Question 49. Do you admit or deny that on January 18, 1998, at or about 12:50 p.m., you telephoned Vernon Jordan at his home? Answer. According to White House records included in the OIC Referral, I telephoned Mr. Jordan's residence on January 18, 1998, at or about 12:50 p.m. App. at 2878.

Reference. The record indicates that such a telephone call was made. See Telephone Table 47, Call 2, as referenced on p. 174 of H. Doc. 105-311.

Question 50. Do you admit or deny that on January 18, 1998, at or about 1:11 p.m., you telephoned Betty Currie at her home?

Answer. According to White House records included in the OIC Referral, I telephoned Ms. Currie's residence on January 18, 1998, at or about 1:11 p.m. App. at 2878.

Reference. The record indicates that such a telephone call was made. See Telephone Table 47, Call 3, as referenced on p. 174 of H. Doc. 105-311.

Question 51. Do you admit or deny that on January 18, 1998, at or about 2:55 p.m., you received a telephone call from Vernon Jordan?

Answer. According to White House records included in the OIC Referral, Mr. Jordan telephoned me from his residence on January 18, 1998, at or about 2:55 p.m. App. at 2879.

Reference. The record indicates that such a telephone call was made. See Telephone Table 47, Call 5, as referenced on p. 174 of H. Doc. 105-311.

Question 52. Do you admit or deny that on January 18, 1998, at or about 5:00 p.m., you had a meeting with Betty Currie at which you made statements similar to any of the following regarding your relationship with Monica Lewinsky?

a. "You were always there when she was there, right? We were never really alone."

b. "You could see and hear everything."

c. "Monica came on to me, and I never touched her right?' d. "She wanted to have sex with me and I couldn't do that.” Answer. When I met with Ms. Currie, I believe that I asked her certain questions, in an effort to get as much information as quickly as I could, and made certain statements, although I do not remember exactly what I said. See App. at 508.

Some time later, I learned that the Office of Independent Counsel was involved and that Ms. Currie was going to have to testify before the grand jury. After learning this, I stated in my grand jury testimony, I told Ms. Currie, "Just relax, go in there and tell the truth." App. at 591.

Reference. The record indicates that the President made statements similar to these to Betty Currie on January 18, 1998 at a meeting held around 5:00 p.m.:

Question. Is that what you remember him saying?

Answer. Could you do the second point again—the

video

Question. Okay. The second-the videotape

Answer. She was over at the White House, and then she was alone.

Question. Right. That those were among the issues the President brought to your attention when he initially came to your desk?

Answer. The best I remember it, yes, sir.

Question. Okay. And then you told us that the President began to ask you a series of questions that were more like statements than questions.

Answer. Right.

Question. And you were nodding your head correct; is that right?

Answer. That's correct, sir.

Question. Okay. So the President asked you or made a series of statements to you; is that correct?

Answer. That's correct, sir.

Question. Okay. Do you remember what the statements were?

Answer. The best I can remember sir-and it's getting worse by the minutes, seems like "Monica was neverYou were always there when Monica was there. We were never really alone." Those two stick in my mind as two statements he made.

Question. Let me see if I can refresh your recollection as to some others.

Answer. Yes.

Question. Did the President also make the statement: 'Monica came on to me, and I never touched her, right?? Answer. Yes, that statement was made, sir.

Question. Did the President also state to you at that time: 'She wanted to have sex with me, and I can't do that, right'?

Answer. I don't remember the 'right' part coming after there but probably without the right.”

Question. Okay.

Answer. Or I don't-but that just that that statement was made, yes, sir.

Question. Okay. And did the President also say to you, You could see and hear everything?'

Answer. Correct.

Question. You indicated that the President may not have added the 'right' at the end. But would it be fair to say that the way the President was posing these statements to you, that he wanted you to agree with them?

Answer. Not on that one.

Question. Not on the 'She wanted to have sex with me, and I can't do that"?

Answer. 'I told her I couldn't do that' or something like that. So it wasn't one that I-I may have been saying 'right,' but I don't think he-I don't-the best that I remember on that one, 'She wanted to have sex with me, but I can't-I told her I couldn't do that.'

Question. And that one, he didn't necessarily want you to agree with-it is that what your testimony is that it was just a statement?

Answer. That-I would call it a statement, sir.

Question. But the way the other statements were posed to you-and I'll read them again. The way the other statements were posed to you-is it correct that the way they were posed, the President wished you to agree with them? And I'll read them back to you.

Answer. The President wished me to agree with them? Question. Yes.

Answer. Read them again.

Question. You were always there when she was there. Answer. (Nodding.) Right.

Question. Okay. Is 'right' meaning, correct, he wantedthe President wanted you to agree with that?

Answer. Oh, because I said 'right'-I was always there. Since I can't say what he wanted-but my impression was that he was just making statements.

I—

Question. You added a 'right' to the last statement that

Answer. Which one was that?

Question. The 'You were always there when she was there, right? Is that the way you remember the President stating it to you?

Answer. That's how I remember him stating it to me.

Question. Would it be fair to say, then-based on the way he stated it and the demeanor that he was using at the time that he stated it to you-that he wished you to agree with that statement?

Answer. I can't speak for him, but

Question. How did you take it? Because you told us at these meetings in the last several days that that is how you took it.

Answer. (Nodding.)

Question. And you're nodding your head 'Yes', is that correct?

Answer. That's correct.

Question. Okay. With regard to the statement that the President made to you, You remember I was never really alone with Monica, right?'-was that also a statement that, as far as you took, that he wished you to agree with that?

Answer. Correct.

Question. And to the President's statement to you: You could see and hear everything, right?"-was that also a statement that the president, as far as you could tell, wished you to agree to?

Answer. Not only did he wish me to agree to it, but they were also right. But right.

Question. What do you mean they were also right?

Answer. I was always there. I could always hear. And the last one

Question. Okay. You could not hear the President

Answer. Well, read that question.

Question. You could

Answer. I was always there.

Question. Well, the last one was: You could see and hear everything.' That is not correct, is it?

Answer. I could not see and hear everything, no.

Question. Okay. Now, there was a first one: You were there when I was'

A-when she was there.'

Question. -when she was there.'

Answer. And that's-to my knowing, that's correct.

Question. Well, but you've already testified that there were several occasions when the President and Ms. Lewinsky were in the Oval Office when you were not there in

Answer. But if she was there, I was there. She was not-to my knowing, she didn't come to see him or come there, and I wasn't there.

Question. You mean that she was always-you were always there when Ms. Lewinsky came to visit him.

Answer. Mm-hmm.

Question. You were always in the general area.

Answer. Correct.

Question. Okay. You also told us in the last couple days when we discussed this matter with the President, that he appeared to you-when he was going through these statements and talking about what occurred in the deposition, that he appeared to be concerned.

Answer. Appeared to be concerned, yes.

Question. Okay. Let's move on—

Answer. Thank you.

Question. -to the next-the following days. You left the White House after this discussion with the President; is that correct?

Answer. (Nodding.)

Question. When was the next time you heard from him,
approximately?

Answer. I was reminded that Monday was a holiday.
Question. "Martin Luther King's birthday."

(Grand Jury Testimony of Betty Currie, 1/27/98, pp. 71–76, H. Doc. 105-316, pp. 559-60).

The evidence also indicates that the President knew the Paula Jones attorneys might contact Betty Currie because he suggested to them several times during his deposition that she may possessed information necessary to answer questions posed by counsel. (Deposition of President Clinton, 1/17/98 (released in news accounts)).

Question 53. Do you admit or deny that you had a conversation with Betty Currie within several days of January 18, 1998, in which you made statements similar to any of the following regarding your relationship with Monica Lewinsky?

a. "You were always there when she was there, right? "We were never really alone."

b. "You could see and hear everything."

c. "Monica came on to me, and I never touched her right?' d. "She wanted to have sex with me and I couldn't do that." Answer. I previously told the grand jury that, "I don't know that I" had another conversation with Ms. Currie within several days of

January 18, 1998, in which I made statements similar to those quoted above. "I remember having this [conversation] one time.” App. at 592. I further explained, "I do not remember how many times I talked to Betty Currie or when. I don't. I can't possibly remember that. I do remember, when I first heard about this story breaking, trying to ascertain what the facts were, trying to ascertain what Betty's perception was. I remember that I was highly agitated, understandably, I think." App. at 593.

I understand that Ms. Currie has said a second conversation occurred the next day that I was in the White House (when she was), Supp. at 535-36, which would have been Tuesday, January 20, before I knew about the grand jury investigation.

Reference. The record indicates that the President made statements similar to these to Betty Currie within several days of January 18, 1998:

66

[W]hen he called me in the Oval Office, it was sort of a recapitulation of what we had talked about on Sunday.. (Grand Jury Testimony of Betty Currie, 1/27/98, p. 81, H. Doc. 105-316, p. 561).

Question 54. Do you admit or deny that on January 18, 1998, at or about 11:02 p.m., you telephoned Betty Currie at her home?

Answer. According to White House records included in the OIC Referral, I called Ms. Currie's residence on January 18, 1998, at or about 11:02 p.m. App. at 2881.

Reference. The record indicates that such a telephone call was made. See Telephone Table 47, Call 11, as referenced on p. 174 of H. Doc. 105-311.

Question 55. Do you admit or deny that on Monday, January 19, 1998, at or about 8:50 a.m., you telephoned Betty Currie at her home?

Answer. According to White House records included in the OIC Referral, I called Ms. Currie's residence on January 19, 1998, at or about 8:50 a.m. App. at 3147.

Reference. The record indicates that such a telephone call was made. See Telephone Table 48, Call 8, as referenced on p. 176 of H. Doc. 105-311.

Question 56. Do you admit or deny that on Monday, January 19, 1998, at or about 8:56 a.m., you telephoned Vernon Jordan at his home?

Answer. According to White House records included in the OIC Referral, I called Mr. Jordan's residence on January 19, 1998, at or about 8:56 a.m. App. at 2864.

Reference: The record indicates that such a telephone call was made. See Telephone Table 48, Call 10, as referenced on p. 176 of H. Doc. 105-311.

Question 57. Do you admit or deny that on Monday, January 19, 1998, at or about 10:58 a.m., you telephoned Vernon Jordan at his office?

Answer. According to White House records included in the OIC Referral, I called Mr. Jordan's office on January 19, 1998, at or about 10:58 a.m. App. at 2883

Reference: The record indicates that such a telephone call was made. See Telephone Table 48, Call 16, as referenced on p. 177 of H. Doc. 105–311.