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CONTENTS

Articles of Impeachment

Table of Contents

I. Introduction

II. Narrative

A. The Paula Jones Litigation

B. The Relationship Between President Clinton and Monica Lewinsky

C. CA 204 The Events of December 5–6, 1997—President Clinton

Learns Ms. Lewinsky is on the Witness List

D. The Search for a Job for Ms. Lewinsky

E. CA 204 The Events of December 17, 1997—President Clinton In-

forms Ms.

Lewinsky that She is on the Witness List

F. CA 204 The Events of December 19, 1997—Ms. Lewinsky Receives

a Subpoena

G. The Events of December 28, 1997–Ms. Currie Retrieves the Gifts

H. CA 204 The Events of January 5-9, 1997–Ms. Lewinsky Signs

the False Affidavit and Gets the Job

I. The Filing of the False Affidavit

J. CA 204 The Events of January 17, 1998—President Clinton and

Mr. Bennett at the Deposition

K. The Events of Late January, 1998—The Deposition Aftermath

L. The Events of August 17, 1998—The Grand Jury Testimony

M. Answers to the Committee's Requests for Admission

III. Explanation of Articles of Impeachment

A. Article I–Perjury in the Civil Case

1. The Committee concluded that, on August 17, 1998, the Presi-

dent provided perjurious, false, and misleading testimony to a

Federal grand jury concerning the nature and details of his

relationship with a subordinate

government employee.

2. The Committee concluded that the President provided perjuri-

ous, false, and misleading testimony to a Federal grand jury

concerning prior perjurious, false, and misleading testimony he

gave in a federal civil rights action brought against him.

3. The Committee concluded that the President provided perjuri-

ous, false, and misleading testimony to a Federal grand jury

concerning prior false and

misleading statements he allowed his

attorney to make to a Federal judge in that civil rights action.

4. The Committee concluded that the President provided perjuri-

ous, false, and misleading testimony to a Federal grand jury

concerning his corrupt efforts to influence the testimony of wit-

nesses and to impede the discovery of evidence in that civil

rights action.

a. The President gave perjurious, false and misleading testi-

mony before the grand jury when he denied engaging in

a plan to hide evidence that had been subpoenaed in the

federal civil rights action against him.

b. The President made false and misleading statements before

the grand jury regarding his knowledge that the contents

of an affidavit executed by a subordinate federal employee

who was a witness in the federal civil rights action brought

against him were untrue.

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c. The President made false and misleading statements before

the grand jury when he recited a false account of the facts

regarding his interactions with Monica Lewinsky to Betty

Currie, a potential witness in the federal civil rights action

brought against him.

d. The President made perjurious, false and misleading state-

ments before the grand jury concerning statements he made

to aides regarding his relationship with Monica Lewinsky.

5. Explanation of the Rogan Amendment to Article I

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 Federal

civil rights action in response to written questions.

2. The Committee concluded that, in the civil case, the President

provided perjurious, false, and misleading testimony in a Federal

civil rights action in his deposition.

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.

b. 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 concern-

ing the Jones v. Clinton lawsuit.

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.

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.

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 em-

ployee might be called as a witness to testify in the federal

civil rights action brought against him.

f. The President lied in his deposition about his knowledge

of the service of a subpoena to a subordinate federal em-

ployee to testify as a witness in the federal civil rights

action brought against him.

g. The President lied in his deposition about his knowledge

of the final conversation he had with a subordinate employee

who was a witness in the federal civil rights action brought

against him.

h. The President lied in his deposition about his knowledge

that the contents of an affidavit executed by a subordinate

federal employee who was witness in the federal civil rights

action brought against him.

C. Article III-Obstruction of Justice

1. The Committee concluded that 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. The Committee concluded that 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. The Committee concluded that on or about December 28, 1997,

William Jefferson Clinton corruptly engaged in, encouraged, or

supported a scheme to conceal evidence that had been subpoe-

naed in a Federal civil rights action brought against him.

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69

72

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4. The Committee concluded that 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. The Committee concluded that 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 characteriz-
ing an affidavit, in order to prevent questioning deemed relevant
by the judge. Such false and misleading statements were subse-
quently acknowledged by his attorney in a communication to

that judge.
6. The Committee concluded that 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. The Committee concluded that on or about January 21, 23,

and 26, 1998, William Jefferson Clinton made false and mislead-
ing 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.
D. Article IV-Abuse of Power

1. The President abused his power by refusing and failing to re

spond to certain written requests for admission and willfully
made perjurious, false, and misleading sworn statements in re-
sponse to certain written requests for admission propounded to
him by the Committee.

a. Request for Admission Number 19
b. Request for Admission Number 20
c. Request for Admission Number 24
d. Request for Admission Number 26
e. Request for Admission Number 27
f. Request for Admission Number 34
g. Request for Admission Number 42
h. Request for Admission Number 43
i. Request for Admission Number 52

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j. Request for Admission Number 53
2. Explanation of the Gekas Amendment to Article IV
IV. The Constitutional Process of Impeachment
A. General Arguments About Impeachment

1. Constitutional Provisions
2. Impeachment is Not Removal from Office
3. Impeachment Does Not Overturn an Election

4. A Senate Trial of an Impeachment is a Constitutional Process
B. Articles of Impeachment Against President Clinton
1. Article I Grand Jury Perjury

a. Facts
b. Lessons from the Judicial Impeachments of the 1980s

i. Federal Judges v. Presidents
ii. Perjurious, False, and_ Misleading Statements Made

Under Oath of Subject to Penalty for Perjury
a. Judge Harry E. Claiborne
b. Judge Walter Nixon
c. Judge Alcee Hastings

d. Conclusion

iii. Conduct Not Related to Official Duties 2. Article II—Perjury in the Civil Case 3. Article III—Obstruction of Justice

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IMPEACHMENT OF WILLIAM JEFFERSON CLINTON,

PRESIDENT OF THE UNITED STATES

DECEMBER 15, 1998.—Referred to the House Calendar and ordered to be printed

Mr. HYDE, from the Committee on the Judiciary,

submitted the following

R E P O R T

together with

ADDITIONAL AND DISSENTING VIEWS

The Committee on the Judiciary, to whom was referred the consideration of recommendations concerning the exercise of the constitutional power to impeach William Jefferson Clinton, President of the United States, having considered the same, reports thereon pursuant to H. Res. 581 as follows and recommends that the House exercise its constitutional power to impeach William Jefferson Clinton, President of the United States, and that articles of impeachment be exhibited to the Senate as follows:

RESOLUTION Impeaching William Jefferson Clinton, President of the United States, for high crimes and misdemeanors.

Resolved, That William Jefferson Clinton, President of the United States, is impeached for high crimes and misdemeanors, and that the following articles of impeachment be exhibited to the United States Senate:

Articles of impeachment exhibited by the House of Representatives of the United States of America in the name of itself and of the people of the United States of America, against William Jefferson Clinton, President of the United States of America, in maintenance and support of its impeachment against him for high crimes and misdemeanors.

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