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

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

In that same January 23rd conversation with John Podesta, the President stated he was not alone with Monica Lewinsky in the Oval Office, and that Betty Currie was either in his presence or outside his office with the door open while he was visiting with Monica Lewinsky:

Q. 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?

A. 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.

Harold Ickes On or about January 26, 1998, The President had a conversation with Harold Ickes, in which he made statements to the effect that he did not have an affair with Monica Lewinsky:

Q. What did the President say about Monica Lewinsky?

A. 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")). 5. Explanation of the Rogan Amendment to Article I

The Committee adopted an amendment to Article I of the Resolution offered by Representative Rogan of California. Article I addresses certain statements which the President made during his grand jury testimony on August 17, 1997. More explicitly, the Article charges the President with providing perjurious, false, and misleading testimony governing the following topics:

The nature and details of his relationship with a subordinated
Government employee;

ure and overning th providing?. Moren

the 1974 Artisinguage simply frmore” of the f

1. The Comm perjurious, faine response

Prior testimony in a deposition he gave in a Federal civil rights action against brought against him in the case of Jones v. Clinton;

Prior false and misleading statements he allowed his attorney to make to a Federal judge in that civil rights action; and

His corrupt efforts to influence the testimony of witnesses and to impede the discovery of evidence in that civil rights ac

tion. The Rogan amendment supplements the language of Article I by specifying that the President willfully provided perjurious, false, and misleading testimony to the grand jury concerning any one or more of the four topics enumerated. In other words, contrary to his grand jury oath, the President provided perjurious, false, and misleading testimony about “one or more” of the four topics.

The Rogan language simply tracks identical language invoked in the 1974 Articles of Impeachment against President Nixon. Like the evidence in the Nixon precedent, the evidence in the instant case is sufficient to sustain President Clinton's culpability under Article I for his testimony concerning all four topics collectively, or each topic individually.

B. ARTICLE II—PERJURY IN THE CIVIL CASE 1. The Committee concluded that, in the civil case, the President

provided perjurious, false, and misleading testimony in a Fed

eral civil rights action in response to written questions 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.

The evidence reveals that the President Clinton made perjurious, false, and misleading statements in response to written interrogatories in the civil rights case of Jones v. Clinton. The perjurious, false, and misleading statements are set forth below: 1. Interrogatory Number 10: Please state the name, address, and

telephone number of each and every individual (other than Hil-
lary Rodham Clinton) with whom you had sexual relations
when you held any of the following positions:

a. Attorney General of the State of Arkansas;
b. Governor of the State of Arkansas;

c. President of the United States. On December 11, 1997, the Court issued an order modifying the scope of the interrogatories to incidents from May 8, 1986 to the present involving state or federal employees and compelling the President to answer the interrogatories.

The President's December 23, 1997, supplemental response to Interrogatory Number 10 (as modified by direction of the Court): None

at order mo86 to the Presi

2. Interrogatory Number 11: Please state the name, address, and

telephone number of each and every individual (other than Hil-
lary Rodham Clinton) with whom you sought to have sexual re-
lations when you held any of the following positions:

a. Attorney General of the State of Arkansas;
b. Governor of the State of Arkansas;

c. President of the United States. The same court order modifying the scope of the interrogatories to incidents from May 8, 1986 to the present involving state or federal employees and compelling the President to answer the interrogatories was applicable to this question.

The President's December 23, 1997, supplemental response to Interrogatory Number 10 (as modified by direction of the Court): None

It is clear from the evidence before the Committee that the President did have sexual relations with Monica Lewinsky, a young, subordinate federal employee in the Oval Office complex of the White House while he was President of the United States. It is also evident that he sought to have sexual relations with her. This evidence includes, as cited previously, the sworn testimony of Monica Lewinsky, corroborated by the testimony of others and by phone and entrance records. In addition, DNA evidence before the Committee reveals that the President's semen was found on Ms. Lewinsky's dress. 2. The Committee concluded that, in the civil case, the President

provided perjurious, false, and misleading testimony in a Fed

eral civil rights action in his deposition 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 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 and his corrupt efforts to influence the testimony of that employee.

The record indicates that on January 17, 1998, before beginning to respond to questions during a deposition in a civil rights lawsuit in which he was a named defendant, the President answered in the affirmative to the question, “Do you swear and affirm that your testimony will be the truth, the whole truth and nothing but the truth, so help you God.” In the President's Response for Admissions Number 5, the President admits that he took an oath to tell the truth before his deposition in the Jones v. Clinton case.

a. The President lied in his deposition about the nature of his

conduct with a subordinate federal employee who was a witness in the federal civil rights action brought against

him In the President's Deposition he admits that Monica Lewinsky is a federal employee:

Q. Now, do you know a woman named Monica
Lewinsky?

A. I do.
Q. How do you know her?

A. She worked in the White House for a while, first as
an intern, and then in, as the, in the legislative affairs of-

fice. Deposition of President Clinton, 1/17/97, p. 1.

The President was asked about his conduct with Monica Lewinsky and in his deposition he denied having sexual relations with Monica Lewinsky. The definition of sexual relations was: “For purposes of this deposition, a person engages in 'sexual relations' when the person knowingly engages in or causes (1) contact with the genitalia, anus, groin, breast, inner thigh, or buttocks of any person with an intent to arouse or gratify the sexual desire of any person; (2) contact between any part of the person's body or an object and the genitals or anus of another person; or (3) contact between the genitals or anus of the person and any part of another person's body. 'Contact means intentional touching, either directly or through clothing.”

Q. Did you have an extramarital sexual affair with
Monica Lewinsky?

A. No.

Q. If she told someone that she had a sexual affair with you beginning in November of 1995, would that be a lie?

A. It's certainly not the truth. It would not be the truth.

Q. I think I used the term "sexual affair.” And so the
record is completely clear, have you ever had sexual rela-
tions with Monica Lewinsky, as that term is defined in
Deposition Exhibit 1, as modified by the Court.

A. I have never had sexual relations with Monica
Lewinsky. I've never had an affair with her.
Deposition of President Clinton, 1/17/98, p. 78.

According to the sworn testimony of Monica Lewinsky, she and the President had 11 sexual encounters, 8 while she worked at the White House and 2 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 and that he lied about their conduct. According to Ms. Lewinsky, she performed oral sex on the President; he never performed oral sex on her. OIC Referral, H. Doc. 105–310, p. 17.

The record indicates an agreement to deny the conduct and that a relationship existed between the President and Monica Lewinsky:

Q. Had you talked with (the President] earlier (than December 17] about * * * false explanations about what you were doing visiting him on several occasions?

A. Several occasions throughout the entire relationship * **. It was the pattern of the relationship to sort of con

ceal it. Grand Jury Testimony of Monica Lewinsky, 8/6/98, p. 124, H. Doc. 105-311, p. 844.

were doing visiting him false explanation earlier (than De

that Moncord indicar draft alaking

The Committee has concluded that the President lied under oath about his relationship with Monica Lewinsky in his deposition in accord with an agreement to lie developed earlier.

6. The President lied in his deposition after being asked if

anyone had reported to him within the past two weeks
that they had had a conversation with Monica Lewinsky

concerning the Jones v. Clinton lawsuit
Q. * * * within the past two weeks has anyone reported
to you that they had had a conversation with Monica
Lewinsky concerning this lawsuit?

A. I don't believe so. I'm sorry, I just don't believe so. Deposition of President Clinton, 1/17/98, pp. 12–13 of public copy.

The record indicates that a telephone conversation took place on January 6, 1998, with Vernon Jordan and President Clinton during which President Clinton discussed Monica Lewinsky's affidavit, yet to be filed, in the case of Jones v. Clinton. See Telephone Calls, Table 35, included in Appendix G as referenced in note 928, H. Doc. 105–310, p. 108 (Vernon Jordan telephones the President less than 30 minutes after speaking with Monica Lewinsky over the telephone about her draft affidavit).

The record indicates that the President had knowledge of the fact that Monica Lewinsky executed for filing an affidavit in the case of Jones v. Clinton on January 7, 1998.

Q.... [Y]ou conveyed . . . both to Betty Currie and to the President-namely, that you knew Ms. Lewinsky had signed the affidavit (on January 7, 1998]?

A. “Right.” Grand Jury Testimony of Vernon Jordan, 5/5/98, p. 223, H. Doc. 105–316, p. 1828.

The record indicates that on or about January 7, 1998, the President had a discussion with Vernon Jordan in which Mr. Jordan mentioned that Monica Lewinsky executed for filing an affidavit in the case of Jones v. Clinton.

Q. Okay, do you believe that it would have been during one of these calls (phone conversations between the President and Vernon Jordan on January 7, 1998] that you would have indicated to the President that Ms. Lewinsky had, in fact, signed the affidavit?

A. That, too, is a reasonable assumption. Grand Jury Testimony of Vernon Jordan, 5/5/98, p. 224, H. Doc. 105–316, p. 1828.

Furthermore, the President acknowledged before the grand jury and to this Committee, that Vernon Jordan discussed Monica Lewinsky's affidavit with him and within two weeks of his deposition. “As I testified before the grand jury, 'I believe that (Mr. Jordan) did notify us when she signed the affidavit. While I do not remember the timing, as I told the grand jury, I have no reason to doubt Mr. Jordan's statement that he notified me about the affidavit around January 7, 1998." See Request for Admission number 29 and Grand Jury testimony of President Clinton, 8/17/98, H. Doc. 105–311, p. 525.

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