MAJORITY STAFF

THOMAS E. MOONEY, SR., General Counsel-Chief of Staff
JON W. DUDAS, Deputy General Counsel-Staff Director
DIANA L. SCHACHT, Deputy Staff Director-Chief Counsel
DANIEL M. FREEMAN, Parliamentarian-Counsel
PAUL J. MCNULTY, Director of Communications-Chief Counsel
JOSEPH H. GIBSON, Chief Counsel

RICK FILKINS, Counsel
SHAREE M. FREEMAN, Counsel
PETER J. LEVINSON, Counsel
JOHN F. MAUTZ, IV, Counsel
WILLIAM E. MOSCHELLA, Counsel
STEPHEN PINKOS, Counsel

CONTENTS

Page

Articles of Impeachment

I. Introduction

II. Narrative

...........

A. The Paula Jones Litigation

B. The Relationship Between President Clinton and Monica Lewinsky

C. 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. The Events of December 17, 1997-President Clinton Informs Ms.

Lewinsky that She is on the Witness List

F. The Events of December 19, 1997—Ms. Lewinsky Receives a Sub-

poena

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

H. 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. 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 Grand Jury

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 perjurious, 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 perjurious, false, and misleading state-

ments 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.

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

ments 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 the President provided perjuri-

ous, false, and misleading testimony in a Federal civil rights

action in response to written questions.

2. The Committee concluded that the President provided perjuri-

ous, 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 a subordinate federal em-

ployee concerning 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 a 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.

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 for 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

Request for Admission Number 42

Request for Admission Number 43

i. Request for Admission Number 52

j. Request for Admission Number 53

2. Explanation of the Gekas Amendment to Article IV

84

IV. The Constitutional Process of Impeachment

106

A. General Arguments About Impeachment

106

1. Constitutional Provisions

106

2. Impeachment is Not Removal from Office

106

3. Impeachment Does Not Overturn an Election

107

4. A Senate Trial of an Impeachment is a Constitutional Process

107

b. Lessons from the Judicial Impeachments of the 1980s

i. Federal Judges v. Presidents

110

110

ii. Perjurious, False, and Misleading Statements Made

Under Oath or Subject to Penalty for Perjury

113