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"As I recollect, I said Monica Lewinsky's going to work for Revlon and his response was thank you very much." (Grand Jury Testimony of Vernon Jordan, 5/28/98, p. 59, H. Doc. 105-316, p. 1903). Question 38. Do you admit or deny that between January 9, 1998, and January 15, 1998, you had a conversation with Erskine Bowles in the Oval Office in which you stated that Monica Lewinsky received a job offer and had listed John Hilley as a reference?

Answer. As I testified to the grand jury, I recall at some point talking to Mr. Bowles "about whether Monica Lewinsky could get a recommendation that was not negative from the Legislative Affairs Office," or that "was at least neutral," although I am not certain of the date of the conversation. App. at 562-64. To suggest that I told Mr. Bowles that Ms. Lewinsky had received a job offer and had listed John Hilley as a reference is, as I testified, a "little bit" inconsistent with my memory. App. at 564. It is possible, as I also indicated, that she had identified Mr. Hilley as her supervisor on her resume and in that respect had already listed him as a reference. Ibid.

Reference. The record indicates that such a conversation occurred:

"[S]he [Monica Lewinsky] had found a job in the private sector, and that she had listed John Hilley as a reference, and could we see if he could recommend her, if asked." (Grand Jury Testimony of Erskine Bowles, 4/2/98, p. 78, H. Doc. 105–316, p. 238).

Question 39. Do you admit or deny that you asked Erskine Bowles if he would ask John Hilley to give Ms. Lewinsky a positive job recommendation?

Answer. As I testified to the grand jury, I recall at some point talking to Mr. Bowles "about whether Monica Lewinsky could get a recommendation that was not negative from the Legislative Affairs Office," or that "was at least neutral," although I am not certain of the date of the conversation. App. at 562-64. To suggest that I told Mr. Bowles that Ms. Lewinsky had received a job offer and had listed John Hilley as a reference is, as I testified, a “little bit" inconsistent with my memory. App. at 564. It is possible, as I also indicated, that she had identified Mr. Hilley as her supervisor on her resume and in that respect had already listed him as a reference. Ibid.

Reference. The record indicates that the President asked Erskine Bowles if he would ask Mr. Hilley to give Monica Lewinsky a positive job recommendation. See Request for Admission No. 38 (H. Doc. 105-316, p. 238).

Question 40. Do you admit or deny that during your deposition in the case of Jones v. Clinton on January 17, 1998, you affirmed that the facts or assertions stated in the affidavit executed by Monica Lewinsky on January 7, 1998, were true?

Answer. I was asked at my deposition in January about two paragraphs of Ms. Lewinsky's affidavit. With respect to Paragraph 6, I explained the extent to which I was able to attest to its accuracy. Dep. At 202-03.

With respect to Paragraph 8, I stated in my deposition that it was true. Dep. At 204. In my August 17th grand jury testimony, I sought to explain the basis for that deposition answer: "I believe

at the time that she filled out this affidavit, if she believed that the definition of sexual relationship was two people having intercourse, then this is accurate." App. at 473.

Reference. The record indicates that the President, under oath, affirmed that the assertions made in Monica Lewinsky's affidavit were true, even though he knew they were false. During the January 17, 1998 deposition of President Clinton in the case of Jones v. Clinton, Robert Bennett, the President's attorney, read parts of the affidavit Monica Lewinsky had executed in the case of Jones v. Clinton. At one point Mr. Bennett read part of paragraph eight of Monica Lewinsky's affidavit, in which Monica Lewinsky asserts, "I have never had a sexual relationship with the President, he did not propose that we have a sexual relationship, he did not offer me employment or other benefits in exchange for a sexual relationship, he did not deny me employment or other benefits for reflecting a sexual relationship.

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After reading from the affidavit out loud, Mr. Bennett asked the President: "Is that a true and accurate statement as far as you know it?" The President answered, "That is absolutely true." (Deposition of President Clinton in the case of Jones v. Clinton, 1/17/98, p. 204 (as released in public sources)).

Question 41. As to each, do you admit or deny that you gave the following gifts to Monica Lewinsky at any time in the past? a. A lithograph

b. A hatpin

c. A large "Black Dog" canvas bag

d. A large "Rockettes" blanket

e. A pin of the New York skyline

f. A box of "cherry chocolates'

g. A pair of novelty sunglasses

h. A stuffed animal from the "Black Dog'

i. A marble bear's head j

j. A London pin

k. A shamrock pin

1. An Annie Lennox compact disc

m. Davidoff cigars

Answer. In my deposition in the Jones case, I testified that I "certainly . . . could have" given Ms. Lewinsky a hat pin and that I gave her "something" from the Black Dog. Dep. at 75-76. In my grand jury testimony, I indicated that in late December 1997, I gave Ms. Lewinsky a Canadian marble bear's head carving, a Rockettes blanket, some kind of pin, and a bag (perhaps from the Black Dog) to hold these objects. App. at 484-487. I also stated that I might have given her such gifts as a box of candy and sunglasses, although I did not recall doing so, and I specifically testified that I had given Ms. Lewinsky gifts on other occasions. App. at 487. I do not remember giving her the other gifts listed in Question 41, although I might have. As I have previously testified, I receive a very large number of gifts from many different people, sometimes several at a time. I also give a very large number of gifts. I gave Ms. Lewinsky gifts, some of which I remember and some of which I do not.

Reference. The record indicates that the President did present each of these items as gifts to Monica Lewinsky.

A chart prepared as part of her testimony before the Grand Jury details Monica Lewinsky's visits to the President and the exchange of gifts during those visits is contained in H. Doc. 105-311, pp. 1251-61.

Question 42. Do you admit or deny that when asked on January 17, 1998, in your deposition in the case of Jones v. Clinton if you had ever given gifts to Monica Lewinsky, you stated that you did not recall, even though you actually had knowledge of giving her gifts in addition to gifts from the "Black Dog?'

Answer. In my grand jury testimony, I was asked about this same statement. I explained that my full response was "I don't recall. Do you know what they were?" By that answer, I did not mean to suggest that I did not recall giving gifts; rather, I meant that I did not recall what the gifts were, and I asked for reminders. See App. at 502-03.

Reference. The record indicates that the President stated that he did not recall even though he had knowledge:

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

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

A I don't, I don't remember. But I certainly, I could have." (Deposition of President Clinton in the case of Jones v. Clinton, 1/17/98, p. 75 (as released in public sources). See also request for admission number 41 for evidence of numerous gifts Mr. Clinton gave to Ms. Lewinsky.)

Furthermore, the evidence shows that President Clinton and Monica Lewinsky discussed the hat pin gift on December 28, 1997, after Ms. Lewinsky received a subpoena calling for her to produce all gifts she received from Mr. Clinton, including any hat pins. Ms. Lewinsky stated under oath before the grand jury that "I mentioned that I had been concerned about the hat pin being on the subpoena and he said that that had sort of concerned him also and asked me if I had told anyone that he had given me the hat pin and I said no." (Grand Jury Testimony of Monica Lewinsky, 8/6/98, p. 152, H. Doc. 105- 311, p. 1000).

Question 43. Do you admit or deny that you gave false and misleading testimony under oath in your deposition in the case of Jones v. Clinton when you responded "once or twice" to the question "has Monica Lewinsky ever given you any gifts?"

Answer. My testimony was not false and misleading. As I have testified previously, I give and receive numerous gifts. Before my January 17, 1998, deposition, I had not focused on the precise number of gifts Ms. Lewinsky had given me. App. at 495-98. My deposition testimony made clear that Ms. Lewinsky had given me gifts; at the deposition, I recalled "a book or two" and a tie. Dep. at 77. At the time, those were the gifts I recalled. In response to OIC inquiries, after I had had a chance to search my memory and refresh my recollection, I was able to be more responsive. However, as my counsel have informed the OIC, in light of the very large number of gifts I receive, there might still be gifts from Ms. Lewinsky that I have not identified.

Reference. The record indicates that the President gave such false and misleading testimony:

"Question. Has Monica Lewinsky ever given you any gifts? Answer. Once or twice. I think she's given me a book or two. (Deposition of President Clinton in the case of Jones v. Clinton, 1/ 17/98, p. 76 (as released in public sources)).

The evidence shows that Ms. Lewinsky gave the President approximately 38 gifts presented on numerous occasions. (See chart in House Document 105-311 pp. 1251-61.)

Question 44. Do you admit or deny that on January 17, 1998, at or about 5:38 p.m., after the conclusion of your deposition in the case of Jones v. Clinton, you telephoned Vernon Jordan at his

home?

Answer. I speak to Mr. Jordan frequently, so I cannot remember specific times and dates. According to White House records included in the OIC Referral, I telephoned Mr. Jordan's residence on January 17, 1998, at or about 5:38 p.m. App. at 2876.

Reference. The record indicates that such a telephone call was made. See Telephone Table 46, Call 2, as referenced in 5/28/98 Grand Jury Testimony of Vernon Jordan, pp. 94-95, as cited in Note 1022, H. Doc. 105-310, p. 118.

Question 45. Do you admit or deny that on January 17, 1998, at or about 7:02 p.m., after the conclusion of your deposition in the case of Jones v. Clinton, you telephoned Betty Currie at her home? Answer. According to White House records included in the OIC Referral, I placed a telephone call to Ms. Currie at her residence at 7:02 p.m. and spoke to her at or about 7:13 p.m. App. at 2877. I recall that when I spoke to her that evening, I asked if she could meet with me the following day. According to White House records included in the OIC Referral, I telephoned Mr. Jordan's office on January 17, 1998, at or about 7:02 p.m. Ibid.

Reference. The record indicates that such a telephone call was made. See Telephone Table 46, Call 4, as referenced in 1/27/98 Grand Jury testimony of Betty Currie, pp. 65-66, and all that follows, as cited in Note 1021, H. Doc. 105-310, p. 118.

Question 46. Do you admit or deny that on January 17, 1998, at or about 7:02 p.m., after the conclusion of your deposition in the case of Jones v. Clinton, you telephoned Vernon Jordan at his office?

Answer. According to White House records included in the OIC Referral, I placed a telephone call to Ms. Currie at her residence at 7:02 p.m. and spoke to her at or about 7:13 p.m. App. at 2877. I recall that when I spoke to her that evening, I asked if she could meet with me the following day. According to White House records included in the OIC Referral, I telephoned Mr. Jordan's office on January 17, 1998, at or about 7:02 p.m. Ibid.

Reference. The record indicates that such a telephone call was made. See Request for Admission No. 44, referencing the "second conversation" between Mr. Jordan and the President, as noted on p. 95 of the 5/28/98 Grand Jury testimony of Vernon Jordan, H. Doc. 105-316, p. 1912.

Question 47. Do you admit or deny that on January 17, 1998, at or about 7:13 p.m., after the conclusion of your deposition in the case of Jones v. Clinton, you telephoned Betty Currie at her home and asked her to meet with you the next day, Sunday, January 18, 1998?

Answer. According to White House records included in the OIC Referral, I placed a telephone call to Ms. Currie at her residence at 7:02 p.m. and spoke to her at or about 7:13 p.m. App. at 2877. I recall that when I spoke to her that evening, I asked if she could meet with me the following day. According to White House records included in the OIC Referral, I telephoned Mr. Jordan's office on January 17, 1998, at or about 7:02 p.m. Ibid.

Reference. The record indicates that such a telephone conversation occurred:

"The best that I can remember of a call, the President called, just said that he wanted to talk to me. And I said, 'Fine.' He said, 'Could you come in on Sunday?' And I said, 'Fine."" (Grand Jury Testimony of Betty Currie, 1/27/98, p. 66, H. Doc. 105-316, p. 558; For corroborative evidence, including phone log references, see Note 1021, H. Doc. 105-310, p. 118.)

Question 48. Do you admit or deny that on January 18, 1998, at or about 6:11 a.m., you learned of the existence of tapes of conversations between Monica Lewinsky and Linda Tripp recorded by Linda Tripp?

Answer. I did not know on January 18, 1998 that tapes existed of conversations between Ms. Lewinsky and Ms. Tripp recorded by Ms. Tripp. At some point on Sunday, January 18, 1998, I knew about the Drudge Report. I understand that, while the Report talked about tapes of phone conversations, it did not identify Ms. Lewinsky by name and did not mention Ms. Tripp at all. The Report did not state who the parties to the conversations were or who taped the conversations.

Reference. The record indicates that the President learned of the existence of the tapes early in the morning. The "Drudge Report", which discussed the tapes, was available on the Internet at 6:11

a.m.

"Question. Mr. President, when did you learn about the Drudge Report reporting allegations of you having a sexual relationship with someone at the White House?

Answer. I believe it was the morning of the 18th, I think . . . Question. Very early morning hours, sir?

Answer. *** yeah, I think it was when I got up Sunday morning, I think. Maybe it was late Saturday night. I don't remember." (Grand Jury Testimony of President Clinton, 8/17/98, pp. 142–43, H. Doc. 105-311, pp. 594-95).

This was confirmed by Vernon Jordan during his testimony about a meeting he had with the President on January 19, 1998: "Answer. *** He obviously knew about the Drudge Report, it did not require any lengthy discussion.

Question. Well, when you say he obviously knew about the Drudge Report, how do you know he knew about the Drudge Report?

Answer. He acknowledged in some way that he knew about the Drudge Report and I think it's fair to say he was as surprised at this Drudge Report that reported that there had been these taped conversations with this person named Linda Tripp." (Grand Jury Testimony of Vernon Jordan, 3/5/98, p. 126, H. Doc. 105–316, p.

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