The following material was submitted by independent counsel Kenneth Starr with his report to the House on President Clinton. This document provided by Federal News Service. Editor's Note: Some of the language in these documents is sexually explicit.

Q: Mr. President, if your intent was, as you have earlier testified, that you didn't want anybody to know about this relationship you had with Ms. Lewinsky, why would you feel comfortable giving her gifts in the middle of discovery in the Paula Jones case?

PRESIDENT CLINTON: Well, sir, for one thing, there was no existing improper relationship at that time. I had, for nearly a year, done my best to be a friend to Ms. Lewinsky, to be a counselor to her, to give her good advice, and to help her. She had, for her part, most of the time, accepted the changed circumstances. She talked to me a lot about her life, her job ambitions, and she continued to give me gifts. And I felt that it was a right thing to do to give her gifts back.

I have always given a lot of people gifts. I have always been given gifts. I do not think there is anything improper about a man giving a woman a gift, or a woman giving a man a gift, that necessarily connotes an improper relationship. So, it didn't bother me.

I wasn't – you know, this was December 28th. was – I gave her some gifts. I wasn't worried about it. thought it was an all right thing to do.

Q: What about notes and letters, cards, letters and notes to Ms. Lewinsky? After this relationship, this inappropriate intimate relationship between you and Ms. Lewinsky ended, she continued to send you numerous intimate notes and cards, is that right?

PRESIDENT CLINTON: Well, they were – some of them were, were somewhat intimate. I'd say most of them, most of the notes and cards were, were affectionate all right, but, but she had clearly accepted the fact that there could be no contact between us that was in any way inappropriate.

Now, she, she sent cards sometimes that were just funny, even a little bit off-color, but they were funny. She liked to send me cards, and I got a lot of those cards; several, anyway, I don't know a lot. I got a few.

Q: She professed her love to you in these cards after the end of the relationship, didn't she?

PRESIDENT CLINTON: Well, –

Q: She said she loved you?

PRESIDENT CLINTON: Sir, the truth is that most of the time, even when she was expressing her feelings for me in affectionate terms, I believed that she had accepted, understood my decision to stop this inappropriate contact. She knew from the very beginning of our relationship that I was apprehensive about it. And I think that in a way she felt a little freer to be affectionate, because she knew that nothing else was going happen. I can't explain entirely what was in her mind.

But most of these messages were not what you would call over the top. They weren't things that, if you read them. you would say, oh, my goodness, these people are having some sort of sexual affair.

Q: Mr. President, the question –

PRESIDENT CLINTON: But some of them were quite affectionate.

Q: My question was, did she or did she not profess her love to you in those cards and letters that she sent to you after the relationship ended?

PRESIDENT CLINTON: Most of them were signed, "Love", you know, "Love, Monica" I don't know that I would consider – I don't believe that in most of these cards and letters she professed her love, but she might well have. I – but, you know; love can mean different things, too, Mr. Bittman. I have – there are a lot of women with whom I have never had any inappropriate conduct who are friends of mine, who will say from time to time, I love you. And I know that they don't mean anything wrong by that.

Q: Specifically, Mr. President, do you remember a card she sent you after she saw the movie Titanic, in which she said that she reminisced or dreamed about the romantic feelings that occurred in the movie, and how that reminded her of you two? Do you remember that?

PRESIDENT CLINTON: No, sir, but she could have sent it. I – just because I don't remember it doesn't mean it wasn't there.

Q: You're not denying that, that –

PRESIDENT CLINTON: Oh, no. I wouldn't deny that. I just don't remember it. You asked me if I remembered. I don't. She might have done it.

Q: Do you ever remember telling her, Mr. President, that she should not write some of the things that she does in those cards and letters that she sends to you because it reveals, if disclosed, this relationship that you had, and that she shouldn't do it?

PRESIDENT CLINTON: 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. I don't remember.

Q: Embarrassing, in that it was revealing of the intimate relationship that you and she had, is that right?

PRESIDENT CLINTON: I do not know when I said this. So, I don't know whether we did have any sort of inappropriate relationship at the time I said that to her. I don't remember. But it's obvious that if she wrote things that she should not have written down and someone else read it, that it would be embarrassing.

Q: She certainly sent you something like that after the relationship began, didn't she? And so, therefore, there was, at the time she sent it, something inappropriate going on?

PRESIDENT CLINTON: Well, my recollection is that she – that maybe because of changed circumstances in her own life in 1997, after there was no more inappropriate contact, that she sent me more things in the mail, and that there was sort of a disconnect sometimes between what she was saying and the plain facts of our relationship. And I don't know what caused that. But it may have been dissatisfaction with the rest of her life. I don't know. You know, she had, from the time I first met her, talked to me about the rest of her personal life, and it may be that there was some reason for that. It may be that when I did the right thing and made it stick, that in a way she felt a need to cling more closely, or try to get closer to me, even though she knew nothing improper was happening or was going to happen. I don't know the answer to that.

Q: After you gave her the gifts on December 28th, did you speak with your secretary, Ms. Currie, and ask her to pick up a box of gifts that were some compilation of gifts that Ms. Lewinsky would have –

PRESIDENT CLINTON: No, sir, I didn't do that.

Q: – to give to Ms. Currie?

PRESIDENT CLINTON: I did not do that.

Q: When you testified in the Paula Jones case, this was only two and a half weeks after you had given her these six gifts, you were asked, at page 75 in your deposition, lines 2 through 5, "Well, have you ever given any gifts to Monica Lewinsky?" And you answer, "I don't recall." And you were correct. You pointed out that you actually asked them, for prompting, "Do you know what they were?"

PRESIDENT CLINTON: I think what I meant there was – don't recall what they were, not that I don't recall whether I had given them. And then if you see, they did give me these specifics, and I gave them quite a good explanation here. I remembered very clearly what the facts were about The Black Dog. And I said that I could have given her a hat pin and a Walt Whitman book; that I did not remember giving her a gold broach, which was true. I didn't remember it. I may have given it to her, but I didn't remember giving her one. They didn't ask me about the, about the Christmas gifts, and I don't know why I didn't think to say anything about them. But I have to tell you again, I even invited them to have a list. It was obvious to me by this point in the definition, in this deposition, that they had, these people had access to a lot of information from somewhere, and I presume it came from Linda Tripp. And I had no interest in not answering their questions about these gifts. I do not believe that gifts are incriminating, nor do I think they are wrong, I think it was a good thing to do. I'm not, I'm still not sorry I gave Monica Lewinsky gifts.

Q: Why did you assume that that information came from Linda Tripp?

PRESIDENT CLINTON: I didn't then.

Q: Well, you didn't? I thought you just testified you did then?

PRESIDENT CLINTON: No, no, no. I said I now assume that because –

PRESIDENT CLINTON: – of all of the subsequent events. I didn't know. I just knew that –

Q: Let me ask you about –

PRESIDENT CLINTON: – that somebody had access to some information and they may have known more about this than I did.

Q: Let me ask you about the meeting you had with Betty Currie at the White House on Sunday, January 18 of this year, the day after your deposition. First of all, you didn't – Mrs. Currie, your secretary of six-some years, you never allowed her, did you, to watch whatever intimate activity you did with Ms. Lewinsky, did you?

PRESIDENT CLINTON: No, sir, not to my knowledge.

Q: And as far as you know, she couldn't hear anything either, is that right?

PRESIDENT CLINTON: There were a couple of times when Monica was there when I asked Betty to be places where she could hear, because Monica was upset and I – this was after there was – all the inappropriate contact had been terminated.

Q: No, I'm talking –

PRESIDENT CLINTON: But –

Q: – about the times that you actually had the intimate contact.

PRESIDENT CLINTON: She was – I believe that – well, first of all, on that one occasion in 1997, I do not know whether Betty was in the White House after the radio address in the Oval Office complex. I believe she probably was, but I'm not sure. But I'm certain that someone was there. I always – always someone was there. In 1996, I think most of the times that Ms. Lewinsky was there, there may not have been anybody around except maybe coming in and out, but not permanently so. I – that's correct. I never – I didn't try to involve Betty in that in any way.

Q: Well, not only did you not try to involve her, you specifically tried to exclude her and everyone else, isn't that right?

PRESIDENT CLINTON: Well, yes. I've never – I mean, it's almost humorous, sir. I'd, I'd, I'd have to be an exhibitionist not to have tried to exclude everyone else.

Q: So, if Ms. Currie testified that you approached her on the 18th, or you spoke with her and you said, you were always there when she was there, she wasn't, was she? That is, Mrs. Currie?

PRESIDENT CLINTON: She was always there in the white House, and I was concerned – let me back up and say –

Q: What about the radio address, Mr. President?

PRESIDENT CLINTON: Let me back a second, Mr. Bittman. I knew about the radio address. I was sick after it was over and I, I was pleased at that time that it had been nearly a year since any inappropriate contact had occurred with Ms. Lewinsky.

I promised myself it wasn't going to happen again. The facts are complicated about what did happen and how it happened. But, nonetheless, I'm responsible for it. On that night, she didn't.

I was more concerned about the times after that when Ms. Lewinsky was upset, and I wanted to establish at least that I had not – because these questions were – some of them were off the wall. Some of them were way out of line, I thought.

And what I wanted to establish was 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. And what I did not know was – I did not know that. And I was trying to figure out, and I was trying to figure out in a hurry because I knew something was up.

Q: So, you wanted –

PRESIDENT CLINTON: After that deposition.

Q: – to check her memory for what she remembered, and that is –

PRESIDENT CLINTON: That's correct.

Q: – whether she remembered nothing, or whether she remembered an inappropriate intimate –

PRESIDENT CLINTON: Oh, no, no, no, no.

Q: – relationship?

PRESIDENT CLINTON: No. I didn't ask her about it in that way. I asked her about what the – what I was trying to determine was whether my recollection was right and that she was always in the office complex when Monica was there, and whether she thought she could hear any conversations we had, or did she hear any.

And then I asked her specifically about a couple of times when – once when I asked her to remain in the dining room, Betty, while I met with Monica in my study. And once when I took Monica in the, the small office Nancy Hernreich occupies right next to Betty's and talked to her there for a few minutes. That's my recollection of that.

I was trying to – I knew, Mr. Bittman, to a reasonable certainty that I was going to be asked more questions about this. I didn't really expect you to be in the Jones case at the time. I thought what would happen is that it would break in the press, and I was trying to get the

facts down. I was trying to understand what the facts were.

Q: If Ms. Currie testified that these were not really questions to her, that they were more like statements, is that not true?

PRESIDENT CLINTON: Well, I can't testify as to what her perception was. I can tell you this. I was trying to get information in a hurry. I was downloading what I remembered. I think Ms. Currie would also testify that I explicitly told her, once I realized that you were involved in the Jones case – you, the Office of Independent Counsel – and that she might have to be called as a witness, that she should just go in there and tell the truth, tell what she knew, and be perfectly truthful.

So, I was not trying to get Betty Currie to say something that was untruthful. I was trying to get as much information as quickly as I could.

Q: What information were you trying to get from her when you said, I was never alone with her, right?

PRESIDENT CLINTON: I don't remember exactly what I did say with her. That's what you say I said.

Q: If Ms. Currie testified to that, if she says you told her, I was never alone with her, right?

PRESIDENT CLINTON: Well, I was never alone with her –

Q: Did you not say that, Mr. President?

PRESIDENT CLINTON: Mr. Bittman, just a minute. I was never alone with her, right, might be a question. And what £ might have meant by that is, in the Oval Office complex.

Could –

Q: Well, you knew the answer to that, didn't you?

PRESIDENT CLINTON: We've been going for more than an hour. Would you mind if we took a break? I need to go to the restroom.

MR. BITTMAN: Let's take a break.

MR. KENDALL: It's 2:38.

(Whereupon, the proceedings were recessed from 2:38 until 2:48 p.m.)

MR. KENDALL: It is 2:38 – sorry, 2:48.

BY MR. WISENBERG:

Q: Mr. President, I want to, before I go into a new subject area, briefly go over something you were talking about with Mr. Bittman. The statement of your attorney, Mr. Bennett, at Paula Jones deposition, "Counsel is fully aware" – it's page 54, line 5 – "Counsel is fully aware that Ms. Lewinsky has filed, has an affidavit which they are in possession of saying that there is absolutely no sex of any kind in any manner, shape or form, with President Clinton". That statement is made by your attorney in front Judge Susan Webber Wright, correct?

PRESIDENT CLINTON: That's correct.

Q: That statement is a completely false statement.

Whether or not Mr. Bennett knew of your relationship with Ms. Lewinsky, the statement that there was "no sex of any kind in any manner, shape or form, with President Clinton," was an utterly false statement. Is that correct?

PRESIDENT CLINTON: It depends on what the meaning of the word "is" is. If the – if he – if "is" means is and never has been that is not – that is one thing. If it means there is none, that was a completely true statement. But, as I have testified, and I'd like to testify again, this is – it is somewhat unusual for a client to be asked about his lawyer's statements, instead of the other way around. I was not paying a great deal of attention to this exchange. I was focusing on my own testimony. And if you go back and look at the sequence of this, you will see that the Jones lawyers decided that this was going to be the Lewinsky deposition, not the Jones deposition. And, given the facts of their case, I can understand why they made that decision. But that is not how I prepared for it. That is not how I was thinking about it. And I am not sure, Mr. Wisenberg, as I sit here today, that I sat there and followed all these interchanges between the lawyers. I'm quite sure that I didn't follow all the interchanges between the lawyers all that carefully. And I don't really believe, therefore, that I can say Mr. Bennett's testimony or statement is testimony and is imputable to me. I didn't – I don't know that I was even paying that much attention to it.

Q: You told us you were very well prepared for the deposition.

PRESIDENT CLINTON: No. I said I was very well prepared to talk about Paula Jones and to talk about Kathleen Willey, because she had made a related charge. She was the only person that I think I was asked about who had anything to do with anything that would remotely approximate sexual harassment. The rest of this looked to me like it was more of a way to harass me.

Q: You are the President of the United States and your attorney tells a United States District Court Judge that there is no sex of any kind, in any way, shape or form, whatsoever. And you feel no obligation to do anything about that at that deposition, Mr. President?

PRESIDENT CLINTON: I have told you, Mr. Wisenberg, I will tell you for a third time. I am not even sure that when Mr. Bennett made that statement that I was concentrating on the exact words he used. Now, if someone had asked me on that day, are you having any kind of sexual relations with Ms. Lewinsky, that is, asked me a question in the present tense, I would have said no. And it would have been completely true.

Q: Was Mr. Bennett aware of this tense-based distinction you are making now –

PRESIDENT CLINTON: I don't –

MR. KENDALL: I'm going to object to any questions about communications with private counsel.

MR. WISENBERG: Well, the witness has already testified, I think, that Mr. Bennett didn't know about the inappropriate relationship with Ms. Lewinsky. I guess –

PRESIDENT CLINTON: Well, you'll have to ask him that, you know. He was not a sworn witness and I was not paying that close attention to what he was saying, i've told you that repeatedly. I was – I don't – I never even focused on that until I read it in this transcript in preparation for this testimony. When I was in there, I didn't think about my lawyers. I was, frankly, thinking about myself and my testimony and trying to answer the questions.

BY MR. WISENBERG:

Q: I just want to make sure I understand, Mr. President. Do you mean today that because you were not engaging in sexual activity with Ms. Lewinsky during the deposition that the statement of Mr. Bennett might be literally true?

PRESIDENT CLINTON: No, sir. I mean that at the time of the deposition, it had been – that was well beyond any point of improper contact between me and Ms. Lewinsky. So that anyone generally speaking in the present tense, saying there is not an improper relationship, would be telling the truth if that person said there was not, in the present tense; the present tense encompassing many months. That's what I meant by that.

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