Excerpt from Kathleen Willey Cross-Examination
Following is the excerpt from Kathleen E. Willey's deposition released on March 20 by President Clinton's lawyer Robert S. Bennett.
The Jones legal team on March 13 released long portions of this same deposition, which was originally taken on Jan. 11, but did not include any of the cross examination by Bennett. The deposition was presided over by Judge Robert R. Merhige Jr.
CROSS EXAMINATION BY MR. BENNETT:
Q. Ms. Willey, would you like I have about 15 minutes maybe.
A. I'm okay.
Q. Ms. Willey, you've referred to an incident in November '93; is that correct?
Q. November 29 to be exact?
Q. And that is the date that your husband committed suicide; is that correct?
Q. How long had you known Bill Clinton as of November 29, 1993?
A. We had met him I believe in 1989 at a fundraiser for Governor Wilder.
Q. Is it fair to say that you considered him a friend and he considered you a friend?
Q. You had a good relationship; isn't that correct?
Q. On the date of the incident, you say Bill Clinton made a pass at you; is that right?
[Jones lawyer] MR. [Donovan] CAMPBELL: Objection. Misstates prior testimony.
THE COURT: That's a conclusion that somebody else might make. Did you view it as a pass?
MR BENNETT: I believe she testified she did, Your Honor.
MR. CAMPBELL: Same objection.
THE COURT: You may answer.
A. Yeah. Yes.
Q. And you rebuffed it?
Q. You rebuffed it; is that correct?
Q. Is it fair to say that Mr. Clinton accepted that rebuff and didn't force himself upon you?
A. That's right.
Q. He accepted that; didn't he?
Q. You were free to leave right away if you wanted to; isn't that correct?
A. Yes, sir.
Q. Did Mr. Clinton expose his private parts to you?
A. No, sir.
Q. Did Mr. Clinton ask you to undress?
A. No, sir.
Q. Did he undress in any way?
Q. Do you know Paula Jones?
A. I know who she is.
Q. Have you ever met her?
Q. Have you ever talked to her?
Q. Have you ever talked to Mr. Clinton about her?
Q. Do you know anything at all about personal knowledge about the incident which occurred in 1991 which allegedly occurred at the Excelsior Hotel?
Q. Have you ever been employed by the Arkansas state government in any way?
Q. Have you ever communicated at any time with Ms. Jones or with Mr. Clinton about the lawsuit, the Clinton the Jones-Clinton lawsuit?
Q. At the time of this incident, were you a paid employee?
Q. These meetings you had with Mr. Clinton, you were the one that instigated the meetings; is that correct? May I finish?
MR. CAMPBELL: You may.
Q. You instigated the meetings; you asked to see him; correct?
MR. CAMPBELL: Objection. Misstates prior testimony.
THE COURT: Overruled.
Q. Certainly Arkansas state troopers were not involved in setting up these meetings; were they?
A. No, they weren't.
Q. Indeed, the Secret Serviuce agents weren't?
A. No, they weren't.
Q. Used to set up; were they?
A. No, they weren't.
Q. Has Mr. Clinton at any time ever offered you any employment or favorable benefits in return for sexual favors?
Q. Has he ever threatened you that if you didn't engage in sexual activity with him that somehow you would be penalized?
Q. Have you ever had sexual relations with Mr. Clinton, sexual intercourse with him?
Q. Has he ever asked you to have it?
Q. Following this incident, you've testified that you went and saw Mr. Clinton in the Oval Office on a few occasions; is that correct?
Q. And after the incident you corresponded with him; isn't that correct?
A. That's correct.
Q. And on occasions you would communicate that you would request certain favors of him, such as your friend who was sick with the tumor?
A. Right, yes.
Q. And he was always very gracious and responsive to that; isn't that correct?
Q. Now, I know it's very difficult to go back into the incident involving your husband, but I'd like to briefly for the completeness of the record. On November 29, 1993, when you went to see Mr. Clinton, you wanted to communicate to him what you have referred to as a family crisis; is that correct?
Q. Could you tell us in essence what that family crisis was that you were communicating to Mr. Clinton?
A. My husband had asked me to sign a promissory note to some clients of his two weeks prior to that and subsequent to my signing that he told me that he had stolen the money from his client and then but he told me that he was going to take care of everything.
Q. And you went in and spoke to Mr. Clinton and he told him about this; is that right?
A. Yes. I told him that there was a crisis and that he was facing some possible trouble and that it was time for me to take over.
Q. And he was sympathetic to you; wasn't he?
Q. And during that meeting you were crying; weren't you?
Q. And you were understandably emotional and upset; isn't that correct?
MR. CAMPBELL: Judge, I think he's leading the witness.
THE COURT: He has a right to. He's got her on cross examination. Objection overruled.
Q. You were emotionally upset during that meeting; isn't that right?
Q. Following this incident, you again spoke to Mr. Clinton about some of your personal difficulties; is that correct?
Q. And he, again, was very sympathetic and consoling to you; wasn't he?
Q. On all the occasions that you met with Mr. Clinton both before and after the incident, it would be commonplace, wouldn't it, for both you and he to hug each other?
Q. In fact, Exhibit 7, which counsel showed you, it appears that you're both about to hug. Would you look at it is that correct?
A. Yes, that's correct.
Q. Who is Julie Steele? Exactly?
A. She's a former friend of mine.
Q. And how do you spell that for the reporter?
MR. BENNETT: I don't know how.
Q. Where does she work; do you know?
A. I don't know.
Q. When's the last time that you talked with her?
A. The last time I talked to her was in the grocery store when I ran into her after I found out that she sold my picture to the National Enquirer for $10,000.
MR. BENNETT: Your Honor, I don't think I have any other question.
THE COURT: Any redirect, Mr. Campbell?
MR. CAMPBELL: Just one.
REDIRECT BY MR. CAMPBELL
Q. Ms. Willey, I thought that you testified on direct that at least one of the meetings that you had with defendant Clinton was arranged by Nancy; isn't that right?
A. Well, they're all arranged by Nancy.
Q. Well, one of them was initiated by Nancy?
MR. BENNETT: Well, I object. What do you mean by "initiated"?
MR. CAMPBELL: Fine. Let me clarify that.
Q. Isn't it correct that your understanding of one of those meetings was that Mr. Clinton wanted to see you?
A. I understand what you mean. I understood that the president wanted to see me when I came back to the White House after my husband's suicide. I don't remember how I knew that because I was in a horrible state after he died for quite a long time. I think I do know that Nancy had called. I think maybe she had said, "Please let us know when you come back becuase we would like to see you." I think.
MR. CAMPBELL: Pass the witness.
THE DEPONENT: That's my feeling for how Nancy initiated that.
THE COURT: Any recross?
MR. BENNETT: Just very, very briefly. Very, very briefly.
RECROSS EXAMINATION BY MR. BENNETT
Q. When you saw him after that, he, again, was very sympathetic and consoling to you; isn't that correct?
A. Yes, sir.
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