ARTICLE I

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

On August 17, 1998, William Jefferson Clinton swore to tell the truth, the whole truth, and nothing but the truth before a Federal grand jury of the United States. Contrary to that oath, William Jefferson Clinton willfully provided perjurious, false and misleading testimony to the grand jury concerning one or more of the following: (1) the nature and details of his relationship with a subordinate Government employee; (2) prior perjurious, false and misleading testimony he gave in a Federal civil rights action brought against him; (3) prior false and misleading statements he allowed his attorney to make to a Federal judge in that civil rights action; and (4) his corrupt efforts to influence the testimony of witnesses and to impede the discovery of evidence in that civil rights action.

In doing 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 of 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

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 willfully corrupted 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 rights action brought against him. Contrary to that oath, William Jefferson Clinton willfully provided perjurious, false and mislead

ing 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 of 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 III

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 would have been harmful to him.

(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.

(6) On or about January 18 and January 20-21, 1998, William Jefferson Clinton related a false and misleading account of events relevant to a Federal civil rights action brought against him to a potential witness in that proceeding, in order to corruptly influence the testimony of that witness.

(7) On or about January 21, 23 and 26, 1998, William Jefferson Clinton made false and misleading statements to potential witnesses in a Federal grand jury proceeding in order to corruptly influence the testimony of those witnesses. The false and misleading statements made by William Jefferson Clinton were repeated by the witnesses to the grand jury, causing the grand jury to receive false and misleading information.

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 of 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 IV

Using the powers and influence of the office of 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 disregard of his constitutional duty to take care that the laws be faithfully executed, has engaged in conduct that resulted in misuse and abuse of his high office, impaired the due and proper administration of justice and the conduct of lawful inquiries, and contravened the authority of the legislative branch and the truth seeking purpose of a coordinate investigative proceeding, in that, as President, William Jefferson Clinton refused and failed to respond to certain written requests for admission and willfully made perjurious, false and misleading sworn statements in response to certain written requests for admission propounded to him as part of the impeachment inquiry authorized by the House of Representatives of the Congress of the United States. William Jefferson Clinton, in refusing and failing to respond and in making perjurious, false and misleading statements, assumed to himself functions and judgments necessary to the exercise of the sole power of impeachment vested by the Constitution in the House of Representatives and exhibited contempt for the inquiry.

In doing 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 subver

sive of 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.

I. INTRODUCTION

"Equal Justice Under Law"-That principle so embodies the American constitutional order that we have carved it in stone on the front of our Supreme Court. The carving shines like a beacon from the highest sanctum of the Judicial Branch across to the Capitol, the home of the Legislative Branch, and down Pennsylvania Avenue to the White House, the home of the Executive Branch. It illuminates our national life and reminds those other branches that despite the tumbling tides of politics, ours is a government of laws and not of men. It was the inspired vision of our founders and framers that the Judicial, Legislative, and Executive branches would work together to preserve the rule of law.

But "Equal Justice Under Law" amounts to much more than a stone carving. Although we cannot see or hear it, this living, breathing force has real consequences in the lives of average citizens every day. Ultimately, it protects us from the knock on the door in the middle of the night. More commonly, it allows us to claim the assistance of the government when someone has wronged us-even if that person is stronger or wealthier or more popular than we are. In America, unlike other countries, when the average citizen sues the Chief Executive of our nation, they stand equal before the bar of justice. The Constitution requires the judicial branch of our government to apply the law equally to both. That is the living consequence of "Equal Justice Under Law."

The President of the United States must work with the Judicial and Legislative branches to sustain that force. The temporary trustee of that office, William Jefferson Clinton, worked to defeat it. When he stood before the bar of justice, he acted without authority to award himself the special privileges of lying and obstructing to gain an advantage in a federal civil rights action in the United States District Court for the Eastern District of Arkansas, in a federal grand jury investigation in the United States District Court for the District of Columbia, and in an impeachment inquiry in the United States House of Representatives. His resistance brings us to this most unfortunate juncture.

So "Equal Justice Under Law" lies at the heart of this matter. It rests on three essential pillars: an impartial judiciary, an ethical bar, and a sacred oath. If litigants profane the sanctity of the oath, "Equal Justice Under Law" loses its protective force. Against that backdrop, consider the actions of President Clinton.

On May 27, 1997, the nine justices of the Supreme Court of the United States unanimously ruled that Paula Corbin Jones could pursue her federal civil rights actions against William Jefferson Clinton. Clinton v. Jones, 520 U.S. 681 (1997). On December 11, 1997, United States District Judge Susan Webber Wright ordered President Clinton to provide Ms. Jones with answers to certain routine questions relevant to the lawsuit. Acting under the author

ity of these court orders, Ms. Jones exercised her rights-rights that every litigant has under our system of justice. She sought answers from President Clinton to help her prove her case against him-just as President Clinton sought and received answers from her. President Clinton used numerous means to prevent her from getting truthful answers.

On December 17, 1997, he encouraged a witness, whose truthful testimony would have helped Ms. Jones, to file a false affidavit in the case and to testify falsely if she were called to testify in the case. On December 23, 1998, he provided, under oath, false written answers to Ms. Jones's questions. On December 28, 1997, he began an effort to get the witness to conceal evidence that would have helped Ms. Jones. Throughout this period, he intensified efforts to provide the witness with help in getting a job to ensure that she carried out his designs.

On January 17, 1998, President Clinton provided, under oath, numerous false answers to Ms. Jones's questions during his deposition. In the days immediately following the deposition, he provided a false and misleading account to another witness, Betty Currie, in hopes that she would substantiate the false testimony he gave in the deposition. These actions denied Ms. Jones her rights as a litigant, subverted the fundamental truth seeking function of the United States District Court for the Eastern District of Arkansas, and violated President Clinton's constitutional oath to "preserve, protect and defend the Constitution of the United States" and his constitutional duty to "take care that the laws be faithfully executed."

Beginning shortly after his deposition, President Clinton became aware that a federal grand jury empaneled by the United States District Court for the District of Columbia was investigating his actions before and during his civil deposition. President Clinton made numerous false statements to potential grand jury witnesses in hopes that they would repeat these statements to the grand jury. On August 17, 1998, President Clinton appeared before the grand jury by video and, under oath, provided numerous false answers to the questions asked. These actions impeded the grand jury's investigation, subverted the fundamental truth seeking function of the United States District Court for the District of Columbia, and violated President Clinton's constitutional oath to "preserve, protect and defend the Constitution of the United States" and his constitutional duty to "take care that the laws be faithfully executed."

President Clinton's actions then led to this inquiry. On October 8, 1998, the United States House of Representatives passed House Resolution 581 directing the Committee on the Judiciary to begin an inquiry to determine whether President Clinton should be impeached. As part of that inquiry, the Committee sent written requests for admission to him. On November 27, 1998, President Clinton provided, under oath, numerous false statements to this Committee in response to the requests for admission. These actions impeded the committee's inquiry, subverted the fundamental truth seeking function of the United States House of Representatives in exercising the sole power of impeachment, and violated President Clinton's constitutional oath to "preserve, protect and defend the