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Monica Lewinsky's name appeared on a witness list provided by the plaintiffs.

Q. From whom did you receive the witness list?

A. Again, you know, I–I'm-we're walking down that road. You know, I don't know if I can respond to that.

Q. When did you receive the witness list?

A. I think I can—well, let me see if I can answer when-Lindsey 2/18/98 GJT at 96–97; Supplemental Materials (H. Doc. 105–316) at 2363.

12. "Has there been a concerted effort known to you, either conducted out of your office or in some other office in the White House, that is designed to criticize the Independent Counsel investigation and this grand jury's work?” Lindsey 2/18/98 GJT at 103; Supplemental Materials at (H. Doc. 105- 316) 2364.

13. “What was discussed [between Mr. Lindsey and Vernon Jordan about the Paula Jones case on January 18]?” Lindsey 2/18/98 GJT at 108, 112; Supplemental Materials (H. Doc. 105–316) at 2365, 2366.

14. “What did you discuss [between Mr. Lindsey, Ms. Mills, and Vernon Jordan about the Paula Jones case on January 19]?” Lindsey 2/18/98 GJT at 113; Supplemental Materials (H. Doc. 105316) at 2366.

15. After this exchange, Mr. Lindsey was asked a number of questions about when he would assert executive privilege that repeated the questions set out above and his assertions of the privilege. Lindsey 2/18/98 GJT at 115–22; Supplemental Materials (H. Doc. 105–316) at 2366–68.

16. "What was discussed at the meeting—the subject-I mean, the substance of the meeting (among Mr. Lindsey, Ms. Mills, Mr. Ruff, the President, and the First Lady on February 17]. I am now asking you.” Lindsey 2/19/98 GJT at 7; Supplemental Materials (H. Doc. 105–316) at 2389.

17. What was the substance of what occurred at the meeting [among Mr. Lindsey, Ms. Mills, Mr. Ruff, Mr. Breuer, Mr. Eggleston, and the President on February 18]?” Lindsey 2/19/98 GJT at 8; Supplemental Materials (H. Doc. 105–316) at 2389.

18. "What did you talk about at this meeting (among Mr. Lindsey, the President's private lawyers, and the President) on the [January] 17th-before the [President's] deposition?” Lindsey 2/19/ 98 GJT at 11; Supplemental Materials (H. Doc. 105–316) at 2389.

19. “What was discussed with regard to Monica Lewinsky (among Mr. Lindsey, the President's private lawyers, and the President during the breaks in the President's deposition]?” Lindsey 2/19/98 GJT at 13; Supplemental Materials (H. Doc. 105–316) at 2390.

20. “Again what was discussed at that meeting [among Mr. Lindsey, Mr. Bowles, and the President shortly after the President's deposition]?” Lindsey 2/19/98 GJT at 14; Supplemental Materials (H. Doc. 105–316) at 2390.

21. “At any of these meetings that occurred that day—that is, the day of the (January] 17th-did Betty Currie's name come up?" Lindsey 2/19/98 GJT at 14; Supplemental Materials (H. Doc. 105

316) sty 2/19/98 GJY al 7th-did Berccurred tha

22. "What was said during that conversation [i.e. Mr. Lindsey's phone conversation with the President in the early morning hours

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of January 21, the day the Lewinsky story was first published in the Washington Post]?” Lindsey 2/19/98 GJT at 42; Supplemental Materials (H. Doc. 105–316) at 2394.

23. “What did he [Mr. McCurry] say occurred in a meeting among White House staff in the morning of January 21, the day the Lewinsky story was first published in the Washington Post]?” Lindsey 2/19/98 GJT at 44; Supplemental Materials (H. Doc. 105– 316) at 2395.

24. “And you will not tell us about the substance of what occurred with your conversation with Mr. McCurry (about a meeting among White House staff in the morning of January 21, the day the Lewinsky story was first published in the Washington Post]?” Lindsey 2/19/98 GJT at 45; Supplemental Materials (H. Doc. 105– 316) at 2395.

25. "Tell us everything that occurred in the 10 minutes that you talked about the Monica Lewinsky matter (in a meeting among White House Counsel's Office staff, White House press staff, and the President on January 21, the day the Lewinsky story was first published in the Washington Post]?” Lindsey 2/19/98 GJT at 48; Supplemental Materials (H. Doc. 105–316) at 2395.

26. “What did you talk to him the President's personal aide, Stephen Goodin) about [shortly after the Lewinsky story broke]?” Lindsey 2/19/98 GJT at 49; Supplemental Materials (H. Doc. 105– 316) at 2396.

27. “What did you [Mr. Lindsey] say, and what did he [Mr. McGrath, an attorney for a witness] say [in a telephone conversation that occurred in early February]?” Lindsey 2/19/98 GJT at 51; Supplemental Materials (H. Doc. 105–316) at 2396.

28. “What did you (Mr. Lindsey and Mr. Podesta's lawyer) talk about (in a conversation that occurred in early February]?” Lindsey 2/19/98 GJT at 53; Supplemental Materials (H. Doc. 105–316) at 2396.

29. “You know they [i.e. other attorneys in the White House Counsel's Office] have (spoken to Betty Currie's attorney]? How do you know that?” Lindsey 2/19/98 GJT at 54; Supplemental Materials (H. Doc. 105–316) at 2396.

30. “Q. Are you prepared to answer any questions about conversations you are aware of about Monica Lewinsky that occurred among White House staff?

A. I believe the answer is that I'm not because of the reasons I stated: the presidential communication, the deliberative process, and/or the attorney-client privilege.” Lindsey 2/19/98 GJT at 59; Supplemental Materials (H. Doc. 105–316) at 2397.

31. “Are you prepared to tell us about your discussion with Lanny Breuer about that [i.e. Mr. Breuer's conversation with the attorney for witness, Michael McGrath]?” Lindsey 2/19/98 GJT at 60; Supplemental Materials (H. Doc. 105–316) at 2397.

32. Towards the end of Mr. Lindsey's appearance before the grand jury on February 19, he gave a lengthy explanation of his view of the various privileges that he claimed. Lindsey 2/19/98 GJT at 64–79; Supplemental Materials (H. Doc. 105–316) at 2399–401.

33. “And you decline to answer either one-the substance of either one (of Mr. Lindsey's meetings with Mickey Kantor, one of the

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President's private attorneys, after January 20th]?” Lindsey 2/19/ 98 GJT at 81; Supplemental Materials (H. Doc. 105–316) at 2401.

34. “Are you prepared to discuss the substance of what you heard [from other members of the White House Counsel's Office about the testimony of White House steward Bayani Nelvis]?” Lindsey 2/19/ 98 GJT at 82; Supplemental Materials (H. Doc. 105–316) at 2401.

35. “Q. Mr. Lindsey, my understanding from discussions with your attorney is, at least as of now, you are going to claim all the privileges you've mentioned with respect to which individuals (i.e. grand jury witnesses), if any, you received information [i.e. how they testified] about; is that correct?

A. That is correct, yes, sir.” Lindsey 2/19/98 GJT at 83–84; Supplemental Materials (H. Doc. 105- 316) at 2401.

36. “Okay. Who was that (who asked him why Mr. Lindsey why he did not return Linda Tripp's page in the summer of 1997 regarding Kathleen Willey]?” Lindsey 3/12/98 GJT at 16–17; Supplemental Materials (H. Doc. 105–316) at 2406–07.

37. “Did the President seem concerned about the number of deposition questions he was asked pertaining to Monica Lewinsky when you spoke to him after the deposition?” Lindsey 3/12/98 GJT at 18; Supplemental Materials (H. Doc. 105–316) at 2407.

38. “Was the President concerned about the number of deposition questions asked about Monica Lewinsky?” Lindsey 3/12/98 GJT at 20; Supplemental Materials (H. Doc. 105–316) at 2407.

39. “My question would be after that weekend [i.e. the weekend immediately after the Lewinsky story broke), aside from anything that might have been reported in the press, did you hear directly or indirectly that she [i.e. Betty Currie) might have been talking to representatives from our office?” Lindsey 3/12/98 GJT at 27-28; Supplemental Materials (H. Doc. 105–316) at 2409.

40. “Did Vernon Jordan ever tell you that President Clinton should settle the Paula Jones matter?” Lindsey 3/12/98 GJT at 3132; Supplemental Materials (H. Doc. 105–316) at 2410.

41. “I had asked you how much of your discussion with Vernon Jordan was related to settlement and you are invoking the privilege on that?” Lindsey 3/12/98 GJT at 36; Supplemental Materials (H. Doc. 105–316) at 2411.

42. "Did you discuss with him [Vernon Jordan) or did he discuss with you how much money would be needed to settle the case and who would raise it?" Lindsey 3/12/98 GJT at 37; Supplemental Materials (H. Doc. 105–316) at 2412.

43. “Can you tell us what that conversation (among Mr. Lindsey, Ms. Mills, and Mr. Jordan on January 19] was about?” Lindsey 3/ 12/98 GJT at 39; Supplemental Materials (H. Doc. 105–316) at 2412.

44. “Okay. And what was the reason that he [Mr. Jordan) was there (at the January 19 meeting among Mr. Lindsey, Ms. Mills, and Mr. Jordan)?” Lindsey 3/12/98 GJT at 40; Supplemental Materials (H. Doc. 105–316) at 2412.

45. “Q. Are your claiming a privilege as to any Monica Lewinsky/ Paula Jones discussions you may have had with the First Lady?

A. I consider at a minimum the First Lady to be an advisor to the President, yes.” Lindsey 3/12/98 GJT at 47; Supplemental Materials (H. Doc. 105–316) at 2414.

Paula Jonare your 226) at 23:22

105-316) at 24122/98 GJT at 47. to be an advisor to

46. “Did the President know whether Betty Currie had called Vernon Jordan in order to help Monica Lewinsky get a job in New York?” Lindsey 3/12/98 GJT at 53; Supplemental Materials (H. Doc. 105–316) at 2416.

47. "When, if ever, did you know it [i.e. that Ms. Lewinsky had been in the White House on December 6th), if you know it?” Lindsey 3/12/98 GJT at 64; Supplemental Materials (H. Doc. 105316) at 2418.

48. “What did he [i.e. the President) say (about his relationship with Ms. Lewinsky at a meeting among Mr. Lindsey, Ms. Mills, and the President shortly after the Lewinsky story broke]?” Lindsey 8/28/98 GJT at 22; Supplemental Materials (H. Doc. 105– 316) at 2428.

49. “Okay. The Grand Jury also asked the question: In your discussions with the President about the relationship that he had with Ms. Lewinsky, did you ever explicitly ask him, you know, “What exactly did you do with her?” Not, “What didn't you do?”_ “What did you do?” Lindsey 8/28/98 GJT at 84–87; Supplemental Materials (H. Doc. 105–316) at 2444.

50. “And this is a telephone log from the White House log indicating the President spoke to you-called you the morning of January 21, 1998, and spoke to you from the hours of 12:41 to 1:10 a.m. What did you talk about?” Lindsey 8/28/98 GJT at 88; Supplemental Materials (H. Doc. 105–316) at 2445.

51. “This Grand Jury exhibit, BRL-1, also indicates that you called the President back after your conversation with him (Mr. Podesta]—twice. At 1:36 a.m., you talked to him for two minutes; then you called him back again at 1:39 a.m. and talked to him for no more than two minutes. What did you talk about with the President then?” Lindsey 8/28/98 GJT at 90; Supplemental Materials (H. Doc. 105–316) at 2445.

52. “And then, the President called you at 7:14 a.m. that Wednesday, January 21, and you talked from 7:14 a.m. to 7:22 a.m. What did you talk about then?” Lindsey 8/28/98 GJT at 90; Supplemental Materials (H. Doc. 105–316) at 2445.

Questions on which Lanny Breuer asserted executive privi

lege 1. “All right. Do you recall“ and again, I'll go back to the time period we identified when the Washington Post article appeared, January 1, 1998, do you recall Mr. Blumenthal on or about that date revealing to you a conversation he had had with the President regarding Monica Lewinsky?” Breuer 8/4/98 GJT at 19; Supplemental Materials (H. Doc. 105–316) at 269.

Although Mr. Breuer refused to answer this question, Mr. Blumenthal had already testified to the substance of the conversation. Blumenthal 6/25/98 GJT at 30–31, 50; Supplemental Materials (H. Doc. 105–316) at 196, 201.

2. “Do you recall what that [i.e. what else was discussed with Mr. Blumenthal during this conversation] was?” Breuer 8/4/98 GJT at 22–23; Supplemental Materials (H. Doc. 105–316) at 270.

Although Mr. Breuer refused to answer this question, Mr. Blumenthal had already testified to the substance of the conversa

tion. Blumenthal 6/25/98 GJT at 30–31, 50; Supplemental Materials (H. Doc. 105–316) at 196, 201.

3. “Mr. Breuer, let me pick back up on our discussion of the conversation that you had with Mr. Blumenthal. Did he tell you when he had had the conversation with the President that he related to you?” Breuer 8/4/98 GJT at 28; Supplemental Materials (H. Doc. 105–316) at 271. (Although Mr. Breuer refused to answer this question, Mr. Blumenthal had already testified to the substance of the conversation. Blumenthal 6/25/98 GJT at 30-31, 50; Supplemental Materials (H. Doc. 105–316) at 196, 201.)

4. “Q. The President's private lawyers, where do they fit in?”

A. I will not-conversations that I had with the President's personal lawyers, I will claim privilege over.

Q. Both privileges [i.e. executive privilege and attorney-client privilege)?

A. Both privileges. Breuer 8/4/98 GJT at 45; Supplemental Materials (H. Doc. 105–316) at 276.

5. “Q. Okay. Do you know how Ms. White (an attorney) came to represent Ms. Raines [a White House employee)?

A. I do know the answer to that.
Q. Can you tell us how that came about?

A. Well, I don't believe I can because I think to do that would force me to reveal a conversation that I've had with Ms. Raines. Since Ms. Raines is a White House employee and I would have had a conversation with her in my capacity as special counsel, I think my discussion with Ms. Raines would be protected, given that she was seeking advice, it would be protected by both the attorney- client privilege and executive privilege. Breuer 8/4/98 GJT at 59; Supplemental Materials (H. Doc. 105–316) at 279.

6. "Q. Okay. I guess I'm asking you if you gave Ms. Raines Wendy White's [name]”

A. Řight. And I guess I can't answer that, given that I'm trying to preserve the substance of the conversation, so I think you might make a natural conclusion of that, but I really, truly believe that I'm going to try as best I can to preserve the communications I have with White House employees and over the substance of them assert attorney-client privilege and executive privilege. I don't think I can answer that specific question. Breuer 8/4/98 GJT at 65; Supplemental Materials (H. Doc. 105- 316) at 281.

7. Mr. Breuer asserted executive privilege with respect to five meetings he had with the President relating to the Lewinsky matter. Breuer 8/4/98 GJT at 70–78; Supplemental Materials (H. Doc. 105- 316) at 282–84.

8. Mr. Breuer asserted executive privilege with respect to the White House Counsel's Office's preparations for impeachment proceedings. Breuer 8/4/98 GJT at 78; Supplemental Materials (H. Doc. 105–316) at 284.

9. "Have you ever discussed with Mr. Kendall the relationship between the President and Monica Lewinsky?” Breuer 8/4/98 GJT at 79; Supplemental Materials (H. Doc. 105–316) at 284.

10. “Have you ever discussed with Ms. Seligman, who is another of the President's private lawyers, the relationship between the President and Monica Lewinsky?” Breuer 8/4/98 GJT at 80; Supplemental Materials (H. Doc. 105–316) at 284.

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