Question. What did the President say about Monica Answer. The only discussion I recall having with him, he denied that he had had sexual relations with Ms. Lewinsky and denied that he had-I don't know how to capsulize it— obstructed justice, let's use that phrase. (Grand Jury Testimony of Harold Ickes, 6/10/98, p. 21, H. Doc. 105-316, p. 1487; See also Grand Jury Testimony of Harold Ickes from 8/5/98, p. 88, H. Doc. 105-316, p. 1610 ("He denied to me that he had had a sexual relationship. I don't know the exact phrase, but the word 'sexual' was there. And he denied any obstruction of justice")). Question 68. 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 had not asked anyone to change their story, suborn perjury or obstruct justice if called to testify or otherwise respond to a request for information from the Office of Independent Counsel or in any other legal proceeding? 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 testified before the grand jury that: "The two things I recall, the two things that he again repeated in publichad already said publicly and repeated in public that same Monday morning was that he had not-he did not have a-or he had not had a sexual relationship with Ms. Lewinsky and that he had done nothing-now I'm paraphrasing-had done nothing to ask anybody to change their story or suborn perjury or obstruct justice." (Grand Jury Testimony of Harold Ickes, 6/10/98, p. 73, H. Doc. 105–316, p. 1539). 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 Answer. I recall telling a number of those people that I 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 69. Do you admit or deny that, on or about January 21, 1998, you and Richard "Dick" Morris discussed the possibility of commissioning a poll to determine public opinion following the Washington Post story regarding the Monica Lewinsky matter? Answer. At some point after the OIC investigation became public, Dick Morris volunteered to conduct a poll on the charges reported in the press. He later called back. What I recall is that he said the public was most concerned about obstruction of justice or subornation of perjury. I do not recall saying, "Well, we just have to win then." Reference. The record indicates that such a discussion occurred. Richard "Dick" Morris testified before the Grand Jury that during a conversation with the President the same day the Washington Post published a story concerning Monica Lewinsky, Mr. Morris suggested a public poll to test public opinion about the story. President Clinton asked Mr. Morris "When can you do it?", Mr. Morris replied "Tonight." and President Clinton requested Mr. Morris to "Call me tonight with the numbers." (Grand Jury Testimony of Richard Morris, 8/18/98, p. 17, H. Doc. 105–316, p. 2927). Question 70. Do you admit or deny that you had a later conversation with Richard "Dick" Morris in which he stated that the polling results regarding the Monica Lewinsky matter suggested that the American people would forgive you for adultery but not for perjury or obstruction of justice? Answer. At some point after the OIC investigation became public, Dick Morris volunteered to conduct a poll on the charges reported in the press. He later called back. What I recall is that he said the public was most concerned about obstruction of justice or subornation of perjury. I do not recall saying, "Well, we just have to win then. Reference. The record indicates that such a conversation occurred. Richard "Dick" Morris testified before the Grand Jury that he explained the results of a public opinion poll to President Clinton. Mr. Morris testified, "They're just too shocked by this. It's just too new, it's too raw. And the problem is they're willing to forgive you for adultery, but not for perjury or obstruction of justice or the various other things. They're even willing to forgive the conduct. They're not willing to forgive the word. In other words, if in fact you told Monica Lewinsky to lie, they can forgive that, but if you committed subornation of perjury, they won't." (Grand Jury Testimony of Richard Morris, 8/18/98, pp. 28, 29, H. Doc. 105–316, pp. 2929, 2930). Question 71. Do you admit or deny that you responded to Richard "Dick" Morris's explanation of these polling results by making a statement similar to the following: "[w]ell, we just have to win, then" ? Answer. At some point after the OIC investigation became public, Dick Morris volunteered to conduct a poll on the charges reported in the press. He later called back. What I recall is that he said the public was most concerned about obstruction of justice or suborna tion of perjury. I do not recall saying, “Well, we just have to win then. Reference. The record indicates that the President gave such a response. Richard Morris testified before the Grand Jury that after explaining to President Clinton that he would lose political support by admitting to obstructing justice and suborning perjury, President Clinton replied "[w]ell, we just have to win then." (Grand Jury Testimony of Richard Morris, 8/18/98, p. 30, H. Doc. 105–316, p. 2930). Question 72. Do you admit or deny the past or present existence of or the past or present direct or indirect employment of individuals, other than counsel representing you, whose duties include making contact with or gathering information about witnesses or potential witnesses in any judicial proceeding related to any matter in which you are or could be involved? Answer. I cannot respond to this inquiry because of the vagueness of its terms (e.g., "indirect," "potential," "could be involved"). To the extent it may be interpreted to apply to individuals assisting counsel, please see my responses to Request Nos. 73-75, infra. To the extent the inquiry addresses specific individuals, as in Request Nos. 73-75, infra, I have responded and stand ready to respond to any other specific inquiries. Reference. The record indicates that such individuals may have been employed for such a purpose. Richard Morris testified before the Grand Jury that there was a "White House Secret Police Operation", Mr. Morris explained that the operation stemmed "more from Hillary Clinton than from Bill." Mr. Morris identified Terry Lenzner, Jack Palladino and Betsey Wright as members of this group. (Grand Jury Testimony of Richard Morris, 8/18/98, p. 60, H. Doc. 105-316, p. 2937). Question 73. Do you admit or deny having knowledge that Terry Lenzner was contacted or employed to make contact with or gather information about witnesses or potential witnesses in any judicial proceeding related to any matter in which you are or could be involved? Answer. My counsel stated publicly on February 24, 1998, that Mr. Terry Lenzner and his firm have been retained since April 1994 by two private law firms that represent me. It is commonplace for legal counsel to retain such firms to perform legal and appropriate tasks to assist in the defense of clients. See also Response to No. 72. Reference. The record indicates that Terry Lenzner may have been contacted or employed for such a purpose. Richard Morris testified before the Grand Jury that Terry Lenzner was a member of the "White House Secret Police Operation" but that he was only aware of Mr. Lenzner from news accounts. (Grand Jury Testimony of Richard Morris, 8/18/98, pp. 60, 72, H. Doc. 105-316, pp. 2937, 2941). Question 74. Do you admit or deny having knowledge that Jack Palladino was contacted or employed to make contact with or gather information about witnesses or potential witnesses in any judicial proceeding related to any matter in which you are or could be involved? Answer. My understanding is that during the 1992 Presidential Campaign, Mr. Jack Palladino was retained to assist legal counsel for me and the Campaign on a variety of matters arising during the Campaign. See also Response to No. 72. Reference. The record indicates that Mr. Palladino may have been contacted or employed for such a purpose. Richard Morris testified before the Grand Jury that Mr. Palladino was a member of the "White House Secret Police Operation." (Grand Jury Testimony of Richard Morris, 8/18/98, p. 72, H. Doc. 105-316, p. 2941.) Question 75. Do you admit or deny having knowledge that Betsey Wright was contacted or employed to make contact with or gather information about witnesses or potential witnesses in any judicial proceeding related to any matter in which you are or could be involved? Answer. Ms. Betsey Wright was my long-time chief of staff when I was Governor of Arkansas, and she remains a good friend and trusted advisor. Because of her great knowledge of Arkansas, from time to time my legal counsel and I have consulted with her on a wide range of matters. See also Response to No. 72. Reference. The record indicates that Betsey Wright was contacted or employed for such a purpose. Richard "Dick" Morris testified before the Grand Jury that Betsey Wright told him that “what we do is we work on getting material on them to try to induce them not to compromise the President." Betsey Wright was identified by Mr. Morris as a member of the "White House Secret Police Operation." (Grand Jury Testimony of Richard Morris, p. 76, H. Doc. 105-316, p. 2941). Question 76. Do you admit or deny that you made false and misleading public statements in response to questions asked on or about January 21, 1998, in an interview with Roll Call, when you stated "Well, let me say, the relationship was not improper, and I think that's important enough to say. But because the investigation is going on and because I don't know what is out-what's going to be asked of me, I think I need to cooperate, answer the questions, but I think it's important for me to make it clear what is not. And then, at the appropriate time, I'll try to answer what is. But let me answer-it is not an improper relationship and I know what the word means."? Answer. The tape of this interview reflects that in fact I said: "Well, let me say the relationship's not improper and I think that's important enough to say. "With that revision, the quoted words accurately reflect my remarks. As I stated in Response to Request Nos. 62 to 68, in the days following the January 21, 1998, disclosures, I misled people about this relationship, for which I have apologized. Reference. On August 17, 1998, after testifying before the grand jury, the President addressed the American people from the White House and stated "Indeed I did have a relationship with Ms. Lewinsky that was not appropriate. In fact, it was wrong. It constituted a critical lapse in judgment and a personal failure on my part for which I am solely and completely responsible." (34 Weekly Compilation of Presidential Documents, p. 1638). Question 77. Do you admit or deny that you made false and misleading public statements in response to questions asked on or about January 21, 1998, in the Oval Office during a photo opportunity, when you stated "Now, there are a lot of other questions that are, I think, very legitimate. You have a right to ask them; you and the American people have a right to get answers. We are working very hard to comply and get all the requests for information up here, and we will give you as many answers as we can, as soon as we can, at the appropriate time, consistent with our obligation to also cooperate with the investigations. And that's not a dodge, that's really what I've I've talked with our people. I want to do that. I'd like for you to have more rather than less, sooner rather than later. So we'll work through it as quickly as we can and get all those questions out there to you."? Answer. I made this statement (as corrected), according to a transcript of a January 22, 1998 photo opportunity in the Oval Office. This statement was not false and misleading. It accurately represented my thinking. Reference. On January 26, 1998, after making the above statement that he would give as many answers as he could, as soon as he could, the President stated publicly "I did not have sexual relations with that woman, Ms. Lewinsky... these allegations are false." Question 78. Do you admit or deny that you discussed with Harry Thomasson, prior to making public statements in response to questions asked by the press in January, 1998, relating to your relationship with Monica Lewinsky, what such statements should be or how they should be communicated? Answer. Mr. Thomasson was a guest at the White House in January 1998, and I recall his encouraging me to state my denial forcefully. Reference. The record indicates that such a discussion occurred. On January 22nd, the President Clinton's friend and advisor, Harry Thomasson traveled from California to Washington, D.C., and stayed in the White House residence for the next 34 days. Mr. Thomasson advised the President on how best to communicate with the public regarding his relationship with Monica Lewinsky. Mr. Thomasson appeared before the grand jury on August 11, 1998: Question. Okay. Did you talk specifically about his performance in the interview and his responses in the interview? (referring to a January 21, 1998, interview on television with Jim Lehrer) Answer. Yes. I mean, to the best of my knowledge, I said, "You know, what you said was exactly right, but the press is just saying you were equivocating." You know. And I said, "If the allegation is not true, then you shouldn't equivocate. You should explain it so there's no doubt in anybody's mind that nothing happened." Question. Okay. Did you tell the President that you thought he had equivocated in the interview? Answer. I told the President that I though his response wasn't as strong as it could have been. Harry Thomasson testified later that the President replied to Mr. Thomasson's statements by saying "You know, you're right. I should be more forceful than that." Grand Jury Testimony of Harry Thomasson, 8/11/98, pp. 15-16, 27 (H. Doc. 105-316, pp. 3730 and 3733). |