that someone was listening, so that it was not for the purposes that it might have seemed.

Q. Did you find it a little strange that he would express concern about possible eavesdropping and still persist in these calls to you?

A. I don't think phone calls of that nature occurred and happened right after, or soon after that discussion. I think it was quite a few months until that resumed.

Q. I think my question was more did you not find it a little strange that he felt that perhaps his phone was being tapped and conversations taped by a foreign embassy, and he--

A. I--I thought it was strange, but if--I mean, I wasn't going to question what he was saying to me.

Q. But that he also continued to make the calls--you're saying he didn't make any calls after that?

A. No. My understanding was it was referencing a certain type of phone call, certain nature of phone call, uh, and those--

Q. Let me direct your attention back to a point I did not mention a couple--a few days before the December--early December telephone call, the lengthy telephone call from the President. We had talked about how that was a heated conversation.

A. Correct.

Q. At--did at some point during that telephone conversation--did the tone--did the President's tone change to a more receptive, friendly conversation?

A. Yes.

Q. Do you know why that happened?

A. No, nor do I remember whose tone changed first. I
mean, we made up, so--

Q. Okay. Now let me go back again to the December 11th date--I'm sorry--the 17th. This is the conversation in the morning. What else--was there anything else you talked about in terms of--other than your name being on the list and the affidavit and the cover story?

A. Yes. I had--I had had my own thoughts on why and how he should settle the case, and I expressed those thoughts to him. And at some point, he mentioned that he still had this Christmas present for me and that maybe he would ask Mrs. Currie to come in that weekend, and I said not to because she was obviously going to be in mourning because of her brother.

Q. In--in that--in that relationship with the President, I think you have expressed in your testimony somewhere that you weren't necessarily jealous of those types of people like Kathleen Willey or Paula Jones, and perhaps you didn't even believe those stories occurred as--as they alleged.

A. That's correct. I don't--I don't know, jealous or not jealous. I don't think I've testified to my feelings of jealousy, but the latter half of the question is true.

Q. I--I saw it. I mean, it's not a major point. I thought I saw that in your testimony, that particular word.

A. Okay. If I said that, then I--I don't.

Q. Was it your belief that the Paula Jones case was not a valid lawsuit? Was that part of that discussion that night, or your strategy?

A. Uh, can I separate that--that into two questions?

Q. Any way, any way you want to.

A. Okay. I don't believe it was a valid lawsuit, and I don't think whether I believed it was a valid lawsuit or not was the topic of the conversation.

Q. Okay, that's a fair answer.

You believe the President's version of the Paula Jones incident?

A. Is that relevant to--

Q. I--I just asked you the question.

A. I don't believe Paula Jones' version of the story.

Q. Okay, good. That's a fair answer.

You have testified previously that you tried to maintain secrecy regarding this relationship--and we're talking about obviously with the President. Is that true?

A. Yes.

Q. And to preserve the secrecy and I guess advance this cover story, you would bring papers to the President and always use Betty Currie for the excuse for you to be WAVE'd in. Is that right?

A. Papers when I was working at the White House and Mrs. Currie after I left the White House. So Mrs. Currie wasn't involved when I was working at the White House.

Q. Were these papers you carried in to the President--were they--were they business documents, or were they more personal papers from you to him?

A. They--they weren't business documents.

Q. So, officially, you were not carrying in official papers?

A. Correct.

Q. You were carrying in personal papers that would not have entitled you ordinarily to go see the President?

A. Correct.

Q. When--in this procedure where Betty Currie was always the one that WAVE'd you in to the White House--and I--I don't know if the people who may be watching this deposition, the Senators, understand that the WAVES process is just the--to give the guards the okay for you to come in. Is that a short synopsis?

A. I'm not really versed on--

Q. I'm not either. You know more than I do, probably, since you worked there, but--

A. Well, I know you had to go, you had to type in a thing in at WAVES, and now you have to give a Social Security, birth date, have to show ID.

Q. Is there a record kept of that?

A. I believe so.

Q. Was it always Betty Currie that WAVE'd you in to the--access to the White House? I'm talking about now after you left and went to work at the Pentagon.

A. No.

Q. Other people did that?

A. There were other reasons that I came to the White House at times.

Q. Did you ever ask the President if he would WAVE you in?

A. Yes.

Q. Did he ever do that?

A. No, not to my--not to my knowledge.

Q. Was there a reason? Did he express anything to you why he would or would not?

A. Yes. He said that, uh--I believe he said something about that there's a specific list made of people that he requests to come in and--and there are people who have access to that list.

Q. So, obviously, he didn't want your name being on that list?

A. Correct.

Q. Now, some of those people--

A. I think--well, that's my understanding.

Q. Would some of those people be the people that worked outside his office, Ms. Lieberman and those--those folks?

A. I--I believe so, but I'm not really sure.

Q. Did you not want those people to know that you were inside the White House?

A. I didn't.

Q. Why is that?

A. Because they didn't like me.

Q. Would they have objected, do you think--if you know.

A. I don't know.

Q. Did you work with Betty Currie on occasions to--to get in to see the President, perhaps bypass some of these people?

A. Yes.

Q. And that would be another way that you would conceal the meeting with the President, by using Betty Currie to get you in?

A. I--I think, yes, be cautious of it.

Q. Did--well, I think we've covered that, about some papers, and I think we've covered that after you left your job inside the White House with Legislative Affairs and went to the Pentagon, you developed a story, a cover story to the effect that you were going to see Betty, that's how you would come in officially?

A. Correct.

Q. And during that time that you were at the Pentagon, you would more likely visit him on weekends or during the week? Which would--which would--

A. Weekends.

Q. Weekends. And why--why the weekends?

A. First, I think he had less work, and second of all, there were--I believe there were less people around.

Q. Now, whose idea was it for you to come on weekends?

A. I believe it was the President's.

Q. When you--when the President was in his office, was your purpose to go there and see him? If he was in the office, you would go see him?

A. What--I'm sorry.

Q. No--that's not clear. I'll withdraw that question.

Was Ms. Currie, the President's secretary--was she in the loop, so to speak, in keeping this relationship and how you got in and out of the White House, keeping that quiet?

A. I think I actually remember reading part of my grand jury testimony about this and that it was more specific in that she was in the loop about my friendship with the President, but I just want to not necessarily--there was a clarification, I believe, in that about knowledge of the complete relationship or not. So--

Q. She would help with the gifts and notes and things like that--the passing?

A. Yes.

Q. Would you agree that these cover stories that you've just testified to, if they were told to the attorneys for Paula Jones, that they would be misleading to them and not be the whole story, the whole truth?

A. They would--yes, I guess misleading. They were literally true, but they would be misleading, so incomplete.

Q. As I understand your testimony, too, the cover stories were reiterated to you by the President that night on the telephone--

A. Correct.

Q. --and after he told you you would be a witness--or your name was on the witness list, I should say?

A. Correct.

Q. And did you understand that since your name was on the witness list that there would be a possibility that you could be subpoenaed to testify in the Paula Jones case?

A. I think I understood that I could be subpoenaed, and there was a possibility of testifying. I don't know if I necessarily thought it was a subpoena to testify, but--

Q. Were you in fact subpoenaed to testify?

A. Yes.

Q. And that was what--

A. December 19th, 1997.

Q. December 19th.

Now, you have testified in the grand jury. I think your closing comments was that no one ever asked you to lie, but yet in that very conversation of December the 17th, 1997 when the President told you that you were on the witness list, he also suggested that you could sign an affidavit and use misleading cover stories. Isn't that correct?

A. Uh--well, I--I guess in my mind, I separate necessarily signing affidavit and using misleading cover stories. So, does--

Q. Well, those two--

A. Those three events occurred, but they don't--they weren't linked for me.

Q. But they were in the same conversation, were they not?

A. Yes, they were.

Q. Did you understand in the context of the conversation that you would deny the--the President and your relationship to the Jones lawyers?

A. Do you mean from what was said to me or--

Q. In the context of that--in the context of that conversation, December the 17th--

A. I--I don't--I didn't--

Q. Okay. Let me ask it. Did you understand in the context of the telephone conversation with the President that early morning of December the 17th--did you understand that you would deny your relationship with the President to the Jones lawyers through use of these cover stories?

A. From what I learned in that--oh, through those cover stories, I don't know, but from what I learned in that conversation, I thought to myself I knew I would deny the relationship.

Q. And you would deny the relationship to the Jones lawyers?

A. Yes, correct.

Q. Good.

A. If--if that's what it came to.

Q. And in fact you did deny the relationship to the Jones lawyers in the affidavit that you signed under penalty of perjury; is that right?

A. I denied a sexual relationship.

Q. The President did not in that conversation on December the 17th of 1997 or any other conversation, for that matter, instruct you to tell the truth; is that correct?

A. That's correct.

Q. And prior to being on the witness list, you--you both spoke--

A. Well, I guess any conversation in relation to the Paula Jones case. I can't say that any conversation from
the--the entire relationship that he didn't ever say, you know, `Are you mad? Tell me the truth.' So--

Q. And prior to being on the witness list, you both spoke about denying this relationship if asked?

A. Yes. That was discussed.

Q. He would say something to the effect that--or you would say that--you--you would deny anything if it ever came up, and he would nod or say that's good, something to that effect; is that right?

A. Yes, I believe I testified to that.

Q. Let me shift gears just a minute and ask you about--and I'm going to be delicate about this because I'm conscious of people here in the room and my--my own personal concerns--but I want to refer you to the first so-called salacious occasion, and I'm not going to get into the details. I'm not--

A. Can--can we--can you call it something else?

Q. Okay.

A. I mean, this is--this is my relationship--

Q. What would you like to call it?

A. --so, I mean, is--

Q. This is the--or this was--

A. It was my first encounter with the President, so I don't really see it as my first salacious--that's not what this was.

Q. Well, that's kind of been the word that's been picked up all around. So--

A. Right.

Q. --let's stay on this first--

A. Encounter, maybe?

Q. Encounter, okay.

A. Okay.

Q. So we all know what we're talking about. You had several of these encounters, perhaps 10 or 11 of these encounters; is that right?

A. Yes.

Q. Okay. Now, with regard to the first one on November the 15th, 1995, you have testified to a set of facts where the President actually touched you in certain areas--is that right--and that's--that's where I want to go. That's as far as I want to go with that question.

MR. CACHERIS: If that's as far as it goes, we will not object--

MR. BRYANT: Okay.

MR. CACHERIS: --and if it goes any further, we will object.

MR. BRYANT: Okay.

BY MR. BRYANT:

Q. You have testified to that?

A. Yes.

Q. And I have the excerpts out, and I don't--but they've been adopted and affirmed as true. So I'm not going to get--get you looking at--have you read those excerpts.

A. I appreciate that.

Q. Now, in the--in later testimony before the grand jury, you were given a definition, and in fact it was the same definition that was used in the Paula Jones lawsuit, of `sexual relations.' Do you recall the--

A. So I've read.

Q. Yes.

A. I was not shown that definition.

Q. But you were asked a question that incorporated that definition.

A. Not prior to this whole--not prior to the Independent Counsel getting involved.

Q. But--no--it was the Independent Counsels themselves who asked you this question.

A. Right. Oh, so you're--you're saying in the grand jury, I was shown a definition of--

Q. Right.

A. Yes, that's correct.

Q. And you admitted in that answer to that question that the conduct that you were involved in, the encounter of November the 15th, 1995, fit within that definition of `sexual relations'?

A. The second encounter of that evening did.

Q. Right.

And were there other similar encounters later on with the President, not that day, but other occasions that would have likewise fit into that definition of `sexual relations' in the Paula Jones case?

A. Yes. And--yes.

Q. There was more than one occasion where that occurred?

A. Correct.

Q. So, if the President testifies that he did not--he was not guilty of having a sexual relationship under the Paula Jones definition even, then that testimony is not truthful, is it?

MR. CACHERIS: Objection. She should not be called upon to testify what was in the mind of another person. She's testifying to the facts, and she has given the facts.

MR. BRYANT: I would ask that she answer the question.

SENATOR DeWINE: Go ahead.

SENATOR LEAHY: The objection is noted for the record.

SENATOR DeWINE: The objection is noted. She may answer the question.

THE WITNESS: I--I really--

SENATOR LEAHY: If she can.

THE WITNESS: --don't feel comfortable characterizing whether what he said was truthful or not truthful. I know I've testified to what I believe is true.

BY MR. BRYANT:

Q. Well, truth is not a wandering standard.

A. Well--

Q. I would hope not. But you have testified, as I've told you, that what you and he did together on November the 15th, 1995 fit that definition of the Paula Jones, and you've indicated that there were other occasions that likewise--

A. Yes, sir.

Q. --that that occurred.

But now the President has indicated as a part of his specific defense--he has filed an answer with this Senate denying that this occurred, that he did these actions.

A. I know. I'm not trying to be difficult, but there is a portion of that definition that says, you know, with intent, and I don't feel comfortable characterizing what someone else's intent was.

I can tell you that I--my memory of this relationship and what I remember happened fell within that definition.

If you want to--I don't know if there's another way to phrase that, but I'm just not comfortable commenting on someone else's intent or state of mind or what they thought.

Q. Let's move forward to December the 19th, 1997, at that point you made reference to earlier.

A. I'm sorry. Can you repeat the date again? I'm sorry.

Q. Yes. December the 19th, 1997.

A. Okay, sorry.

Q. At that point where you testified that you received a subpoena in the Paula Jones case, and that was, of course, on December the 19th, 1997.

Do you recall the specific time of day and where you were when you were served with the subpoena?

A. I was actually handed the subpoena at the Metro entrance of the Pentagon--at the Pentagon, and the time--I think it was around 4:30--4--I--I--if I've testified to something different, then, I accept whatever I testified to, closer to the date. Sometime in the late afternoon.

Q. Did they call you, and you had to come out of your office and go outside--

A. Correct.

Q. --and do that?

Okay. And what did you do after you accepted service of the subpoena?

A. I started crying.

Q. Did he just give it to you and walk away, or did he give you any kind of explanation?

A. I think I made a stink. I think I was trying to hope that he would convey to the Paula Jones attorneys that I didn't know why they were doing this, and this is ridiculous, and he said something or another, there is a check here for witness fee. And I said I don't want their stinking money, and so--

Q. What did you do after, after you got through the emotional part?

A. I went to a pay phone, and I called Mr. Jordan.

Q. Any reason you went to a pay phone, and why did you call Mr. Jordan? Two questions, please.

A. First is because my office in the Pentagon was probably a room this size and has--let's see, one, two, three, four--four other people in it, and there wasn't much privacy. So that I think that's obvious why I wouldn't want to discuss it there.

And the second question was why Mr. Jordan--

Q. Why did you call Mr. Jordan; yes.

A. Because I couldn't call Mrs. Currie because it was--I hadn't expected to be subpoenaed that soon. So she was grieving with her brother's passing away, and I didn't know who else to turn to. So--

Q. And what--what occurred with that conversation with Mr. Jordan?

A. Well, I remember that--that he couldn't understand me because I was crying. So he kept saying: `I don't understand what you're saying. I don't understand what you're saying.'

And I just was crying and crying and crying. And so all I remember him saying was: `Oh, just come here at 5 o'clock.'

So I did.

Q. You went to see Mr. Jordan, and you were inside his office after 5 o'clock, and you did--is that correct?

A. Yes.

Q. Were--were you interrupted, in the office?

A. Yes. He received a phone call.

Q. And you testified that you didn't know who that was that called?

A. Correct.

Q. Did you excuse yourself?

A. Yes.

Q. What--after you came back in, what--what occurred? Did he tell you who he had been talking to?

A. No.

Q. Okay. What happened next?

A. I know I've testified about this--

Q. Yes.

A. --so I stand by that testimony, and my recollection right now is when I came back in the room, I think shortly after he had placed a phone call to--to Mr. Carter's office, and told me to come to his office at 10:30 Monday morning.

Q. Did you know who Mr. Carter was?

A. No.

Q. Did Mr. Jordan tell you who he was?

A. No--I don't remember.

Q. Did you understand he was going to be your attorney?

A. Yes.

Q. Did you express any concerns about the--the subpoena?

A. I think that happened before the phone call came.

Q. Okay, but did you express concerns about the subpoena?

A. Yes, yes.

Q. And what were those concerns?

A. In general, I think I was just concerned about being dragged into this, and I was concerned because the subpoena had called for a hatpin, that I turn over a hatpin, and that was an alarm to me.

Q. How--in what sense was it--in what sense was it an alarm to you?

A. The hatpin being on the subpoena was evidence to me that someone had given that information to the Paula Jones people.

Q. What did Mr. Jordan say about the subpoena?

A. That it was standard.

Q. Did he have any--did he have any comment about the specificity of the hatpin?

A. No.

Q. And did you--

A. He just kept telling me to calm down.

Q. Did you raise that concern with Mr. Jordan?

A. I don't remember if--if I've testified to it, then yes. If--I don't remember right now.

Q. Did--would you have remembered then if he made any comment or answer about the hatpin?

A. I mean, I think I would.

Q. And you don't remember?

A. I--I remember him saying something that it was--you know, calm down, it's a standard subpoena or vanilla subpoena, something like that.

Q. Did you ask Mr. Jordan to call the President and advise him of the subpoena?

A. I think so, yes. I asked him to inform the President. I don't know if it was through telephone or not.

Q. And you did that because the President had asked you to make sure you let Betty know that?

A. Well, sure. With Betty not being in the office, I couldn't--there wasn't anyone else that I could call to get through to him.

Q. Did Mr. Jordan say to you when he might see the President next?

A. I believe he said he would see him that evening at a holiday reception.

Q. Did Mr. Jordan during that meeting make an inquiry about the nature of the relationship between you and the President?

A. Yes, he did.

Q. What was that inquiry?

A. I don't remember the exact wording of the questions, but there were two questions, and I think they were something like did you have sex with the President or did he--and if--or did he ask for it or some--something like that.

Q. Did you--what did you suspect at that point with these questions from Mr. Jordan in terms of did he know or not know about this?

A. Well, I wasn't really sure. I mean, two things. I think there is--I know I've testified to this, that there was another component to all of this being Linda Tripp and her--what she might have led me to believe or led me to think and how that might have characterized how I was perceiving the situation.

I--I sort of felt that I didn't know if he was asking me as what are you going to say because I--I don't know these answer to these questions, or he was asking me as I know the answer to these questions and what are you going to say. So, either way, for me, the answer was no and no.

Q. And that's just what I wanted to ask you--you did answer no to both of those, but--

A. Yes.

Q. --as you explained--you didn't mention this directly, but you mentioned in some of your earlier testimony about it, that this was kind of a wink and--you thought this might be a wink-and-nod conversation, where he really knew what was going on, but--

A. Well, I think that's what I just said.

Q. --he was testing you to see what you would say?

A. --that I wasn't--I--that was one of the--that was one of the things that went through my mind. I mean, it was not--I think that's what I just testified to, didn't I?

Q. You didn't use the term `wink-and-nod,' though.

A. Oh.

Q. Did you have any conversation with Mr. Jordan during that meeting about the specifics of an affidavit?

A. No.

Q. Do you know if the subject of an affidavit even came up?

A. I don't think so.

Q. What happened next? Is that when he made the call to Mr. Carter, after this conversation?

A. No. He made the call to Mr: I think--well, I think he made the call to Mr. Carter, uh, shortly after I came back into the room, but I could be wrong.

Q. And then the meeting concluded after that--after the appointment was set up with Mr. Carter, the meeting concluded?

A. Yes.

SENATOR DeWINE: Mr. Bryant, we're going to need to break sometime in the next 5 minutes. Is this a good time, or do you want to complete--

MR. BRYANT: This is a good time.

SENATOR DeWINE: Okay. We'll take a 5-minute break.

THE VIDEOGRAPHER: We're going off the record at 12:04 p.m.

[Recess.]

THE VIDEOGRAPHER: We are going back on the record at 12:16 p.m.

SENATOR DeWINE: We are back on the record.

Let me advise House Managers that they have consumed one hour and 54 minutes.

Mr. Bryant, you may proceed.

MR. BRYANT: Thank you, sir.

BY MR. BRYANT:

Q. Ms. Lewinsky, let me just cover a couple of quick points, and then I'll move on to another area, at least the next meeting with Mr. Jordan and eventual meeting with Mr. Carter.

Back when issues of--we were discussing the issues of cover stories, uh, would you tell me about the, uh, code name with Betty Currie, the President's secretary and how that worked in terms of the use--I guess the word `Kay,' the name `Kay,' and were there other code names, and when did this start?

A. Sure. First, let me say there's--from my experience with working with Independent Counsel on this subject area, there--my initial memory of things and then what I came to learn from, from other evidence, I think, are sort of two different things. So I initially hadn't remembered when that had happened or what had happened.

The name `Kay' was used because Betty and I first came to know each other and know--or, I guess I came to know of Mrs. Currie through Walter Kaye, who was a family friend, and I think that that--I don't remember when we started using it, but I know that by January at some point--by let's just say January, I think, 12th or 13th, we were doing that. So I know I was beyond paranoid at this point.

Q. Was `Kay' your code name, so to speak?

A. I believe--yes, yes. So she was `Kay' and I was `Kay.'

Q. So any time, uh--not any time--so you used the `Kay' name interchangeably between the two--just between the two of you?

A. Just for paging messages.

Q. And, uh, when we're talking about that Ms. Currie would WAVE you into the White House, would that occur when the President was there? I mean, you went in--

A. There--there were times that I went to see Mrs. Currie when the President wasn't there.

Q. Right. And she would WAVE you in.

A. Correct.

Q. And there were times other people WAVE'd you in when the President wasn't there?

A. Correct.

Q. But when the President was there, and you were going to see the President, Ms. Currie was the one that always WAVE'd you in?

A. Yes, and I think, unless--maybe on the occasions of the radio address or it was an official function.

Q. Now, I think we talked a little bit about this. During your December the 19th meeting with Mr. Jordan, uh, he did schedule you a time to meet, uh, and introduce you to Mr. Carter?

A. Correct.

Q. And that--when was that meeting with Mr. Carter scheduled?

A. Uh, I believe for--it was Monday morning. I think it was 11 o'clock, around--sometime around that time.

Q. And my notes say that would have been December the 22nd, 1997.

A. Correct.

Q. Did you, uh, call to meet him earlier, and if so, why?

A. Yes. I had--I had had some concerns over the weekend that I didn't know if--if Mr. Jordan knew about the relationship or didn't know about the relationship. I was concerned about--I'm sure you can understand that I was dealing with a set of facts that were very different from what the President knew about being pulled into this case in that I had, in fact, disclosed information. So I was very paranoid, and, uh, I, uh, I--I was trying to--trying to see what Mr. Jordan knew was--was trying to inform him, was trying to just get a better grasp of what was going on.

Is that--is that clear? No?

Q. You were--you were worried that Mr. Jordan didn't have a--did not have a grasp of what was really going on?

A. Correct.

Q. And that would be in terms of actually knowing the real relationship between you and the President?

A. Correct.

Q. So how did you attempt to correct that?

A. Well, I--I sort of--I think the way it came up was I said, uh--I think I said to Mr. Jordan--I know I've testified to this, uh, that--something about what about if someone overheard the phone calls that I had with him. And Mr. Jordan, I believe, said something like: So what? The President's allowed to call people.

And then--well.

Q. Now, was this at a meeting on December the 22nd, before you went to see Mr. Carter?

A. Correct.

Q. I assume you--you went to Mr. Jordan's office first, and then he was going to escort you over and turn you over to Mr. Carter?

A. Correct.

Q. And it was at that meeting that you brought up the possibility of someone overhearing a conversation with the President and you--between the two of you?

A. Yes.

Q. What else was said at that meeting with Mr. Jordan?

A. I think it covered a topic that I thought we weren't discussing here.

Q. Uh, okay. All right. I'm not sure.

A. Okay. Well, I--I know I've testified to this in my--I think in all three, if not both of my grand jury appearances, and I'm very happy to stand by that testimony.

Q. All right. I'm going to go around this a little bit without getting into details. You had a conversation with Mr. Jordan to detail--to give him more specific details of your relationship with the President.

A. Uh, to give him more details of some of the types of phone calls that we had.

Q. Okay. Uh, did you ask Mr. Jordan had he spoken with the President during that conversation?

A. Yes, I believe so.

Q. And why was this--why did you need to know that, or why was it important that you know that?

A. I wanted the President to know I'd been subpoenaed.

Q. Did, uh--in your, uh, proffer, you say that you made it clear to Mr. Jordan that you would deny the sexual relationship. Do you recall saying that in your proffer?

A. Uh, I know--I know that was written in my proffer.

Q. Okay. Well, I guess the better question is did you--did you in fact make that clear to Mr. Jordan that you would deny a sexual relationship with the President?

A. I--I'm not really sure. I--this is sort of an
area that, uh, has been difficult for me. I think, as I might have discussed in the grand jury, that when I originally wrote this proffer, it was to be a road map and, really, something to help me to get immunity and not necessarily--it's not perfect.

Uh, so, I think that was my intention--I know that was my intention of--or at least what I thought I was doing--but I never really thought that this would become the be-all and end-all, my proffer.

Q. Did, uh, did you bring with you to the meeting with Mr. Jordan, and for the purpose of carrying it, I guess, to Mr. Carter, items in response to this request for production?

A. Yes.

Q. Did you discuss those items with Mr. Jordan?

A. I think I showed them to him, but I'm not 100 percent sure. If I've testified that I did, then I'd stand by that.

Q. Okay. How did you select those items?

A. Uh, actually, kind of in an obnoxious way, I guess. I--I felt that it was important to take the stand with Mr. Carter and then, I guess, to the Jones people that this was ridiculous, that they were--they were looking at the wrong person to be involved in this. And, in fact, that was true. I know and knew nothing of sexual harassment. So I think I brought the, uh, Christmas cards, that I'm sure everyone in this room has probably gotten from the President and First Lady, and considered that correspondence, and some innocuous pictures and--they were innocuous.

Q. Were they the kind of items that typically, an intern would receive or, like you said, any one of us might receive?

A. I think so.

Q. In other words, it wouldn't give away any kind of special relationship?

A. Exactly.

Q. And was that your intent?

A. Yes.

Q. Did you discuss how you selected those items with anybody?

A. I don't believe so.

Q. Did Mr. Jordan make any comment about those items?

A. No.

Q. Were any of these items eventually turned over to Mr. Carter?

A. Yes.

Q. And did you tell Mr. Jordan at that meeting that morning that these were not all of the gifts?

A. I think I--I know I sort of alluded to that in my proffer, and I don't, uh--it's possible. I don't have a specific recollection of that.

Q. And do you have a recollection of any response he may have made if you said that?

A. No.

Q. That--did you tell Mr. Jordan that day that the, uh, President gave you a hatpin and that the hatpin was mentioned in the subpoena?

A. No.

Q. Did you discuss the hatpin with Mr. Jordan?

A. On the 22nd?

Q. Yes.

A. No.

Q. Any other time?

A. Yes.

Q. When was that?

A. On the 19th.

Q. Okay, and what was--I think I may have missed that, going through that. Tell me about it.

A. Actually, I think we--we went through it.

Q. You just maybe mentioned it.

A. I mentioned it when I first mentioned to him the subpoena that the hatpin had concerned me.

Q. What was the significance of that hatpin to you? That seems to stand out. Was that--was that a--

A. Right. I think, as I mentioned before, it was an alarm to me because it was a specific item--

Q. Right.

A. --in this list of generalities--I don't know generalities, but of general things--you sort of go--hatpin?

Q. Right. I recall that, but I--I think my question was, was it of any special significance to you.

A. Sure.

Q. Was it, like, the first gift or something, that it really stood out above the others?

A. Yes. It--it was--it was the first gift he gave me. It was a thoughtful gift. It was beautiful.

Q. And was the hatpin in that list, that group of items that you carried to surrender to Mr. Carter?

A. No.

Q. And the hatpin was not in that list of items that you showed Mr. Jordan?

A. I--I didn't show Mr. Jordan a list of items.

Q. No--I thought you said you showed him the items.

A. Correct.

Q. And the hatpin was not in that group--I may have `list'--

A. Oh.

Q. --but the hatpin was not in that group of items--

A. No, it was not.

Q. --that you showed Mr. Jordan. Okay.

Tell us, if you would, how you arrived at Mr. Carter's. I know you rode in a car, but Mr. Jordan was with you--

A. Yes.

Q. --you went in--and tell us what happened.

A. Uh, in the car, we spoke about job things. I know he mentioned something about, I think, getting in touch with Howard Pastor, and I mentioned to Mr. Jordan that Mr. Bacon knew Mr. Pastor and had already gotten in touch with him, and so he should--I just wanted Mr. Jordan to be aware of that.

Uh, we talked about--it was really all about the job stuff because Mr. Jordan--the man driving the car--I didn't want to discuss anything with the case.

Q. But once you arrived, and Mr. Jordan made the introduction--

A. Correct.

Q. --between the two of you. And did he explain to Mr. Carter your situation, or did he go beyond just the perfunctory introduction?

A. No.

Q. Did he leave?

A. Yes.

Q. Did you, uh--I guess, generally, what did you discuss with Mr. Carter?

A. The same vanilla story I had kind of--well, actually, not even that. I discussed with Mr. Carter the, uh, that this was ridiculous, that I was angry, I didn't want to be involved with this, I didn't want to be associated with Paula Jones, with this case.

Q. Did you, uh--

A. I asked if I could sue Paula Jones. [Laughing.]

Q. Did you discuss an affidavit?

A. Yes, I believe I mentioned an affidavit.

Q. Did you mention, uh, the, uh--well, was there discussion about how you could sign an affidavit that might be--allow you to skirt being called as a witness?

A. Mr. Carter said that was a possibility but that there were other things that we should try first; that he, uh, thought--well, actually, can I ask my attorneys a question for a moment?

MR. BRYANT: Uh, sure.

[Witness conferring with counsel.]

SENATOR DeWINE: Counsel, Ms. Lewinsky's mike is carrying; it's picking up, so we don't want to--

THE WITNESS: Sorry. I was only saying nice things about you all.

SENATOR DeWINE: Thank you.

[Laughter.]

MR. CACHERIS: So that you'll know what we're discussing here, as you know, Ms. Lewinsky is not required to give up her lawyer-client privileges, and the question we don't know the answer to and would like to address after lunch is whether in fact Mr. Carter has testified to this conversation.

Therefore, perhaps--

SENATOR DeWINE: All right. Maybe counsel at this point could--could you rephrase--rephrase the question or ask another question, and after lunch, we can come back--

MR. CACHERIS: Or come back.

SENATOR DeWINE: Well, I don't want--I don't think he has to move off the general area if he can--I'll leave that up to counsel.

MR. BRYANT: There may be some misunderstanding or--

SENATOR DeWINE: Why don't you rephrase the question, and we'll see where we are.

MR. BRYANT: --on this issue of--well, on this issue of the attorney-client privilege. It is our understanding that she is able to testify. But again, I don't know, uh, if we're going to resolve that right now.

SENATOR DeWINE: Why don't we try to resolve that issue over lunch, and--

MR. BRYANT: Because I do have other questions that would relate to this area.

SENATOR DeWINE: --you can stay in this general area.

MR. BRYANT: Well, I'm not sure I can stay in this area too far without other questions that might arguably be involved in that privilege. I can ask them, and you can object if you think they're within that range.

MR. CACHERIS: Well, as I said, it's our understanding that under her agreement with the Independent Counsel, she has not been required to waive her lawyer-client privilege, and we don't want to do so here. That's that simple. And, Mr. Bryant, I want to check to see if Mr. Carter has testified about this. If he has, then we might be objecting--

MR. BRYANT: Well, she has already, I think, waived that privilege through talking with the FBI and those folks. I mean, we have statements that concern those conversations--

SENATOR DeWINE: Well, let's, instead of MR. BRYANT: And the 302's.

SENATOR DeWINE: Counsel, let me just--if I could interrupt both of you, to keep moving here, Mr. Bryant, you have a choice. You can continue on this line of questioning, and we will have to deal with that, or you can move off of it, and in 20 minutes we'll be at a lunch break and then we can try to resolve that.

MR. BRYANT: To be clear and fair, let's just--let me postpone the rest of this--

SENATOR DeWINE: That will be fine.

MR. BRYANT: --exam, and we'll move over to December 28th, and we'll come back if it's appropriate.

SENATOR DeWINE: That will be fine.

THE WITNESS: I'm sorry. I'm not trying to be difficult. I'm sorry.

MR. BRYANT: No. That's a valid concern; it really is.

Let's talk a minute--I just don't want to forget to do this; unless I make notes, I forget.

SENATOR LEAHY: You've got enough people here making notes; I don't think it'll be--I don't think it'll be forgotten.

BY MR. BRYANT:

Q. We're going to move in the direction of the December 28th, 1997 meeting, and I'm going to ask you at some point did you meet with the President later in December.

A. Yes.

Q. Okay, and what date was that?

A. December 28th, 1997.

Q. Thank you. How did the meeting come about?

A. Uh, I contacted Mrs. Currie after Christmas and asked her to find out if the President still wanted to give me his Christmas present, or my Christmas present.

Q. Did Ms. Currie get back to you?

A. Yes, she did.

Q. And what was her response?

A. To come to the White House at 8:30 a.m. on the 28th.

Q. And that would have been Sunday?

A. Yes.

Q. Did you in fact go to the White House on that date?

A. Yes.

Q. And how did you get in?

A. I believe the Southwest Gate.

Q. Did Ms. Currie WAVE you in?

A. I think so.

Q. You've testified to that previously.

A. Okay, then I accept that.

Q. This, uh, meeting on the 28th was a Sunday, and Ms. Currie--again, according to your prior testimony--WAVE'd you in. This was all consistent with what the President had told you to do about, number one, coming on weekends; is that correct?

A. I--I--I don't think me coming in on that Sunday had--I mean, for me, my memory of it was that it was a holiday time, so it could have been any day. It's pretty quiet around the White House from Christmas to New Year's.

Q. And it would have been consistent with her WAVEing you in when she was there at work on Sunday?

A. Yes.

Q. That was unusual, though, for her to be in on Sunday, wasn't it?

A. I--I--I--I think so, but I mean, that's her--I think that's something you'd have to ask her.

MR. BRYANT: I'm concerned about the time. I'm going to go ahead and continue with this, and we'll just stop wherever we have a--whenever you tell us to stop. This will take a little bit longer than another 15 minutes or so; but it's appropriate, I think, for us to continue.

SENATOR DeWINE: Well, frankly, it's up to you.

MR. BRYANT: Okay.

SENATOR DeWINE: Do you have a problem in breaking it?

MR. BRYANT: No; no, I don't think so.

SENATOR DeWINE: I mean, if you do, we can take lunch now. I'll leave that up to you.

MR. BRYANT: Uh, why don't we take the lunch now--

SENATOR DeWINE: All right. No one has any objection to that, we will do that.

THE WITNESS: I never object to food.

SENATOR DeWINE: Let me just announce to counsel you have used 2 hours and 14 minutes. It is now 20 minutes until 1. We'll come back here at 20 minutes until 2. And we need during this break also to see counsel and try to resolve the other issue prior to going back in. This is the privilege issue.

SENATOR LEAHY: Did counsel for Ms. Lewinsky have to make a couple phone calls first, before we have that discussion? I think--

SENATOR DeWINE: My suggestion would be we do that at the last 15 minutes of the break.

SENATOR LEAHY: I think he said he wanted to call Mr. Carter; that's why--

MR. CACHERIS: Meet you back up here?

SENATOR DeWINE: Yes. I would also--the sergeant-at-arms has asked me to announce that the food is on this floor, and since we have a very limited period of time, we suggest you try to stay on the floor.

MS. HOFFMANN: We were planning to go back--

SENATOR DeWINE: Except--I understand. I know that you're--

MR. CACHERIS: We have our own arrangements.

SENATOR DeWINE: I know that you have your room, and you've made your own arrangements, and that's fine.

So we will start back in one hour.

THE VIDEOGRAPHER: We are going off the record at 12:39 p.m.

[Whereupon, at 12:39 p.m., the deposition was recessed, to reconvene at 1:39 p.m. this same day.]

AFTERNOON SESSION

THE VIDEOGRAPHER: We are going back on the record at 13:43 hours.

SENATOR DeWINE: We are now back on the record.

As we broke for lunch, there was an objection that had been made by Ms. Lewinsky's counsel. Let me call on them at this point for statements.

MR. CACHERIS: Yes. We have examined the record during the course of the break, and while we know that the immunity agreement does provide for Ms. Lewinsky to maintain her lawyer-client privilege, we think in this instance, the matter has been testified so fully that it has been waived. So the objection that we lodged is withdrawn.

SENATOR DeWINE: Thank you very much.

Mr. Bryant, you may proceed.

MR. BRYANT: Thank you, Mr. Senator.

BY MR. BRYANT:

Q. We've got you to the point where Mr. Jordan has escorted you to Mr. Carter's office and has departed, and you and Mr. Carter have conversations.

Generally, what did you discuss with Mr. Carter?

A. I guess the--the reasons why I didn't think I should be called in this matter.

Q. Did he ask you questions?

A. Yes.

Q. What type of questions did he ask you?

A. Um, they ranged from where I lived and where I was working to did I have a relationship with the President, did--everything in between.

Q. When he--when he asked you about the relationship, did you understand he meant a sexual-type relationship?

A. He asked me questions that--that indicated he was being specific.

Q. And did--did you deny such a relationship?

A. Yes, I did.

Q. Did he ask you questions about if you were ever alone with the President?

A. Yes, he did.

Q. And did you deny that?

A. I think I mentioned that I might have brought the President papers on occasion, may have had an occasion to be alone with him, but not--not anything I considered significant.

Q. But that was not true either, was it?

A. No.

Q. And in fact, that--the fact that you brought him papers, that was part of the cover-up story?

A. Correct.

Q. I'm unclear on a point I want to ask you. Also, did Mr. Carter ask you about how you perhaps were pulled into this case, and you gave some answer about knowing Betty Currie and--and Mr. Kaye? Does that ring bells? You gave that testimony in your deposition.

A. That that's how I got pulled into the case?

Q. Right. Did--

A. May I see that, please?

Q. It's about your denying the relationship with the President, and you think maybe you got pulled into the case. It's--certainly, it's--it's in your grand jury--okay. It's--it's in the August 1 interview, page 9. This was a 302 exam from the FBI.

A. Um--

MR. BRYANT: Let me give that to her. Let me just give it to her to refresh her memory. I'm not going to put it in evidence, although it's--it should be there.

[Handing document.]

[Witness perusing document.]

THE WITNESS: I don't think that's an accurate representation of what I might have said in this interview.

BY MR. BRYANT:

Q. Okay. Would you--how would you have related Walter Kaye in that interview? How would his name have come up?

A. In this interview or with Mr. Carter?

Q. Well, in the interview with Mr. Carter that I assume was sort of summarized in that--

A. Right.

Q. --302, but, yes, with Mr. Carter.

A. Uh, I think I mentioned that I was friendly with Betty Currie, the President's secretary.

Q. And how would Mr. Kaye's name have come up in the conversation?

A. Because of how I met Ms. Currie was through--that's how I came to know of Ms. Currie and--and first introduced myself to her. Excuse me.

Q. Let's go back now and resume where we were before the lunch break. We were talking about the December visit to the White House and the conversation with the President. You had discussed--well, I think we're to the point where perhaps you--or I'll ask you to bring up your discussion with the President about the subpoena and the request for production.

A. Um, part way into my meeting with the President, I brought up the concern I had as to how I would have been put--how I might have been alerted or--not alerted, but how I was put on the witness list and how I might have been alerted to the Paula Jones' attorneys, and that that was--I was sort of concerned about that. So I discussed that a little, and then I said, um, that I was concerned about the hatpin. And to the best of my memory, he said that that had concerned him as well, and--

Q. Could he have said that bothered him?

A. He--he could have. I--I mean, I don't--I know that sometimes in the--in my grand jury testimony, they've put quotations around things when I'm attributing statements to other people, and I didn't necessarily mean that those were direct quotes. That was the gist of what I remembered him saying. So, concern, bothered, it doesn't--

Q. Was--was there a discussion at that point as to how someone might have--may have discovered the--the hatpin and why?

A. Well, he asked me if I had told anybody about it, and I said no.

Q. But the two of you reached no conclusion as to how that hatpin came--

A. No.

Q. --to appear on the motion?

A. No.

Q. Did he appear at all, I think, probably surprised that--that you had received a request for production of documents or the--the hatpin was on that document?

A. I didn't discuss--we didn't discuss documents, request for documents, but with regard to the hatpin, um, I don't remember him being surprised.

Q. Mm-hmm. How long did the discussion last about the--this request for production of--of the items?

A. The topic of the Paula Jones case, maybe 5 minutes. Not very much.

Q. What else was said about that?

A. About the case?

Q. Yes.

A. There was--then, at some point in this discussion--I think it was after the hatpin stuff--I had said to him that I was concerned about the gifts and maybe I should put them away or possibly give them to Betty, and as I've testified numerously, his response was either ranging from no response to `I don't know' or `let me think about it.'

Q. Did the conversation about the--the gifts that you just mentioned, did that immediately follow and tie into, if you will, the conversation about the request for production of items, the hatpin and so forth? Did one lead to the other?

A. I don't remember. I know the gift conversation was subsequent to the hatpin comment, but I--I don't remember if one led to the other.

Q. What else happened after that?

A. Hmm, I think we went back to sort of--we left that topic, kind of went back to the visit.

Q. Did--which included exchanging the Christmas gifts?

A. Correct.

Q. Okay.

A. I had already--he had already given me my presents at this point.

Q. Okay. Did--he gave you some gifts that day, and my question to you is what went through your mind when he did that, when you knew all along that you had just received a subpoena to produce gifts. Did that not concern you?

A. No, it didn't. I was happy to get them.

Q. All right. Why did it--beyond your happiness in receiving them, why did the subpoena aspect of it not concern you?

A. I think at that moment--I mean, you asked me when he gave me those gifts. So, at that moment, when I was there, I was happy to be with him. I was happy to get these Christmas presents. So I was nervous about the case, but I had made a decision that I wasn't going to get into it too much--

Q. Well--

A. --with a discussion.

Q. --have you in regards to that--you've testified in the past that from everything that the President had told you about things like this, there was never any question that you were going to keep everything quiet, and turning over all the gifts would prompt the Jones attorneys to question you. So you had no doubt in your mind, did you not, that you weren't going to turn these gifts over that he had just given you?

A. Uh, I--I think the latter half of your statement is correct. I don't know if you're reading from my direct testimony, but--because you said--your first statement was from everything the President had told you. So I don't know if that was--if those were my words or not, but I--no, I was--I--it--I was concerned about the gifts. I was worried someone might break into my house or concerned that they actually existed, but I wasn't concerned about turning them over because I knew I wasn't going to, for the reason that you stated.

Q. But the pattern that you had had with the President to conceal this relationship, it was never a question that, for instance, that given day that he gave you gifts that you were not going to surrender those to the Jones attorneys because that would--

A. In my mind, there was never a question, no.

Q. I'm just actually looking at your deposition on page--no, I'm sorry--your grand jury proceedings of August the 6th, just to be clear, since you raised that question.

1004 in the book, appendices.

You indicate that in response to a question, `What do you think the President is thinking when he is giving you gifts when there is a subpoena covering gifts. I mean, does he think in any way, shape or form that you're going to be turning these gifts over?' And your answer is, `You know, I can't answer what he was thinking, but, to me, it was--there was never a question in my mind, and I--from everything he said to me, I never questioned him that we were ever going to do anything but keep this private. So that meant deny it, and that meant do whatever appropriate--take whatever appropriate steps needed to be taken, you know, for that to happen, meaning that if--if I had to turn over every gift--if I had turned over every gift he had given me--first of all, the point of the affidavit and the point of everything was to try to avoid a deposition. So where I'd have to sort of--you know, I wouldn't have to lie as much as I would necessarily in an affidavit how I saw it,' and you continue on, just one short paragraph.

A. Right.

Q. `So, by turning over all of these gifts, it would at best prompt him to want to question me about what kind of friendship I had with the President, and they would want to speculate and they'd leak it, and my name would be trashed and he would be in trouble.'

So you recall giving that testimony?

A. Yes. I accept--I accept what's said here.

Q. Okay.

A. It's a little different from what you said, but very close.

Q. Thank you.

Did the President ever tell you to turn over the gifts?

A. Not that I remember.

Q. Now, is that--does that bring us to the end of this conversation with the President, or did other things occur?

A. I think that the aspect of where this case is related, yes.

Q. Okay. And then you left, and where did you go when you left the White House?

A. I think I went home.

Q. This is at--at your apartment?

A. My mother's apartment.

Q. Mother's apartment.

Did you later that day receive a call from Betty Currie?

A. Yes, I did.

Q. Tell us about that.

A. I received a call from--from Betty, and to the best of my memory, she said something like I understand you have something for me or I know--I know I've testified to saying that--that I remember her saying either I know you have something for me or the President said you have something for me. And to me, it's a--she said--I mean, this is not a direct quote, but the gist of the conversation was that she was going to go visit her mom in the hospital and she'd stop by and get whatever it was.

Q. Did you question Ms. Currie or ask her, what are you talking about or what do you mean?

A. No.

Q. Why didn't you?

A. Because I assumed that it meant the gifts.

Q. Did--did you have other telephone calls with her that day?

A. Yes.

Q. Okay. What was the purpose of those conversations?

A. I believe I spoke with her a little later to find out when she was coming, and I think that I might have spoken with her again when she was either leaving her house or outside or right there, to let me know to come out.

Q. Do--at that time, did you have the caller identification--

A. Yes, I did.

Q. --on your telephone?

A. Yes.

Q. And did you at least on one occasion see her cell phone number on your caller-ID that day?

A. Yes, I did.

Q. Now, Ms. Currie has given different versions of what happened there, but I recall one that she mentioned about Michael Isikoff, that you had called her and said Michael Isikoff is calling around or called me--

A. Mm-hmm.

Q. --about some gifts.

Did Mr. Isikoff ever call you about the gifts?

A. No.

Q. Okay. Would there have been--would there have been any reason for you not to have carried the gifts to Ms. Currie had you wanted her--had you called her, would you have had her come over to get them from you, or does that--

A. Probably not.

Q. I mean, is there--is there any doubt in your mind that she called you to come pick up the gifts?

A. I don't think there is any doubt in my mind.

Q. Okay. Let me ask was--I think you did something special for her, as I recall, too, or her mother. Did you prepare a plant or something for her to pick up?

A. Um, no. I just--

Q. To take to her mother?

A. I bought a small plant and a balloon.

Q. Okay. What was your understanding about her mother, and was--

A. Oh, I--I knew her mom was in--was in the hospital and was sick, and I think this was her second trip to the hospital in several months, and it had been a tough year.

Q. And was she--was Mrs. Currie coming by your place on her way to visit her mother in the hospital? Do you know that?

A. That's what I remember her saying.

Q. So you prepared--and you bought a gift for her mother?

A. Correct.

Q. Okay. Do you know what kind of time frame this covered? First of all, it was the same day, December the 28th, 1997?

A. Seven, yes.

Q. Do you know what kind of time frame it covered?

A. I think it was afternoon. I know I've testified to around 2 o'clock.

Q. Could it have been later?

A. Sure.

Q. So, when Betty Currie came, what--what did you have prepared for her?

A. I had a box from the Gap with some of the presents the President had given me, taped up in it.

Q. What happened when she arrived?

A. Uh, I think I walked out to the car and asked her to hold onto this, and I think we talked about her mom for a few minutes. Um--

Q. Did she call you right before she arrived, or did you just go wait for her in the building?

A. I think she called me right before she--at some point, I think, before she--either when she was leaving or she was outside.

Q. Do you know--did you have any indication from Ms. Currie what she was going to do with that box of gifts?

A. Um, I know I've testified to this. I don't--I don't remember. I think maybe she said something about putting it in a closet, but whatever I--I stand by whatever I've said in my testimony about it.

Q. But she was supposed to keep these for you?

A. Well, I had asked her to.

Q. Okay. Did Ms. Currie ask you at any time about what was in the box?

A. No, or not that I recall, I guess I should say.

Q. What was the--in your mind, what was the purpose of having Ms. Currie retain these gifts as opposed to another friend of yours?

A. Hmm, I know I've testified to this, and I can't--can I look at my grand jury--I mean, I don't really remember sitting here right now, but if I could look at my grand jury testimony, I--or I'd just stand by it.

Q. We will pass that to you.

A. Okay. Thank you.

[Witness handed documents.]

BY MR. BRYANT:

Q. The answer I'm looking for is--if this refreshes your recollection is that turning these over was a reassurance to the President that everything was okay. Is that--

A. Can I read it in context, please?

Q. Sure, sure.

A. Thank you.

[Witness perusing document.]

THE WITNESS: I--I--I stand by this testimony. I mean, I'd just note that it--what I'm saying here about giving it to the President or the assurance to the President is how I saw it at that point, not necessarily how I felt then. So I think you asked me what--why I didn't at that point, and I'm just--that's what's a little more clear there, just to be precise. I'm sorry.

BY MR. BRYANT:

Q. Okay. Did you have any later conversations with either Ms. Currie or the President about these gifts in the box?

A. No.

Q. Let me direct your attention to your meeting with Vernon Jordan on December the 31st of 1997. Was that to go back and talk about the job again?

A. Little bit, but the--the--for me, the point of that meeting was I had gotten to a point where Linda Tripp wasn't returning my phone calls, and so I felt that I needed to devise some way, that somehow--to kind of cushion the shock of what would happen if Linda Tripp testified all the facts about my relationship, since I had never disclosed that to the President. So that was sort of my intention in meeting with Mr. Jordan, was hoping that I could give a little information and that would get passed on.

Q. This was at a meeting for breakfast at the Park Hyatt Hotel?

A. Yes.

Q. Were just the two of you present?

A. Yes.

Q. Did you discuss other things, other than Linda Tripp and your job search?

A. I think we talked about what each of us were doing New Year's Eve.

Q. Specifically about some notes that you had at your
apartment?

A. Oh, yes. I'm sorry.

Um, well, I mean, that really was in relation to discussing Linda Tripp. So--

Q. And the Jones lawyers, too. Was that right?

A. Um, I--I don't know that I discussed the Jones lawyers. If I've testified that I discussed the Jones lawyers, then I did, but--

Q. Okay. Well, tell us about the notes.

A. Well, the--sort of the--I don't know what to call it, but the story that I gave to Mr. Jordan was that I was trying to sort of alert to him that, gee, maybe Linda Tripp might be saying these things about me having a relationship with the President, and right now, I'm explaining this to you. These aren't the words that I used or how I said it to him, and that, you know, maybe she had seen drafts of notes, trying to obviously give an excuse as to how Linda Tripp could possibly know about my relationship with the President without me having been the one to have told her. So that's what I said to him.

Q. And what was his response?

A. I think it was something like go home and make sure--oh, something about a--I think he asked me if they were notes from the President to me, and I said no. I know I've testified to this. I stand by that testimony, and I'm just recalling it, that I said no, they were draft notes or notes that I sent to the President, and then I believe he said something like, well, go home and make sure they're not there.

Q. And what did you do when you went home?

A. I went home and I searched through some of my papers, and--and the drafts of notes I found, I sort of--I got rid of some of the notes that day.

Q. So you threw them away?

A. Mm-hmm.

THE REPORTER: Is that a `yes'?

THE WITNESS: Yes. Sorry.

BY MR. BRYANT:

Q. On your way home, you were with Mr. Jordan? I mean, he carried--did he carry you someplace or take you home, drop you off?

A. Yes, he dropped me off.

Q. Okay. On the way home--

A. It wasn't on the way to my home, but--

Q. Okay. Did he--did you tell him that you had had an affair with the President?

A. Yes.

Q. What was his response?

A. No response.

Q. When was the next time--well, let me direct your attention to Monday, January the 5th, 1998. You had an occasion to meet with your lawyer, Mr. Carter, about your case, possible depositions, and so forth.

Did you have some concern at that point about those depositions and how you might answer questions in the Paula Jones case?

A. Yes.

Q. Did you reach any sort of determination or resolution of those concerns by talking to Mr. Carter?

A. No.

Q. What's the status of the affidavit at this point? Is there one?

A. No.

Q. Do you recall any other concerns or questions that either you or Mr. Carter may have presented to each other during that meeting?

A. I think I--I think it was in that meeting I brought up the notion of having my family present, if I had to do a deposition, and he went through what--I believe we discussed--at this point, I think I probably knew at this point I was going to sign an affidavit, but it wasn't created yet, and I believe we discussed what--if the affidavit wasn't, I guess, successful--I don't know how you'd say legally--say that legally--but what a deposition would be like, sitting at a table.

Q. I'll bet he never told you it would be like this, did he?

A. No.

Q. Did you try to contact the President after you left the meeting with Mr. Carter?

A. Yes.

Q. And you reached Betty Currie?

A. Yes.

Q. And you told her to pass along to the President that you wanted--it was important to talk with him?

A. Yes.

Q. You may have mentioned to her something about signing something?

A. Right; I might have.

Q. What response did you get from that telephone call?

A. Uh, Betty called me back, maybe an hour or two later, and put the President through.

Q. And what was that conversation?

A. I know I've testified to this, and it was sort of two-fold. On the one hand, I was, uh, upset, so I was sort of in a pissy mood and a little bit contentious. Uh, but more related to the case, uh, I had concerns that from questions Mr. Carter had asked me about how I got my job at the Pentagon and transferred and, and, uh, I was concerned as to how to answer those questions because those questions involved naming other people who I thought didn't like me at the White House, and I was worried that those people might try and--just to get me in trouble because they didn't like me--so that if they were then--I mean, I had no concept of what exactly happens in these legal proceedings, and I thought, well, maybe if I say Joe Schmo helped me get my job, then they'd go interview Joe Schmo, and so, if Joe Schmo said, `No, that's not true,' because he didn't like me, then I didn't want to get in trouble. So--

Q. Did there appear to be a question possibly about how you--how you got the job at the Pentagon? Did you fear for some questions there?

A. Yes. I think I tend to be sort of a
detail-oriented person, and so I think it was, uh, my focusing on the details and thinking everything had to be a very detailed answer and not being able to kind of step back and look at how I could say it more generally. So that's what concerned me.

Q. Mm-hmm. This--

A. Because clearly, I mean, I would have had to say, `Gee, I was transferred from the Pentagon because I had this relationship that I'm not telling you about with the President.' So there was--there was that concern for me there.

Q. And what did the President tell you that you could say instead of saying something like that?

A. That the people in Legislative Affairs helped me get the job--and that was true.

Q. Okay, but it was also true, to be complete, that they moved you out into the Pentagon because of the relationship with the President?

A. Right.

Q. Did--did the subject of the affidavit come up with the President?

A. Yes, towards the end of the conversation.

Q. And how did--tell us how that occurred.

A. I believe I asked him if he wanted to see a copy of it, and he said no.

Q. Well, I mean, how did you introduce that into the subject--into the conversation?

A. I don't really remember.

Q. Did he ask you, well, how's the affidavit coming or--

A. No, I don't think so.

Q. But you told him that you had one being prepared, or something?

A. I think I said--I think I said, you know, I'm going to sign an affidavit, or something like that.

Q. Did he ask you what are you going to say?

A. No.

Q. And this is the time when he said something about 15 other affidavits?

A. Correct.

Q. And tell us as best as you can recall what--how that--how that part of the conversation went.

A. I think that was the--sort of the other half of his sentence as, No, you know, I don't want to see it. I don't need to--or, I've seen 15 others.

It was a little flippant.

Q. In his answer to this proceeding in the Senate, he has indicated that he thought he had--might have had a way that he could have you--get you to file a--basically a true affidavit, but yet still skirt these issues enough that you wouldn't be called as a witness.

Did he offer you any of these suggestions at this time?

A. He didn't discuss the content of my affidavit with me at all, ever.

Q. But, I mean, he didn't make an offer that, you know, here's what you can do, or let me send you over something that can maybe keep you from committing perjury?

A. No. We never discussed perjury.

Q. On--well, how did that conversation end? Did you talk about anything else?

A. I said goodbye very abruptly.

Q. The next day--well, on January the 6th--I'm not sure exactly what day we are--1998, did you pick up a draft of the affidavit from Mr. Carter?

A. Yes, I did.

Q. What did you do with that draft?

A. I read it and went through it.

Q. How did it look?

A. I don't really remember my reaction to it. I know I had some changes. I know there's a copy of this draft affidavit that's part of the record, but--

Q. Were portions of it false?

A. Incomplete and misleading.

Q. Did you take that affidavit to Mr. Jordan?

A. I dropped off a copy in his office.

Q. Did you have any conversation with him at that point or some later point about that affidavit?

A. Yes, I did.

Q. And tell us about that.

A. I had gone through and had, I think, as it's marked--can I maybe see? Isn't there a copy of the draft?

[Witness handed document.]

[Witness perusing document.]

The WITNESS: Thank you.

SENATOR DeWINE: Mr. Bryant, can you reference for the record at this point?

MR. BRYANT: Okay.

SENATOR DeWINE: If you can.

MR. BRYANT: It would be--

MR. SCHIPPERS: 1229.

SENATOR DeWINE: 1229?

MR. SCHIPPERS: Yes.

SENATOR DeWINE: All right. Thank you.

BY MR. BRYANT:

Q. Okay. Have you had an opportunity to review the draft of your affidavit?

A. I--yes.

Q. Okay. What--do you have any comment or response?

A. I received it. I made the suggested changes, and I believe I spoke with Mr. Jordan about the changes I wanted to make.

Q. Did he have any comment on your proposed changes?

A. I think he said the part about Lewis & Clark College was irrelevant. I'd have to see the--I don't believe it's in the final copy in the affidavit, so--but I could be mistaken.

Q. At this point, of course, you had a lawyer, Mr. Carter, who was representing your interest. Mr. Jordan was--I'm not sure if he--how you would characterize him, but would it--would it be that you view Mr. Jordan as, in many ways, Mr: the President--if Mr. Jordan knew it, the President knew it, or something of that nature?

A. I think I testified to something similar to that.
I felt that, I guess, that Mr. Jordan might have had the President's best interest at heart and my best interest at heart, so that that was sort of maybe a--some sort of a blessing.

Q. I think, to some extent, what you--what you had said was getting Mr. Jordan's approval was basically the same thing as getting the President's approval. Would you agree with that?

A. Yeah. I believe that--yes, I believe that's how I testified to it.

Q. The fact that you assume that Mr. Jordan was in contact with the President--and I believe the evidence would support that through his own testimony that he had talked to the President about the signed affidavit and that he had kept the President updated on the subpoena issue and the job search--

A. Sir, I'm not sure that I knew he was having contact with the President about this. I--I think what I said was that I felt that it was getting his approval. It didn't necessarily mean that I felt he was going to get a direct approval from the President.

I'm sorry to interrupt you.

Q. Oh, that's fine. At any time you need to clarify a point, please--please feel free to do so.

Did--did--did you have any indication from Mr. Jordan that he--when he discussed the signed affidavit with the President, they were discussing some of the contents of the affidavit? Did you have--

A. Before I signed it or--

Q. No; during the drafting stage.

A. No, absolutely not--either/or. I didn't. No, I did not.

Q. Now, the changes that you had proposed, did Mr. Jordan agree to those changes?

A. I believe so.

Q. And then you somehow reported those changes back to Mr. Carter or to someone else?

A. No. I believe I spoke with Mr. Carter the next morning, before I went in to see him, and that's when I--I believe that's--I dictated the changes.

Q. Okay. Mr. Jordan did not relay the changes to Mr. Carter--you did?

A. I know I relayed the changes, these changes to Mr. Carter.

Q. Specifically, the concerns that you had about--about the draft, what did they include, the changes?

A. I think one of the--I think what concerned me--and I believe I've testified to this--was--was in Number 6. Even just mentioning that I might have been alone with the President, I was concerned that that would give the Jones people enough ammunition to want to talk to me, to think, oh, well, maybe if she was alone with him that--that he propositioned me or something like that, because I hadn't--of course, I mean, you remember that at this point, I had no idea the amount of knowledge they had about the relationship. So--

Q. Did--Mr. Carter, I assume, made those changes, and
then you subsequently signed the affidavit?

A. We worked on it in his office, and then, yes, I signed the affidavit.

Q. Is this the same day--

A. Yes.

Q. --at this point?

A. This was the 7th?

Q. Yes.

A. Correct.

Q. Did--did you take the signed--or a copy of the signed affidavit, I should say--did you take a copy--did you keep a copy?

A. Yes, I did.

Q. Did you give it to anyone or give anyone else a copy?

A. No.

Q. Now, did you, the next day on the 8th, go to New York for some interviews for jobs?

A. It was--it--I either went later on the 7th or on the 8th, but around that time, yes.

Q. Was this a place that you had already interviewed?

A. Yes.

Q. And I assume this was at McAndrews and Forbes?

A. Yes.

Q. How did you feel that the interview went?

A. I--I know I characterized it in my grand jury testimony as having not gone very well.

Q. Okay. I think you also mentioned it went very poorly, too. Does that sound--does that ring a bell?

A. Sure.

Q. Why? Why would you so characterize it?

A. Well, as I've had a lot of people tell me, I'm a pessimist, but also I--I wasn't prepared. I was in a waiting room downstairs at McAndrews and Forbes, and--or at least, I thought it was a waiting room--and Mr. Durnan walked into the room unannounced, and the interview began. So I felt that I started on the wrong foot, and I just didn't feel that I was as articulate as I could have been.

Q. Did you call Mr. Jordan after that?

A. Yes, I did.

Q. Did you express those same concerns?

A. Yes, I did.

Q. What did he say?

A. And this is a little fuzzy for me. I know that I had a few phone calls with him in that day. I think in this call, he said, you know, `Don't worry about it.' I--my testimony is probably more complete on this. I'm sorry.

Q. What--what other phone calls did you have with him that day?

A. I remember talking to--I know that at some point, he said something about that he'd call the chairman, and then I think he said just at some point not to worry. He was always telling me not to worry because I always--I overreact a little bit.

Q. All total, how many calls did you have with him that day--your best guess?

A. I have no idea.

Q. More than two?

A. I--I don't know.

Q. Can you think of any other subjects the two of you would have talked about?

A. I don't think so.

Q. Did he, Mr. Jordan, tell you that he had talked to the chairman, or Mr. Perelman, whatever his title is?

A. I'm sorry. I know I've testified to this. I don't--I think so.

Q. And you had--did you have additional interviews at this company or a subsidiary?

A. Yes, I--well, I had with the sort of, I guess, daughter--daughter company, Revlon. I had an interview with Revlon the next day.

Q. And you were offered a job?

A. Yes, I was.

Q. About the 9th or so? That would have been 2 days after the affidavit?

A. Oh. Actually, no. I think I was offered a position, whatever that Friday was. Oh, yes, the 9th. I'm sorry. You're right.

Oh, wait. It was either the 9th or the 13th--or the 12th--the 9th or the 12th.

Q. Okay. Now, I'm--I was looking away. I'm confused.

A. That's okay. I--my interview was on the 9th, and I don't remember right now--I know I've testified to this--whether I found out that afternoon or it was on Monday that I got the informal offer.

Q. Mm-hmm.

A. So, if you want to tell me what I said in my grand jury testimony, I'll be happy to affirm that.

Q. I think we may be talking about perhaps an informal offer. Does that--on the 9th?

A. Yes. I know it was--okay. Was it on the--I don't--

Q. Yes.

A. --remember if it was the 9th or the 13th--

A. Okay.

Q. --but I know Ms. Sideman called me to extend an informal offer, and I accepted.

Q. Okay. Now, in regard to the affidavit--do you still have your draft in front of you?

A. Yes, sir.

Q. In paragraph number 3, you say: `I can not fathom any reason--fathom any reason why--that the plaintiff would seek information from me for her case.'

A. Yes, sir.

Q. Did Mr. Carter at all go into the gist of the Paula Jones lawsuit, the sexual harassment part of it, and tell you what it was about?

A. I think I knew what it was about.

Q. All right. And then you indicated that you didn't like the part about the doors, being behind closed doors, but on the sexual relationship, paragraph 8, the first sentence, `I've never had a sexual relationship with the President'--

A. Mm-hmm.

Q. --that's not true, is it?

A. No. I haven't had intercourse with the President, but--

Q. Was that the distinction you made when you signed that affidavit, in your own mind?

A. That was the justification I made to myself, yes.

Q. Let me send you the final affidavit. It might be a little easier to work from--

A. Okay.

Q. --than the--than the original.

MR. BRYANT: Do we have all the--1235.

[Witness handed document.]

SENATOR DeWINE: Congressman?

MR. BRYANT: Yes.

SENATOR DeWINE: We're down to 3 minutes on the tape. Would now be a good time to have him switch tapes and then we'll go right back in?

MR. BRYANT: Okay, that would be fine.

SENATOR DeWINE: I think we'll hold right at the table, and we'll get the tapes switched.

THE VIDEOGRAPHER: Okay, we will do that now.

This marks the end of Videotape Number 2 in the deposition of Monica S. Lewinsky.

We are going off the record at 14:31 hours.

[Recess.]

THE VIDEOGRAPHER: This marks the beginning of Videotape Number 3 in the deposition of Monica S. Lewinsky. The time is 14:44 hours.

SENATOR DeWINE: We are back on the record.

Let me advise counsel that you have used 3 hours and 2 minutes.

Congressman Bryant, you may continue.

MR. BRYANT: Thank you, sir.

BY MR. BRYANT:

Q. Ms. Lewinsky, let me just follow up on some points here, and then I'll move toward the conclusion of my direct examination very, very quickly, I hope.

In regard to the affidavit--I think you still have it in front of you--the final copy of the affidavit--I wanted to revisit your answer about paragraph 8--

A. Yes, sir.

Q. --and also refer you to your grand jury testimony of August the 6th. This begins on--actually, it is on page 1013 of the--it should be the Senate record, in the appendices, but it's your August 6th, 1998, grand jury testimony.

And it's similar to the--my question about paragraph 8 about the sexual relationship--and I notice you--you now carve out an exception to that by saying you didn't have intercourse, but I would direct your attention to a previous answer and ask if you can recall being asked this question in your grand jury testimony and ask--giving the answer--the question is: `All right. Let me ask you a straightforward question. Paragraph 8, at the start, says, quote, 'I have never had a sexual relationship with the President,' unquote. Is that true?,' and your answer is, `No.'

Now, do you have any comment about why your answer still would not be no, that that is not a true statement in paragraph 8?

A. I think I was asked a different question.

Q. Okay.

A. My recollection, sir, was that you asked me if that was a lie, if paragraph 8 was--I--I'm not trying to--

Q. Okay. Well, if--if I ask you today the same question that was asked in your grand jury, is your statement, quote, `I have never had a sexual relationship with the President,' unquote, is that a true statement?

A. No.

Q. Okay, that's good.

Now, also in paragraph 8, you mention that there were occasions after you left--I think it looks like the--the last sentence in paragraph 8, `The occasions that I saw the President after I left my employment at the White House in April 1996 were official receptions, formal functions, or events related to the United States Department of Defense, where I was working at the time,' period-- actually the last sentence, `There were other people present on those occasions.' Now, that also is not a truthful statement; is that correct?

A. It--I think I testified that this was misleading. It's incomplete--

Q. Okay. It's not a truthful statement?

A. --and therefore, misleading.

Well, it--it is true; it's not complete.

Q. Okay. All right. Now, I will accept that.

A. Okay. Thank you.

Q. Thank you.

Going back to the gift retrieval of December the 28th, I want to be clear that we're on the same sheet of music on this one. As I understand, there's no doubt in your mind that Betty Currie called you, initiated the call to you to pick up the gifts? She--

A. That's how I remember this event.

Q. And you went through that process, and at the very end, you were sitting out in the car with her, with a box of gifts, and it was only at that time that you asked her to keep these gifts for you?

A. I don't think I said `gifts.' I don't--

Q. Or keep this package?

A. I think I said--gosh, was it in the car that I said that or on the phone? I think it was in the car. I--I'm--I don't know if that makes a difference.

Q. But this was at the end of a process that Betty Currie had initiated by telephone earlier that day to come pick up something that you have for her?

A. Yes.

Q. Okay. Now, were you ever under the impression from anything that the President said that you should turn over all the gifts to the Jones lawyers?

A. No, but where this is a little tricky--and I think I might have even mentioned this last weekend--was that I had an occasion in an interview with one of the--with the
OIC--where I was asked a series of statements, if the President had made those, and there was one statement that Agent Phalen said to me--I--there were--other people, they asked me these statements--this is after the President testified and they asked me some statements, did you say this, did you say this, and I said, no, no, no. And Agent Phalen said something, and I think it was, `Well, you have to turn over whatever you have.' And I said to you, `You know, that sounds a little bit familiar to me.'

So that's what I can tell you on that.

Q. That's in the 302 exam?

A. I don't know if it's in the 302 or not, but that's what happened.

Q. Uh-huh.

A. Or, that's how I remember what happened.

Q. Okay. And your response to the question in the deposition that I just asked you--were you ever under the impression from anything the President said that you should have--that you should turn over all the gifts to the Jones lawyers--your answer in that deposition was no.

A. And which date was that, please?

Q. The deposition was August the 26th.

A. Oh, the 26th.

Q. Yes.

A. It might have been after that, or maybe it was--I don't--

Q. Okay. I wanted to ask you, too, about a couple of other things in terms of your testimony. Regarding the affidavit--and this appears to be, again, grand jury testimony--

A. Sir, do you have a copy that I could look at if you're going to--

Q. Sure. August, the August 6th--233--it's the--it's this page here.

While we're looking at that, let me ask you a couple other things here. I wanted to ask you--I talked to you a little bit about the President today and your feelings today that persist that you think he's a good President, and I assume you think he's a very intelligent man?

A. I think he's an intelligent President.

[Laughter.]

MR. BRYANT: Okay. Thank goodness, this is confidential; otherwise, that might be the quote of the day. I know we won't see that in the paper, will we?

BY MR. BRYANT:

Q. Referring to January the 18th, 1998, the President had a conversation with Betty Currie, and he made five statements to her. One was that `I was never really alone with Monica; right?' That's one. That's not true, is it, that `I was never alone with'--

A. Sir, I was not present for that conversation. I don't feel comfortable--

Q. Let me ask you, though--I realize none of us were there--but that statement, `I was never really alone with Monica; right?'--that was not--he was alone with you on many occasions, was he not?

A. I--I'm not trying to be difficult, but I feel very uncomfortable making judgments on what someone else's statement when they're defining things however they want to define it. So if you--if you ask me, Monica, were you alone with the President, I will say yes, but I'm not comfortable characterizing what someone else says--

Q. Okay.

A. --passing judgment on it. I'm sorry.

Q. Were you--was Betty Currie always with you when the President was with you?

A. Betty Currie was always at the White House when I went to see the President at the White House after I left working at the White House.

Q. But was--at all times when you were alone with the President, was Betty Currie always there with you?

A. Not there in the room.

Q. Okay. Did--did--did you come on to the President, and did he never touch you physically?

A. I guess those are two separate questions, right?

Q. Yes, they are.

A. Did I come on to him? Maybe on some occasions.

Q. Okay.

A. Not initially.

Q. Okay. Not initially.

A. I--

Q. Did he ever--did he ever touch you?

A. Yes.

Q. Okay. Could Betty Currie see and hear everything that went on between the two of you all the time?

A. I can't answer that. I'm sorry.

Q. As far as you know, could she see and hear everything that went on between the two of you?

A. Well, if I was in the room, I couldn't--I--I couldn't be in the room and being able to see if Betty Currie could see and hear what was--

Q. I think I--

MR. STEIN: Wouldn't it be a little speedier--if I may make this observation, you have her testimony; you have the evidence of--

SENATOR DeWINE: Counsel, is this an objection?

MR. STEIN: I just would ask him to draw whatever inferences there were to speed this up.

SENATOR DeWINE: I'll ask him to rephrase the question.

MR. BRYANT: I would just stop at that point. I think, uh, that's enough of that.

BY MR. BRYANT:

Q. The President also had conversations with Mr. Blumenthal on January the 21st, 1998, and indicated that you came on to the President and made a sexual demand. At the initial part of this, did you come on to the President and make a sexual demand on the President?

A. No.

Q. At the initial meeting on November the 15th, 1995, did he ever rebuff you from these advances, or from any kind of--

A. On November 15th?

Q. November 15th. Did he rebuff you?

A. No.

Q. Did you threaten him on November 15th, 1995?

A. No.

Q. On January 23rd, 1998, the President told John Podesta that--many things. I'll--I'll withdraw that. Let me go--kind of wind this down. I'd like to save some time for redirect.

You've indicated that with regard to the affidavit and telling the truth, there is some testimony I'd like to read you from your deposition that we started out--August the 6th--I'm sorry--the grand jury, August 6th, 1998--

MS. MILLS: What internal page number?

MR. SCHIPPERS: 1021 internal, 233.

MR. BRYANT: Okay, we need to get her a copy.

MR. SCHIPPERS: Do you have the August 6th still over there?

THE WITNESS: I can share with Sydney--if you don't mind.

[Witness perusing document.]

BY MR. BRYANT:

Q. Beginning--do you have page 233--

A. Uh-huh.

Q. --okay--beginning at line 6--

A. Okay.

Q. --it reads--would you prefer to read that? Why don't you read--

A. Out loud?

Q. Would you read it out loud?

A. Okay.

Q. Through line 16--6 through 16. This is your answer.

A. `Sure. Gosh. I think to me that if--if the President had not said the Betty and letters cover, let's just say, if we refer to that, which I'm talking about in paragraph 4, page 4, I would have known to use that. So to me, encouraging or asking me to lie would have--you know, if the President had said, Now, listen, you'd better not say anything about this relationship, you'd better not tell them the truth, you'd better not--for me, the best way to explain how I feel what happened was, you know, no one asked or encouraged me to lie, but no one discouraged me, either.'

Q. Okay. That--that statement, is that consistent in your view with what you've testified to today?

A. Yes.

Q. Okay. Look at page 234, which is right below there.

A. Okay. [Perusing document.]

Q. Beginning with the--your answer on line 4, and read down, if you could, to line 14--4 through 14.

A. `Yes and no. I mean, I think I also said that Monday that it wasn't as if the President called me and said, You know, Monica, you're on the witness list. This is going to be really hard for us. We're going to have to tell the truth and be humiliated in front of the entire world about what we've done, which I would have fought him on, probably. That was different. And by him not calling me and saying that, you know, I knew what that meant. So I, I don't see any disconnect between paragraph 10 and paragraph 4 on the page. Does that answer your question?'

Q. Okay. Now, has that--has your testimony today been consistent with that provision?

A. I--I think so.

Q. Okay.

A. I've intended for my testimony to be consistent with my grand jury testimony.

Q. Okay. And one final read just below that, line 16 through 24.

A. `Did you understand all along that he would deny the relationship also?'

`Mm-hmm, yes.'

Q. And 19 through 24--the rest of that.

A. Oh, sorry.

`And when you say you understood what it meant when he didn't say, Oh, you know you must tell the truth, what did you understand that to mean?'

`That, that, as we had on every other occasion and in every other instance of this relationship, we would deny it.'

MR. BRYANT: Okay.

Could we have just--go off the record here a minute?

SENATOR DeWINE: Sure. Let's go off the record at this point.

THE VIDEOGRAPHER: We're going off the record at 1459 hours.

[Recess.]

THE VIDEOGRAPHER: We're going back on the record at 1504 hours.

SENATOR DeWINE: Manager Bryant, you may proceed.

MR. BRYANT: Thank you, Senator.

BY MR. BRYANT:

Q. Ms. Lewinsky, I have just a few more questions here.

With regard to the false affidavit, you do admit that you filed an untruthful affidavit with the court in the Jones case; is that correct?

A. I think I--I--yes--I mean, it was incomplete and misleading, and--

Q. Okay. With regard to the cover stories, on December the 6th, you and the President went over cover stories, and in the same conversation he encouraged you to file an affidavit in the Jones case; is that correct?

A. No.

MS. SELIGMAN: I think that misstates the record.

BY MR. BRYANT:

Q. All right. On December the 17th. Let's try December 17; all right?

A. Okay.

Q. You and the President went over cover stories--that's the telephone conversation--

A. Okay--I'm sorry--can you repeat the question?

Q. Okay. On December 17th, you and the President went over cover stories in a telephone conversation.

A. Correct.

Q. And in that same telephone conversation, he encouraged you to file an affidavit in the Jones case?

A. He suggested I could file an affidavit.

Q. Okay. With regard to the job, between your meeting with Mr. Jordan in early November and December the 5th when you met with Mr. Jordan again, you did not feel that Mr. Jordan was doing much to help you get a job; is that correct?

MS. SELIGMAN: Objection. Misstates the record.

BY MR. BRYANT:

Q. Okay. You can answer that.

A. It--

Q. Let me repeat it. Between your meeting with Mr. Jordan in early November and December the 5th when you met with Mr. Jordan again, you did not feel that Mr. Jordan was doing much to help you get a job; is that correct?

MS. SELIGMAN: Same objection.

THE WITNESS: Do you mean when I met with him again on December 11th? I don't--

MR. BRYANT: The--

THE WITNESS: --I didn't meet with Mr. Jordan on December 5th. I'm sorry--

MR. BRYANT: Okay.

THE WITNESS: --am I misunderstanding something?

MR. BRYANT: We're getting our numbers wrong here.

THE WITNESS: Okay.

BY MR. BRYANT:

Q. Between your meeting with Mr. Jordan in early November and December the 11th when you met with Mr. Jordan again, you did not feel that Mr. Jordan was doing much to help you get a job; is that correct?

A. I hadn't seen any progress.

Q. Okay. After you met with Mr. Jordan in early December, you began to interview in New York and were much more active in your job search; correct?

A. Yes.

Q. In early January, you received a job offer from Revlon with the help of Vernon Jordan; is that correct?

A. Yes.

Q. Okay. With regard to gifts, regarding the gifts that were subpoenaed in the Jones case, you are certain that Ms. Currie called you and that she understood you had something to give her; is that correct?

A. That's my recollection.

Q. You never told Ms. Currie to come pick up the gifts or that Michael Isikoff had called about them; is that correct?

A. I don't recall that.

Q. Regarding stalking, you never stalked the President; is that correct?

A. I--I don't believe so.

Q. Okay. You and the President had an emotional relationship as well as a physical one; is that right?

A. That's how I'd characterize it.

Q. Okay. He never rebuffed you?

A. I--I think that gets into some of the intimate details of--no, then, that's not true. There were occasions when he did.

Q. Uh-huh. Okay. But he never rebuffed you initially on that first day, November the 15th, 1995?

A. No, sir.


LAW OFFICES OF
Plato Cacheris,
Washington, DC, February 2, 1999.
Re February 1, 1999, Monica S. Lewinsky deposition transcript.

Dear Ms. Jardim and Mr. Bitsko: Upon our review of the videotape and transcript of Monica S. Lewinsky's deposition transcript, we have noted the following errors or omissions:

Page Line Corrections
19 14 The oath and affirmation are not transcribed.
24 9 `second . . .' should replace `2d'
44 6 Comments by counsel are not transcribed.
61 11-13 Delete quotation marks. These are not direct quotes in this instance.
62 23 `town' should replace `down'
63 17 `called' should replace `found'
63 23 `after Thanksgiving' should follow `back.'
63 24 Insert following line 23:
A: Yes I did.
Q: What did he tell you then?
65 21 `tchotchke' should replace `chochki'
65 24 `on' should replace `home'
66 20 The line should read: `see if I could see the President. I apologize,' not `see if I could see the President and apologize.'
75 1 `needed' should replace `need'
90 5 `the' should replace `some'
116 16 `said' should precede `list'
128 9 `that's' should replace `of'
154 5 Delete quotation marks.
156 6 Delete quotation marks.
156 6 `Seidman' should replace `Sideman'
161 15 `Fallon' should replace `Phalen'

Provided these changes are made, we will waive signature on behalf of Ms. Lewinsky.

We understand from Senate Legal Counsel that copies of this letter will be made available to the parties and Senate.

Thank you for your assistance.

Sincerely,
PLATO CACHERIS.
PRESTON BURTON.
SYDNEY HOFFMANN.


© Copyright 1999 The Washington Post Company

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