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Justice during which he held the following positions: Acting Deputy Attorney General, Assistant Attorney General for the Criminal Division; and U.S. Attorney for the Eastern District of Pennsylvania. He is Co-Chairman of the Corporate Investigations and Criminal Defense Practice Group.

William W. Taylor, III, Esq: Mr. Taylor served as Chair of the Criminal Justice Section of the American Bar Association from 1996–97. In that capacity, he organized a task force chaired by former Attorney General Edwin Meese to study the federalization of state crime. From 1979–84, he served as a member of the District of Columbia Commission on Judicial Disabilities and Tenure, serving as its Chair for four years. He is a Fellow of the American College of Trial Lawyers, a member of The Fellows of the American Bar Foundation, and a member of the National Association of Criminal Defense Lawyers. Mr. Taylor is a 1966 graduate of the University of North Carolina and a 1969 graduate of Yale Law School. He clerked for the Honorable Caleb M. Wright, Chief Judge of the United States District Court for the District of Delaware.

Ronald Noble, Esq: Currently Mr. Noble is Associate Professor of Law at NYU Law School. He served as Undersecretary of the Treasury for Enforcement (1994–96); as Deputy Assistant Attorney General and Chief of Staff in the Criminal Division of the Department of Justice (1988–90); as Assistant United States Attorney in the Eastern District of Pennsylvania (1984–88).

1:00 p.m.-The Honorable Charles F.C. Ruff, Counsel to the President.

HOUSE OF REPRESENTATIVES,

COMMITTEE ON THE JUDICIARY,

Washington, DC, December 7, 1998. CHARLES F.C. RUFF, Esq., Counsel to the President. GREGORY B. CRAIG, Esq., Special Counsel to the President. The White House, Washington, DC.

DEAR MESSRS. RUFF AND CRAIG: The Committee is pleased to accommodate the proposed schedule of witnesses which was received from you this afternoon. While we would have in the normal course of business expected each witness to provide us with a written version of their statement prior to their testimony, we will not insist on it in this instance in light of the short notice of the identity of your witnesses.

Although the Committee had noticed its hearing for Tuesday, December 8 to begin at 9:00 a.m., so as to allow you a full 15 hours in which to present your case, we will instead begin at 10:00 at your request. It is nevertheless our intention to complete testimony by and questioning of all three panels you have proposed for December 8 that day.

The session will begin with brief opening statements by the Chairman and the Ranking Minority Member, after which we will hear from Mr. Craig. I understand that 15 minutes will be suffi

. cient for his testimony. The remaining witnesses from Panel 1 will be allowed 10 minutes each for their oral presentation. Following

their testimony, they and Mr. Craig will be available to Members of the Committee for questioning under the five minute rule.

As you have not sought to question the panels on behalf of the President, at the conclusion of questioning of Panel 1 we will move immediately to Panel 2 and then Panel 3, observing the same procedures of 10 minute witness presentations followed by questioning under the 5 minute rule. We do not intend to recess during the session.

In the interest of ensuring that the Committee can complete its questioning of the panel proposed for Wednesday, December 9, we have asked that you begin at 8:00 a.m. We await your response to this request In any event, testimony and questioning of that panel will follow the model established on Tuesday. As you did not provide us with information about an additional potential witness for this panel by the end of the business day today-as you requested in your letter-Panel 1 on Wednesday will be limited to the five witnesses described in the schedule attached to your earlier correspondence.

As you have acknowledged, it is imperative that Mr. Ruff begin his testimony making a presentation on behalf of the President by 1:00 p.m. on Wednesday in order to permit a full examination of the witness by the Committee and its counsel. The schedule that you have proposed and the Committee has accepted will meet that important deadline.

I look forward to hearing from you on behalf of the President beginning promptly tomorrow morning at 10:00 a.m. Sincerely,

THOMAS E. MOONEY, Chief of Staff-General Counsel.

D. THE COMMITTEE'S 81 REQUESTS TO THE PRESIDENT FOR ADMIS

SION, THE PRESIDENT'S RESPONSES, AND CITATIONS TO RELEVANT PARTS OF THE RECORD PROVIDED BY THE COMMITTEE'S MAJORITY STAFF

COMMITTEE ON THE JUDICIARY UNITED STATES HOUSE OF REP

RESENTATIVES INQUIRY OF IMPEACHMENT AUTHORIZED PURSUANT TO H. RES. 581—REQUESTS FOR ADMISSION OF WILLIAM J. CLINTON, PRESIDENT OF THE UNITED STATES AND RESPONSES TO THE REQUESTS FOR ADMISSION GIVEN BY THE PRESIDENT AND RELEVANT CITATIONS TO THE RECORD OF EVIDENCE AND LAW RELATED TO THE REQUESTS FOR ADMISSION AND THE RESPONSES THERETO

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

Answer. The President is frequently referred to as the chief law enforcement officer, although nothing in the Constitution specifically designates the President as such. Article II, Section 1 of the United States Constitution states that "[t]he executive Power shall be vested in a President of the United States of America," and the law enforcement function is a component of the executive power.

Reference. Article II, Section 3 of the U.S. Constitution states in part that the President shall “take Care that the Laws be faithfully executed.” Article II, Section 1, clause 1 of the Constitution vests the entire executive branch of government, which includes the United States Department of Justice, in the President. He authorizes, through the Attorney General, all prosecutions brought on behalf of the people of the United States in carrying out his constitutional duty to take care that the laws be faithfully executed.

Question 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?

Answer. At my Inauguration in 1993 and 1997, I took the following oath: “I do solemnly swear that I will faithfully execute the Office of President of the United States, and will to the best of my ability, preserve, protect and defend the Constitution of the United States."

Reference. Article II, Section 1, clause 8 of the U.S. constitution states that before the President enters on the execution of his office, he shall take, and William J. Clinton did take, the following oath or affirmation: “I do solemnly swear (or affirm) that I will faithfully execute the Office of President of the United States, and will to the best of my Ability, preserve, protect and defend the Constitution of the United States.

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

Answer. Article II, Section 3 (not Section 2), of the Constitution states that the President “shall take Care that the Laws be faithfully executed,” and that is a Presidential obligation.

Reference. Article II, Section 3 of the United States Constitution states in part that the President shall “take Care that the Laws be faithfully executed.”

Question 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?

Answer. I have an active license to practice law (inactive for continuing legal education purposes) issued by the Supreme Court of Arkansas. The license, No. 73017, was issued in 1973.

Reference. The Arkansas Rules of Court and Rules of Professional Conduct governing the actions of lawyers licensed to practice law in the State of Arkansas declare that it is professional misconduct for a lawyer to "commit a criminal act that reflects adversely on the lawyers honesty, trustworthiness or fitness as a lawyer in other respects; engage in conduct involving dishonesty, fraud, deceit or misrepresentation; or engage in conduct that is prejudicial to the administration of justice.(Arkansas Rules of Professional Conduct, Rule 8.4 (b-d)).

The comments following Rule 8.4 assert that “lawyers holding public office assume legal responsibilities going beyond those of other citizens. A lawyer's abuse of public office can suggest an inability to fulfill the professional role of attorney."

Furthermore, "Every attorney now or hereafter licensed to practice law in the State of Arkansas shall be a member of the bar of this State and subject to these procedures. The jurisdiction of the

Supreme Court Committee on Professional Conduct shall extend to lawyers on inactive or suspended status.” (Arkansas Procedures of the Court Regulating Professional Conduct of Attorneys at Law, Section 1 (A)).

Question 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?

Answer. I took an oath to tell the truth on January 17, 1998, before my deposition in the Jones v. Clinton case. While I do not recall the precise wording of that oath, as I previously stated in my grand jury testimony on August 17, 1998, in taking the oath “I believed then that I had to answer the questions truthfully." App. at 458.1

Reference. The record indicates that on January 17, 1998, before beginning to respond to questions during a deposition in a civil rights lawsuit in which he was a named defendant, the President answered in the affirmative to the question “Do you swear and affirm that your testimony will be the truth, the whole truth and nothing but the truth, so help you God?

Question 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?

Answer. As the August 17, 1998, videotape reflects, I was asked “Do you solemnly swear that the testimony you are about to give in this matter will be the truth, the whole truth, and nothing but the truth, so help you God?," and I answered, “I do.”

Reference. The record indicates that on August 17, 1998, before testifying before a grand jury empaneled by the United States District Court for the District of Columbia Circuit to investigate whether the President committed acts of perjury, subornation of perjury, obstruction of justice and witness tampering, President Clinton, having been called for examination by the Independent Counsel, answered in the affirmative to the question "Do you swear and affirm that your testimony will be the truth, the whole truth and nothing but the truth, so help you God?'

Question 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?

Answer. At some point I learned of Ms. Lewinsky's decision to seek suitable employment in New York. I do not recall receiving a letter in which she expressed dissatisfaction about her New York job search. I understand Ms. Lewinsky has stated that she sent a note indicating her decision to seek employment in New York, but I do not believe she has said the note expressed dissatisfaction

Citations to “App." refer to the Appendices to the Office of Independent Counsel Referral to the United States House of Representatives, as published by the House Judiciary Committee. Citations to "Supp." refer to the Supplemental Materials to the Office of Independent Counsel Referral, as published by the House Judiciary Committee. Citations to “Dep.” refer to my January 17, 1998, deposition testimony in the civil case, Jones v. Clinton, No. LR-C-94–290 (E.D. Ark.).

about her search for a job there. App. at 822–23 (grand jury testimony of Ms. Lewinsky).

Reference. The record indicates that on October 7, 1997, Ms. Lewinsky may have couriered a letter expressing dissatisfaction with her job search to the President. (H. Doc. 105–310, p. 181; see also Grand Jury Testimony of Monica Lewinsky, 8/6/98, pp. 102– 03, H. Doc. 105-311, p. 988).

Question 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?

Answer. I understand that Ms. Lewinsky testified that I called her on the 9th of October, 1997. App. at 823 (grand jury testimony of Ms. Lewinsky). I do not recall that particular telephone call.

Reference. The record indicates that “Lewinsky advised that on October 9 or 10, 1997, Clinton called her between 2:00 and 2:30 in the morning. Lewinsky advised she was asleep when Clinton called. The call lasted for approximately one and one half-hours. Lewinsky and Clinton had their biggest fight ever in this telephone conversation. Clinton said that if he had known how difficult it would be to bring Lewinsky back to the White House, he would have never let her be transferred in the first place. Clinton said he was obsessed with her career and wanted to help her. Clinton said he would get working on a job in New York for Lewinsky.” (7/31/ 98 OIC interview of Monica Lewinsky, pp. 10–11, H. Doc. 105–311, pp. 1460–61; see also Grand Jury Testimony of Monica Lewinsky, 8/6/98, p. 104, H. Doc. 105–311, p. 988).

Question 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?

Answer. At some point, Ms. Lewinsky either discussed with me or gave me a list of the kinds of jobs she was interested in, although I do not know whether it was on Saturday, October 11, 1997. Records included in the OIC Referral indicate that Ms. Lewinsky visited the White House on October 11, 1997, App. at 2594, and I may have seen her on that day.

I do not believe I suggested to Ms. Lewinsky that Mr. Jordan might be able to assist her in her job search, and I understand that Ms. Lewinsky has stated that she asked me if Mr. Jordan could assist her in finding a job in New York. App. at 1079 (grand jury testimony of Ms. Lewinsky); App. at 1393 (7/27/98 FBI Form 302 Interview of Ms. Lewinsky); App. at 1461-62 (7/31/98 FBI Form 302 Interview of Ms. Lewinsky).

I speak to Mr. Jordan often, and I understand that records included in the OIC Referral indicate that he telephoned me shortly after Ms. Lewinsky left the White House complex. Supp. at 1836, 1839. I understand that Mr. Jordan testified that he and I did not discuss Ms. Lewinsky during that call. Supp. at 1793–94 (grand jury testimony of Vernon Jordan).

Reference. The record indicates that on “October 11, 1997, at approximately 8:30 a.m., Currie called Lewinsky from the hospital and said Clinton wanted to see Lewinsky at approximately 9:00 a.m., at the White House. Currie told Lewinsky that Clinton had paged Currie to tell her to get in touch with Lewinsky. Lewinsky met alone with Clinton in the dining room.” (7/31/98 OIC interview

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