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and manipulated the judicial process of the United States for his personal gain and exoneration, impeding the administration of justice, in that:

(1) On December 23, 1997, William Jefferson Clinton, in sworn answers to written questions asked as part of a Federal civil rights action brought against him, willfully provided perjurious, false and misleading testimony in response to questions deemed relevant by a Federal judge concerning conduct and proposed conduct with subordinate employees.

(2) On January 17, 1998, William Jefferson Clinton swore under oath to tell the truth, the whole truth, and nothing but the truth in a deposition given as part of a Federal civil right action brought against him. Contrary to that oath, William Jefferson Clinton willfully provided perjurious, false and misleading testimony in response to questions deemed relevant by a Federal judge concerning the nature and details of his relationship with a subordinate Government employee, his knowledge of that employee's involvement and participation in the civil rights action brought against him, and his corrupt efforts to influence the testimony of that employee.

In all of this, William Jefferson Clinton has undermined the integrity of his office, has brought disrepute on the Presidency, has betrayed his trust as President, and has acted in a manner subversive to the rule of law and justice, to the manifest injury of the people of the United States.

Wherefore, William Jefferson Clinton, by such conduct, warrants impeachment and trial, and removal from office and disqualification to hold and enjoy any office of honor,

trust, or profit under the United States. Article II passed the Judiciary Committee by a vote of 20 to 17 on December 11, 1998. I voted in support of its passage.

The specific allegations contained in Article II are that the President willfully provided perjurious, false and misleading testimony in answers to written questions posed by the plaintiff

in Jones v. Clinton on December 23, 1997, and that the President willfully provided perjurious, false and misleading testimony in answers to questions proposed by the plaintiff's attorney in a deposition on January 17, 1998.

a. On December 23, 1997, the President, in Sworn Answers

to Written Questions Asked As Part of A Federal Civil Rights Action Brought Against Him, Willfully Provided Perjurious, False and Misleading Testimony In Response To Questions Deemed Relevant By A Federal Judge Concerning Conduct And Proposed Conduct With Subordi

nate Employees. As stated previously, on December 23, 1997, the President answered interrogatories in the Jones case under oath.113 When asked under oath to identify women with whom he had sexual relations who were state or federal employees during a specified limited time frame, the President responded "none." 114 The President lied.

113 OIC Referral. at 13.

b. On January 17, 1998, the President Swore Under Oath To

Tell The Truth, The Whole Truth, And Nothing But The
Truth In a Deposition Given As Part of A Federal Civil
Rights Action Brought Against Him. Contrary To That
Oath, the President Willfully Provided Perjurious, False
and Misleading Testimony in Response To Questions
Deemed Relevant By a Federal Judge Concerning The
Nature and Details Of His Relationship With A Subordi.
nate Government Employee And His Corrupt Efforts To

Influence The Testimony Of That Employee. On January 17, 1998, the President was questioned under oath at a deposition regarding sexual relationships with women in the workplace.115 During the deposition, the President denied that he had engaged in a “sexual affair,” a “sexual relationship,” or “sexual relations" with Ms. Lewinsky, while also stating that he "had no specific memory of being alone with Ms. Lewinsky, that he remembered few details of any gifts they might have exchanged, and indicated that no one except his attorneys had kept him informed of Ms. Lewinsky's status as a potential witness in the (Jones v. Clinton] case.” 116 Under oath the President stated that he had not had sexual relations with any federal employees during a particular time frame. 117 As we now know, in fact the President did have sexual relations with a federal employee during the stated time frame. The President lied.

According to Ms. Lewinsky, she and the President had ten sexual encounters, eight while she was a White House intern or employee, and two thereafter. The sexual encounters generally occurred in or near the Oval Office private study. The evidence indicates that the conduct the President had with Ms. Lewinsky met the definition of sex, and that he lied about their conduct. Ms. Lewinsky testified that her physical relationship with the President included oral sex but not sexual intercourse.

c. The President Lied in His Deposition About Being Alone in

Certain Locations of the White House with A Subordinate
Federal Employee Who Was a Witness In The Action

Brought Against Him The evidence is clear that Ms. Lewinsky and the President did have sexual relations when they were "alone." There is no evidence that anyone saw them, or that they were caught in a sex act, which would lead reasonable minds to believe that their relationship was always covert. They were in fact alone. The President's attempt to defend himself on this charge is a tortured definition of the word “alone,” wherein it refers to an entire geographical area, rather than the immediate surroundings. When the President said he was never alone with Ms. Lewinsky, he meant he was never alone in the White House oval office complex. In fact, the President and Ms. Lewinsky were alone on at least 21 occasions. Naturally, in the literal sense, one is never alone in the cosmos. Reasonable people do not believe the absurd. Reasonable people would believe that the President's testimony was perjurious.

114V002–DC-00000053 (President Clinton's Supplemental Responses to Plaintiff's Second Set of Interrogatories at 2).

115 OIC Referral at 3.
116 Id. at 3.
117 Id.

The President relies on the literal truth defense. He asserts that he is never really alone in the White House. There must be a objective reasonable basis for a subjective belief to have merit. The President's subjective belief is neither reasonable nor sufficient to shield him from perjury charges. There was no reasonable basis. The evidence supports that the President lied.

d. The President Lied In His Deposition About His Knowl

edge of Gifts Exchanged Between Himself and a Subordinate Federal Employee Who Was A Witness in the Action

Brought Against Him The evidence shows that the President presented Ms. Lewinsky with a number of gifts, including, a lithograph, a hat pin, a large “Black Dog” canvas bag, a large “Rockettes” blanket, a pin of the New York City skyline, a box of chocolates, a pair of sunglasses, a stuffed animal from the “Black Dog," a marble bear's head, a London pin., a shamrock pin, an Annie Lennox compact disc, and Davidoff cigars. 118 In the deposition of the President he provided false answers when he testified that Ms. Lewinsky has given him "a book or two." The evidence also shows that Ms. Lewinsky gave the President approximately 38 gifts.119 The President gave Ms. Lewinsky approximately 24 gifts. The evidence supports that the President lied.

e. The President Lied In His Deposition About His Knowledge

Regarding Whether He Had Ever Spoken To A Subordi-
nate Federal Employee About The Possibility That Such
Subordinate Employee Might Be Called As A Witness To
Testify In The Federal Civil Rights Action Brought

Against Him When asked in the deposition about whether he talked to Ms. Lewinsky about her being called as a witness the President testified that he could not recall. However, the evidence shows that on December 17, 1997, the President called Ms. Lewinsky and informed her that he had seen the witness list and that her name was on it. 120 Moreover, he told her that if she was called as a witness she was to notify Ms. Currie. 121 The evidence supports that the President lied.

f. The President lied in his deposition about his knowledge of

the service of a subpoena to a subordinate federal employee to testify as a witness in the federal civil rights ac

tion brought against him In the civil deposition, the President was asked the question:

118 OIC Referral at 101. 119 Id. at 157. 120 Id. at 843.

121 Id..

» 122

Q. Did she tell you she had been served with a subpoena in this case?

A. No. I don't know if she had been.

Q. Did anyone other than your attorneys tell you that Monica Lewinsky had been served with a subpoena in this case?

A. I don't think so.' The evidence shows that the President discussed with Vernon Jordan the fact that Ms. Lewinsky was served with a subpoena. The testimony of the President and Vernon Jordan is in direct conflict on this fact. 123 The record indicates that the President knew, before his deposition, that Ms. Lewinsky had been subpoenaed in the case of Jones v. Clinton. 124 Ms. Lewinsky was served with a subpoena on December 19, 1997, a subpoena that commanded her to appear for a deposition on January 23, 1998, and to produce certain documents and gifts. 125 Monica Lewinsky talked to Vernon Jordan about the subpoena on December 19, 1997, and Mr. Jordan spoke to the President that afternoon and again that evening. 126 He told the President that he had met with Ms. Lewinsky, she had been subpoenaed, and that he planned on obtaining an attorney for her. 127 On Sunday, December 28, 1997, the President met with Ms. Lewinsky who expressed concerns about the subpoena's demand for gifts he had given her. 128 The evidence supports that the President lied. g. The President Lied In His Deposition About His Knowledge

Of The Final Conversation He Had With A Subordinate
Employee Who Was A Witness In The Federal Civil

Rights Action Brought Against Him The testimony of the President and Ms. Lewinsky regarding their last meeting are in direct conflict. The President testified that he stuck his head out of his office and said hello to Ms. Lewinsky at the time of their last meeting. Ms. Lewinsky testified that the President gave her Christmas gifts, and they talked about the Jones v. Clinton case. 129 Specifically, she wanted to know how she got put on the witness list and they discussed the subpoena and its direct reference to a hat pin which was the first gift he had ever given her.130 The evidence supports that the President lied.

122 Deposition of President Clinton in the case of Jones v. Clinton, January 18, 1998, p. 068. 123 OIC Referral at 96. 124 Id. at 97. 125 Id. at 96. 126 Id. at 96–97. 127 Id. at 97.

128 Id.

129 Id. at 101.

130 Id. Corroborating evidence shows that Ms. Currie called Ms. Lewinsky and asked her to come to the White House at 8:30 a.m. on the morning of December 28, the day of their last meeting. WAVES records indicate that the meeting was requested by Ms. Currie and that Ms. Lewinsky entered the White House at 8:16 a.m., December 28, 1997. After she arrived at the Oval Office, she, the President and Ms. Currie played with Buddy, the President's dog, and chatted. Then the President took Ms. Lewinsky into the study and gave her several Christmas presents: a marble bear's head, a Rockettes blanket, a Black Dog stuffed animal, a small box of chocolate, a pair of joke sunglasses, and a pin with the New York skyline on it. Ms. Lewinsky testified that on this occasion she and the President had a "passionate and physically intimate kiss.” Id.

h. The President Lied In His Deposition About His Knowl

edge That The Contents Of An Affidavit Executed By A Subordinate Federal Employee Who Was A Witness In

The Federal Civil Rights Action Brought Against Him As discussed elsewhere, the President affirmed to the court in his civil deposition the truth of the statements contained in Ms. Lewinsky's affidavit regarding sexual relations. The President and Ms. Lewinsky concocted a cover story with the willful intent to deceive the court. As the evidence shows, the President did in fact have sexual relations with Ms. Lewinsky. The evidence supports that the President lied. (3) Article IIIObstruction of Justice

In his conduct while President of the United States, William Jefferson Clinton, in violation of his constitutional oath faithfully to execute the office of President of the United States and, to the best of his ability, preserve, protect, and defend the Constitution of the United States, and in violation of his constitutional duty to take care that the laws be faithfully executed, has prevented, obstructed, and impeded the administration of justice, and has to that end engaged personally, and through his subordinates and agents, in a course of conduct or scheme designed to delay, impede, cover up, and conceal the existence of evidence and testimony related to a Federal civil rights action brought against him in a duly instituted judicial proceeding.

The means used to implement this course of conduct or scheme included one or more of the following acts:

(1) On or about December 17, 1997, William Jefferson Clinton corruptly encouraged a witness in a Federal civil rights action brought against him to execute a sworn affidavit in that proceeding that he knew to be perjurious, false and misleading.

(2) On or about December 17, 1997, William Jefferson Clinton corruptly encouraged a witness in a Federal civil rights action brought against him to give perjurious, false and misleading testimony if and when called to testify personally in that proceeding.

(3) On or about December 28, 1997, William Jefferson Clinton corruptly engaged in, encouraged, or supported a scheme to conceal evidence that had been subpoenaed in a Federal civil rights action brought against him.

(4) Beginning on or about December 7, 1997, and continuing through and including January 14, 1998, William Jefferson Clinton intensified and succeeded in an effort to secure job assistance to a witness in a Federal civil rights action brought against him in order to corruptly prevent the truthful testimony of that witness in that proceeding at a time when the truthful testimony of that witness could have been harmed.

(5) On January 17, 1998, at his deposition in a Federal civil rights action brought against him, William Jefferson Clinton corruptly allowed his attorney to make false and misleading statements to a Federal Judge characterizing an affidavit, in order to prevent questioning deemed relevant by the Judge. Such false and misleading statements were subsequently acknowledged by his attorney in a communication to that judge.

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