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I. Nature of President Clinton's Relationship with Monica Lewinsky
B. Evidence Establishing Nature of Relationship
2. Ms. Lewinsky's Statements 3. Ms. Lewinsky's Confidants 4. Documents 5. Consistency and Corroboration D. Emotional Attachment E. Conversations and Phone Messages F. Gifts G. Messages H. Secrecy II. 1995: Initial Sexual Encounters
B. First Meetings with the President C. November 15 Sexual Encounter D. November 17 Sexual Encounter E. December 31 Sexual Encounter F. President's Account of 1995 Relationship III. January-March 1996: Continued Sexual Encounters
B. January 21 Sexual Encounter C. February 4 Sexual Encounter and Subsequent Phone Calls D. President's Day (February 19) Break-up E. Continuing Contacts F. March 31 Sexual Encounter IV. April 1996: Ms. Lewinsky's Transfer to the Pentagon
B. Decision to Transfer Ms. Lewinsky C. Ms. Lewinsky's Notification of Her Transfer D. Conversations with the President about Her Transfer V. April-December 1996: No Private Meetings
B. No Physical Contact C. Telephone Conversations D. Public Encounters E. Ms. Lewinsky's Frustrations VI. Early 1997: Resumption of Sexual Encounters
B. Valentine's Day Advertisement C. February 24 Message D. February 28 Sexual Encounter E. March 29 Sexual Encounter F. Continuing Job Efforts VII. May 1997: Termination of Sexual Relationship VIII. June-October 1997: Continuing Meetings and Calls
B. July 3 Letter C. July 4 Meeting D. July 14-15 Discussions of Linda Tripp E. July 16 Meeting with Marsha Scott F. July 24 Meeting G. Newsweek Article and Its Aftermath H. August 16 Meeting I. Continuing Job Efforts J. Black Dog Gifts K. Lucy Mercer Letter and Involvement of Chief of Staff L. News of Job Search Failure IX. October-November 1997: United Nations' Job Offer
B. October 11 Meeting C. October 16-17: The "Wish List D. The President Creates Options E. The U.N. Interview and Job Offer F. The U.N. Job Offer Declined X. November 1997: Growing Frustration
B. First Vernon Jordan Meeting C. November 13: The Zedillo Visit D. November 14-December 4: Inability to See the President XI. December 5-18, 1997: The Witness List and Job Search
B. December 5: Christmas Party at the White House C. December 6: The Northwest Gate Incident
2. Ms. Lewinsky Returns to the White House 3. "Whatever Just Happened Didn't Happen" E. Second Jordan Meeting F. Early Morning Phone Call G. Job Interviews XII. December 19, 1997 - January 4, 1998: The Subpoena
B. December 22: Meeting with Vernon Jordan C. December 22: First Meeting with Francis Carter D. December 23: Clinton Denials to Paula Jones E. December 28: Final Meeting with the President E. December 28: Concealment of Gifts D. December 31: Breakfast with Vernon Jordan E. January 4: The Final Gift XIII. January 5-January 16, 1998: The Affidavit
B. January 5: Call from the President C. January 6: The Draft Affidavit D. January 7: Ms. Lewinsky Signs Affidavit E. January 8: The Perelman Call F. January 9: "Mission Accomplished" G. January 12: Pre-Trial Hearing in Jones Case H. January 13: References from the White House I. January 13: Final Jordan Meeting J. January 13-14: Lewinsky-Tripp Conversation and Talking Points K. January 15: The Isikoff Call L. January 15-16: Developments in the Jones Law Suit XIV. January 17, 1998-Present: The Deposition and Afterward
B. The President Meets with Ms. Currie C. January 18-19: Attempts to Reach Ms. Lewinsky D. January 20-22: Lewinsky Story Breaks | ||
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(2) He denied that he had a "sexual affair" with Monica Lewinsky (3) He denied that he had "sexual relations" with Monica Lewinsky (4) He denied that he engaged in or caused contact with the genitalia of "any person" with an intent to arouse or gratify (oral sex performed on him by Ms. Lewinsky) (5) He denied that he made contact with Monica Lewinsky's breasts or genitalia with an intent to arouse or gratify
2. Monica Lewinsky's Testimony
(ii) Friday, November 17, 1995 (iii) Sunday, December 31, 1995 (iv) Sunday, January 7, 1996 (v) Sunday, January 21, 1996 (vi) Sunday, February 4, 1996 (vii) Sunday, March 31, 1996 (viii) Sunday, April 7, 1996 (ix) Friday, February 28, 1997 (x) Saturday, March 29, 1997 (xi) Two Subsequent Meetings 4. Physical Evidence 5. Testimony of Ms. Lewinsky's Friends, Family Members, and Counselors
(ii) Neysa Erbland (iii) Natalie Rose Ungvari (iv) Ashley Raines (v) Andrew Bleiler (vi) Dr. Irene Kassorla (vii) Linda Tripp (viii) Debra Finerman (ix) Dale Young (x) Kathleen Estep II. There is substantial and credible information that President Clinton lied under oath to the grand jury about his sexual relationship with Monica Lewinsky. III. There is substantial and credible information that President Clinton lied under oath during his civil deposition when he stated that he could not recall being alone with Monica Lewinsky and when he minimized the number of gifts they had exchanged.
2. Evidence That Contradicts the President's Testimony 3. The President's Grand Jury Testimony 4. Summary
2. Evidence that Contradicts the President's Civil Deposition Testimony 3. President's Civil Deposition Testimony About Gifts from Monica Lewinsky to the President 4. Evidence that Contradicts the President's Testimony 5. Grand Jury Testimony of the President and Ms. Currie 6. Summary IV. There is substantial and credible information that the President lied under oath during his civil deposition concerning conversations he had with Monica Lewinsky about her involvement in the Jones case.
2. Evidence that Contradicts the President's Civil Deposition Testimony 3. Summary V. There is substantial and credible information that President Clinton endeavored to obstruct justice by engaging in a pattern of activity to conceal evidence regarding his relationship with Monica Lewinsky from the judicial process in the Jones case. The pattern included: VI. There is substantial and credible information that
(ii) President Clinton endeavored to obstruct justice by suggesting that Ms. Lewinsky file an affidavit so that she would not be deposed, she would not contradict his testimony, and he could attempt to avoid questions about Ms. Lewinsky at his deposition. B. Summary of President's Grand Jury Testimony C. Evidence Regarding Cover Stories D. The President's Grand Jury Testimony on Cover Stories E. Summary VII. There is substantial and credible information that President Clinton endeavored to obstruct justice by helping Ms. Lewinsky obtain a job in New York at a time when she would have been a witness against him were she to tell the truth during the Jones case. VIII. There is substantial and credible information that the President lied under oath in describing his conversations with Vernon Jordan about Ms. Lewinsky.
B. Evidence That Contradicts the President's Civil Deposition C. Summary IX. There is substantial and credible information that President Clinton endeavored to obstruct justice by attempting to influence the testimony of Betty Currie.
2. Sunday, January 18, 1998, Meeting with Ms. Currie 3. Conversation Between the President and Ms. Currie on Tuesday, January 20, 1998, or Wednesday, January 21, 1998. C. Summary X. There is substantial and credible information that President Clinton endeavored to obstruct justice during the federal grand jury investigation. While refusing to testify for seven months, he simultaneously lied to potential grand jury witnesses knowing that they would relay the falsehoods to the grand jury. XI. There is substantial and credible information that President Clinton's actions since January 17, 1998, regarding his relationship with Monica Lewinsky have been inconsistent with the President's constitutional duty to faithfully execute the laws.
B. The First Lady, the Cabinet, the President's staff, and the President's associates relied on and publicly emphasized the President's denial. C. The President repeatedly and unlawfully invoked the Executive Privilege to conceal evidence of his personal misconduct from the grand jury. D. The President refused six invitations to testify to the grand jury, thereby delaying expeditious resolution of this matter, and then refused to answer relevant questions before the grand jury when he testified in August 1998. E. The President misled the American people and the Congress in his public statement on August 17, 1998, when he stated that his answers at his civil deposition in January had been "legally accurate." F. Summary End Page
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