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and always protect him. The President would respond "that's good” or similar language of encouragement.

When President Clinton called Ms. Lewinsky to tell her she was on the witness list, he made sure to remind her of those prior cover stories. Ms. Lewinsky testified that when he brought up the misleading story, she understood that the two would continue their pre-existing pattern of deception. President Clinton had no intention of making his sexual relationship with Ms. Lewinsky a public affair. He would use lies, deceit, and deception to ensure that the truth would not be known.

When the President was asked by the grand jury whether he remembered calling Monica Lewinsky at 2:00 a.m., he responded: “No sir, I don't. But it would—it is quite possible that that happened ..." Clinton 8/17/98 GJT at 116. When he was asked whether he encouraged Ms. Lewinsky to continue the cover stories of "coming to see Betty” or “bringing the letters," he answered: “I don't remember exactly what I told her that night." Clinton 8/17/98 GJT at 117.

Six days earlier, he had become aware that Ms. Jones's lawyers were now able to inquire about other women. Ms. Lewinsky could file a false affidavit, but it might not work. It was absolutely essential that both parties tell the same story. He knew that he would lie if asked about Ms. Lewinsky; and he wanted to make certain that she would lie also.

But President Clinton had an additional problem. It was not enough that he and Ms. Lewinsky simply deny the relationship. The evidence was accumulating. And the evidence was driving the President to reevaluate his defense. By this time, the evidence was establishing, through records and eyewitness accounts, that President Clinton and Ms. Lewinsky were spending a significant amount of time together in the Oval Office complex. The unassailable facts were forcing President Clinton to acknowledge the relationship. But at this point, he still had the opportunity to establish an explanation for their meetings that did not reveal the sexual relationship. He still had this opportunity because his DNA had not yet been identified on Ms. Lewinsky's blue dress. For that reason, President Clinton needed Ms. Lewinsky to go along with the cover story to provide an innocent explanation for their frequent meetings. And that innocent explanation came in the form of “document deliveries” and “friendly chats with Betty Currie.”

When the President was deposed on January 17, 1998, he used the exact same cover stories that Ms. Lewinsky had used. In doing so, he maintained consistency with any future Lewinsky testimony while also maintaining his defense in the Jones lawsuit. In his deposition, he was asked whether he was ever alone with Ms. Lewinsky. He responded: "I don't recall ... Sheit 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." Clinton 1/17/98 Dep. at 52–53 (emphasis added).

Additionally, whenever questions were posed regarding Ms. Lewinsky's frequent visits to the Oval Office, President Clinton never hesitated to bring Betty Currie's name into his answers:

So, he mainame cover stories deposed on Jan

was asing his defensth any future y had htten responded: whether he the Jones lawsn

A. And my recollection is that on a couple of occasions after [the pizza party meeting), she was there [in the oval

office] but my secretary, Betty Currie, was there with her. Clinton 1/17/98 Dep. at 58.

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. Clinton 1/17/98 Dep. at 68. Or in another example:

Q. Mr. President, before the break, we were talking about Monica Lewinsky. At any time were you and Monica Lewinsky together alone 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. I don't have any specific recollections of what the issues were, what was going on, but when the Congress is there, we're working all the time, and typically I would do some work on one of the day of the weekends in the afternoon.

Q. So I understand, your testimony is that it was possible, then, that you were alone with her, but you have no specific recollection of that ever happening?

A. Yes, that's correct. It's possible that she, in, while she was working there, brought something to me and that at the time she brought it to me, she was the only person there. That's possible.

Q. At any time were you and Monica Lewinsky alone in the hallway between the Oval Office and this kitchen area?

A. I don't believe so, unless we were walking back to the back dining room with the pizza. I just, I don't remember. I don't believe we were alone in the hallway, no.

Q. At any time have you and Monica Lewinsky ever been alone together in any room in the White House?

A. I think I testified to that earlier. I think that there is a, it is—I have no specific recollection, but it seems to me that she was on duty on a couple of occasions working for the legislative affairs office and brought me some things to sign, something on the weekend. That's—I have a general memory of that.

Q. Do you remember anything that was said in any of those meetings?

A. No. You know, we just have conversation, I don't remember. Clinton 1/17/98 Dep. at 52-53, 58–59.

etiad been dan called extremis, office


SUBPOENA President Clinton and Ms. Lewinsky realized their greatest fears on December 19, 1997, when Ms. Lewinsky received a subpoena to testify in a deposition on January 23, 1998 in the Jones case. Lewinsky 8/6/98 GJT at 128. It also called for her to produce gifts given to her by President Clinton, including a hat pin. Extremely distraught, she immediately called Mr. Jordan. Ms. Lewinsky testified that President Clinton previously told her to call Ms. Currie if she were subpoenaed. She called Mr. Jordan instead because Ms. Currie's brother recently died, and Ms. Lewinsky did not want to bother her. Lewinsky 8/6/98 GJT at 128–29.

Mr. Jordan invited Ms. Lewinsky to his office and she arrived shortly before 5 p.m. She was still extremely distraught. Sometime around this time, Mr. Jordan called President Clinton and told him Ms. Lewinsky had been subpoenaed. Jordan 5/5/98 GJT at 145. During the meeting with Ms. Lewinsky, which Mr. Jordan characterized as “disturbing," she talked about her infatuation with President Clinton. Jordan 3/3/98 GJT at 100, 150. Mr. Jordan also decided that he would call a lawyer for her. Jordan 3/3/98 GJT at 161. That evening, Mr. Jordan met with President Clinton and relayed his conversation with Ms. Lewinsky. The details are important because President Clinton, in his deposition, testified that he did not recall that meeting.

Mr. Jordan told President Clinton again that Ms. Lewinsky had been subpoenaed, that he was concerned about her fascination with President Clinton, and that Ms. Lewinsky had asked Mr. Jordan if he thought President Clinton would leave the First Lady. He also asked President Clinton if he had sexual relations with Ms. Lewinsky. Jordan 3/3/98 GJT at 169. President Clinton was asked:

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. Clinton 1/17/98 Dep. at 68–69.

In the grand jury, President Clinton first repeated his denial that Mr. Jordan told him Ms. Lewinsky had been subpoenaed. Clinton 8/17/98 GJT at 39. Then, when given more specific facts, he admitted that he "knows now” that he spoke with Mr. Jordan about the subpoena on the night of December 19, but his “memory is not clear.” Clinton 8/17/98 GJT at 41-42. In an attempt to explain away his false deposition testimony, the President testified in the grand jury that he was trying to remember who told him first. Clinton 8/17/98 GJT at 41. But that was not the question. So his answer was again false and misleading. When one considers the nature of the conversation between President Clinton and Mr. Jordan, the suggestion that President Clinton forgot it defies common sense.


GIFTS December 28, 1997 is a crucial date because the evidence shows that President Clinton made false and misleading statements to the federal court, the federal grand jury and the Congress of the United States about the events on that date. He also continued his course of obstructing justice.

President Clinton testified that it was “possible” that he invited Ms. Lewinsky to the White House for a visit on this date. Clinton 8/17/98 GJT at 34. He admitted that he "probably” gave Ms. Lewinsky the most gifts he had ever given her on that date and that he had given her gifts on other occasions. Clinton 8/17/98 GJT at 35. Among the many gifts the President gave Ms. Lewinsky on December 28 was a bear that he said was a symbol of strength. Clinton 8/17/98 GJT at 176. Yet on January 17, just three weeks later, the President forgot that he had given any gifts to Monica:

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

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 could have.
Clinton 1/17/98 Dep. at 75.

As an attorney, he knew that the law will not tolerate someone who says “I don't recall” when that answer is unreasonable under the circumstances. He also knew that, under those circumstances, his answer in the deposition could not be believed. When asked in the grand jury why he was unable to remember, though he had given Ms. Lewinsky so many gifts only three weeks before the deposition, the President gave a contrived explanation:

A. I think what I meant there was I don't recall what they were, not that I don't recall whether I had given

them. Clinton 8/17/98 GJT at 51.

President Clinton adopted that same answer in Response No. 42 to the Committee's Requests for Admissions. He was not asked in the deposition to identify the gifts. He was simply asked, "Have you ever” given gifts to Ms. Lewinsky. The law does not allow a witness to insert “unstated premises” or mental reservations into the question to make his answer technically true, if factually false. The essence of lying is in deception, not in words.

His false testimony with respect to gifts also extends to whether Ms. Lewinsky gave him gifts. President Clinton was asked in the deposition if Ms. Lewinsky ever gave him gifts.

Q. Has Monica Lewinsky ever given you any gifts?

A. Once or twice. I think she's given me a book or two. Clinton 1/17/98 Dep. at 7677.

This is also false testimony. He answered this question in his Response Number 43 to the Committee by saying that he receives numerous gifts, and he did not focus on the precise number. The law again does not support the President's position. An answer that “baldly understates a numerical fact” in “response to a specific

Learn why position cow th

Cliphis is also false testimony, mittee by saying that meher. The i

quantitative inquiry" can be deemed "technically true” but actually false. For example, a witness is testifying falsely if he says he went to the store five times when in fact he had gone fifty, even though technically he had gone five times also. So too, when the President answered once or twice in the face of evidence that Ms. Lewinsky brought him 40 gifts, he was lying.

On December 28, one of the most blatant efforts to obstruct justice and conceal evidence occurred. Ms. Lewinsky testified that she discussed with President Clinton her having been subpuenaed and the subpoena's calling for her to produce gifts. She recalled telling him that the subpoena requested a hat pin and that that caused her concern. Lewinsky 8/6798 GJT at 151-52. He told her that it "bothered” him, too. Lewinsky 8/20/98 GJT at 66. Ms. Lewinsky then suggested that she take the gifts somewhere, or give them to someone, possibly Ms. Currie. The President answered: “I don't know” or “Let me think about that.” Lewinsky 8/6/98 GJT at 15253. Later that day, Ms. Lewinsky got a call from Ms. Currie, who said: “I understand you have something to give me” or “the President said you have something to give me.” Lewinsky 8/6/98 GJT at 154–55. Ms. Currie has an unclear memory about this incident, but says that “the best she can remember,” Ms. Lewinsky called her. Currie 5/6/98 GJT at 105. Key evidence shows that Ms. Currie's unclear recollection is wrong. Ms. Lewinsky said that she thought Ms. Currie called from her cell phone. Lewinsky 8/6/98 GJT at 154–55. Ms. Currie's cell phone record corroborates Ms. Lewinsky and proves conclusively that Ms. Currie called Ms. Lewinsky from her cell phone several hours after she had left the White House. The evidence strongly suggests that President Clinton directed her to do so.

Ms. Currie's actions buttress that conclusion. There is no evidence that she asked why Ms. Lewinsky would have called her for this strange task. Rather, she simply took the gifts and placed them under her bed without asking a single question. Currie 1/27/ 98 GJT at 57-58, 5/6/98 GJT at 105–08, 114.

President Clinton stated in his Response to Requests for Admissions No. 24 and 25 from this Committee that he was not concerned about the gifts. In fact, he said that he recalled telling Ms. Lewinsky that if the Jones lawyers request gifts, she should turn them over. He testified that he is “not sure" if he knew the subpoena asked for gifts. Clinton 8/17/98 GJT at 42–43. There would be no reason for Ms. Lewinsky and President Clinton to discuss turning over gifts to the Jones lawyers if Ms. Lewinsky had not told him that the subpoena asked for gifts.

On the other hand, knowing the subpoena requested gifts, his giving Ms. Lewinsky more gifts on December 28 seems odd. But Ms. Lewinsky's testimony reveals why he did so. She said that she never questioned “that we were ever going to do anything but keep this private” and that meant to take "whatever appropriate steps needed to be taken” to keep it quiet. Lewinsky 8/6/98 GJT at 166. The only logical inference is that the gifts—including the bear symbolizing strength-were a tacit reminder to Ms. Lewinsky that they would deny the relationship-even in the face of a federal subpoena.

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