of Monica Lewinsky, p. 11, H. Doc. 105-311, p. 1461; see also Grand Jury Testimony of Monica Lewinsky, 8/6/98, p. 104, H. Doc. 105-311, p. 988.)

Question 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?

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, 1977, 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, 1998, President Clinton instructed Monica Lewinsky to draft a list of jobs in which she was interested:

"Question. At some point, did you send the President something like a list of jobs or interests that you might have in New York? Answer. Yes. He asked me to prepare that on the 11th of October."

(Grand Jury Testimony of Monica Lewinsky, 8/6/98, pp. 103-104, H. Doc. 105-311, p. 988).

"Lewinsky advised that Clinton asked her to write a list of potential employers, or jobs she was interested in, and to give it to him. On October 16, 1997, Lewinsky sent Clinton the list, which she refers to as a "wish list."" (8/13/98 OIC interview of Monica Lewinsky, p. 3, H. Doc. 105-311, p. 1545).

Question 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?

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, 1977, 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 the President agreed to ask Vernon Jordan to assist Monica Lewinsky in her job search:

"Question. What do you have in mind about the first time Vernon Jordan's name would have come up in conversations with the President?

Answer. It was either in that phone call or [at the meeting] on October 11th.

Question. And tell us what was said about Vernon Jordan, whether it was in the phone call or on the 11th.

Answer. I don't remember. I know that I had discussed with Linda and either I had thought or she had suggested that Vernon Jordan would be a good person who is a close friend of the President and who has a lot of contacts in New York, so that he might be someone who might be able to help me procure a position in New York, if I didn't want to go to the U.N.

Question. And what was the President's response?

Answer. I think that was a good idea." (Grand Jury Testimony of Monica Lewinsky, 8/6/98, pp. 103-104, H. Doc. 105-311, p. 988) "Following this conversation, Ms. Lewinsky requested of the Pres. that he ask Vernon Jordan to help secure her a non-governmental position in NY. He agreed to ask Mr. Jordan." (2/1/98 Handwritten proffer of Monica Lewinsky, H. Doc. 105-311, p. 710; see also H. Doc. 105–311, p. 1212.)

Question 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?

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, 1977, 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 10:57 a.m., after meeting with Monica Lewinsky beginning at 9:00 a.m., President Clinton took a phone call from Vernon Jordan. (Presidential call log, H. Doc. 105-311, p. 2829.)

Question 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?

Answer. I was asked essentially these same questions by OIC lawyers. I testified that Ms. Lewinsky and I "may have talked about what to do in a non-legal context at some point in the past, but I have no specific memory of that conversation." App. at 569. That continues to be my recollection today—that is, any such conversation was not in connection with her status as a witness in the Jones v. Clinton case.

Reference. The record indicates that such a plan existed. Monica Lewinsky provided the following testimony under oath regarding this subject:

"Question. I would like to ask you some questions about any steps you took to keep your relationship with the President secret. Answer. A lot.

Question. All right. Well, why don't we just ask the question open-endedly and we'll follow up.

Answer. Okay. I'm sure, as everyone can imagine, that this is a kind of relationship that you keep quiet, and we both wanted to be careful being in the White House. Whenever I would visit him during-when-during my tenure at the White House, we always-unless it was sort of a chance meeting on the weekend and then we ended up back in the office, we would usually plan that I would either bring papers, or one time we had accidentally bumped into each other in the hall and went from that way, so then we planned to do that again because that seemed to work well. But we always there was always some sort of a cover.

Question. When you say you planned to bring papers, did you ever discuss with the President the fact that you would try to use that as a cover?

Answer. Yes.

Question. Okay. What did the two of you say in those conversations?

Answer. I don't remember exactly. I mean, in general, it might have been something like me saying, well, maybe once I got there kind of saying, "Oh, gee here are your letters," wink, wink, wink, and him saying: "Okay that's good," or

Question. And as part of this concealment, if you will, did you carry around papers when you went to visit the President while you worked at Legislative Affairs?

Answer. Yes, I did.

Question. Did you ever actually bring him papers to sign as part of business?

Answer. No.

Question. Did you actually bring him papers at all?

Answer. Yes.

Question. All right. And tell us a little about that.

Answer. It varied. Sometimes it was just actual copies of letters. One time I wrote a really stupid poem. Sometimes I put gifts in the folder which I brought.

Question. And even on those occasions, was there a legitimate business purpose to that?

Answer. No." (Grand Jury Testimony of Monica Lewinsky, 8/6/98, pp. 53-55, H. Doc. 105-311, p. 977.)

President Clinton gave the following testimony under oath in his deposition the case of Jones v. Clinton regarding the subject:

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

Answer. I don't know about several times. There was a period 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.' (Deposition of President Clinton, 1/17/98, pp. 50-51 (released in news accounts)).

Question 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?

Answer. I was asked essentially these same questions by OIC lawyers. I testified that Ms. Lewinsky and I "may have talked about what to do in a non-legal context at some point in the past, but I have no specific memory of that conversation." App. at 569. That continues to be my recollection today—that is, any such conversation was not in connection with her status as a witness in the Jones v. Clinton case.

Reference. The record indicates the President had such discussions with Monica Lewinsky prior to December 17, 1997. Monica Lewinsky provided the following testimony under oath regarding this subject:

"Question. Did you ever [prior to your conversation with the President on December 17] have discussions with the President about what you would say about your frequent visits with him after you had left legislative affairs?

Answer. Yes.

Question. Yes. What was that about?

Answer. I think we we discussed that-you know, the backwards route of it was that Betty always needed to be the one to clear me in so that, you know, I could always say I was coming to see Betty." (Grand Jury Testimony of Monica Lewinsky, 8/6/98, p. 55, H. Doc. 105-311, p. 977.)

President Clinton was asked about this subject during his deposition on January 17, 1998:

"Question. Has it ever happened that a White House record was created that reflected that Betty Currie was meeting with Monica Lewinsky when in fact you were meeting with Monica Lewinsky? Answer. Not to my knowledge." (Deposition Testimony of President Clinton in the case of Jones v. Clinton, 1/17/98).

Question 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?

Answer. I was asked essentially these same questions by OIC lawyers. I testified that Ms. Lewinsky and I "may have talked about what to do in a non-legal context at some point in the past, but I have no specific memory of that conversation." App. at 569. That continues to be my recollection today-that is, any such conversation was not in connection with her status as a witness in the Jones v. Clinton case.

Reference. The record indicates that such an agreement to deny existed between the President and Monica Lewinsky:

"Question. Had you talked with [the President] earlier [than December 17] about * * * false explanations about what you were doing visiting him on several occasions?

Answer. Several occasions throughout the entire relationship. *** It was the pattern of the relationship to sort of conceal it." (Grand Jury Testimony of Monica Lewinsky, 8/6/98, p. 124, H. Doc. 105-311, p. 844).

Question 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?

Answer. As I stated in my August 17th grand jury testimony, I believe that I found out that Ms. Lewinsky's name was on a witness list in the Jones v. Clinton case late in the afternoon on the 6th of December, 1997. App. at 535.

Reference. The record indicates that according to the President's sworn testimony, he had such knowledge:

"Question. *** [W]hen did you find out that Monica's name was on that witness list?

"Answer. I believe that I found out late in the afternoon on the 6th." (Grand Jury Testimony of President Clinton, 8/17/98, p. 83, H. Doc. 105-311, p. 535).

Question 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?

* *

Answer. As I previously testified, I recall telephoning Ms. Lewinsky to tell her Ms. Currie's brother had died, and that call was in the middle of December. App. at 567. I do not recall other particulars of such a call including whether we discussed the fact that her name was on the Jones v. Clinton witness list. As I stated in my August 17th grand jury testimony in response to essentially the same questions, it is "quite possible that that happened. * I don't have any memory of it, but I certainly wouldn't dispute that I might have said that [she was on the witness list]." App. at 567. I recall that Ms. Lewinsky asked me at some time in December whether she might be able to get out of testifying in the Jones v. Clinton case because she knew nothing about Ms. Jones or the case. I told her I believed other witnesses had executed affidavits, and there was a chance they would not have to testify. As I stated in my August 17th grand jury testimony, "I felt strongly that * * * [Ms. Lewinsky] could execute an affidavit that would be factually truthful, that might get her out of having to testify." App. at 571.