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Highlights from President Clinton's Deposition


Related Links
_ Full Text of Other Legal Documents

_ Full Coverage: Clinton Accused

_ In Deposition, Clinton Denied Initiating Lewinsky Aid (Washington Post, March 5)


Released on Friday, March 13, 1998

Following are highlights from Clinton's deposition in Paula Jones's sexual harassment suit on Jan. 17. Long excerpts of the deposition were released on March 13 by Paula Jones's lawyers, as part of their opposition to the Clinton legal team's Feb. 17 motion for summary judgement. Jones's lawyer James A. Fisher questioned the president. You can also read the related Post story or the full text of the the parts of the deposition that were made public.

Regarding Kathleen Willey

Editor's Note: Kathleen Willey and her husband, Edward E. Willey Jr., were prominent Democratic fund-raisers in Richmond. After President Clinton took office, she worked as a volunteer in the White House social office. On Nov. 29, 1993, she went to see Clinton about getting a full-time job because her husband's real estate business was nearing bankruptcy. According to Willey's sworn statements, Clinton made an uninvited sexual advance, kissing and groping her, in a secluded corridor just off the Oval Office. Unbeknownst to Clinton or Willey, her husband had committed suicide that afternoon.

Q. Mr. Clinton, do you know a woman named Kathleen Willey?

A. I do.

Q. When did you meet her for the first time?

A. I believe in the presidential campaign of 1992 in Virginia.

Q. She was married to a man named Edward E. Willey Jr., before he passed away, correct?

A. That's right.

Q. And she and her husband donated money to your presidential campaign in 1992, correct?

A. That's correct.

Q. And Kathleen Willey and her husband also did some fund-raising work for your campaign, correct?

A. I believe that's right. I'm not sure, but I think they did.

Q. If she were to describe herself as a Democratic party activist, would you disagree with that characterization of her?

A. No. I believe she was actually working very closely with Gov. Wilder in Virginia in 1992 at the time I was running for president.

Q. All right, sir. On election night in November 1992, did Kathleen Willey and her husband travel to Little Rock, Arkansas?

A. I have no idea.

Q. You don't recall seeing them in Little Rock that night?

A. No. But, you know, we stayed up late and there were hundreds, thousands of people there. I don't know whether they were there or not.

Q. Do you recall that after the election you personally called Kathleen Willey and, to thank her for helping you to be elected president?

A. No, I don't remember that.

Q. After you became president, she got a job working in the White House, correct?

A. I believe she worked in the social office. I seem to remember she started as a volunteer. I'm not sure, but I think she was a volunteer.

Q. All right, sir. Do you recall that she was living in Richmond, Virginia, at that time and commuting all the way to Washington?

A. Yeah, I knew that she and Ed lived in Richmond.

Q. Do you recall approximately when she was working in the White House as a volunteer?

A. No, I don't even – I don't know how many days a week she worked and what hours she worked.

Q. Have you read any part of the deposition testimony given by Kathleen Willey in this case?

A. No, but I have seen a summary of it.


_     _     _

Q. Mr. President, did Kathleen Willey ever give you permission to touch her breasts?

A. No, I never asked, and I never did.

Q. Did she ever give you permission to kiss her on the lips?

A. No.

Q. Did you ever attempt to kiss her on the lips?

A. No.

Q. Did you ever attempt to touch her breasts?

A. No.

Q. Did Kathleen Willey ever give you permission to take her hand and place it on your genitals?

A. No, she didn't.

Q. Did you at any time have any form of sexual relations with Kathleen Willey?

A. No, I didn't.

Q. Do you recall, sir, that you met with Kathleen Willey at or near the time of her husband's death?

A. The meeting I recall occurred before her husband's death. She had requested, my recollection is that she requested several times to come in to see me. She wanted to come in and see me, and kept asking to do that.

MR. [Robert] BENNETT [the president's attorney]: Mr. President, just answer his questions, please, sir.

A. And my – and she did come in to see me.

Q. Do you recall whether that particular meeting you just described was before or after her husband's death?

A. That was before her husband's death.

Q. All right, sir. What, if anything, do you recall being said in that meeting?

A. Well, my recollection is that she, that originally she wanted to come in to talk about moving out of the social office where she was not happy, but when she came in – that's what I had been told the meeting was about. But when she came in, she said that, and she also said that she probably needed a paying job, but she was, she was very upset that day, I remember very well, and she didn't stay long, but she was quite agitated, and that was the only meeting I had with her, and she said that she was faced, she was afraid that they, she'd have to contribute to the family income, and she wanted a job.

Q. All right, sir. If she testified that that meeting occurred at about three o'clock in the afternoon, would you have any different recollection?

A. I don't have – I don't remember what time of day it occurred. I just remember she came in and stayed a few minutes and talked to me about her problems.

Q. Was anyone else present in the room while you were talking to her?

A. I don't think so, no.

Q. And was this conversation in the Oval Office?

A. I think it was partly in the Oval Office and partly in the dining room I have in the back, which is – my memory is she was quite upset, I asked her if she wanted something to drink, she said she did, we went back there, she got something to drink, I got something to drink, and I let her sit down at the table in the dining room, and that, and we talked a little there. I can't remember how much time we spent at which place, but she wasn't there very long.

Q. Is there a hallway leading from the Oval Office to this private dining room?

A. Yes. It's very short. It's probably 12, 15 feet long.

Q. How wide is it?

A. Not wide.

Q. What did you have to drink?

A. I don't remember.

Q. Was it alcoholic?

A. Oh, no, no, I don't serve alcohol there in the office of the White House.


Q. Not ever?

A. Never.

Q. Did she tell you that she and her husband had some large debts to pay?

A. I don't remember that. What I remember is that she was very – she was obviously agitated, and I'd never really had a conversation with her before so I, you know, except in public, I'd see her, and she always seemed sort of shy, you know, upbeat, positive, but this day she was clearly concerned, but I don't remember going into any great detail. What I remember her saying is that her family, that there was some family financial issues she had to deal with, and she needed to earn some money to work there, and I had, I don't remember her going into any great detail about it. I don't think she stayed long enough to go into any great detail, but she was clearly upset.

Q. Do you recall, sir, that she said that one reason she was upset was that her husband was missing?

A. No, I didn't know anything about her husband being missing until I learned that, that he was dead.

Q. Do you recall how many days passed before you learned that he had passed away?

A. I don't. I don't think it was very long, but I don't remember.

Q. She took a leave of absence after her husband died, correct?

A. I don't know what she did. When I heard that he was dead and that he apparently killed himself, I called her and expressed my condolences and said that she could take whatever time she needed. It was a brief call, but I remember that call and I don't know exactly what she did, when she came back, or what the other facts are.

Q. Do you recall telling anyone in the White House that as soon as she did come back, you wanted to meet with her?

A. No, but I, I might well have said something like that, I mean, when something that traumatic happens in someone's family, I might have wanted to say something, I just had one of my speech writers' wife just had a stroke. When he came back to work, I said something to him. I might have done it, but I don't remember.

Q. So if someone in the White House testified that you told them you wanted to see Kathleen Willey as soon as she returned from her bereavement, you wouldn't find that implausible testimony?

A. It might well have happened. I just don't remember.

Q. All right. Having read a summary of her testimony, are you aware that she has testified that you kissed her in the hallway between the Oval Office and the private kitchen?

A. I am aware of that.

Q. And you're aware that she testified that you took her hand and put it on your penis?

A. I'm aware of that.

Q. All right, and you deny that testimony?

A. I emphatically deny it. It did not happen.

Q. Do you know why she would tell a story like that if it weren't true?

A. No, sir, I don't. I don't know. She'd been through a lot, and apparently the, the financial difficulties were even greater than she thought they were at the time she talked to me. Her husband killed himself, she's been through a terrible time. I have – I can't say. All I can tell you is, in the first place, when she came to see me she was clearly upset. I did to her what I have done to scores and scores of men and women who have worked for me or been my friends over the years. I embraced her, I put my arms around her, I may have even kissed her on the forehead. There was nothing sexual about it. I was trying to help her calm down and trying to reassure her. She was in difficult condition. But I have no idea why she said what she did, or whether she now believes that actually happened. She's been through a terrible, terrible time in her life, and I have nothing else to say. I don't want to speculate about it.

Q. Has she ever asked you to pay her money in return for her not disclosing this story?


A. Not to my knowledge.

Q. Do you recall at any time in that meeting with Kathleen Willey saying to her, "I wanted to do that for a long time"?

A. No, sir. Let me remind you, Kathleen Willey asked for this meeting with me. I didn't ask for the meeting with her. I didn't say anything like that.

Q. Do you recall meeting with her again in the Oval Office after she returned from her bereavement?

A. I remember that, it seems to me that she came in there once with a friend of hers who was sick, who had cancer, and we had a picture taken. I think you have a copy of that picture. She, she may have come in and said goodbye briefly and had another picture taken when she left, but that's all I remember.

Q. All right. Do you recall any conversation with her about obtaining a paying job after she returned from her absence?

A. I don't.

Q. I'm talking about the absence caused by her husband's death?

A. I understand. No, I don't. I don't know if one occurred. I don't remember one.

Q. Do you recall, though, that at some point she did receive a job that was a paid position at the White House?

A. Yes, I believe that she went to work in the counsel's office.

Q. What was the process by which she received that job?

A. I don't know the answer to that. After she came to see me, and she was, as I said, clearly quite agitated, when she walked out I said to someone, maybe it was Nancy Hernreich was there who knew her –

MR. BENNETT: Keep your voice up, Mr. President.


A. Maybe it was Nancy Hernreich who was there and who knew her, perhaps it was someone else, that we ought to see if we could do something for her, and that's all I heard about it. I don't think I was notified when she got the job at the counsel's office, and I'm not aware of what she did there exactly, but I know that she did get a job in the counsel's office, which she held for some time.

Q. Who in the White House would be responsible for receiving applications for that job and making the decision who would receive it?

A. I'm not sure. The – Bob Nash runs the appointments operation, but I'm not sure that it would have gone through him. It might have gone to the person, might have gone to someone in the administrative line, like a deputy chief of staff or someone like that. I really don't know. Perhaps we can find out for you, but I just don't know.

Q. Is Mr. Nash's title Director of Presidential Personnel?

A. I don't think so. I think his title is Director of Appointments. I honestly don't know what his direct title is, but when I deal with him, we're dealing with appointments to boards and commissions and things like that.

Q. All right.

A. Ambassadorships, Cabinet, subcabinet.

Q. Now, you appointed Kathleen Willey to travel to Copenhagen to serve on the official delegation of the United States of America at a world summit for social development, true?

A. She went as a White House appointee. I'm not sure I knew in advance of her going that she was on the delegation. I don't believe I did. But I don't have any reason to know one way or the other. I'm not sure I knew who was on that delegation.

Q. She did in fact attend that world summit in March of 1995, correct?

A. I don't know if she did, but it, it, if that's what the record reflects, then she did.

Q. And then –

A. I have no direct knowledge of that. I don't remember who went for the United States.

Q. Was she appointed to serve on the official delegation of the United States of America at a convention on biological diversity in Jakarta, Indonesia?

A. I don't have any direct knowledge of that. Since, in preparing for this deposition, I have been informed that she was, but I don't believe that I knew about it at the time she went.

Q. Do you know who made the decision to place her on that delegation?

A. I don't. She had – was this after she had left the White House?

Q. Yes, sir.

A. She had friends in the White House who may well have recommended her for it. I don't believe that I did, but I just, I don't know anything about that.

Q. Can you shed any light on the process by which she was selected to serve on the delegation?

A. No. I'm sure there's someone in the White House who put that delegation together who could do so, but I can't. I don't know.

Q. If you wanted to find out the answer to that question, who would you go ask?

A. I would ask either the, probably my deputy chief of staff, John Podesta, to find out. If it was a foreign trip, perhaps the, Mr. Nash. Katie McGinney, I don't know. But I have no idea how that particular delegation was put together.

Q. Are you aware that she was appointed to a position on the Board of Governors of the United Service Organizations Inc., also known as the USO?

A. I am now. When I was told about her, I do not remember appointing her, but that was a direct presidential appointment, so I assume at some point that I actually checked a piece of paper which had her name on it, perhaps some others, but I didn't remember it at the time until I learned it.

Q. That position on the USO Board of Governors has a three-year term, does it not?


A. I don't know. I make hundreds of those appointments and all those recommendations are put together by Mr. Nash. If I wanted to know why he was – literally in 90 percent, perhaps more, of the cases of all presidential appointments, they're sent to me on a piece of paper which says here's the appointment, here's the name of the person, and there's a brief description of the position and who has recommended the person and then accept or reject, and 90 percent of the time I just get the files and I look at the position and I check it off and go on, unless it's something that I know something about or care a great deal about. I just trust the staff to handle it, so I would have no idea why she was recommended or why she was appointed.

Q. Well, you would not check off someone's name approving the appointment if you had some reason to question the trustworthiness of the individual, would you?

A. No.

Q. And to your own knowledge, did Kathleen Willey have a reputation while working in the White House with respect to her character for truthfulness?

A. No. I only know, the only thing that, the only conversation I ever had with her that amounted to anything was this conversation which lasted about 10 minutes, maybe a little more, and I didn't doubt that she was telling the truth about what she was talking about, but I didn't know her well enough to draw a final conclusion about whether she was generally truthful or not.

Q. Was that the first conversation that you ever had with her?

A. I think it was the first – I mean I had talked to her in passing, you know. She was, as I said, she was in Virginia when I was there in the campaign, and I'd had conversations with her, but that's the first time I'd ever actually sat and talked with her, to the best of my knowledge. She was around when we did the presidential debate in Richmond. She was around that, you know, working in that, and I would talk to her, and she was always very friendly and very nice, but that conversation, I remember this conversation very vividly because she was so agitated and she seemed to be in very difficult straits.

Q. But you don't remember any earlier conversation other than just casual conversation?

A. Yeah, I'm sure I had casual conversation with her. I knew who she was and she was always there when we were there in Virginia.

Regarding Monica S. Lewinsky

Q. Now, do you know a woman named Monica Lewinsky?

A. I do.

Q. How do you know her?

A. She worked in the White House for a while, first as an intern, and then in, as the, in the legislative affairs office. . . . So that's how I know her.

Q. . . . Did she begin to work as an intern in the White House in the summer of 1995?

A. I don't know when she started working at the White House.

Q. Do you recall when you met her for the first time?

A. It would be sometime, I'd think, in later 1995. . . .

Q. Did you ever talk to anyone about the possibility of her obtaining a job in the White House?

A. She, she came there as an intern, and as several of them have, she applied for some job there apparently and got the job. I was not involved in her moving from being an intern to being a full-time employee. I had no involvement in that whatever. . . .

Q. Is it true that when she worked at the White House she met with you several times?


A. I don't know about several times. There was a period when the, when the Republican Congress shut the government down that the whole White House was being run by interns, and she was assigned to work back in the chief of staff's office, and we were all working there, and so I saw her on two or three occasions then, and then when she worked at the White House, I think there was one or two other times when she brought some documents to me. . . .

Q. Mr. President. . . . At any time were you and Monica Lewinsky alone together in the Oval Office?

A. I don't recall, but as I said, when she worked at the legislative affairs office, they always had somebody there on the weekends. I typically worked some on the weekends. Sometimes they'd bring me things on the weekends. She – it seems to me she brought things to me once or twice on the weekends. In that case, whatever time she would be in there, drop it off, exchange a few words and go, she was there. . . .

Q. Did it ever happen that you and she went down the hallway from the Oval Office to the private kitchen. . . .

A. Well, let me try to describe the facts first, because you keep talking about this private kitchen. The private kitchen is staffed by two naval aides. They have total, unrestricted access to my dining room, to that hallway, to coming into the Oval Office. The people who are in the outer office of the Oval Office can also enter at any time.

I was, after I went through a presidential campaign in which the far right tried to convince the American people I had committed murder, run drugs, slept in my mother's bed with four prostitutes, and done numerous other things, I had a high level of paranoia.

There are no curtains on the Oval Office, there are no curtains on my private office, there are no curtains or blinds that can close the windows in my private dining room. The naval aides come and go at will. There is a peephole on the office that George Stephanopoulos first and then Rahm Emanuel occupied that looks back down that corridor. I have done everything I could to avoid the kind of questions you are asking me here today, so to talk about this kitchen as if it is a private kitchen, it's a little cubbyhole, and these guys keep the door open. They come and go at will. Now that's the factual background here.

Now, to go back to your question, my recollection is that, that at some point during the government shutdown, when Ms. Lewinsky was still an intern but was working the chief staff's office because all the employees had to go home, that she was back there with a pizza that she brought to me and to others. I do not believe she was there alone, however. I don't think she was. And my recollection is that on a couple of occasions after that she was there but my secretary Betty Currie was there with her. . . .

Q. Have you ever met with Monica Lewinsky in the White House between the hours of midnight and six a.m.?

A. I certainly don't think so. . . . Now, let me just say, when she was working there, during, there may have been a time when we were all – we were up working late. There are lots of, on any given night, when the Congress is in session, there are always several people around until late in the night, but I don't have any memory of that. I just can't say that there could have been a time when that occurred, I just – but I don't remember it.

Q. Certainly if it happened, nothing remarkable would have occurred?

A. No, nothing remarkable. I don't remember it.

Q. It would be extraordinary, wouldn't it, for Betty Currie to be in the White House between midnight and six a.m., wouldn't it?

A. I don't know what the facts were. I mean I don't know. She's an extraordinary woman.

Q. Does that happen all the time, sir, or rarely?

A. Well, I don't know, because normally I'm not there between midnight and six, so I wouldn't know how many times she's there. Those are questions you'd have to ask her. I just can't say.

Q. Has it ever happened that a White House record was created that showed the Monica Lewinsky was meeting with Betty Currie when in fact Monica Lewinsky was meeting with you. . . .

A. Not to my knowledge.

Q. Are there records created of your meetings with people in the White House?


A. I believe we have a record of the people that, that see me. We have – I think there's a record of everybody that comes in and out of the White House. . . .

Q. When was the last time you spoke with Monica Lewinsky?

A. I'm trying to remember. Probably sometime before Christmas. She came by to see Betty sometime before Christmas. And she was there talking to her, and I stuck my head out, said hello to her.

Q. Stuck your head out of the Oval Office?

A. Uh-huh, Betty said she was coming by and talked to her, and I said hello to her.

Q. Was that shortly before Christmas or –

A. I'm sorry, I don't remember. Been sometime in December, I think, and I believe – that may not be the last time. I think she came to one of the, one of the Christmas parties.

Q. Did she tell you she had been served with a subpoena in this case?

A. No. I don't know if she had been.

Q. Did anyone other than your attorneys ever tell you that Monica Lewinsky had been served with a subpoena in this case?

A. I don't think so.

Q. Did you ever talk with Monica Lewinsky about the possibility that she might be asked to testify in this case?

A. Bruce Lindsey, I think Bruce Lindsey told me that she was, I think maybe that's the first person told me she was. I want to be as accurate as I can.

[Robert Bennett, the president's attorney]: Keep your voice up Mr. President.

Q. Did you talk to Mr. Lindsey about what action, if any, should be taken as a result of her being served with a subpoena?

A. No. . . .

Q. Have you ever talked to Monica Lewinsky about the possibility that she might be asked to testify in this lawsuit?

A. I'm not sure, and let me tell you why I'm not sure. It seems to me the, the, the – I want to be as accurate as I can here. Seems to me the last time she was there to see Betty before Christmas we were joking about how you-all, with the help of the Rutherford Institute, were going to call every woman I'd ever talked to, and I said, you know –

Bennett: We can't hear you, Mr. President.

A. And I said that you-all might call every woman I ever talked to and ask them that, and so I said you would qualify, or something like that. I don't, I don't think we ever had more of a conversation than that about it, but I might have mentioned something to her about it, because when I saw how long the witness list was, or I heard about it, before I saw, but actually by the time I saw it her name was in it, but I think that was after all this had happened. I might have said something like that, so I don't want to say for sure I didn't, because I might have said something like that. . . .

Q. What, if anything, did Monica Lewinsky say in response?

A. Nothing that I can remember. Whatever she said, I don't remember. Probably just some predictable thing. . . .

Q. Excluding conversations that you may have had with Mr. Bennett or any of your attorneys in this case, within the past two weeks has anyone reported to you that they had had a conversation with Monica Lewinsky concerning this lawsuit?

A. I don't believe so. I'm sorry, I just don't believe so.

Q. You know a man named Vernon Jordan?

A. I know him well.

Q. You've known him for a long time.

A. A long time.

Q. Has it ever been reported to you that he met with Monica Lewinsky and talked about this case?

A. I knew that 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. . . .

Q. What do you know about her moving to New York?

A. Just that.

Q. Is she going to move to New York?

A. I don't know. She may have already moved to New York. I don't know. My understanding was that her mother moved to New York and that she was going to move to New York and that she was looking for some advice about what she should do when she got there.

Q. Is it your understanding that she was offered a job at the U.N.?

A. I know that she interviewed for one. I don't know if she was offered one or not.

Q. Have You ever talked to [U.N. Ambassador] Bill Richardson about Monica Lewinsky?

A. No. . . .

Q. Have you ever asked anyone to talk to Bill Richardson about Monica Lewinsky?

A. I believe that, I believe that Monica, what I know about that is I believe Monica asked Betty Currie to ask someone to talk to him, and she, and she talked to him and went to an interview with him. That's what I believe happened. . . .

Q. Well, have you ever given any gifts to Monica Lewinsky?

A. I don't recall. Do you know what they were?

Q. A hat pin?

A. I don't, I don't remember. But I certainly, I could have.

Q. A book about Walt Whitman?

A. I give – let me just say, I give people a lot of gifts, and when people are around I give a lot of things I have at the White House away, so I could have given her a gift, but I don't remember a specific gift.

Q. Do you remember giving her a gold brooch?

A. No.

Q. Do you remember giving her an item that had been purchased from The Black Dog store at Martha's Vineyard?

A. I do remember that, because when I went on vacation, Betty said that, asked me if I was going to bring some stuff back from The Black Dog, and she said Monica loved, liked that stuff and would like to have a piece of it, and I did a lot of Christmas shopping from The Black Dog, and I bought a lot of things for a lot of people, and I gave Betty a couple of the pieces, and she gave I think something to Monica and something to some of the other girls who worked in the office. I remember that because Betty mentioned it to me. . . .

Q. Has Monica Lewinsky ever given you any gifts?

A. Once or twice. I think she's given me a book or two.

Q. Did she give you a silver cigar box?

A. No.

Q. Did she give you a tie?

A. Yes, she had given me a tie before. I believe that's right. . . .


Q. Did you have an extramarital sexual affair with Monica Lewinsky?

A. No.

Q. If she told someone that she had a sexual affair with you beginning in November of 1995, would that be a lie?

A. It's certainly not the truth. It would not be the truth.

Q. I think I used the term "sexual affair." And so the record is completely clear, have you ever had sexual relations with Monica Lewinsky, as that term is defined in Deposition Exhibit 1, as modified by the Court. . . .

A. I have never had sexual relations with Monica Lewinsky. I've never had an affair with her.

Q. Have you ever had a conversation with Vernon Jordan in which Monica Lewinsky was mentioned?

A. I have. He told me that he called – he mentioned in passing to me that he had talked to her, and she had come to him for advice about moving to New York. . . .

Q. What did he say that she had said to him in response?

A. He just said she seemed like a bright, energetic young woman and she had certain interests, and he made some suggestions to her and suggested where she ought to go for interviews. That's all I know about that. . . .

Q. Did you do anything, sir, to prompt this conversation to take place between Vernon Jordan and Monica Lewinsky?

A. I can tell you what my memory is. My memory is that Vernon said something to me about her coming in, Betty had called and asked if he would see her and he said she would, he said he would, and then she called him and then he said something to me about it. I'm sure if he said something to me about it I said something positive about it. I wouldn't have said anything negative about it. I didn't have any negative knowledge. I mean there would be no reason for me to be negative about it. Vernon liked to help people. He was always trying to help people.

Q. My question, though, is focused on the time before the conversation occurred, and the question is whether you did anything to cause the conversation to occur.

A. I think in the mean – I'm not sure how you mean the question. I think the way you mean the question, the answer to that is no, I've already testified. . . .

Q. Have you ever had a conversation with Vernon Jordan in which Paula Jones was mentioned?

A. I'm sure I have. I don't remember what it would have been, but I'm sure I have. I mean after all this time, I'm sure I have.

[Bill Bristow, attorney for Clinton co-defendant Danny Ferguson]: Your Honor, I just think we should note for the record that it is now almost 12:30, and to my knowledge this is the first moment in the deposition that the word "Paula Jones" has been mentioned. . . .

Q. Mr. President, have you ever paid any money to Monica Lewinsky?

A. No, sir.

Q. Have you ever caused money to be paid to her?

A. Absolutely not.

Q. Have you ever paid off any debt that she owed to some other person?

A. No, sir.

Q. Have you ever caused a debt that she owed to some other person to be repaid?

A. No, sir. . . .

© Copyright 1998 The Washington Post Company

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