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Narrative Pt. XIV: The Deposition and Afterward

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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XIV. January 17, 1998-Present:

The Deposition and Afterward

The President was asked a number of questions about Ms. Lewinsky during his January 17, 1998, deposition in the Jones case. In sworn testimony, the President denied having a sexual affair or sexual relations with her. That evening, the President called Ms. Currie and asked her to meet him the following day to discuss Ms. Lewinsky. After allegations that the President had an affair with a White House intern became public, the President emphatically denied the reports to aides and to the American public.

A. January 17: The Deposition


On Saturday, January 17, 1998, the President testified under oath at a deposition in the Jones case.(999) Judge Susan Webber Wright traveled from Little Rock, Arkansas, to preside at the deposition in Washington, D.C.(1000)

Prior to any questions, Judge Wright reminded the parties about her standing Protective Order. She specifically stated: "[I]f anyone reveals anything whatsoever about this deposition,

. . . it will be in violation of the Protective Order. This includes the questions that were asked, . . . You may acknowledge that [the deposition] took place, but that is it."(1001) Judge Wright accepted the following definition of the term "sexual relations:"

For the purposes of this deposition, a person engages in "sexual relations" when the person knowingly engages in or causes . . . contact with the genitalia, anus, groin, breast, inner thigh, or buttocks of any person with an intent to arouse or gratify the sexual desire of any person . . . . "Contact" means intentional touching, either directly or through clothing.(1002)

After the President had answered a few questions about Ms. Lewinsky, his attorney, Robert Bennett, urged Judge Wright to limit further inquiries. Mr. Bennett stated that Ms. Lewinsky had executed an affidavit "saying that there is absolutely no sex of any kind of any manner, shape or form, with President Clinton."(1003) When Judge Wright cautioned Mr. Bennett not to make remarks that "could be arguably coaching the witness," Mr. Bennett represented to Judge Wright: "In preparation of the witness for this deposition, the witness is fully aware of Ms. Lewinsky's affidavit, so I have not told him a single thing he doesn't know . . . ."(1004) President Clinton, who was presentwhen Mr. Bennett made his objection, did not contradict his attorney's comment. Rejecting Mr. Bennett's argument, Judge Wright permitted the questioning about Ms. Lewinsky to continue.(1005)

Over the course of extensive questioning, the President testified that he had seen Ms. Lewinsky "on two or three occasions" during the government shutdown in the fall of 1995, including one occasion when she brought pizza to him, and one or two other occasions when she delivered documents to him.(1006) He could not recall whether he had been alone with Ms. Lewinsky on such occasions, although he acknowledged that it was possible.(1007) The President further testified that he could not remember the subject of any conversations with Ms. Lewinsky.(1008)

President Clinton recalled that he received only a couple of unremarkable personal messages from Ms. Lewinsky, and he could not recall ever having received a cassette tape from her.(1009) He received presents from her "[o]nce or twice" -- a book or two and a tie.(1010) The President originally testified that he could not recall any gifts he might have given her; later in the deposition, however, he remembered that some merchandise he had purchased from a Martha's Vineyard restaurant might have reached her through Ms. Currie.(1011) The President stated that he might have given Ms. Lewinsky a hat pin, though he could not recall for certain.(1012)

The President testified that his last conversation with Ms. Lewinsky had been before Christmas, when she had visited the White House to see Ms. Currie. The President stated: "I stuck my head out, said hello to her."(1013) He said it was also possible that, during that encounter, he had joked with Ms. Lewinsky that the plaintiff's attorneys were going to subpoena "every woman I ever talked to" and Ms. Lewinsky "would qualify."(1014)

The President testified that he was unaware that Mr. Jordan had talked with Ms. Lewinsky about the Jones case, in which she had also been subpoenaed to testify at a deposition.(1015)

The President emphatically denied having had sexual relations with Ms. Lewinsky.(1016)

At the conclusion of the deposition, Judge Wright said: "Before [the President] leaves, I want to remind him, as the witness in this matter, and everyone else in the room, that this case is subject to a Protective Order regarding all discovery, . . . and . . . all parties present, including . . . the witness are not to say anything whatsoever about the questions they were asked, the substance of the deposition, . . . any details, . . . and this is extremely important to this Court."(1017)

Sometime after the President's deposition, Mr. Podesta saw Bruce Lindsey, Deputy White House Counsel, at the White House and inquired how the deposition went. According to Mr. Podesta, Mr. Lindsey said that the President had been asked about Monica Lewinsky.(1018) Mr. Lindsey testified that, during a break in the President's deposition, the President had told him that Ms. Lewinsky's name had come up.(1019)

That same evening, Mr. Lindsey met with the President in the Oval Office, where they discussed the deposition.(1020) Mr. Lindsey, relying on the attorney-client, presidential communication, deliberative process, and work-product privileges, declined to say what specifically was discussed at this meeting.

B. The President Meets with Ms. Currie

Soon after the deposition, the President called Ms. Currie and asked her to come to the White House the next day.(1021) Ms. Currie acknowledged that, "It's rare for [the President] to ask me to come in on Sunday."(1022) The President wanted to discuss Ms. Lewinsky's White House visits.(1023)

At approximately 5:00 p.m. on Sunday, January 18, 1998, Ms. Currie met with the President.(1024) The meeting took place at her desk outside the Oval Office. According to Ms. Currie, the President appeared "concerned."(1025) He told Ms. Currie that, during his deposition the previous day, he had been asked questions about Monica Lewinsky.(1026) Ms. Currie testified: "I think he said, 'There are several things you may want to know.'"(1027) He proceeded to make a series of statements,(1028) one right after the other:(1029)

  • "You were always there when she was there, right?"
  • "We were never really alone."
  • "Monica [Lewinsky] came on to me, and I never touched her, right?"
  • "You can see and hear everything, right?"(1030)

Ms. Currie testified that, based on his demeanor and the way he made the statements, the President wanted her to agree with them.(1031)

Ms. Currie testified that she did, in fact, agree with the President when he said, "You were always there when she was there, right?"(1032) Before the grand jury, however, Ms. Currie acknowledged the possibility that Ms. Lewinsky could have visited the President when she was not at the White House.(1033)

With respect to whether the President was "never really alone" with Ms. Lewinsky, Ms. Currie testified that there were several occasions when the President and Ms. Lewinsky were either in the Oval Office or in the study without anyone else present.(1034)

Ms. Currie explained that she did not consider the President and Ms. Lewinsky to be "alone" on such occasions because she was at her desk outside the Oval Office; accordingly, they were all together in the same "general area."(1035) Ms. Currie testified that "the President, for all intents and purposes, is never alone. There's always somebody around him."(1036)


As to whether Ms. Lewinsky "came on" to him, Ms. Currie testified that she "would have no reason to know" whether Ms. Lewinsky ever "came on" to the President because Ms. Currie was not present all the time.(1037) Finally, as to whether she "could see and hear everything," Ms. Currie testified that she should not have agreed with the President.(1038) She testified that when the President and Ms. Lewinsky were alone together in the study, while Ms. Currie was at her desk, she could "hear nothing."(1039)

The President also made the following statement during their January 18, 1998 meeting, according to Ms. Currie: "[Monica Lewinsky] wanted to have sex with me, but I told her I couldn't do that."(1040)

When the President was questioned about this meeting with Ms. Currie in the grand jury, he testified that he recalled the conversation, but he denied that he was "trying to get Betty Currie to say something that was untruthful."(1041) Rather, the President testified that he asked a "series of questions" in an effort to quickly "refresh [his] memory."(1042) The President explained: "I wanted to establish . . . that Betty was there at all other times in the complex, and I wanted to know what Betty's memory was about what she heard, what she could hear . . . . [a]nd I was trying to figure [it] out . . . in a hurry because I knew something was up."(1043)

In his grand jury testimony, the President acknowledged that, "in fairness," Ms. Currie "may have felt some ambivalence about how to react" to his statements.(1044) The President maintained that he was trying to establish that Ms. Currie was "always there," and could see and hear everything.(1045) At the same time, he acknowledged that he had always tried to prevent Ms. Currie from learning about his relationship with Ms. Lewinsky.(1046) "[I] did what people do when they do the wrong thing. I tried to do it where nobody else was looking at it."(1047)

The President was also asked about his statement that Ms. Currie was always in the Oval Office when Ms. Lewinsky visited. He explained that he may have intended the term "Oval Office" to include the entire Oval Office complex.(1048) The President further explained, "I was talking about 1997. I was never, ever trying to get Betty Currie to claim that on the occasions when Monica Lewinsky was there when she wasn't anywhere around, that she was."(1049) When asked whether he restricted his remarks to the year 1997, the President responded, "Well, I don't recall whether I did or not, but . . . I assumed [Ms. Currie] knew what I was talking about."(1050)

When questioned about his statement to Ms. Currie, "you

could see and hear everything," the President responded:

My memory of that was that, that she had the ability to hear what was going on if she came in the Oval Office from her office. And a lot of times, you know, when I was in the Oval Office, she just had the door open to her office. Then there was -- the door was never completely closed to the hall. So, I think there was -- I'm not entirely sure what I meant by that, but I could have meant that she generally would be able to hear conversations, even if she couldn't see them. And I think that's what I meant.(1051)

Finally, when asked about his statement to Ms. Currie that "Monica came on to me and I never touched her," the President refused to answer.(1052)

C. January 18-19: Attempts to Reach Ms. Lewinsky

In the wake of her Sunday afternoon session, Ms. Currie paged Ms. Lewinsky four times.(1053) She testified that the President "may have asked me to call [Ms. Lewinsky] to see what she knew or where she was or what was happening."(1054) Later that evening, at 11:02 p.m., the President called Ms. Currie to ask whether she had spoken to Ms. Lewinsky.(1055)

Over a two-hour span the next morning, Monday, January 19, 1998, Ms. Currie made eight unsuccessful attempts to contact Ms. Lewinsky, by either pager or telephone.(1056) After speaking with the President to let him know that she was unable to reach Ms. Lewinsky, Ms. Currie again paged her.(1057) The purpose of these calls, according to Ms. Currie, was to tell Ms. Lewinsky that her name had been mentioned in the President's deposition.(1058)

Mr. Jordan also tried unsuccessfully to reach Ms. Lewinsky that morning.(1059) That afternoon, Mr. Jordan met with the President in the Oval Office.(1060) Later, Ms. Lewinsky's attorney, Frank Carter, called Mr. Jordan and told him that Ms. Lewinsky had obtained new counsel, William Ginsburg and Nathaniel Speights.(1061) Mr. Jordan passed this information on to the President that evening in a seven-minute phone conversation.(1062)

D. January 20-22: Lewinsky Story Breaks

After the publication of an article alleging a sexual relationship with Ms. Lewinsky, President Clinton conferred with his attorneys and issued a number of denials to his aides and to the American public.

1. "Clinton Accused"

On Wednesday, January 21, 1998, the Washington Post published a story entitled "Clinton Accused of Urging Aide to Lie; Starr Probes Whether President Told Woman to Deny Alleged Affair to Jones's Lawyers."(1063) The White House learned the essentials of the Post story on the night of January 20, 1998.(1064)

President Clinton placed a number of phone calls that night and the following morning.(1065) From 12:08 a.m. to 12:39 a.m., he spoke with his personal attorney, Robert Bennett. Mr. Bennett would be quoted in the Post article as saying, "The President adamantly denies he ever had a relationship with Ms. Lewinsky and she has confirmed the truth of that."(1066) He added: "This story seems ridiculous and I frankly smell a rat."(1067)

Immediately after his call to Mr. Bennett, President Clinton called Deputy White House Counsel Bruce Lindsey; they spoke for about half an hour, until 1:10 a.m.(1068)

At 1:16 a.m., the President called Ms. Currie at home and spoke to her for 20 minutes. Ms. Currie testified that the President was concerned that her name was mentioned in the Post article.(1069) Soon after this call, the President called Mr. Lindsey.(1070)

A few hours later, at approximately 6:30 a.m., the President called Mr. Jordan in New York City to tell him, according to Mr. Jordan, that the Post story was untrue.(1071) From 7:14 a.m. to 7:22 a.m., the President spoke again with Mr. Lindsey.(1072)

Responding to the Post story that day, the White House issued a statement, personally approved by the President, declaring that he was "outraged by these allegations" and that "he has never had an improper relationship with this woman." White House spokesperson Mike McCurry said that the statement "was prepared by the Counsel's office, and I reviewed it with the President to make sure that it reflected what he wanted me to say . . . He looked at it, and he said fine. . . . It was prepared in consultation between the lawyers and the President. The Counsel's Office gave it to me. I wanted to, of course, verify that that's exactly what the President wanted me to say."(1073)

2. Denials to Aides

According to Mr. Lindsey, the remainder of the morning was spent in a series of meetings about the Lewinsky matter, including preparing the President for anticipated Lewinsky-related questions in three previously scheduled media interviews.(1074) At these meetings, President Clinton denied the allegations to several of his top aides.

The President met with Chief of Staff Erskine Bowles, along with his two deputies, John Podesta and Sylvia Matthews. According to Mr. Bowles, the President told them, "I want you to know I did not have sexual relationships with this woman, Monica Lewinsky. I did not ask anybody to lie. And when the facts come out, you'll understand."(1075) The President made a similar denial that morning to Harold Ickes, his former Deputy Chief of Staff.(1076) The President also discussed the matter with Ms. Currie for a second time.(1077) According to Ms. Currie, the President called her into the Oval Office and gave a "sort of a recapitulation of what we had talked about on Sunday -- you know, 'I was never alone with her' -- that sort of thing."(1078) The President spoke with the same tone and demeanor that he used during his previous session with her.(1079) Ms. Currie testified that the President may have mentioned that she might be asked about Ms. Lewinsky.(1080)

Later that day, the President summoned Sidney Blumenthal to the Oval Office. They spoke for about 30 minutes.(1081) The President said to Mr. Blumenthal, "I haven't done anything wrong."(1082) Mr. Blumenthal testified that the President told him, "Monica Lewinsky came on to me and made a sexual demand on me." The President said that he "rebuffed her."(1083) The President also told Mr. Blumenthal that Ms. Lewinsky had "threatened him. She said that she would tell people they'd had an affair, that she was known as the stalker among her peers, and that she hated it and if she had an affair or said she had an affair then she wouldn't be the stalker any more."(1084) Mr. Blumenthal then asked the President whether he and Ms. Lewinsky were alone when she threatened him. The President responded, "Well, I was within eyesight or earshot of someone."(1085)

According to Mr. Blumenthal, the President complained: "I feel like a character in a novel. I feel like somebody who is surrounded by an oppressive force that is creating a lie about me and I can't get the truth out. I feel like the character in the novel Darkness at Noon."(1086)

Soon thereafter, in the course of a meeting about the progress of the President's State of the Union address, the President made a second denial of the allegations to Mr. Podesta.(1087) Mr. Podesta testified:

[H]e said to me that he had never had sex with her, and that -- and that he never asked -- you know, he repeated the denial, but he was extremely explicit in saying he never had sex with her . . . . Well, I think he said -- he said that -- there was some spate of, you know, what sex acts were counted, and he said that he had never had sex with her in any way whatsoever -- that they had not had oral sex.(1088)

The President was asked during his grand jury appearance whether he recalled denying a sexual relationship with Ms. Lewinsky to his senior aides and advisors, including Mr. Bowles, Mr. Podesta, Mr. Blumenthal, Mr. Ickes, and Mr. Jordan.(1089) The President did not recall specific details but did remember the following:

I met with certain people, and [to] a few of them I said I didn't have sex with Monica Lewinsky, or I didn't have an affair with her or something like that. I had a very careful thing I said, and I tried not to say anything else . . . . I remember that I issued a number of denials to people that I thought needed to hear them, but I tried to be careful and to be accurate.

* * *

And I believe, sir, that -- you'll have to ask them what they thought. But I was using those terms in the normal way people use them.(1090)

The President testified that he had said "things that were true about this relationship. That I used -- in the language I used, I said, there's nothing going on between us. That was true.(1091) I said I did not have sex with her as I defined it. That was true."(1092) The President qualified this answer, however: "I said things that were true. They may have been misleading, and if they were I have to take responsibility for it, and I'm sorry."(1093)

3. Initial Denials to the American Public

On the afternoon of January 21, the President made his first of a series of previously scheduled media appearances. In an interview on National Public Radio's "All Things Considered," the following colloquy took place:

Q: Mr. President, . . . . [m]any Americans woke up to the news today that the Whitewater independent counsel is investigating an allegation that you . . . encouraged a young woman to lie to lawyers in the Paula Jones civil suit. Is there any truth to that allegation?

WJC: No, sir, there's not. It's just not true.

Q: Is there any truth to the allegation of an affair between you and the young woman?

WJC: No. That's not true either. . . . The charges are not true. And I haven't asked anybody to lie.(1094)

That evening, the President appeared on the PBS program "The News Hour with Jim Lehrer." He was asked again whether the allegation of an affair with a White House intern was true. The President replied, "That is not true. That is not true. I did not ask anyone to tell anything other than the truth. There is no improper relationship. And I intend to cooperate with this inquiry. But that is not true." When asked to define what he meant by the term "improper relationship," the President answered, "Well, I think you know what it means. It means that there is not a sexual relationship, an improper sexual relationship, or any other kind of improper relationship."(1095)

The following morning, on January 22, 1998, the President again denied he had done anything improper. Speaking at a televised White House photo opportunity with Palestinian Authority Chairman Yasser Arafat, the President stated: "[T]he allegations are false, and I would never ask anybody to do anything other than tell the truth. That is false."(1096)

The President also gave an interview to Roll Call that day. He stated: "[T]he relationship was not improper, and I think that's important enough to say. . . . But let me answer -- it is not an improper relationship and I know what the word means. . . . The relationship was not sexual. And I know what you mean, and the answer is no."(1097)

At each of these interviews, the President pledged he would cooperate fully with the investigation. On NPR, the President stated: "I have told people that I would cooperate in the investigation, and I expect to cooperate with it. I don't know any more about it, really, than you do. But I will cooperate. . . . I'm doing my best to cooperate with the investigation."(1098) To Mr. Lehrer, he said: "[W]e are doing the best to cooperate here, but we don't know much yet. . . . I think it's important that we cooperate, I will cooperate, but I want to focus on the work at hand."(1099)

In his photo opportunity with Mr. Arafat, the President stated:

[T]he American people have a right to get answers. We are working very hard to comply, get all the requests for information up here. And we will give you as many answers as we can, as soon as we can, at the appropriate time, consistent with our obligation to also cooperate with the investigations. And that's not a dodge; that's really what I've -- I've talked with our people. I want to do that. I'd like for you to have more rather than less, sooner rather than later. So we will work through it as quickly as we can and get all those questions out there to you."(1100)

Finally, in his Roll Call interview, the President vowed: "I'm going to cooperate with this investigation. . . . And I'll cooperate."(1101)

4. "We Just Have To Win"

Amidst the flurry of press activity on January 21, 1998, the President's former political consultant, Dick Morris, read the Post story and called the President.(1102) According to Mr. Morris, he told the President, "You poor son of a bitch. I've just read what's going on."(1103) The President responded, Mr. Morris recalled, "Oh, God. This is just awful. . . . I didn't do what they said I did, but I did do something. I mean, with this girl, I didn't do what they said, but I did . . . do something(1104). . . . And I may have done enough so that I don't know if I can prove my innocence. . . . There may be gifts. I gave her gifts, . . . . [a]nd there may be messages on her phone answering machine."(1105)

Mr. Morris assured the President, "[t]here's a great capacity for forgiveness in this country and you should consider tapping into it."(1106) The President said, "But what about the legal thing? You know, the legal thing? You know, Starr and perjury and all. . . . You know, ever since the election, I've tried to shut myself down. I've tried to shut my body down, sexually, I mean. . . . But sometimes I slipped up and with this girl I just slipped up."(1107)

Mr. Morris suggested that he take a poll on the voters' willingness to forgive confessed adultery. The President agreed.(1108)

Mr. Morris telephoned the President later that evening with the poll results, which showed that the voters were "willing to forgive [the President] for adultery, but not for perjury or obstruction of justice[.]"(1109) When Mr. Morris explained that the poll results suggested that the President should not go public with a confession or explanation, he replied, "Well, we just have to win, then."(1110)

The President had a follow-up conversation with Mr. Morris during the evening of January 22, 1998, when Mr. Morris was considering holding a press conference to "blast Monica Lewinsky 'out of the water.'"(1111) The President told Mr. Morris to "be careful". According to Mr. Morris, the President warned him not to "be too hard on [Ms. Lewinsky] because there's some slight chance that she may not be cooperating with Starr and we don't want to alienate her by anything we're going to put out."(1112)

Meanwhile, in California, the President's good friend and Hollywood producer, Harry Thomason, had seen the President's interview with Jim Lehrer on televison.(1113) Mr. Thomason, who had occasionally advised the President on matters relating to the media, traveled to Washington, D.C., and met with him the next day.(1114) Mr. Thomason told the President that "the press seemed to be saying that [the President's comments were] weak" and that he, Mr. Thomason, "thought his response wasn't as strong as it could have been."(1115) Mr. Thomason recommended that the President "should explain it so there's no doubt in anybody's mind that nothing happened."(1116) The President agreed: "You know, you're right. I should be more forceful than that."(1117)

In the ensuing days, the President, through his Cabinet, issued a number of firm denials. On January 23, 1998, the President started a Cabinet meeting by saying the allegations were untrue.(1118) Afterward, several Cabinet members appeared outside the White House. Madeline Albright, Secretary of State, said: "I believe that the allegations are completely untrue." The others agreed. "I'll second that, definitely," Commerce Secretary William Daley said. Secretary of Education Richard Riley and Secretary of Health and Human Services Donna Shalala concurred.(1119)

The next day, Ann Lewis, White House Communications Director, publicly announced that "those of us who have wanted to go out and speak on behalf of the president" had been given the green light by the President's legal team.(1120) She reported that the President answered the allegations "directly" by denying any improper relationship. She believed that, in issuing his public denials, the President was not "splitting hairs, defining what is a sexual relationship, talking about 'is' rather than was.(1121) You know, I always thought, perhaps I was naive, since I've come to Washington, when you said a sexual relationship, everybody knew what that meant." Ms. Lewis expressly said that the term includes "oral sex."(1122)

* * *

On Monday, January 26, 1998, in remarks in the Roosevelt Room in the White House, President Clinton gave his last public statement for several months on the Lewinsky matter. At an event promoting after-school health care, the President denied the allegations in the strongest terms: "I want to say one thing to the American people. I want you to listen to me. I'm going to say this again: I did not have sexual relations with that woman, Miss Lewinsky. I never told anybody to lie, not a single time. Never. These allegations are false."(1123)

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