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As this plainly indicates, Ms. Lewinsky also testified that the efforts of Vernon Jordan to find her a job were not part of any scheme to obstruct justice or buy her testimony.

The decision by Mr. Starr to specifically exclude Ms. Lewinsky's exculpatory statements and express denials raises grave questions about the fundamental fairness of the Starr Referral. The OIC chose to print over 150 pages of gratuitous and graphic sexual detail but could not find space for a single sentence quoting Ms. Lewinsky's sworn testimony which directly undermines the central obstruction-of-justice allegations in the Referral, and, for that matter, the very basis of the Lewinsky investigation.

We have not yet had a chance to analyze properly the 3200 pages released yesterday by the Committee, but we think the OIC's failure to give a fair presentation of Ms. Lewinsky's testimony is indicative of the one-sided nature of the Referral, a document whose true goal was to embarrass the President and inflame the public. We hope that you and the other distinguished Members of your Committee will proceed with due caution and appropriate fairness as you move forward to review the materials of the OIC prosecutors have submitted.

We look forward to making additional submissions to the Committee as its review-and ours-proceed, Sincerely,

CHARLES F.C. RUFF,
Counsel to the President,

The White House, Wash

ington, DC. DAVID E. KENDALL, Williams & Connolly, Wash

ington, DC.

OCTOBER 2, 1998. Hon. HENRY J. HYDE, Chairman, House Judiciary Committee, 2110 Rayburn Office Bldg.,

Washington, DC. Hon. JOHN CONYERS, Jr., Ranking Minority Member, House Judiciary Committee, 2426 Ray

burn Office Bldg., Washington, DC. GENTLEMEN: At our meeting in Chairman Hyde's office on September 10, you invited us to submit our views on issues before the Committee as a result of the Starr Referral. Accordingly, we are transmitting to you herewith a Memorandum Regarding Standards for Impeachment. Sincerely,

CHARLES F.C. RUFF,
Counsel to the President,

The White House, Wash

ington, DC. DAVID E. KENDALL, Williams & Connolly, Wash

ington, DC.

THE WHITE HOUSE,

Washington, October 21, 1998. Hon. HENRY J. HYDE, Chairman, House Judiciary Committee. Ranking Member, House Judiciary Committee.

, Re Proposed Testimony from Constitutional Experts

GENTLEMEN: In our joint capacity as Counsel for President Clinton in the impeachment inquiry currently underway in the House Judiciary Committee, we are writing respectfully to request the Committee to schedule hearings—as its first order of business

on the meaning of Article II, Section 4. That provision sets forth the constitutional standards governing the impeachment of a President. We believe it is important for the full Committee to address the question of what those standards are, how those standards have evolved through our nation's history, and how those standards should be applied to the allegations and conduct at issue in the impeachment inquiry.

We are of course interested in moving these proceedings forward. To that end, we would suggest that the Committee schedule hearings to be completed during the week of November 9, and that the Committee take testimony from at least two panels of witnesses. One panel would be composed of constitutional scholars, experts and historians designated by the American Bar Association. A second panel would be composed of additional witnesses equally divided between the majority and the minority.

We respectfully submit that the evidence that we are proposing here is necessary and desirable to a full and fair record in the inquiry. We further suggest that the process will not be full and fair if such evidence is not included in the record. Very truly yours,

CHARLES F.C. RUFF,

Counsel to the President.
GREGORY B. CRAIG,
Special Counsel to the Presi-

dent.
DAVID E. KENDALL,
Personal Counsel to the

President.

THE WHITE HOUSE,

Washington, October 23, 1998. Hon. HENRY J. HYDE, Chairman, Committee on the Judiciary, House of Representatives,

Rayburn House Office Building, Washington, DC. DEAR CHAIRMAN HYDE: We write to follow up on our meeting with Committee counsel. We appreciate your courtesy and theirs in affording us the opportunity to present our views.

The issue of particular concern to us is the right of the President's counsel to participate in depositions and interviews of witnesses conducted by Committee counsel. When we raised this issue at our meeting, we were informed that, under the rules adopted by

the Committee, we would not be allowed to participate, at least in part because a similar request by President Nixon's counsel had been rejected. To our knowledge, no depositions were actually taken in 1974, and, thus, the issue became moot. In any event, even acknowledging that theoretical precedent, in the circumstances of this inquiry we believe that principles of elemental fairness mandate our participation.

Although the Committee's rules contemplate our being able to attend evidentiary hearings and to "question any witness before the Committee,” that right will prove utterly meaningless if the Committee's ultimate judgment is to be based on testimony taken outside the presence of both the Members and the President's counsel. This Committee, above all, needs no instruction in the basic principles of due process; nor does it need to be reminded of the importance our system of justice places on the right of a citizen to confront the witnesses against him-a right predicated on the belief that truth will emerge most clearly from the interplay of examination and cross-examination. We are certain that the commitment to fairness that you have so eloquently voiced will lead you to grant our request.

Committee counsel also raised with us their concern that the presence of the President's counsel would somehow "chill" the testimony of the witnesses, or at least those who are White House or executive branch employees. With all due respect, any such concern is baseless. We know of no evidence that any witnesses have been "chilled” or otherwise improperly influenced, and, in the absence of such evidence, it would be unfair to deprive the President of the most important right afforded any accused. Further, as you know, the relevant witnesses are represented by personal counsel and have already testified before the grand jury or been interviewed at length by the Independent Counsel.

This matter is of sufficiently grave import that we would ask for the opportunity to meet with you and to discuss our concerns before a decision is made. Sincerely,

CHARLES F.C. RUFF,

Counsel to the President.
GREGORY B. CRAIG,
Special Counsel to the Presi-

dent.
DAVID E. KENDALL,
Personal Counsel to the

President

U.S. HOUSE OF REPRESENTATIVES,

COMMITTEE ON THE JUDICIARY,

Washington, DC, November 5, 1998. Hon. WILLIAM JEFFERSON CLINTON, President of the United States, The White House, Washington, DC.

DEAR MR. PRESIDENT: I respectfully seek your cooperation in responding to the enclosed requests for admission in writing and under oath, utilizing the enclosed affidavit. The Committee is seeking this information in order to expedite the inquiry of impeachment authorized pursuant to House Resolution 581.

The enclosed requests for admission are for purposes of the inquiry of impeachment only and the responses you provide shall not be considered to have any bearing or effect on any subsequent or prospective action by the Executive or Judicial branches of the United States that may be related to this matter. Thank you for your cooperation. Sincerely,

HENRY J. HYDE,

Chairman.

COMMITTEE ON THE JUDICIARY, U.S. HOUSE OF REPRESENTATIVES REQUESTS FOR ADMISSION OF WILLIAM J. CLINTON PRESIDENT OF THE

UNITED STATES RELATING TO THE INQUIRY OF IMPEACHMENT AUTHORIZED PURSUANT TO H. RES. 581

1. Do you admit or deny that you are the chief law enforcement officer of the United States of America?

2. Do you admit or deny that upon taking your oath of office that you swore you would faithfully execute the office of President of the United States, and would to the best of your ability, preserve, protect and defend the Constitution of the United States?

3. Do you admit or deny that, pursuant to Article II, section 2 of the Constitution, you have a duty to "take care that the laws be faithfully executed?"

4. Do you admit or deny that you are a member of the bar and officer of the court of a state of the United States, subject to the rules of professional responsibility and ethics applicable to the bar of that state?

5. Do you admit or deny that you took an oath in which you swore or affirmed to tell the truth, the whole truth, and nothing but the truth, in a deposition conducted as part of a judicial proceeding in the case of Jones v. Clinton on January 17, 1998?

6. Do you admit or deny that you took an oath in which you swore or affirmed to tell the truth, the whole truth, and nothing but the truth, before a grand jury empaneled as part of a judicial proceeding by the United States District Court for the District of Columbia Circuit on August 17, 1998?

7. Do you admit or deny that on or about October 7, 1997, you received a letter composed by Monica Lewinsky in which she expressed dissatisfaction with her search for a job in New York?

8. Do you admit or deny that you telephoned Monica Lewinsky early in the morning on October 10, 1997, and offered to assist her in finding a job in New York?

9. Do you admit or deny that on or about October 11, 1997, you met with Monica Lewinsky in or about the Oval Office dining room?

10. Do you admit or deny that on or about October 11, 1997, Monica Lewinsky furnished to you, in or about the Oval Office dining room, a list of jobs in New York in which she was interested?

11. Do you admit or deny that on or about October 11, 1997, you suggested to Monica Lewinsky that Vernon Jordan may be able to assist her in her job search?

12. Do you admit or deny that on or about October 11, 1997, after meeting with Monica Lewinsky and discussing her search for a job in New York, you telephoned Vernon Jordan?

13. Do you admit or deny that you discussed with Monica Lewinsky prior to December 17, 1997, a plan in which she would pretend to bring you papers with a work-related purpose, when in fact such papers had no work-related purpose, in order to conceal your relationship?

14. Do you admit or deny that you discussed with Monica Lewinsky prior to December 17, 1997, that Betty Currie should be the one to clear Ms. Lewinsky in to see you so that Ms. Lewinsky could say that she was visiting with Ms. Currie instead of with you?

15. Do you admit or deny that you discussed with Monica Lewinsky prior to December 17, 1997, that if either of you were questioned about the existence of your relationship you would deny its existence?

16. Do you admit or deny that on or about December 6, 1997, you learned that Monica Lewinsky's name was on a witness list in the case of Jones v. Clinton?

17. Do you admit or deny that on or about December 17, 1997, you told Monica Lewinsky that her name was on the witness list in the case of Jones v. Clinton?

18. Do you admit or deny that on or about December 17, 1997, you suggested to Monica Lewinsky that the submission of an affidavit in the case of Jones v. Clinton might suffice to prevent her from having to testify personally in that case?

19. Do you admit or deny that on or about December 17, 1997, you suggested to Monica Lewinsky that she could say to anyone inquiring about her relationship with you that her visits to the Oval Office were for the purpose of visiting with Betty Currie or to deliver papers to you?

20. Do you admit or deny that you gave false and misleading testimony under oath when you stated during your deposition in the case of Jones v. Clinton on January 17, 1998, that you did not know if Monica Lewinsky had been subpoenaed to testify in that case?

21. Do you admit or deny that you gave false and misleading testimony under oath when you stated before the grand jury on August 17, 1998, that you did know prior to January 17, 1998, that Monica Lewinsky had been subpoenaed to testify in the case of Jones v. Clinton?

22. Do you admit or deny that on or about December 28, 1997, you had a discussion with Monica Lewinsky at the White House regarding her moving to New York?

23. Do you admit or deny that on or about December 28, 1997, you had a discussion with Monica Lewinsky at the White House in which you suggested to her that she move to New York soon because by moving to New York, the lawyers representing Paula Jones in the case of Jones v. Clinton may not contact her?

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