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Question 58. Do you admit or deny that on Monday, January 19, 1998, at or about 1:45 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 19, 1998, at or about 1:45 p.m. App. at 2883.

Reference: The record indicates that such a telephone call was made. See Telephone Table 48, Call 21, as referenced on p. 177 of H. Doc. 105–311.

Question 59. Do you admit or deny that on Monday, January 19, 1998, at or about 2:44 p.m., you met with individuals including Vernon Jordan, Erskine Bowles, Bruce Lindsey, Cheryl Mills, Charles Ruff, and Rahm Emanuel?

Answer. I do not believe such a meeting occurred. White House records included in the OIC Referral indicate that Mr. Jordan entered the White House complex that day at 2:44 p.m. Supp. at 1995. According to Mr. Jordan's testimony, he and I met alone in the Oval Office for about 15 minutes. Supp. at 1763 (grand jury testimony of Vernon Jordan).

I understand that Mr. Jordan testified that we discussed Ms. Lewinsky at that meeting and also the Drudge Report, in addition to other matters. Supp. at 1763. Please also see my Response to Request No. 48. supra.

Reference: The record indicates that Vernon Jordan entered the White House at 2:44 p.m. on January 19, 1998 (H. Doc. 105-316, p. 1995). Vernon Jordan's Grand Jury Testimony reveals that he and the President had a meeting at that time. (Grand Jury Testimony of Vernon Jordan, 3/5/98, p. 124, H. Doc. 105-316, p. 1763). Question 60. Do you admit or deny that on Monday, January 19, 1998, at or about 2:44 p.m., at any meeting with Vernon Jordan, Erskine Bowles, Bruce Lindsey, Cheryl Mills, Charles Ruff, Rahm Emanuel, and others, you discussed the existence of tapes of conversations between Monica Lewinsky and Linda Tripp recorded by Linda Tripp, or any other matter relating to Monica Lewinsky?

Answer. I do not believe such a meeting occurred. White House records included in the OIC Referral indicate that Mr. Jordan entered the White House complex that day at 2:44 p.m. Supp. at 1995. According to Mr. Jordan's testimony, he and I met alone in the Oval Office for about 15 minutes. Supp. at 1763 (grand jury testimony of Vernon Jordan).

I understand that Mr. Jordan testified that we discussed Ms. Lewinsky at that meeting and also the Drudge Report, in addition to other matters. Supp. at 1763. Please also see my Response to Request No. 48. supra.

Reference: The record indicates that Vernon Jordan entered the White House at 2:44 p.m. on January 19, 1998 (H. Doc. 105-316, p. 1995). The President met with Vernon Jordan shortly thereafter and they discussed the existence of the Tripp tapes:

Question. Now, with as much specificity as you can, what would you have told him about the Drudge Report? Answer. That I had seen the Drudge Report. 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. 1764).

Question 61. Do you admit or deny that on Monday, January 19, 1998, at or about 5:56 p.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 5:56 p.m. App. at 2883.

Reference: The record indicates that such a telephone call was made. See Presidential Call Log, H. Doc. 105-311, p. 2882.

Question 62. Do you admit or deny that on January 21, 1998, the day the Monica Lewinsky story appeared for the first time in the Washington Post, you had a conversation with Sidney Blumenthal, in which you stated that you rebuffed alleged advances from Monica Lewinsky and in which you made a statement similar to the following?: "Monica Lewinsky came at me and made a sexual demand on me.'

Answer. As I have previously acknowledged, I did not want my family, friends, or colleagues to know the full nature of my relationship with Ms. Lewinsky. In the days following the January 21, 1998, Washington Post article, I misled people about this relationship. I have repeatedly apologized for doing so.

Reference: The record indicates that such a conversation occurred. Testifying before the grand jury on June 4, 1998, Sidney Blumenthal, an Assistant to the President, related the following discussion he had with the President on January 21, 1998:

He said Dick Morris had called him that day and he said Dick had told him that Nixon-he had read the newspaper and he said "You know, Nixon could have survived if he had gone on television and given an address and said everything he had done wrong and got it all out in the beginning."

And I said to the President, "What have you done wrong?" And he said, "Nothing, I haven't done anything wrong." I said, "Well then, that's one of the stupidest things I've ever heard. Why would you do that if you've done nothing wrong?"

And it was at that point that he gave his account of what had happened to me and he said that Monica-and it came very fast. He said, "Monica Lewinsky came at me and made a sexual demand on me.” He rebuffed her. He said, I've gone down that road before, I've caused pain for a lot of people and I'm not going to do that again." (Grand Jury Testimony of Sidney Blumenthal, 6-4-98, p. 49, H. Doc. 105-316, p.185).

During his testimony before the grand jury, President Clinton admitted he made "misleading" statements to aides whom he knew were likely to be called to testify before the grand jury. The President testified as follows:

"Question. Do you recall denying any sexual relationship with Monica Lewinsky to the following people: Harry Thomasson, Erskine Bowles, Harold Ickes, Mr. Podesta, Mr. Blumenthal, Mr. Jordan, Ms. Betty Currie? Do you recall denying any sexual relationship with Monica Lewinsky to these individuals?

Answer. I recall telling a number of those people that I didn't have, either I didn't have an affair with Monica Lewinsky or didn't have sex with her. And I believe sir, that-you'll have to ask them what they thought. But I was using those terms in the normal way people use them. You'll have to ask them what they thought I was saying. Question. You knew that they might be called into a grand jury, didn't you?

Answer That's right." (Grand Jury Testimony of William Jefferson Clinton, 8/17/98, pp. 105-107, H. Doc. 105-311, p. 647).

Question 63. Do you admit or deny that on January 21, 1998, the day the Monica Lewinsky story appeared for the first time in the Washington Post, you had a conversation with Sidney Blumenthal, in which you made a statement similar to the following in response to a question about your conduct with Monica Lewinsky?: "I haven't done anything wrong."

Answer. As I have previously acknowledged, I did not want my family, friends, or colleagues to know the full nature of my relationship with Ms. Lewinsky. In the days following the January 21, 1998, Washington Post article, I misled people about this relationship. I have repeatedly apologized for doing so.

Reference. The record indicates that such a conversation occurred. See Blumenthal testimony in request for admission number 62.

Question 64. Do you admit or deny that on January 21, 1998, the day the Monica Lewinsky story appeared for the first time in the Washington Post, you had a conversation with Erskine Bowles, Sylvia Matthews and John Podesta, in which you made a statement similar to the following?: "I want you to know I did not have sexual relationships with this woman Monica Lewinsky. I did not ask anybody to lie. And when the facts come out, you'll understand."

Answer. As I have previously acknowledged, I did not want my family, friends, or colleagues to know the full nature of my relationship with Ms. Lewinsky. In the days following the January 21, 1998, Washington Post article, I misled people about this relationship. I have repeatedly apologized for doing so.

Reference. The record indicates that such a conversation occurred. In his grand jury testimony on June 16, 1998, then White House Deputy Chief of Staff John Podesta (now Chief Of Staff) testified to the following regarding a January 21, 1998 meeting with President Clinton:

"Answer And we went in to see the President.

Question. Who's we?

Answer Mr. Bowles, myself and Ms. Matthews.
Question. Okay. Tell us about that.

Answer And we started off the meeting-we didn't-I
don't think we said anything, and I think the President di-
rected this specifically to Mr. Bowles. He said, "Erskine, I
want you to know that this story is not true.

Question. What else did he say?

Answer He said that-that he had not had a sexual relationship with her, and that he never asked anybody to lie." (Grand Jury Testimony of John Podesta, 6/16/98, p. 85, H. Doc. 105-316, p. 3310).

Erskine Bowles had the following recollection of the same meeting:

"Answer And this was the day this huge story breaks. And the three of us walk in together-Sylvia Matthews, John Podesta and me-into the oval office, and the President was standing behind his desk.

Question. About what time of day is this?

Answer This is approximately 9:00 in the morning or something-you know, in that area. And he looked up at us and he said the same thing he said to the American people. He said, I want you to know I did not have sexual relationships with this woman Monica Lewinsky. I did not ask anybody to lie. And when the facts come out, you'll understand." (Grand Jury Testimony of Erskine Bowles, 4/2/ 98, pp. 83-84, H. Doc. 105-316, p. 239).

Question 65. Do you admit or deny that on or about January 23, 1998, you had a conversation with John Podesta, in which you stated that you had never had an affair with Monica Lewinsky?

Answer. As I have previously acknowledged, I did not want my family, friends, or colleagues to know the full nature of my relationship with Ms. Lewinsky. In the days following the January 21, 1998, Washington Post article, I misled people about this relationship. I have repeatedly apologized for doing so.

Reference. The record indicates that on January 23, 1998, President Clinton told John Podesta that he had never had sex with Monica Lewinsky in any way whatsoever:

"Answer See, we were getting ready to do the State of the Union prep and he was working on the state of the union draft back in his study. I went back there to just to kind of get him going-this is the first thing in the morning-you know, we sort of get engaged. I asked him how he was doing, and he said he was working on this draft, and he said to me that he had never had sex with her, and that-he never asked-you know, he repeated the denial, but he was extremely explicit in saying he never had sex with

her.

Question. How do you mean?

Answer Just what I said.

Question. Okay. Not explicit, in the sense that he got more specific than sex, than the word "sex."

Answer Yes, he was more specific than that.

Question. Okay. Share that with us.

Answer Well, I think he said-he said that-there was some spate of, you know, what sex acts were counted, and he said that he had never had sex with her in any way whatsoever.

Question. Okay.

Answer that they had not had oral sex.

Question. No question in you mind he's denying any sex
in any way, shape or form, correct?

Answer That's correct." (Grand Jury Testimony of John
Podesta, 6/16/98, pp. 91–3, H. Doc. 105–316, p. 3311).

Question 66. Do you admit or deny that on or about January 23, 1998, you had a conversation with John Podesta, in which you stated that you were not alone with Monica Lewinsky in the Oval Office, and that Betty Currie was either in your presence or outside your office with the door open while you were visiting with Monica Lewinsky?

Answer. As I have previously acknowledged, I did not want my family, friends, or colleagues to know the full nature of my relationship with Ms. Lewinsky. In the days following the January 21, 1998, Washington Post article, I misled people about this relationship. I have repeatedly apologized for doing so.

Reference. The record indicates that such a conversation occurred:

Question. Did the President ever speak to that issue with you, the issue of if he didn't have an improper relationship with Ms. Lewinsky, what was she doing there so often? Did he ever speak to that?

Answer He said to me-I don't think it was in this conversation, I think it was a couple weeks later. He said to me that after she left, that when she had come by, she came to see Betty, and that he when she was there, either Betty was with them either that she was with Betty when he saw her or that he saw her in the Oval Office with the door open and Betty was around—and Betty was out at her desk." (Grand Jury Testimony of John Podesta, 6/ 16/98, p.88, H. Doc. 105-316, p. 3310).

Question 67. Do you admit or deny that on or about January 26, 1998, you had a conversation with Harold Ickes, in which you made statements to the effect that you did not have an affair with Monica Lewinsky?

Answer. As I have previously acknowledged, I did not want my family, friends, or colleagues to know the full nature of my relationship with Ms. Lewinsky. In the days following the January 21, 1998, Washington Post article, I misled people about this relationship. I have repeatedly apologized for doing so.

Reference. The record indicates that such a conversation occurred. Harold Ickes, a former Deputy Chief of Staff at the White House testified before the grand jury that President Clinton told him that he had not had a sexual relationship with Monica Lewinsky:

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