deposition, in which he discussed subpoenaed gifts with her, including a specific gift, a hat pin. His response of "I don't recall" was perjurious, false, and misleading, as was his explanation to this Committee. Deposition of President Clinton in the case of Jones v. Clinton, 1/17/98, p. 75. h. Request for Admission, Number 43 Q. Do you admit or deny that you gave false and misleading testimony under oath in your deposition in the case of Jones v. Clinton when you responded "once or twice" to the question "has Monica Lewinsky ever given you any gifts?" A. My testimony was not false and misleading. As I have testified previously, I give and receive numerous gifts. Before my January 17, 1998, deposition, I had not focused on the precise number of gifts Ms. Lewinsky had given me. App. At 495-98. My deposition testimony made clear that Ms. Lewinsky had given me gifts; at the deposition, I recalled "a book or two" and a tie. Dep. At 77. At the time, those were the gifts I recalled. In response to OIC inquiries, after I had had a chance to search my memory and refresh my recollection, I was able to be more responsive. However, as my counsel have informed the OIC, in light of the very large number of gifts I receive, there might still be gifts from Ms. Lewinsky that I have not identified. The President's Request for Admission number 43 is also false and misleading because in it he continues to insist that he was being truthful when he responded "once or twice" at the deposition when he was asked if Monica Lewinsky had ever given him any gifts. In fact, the evidence shows that Ms. Lewinsky gave the President approximately 38 gifts presented on numerous occasions. See chart H. Doc. 105-311, pp. 1251-61; Deposition of President Clinton in the case of Jones v. Clinton, 1/17/98, p. 76. i. Request for Admission, Number 52 Q. Do you admit or deny that on January 18, 1998, at or about 5:00 P.M., you had a meeting with Betty Currie at which you made statements similar to any of the following regarding your relationship with Monica Lewinsky? You were always there when she was there, right? We were never really alone. You could see and hear everything. Monica came on to me, and I never touched her right? She wanted to have sex with me and I couldn't do that. A. When I met with Ms. Currie, I believe that I asked her certain questions, in an effort to get as much information as quickly as I could and made certain statements, although I do not remember exactly what I said. See App. At 508. Some time later, I learned that the Office of Independent Counsel was involved and that Ms. Currie was going to have to testify before the grand jury. After learning this, I stated in my grand jury testimony, I told Ms. Currie, "Just relax, go in there and tell the truth.” App. At 591. j. Request for Admission, Number 53 Q. Do you admit or deny that you had a conversation with Betty Currie within several days of January 18, 1998, in which you made statements similar to any of the following regarding your relationship with Monica Lewinsky? You were always there when she was there, right? We were never really alone. You could see and hear everything. Monica came on to me, and I never touched her right? She wanted to have sex with me and I couldn't do that. A. I previously told the grand jury that, "I don't know that I" had another conversation with Ms. Currie within several days of January 18, 1998, in which I made statements similar to those quoted above. "I remember having this [conversation] one time." App. At 592. I further explained. "I do not remember how many times I talked to Betty Currie or when. I don't. I can't possibly remember that. I do remember, when I first heard about this story breaking, trying to ascertain what the facts were, trying to ascertain what Betty's perception was. I remember that I was highly agitated, understandably, I think." App at 593. I understand that Ms. Currie has said a second conversation occurred the next day that I was in the White House (when she was), Supp. At 535-36, which would have been Tuesday, January 20, before I knew about the grand jury investigation. The President provided this committee with false and misleading answers to Request for Admissions number 52 and 53. He denies "coaching" Betty Currie after his deposition in the case of Jones v. Clinton; instead, he responded "I believe I asked her certain questions, in an effort to get as much information as quickly as I could." In number 53, the President quoted his grand jury testimony, "I do not remember how many times I talked to Betty Currie or when. I don't, I can't possibly remember that. I do remember, when I first heard about this story breaking, trying to ascertain what the facts were, trying to ascertain what Betty's perception was." Grand Jury testimony of President Clinton, 8/17/98, H. Doc. 105-311, p. 593. These answers are not credible because the statements he made to Ms. Currie were clearly false. Why would he be trying to get information from her about false statements or refresh his recollection concerning falsehoods? When President Clinton was asked in his deposition whether it would be extraordinary for Betty Currie to be in the White House between midnight and six a.m., the President answered in part, "those are questions you'd have to ask her." Furthermore, he invoked Betty Currie's name numerous times throughout the deposition, oftentimes asserting that Ms. Lewinsky was around the oval office to see Ms. Currie and that Ms. Currie talked about Vernon Jordan helping Ms. Lewinsky and Betty talked with Ms. Lewinsky about her move to New York. After mentioning Betty Currie so often during his deposition, it was very logical for the President to assume that the lawyers for Paula Jones may call her as a witness. That explains why the President called her about two hours after the completion of his deposition and asked her to come into the office the next day, which was a Sunday. In her testimony, Ms. Currie indicated that the President's remarks were "more like statements than questions." Based on his demeanor and the manner in which he asked the questions, she concluded that the President wanted her to agree with him. Ms. Currie thought that the President was attempting to gauge her reaction, and appeared concerned. Grand Jury Testimony of Betty Currie, 1/17/98, pp. 71-76, H. Doc. 105-316, pp. 559-60. The evidence clearly reveals the President was not trying to refresh his recollection during a conversation with Betty Currie on January 18, 1998, rather it reveals that President Clinton was attempting to influence the testimony of Betty Currie, by coaching her to recite inaccurate answers to possible questions that might be asked of her if called to testify in the case of Jones v. Clinton. 2. Explanation of the Gekas Amendment to Article IV Representative Gekas of Pennsylvania offered an amendment to strike paragraphs one, two, and three of Article IV. The amendment was adopted by a vote of 29-5, with three Members voting present. The stricken paragraphs asserted that President Clinton abused the office of the President by lying to the American people, aides and cabinet officials and by frivolously asserting executive privilege in order to impede a federal investigation. The remaining paragraph of Article IV charges that the President abused the office of the President by making perjurious, false and misleading statements in his response to written requests for admission submitted to him by this Committee as part of its impeachment inquiry. The Committee's general conclusion regarding Mr. Gekas's amendment was summed up by Mr. Goodlatte: I think that no one should take from the decision to delete these three sections of the article that we don't severely abhor the actions of the President in regard to these three sections. I believe that the allegations contained in them are all true. I believe the President of the United States did lie to the American people. I do believe the President lied to his cabinet and others, and I think that he hoped that in so doing that they would carry forth his lies and I think that is wrong as well. And I do believe that the President has improperly exercised executive privilege. But, I also don't believe that any of these three items are impeachable offenses. And as a result, I'll support this amendment. Article IV originally read as follows: 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 repeatedly 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 con travened the laws governing the integrity of the judicial and legislative branches and the truth- seeking purpose of coordinate investigative proceedings. This misuse and abuse of office has included one or more of the following: (1) As President, using the attributes of office, William Jefferson Clinton willfully made false and misleading public statements for the purpose of deceiving the people of the United States in order to continue concealing his misconduct and to escape accountability for such misconduct. (2) As President, using the attributes of office, William Jefferson Clinton willfully made false and misleading public statements to members of his cabinet, and White House aides, so that these Federal employees would repeat such false and misleading statements publicly, thereby utilizing public resources for the purpose of deceiving the people of the United States, in order to continue concealing his misconduct and to escape accountability for such misconduct. The false and misleading statements made by William Jefferson Clinton to members of his cabinet and White House aides were repeated by those members and aides, causing the people of the United States to receive false and misleading information from high government officials. (3) As President, using the Office of the White House Counsel, William Jefferson Clinton frivolously and corruptly asserted executive privilege, which is intended to protect from disclosure communications regarding the constitutional functions of the Executive, and which may be exercised only by the President, with respect to communications other than those regarding the constitutional functions of the Executive, for the purpose of delaying and obstructing a Federal criminal investigation and the proceedings of a Federal grand jury. (4) 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 admissions 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 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, 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, Paragraph (1) In consideration of the drafting of Article IV, several members had expressed grave concern regarding the President's lies to the American people with respect to the Paula Jones lawsuit, Monica Lewinsky and his potential criminal culpability. President Clinton made six public statements denying allegations that he had an improper sexual relationship with Monica Lewinsky or obstructed justice in the federal civil rights case of Jones v. Clinton. The Committee concluded that the public trust, which is held by the President of the United States, was deliberately abused by President Clinton when he made these false statements. The intent of President Clinton making false statements to the American public was to utilize the power of the office of the President and convince the public that these allegations were false. The political powers that accompany the office of the President do not include misleading the American public in an attempt to avoid or thwart federal investigation. President Clinton addressed the nation on August 17, 1998 and continued to mislead the American public. Although President Clinton took this opportunity to disclose his inappropriate sexual relationship, he stated that he had testified truthfully before the grand jury and maintained that his statements in his civil deposition were still "legally accurate." This statement was made from the map room of the White House and aired across the country on almost every radio or television station. The statement was not related to any official business of the White House, it was made in the wake of a federal investigation, and it was designed to mislead. This statement was unlike any other statement President Clinton has ever made and only analogous to a handful of other Presidential statements throughout our history. However, the Committee believes this statement was designed to mislead the American public. President Clinton has publicly apologized to the American public for his inappropriate relationship but he has continually denied any criminal allegations. The President holds the highest office in the country and the trust of the people. The Committee believes his failure to address these criminal allegations while he has apologized for his personal acts is a deliberate attempt by President Clinton to cloud the issues before the American public. În 1974, the current distinguished Ranking Member, Representative John Conyers, noted that the American public cannot judge a chief executive if he does not or will not speak to the American people truthfully. The chronology of the President's lies to the American public began almost immediately after the Washington Post published an article regarding the Lewinsky-Clinton affair on Wednesday, January 21, 1998. The White House learned about the story on the night of January 20th. The President spoke with Bob Bennett between 12:08 a.m. and 12:39 a.m. on the 21st. Mr. Bennett was quoted in the Washington Post article of the 21st as saying, "The President adamantly denies he ever had a relationship with Ms. Lewinsky and she has confirmed the truth of that." The White House issued a statement later that same the day in response to |