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c. The President lied in his deposition about his being alone

or in certain locations with a subordinate federal employee who was a witness in the action brought against

him President Clinton gave the following testimony under oath in his deposition in the case of Jones v. Clinton regarding the subject:

Q. Is it true that when she worked at the White House she met with you several times?

A. I don't know about several times. There was a period when the Republican Congress shut the government down that the whole White House was being run by interns, and she was assigned to work back in the chief of staffs office, and we were all working there, and so I saw her on two or three occasions then, and then when she worked at the White House, I think there was one or two other times

when she brought some documents to me. Deposition of President Clinton, 1/17/98, pp. 50–51.

Q. At any time were you and Monica Lewinsky alone in the hallway between the Oval Office and this kitchen area?

A. I don't believe so, unless we were walking back to the
back dining room with the pizzas. I just, I don't remember.
I don't believe we were alone in the hallway, no.

Q. Are there doors at both ends of the hallway?
A. They are, and they're always open.

Q. At any time have you and Monica Lewinsky ever
been alone together in any room in the White House?

A. I think I testified to that earlier. I think that there is a, it is—I have no specific recollection, but it seems to me that she was on duty on a couple of occasions working for the legislative affairs office and brought me some things to sign, something on the weekend. That's I have a general memory of that.

Q. Do you remember anything that was said in any of those meetings.

A. No. You know, we just have conversation. I don't re

member. Deposition of President Clinton, 1/17/98, p. 58.

The record indicates that a plan existed to cover the fact that they were alone and were having a sexual relationship. Monica Lewinsky provided the following testimony under oath regarding this subject:

Q. I would like to ask you some questions about any steps you took to keep your relationship with the President secret.

A. A lot.

Q. All right. Well, why don't we just ask the question open-endedly and we'll follow up.

A. Okay. I'm sure, as everyone can imagine, that this is a kind of relationship that you keep quiet, and we both wanted to be careful being in the White House. Whenever

I would visit him during-when-during my tenure at the White House, we always—unless it was sort of a chance meeting on the weekend and then we ended up back in the office, we would usually plan that I would either bring papers, or one time we had accidentally bumped into each other in the hall and went from that way, so then we planned to do that again because that seemed to work well. But we always there was always some sort of a cover.

Q. When you say you planned to bring papers, did you ever discuss with the President the fact that you would try to use that as a cover?

A. Yes.

Q. Okay. What did the two of you say in those conversations?

A. I don't remember exactly. I mean, in general, it might have been something like me saying, well, maybe once I got there kind of saying, “Oh, gee here are your letters,” wink, wink, wink, and him saying: “Okay that's good,” or

Q. And as part of this concealment, if you will, did you carry around papers when you went to visit the President while you worked at Legislative Affairs?

A. Yes, I did.

Q. Did you ever actually bring him papers to sign as
part of business?

A. No.
Q. Did you actually bring him papers at all?
A. Yes.
Q. All right. And tell us a little about that.

A. It varied. Sometimes it was just actual copies of let-
ters. One time I wrote a really stupid poem. Sometimes I
put gifts in the folder which I brought.

Q. And even on those occasions, was there a legitimate business purpose to that?

A. No. Grand Jury Testimony of Monica Lewinsky, 8/6/98, pp. 53–55, H. Doc. 105–311, p. 977.

President Clinton was also asked during his deposition on January 17, 1998:

Q. Has it ever happened that a White House record was
created that reflected that Betty Currie was meeting with
Monica Lewinsky when in fact you were meeting with
Monica Lewinsky?

A. Not to my knowledge.
Deposition Testimony of President Clinton in the case of Jones v.
Clinton, 1/17/98.

The record indicates the President had such discussions with Monica Lewinsky prior to December 17, 1997 that Betty Currie should be the one to clear Ms. Lewinsky in to see him so that Ms. Lewinsky could say that she was visiting with Ms. Currie instead of with him. Monica Lewinsky provided the following testimony under oath regarding this subject:

Q. Did you ever (prior to your conversation with the
President on December 17] have discussions with the
President about what you would say about your frequent
visits with him after you had left legislative affairs?

A. Yes.
Q. Yes. What was that about?

A. I think wewe discussed that—you know, the back-
wards route of it was that Betty always needed to be the
one to clear me in so that, you know, I could always say

I was coming to see Betty. Grand Jury Testimony of Monica Lewinsky, 8/6/98, p. 55, H. Doc. 105-311, p. 977.

Q. Did you come to have a telephone conversation with
the President on December 17?

A. Yes ...
Q. Tell us how the conversation went from there ..

A. . . . At some point in the conversation, and I don't
know if it was before or after the subject of the affidavit
came up, he sort of said, “You know, you can always say
you were coming to see Betty or that you were bringing me
letters." Which I understood was really a reminder of

things that we had discussed before. Grand Jury Testimony of Monica Lewinsky, 8/6/98, p. 123, H. Doc. 105-311, p. 843.

In his grand jury testimony, the President himself admits that he was alone with Ms. Lewinsky: "When I was alone with Ms. Lewinsky on certain occasions in early 1996 and once in early 1997, I engaged in conduct that was wrong." Grand Jury Testimony of President Clinton, 8/17/98, pp. 8–9, H. Doc. 105–311, pp. 460– 61.

d. The President lied in his deposition about his knowledge

of gifts exchanged between himself and a subordinate federal employee who was a witness in the action brought

against him The record indicates that the President did present each of these items as gifts to Monica Lewinsky:

1. A lithograph
2. A hatpin
3. A large “Black Dog” canvas bag
4. A large "Rockettes" blanket
5. A pin of the New York skyline
6. A box of "cherry chocolates"
7. A pair of novelty sunglasses
8. A stuffed animal from the “Black Dog"
9. A marble bear's head
10. A London pin
11. A shamrock pin
12. An Annie Lennox compact disc

13. Davidoff cigars A chart prepared as part of her testimony before the Grand Jury details Monica Lewinsky's visits to the President and the exchange of gifts during those visits is contained in H. Doc. 105-311, pp. 1251-61.

52-759 98-3

The record indicates that the President gave false and misleading testimony in his deposition when he responded "once or twice” to the question “has Monica Lewinsky ever given you any gifts?"

Q. Has Monica Lewinsky ever given you any gifts?

A. Once or twice. I think she's given me a book or two. Deposition of President Clinton in the case of Jones v. Clinton, 117/98, p. 76.

The evidence shows that Ms. Lewinsky gave the President approximately a total of 38 gifts presented on numerous occasions. (See chart in House Document 105-311, pp. 1251-61.)

The record indicates that the President had a discussion with Monica Lewinsky regarding the gifts he had given to Ms. Lewinsky that were subpoenaed in the case of Jones v. Clinton.

A. Wewe really spent maybe about five no more than ten minutes talking about the Paula Jones case on [December 28] . . . I brought up the subject of the case because I was concerned about how I had been brought into the case and been put on the witness list . . . And then at some point I said to him, "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.

Furthermore, the evidence shows that President Clinton and Monica Lewinsky discussed the hat pin gift on December 28, 1997, after Ms. Lewinsky received a subpoena calling for her to produce all gifts she received from Mr. Clinton, including any hat pins. Ms. Lewinsky stated under oath before the grand jury that “I mentioned that I had been concerned about the hat pin being on the subpoena and he said that that had sort of concerned him also and asked me if I had told anyone that he had given me the hat pin and I said no.” Grand Jury Testimony of Monica Lewinsky, 8/6/98, p. 152, H. Doc. 105–311, p. 1000.

The record indicates that the President stated that he did not recall giving gifts to Ms. Lewinsky even though he had knowledge:

Q. Well, have you ever given any gifts to Monica
Lewinsky?

A. I don't recall. Do you know what they were?
Q. A hat pin?

A. I don't, I don't remember. But I certainly, I could

have. Deposition of President Clinton in the case of Jones v. Clinton, 1/17/98, p. 75. See also request for admission number 41 for evidence of numerous gifts Mr. Clinton gave to Ms. Lewinsky.

e. The President lied in his deposition about his knowledge

about whether he had ever spoken to a subordinate 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. President Clinton was asked about this subject during his deposition on January 17, 1998:

Q. Did you ever talk with Monica Lewinsky about the possibility that she might be asked to testify on this case?

A. Bruce Lindsey, I think Bruce Lindsey told me that she was, I think maybe that's the first person (who] told me she was. I want to be as accurate as I can.

Q. I believe I was starting to ask you a question a moment ago and we got sidetracked. Have you ever talked to Monica Lewinsky about the possibility that she might be asked to testify in this lawsuit?

A. I'm not sure, and let me tell you why I'm not sure. It seems to me the, the, the I want to be as accurate as I can here. Seems to me the last time she was there to see Betty before Christmas we were joking about how youall, with the help of the Rutherford Institute, were going to call every woman I'd ever talked to and ask them that, and so I said you would qualify, or something like that. I don't think we ever had more of a conversation than that

about it. . Deposition Testimony of President Clinton in the case of Jones v. Clinton, 1/17/98 pp. 70–71.

The record indicates that the President did indeed tell Monica Lewinsky about the appearance of her name on December 17, 1998:

Did you come to have a telephone conversation with the President on December 17?

A. Yes . . . he told me he had some more bad news, that he had seen the witness list for the Paula Jones case and my name was on it ... He told me that it didn't necessarily mean that I would be subpoenaed, but that that was a possibility, and if I were subpoenaed, that I should contact Betty and let Betty know that I had received the

subpoena. Grand Jury Testimony of Monica Lewinsky, 8/6/98, p. 123, H. Doc. 105–311, p. 843.

The record indicates that the President on or about December 17, 1997, made the suggestion to Monica Lewinsky that the submission of an affidavit in the case of Jones v. Clinton might prevent her from having to testify:

A. I believe I probably asked him, you know, what should I do in the course of that and he suggested, he said, "Well, maybe you can sign an affidavit.”

Q. When he said that you might sign an affidavit, what did you understand it to mean at that time?

A. I thought that signing an affidavit could range from anywhere—the point of it would be to deter or to prevent me from being deposed and so that that could range from

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