Following is the affidavit submitted by Sidney Blumenthal to federal court on March 16, 1998. It was one of the documents among the 3,183 pages of appendices to independent counsel Kenneth Starr's report released by the House Judiciary Committee on Sept. 21.

DECLARATION OF SIDNEY BLUMENTHAL

Sidney Blumenthal, under penalty of perjury, hereby declares as follows:

1. I am competent to testify from personal knowledge as to the matters set forth in the Declaration. I am filing this Declaration in connection with the Motion to Compel recently filed by the Office of the Independent Counsel ("OIC").

2. I am an Assistant to the President of the United States of America. My office is in the West Wing of the White House.

3. I assumed this position August 11, 1997. Prior to that time, I was a working journalist and was not employed by the White House. My job duties require me to consult with other White House advisors and with private presidential advisors to gather information and advice so that I can properly advise the President.

4. As part of my job, I participate in the following policy issues in the White House: global warming, "fast track" trade authority, tobacco issues, health care, general economic issues. Social Security, education, crime, welfare, urban centers, the Race Initiative, environmental issues, and the District of Columbia.

5. As part of my job, I am also responsible for writing major presidential speeches. For example, I was heavily involved in writing the State of the Union Address given by the President January 27, 1998. Under Article II, section 3 of the Constitution, the President has the duty to provide the Congress with "information of the State of the Union." The content of that address is an important presidential decision on which the President's advisors provide input.

6. I am involved in national security policy as it relates to Latin America, China, Bosnia, Germany, the North Atlantic Treaty Organization (NATO), the Organization of American States (OAS), Iraq, Turkey, Israel, Africa, the United Nations, the Landmines Treaty, Ireland and Northern Ireland.

7. I am the principal White House official on freedom of the press issues internationally.

8. I am also the liaison for the President to the office of the Prime Minister of Great Britain. In that role, I communicate regularly with Prime Minister Tony Blair directly, his Chief of Staff Jonathan Powell, Director of Policy David Miliband, Official Spokesman Alistair Campbell, Minister Without Portfolio Peter Mandelson, and various other aides, ministers, and members of the British Government.

9. I have had substantial involvement in the foreign relations between the United States and Great Britain. I regularly brief the President on matters concerning Great Britain. I participated in the First Lady's visit to Ireland, Northern Ireland, and England in October and November of 1997. I also participated with the First Lady in the Northern Ireland peace process. That process included talks with British Minister Mo Mowlam. I also assisted the United States delegation at policy discussions held with the Prime Minister of Great Britain and various ministers at Chequers November 1, 1997.

10. I participated in the visit by the Prime Minister of Great Britain to the United States in early February 1998. One of the core functions of the President involves foreign policy, including meetings with Heads of State of foreign countries. The internal discussions as well as the manner in which those meetings are portrayed are important to United States foreign policy.

11. I was responsible for official statements made by the President, for joint appearances of the President and the Prime Minister, a joint press conference, an informal lunch, a joint radio address on Iraq, an official White House dinner, and a Blair House dinner hosted by the United States and the United Kingdom ambassadors of official delegations. I also directed the United States delegation at joint policy discussions that were held during the visit. The coordination of these events, including joint press conferences, is important to the international relations between countries.

12. I am currently involved in arranging the President's trip to the G-8 meeting in Birmingham, England, and his subsequent visits to London, all of which are set to occur in May 1998. In regard to that trip, I am responsible for coordinating policy, drafting statements, planning appearances, and planning and directing the United States delegation in policy discussions with the Prime Minister and various ministers at Chequers. In addition, I am planning the United States delegation in meetings with British ministers and senior aides of the Prime Minister of Great Britain.

13. In carrying out these duties, I am in almost daily contact with the President and other senior administration officials. In the course of carrying out my official duties, I have discussed with the President, the First Lady, and other senior administration officials certain matters and allegations pertaining to the investigation being conducted by the Independent Counsel. The First Lady functions as a senior advisor to the President, and it was in that capacity that I had discussions with her about the Independent Counsel's investigation. The discussions with the President, the First Lady, and with other senior advisors to the President enabled me to advise the President and his advisors concerning the effect of the investigation on his official duties, including how best to frame his public statements, his legislative agenda, and his dealings with foreign countries in light of that investigation. For example, these discussions enabled me to advise the President and his advisors with respect to the content of the State of the Union address and with respect to press relations and other aspects of the visit of Prime Minister Blair.

14. Confidentiality is critical to my ability to provide open, frank, and candid advice at all times, not only to the President, but to other senior advisors as well. Based on my experience in the White House, I believe that the ability of advisors to the President to provide him with the type of candid advice the President needs would be hindered if the discussions among staff with the President were not confidential.

15. On February 26, 1998, I testified before a grand jury sitting in the District of Columbia. I had been instructed by the Office of the Counsel to the President to assert executive privilege in response to certain of the questions the Independent Counsel asked me. An answer to those questions would have revealed the communications that I had with other senior advisors, and the confidential advice and counsel that I gave to the President, with regard to policy issues, including the policy issues discussed in the foregoing paragraphs.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on March 16, 1998.

Sidney Blumenthal