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Narrative Pt. XIII: The Affidavit

From independent counsel Kenneth Starr's report to the House on President Clinton. Some of the language in these documents is sexually explicit.

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XIII. January 5-January 16, 1998:

The Affidavit

On January 5, 1998, Ms. Lewinsky's attorney, Francis Carter, drafted an affidavit for Ms. Lewinsky in an attempt to avert her deposition. She spoke with the President that evening. On January 6, Ms. Lewinsky talked to Mr. Jordan about the affidavit, which denied any sexual relations between her and the President. On January 7, Ms. Lewinsky signed the affidavit. On January 8, she interviewed for a job in New York City. After the interview went poorly, Mr. Jordan placed a phone call to the company's chairman on her behalf, and Ms. Lewinsky was given a second interview. The following week, after Ms. Lewinsky told Ms. Currie that she would need a reference from the White House, the President asked Chief of Staff Erskine Bowles to arrange one.

A. January 5: Francis Carter Meeting

At 3:00 p.m. on Monday, January 5, 1998, Ms. Lewinsky met with Mr. Carter at his office for approximately one hour.(899)

Ms. Lewinsky testified that Mr. Carter described what a deposition was like and "threw out a bunch of different questions."(900) The questions that most concerned her related to the circumstances of her departure from the White House.(901)

Mr. Carter told Ms. Lewinsky that he would draft an affidavit for her to sign in hopes of averting her deposition. They arranged for Ms. Lewinsky to pick up a draft of the affidavit the next day.(902)


B. January 5: Call from the President

After her meeting with Mr. Carter, Ms. Lewinsky sent word via Ms. Currie that she needed to speak to the President about an important matter.(903) Specifically, Ms. Lewinsky told Ms. Currie she was anxious about something she needed to sign.(904)

A few hours later, according to Ms. Lewinsky, the President returned her call.(905) She mentioned an affidavit she would be signing and asked if he wanted to see it. According to Ms. Lewinsky, the President responded that he did not, as he had already seen about fifteen others.(906) Ms. Lewinsky testified that she told the President that she was troubled by potential questions about her transfer from the White House to the Pentagon. She was concerned that "people at the White House who didn't like [her]" might contradict her and "get [her] in trouble."(907) The President, according to Ms. Lewinsky, advised her: "[Y]ou could always say that the people in Legislative Affairs got it [the Pentagon job] for you or helped you get it."(908)

The President acknowledged in the grand jury that he was aware that Ms. Lewinsky had signed an affidavit in early January, but had no specific recollection of a conversation with her in that time period.(909) He testified that he did not recall telling Ms. Lewinsky that she could say, if asked, that persons in the Legislative Affairs Office of the White House had helped her obtain the job at the Pentagon.(910)

According to Ms. Lewinsky, she and the President also briefly discussed an antique book that she had dropped off with Ms. Currie the day before. With the book, she enclosed a letter telling the President that she wanted to have sexual intercourse with him at least once.(911) In their phone conversation, Ms. Lewinsky told the President, "I shouldn't have written some of those things in the note."(912) She testified that the President agreed.(913)

Although the President had testified in the Jones case that any personal messages from Ms. Lewinsky to him had been "unremarkable," he told the grand jury that he had received "quite affectionate" messages from Ms. Lewinsky, even after their intimate relationship ended.(914) The President testified that he cautioned Ms. Lewinsky about such messages: "I remember telling her she should be careful what she wrote, because a lot of it was clearly inappropriate and would be embarrassing if somebody else read it. I don't remember when I said that. I don't remember whether it was in '96 or when it was."(915) The President did remember the antique book Ms. Lewinsky had given him, but said he did not recall a romantic note enclosed with it.(916)

C. January 6: The Draft Affidavit

According to Ms. Lewinsky, in the afternoon of January 6, 1998, she visited Mr. Carter's office and picked up a draft of the affidavit.(917) Later that day, according to Ms. Lewinsky, she and Mr. Jordan discussed the draft by telephone.(918) Ms. Lewinsky testified that having Mr. Jordan review the affidavit was like getting it "blessed" by the President.(919) Ms. Lewinsky testified that she told Mr. Jordan that she was worried about a sentence that implied that she had been alone with the President and thus might incline Paula Jones's attorneys to question her.(920) She eventually deleted it.(921)

In addition, Paragraph 8 of the draft affidavit provided in part:

I have never had a sexual relationship with the President. . . . The occasions that I saw the President, with crowds of other people, after I left my employment at the White House in April, 1996 related to official receptions, formal functions or events related to the U.S. Department of Defense, where I was working at the time.(922)

Deeming the reference to "crowds" "too far out of the realm of possibility,"(923) Ms. Lewinsky deleted the underscored phrase and wrote the following sentence at the end of this paragraph: "There were other people present on all of these occasions."(924) She discussed this proposed sentence, as well as her general anxiety about Paragraph 8, with Mr. Jordan.(925)

When questioned in the grand jury, Mr. Jordan acknowledged that Ms. Lewinsky called him with concerns about the affidavit,(926) but maintained that he told her to speak with her attorney.(927)

Phone records for January 6 show that Mr. Jordan had a number of contacts with Ms. Lewinsky, the President, and Mr. Carter. Less than thirty minutes after Mr. Jordan spoke by phone to Ms. Lewinsky, he talked with the President for thirteen minutes. Immediately after this call, at 4:33 p.m., Mr. Jordan called Mr. Carter. Less than an hour later, Mr. Jordan placed a four-minute call to the main White House number. Over the course of the day, Mr. Jordan called a White House number twice, Ms. Lewinsky three times, and Mr. Carter four times.(928)


Mr. Carter testified that his phone conversations with Mr. Jordan this day and the next "likely" related to Ms. Lewinsky and his litigation strategy for her.(929) In fact, Mr. Carter billed Ms. Lewinsky for time for "[t]elephone conference with Atty Jordan."(930)

When questioned in the grand jury, Mr. Jordan testified that he could not specifically remember the January 6 calls. He said he "assumed" that he talked with Ms. Lewinsky about her job search, and he believed that he called Mr. Carter to see "how he was dealing with this highly emotional lady."(931) He said that he might have talked with the President about Ms. Lewinsky, but he maintained that "there [was] no connection" between his 13-minute conversation with the President and the call he placed immediately thereafter to Mr. Carter.(932)

D. January 7: Ms. Lewinsky Signs Affidavit

Ms. Lewinsky set an appointment with Mr. Carter to finalize the affidavit for 10 a.m. on January 7, 1998.(933) She signed the affidavit; however, she acknowledged in the grand jury that statements in it were false.(934) Mr. Carter indicated to her that he "intend[ed] to hold onto this until after I talk to plaintiff's lawyers." He told her to "keep in touch," and said: "Good luck on your job search."(935)

According to Mr. Jordan, Ms. Lewinsky came to his office on January 7 and showed him the signed affidavit.(936) Over the course of the day, Mr. Jordan placed three calls of significant duration to the White House.(937) He testified: "I knew the President was concerned about the affidavit and whether it was signed or not."(938) When asked whether the President understood that the affidavit denied a sexual relationship, Mr. Jordan testified: "I think that's a reasonable assumption."(939) According to Mr. Jordan, when he informed the President that Ms. Lewinsky had signed the affidavit, the President said, "Fine, good."(940) Mr. Jordan said he was continuing to work on her job, and the President responded, "Good."(941)

Ten days after this conversation, in the Jones deposition, President Clinton was asked whether he knew that Ms. Lewinsky had met with Vernon Jordan and talked about the Jones case. He answered:

I knew he met with her. I think Betty suggested that he meet with her. Anyway, he met with her. I, I thought that he talked to her about something else. I didn't know that -- I thought he had given her some advice about her move to New York. Seems like that's what Betty said.(942)

In his grand jury appearance, however, President Clinton testified that Mr. Jordan informed "us" on January 7 that Ms. Lewinsky had signed an affidavit to be used in connection with the Jones case.(943) The President defended his deposition testimony by stating:

[M]y impression was that, at the time, I was focused on the meetings. I believe the meetings he had were meetings about her moving to New York and getting a job.

I knew at some point that she had told him that she needed some help, because she had gotten a subpoena. I'm not sure I know whether she did that in a meeting or a phone call. And I was not, I was not focused on that. I know that, I know Vernon helped her get a lawyer, Mr. Carter. And I, I believe that he did it after she had called him, but I'm not sure. But I knew that the main source of their meetings was about her move to New York and her getting a job.(944)

E. January 8: The Perelman Call

The day after she signed the affidavit, January 8, 1998, Ms. Lewinsky interviewed in New York with Jaymie Durnan, Senior Vice President and Special Assistant to the Chairman at MacAndrews & Forbes Holdings, Inc. (MFH).(945) Mr. Durnan testified that, although impressive, Ms. Lewinsky was not suited for any MFH opening.(946) He told her that he would pass on her resume to Revlon, an MFH company.(947) Ms. Lewinsky called Mr. Jordan and reported that she felt that the interview had gone "very poorly."(948) Mr. Jordan indicated in response that "he'd call the chairman."(949)

At 4:54 p.m., Mr. Jordan called Ronald Perelman, chairman and chief executive officer of MFH.(950) Mr. Jordan told the grand jury with respect to Mr. Perelman, one "[c]an't get any higher -- or any richer."(951) Asked why he chose to call Mr. Perelman, Mr. Jordan responded: "I have spent a good part of my life learning institutions and people, and, in that process, I have learned how to make things happen. And the call to Ronald Perelman was a call to make things happen, if they could happen."(952)

According to Mr. Perelman, Mr. Jordan spoke of "this bright young girl, who I think is terrific," and said that he wanted "to make sure somebody takes a look at her."(953) Mr. Perelman testified that, in the roughly twelve years that Mr. Jordan had been on Revlon's Board of Directors, he did not recall Mr. Jordan ever calling to recommend someone.(954)

After he spoke with Mr. Perelman, Mr. Jordan telephoned Ms. Lewinsky and told her, "I'm doing the best I can to help you out."(955) Ms. Lewinsky soon received a call from Revlon, inviting her to another interview.(956)

Over the course of January 8, Mr. Jordan placed three calls to the White House -- twice to a number at the White House Counsel's Office, once to the main White House number.(957) As to the Counsel's Office calls, Mr. Jordan speculated that he was trying to reach Cheryl Mills, Deputy White House Counsel, to express his "frustration" about Ms. Lewinsky.(958) According to Mr. Jordan, Ms. Mills knew who Ms. Lewinsky was: "[T]hat was no secret, I don't think, around the White House, that I was helping Monica Lewinsky."(959)

F. January 9: "Mission Accomplished"

On the morning of Friday, January 9, 1998, Ms. Lewinsky interviewed with Allyn Seidman, Senior Vice President of MFH, and two individuals at Revlon.(960) Ms. Lewinsky testified that the interviews went well and that Ms. Seidman called her back that day and "informally offered [her] a position, and [she] informally accepted."(961)

Ms. Lewinsky then called Mr. Jordan and relayed the good news.(962) When shown records of a seven-minute call at 4:14 p.m., Mr. Jordan testified: "I have to assume that if she got the job and we have a seven-minute conversation and the day before I had talked to the chairman [Ronald Perelman], I have to assume the Jordan magic worked."(963)

According to Mr. Jordan, he believed that he notified Ms. Currie and the President as soon as he learned that Ms. Lewinsky had obtained an offer: "I am certain that at some point in time I told Betty Currie, 'Mission accomplished.'"(964) Mr. Jordan testified that he also told the President directly that, "'Monica Lewinsky's going to work for Revlon,' and his response was, 'Thank you very much.'"(965)

G. January 12: Pre-Trial Hearing in Jones Case

On January 12, 1998, Judge Wright held a hearing in the Jones case to discuss pre-trial issues, including the President's upcoming deposition.(966) At that hearing, Judge Wright required Ms. Jones's counsel to list all the witnesses that they planned to call at trial. Ms. Jones's witness list named many women, among them Ms. Lewinsky, to support her theory that the President had a pattern of rewarding women based on their willingness to engage in sexual relations with him. At the hearing, Judge Wright indicated that she would permit Ms. Jones to call as witnesses some of the women she listed in support of her case.

H. January 13: References from the White House

On Tuesday, January 13, 1998, Jennifer Sheldon, Manager of Corporate Staffing of Revlon, called Ms. Lewinsky and formally extended her a position as a public relations administrator. Asked whether this was a relatively quick hiring process, Ms. Sheldon responded, "In totality of how long open positions normally stay open, yes. This was pretty fast."(967) Ms. Sheldon told Ms. Lewinsky that she needed to send her some references.(968)

According to Ms. Lewinsky, she then called Ms. Currie because she was "concerned that if I put [Mr. Hilley] down as a reference, he might not say flattering things about me."(969) At 11:11 a.m. on January 13, Ms. Currie paged Ms. Lewinsky and left the following message: "Will know something this afternoon. Kay."(970)

That day, January 13, the President talked with Chief of Staff Erskine Bowles about a reference for Ms. Lewinsky.(971) The President told Mr. Bowles that Ms. Lewinsky "had found a job in the . . . private sector, and she had listed John Hilley as a reference, and could we see if he could recommend her, if asked." Mr. Bowles assured the President that Mr. Hilley would give Ms. Lewinsky a recommendation commensurate with her job performance.(972)

Thereafter, Mr. Bowles took the President's request to Mr. Podesta, the Deputy Chief of Staff, who in turn spoke with Mr. Hilley.(973) Mr. Hilley responded that, because he did not know Ms. Lewinsky personally, he would have his office write a recommendation.(974) It would be a generic letter, simply confirming the dates of employment, because of the less than favorable circumstances surrounding Ms. Lewinsky's departure from the White House.(975)

Ms. Lewinsky testified that Ms. Currie called later that day and told her that "Mr. Podesta took care of it and everything would be fine with Mr. Hilley."(976) At 11:17 a.m. the next day, Wednesday, January 14, Ms. Lewinsky faxed her acceptance to Revlon and listed John Hilley and her Defense Department supervisor as references.(977)

The President was asked in the grand jury whether he ever spoke to Mr. Bowles about obtaining a reference from Mr. Hilley for Ms. Lewinsky. He testified that he did, at Ms. Lewinsky's request, although he thought he had done so earlier than January 13 or 14.(978)

I. January 13: Final Jordan Meeting

According to Ms. Lewinsky, on Tuesday, January 13, she stopped by Mr. Jordan's office to drop off some thank-you gifts for helping her find a job. Ms. Lewinsky offered to show him a copy of her signed affidavit in the Jones case, but he indicated that he did not need to see it.(979)

J. January 13-14: Lewinsky-Tripp Conversation and Talking Points

In a face-to-face conversation on January 13, Ms. Lewinsky told Linda Tripp: "This is what my lawyer taught me. You really don't -- you don't very often say 'no' unless you really need to. The best is, 'Well, not that I recall, not that I really remember. Might have, but I don't really remember.'"(980) Ms. Lewinsky said that, if asked in a deposition, "Were you ever alone with the President?" she could say, "Um, it's possible I may have taken a letter on the weekend, but, you know -- I might have, but I don't really. . . ."(981)

Ms. Lewinsky and Ms. Tripp then discussed the situation:

Ms. Lewinsky: I don't think the way that man thinks, I don't think he thinks of lying under oath. . . .

Ms. Tripp: Yes, he is because he's the one who said, "Deny, deny, deny." Of course he knows.

Ms. Lewinsky: Right. But it's -- hard to explain this. It's like -- (sigh)

Ms. Tripp: You know what I mean. I mean, I don't know -- do I think he is consciously --

Ms. Lewinsky: If-- if -- if I said, if somebody said to him, "Is Monica lying under oath," he would say yes. But when he on his own thinks about it, he doesn't think about it in those terms. Okay?

Ms. Tripp: Probably.

Ms. Lewinsky: Okay? He thinks of it as, "We're safe. We're being smart." Okay? "We're being smart, we're being safe, it's good for everybody."(982)

On January 14, Ms. Lewinsky gave Ms. Tripp a three-page document regarding "points to make in [Ms. Tripp's] affidavit."(983) Ms. Lewinsky testified that she wrote the document herself, although some of the ideas may have been inspired by conversations with Ms. Tripp.(984)

K. January 15: The Isikoff Call

In the grand jury, Betty Currie testified that on Thursday, January 15, 1998, she received a telephone call from Michael Isikoff of Newsweek, who inquired about courier receipts reflecting items sent by Ms. Lewinsky to the White House.(985)

Ms. Currie called Mr. Jordan and asked for guidance in responding to Mr. Isikoff's inquiry because, in her words, she had a "comfort level with Vernon."(986) After Ms. Currie arranged to meet with Mr. Jordan at his office,(987) Ms. Lewinsky drove her there.(988)

Mr. Jordan confirmed in the grand jury that Ms. Currie expressed concern about a call from Mr. Isikoff.(989) He invited her to his office but advised her to "talk to Mike McCurry and Bruce Lindsey . . . because I cannot give you that advice."(990)

In a recorded conversation that day, January 15, Ms. Lewinsky encouraged Ms. Tripp not to disclose her (Lewinsky's) relationship with the President. Ms. Lewinsky tried to persuade Ms. Tripp to lie by telling her that others planned to lie: "I'm not concerned all that much anymore because I'm not going to get in trouble because you know what? The story I've signed . . . under oath is what someone else is saying under oath." When Ms. Tripp asked, "Who?" Ms. Lewinsky responded: "He will," referring to the President.(991) Ms. Lewinsky stated that she did not think the President would "slip up" at his deposition because she was not a "big issue" like Gennifer Flowers and Paula Jones. In contrast, she regarded herself as nothing more than "rumor and innuendo."(992)

One of Ms. Lewinsky's friends, Natalie Ungvari, testified that, when Ms. Lewinsky was implicated in the Jones case, "it seemed to me that Monica was just confident everybody would say the right thing, that everything would be orchestrated to come out a secret."(993)

L. January 15-16: Developments in the Jones Law Suit

On January 15, 1998, President Clinton's counsel served Ms. Jones's attorneys with the President's responses to Ms. Jones's document requests.(994) One of the requests specifically sought all documents reflecting communications between the President and Monica Lewinsky.(995) President Clinton objected to the scope of this request, but, notwithstanding his objection, he stated that he did not have any responsive documents.

Also on January 15, Mr. Carter drafted a motion to quash the subpoena issued by Paula Jones's attorneys to Ms. Lewinsky. Attached to the motion was Ms. Lewinsky's signed affidavit.(996) At the request of Katherine Sexton, one of the President's personal attorneys, Mr. Carter faxed a copy of the affidavit to her law offices. Mr. Carter testified that he asked Ms. Sexton why she needed the affidavit that day:

I said, "Well, Katie, you're going to get it tomorrow because I'm filing it, and it's going to be attached as an exhibit to the motion." She said, "Well, but you've already provided it to the other side, so can I get a copy" -- words to that effect. I said, "I have no problem." And so I faxed it to her.(997)

On January 16, 1998, Mr. Carter arranged for the overnight delivery of the motion to quash and the accompanying affidavit to Judge Susan Webber Wright's law clerk and Paula Jones's attorneys.(998)

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