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his prior deposition. Thus, the President engaged in an evolving se-
ries of lies in sworn testimony in order to cover previous lies he
told in sworn testimony and previous obstructive conduct. In all of
this, it was the intention of the President to thwart the ability of
Paula Jones to bring a case against him and to sidetrack the OIC
investigation into his misconduct.
4. The Committee concluded that the President provided perjurious,

false, and misleading testimony to a Federal grand jury con-
cerning his corrupt efforts to influence the testimony of wit-
nesses and to impede the discovery of evidence in that civil
rights action
a. The President gave perjurious, false and misleading testi-

mony before the grand jury when he denied engaging in
a plan to hide evidence that had been subpoenaed in the

federal civil rights action against him The President made the following perjurious, false, and misleading statements before the grand jury regarding efforts to hide evidence that had been subpoenaed in the case of Jones v. Clinton.

Q. Getting back to your meeting with Ms. Lewinsky on December 28, you are aware that she's been subpoenaed. You are aware, are you not, Mr. President, that the subpoena called for the production of, among other things, all the gifts that you had given Ms. Lewinsky? You were aware of that on December 28, weren't you?

A. I'm not sure. And I understand this is an important question. I did have a conversation with Ms. Lewinsky at some time about gifts, the gifts I had given her. I do not know whether it occurred on the 28th, or whether it occurred earlier. I do not know whether it occurred in person or whether it occurred on the telephone. I have searched my memory for this, because I know it's an important issue.

Perhaps if you—I can tell you what I remember about the conversation and you can see why I'm having trouble placing the date.

Q. Please.

A. The reason I'm not sure it happened on the 28th is that my recollection is that Ms. Lewinsky said something to me like, what if they ask me about the gifts you've given me. That's the memory I have. That's why I question whether it happened on the 28th, because she had a subpoena with her, request for production.

And I told her if they asked for gifts, she'd have to give

them whatever she had, that that's what the law was. Grand Jury Testimony of President Clinton, 8/17/98, p. 42–43, H. Doc. 105–311, p. 494_495.

Essentially the same perjurious, false, and misleading testimony is repeated by the President later in his grand jury testimony, p. 45, lines 11–23.

The following testimony was also given:

Q. After you gave her the gifts on December 28th, did
you speak with your secretary, Ms. Currie, and ask her to
pick up a box of gifts that were some compilation of gifts
that Ms. Lewinsky would have

A. No, sir, I didn't do that.
Q. —to give to Ms. Currie?

A. I did not do that. Grand Jury Testimony of President Clinton, 8/17/98, p. 50, H. Doc. 105–311, p. 502.

Similar perjurious, false, and misleading grand jury testimony of President Clinton can be found on p. 113, lines 16–25, p. 114, lines 1–25 of the transcript from that grand jury testimony of 8/17/98.

On December 19, 1997, Monica Lewinsky was served with a subpoena in connection with the case of Jones v. Clinton. The subpoena required her to testify at a deposition on January 23, 1998. The subpoena also required her to produce each and every gift given to her by President Clinton. On the morning of December 28, 1998, Ms. Lewinsky met with the President for about 45 minutes in the Oval Office. By this time, President Clinton knew Ms. Lewinsky had been subpoenaed. At this meeting they discussed the fact that the gifts had been subpoenaed, including a hat pin, the first gift Clinton had given Lewinsky. Monica Lewinsky testified that at some point in this meeting she said to the President, “Well, you know, I-maybe I should put the gifts away outside my house somewhere or give them to someone, maybe Betty'. And he sort of said—I think he responded, 'I don't know or 'Let me think about that.' And left that topic.” Grand Jury Testimony of Monica Lewinsky, 8/6/98, p. 152, H. Doc. 105–311, p. 872; See also 7/27/98 OIC Interview of Monica Lewinsky, p. 7, H. Doc. 105–311, p. 1395.

President Clinton provided the following explanation to the grand jury and this Committee regarding this conversation: “Ms. Lewinsky said something to me like, what if they ask me about the gifts you've given me,” but I do not know whether that conversation occurred on December 28, 1997, or earlier. Whenever this conversation occurred, I testified, I told her "that if they asked her for gifts, she'd have to give them whatever she had. .." I simply was not concerned about the fact that I had given her gifts. Indeed, I gave her additional gifts on December 28, 1997. Request for Admission number 24; see also Grand Jury Testimony of President Clinton, 8/ 17/98, p. 43, H. Doc. 105–311, p. 495. The President's statement that he told Ms. Lewinsky that if the attorneys for Paula Jones asked for the gifts, she had to provide them is perjurious, false and misleading. It simply strains logic to believe the President would encourage Monica Lewinsky to turn over the gifts. To do so would have raised questions about their relationship and would have been contrary to all of their other efforts to conceal the relationship, including the filing of an affidavit denying a sexual relationship. The fact that the President gave Ms. Lewinsky additional gifts on December 28, 1998, provides further evidence that the President did not believe Ms. Lewinsky would provide gifts that had been subpoenaed. As Ms. Lewinsky testified, she never questioned, “that we were ever going to do anything but keep this quiet.” This meant that they had to take "whatever steps needed to be taken” to keep it quiet. By giving more gifts to Monica Lewinsky after she received

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a subpoena to appear for a deposition in the case of Jones. v. Clinton, the President was making another gesture of affection towards Ms. Lewinsky to help ensure that she would not testify truthfully regarding their relationship.

Ms. Lewinsky testified that she was never under the impression from anything the President said that she should turn over to Ms. Jones's attorneys all the gifts that he had given her. Deposition of Monica Lewinsky, 8/26/98, p. 58, H. Doc. 105–311, p. 1337. Additionally, she said she can't answer why the President would give her more gifts on the 28th when he knew she was under an obligation to produce gifts in response to a subpoena. She did testify, however, that, “to me it was never a question in my mind and Ifrom everything he said to me, I never questioned him, that we were never going to do anything but keep this private, so that meant deny it and that meant dotake whatever appropriate steps needed to be taken, you know, for that to happen ***. So by turning over these gifts, it would at least prompt (the Jones attorneys] to question me about what kind of friendship I had with the President * * *.” Grand Jury Testimony of Monica Lewinsky, 8/6/ 98, pp. 166–67, H. Doc. 105–311, pp. 886–87.

After this meeting on the morning of December 28th, Ms. Currie called Monica Lewinsky and made arrangements to pick up gifts the President had given to Ms. Lewinsky. Monica Lewinsky testified under oath before the grand jury that a few hours after meeting with the President on December 28, 1997, a meeting in which Ms. Lewinsky and President Clinton discussed the fact that gifts given to her by Mr. Clinton had been subpoenaed in the case of Jones v. Clinton, Betty Currie called her. The record indicates the following discussion occurred:

Q. What did (Betty Currie] say?

A. She said, “I understand you have something to give me.” Or, “The President said you have something to give me.” Along those lines. * * *

Q. When she said something along the lines of "I understand you have something to give me,” or “The President says you have something for me," what did you understand her to mean?

A. The gifts. Grand Jury Testimony of Monica Lewinsky, 8/6/98, pp. 154-55, H. Doc. 105–311, pp. 874.

Later in the day on December 28th, Ms. Currie drove to Ms. Lewinsky's home and Ms. Lewinsky gave her a sealed box that contained several gifts Ms. Lewinsky had received from the President, including the hat pin. Grand Jury Testimony of Monica Lewinsky, 8/6/98, pp. 156-58, H. Doc. 105–311, pp. 87578. Ms. Currie testified that she understood the box contained gifts from the President. She took the box home and put it under her bed. Grand Jury Testimony of Betty Currie, 5/6/98, pp. 107–8, H. Doc. 105–316, p. 581. In Monica Lewinsky's February 1, 1998 handwritten statement to the OIC, which Ms. Lewinsky has testified is truthful, she stated, "Ms. Currie called Ms. L later that afternoon and said that the Pres. had told her Ms. L wanted her to hold onto something for her. Ms. L boxed up most of the gifts she had received and gave

at Ms. 1 Testim when as Ms. Curwould boon't reme

them to Ms. Currie.” 21/98 Handwritten Proffer of Monica Lewinsky, p. 7, H. Doc. 105–311, p. 715.

Betty Currie testified that she did not recall the President telling her that Ms. Lewinsky wanted her to retrieve and hold some items; that Ms. Lewinsky called her and asked her to come get the gifts. Grand Jury Testimony of Betty Currie, 5/6/98, pp. 105–6, H. Doc. 105-316, p. 581. When asked if a contrary statement by Ms. Lewinsky-indicating that Ms. Currie had in fact spoken to the President about the gift transfer—would be false, Ms. Currie replied: "She may remember better than I. I don't remember.” Grand Jury Testimony of Betty Currie, 5/6/98, p. 126, H. Doc. 105–316, p. 584.

Further evidence before the Committee reveals that Betty Currie telephoned Monica Lewinsky regarding the gifts, and not the other way around:

Mr. Schippers: When Ms. Currie, when they wanted to get rid of the gifts, Ms. Currie went and picked them up, put them under her bed to keep them from anybody else. Another mission accomplished?

Mr. Starr: That's right.

Mr. Schippers: By the way, there has been some talk here that Monica said that she recalled that Betty Currie called her and said, either the President wants me to pick something up, or I understand you have something for me to pick up. Later, Ms. Currie backed off that and said, well, I am not sure, maybe Monica called me. In the material that you made available, you and your staff made available to us, there were 302s in which Monica said, I think when Betty called me, she was using her cell phone. Do you recall that, Judge Starr?

Mr. Starr: I do.

Mr. Schippers: And in that same material that is in your
office that both parties were able to review and that we
did, in fact, review, there are phone records of Ms. Currie;
are there not?
Mr. Starr: There are.

Mr. Schippers: And there is a telephone call on her cell
phone to Monica Lewinsky's home on the afternoon of De-
cember 28, 1997; isn't there?
Mr. Starr: That is correct.

Mr. Schippers: Once again, Monica is right and she has
been corroborated, right?

Mr. Starr: That certainly tends to corroborate Ms.

Lewinsky's recollection. Impeachment Hearing on Inquiry Pursuant to H. Res. 581, Thursday, November 19, 1998, Transcript pp. 407-409.

President Clinton testified before the grand jury, and reiterated to this Committee (Request for Admission number 26) that he did not recall any conversation with Ms. Currie on or about December 28, 1997, about gifts previously given to Ms. Lewinsky and that he never told Ms. Currie to take possession of gifts he had given Ms. Lewinsky. Grand Jury Testimony of President Clinton, 8/17/98, p. 50, H. Þoc. 105–311, p. 502; see also Grand Jury Testimony of

hases case. Additionallents about the gifts esident to provide

President Clinton, 8/17/98, pp. 113–114, H. Doc. 105–311, pp. 565– 66. This answer is false and misleading because the evidence reveals that Betty Currie did call Monica Lewinsky about the gifts and there is no reason for her to do so unless instructed by the President. Because she did not personally know of the gift issue, there is no other way Ms. Currie could have known to call Ms. Lewinsky about the gifts unless the President told her to do so. The President had a motive to conceal the gifts because both he and Ms. Lewinsky were concerned that the gifts might raise questions about their relationship. By confirming that the gifts would not be produced, the President ensured that these questions would not arise. The concealment and non-production of the gifts to the attorneys for Paula Jones allowed the President to provide false and misleading statements about the gifts at his deposition in the Jones case. Additionally, Ms. Lewinsky's testimony on this subject has been consistent and unequivocal; she provided the same facts in February, July and August. Betty Currie's cell phone records show that she placed a one minute call to Monica Lewinsky on the afternoon of December 28th.

b. The President made false and misleading statements before

the grand jury regarding his knowledge 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 were untrue The President provided the following perjurious, false and misleading testimony to the grand jury:

Q. Did you tell her to tell the truth?

A. Well, I think the implication was she would tell the truth. I've already told you that I felt strongly she could execute an affidavit that would be factually truthful, that might get her out of having to testify. Now, it obviously wouldn't if the Jones people knew this, because they knew if they could get this and leak it, it would serve their larger purposes, even if the judge ruled that she couldn't be a witness in that case. The judge later ruled she wouldn't be a witness in that case. The judge later ruled the case had no merit.

So, I knew that. And did I hope she'd be able to get out of testifying on an affidavit? Absolutely. Did I want her to execute a false affidavit? No, I did not.

Q. If Monica has stated that her affidavit that she didn't have a sexual relationship with you is, in fact, a lie, I take it you disagree with that.

A. No. I told you before what I thought the issue was there. I think the issue is how do you define sexual relationship. And there is no definition imposed on her at the time she executed the affidavit. Therefore, she was free to

give it any reasonable meaning. Grand Jury Testimony of President Clinton, 8/17/98, p. 119–120, H. Doc. 105–311, p. 571-572.

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