sexual harassment lawsuits to help prove the underlying claim of the Plaintiff and Judge Susan Weber Wright ruled that Paula Jones was entitled to this information for purposes of discovery. Consequently, if Monica Lewinsky acknowledged a sexual relationship with the President in her affidavit, then she certainly could not have avoided a deposition. The President had to be aware of this and this renders his grand jury testimony on this subject false and misleading.

c. The President made perjurious, 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

The President provided the following perjurious, false and misleading testimony concerning the false account he provided to Betty Currie regarding his relationship with Ms. Lewinsky:

Q. What was your purpose in making these statements to Miss Currie, if they weren't for the purpose to try to suggest to her if ever asked?

A. Now, Mr. Bittman, I told you, the only thing I remember is when all the stuff blew up, I was trying to figure out what the facts were. I was trying to remember.

Grand Jury Testimony of President Clinton, 8/17/98, p. 138–39, H. Doc. 105-311, pp. 590-91.

For very similar perjurious, false and misleading grand jury testimony of President Clinton, see p. 54, lines 19-25, p. 55, lines 125 and p. 56, lines 1-16; p. 130, lines 18-25, p. 131, lines 1-14; p. 141, lines 7-12 and 23-25, p. 142, lines 1–3.

The record reflects that President Clinton attempted to influence the testimony of Betty Currie, his personal secretary, by coaching her to recite inaccurate answers to possible questions that might be asked of her if called to testify in the Paula Jones case. The President did this shortly after he had been deposed in the case. In his grand jury testimony and responses to the Committee's Requests for Admission, the President was occasionally evasive and vague on this point. He stated that on January 18, 1998, he met with Ms. Currie and ". . . 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." Grand Jury Testimony of President Clinton, 8/17/98, H. Doc. 105311, p. 508; Response of President Clinton to Question No. 52 of the Committee's Requests for Admission. The President added that he urged Ms. Currie to "tell the truth" after learning that the Of fice of Independent Counsel (OIC) might subpoena her to testify. (Id at p. 591.)

The President also stated that he could not recall how many times he had talked to Ms. Currie or when, in response to OIC questioning on the subject of a similar meeting that took place on or about January 20 or 21, 1998. He claimed that by asking questions of Ms. Currie he was only attempting 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, pp. 592-93; Response of President Clinton to Question No. 53 of the Committee's Requests for Admission.

While testifying before the grand jury, Ms. Currie was more precise in her recollection of the two meetings. An OIC attorney asked her if the President had made a series of leading statements or questions that were similar to the following:

You were always there when she [Monica Lewinsky] was there, right? We were never really alone."

You could see hear 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.

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. OIC_Referral, H. Doc. 105-3 10, pp. 191-92; Grand Jury Testimony of Betty Currie, 1/27/98, pp. 71– 76, H. Doc. 105-316, pp. 559-60.

Ms. Currie also acknowledged that while she indicated to the President that she agreed with him, in fact she knew that, at times, he was alone with Ms. Lewinsky and that she could not or did not hear or see the two of them while they were alone.

As to their subsequent meeting on January 20 or 21, 1998, Ms. Currie stated that ". it was sort of a recapitulation of what we had talked about on Sunday [January 18, 19981. . . ." Grand Jury Testimony of Betty Currie, 1/27/98, p. 81, H. Doc. 105-316, p. 561.

d. The President made perjurious, false and misleading statements before the grand jury concerning statements he made to aides regarding his relationship with Monica Lewinsky

The President gave the following perjurious testimony under oath before the grand jury:

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

A. Let me finish. So, what-I did not want to mislead my friends but I want to define language where I can say that. I also, frankly, do 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 is nothing go 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.

Grand Jury Testimony of President Clinton 8/17/98, p. 105–106, H. Doc. 105-311 p. 557-558.

Another perjurious, false and misleading statement by the President regarding conversations with his aides is recorded on p. 100, lines 20-25 of the grand jury transcript.

The following grand jury testimony of several Presidential aides demonstrates that the President's testimony that he "said things that were true" to his aides is clearly perjurious, false and misleading.

The record reflects that President Clinton met with a total of five aides who would later be called to testify before the grand jury shortly after the President's deposition in the Paula Jones case and following a Washington Post story, published on January 21, 1998, which detailed the relationship between the President and Monica Lewinsky. During the meetings the President made untrue statements to his aides:

Sidney Blumenthal

Testifying before the grand jury on June 4, 1998, Sidney Blumenthal, an Assistant to the President, related the following discussion he had with the President on January 21, 1998:

He said Dick Morris had called him that day and he said Dick had told him that Nixon-he had read the newspaper and he said "You know, Nixon could have survived if he had gone on television and given an address and said everything he had done wrong and got it all out in the beginning."

And I said to the President, "What have you done wrong?" And he said, "Nothing, I haven't done anything wrong." I said, "Well then, that's one of the stupidest things I've ever heard. Why would you do that if you've done nothing wrong?'

And it was at that point that he gave his account of what had happened to me and he said that Monica-and it came very fast. He said, "Monica Lewinsky came at me and made a sexual demand on me.” He rebuffed her. He said, I've gone down that road before, I've caused pain for a lot of people and I'm not going to do that again.” Grand Jury Testimony of Sidney Blumenthal, 6-4-98, p. 49, Doc. 105-316, p. 185.

John Podesta

H.

In his grand jury testimony on June 16, 1998, then White House Deputy Chief of Staff John Podesta (now Chief Of Staff) testified to the following regarding a January 21, 1998 meeting with President Clinton:

A. And we went in to see the President.

Q. Who's we?

A. Mr. Bowles, myself and Ms. Matthews.

Q. Okay. Tell us about that.

A. And we started off the meeting-we didn't—I don't think we said anything, and I think the President directed

this specifically to Mr. Bowles. He said, "Erskine, I want
you to know that this story is not true.

Q. What else did he say?

A. He said that-that he had not had a sexual relationship with her, and that he never asked anybody to lie.

Grand Jury Testimony of John Podesta, 6/16/98, p. 85, H. Doc. 105-316, p. 3310.

Erskine Bowles had the following recollection of the same meeting:

A. And this was the day this huge story breaks. And the three of us walk in together-Sylvia Matthews, John Podesta and me-into the oval office, and the President was standing behind his desk.

Q. About what time of day is this?

A. This is approximately 9:00 in the morning or something you know, in that area. And he looked up at us and he said the same thing he said to the American people. He said, I want you to know I did not have sexual relationships with this woman Monica Lewinsky. I did not ask anybody to lie. And when the facts come out, you'll understand.

Grand Jury Testimony of Erskine Bowles, 4/2/98, pp. 83-84, H. Doc. 105-316, p. 239.

The record indicates the President also had a January 23, 1998, conversation with John Podesta, in which you stated that you had never had an affair with Monica Lewinsky?

A. See, we were getting ready to do the State of the Union prep and he was working on the state of the union draft back in his study. I went back there to just to kind of get him going-this is the first thing in the morning-— you know, we sort of get engaged. I asked him how he was doing, and he said he was working on this draft, and he said to me that he had never had sex with her, and that— he never asked-you know, he repeated the denial, but he was extremely explicit in saying he never had sex with her.

Q. How do you mean?

A. Just what I said.

Q. Okay. Not explicit, in the sense that he got more specific than sex, than the word "sex."

A. Yes, he was more specific than that.

Q. Okay. Share that with us.

A. Well, I think he said-he said that-there was some spate of, you know, what sex acts were counted, and he said that he had never had sex with her in any way what

soever

Q. Okay.

A. That they had not had oral sex.

Q. No question in you mind he's denying any sex in any way, shape or form, correct?

A. That's correct.

Grand Jury Testimony of John Podesta, 6/16/98, pp. 91-3, H. Doc. 105-316, p. 3311.

In that same January 23rd conversation with John Podesta, the President stated he was not alone with Monica Lewinsky in the Oval Office, and that Betty Currie was either in his presence or outside his office with the door open while he was visiting with Monica Lewinsky:

Q. Did the President ever speak to that issue with you, the issue of if he didn't have an improper relationship with Ms. Lewinsky, what was she doing there so often? Did he ever speak to that?

A. He said to me-I don't think it was in this conversation, I think it was a couple weeks later. He said to me that after she left, that when she had come by, she came to see Betty, and that he when she was there, either Betty was with them-either that she was with Betty when he saw her or that he saw her in the Oval Office with the door open and Betty was around-and Betty was out at her desk.

Grand Jury Testimony of John Podesta, 6/16/98, p. 88, H. Doc. 105-316, p. 3310.

Harold Ickes

On or about January 26, 1998, The President had a conversation with Harold Ickes, in which he made statements to the effect that he did not have an affair with Monica Lewinsky:

Q. What did the President say about Monica Lewinsky? A. The only discussion I recall having with him, he denied that he had had sexual relations with Ms. Lewinsky and denied that he had-I don't know how to capsulize it-obstructed justice, let's use that phrase.

Grand Jury Testimony of Harold Ickes, 6/10/98, p. 21, H. Doc. 105– 316, p. 1487; See also Grand Jury Testimony of Harold Ickes from 8/5/98, p. 88, H. Doc. 105-316, p. 1610 ("He denied to me that he had had a sexual relationship. I don't know the exact phrase, but the word 'sexual' was there. And he denied any obstruction of justice")).

5. Explanation of the Rogan Amendment to Article I

The Committee adopted an amendment to Article I of the Resolution offered by Representative Rogan of California. Article I addresses certain statements which the President made during his grand jury testimony on August 17, 1997. More explicitly, the Article charges the President with providing perjurious, false, and misleading testimony governing the following topics:

The nature and details of his relationship with a subordinated
Government employee;

Prior testimony in a deposition he gave in a Federal civil rights action against brought against him in the case of Jones v. Clinton;

Prior false and misleading statements he allowed his attorney to make to a Federal judge in that civil rights action; and