Blumenthal 6/4/98 GJT at 49. Mr. Blumenthal said President Clinton told him moments later:

And he said, "I feel like a character in a novel. I feel like somebody who is surrounded by an oppressive force that is creating a lie about me and I can't get the truth out. I feel like the character in the novel Darkness at Noon."

And I said to him, "When this happened with Monica Lewinsky, were you alone?" He said, "Well, I was within eyesight or earshot of someone."

Blumenthal 6/4/98 GJT at 50. At one point, Mr. Blumenthal is asked by the grand jury to describe the President's manner and demeanor during the exchange.

Q. In response to my question how you responded to the President's story about a threat or discussion about a threat from Ms. Lewinsky, you mentioned you didn't recall specifically. Do you recall generally the nature of your response to the President?

A. It was generally sympathetic to the President. And I certainly believed his story. It was a very heartfelt story, he was pouring out his heart, and I believed him.

Blumenthal 6/25/98 GJT at 16-17.

President Clinton also implemented a win-at-all-costs strategy. Former presidential advisor Dick Morris testified that on January 21, 1998, he spoke to President Clinton and they discussed the turbulent events of the day. President Clinton again denied the accusations against him. After further discussions, they decided to have an overnight poll taken to determine if the American people would forgive the President for adultery, perjury, and obstruction of justice. When Mr. Morris received the results, he called the President:

And I said, "They're just too shocked by this. It's just too new, it's too raw." And I said, “And the problem is they're willing to forgive you for adultery, but not for perjury or obstruction of justice or the various other things."

Morris 8/18/98 GJT at 28. Mr. Morris then recalls the following exchange:

Morris: And I said, "They're just not ready for it." meaning the voters. President Clinton: Well, we just have to win, then.

Morris 8/18/98 GJT at 30. President Clinton cannot recall this statement.

L. THE EVENTS OF AUGUST 17, 1998-THE GRAND JURY TESTIMONY On August 17, the last act of the tragedy took place. After six invitations, President Clinton appeared before a grand jury of his fellow citizens and took an oath to tell the truth. He equivocated and engaged in legalistic fencing, but he also lied. Actually, the entire testimony was calculated to mislead and deceive the grand jury and eventually the American people.

On August 16, 1998, President Clinton's personal attorney, David Kendall provided the following statement regarding his testimony:

There is apparently an enormous amount of groundless speculation about the President's testimony tomorrow. The truth is the truth. Period. And that's how the President will testify.

Kendall 8/16/98 Statement.

The untruthful tone, however, was set at the very beginning. Judge Starr testified that in a grand jury a witness can tell the truth, lie, or assert a legal privilege. President Clinton was given a fourth choice. The President was permitted to read a statement: 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. These encounters did not consist of sexual intercourse. They did not constitute sexual relations as I understood that term to be defined at my January 17th deposition. But they did involve inappropriate intimate contact.

These inappropriate encounters ended, at my insistence, in early 1997. I also had occasional telephone conversations with Ms. Lewinsky that included inappropriate sexual banter.

I regret that what began as a friendship came to include this conduct, and I will take full responsibility for my actions.

While I will provide the grand jury whatever other information I can, because of privacy considerations affecting my family, myself, and others, and in an effort to preserve the dignity of the office I hold, this is all I will say about the specifics of these particular matters.

I will try to answer, to the best of my ability, other questions including questions about my relationship with Ms. Lewinsky; questions about my understanding of the term "sexual relations," as I understood it to be defined at my January 17th, 1998 deposition; and questions concerning alleged subornation of perjury, obstruction of justice, and intimidation of witnesses. That, Mr. Bittman, is my statement.

Clinton 8/17/98 GJT at 8-10.

That statement itself is false in many particulars. President Clinton claims that he engaged in wrongful conduct with Ms. Lewinsky "on certain occasions in early 1996 and once in 1997." He does not mention 1995. There was a reason. On the three "occasions" in 1995, Ms. Lewinsky was a twenty-one year old intern. As for being alone on “certain occasions," he was alone with Ms. Lewinsky more than twenty times at least. The President also told the jurors that he "also had occasional telephone conversations with Ms. Lewinsky that included sexual banter." Actually, the two had at least fiftyfive phone conversations, many in the middle of the night and in seventeen of these calls, Ms. Lewinsky and President Clinton engaged in phone sex.

Again, President Clinton carefully crafted his statements to give the appearance of being candid, when actually he intended the opposite. In addition, throughout the testimony whenever he was asked a specific question that could not be answered directly with

out either admitting the truth or giving an easily provable false answer, he said, "I rely on my statement." Nineteen times he relied on this false and misleading statement; nineteen times, then, he repeated those lies. For example:

Q. Getting back to the conversation you had with Mrs. Currie on January 18th, you told her if she testified that you told her, Monica came on to me and I never touched her, you did, in fact, of course, touch Ms. Lewinsky, isn't that right, in a physically intimate way?

A. Now, I've testified about that. And that's one of those questions that I believe is answered by the statement that I made.

Clinton 8/17/98 GJT at 138.

He also admitted to the grand jury that, after the allegations were publicly reported, that he made "misleading" statements to particular aides whom he knew would likely be called to testify be-i fore the Grand Jury:

Q. Do you recall denying any sexual relationship with
Monica Lewinsky to the following people: Harry
Thomasson, Erskine Bowles, Harold Ickes, Mr. Podesta,
Mr. Blumenthal, Mr. Jordan, Ms. Betty Currie? Do you re-

call denying any sexual relationship with Monica
Lewinsky to those individuals?

A. I recall telling a number of those people that I didn't
have, either I didn't have an affair with Monica Lewinsky
or didn't have sex with her. And I believe, sir, that—you'll
have to ask them what they thought. But I was using
those terms in the normal way people use them. You'll
have to ask them what they thought I was saying.

Q. If they testified that you denied sexual relations or relationship with Monica Lewinsky, or if they told us that you denied that, do you have any reason to doubt them, in the days after the story broke; do you have any reason to doubt them?

A. No.

Clinton 8/17/98 GJT at 104-05. President Clinton then was specifically asked whether he knew that his aides were likely to be called before the grand jury:

Q. It may have been misleading, sir, and you knew though, after January 21st when the Post article broke and said that Judge Starr was looking into this, you knew that they might be witnesses. You knew that they might be called into a grand jury, didn't you?

A. That's right. I think I was quite careful what I said after that. I may have said something to all these people to that effect, but I'll also whenever anybody asked me any details, I said, look, I don't want you to be a witness or I turn you into a witness or give you information that would get you in trouble. I just wouldn't talk. I, by and large, didn't talk to people about it.

Q. If all of these people let's leave Mrs. Currie for a minute. Vernon Jordan, Sid Blumenthal, John Podesta,

Harold Ickes, Erskine Bowles, Harry Thomasson, after the
story broke, after Judge Starr's involvement was known on
January 21st, have said that you denied a sexual relation-
ship with them. Are you denying that?

A. No.

Q. And you've told us that you

A. I'm just telling you what I meant by it. I told you what I meant by it when they started this deposition.

Q. You've told us now that you were being careful, but that it might have been misleading. Is that correct?

A. It might have been . . . . So, what I was trying to do was to give them something they could-that would be true, even if misleading in the context of this deposition, and keep them out of trouble, and let's deal-and deal with what I thought was the almost ludicrous suggestion that I had urged someone to lie or tried to suborn perjury, in other words.

Clinton 8/17/98 GJT at 106-08.

As the President testified before the grand jury, he maintained that he was being truthful with his aides:

Q. You don't remember denying any kind of sex in any way, shape or form, and including oral sex, correct?

A. I remember that I issued a number of denials to people that I thought needed to hear them, but I tried to be careful and to be accurate, and I do not remember what I said to John Podesta.

Q. Did you deny it to them or not, Mr. President?

A. Let me finish. So, what-I did not want to mislead my friends, but I wanted to find language where I could say that. I also, frankly, did not want to turn any of them into witnesses, because I-and, sure enough, they all became witnesses.

Q. Well, you knew they might be

A. And so

Q. Witnesses, didn't you?

A. And so I said to them things that were true about this relationship. That I used-in the language I used, I said, there's nothing going on between us. That was true. I said, I have not had sex with her as I defined it. That was true. And did I hope that I would never have to be here on this day giving this testimony? Of course.

But I also didn't want to do anything to complicate this matter further. So, I said things that were true. They may have been misleading, and if they were I have to take responsibility for it, and I'm sorry.

Clinton 8/17/98 GJT at 100, 105-06. He stated that when he spoke to his aides, he was careful with his wording. He stated that he wanted his statement regarding “sexual relations" to be literally true because he was only referring to intercourse.

However, John Podesta said that President Clinton denied sex "in any way whatsoever" "including oral sex." He told Mr. Podesta,

Mr. Bowles, Ms. Williams, and Harold Ickes that he did not have a "sexual relationship" with that woman. Seven days after the President's grand jury appearance, the White House issued a document entitled, "Talking Points January 24, 1998." This "Talking Points" document outlines proposed questions that the President may be asked. It also outlines suggested answers to those questions. The "Talking Points" purport to state the President's view of sexual relations and his view of the relationship with Monica Lewinsky.

The "Talking Points" state in relevant part as follows:

Q. What acts does the President believe constitute a sexual relationship?

A. I can't believe we're on national television discussing this. I am not about to engage in an “act-by-act" discussion of what constitutes a sexual relationship.

Q. Well, for example, Ms. Lewinsky is on tape indicating that the President does not believe oral sex is adultery. Would oral sex, to the President, constitute a sexual relationship?

A. Of course it would.

Based upon the foregoing, the President's own talking points refute the President's "literal truth" argument.

M. ANSWERS TO THE COMMITTEE'S REQUESTS FOR ADMISSION In an effort to avoid unnecessary work and to bring this inquiry to an expeditious end, this Committee submitted to the President eighty-one requests to admit or deny specific facts relevant to this investigation. Although, for the most part, the questions could have been answered with a simple "admit" or "deny", President Clinton chose to follow the pattern of selective memory, reference to other testimony, blatant untruths, artful distortions, outright lies and half truths he had already used. When he did answer, he engaged in legalistic hairsplitting in an attempt to skirt the truth and to deceive this Committee.

Thus, on at least twenty-three questions, President Clinton professed a lack of memory despite the testimony of several witnesses that he has a remarkable memory. In at least fifteen answers, he merely referred to "White House Records." He also referred to his own prior testimony and that of others. He answered several of the requests by merely restating the same deceptive answers that he gave to the grand jury.

These half-truths, legalistic parsings, and evasive and misleading answers were calculated to obstruct the efforts of this Committee. They have had the effect of seriously hampering this Committee's ability to ascertain the truth. President Clinton has, therefore, added obstruction of an inquiry by the Legislative Branch to his obstructions of justice before the Judicial Branch.

III. EXPLANATION OF ARTICLES

A. ARTICLE I-PERJURY IN THE GRAND JURY

On August 17, 1998, William Jefferson Clinton swore to tell the truth, the whole truth, and nothing but the truth before a federal