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The Starr report

Saturday 12 September 1998 23:02 BST
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Kenneth Starr's conclusion

Pursuant to Section 595(c) of Title 28, the Office of the Independent Counsel (OIC) hereby submits substantial and credible information that President Clinton obstructed justice during the Jones v. Clinton sexual harassment lawsuit by lying under oath and concealing evidence of his relationship with a young White House intern and federal employee, Monica Lewinsky. After a federal criminal investigation of the President's actions began in January 1998, the President lied under oath to the grand jury and obstructed justice during the grand jury investigation. There also is substantial and credible information that the President's actions with respect to Monica Lewinsky constitute an abuse of authority inconsistent with the President's constitutional duty to faithfully execute the laws.

There is substantial and credible information supporting the following eleven possible grounds for impeachment:

1. President Clinton lied under oath in his civil case when he denied a sexual affair, a sexual relationship, or sexual relations with Monica Lewinsky.

2. President Clinton lied under oath to the grand jury about his sexual relationship with Ms. Lewinsky.

3. In his civil deposition, to support his false statement about the sexual relationship, President Clinton also lied under oath about being alone with Ms. Lewinsky and about the many gifts exchanged between Ms. Lewinsky and him.

4. President Clinton lied under oath in his civil deposition about his discussions with Ms. Lewinsky concerning her involvement in the Jones case.

5. During the Jones case, the President obstructed justice and had an understanding with Ms. Lewinsky to jointly conceal the truth about their relationship by concealing gifts subpoenaed by Ms. Jones's attorneys.

6. During the Jones case, the President obstructed justice and had an understanding with Ms. Lewinsky to jointly conceal the truth of their relationship from the judicial process by a scheme that included the following means:

(i) both the President and Ms. Lewinsky understood that they would lie under oath in the Jones case about their sexual relationship;

(ii) the President suggested to Ms. Lewinsky that she prepare an affidavit that, for the President's purposes, would memorialize her testimony under oath and could be used to prevent questioning of both of them about their relationship;

(iii) Ms. Lewinsky signed and filed the false affidavit;

(iv) the President used Ms. Lewinsky's false affidavit at his deposition in an attempt to head off questions about Ms. Lewinsky; and

(v) when that failed, the President lied under oath at his civil deposition about the relationship with Ms. Lewinsky.

7. President Clinton endeavored to obstruct justice by helping Ms. Lewinsky obtain a job in New York at a time when she would have been a witness harmful to him were she to tell the truth in the Jones case.

8. President Clinton lied under oath in his civil deposition about his discussions with Vernon Jordan concerning Ms. Lewinsky's involvement in the Jones case.

9. The President improperly tampered with a potential witness by attempting to corruptly influence the testimony of his personal secretary, Betty Currie, in the days after his civil deposition.

10. President Clinton endeavored to obstruct justice during the grand jury investigation by refusing to testify for seven months and lying to senior White House aides with knowledge that they would relay the President's false statements to the grand jury - and did thereby deceive, obstruct, and impede the grand jury.

11. President Clinton abused his constitutional authority by:

(i) lying to the public and the Congress in January 1998 about his relationship with Ms.

Lewinsky;

(ii) promising at that time to cooperate fully with the grand jury investigation;

(iii) later refusing six invitations to testify voluntarily to the grand jury;

(iv) invoking Executive Privilege;

(v) lying to the grand jury in August 1998; and

(vi) lying again to the public and Congress on August 17, 1998 - all as part of an effort to hinder, impede, and deflect possible inquiry by the Congress of the United States.

The first two possible grounds for impeachment concern the President's lying under oath about the nature of his relationship with Ms. Lewinsky. The details associated with those grounds are, by their nature, explicit. The President's testimony unfortunately has rendered the details essential.

Factual Background

In May 1994, Paula Corbin Jones filed a lawsuit against William Jefferson Clinton in the United States District Court for the Eastern District of Arkansas. Ms. Jones alleged that while he was the Governor of Arkansas, President Clinton sexually harassed her during an incident in a Little Rock hotel room. President Clinton denied the allegations. He also challenged the ability of a private litigant to pursue a lawsuit against a sitting President.

In May 1997, the Supreme Court unanimously rejected the President's legal argument. The Court concluded that Ms. Jones, "like every other citizen who properly invokes [the District Court's] jurisdiction... has a right to an orderly disposition of her claims," and that therefore Ms. Jones was entitled to pursue her claims while the President was in office. A few months later, the pre-trial discovery process began. One sharply disputed issue in the Jones litigation was the extent to which the President would be required to disclose information about sexual relationships he may have had with "other women". Ms. Jones's attorneys sought disclosure of this information, arguing that it was relevant to proving that the President had propositioned Ms. Jones. The President resisted the discovery requests, arguing that evidence of relationships with other women (if any) was irrelevant.

In late 1997, the issue was presented to United States District Judge Susan Webber Wright for resolution. Judge Wright's decision was unambiguous. For purposes of pretrial discovery, President Clinton was required to provide certain information about his alleged relationships with other women. In an order dated December 11, 1997, for example, Judge Wright said: "The Court finds, therefore, that the plaintiff is entitled to information regarding any individuals with whom the President had sexual relations or proposed or sought to have sexual relations and who were during the relevant time frame state or federal employees." Judge Wright left for another day the issue whether any information of this type would be admissible were the case to go to trial. But for purposes of answering the written questions served on the President, and for purposes of answering questions at a deposition, the District Court ruled that the President must respond.

In mid-December 1997, the President answered one of the written discovery questions posed by Ms. Jones on this issue. When asked to identify all women who were state or federal employees and with whom he had had "sexual relations" since 1986, the President answered under oath: "None." For purposes of this interrogatory, the term "sexual relations" was not defined.

On January 17, 1998, President Clinton was questioned under oath about his relationships with other women in the workplace, this time at a deposition.

Judge Wright presided over the deposition. The President was asked numerous questions about his relationship with Monica Lewinsky, by then a 24-year- old former White House intern, White House employee, and Pentagon employee. Under oath and in the presence of Judge Wright, the President denied that he had engaged in a "sexual affair," a "sexual relationship," or "sexual relations" with Ms. Lewinsky. The President also stated that he had no specific memory of having been alone with Ms. Lewinsky, that he remembered few details of any gifts they might have exchanged, and indicated that no one except his attorneys had kept him informed of Ms. Lewinsky's status as a potential witness in the Jones case.

Nature of President Clinton's

Relationship with Monica Lewinsky

A. Introduction

This Referral presents substantial and credible information that President Clinton criminally obstructed the judicial process, first in a sexual harassment lawsuit in which he was the defendant and then in a grand jury investigation.

The opening section of the Narrative provides an overview of the object of the President's cover-up, the sexual relationship between the President and Ms. Lewinsky. Subsequent sections recount the evolution of the relationship chronologically, including the sexual contacts, the President's efforts to get Ms. Lewinsky a job, Ms. Lewinsky's subpoena in Jones v. Clinton, the role of Vernon Jordan, the President's discussions with Ms. Lewinsky about her affidavit and deposition, the President's deposition testimony in Jones, the President's attempts to coach a potential witness in the harassment case, the President's false and misleading statements to aides and to the American public after the Lewinsky story became public, and, finally, the President's testimony before a federal grand jury.

B. Evidence Establishing Nature of Relationship

1. Physical Evidence

Physical evidence conclusively establishes that the President and Ms. Lewinsky had a sexual relationship. After reaching an immunity and cooperation agreement with the Office of the Independent Counsel on July 28, 1998, Ms. Lewinsky turned over a navy blue dress that she said she had worn during a sexual encounter with the President on February 28, 1997. According to Ms. Lewinsky, she noticed stains on the garment the next time she took it from her closet. From their location, she surmised that the stains were the President's semen. Initial tests revealed that the stains are in fact semen. Based on that result, the OIC asked the President for a blood sample. After requesting and being given assurances that the OIC had an evidentiary basis for making the request, the President agreed. In the White House Map Room on August 3, 1998, the White House Physician drew a vial of blood from the President in the presence of an FBI agent and an OIC attorney. By conducting the two standard DNA comparison tests, the FBI Laboratory concluded that the President was the source of the DNA obtained from the dress. According to the more sensitive RFLP test, the genetic markers on the semen, which match the President's DNA, are characteristic of one out of 7.87 trillion Caucasians. In addition to the dress, Ms. Lewinsky provided what she said were answering machine tapes containing brief messages from the President, as well as several gifts that the President had given her.

2. Ms. Lewinsky's Statements

Ms. Lewinsky was extensively debriefed about her relationship with the President. For the initial evaluation of her credibility, she submitted to a detailed "proffer" interview on July 27, 1998. After entering into a cooperation agreement, she was questioned over the course of approximately 15 days. She also provided testimony under oath on three occasions: twice before the grand jury, and, because of the personal and sensitive nature of particular topics, once in a deposition. In addition, Ms. Lewinsky worked with prosecutors and investigators to create an 11-page chart that chronologically lists her contacts with President Clinton, including meetings, phone calls, gifts, and messages. Ms. Lewinsky twice verified the accuracy of the chart under oath. In the evaluation of experienced prosecutors and investigators, Ms. Lewinsky has provided truthful information. She has not falsely inculpated the President. Harming him, she has testified, is "the last thing in the world I want to do." The details of Ms. Lewinsky's many statements have been checked, cross-checked, and corroborated.

C. Sexual Contacts

1. The President's Accounts

a. Jones Testimony

In the Jones deposition on January 17, 1998, the President denied having had "a sexual affair," "sexual relations," or "a sexual relationship" with Ms. Lewinsky. He noted that "there are no curtains on the Oval Office, there are no curtains on my private office, there are no curtains or blinds that can close [on] the windows in my private dining room," and added: "I have done everything I could to avoid the kind of questions you are asking me here today...." During the deposition, the President's attorney, Robert Bennett, sought to limit questioning about Ms. Lewinsky. Mr. Bennett told Judge Susan Webber Wright that Ms. Lewinsky had executed "an affidavit which [Ms. Jones's lawyers] are in possession of saying that there is absolutely no sex of any kind in any manner, shape or form, with President Clinton." In a subsequent colloquy with Judge Wright, Mr. Bennett declared that as a result of "preparation of [President Clinton] for this deposition, the witness is fully aware of Ms. Lewinsky's affidavit." The President did not dispute his legal representative's assertion that the President and Ms. Lewinsky had had "absolutely no sex of any kind in any manner, shape or form," nor did he dispute the implication that Ms. Lewinsky's affidavit, in denying "a sexual relationship," meant that there was "absolutely no sex of any kind in any manner, shape or form." In subsequent questioning by his attorney, President Clinton testified under oath that Ms. Lewinsky's affidavit was "absolutely true."

b. Grand Jury Testimony

Testifying before the grand jury on August 17, 1998, seven months after his Jones deposition, the President acknowledged "inappropriate intimate contact" with Ms. Lewinsky but maintained that his January deposition testimony was accurate. In his account, "what began as a friendship [with Ms. Lewinsky] came to include this conduct." He said he remembered "meeting her, or having my first real conversation with her during the government shutdown in November of '95." According to the President, the inappropriate contact occurred later (after Ms. Lewinsky's internship had ended), "in early 1996 and once in early 1997." The President refused to answer questions about the precise nature of his intimate contacts with Ms. Lewinsky, but he did explain his earlier denials. As to his denial in the Jones deposition that he and Ms. Lewinsky had had a "sexual relationship," the President maintained that there can be no sexual relationship without sexual intercourse, regardless of what other sexual activities may transpire. He stated that "most ordinary Americans" would embrace this distinction.

2. Ms. Lewinsky's Account

In light of the President's testimony, Ms. Lewinsky's accounts of their sexual encounters are indispensable for two reasons. First, the detail and consistency of these accounts tend to bolster Ms. Lewinsky's credibility. Second, and particularly important, Ms. Lewinsky contradicts the President on a key issue.

According to Ms. Lewinsky, the President touched her breasts and genitalia - which means that his conduct met the Jones definition of sexual relations even under his theory. On these matters, the evidence of the President's perjury cannot be presented without specific, explicit, and possibly offensive descriptions of sexual encounters.

According to Ms. Lewinsky, she and the President had ten sexual encounters, eight while she worked at the White House and two thereafter. The sexual encounters generally occurred in or near the private study off the Oval Office - most often in the windowless hallway outside the study. During many of their sexual encounters, the President stood leaning against the doorway of the bathroom across from the study, which, he told Ms. Lewinsky, eased his sore back. Ms. Lewinsky testified that her physical relationship with the President included oral sex but not sexual intercourse. According to Ms. Lewinsky, she performed oral sex on the President; he never performed oral sex on her. Initially, according to Ms. Lewinsky, the President would not let her perform oral sex to completion. In Ms. Lewinsky's understanding, his refusal was related to "trust and not knowing me well enough." During their last two sexual encounters, both in 1997, he did ejaculate. According to Ms. Lewinsky, she performed oral sex on the President on nine occasions. On all nine of those occasions, the President fondled and kissed her bare breasts. He touched her genitals, both through her underwear and directly, bringing her to orgasm on two occasions. On one occasion, the President inserted a cigar into her vagina. On another occasion, she and the President had brief genital-to-genital contact. Whereas the President testified that "what began as a friendship came to include [intimate contact]," Ms. Lewinsky explained that the relationship moved in the opposite direction: "The emotional and friendship aspects... developed after the beginning of our sexual relationship."

D. Emotional Attachment

As the relationship developed over time, Ms. Lewinsky grew emotionally attached to President Clinton. She testified: "I never expected to fall in love with the President. I was surprised that I did." Ms. Lewinsky told him of her feelings. At times, she believed that he loved her too. They were physically affectionate: "A lot of hugging, holding hands sometimes. He always used to push the hair out of my face." She called him "Handsome"; on occasion, he called her "Sweetie," "Baby," or sometimes "Dear." He told her that he enjoyed talking to her - she recalled his saying that the two of them were "emotive and full of fire," and she made him feel young. He said he wished he could spend more time with her. Ms. Lewinsky told confidants of the emotional underpinnings of the relationship as it evolved. According to her mother, Marcia Lewis, the President once told Ms. Lewinsky that she "had been hurt a lot or something by different men and that he would be her friend or he would help her, not hurt her." According to Ms. Lewinsky's friend Neysa Erbland, President Clinton once confided in Ms. Lewinsky that he was uncertain whether he would remain married after he left the White House. He said in essence, "Who knows what will happen four years from now when I am out of office?" Ms. Lewinsky thought, according to Ms. Erbland, that "maybe she will be his wife."

E. Conversations and Phone Messages

Ms. Lewinsky testified that she and the President "enjoyed talking to each other and being with each other." In her recollection, "We would tell jokes. We would talk about our childhoods. Talk about current events. I was always giving him my stupid ideas about what I thought should be done in the administration or different views on things." One of Ms. Lewinsky's friends testified that, in her understanding, "[The President] would talk about his childhood and growing up, and [Ms. Lewinsky] would relay stories about her childhood and growing up. I guess normal conversations that you would have with someone that you're getting to know." The longer conversations often occurred after their sexual contact. Ms. Lewinsky testified: "When I was working there [at the White House] ... we'd start in the back [in or near the private study] and we'd talk and that was where we were physically intimate, and we'd usually end up, kind of the pillow talk of it, I guess... sitting in the Oval Office..." During several meetings when they were not sexually intimate, they talked in the Oval Office or in the area of the study. Along with face-to-face meetings, according to Ms. Lewinsky, she spoke on the telephone with the President approximately 50 times, often after 10 p.m. and sometimes well after midnight. The President placed the calls himself or, during working hours, had his secretary, Betty Currie, do so; Ms. Lewinsky could not telephone him directly, though she sometimes reached him through Ms. Currie. Ms. Lewinsky testified: "We spent hours on the phone talking." Their telephone conversations were "similar to what we discussed in person, just how we were doing. A lot of discussions about my job, when I was trying to come back to the White House and then once I decided to move to New York...

We talked about everything under the sun." On 10 to 15 occasions, she and the President had phone sex. After phone sex late one night, the President fell asleep mid-conversation. On four occasions, the President left very brief messages on Ms. Lewinsky's answering machine, though he told her that he did not like doing so because (in her recollection) he "felt it was a little unsafe." She saved his messages and played the tapes for several confidants, who said they believed that the voice was the President's. By phone and in person, according to Ms. Lewinsky, she and the President sometimes had arguments. On a number of occasions in 1997, she complained that he had not brought her back from the Pentagon to work in the White House, as he had promised to do after the election. In a face-to-face meeting on July 4, 1997, the President reprimanded her for a letter she had sent him that obliquely threatened to disclose their relationship. During an argument on December 6, 1997, according to Ms. Lewinsky, the President said that "he had never been treated as poorly by anyone else as I treated him," and added that "he spent more time with me than anyone else in the world, aside from his family, friends and staff, which I don't know exactly which category that put me in." Testifying before the grand jury, the President confirmed that he and Ms. Lewinsky had had personal conversations, and he acknowledged that their telephone conversations sometimes included "inappropriate sexual banter." The President said that Ms. Lewinsky told him about "her personal life," "her upbringing," and "her job ambitions." After terminating their intimate relationship in 1997, he said, he tried "to be a friend to Ms. Lewinsky, to be a counselor to her, to give her good advice, and to help her."

F. Gifts

Ms. Lewinsky and the President exchanged numerous gifts. By her estimate, she gave him about 30 items, and he gave her about 18. Ms. Lewinsky's first gift to him was a matted poem given by her and other White House interns to commemorate "National Boss Day," October 24, 1995. This was the only item reflected in White House records that Ms. Lewinsky gave the President before (in her account) the sexual relationship began, and the only item that he sent to the archives instead of keeping. On November 20 - five days after the intimate relationship began, according to Ms. Lewinsky - she gave him a necktie, which he chose to keep rather than send to the archives. According to Ms. Lewinsky, the President telephoned the night she gave him the tie, then sent her a photo of himself wearing it. The tie was logged pursuant to White House procedures for gifts to the President. In a draft note to the President in December 1997, Ms. Lewinsky wrote that she was "very particular about presents and could never give them to anyone else - they were all bought with you in mind." Many of the 30 or so gifts that she gave the President reflected his interests in history, antiques, cigars, and frogs. Ms. Lewinsky gave him, among other things, six neckties, an antique paperweight showing the White House, a silver tabletop holder for cigars or cigarettes, a pair of sunglasses, a casual shirt, a mug emblazoned "Santa Monica," a frog figurine, a letter opener depicting a frog, several novels, a humorous book of quotations, and several antique books. He gave her, among other things, a hat pin, two brooches, a blanket, a marble bear figurine, and a special edition of Walt Whitman's Leaves of Grass. Ms. Lewinsky construed it as a sign of affection when the President wore a necktie or other item of clothing she had given him. She testified: "I used to say to him that `I like it when you wear my ties because then I know I'm close to your heart.' So - literally and figuratively." The President was aware of her reaction, according to Ms. Lewinsky, and he would sometimes wear one of the items to reassure her - occasionally on the day they were scheduled to meet or the day after they had met in person or talked by telephone. The President would sometimes say to her, "Did you see I wore your tie the other day?" In his grand jury testimony, the President acknowledged that he had exchanged a number of gifts with Ms. Lewinsky. After their intimate relationship ended in 1997, he testified, "She continued to give me gifts. And I felt that it was a right thing to do to give her gifts back."

G. Messages

According to Ms. Lewinsky, she sent the President a number of cards and letters. In some, she expressed anger that he was "not paying enough attention to me"; in others, she said she missed him; in still others, she just sent "a funny card that I saw." In early January 1998, she sent him, along with an antique book about American presidents, "an embarrassing mushy note." She testified that the President never sent her any cards or notes other than formal thank-you letters. Testifying before the grand jury, the President acknowledged having received cards and notes from Ms. Lewinsky that were "somewhat intimate" and "quite affectionate," even after the intimate relationship ended.

H. Secrecy

1. Mutual Understanding

Both Ms. Lewinsky and the President testified that they took steps to maintain the secrecy of the relationship. According to Ms. Lewinsky, the President from the outset stressed the importance of keeping the relationship secret. In her handwritten statement to this Office, Ms. Lewinsky wrote that "the President told Ms. L to deny a relationship, if ever asked about it. He also said something to the effect of if the two people who are involved say it didn't happen - it didn't happen." According to Ms. Lewinsky, the President sometimes asked if she had told anyone about their sexual relationship or about the gifts they had exchanged; she (falsely) assured him that she had not. She told him that "I would always deny it, I would always protect him," and he responded approvingly. The two of them had, in her words, "a mutual understanding" that they would "keep this private, so that meant deny it and... take whatever appropriate steps needed to be taken." When she and the President both were subpoenaed to testify in the Jones case, Ms. Lewinsky anticipated that "as we had on every other occasion and every other instance of this relationship, we would deny it." In his grand jury testimony, the President confirmed his efforts to keep their liaisons secret. He said he did not want the facts of their relationship to be disclosed "in any context," and added: "I certainly didn't want this to come out, if I could help it. And I was concerned about that. I was embarrassed about it. I knew it was wrong." Asked if he wanted to avoid having the facts come out through Ms. Lewinsky's testimony in Jones, he said: "Well, I did not want her to have to testify and go through that. And, of course, I didn't want her to do that, of course not."

2. Cover Stories

For her visits to see the President, according to Ms. Lewinsky, "There was always some sort of a cover." When visiting the President while she worked at the White House, she generally planned to tell anyone who asked (including Secret Service officers and agents) that she was delivering papers to the President. Ms. Lewinsky explained that this artifice may have originated when "I got there kind of saying, `Oh, gee, here are your letters,' wink, wink, wink, and him saying, `Okay, that's good.' " To back up her stories, she generally carried a folder on these visits. (In truth, according to Ms. Lewinsky, her job never required her to deliver papers to the President.) On a few occasions during her White House employment, Ms. Lewinsky and the President arranged to bump into each other in the hallway; he then would invite her to accompany him to the Oval Office. Later, after she left the White House and started working at the Pentagon, Ms. Lewinsky relied on Ms. Currie to arrange times when she could see the President. The cover story for those visits was that Ms. Lewinsky was coming to see Ms. Currie, not the President. While the President did not expressly instruct her to lie, according to Ms. Lewinsky, he did suggest misleading cover stories. And, when she assured him that she planned to lie about the relationship, he responded approvingly. On the frequent occasions when Ms. Lewinsky promised that she would "always deny" the relationship and "always protect him," for example, the President responded, in her recollection, " `That's good,' or - something affirmative... Not - `Don't deny it.'" Once she was named as a possible witness in the Jones case, according to Ms. Lewinsky, the President reminded her of the cover stories. After telling her that she was a potential witness, the President suggested that, if she were subpoenaed, she could file an affidavit to avoid being deposed. He also told her she could say that, when working at the White House, she had sometimes delivered letters to him, and, after leaving her White House job, she had sometimes returned to visit Ms. Currie. (The President's own testimony in the Jones case mirrors the recommendations he made to Ms. Lewinsky for her testimony. In his deposition, the President testified that he saw Ms. Lewinsky "on two or three occasions" during the November 1995 government furlough, "one or two other times when she brought some documents to me," and "sometime before Christmas" when Ms. Lewinsky "came by to see Betty.") In his grand jury testimony, the President acknowledged that he and Ms. Lewinsky "might have talked about what to do in a non-legal context" to hide their relationship, and that he "might well have said" that Ms. Lewinsky should tell people that she was bringing letters to him or coming to visit Ms. Currie. But he also stated that "I never asked Ms. Lewinsky to lie."

3. Steps to Avoid Being Seen or Heard

After their first two sexual encounters during the November 1995 government shutdown, according to Ms. Lewinsky, her encounters with the President generally occurred on weekends, when fewer people were in the West Wing. Ms. Lewinsky testified: "He had told me... that he was usually around on the weekends and that it was okay to come see him on the weekends. So he would call and we would arrange either to bump into each other in the hall or that I would bring papers to the office." From some of the President's comments, Ms. Lewinsky gathered that she should try to avoid being seen by several White House employees, including Nancy Hernreich, Deputy Assistant to the President and Director of Oval Office Operations, and Stephen Goodin, the President's personal aide. Fear of discovery constrained their sexual encounters in several respects, according to Ms. Lewinsky. The President ordinarily kept the door between the private hallway and the Oval Office several inches ajar during their encounters, both so that he could hear if anyone approached and so that anyone who did approach would be less likely to suspect impropriety. During their sexual encounters, Ms. Lewinsky testified, "We were both aware of the volume and sometimes... I bit my hand - so that I wouldn't make any noise." On one occasion, according to Ms. Lewinsky, the President put his hand over her mouth during a sexual encounter to keep her quiet. Concerned that they might be interrupted abruptly, according to Ms. Lewinsky, the two of them never fully undressed. While noting that "the door to the hallway was always somewhat open," the President testified that he did try to keep the intimate relationship secret: "I did what people do when they do the wrong thing. I tried to do it where nobody else was looking at it."

4. Ms. Lewinsky's Notes and Letters

The President expressed concern about documents that might hint at an improper relationship between them, according to Ms. Lewinsky. He cautioned her about messages she sent: "There were... some occasions when I sent him cards or notes that I wrote things that he deemed too personal to put on paper just in case something ever happened, if it got lost getting there or someone else opened it. So there were several times when he remarked to me, you know, you shouldn't put that on paper." She said that the President made this point to her in their last conversation, on January 5, 1998, in reference to what she characterized as "an embarrassing mushy note" she had sent him. In addition, according to Ms. Lewinsky, the President expressed concerns about official records that could establish aspects of their relationship. She said that on two occasions she asked the President if she could go upstairs to the Residence with him. No, he said, because a record is kept of everyone who accompanies him there. The President testified before the grand jury: "I remember telling her she should be careful what she wrote, because a lot of it was clearly inappropriate and would be embarrassing if somebody else read it."

5. Ms. Lewinsky's Evaluation of Their Secrecy Efforts

In two conversations recorded after she was subpoenaed in the Jones case, Ms. Lewinsky expressed confidence that her relationship with the President would never be discovered. She believed that no records showed her and the President alone in the area of the study. Regardless of the evidence, in any event, she would continue denying the relationship. "If someone looked in the study window, it's not me," she said. If someone produced tapes of her telephone calls with the President, she would say they were fakes. In another recorded conversation, Ms. Lewinsky said she was especially comforted by the fact that the President, like her, would be swearing under oath that "nothing happened." She said: "To tell you the truth, I'm not concerned all that much anymore because I know I'm not going to get in trouble. I will not get in trouble because you know what? The story I've signed under - under oath is what someone else is saying under oath."

1995: Initial Sexual Encounters

Monica Lewinsky began her White House employment as an intern in the Chief of Staff's office in July 1995. At White House functions in the following months, she made eye contact with the President. During the November 1995 government shutdown, the President invited her to his private study, where they kissed. Later that evening, they had a more intimate sexual encounter. They had another sexual encounter two days later, and a third one on New Year's Eve.

A. Overview of Monica Lewinsky's White House Employment

Monica Lewinsky worked at the White House, first as an intern and then as an employee, from July 1995 to April 1996. With the assistance of family friend Walter Kaye, a prominent contributor to political causes, she obtained an internship starting in early July, when she was 21 years old. She was assigned to work on correspondence in the office of Chief of Staff Leon Panetta in the Old Executive Office Building. As her internship was winding down, Ms. Lewinsky applied for a paying job on the White House staff. She interviewed with Timothy Keating, Special Assistant to the President and Staff Director for Legislative Affairs. Ms. Lewinsky accepted a position dealing with correspondence in the Office of Legislative Affairs on November 13, 1995, but did not start the job (and, thus, continued her internship) until November 26. She remained a White House employee until April 1996, when - in her view, because of her intimate relationship with the President - she was dismissed from the White House and transferred to the Pentagon.

B. First Meetings with the President

The month after her White House internship began, Ms. Lewinsky and the President began what she characterized as "intense flirting." At departure ceremonies and other events, she made eye contact with him, shook hands, and introduced herself. When she ran into the President in the West Wing basement and introduced herself again, according to Ms. Lewinsky, he responded that he already knew who she was. Ms. Lewinsky told her aunt that the President "seemed attracted to her or interested in her or something," and told a visiting friend that "she was attracted to [President Clinton], she had a big crush on him, and I think she told me she at some point had gotten his attention, that there was some mutual eye contact and recognition, mutual acknowledgment." In the autumn of 1995, an impasse over the budget forced the federal government to shut down for one week, from Tuesday, November 14, to Monday, November 20. Only essential federal employees were permitted to work during the furlough, and the White House staff of 430 shrank to about 90 people for the week. White House interns could continue working because of their unpaid status, and they took on a wide range of additional duties. During the shutdown, Ms. Lewinsky worked in Chief of Staff Panetta's West Wing office, where she answered phones and ran errands. The President came to Mr. Panetta's office frequently because of the shutdown, and he sometimes talked with Ms. Lewinsky. She characterized these encounters as "continued flirtation." According to Ms. Lewinsky, a Senior Adviser to the Chief of Staff, Barry Toiv, remarked to her that she was getting a great deal of "face time" with the President.

C. November 15 Sexual Encounter

Ms. Lewinsky testified that Wednesday, November 15, 1995 - the second day of the government shutdown - marked the beginning of her sexual relationship with the President. On that date, she entered the White House at 1:30 p.m., left sometime thereafter (White House records do not show the time), re-entered at 5:07 p.m., and departed at 12:18 a.m. on November 16. The President was in the Oval Office or the Chief of Staff's office (where Ms. Lewinsky worked during the furlough) for almost the identical period that Ms. Lewinsky was in the White House that evening, from 5:01 p.m. on November 15 to 12:35 a.m. on November 16. According to Ms. Lewinsky, she and the President made eye contact when he came to the West Wing to see Mr. Panetta and Deputy Chief of Staff Harold Ickes, then again later at an informal birthday party for Jennifer Palmieri, Special Assistant to the Chief of Staff. At one point, Ms. Lewinsky and the President talked alone in the Chief of Staff's office. In the course of flirting with him, she raised her jacket in the back and showed him the straps of her thong underwear, which extended above her pants. En route to the restroom at about 8 p.m., she passed George Stephanopoulos's office. The President was inside alone, and he beckoned her to enter. She told him that she had a crush on him. He laughed, then asked if she would like to see his private office. Through a connecting door in Mr. Stephanopoulos's office, they went through the President's private dining room toward the study off the Oval Office. Ms. Lewinsky testified: "We talked briefly and sort of acknowledged that there had been a chemistry that was there before and that we were both attracted to each other and then he asked me if he could kiss me." Ms. Lewinsky said yes. In the windowless hallway adjacent to the study, they kissed. Before returning to her desk, Ms. Lewinsky wrote down her name and telephone number for the President. At about 10 p.m., in Ms. Lewinsky's recollection, she was alone in the Chief of Staff's office and the President approached. He invited her to rendezvous again in Mr. Stephanopoulos's office in a few minutes, and she agreed. (Asked if she knew why the President wanted to meet with her, Ms. Lewinsky testified: "I had an idea.") They met in Mr. Stephanopoulos's office and went again to the area of the private study. This time the lights in the study were off. According to Ms. Lewinsky, she and the President kissed. She unbuttoned her jacket; either she unhooked her bra or he lifted her bra up; and he touched her breasts with his hands and mouth. Ms. Lewinsky testified: "I believe he took a phone call... and so we moved from the hallway into the back office... He put his hand down my pants and stimulated me manually in the genital area." While the President continued talking on the phone (Ms. Lewinsky understood that the caller was a Member of Congress or a Senator), she performed oral sex on him. He finished his call, and, a moment later, told Ms. Lewinsky to stop. In her recollection: "I told him that I wanted... to complete that. And he said... that he needed to wait until he trusted me more. And then I think he made a joke... that he hadn't had that in a long time." Both before and after their sexual contact during that encounter, Ms. Lewinsky and the President talked. At one point during the conversation, the President tugged on the pink intern pass hanging from her neck and said that it might be a problem. Ms. Lewinsky thought that he was talking about access - interns were not supposed to be in the West Wing without an escort - and, in addition, that he might have discerned some "impropriety" in a sexual relationship with a White House intern. White House records corroborate details of Ms. Lewinsky's account. She testified that her November 15 encounters with the President occurred at about 8 p.m. and 10 p.m., and that in each case the two of them went from the Chief of Staff's office to the Oval Office area. Records show that the President visited the Chief of Staff's office for one minute at 8:12 p.m. and for two minutes at 9:23 p.m., in each case returning to the Oval Office. She recalled that the President took a telephone call during their sexual encounter, and she believed that the caller was a Member of Congress or a Senator. White House records show that after returning to the Oval Office from the Chief of Staff's office, the President talked to two Members of Congress: Rep. Jim Chapman from 9:25 p.m. to 9:30 p.m., and Rep. John Tanner from 9:31 p.m. to 9:35 p.m.

D. November 17 Sexual Encounter

According to Ms. Lewinsky, she and the President had a second sexual encounter two days later (still during the government furlough), on Friday, November 17.

She was at the White House until 8:56 p.m., then returned from 9:38 to 10:39 p.m. At 9:45 p.m., a few minutes after Ms. Lewinsky's re-entry, the President went from the Oval Office to the Chief of Staff's office (where Ms. Lewinsky worked during the furlough) for one minute, then returned to the Oval Office for 30 minutes. From there, he went back to the Chief of Staff's office until 10:34 p.m. (approximately when Ms. Lewinsky left the White House), then went by the Oval Office and the Ground Floor before retiring to the Residence at 10:40 p.m. Ms. Lewinsky testified: We were again working late because it was during the furlough and Jennifer Palmieri... had ordered pizza along with Ms. Currie and Ms. Hernreich. And when the pizza came, I went down to let them know that the pizza was there and it was at that point when I walked into Ms. Currie's office that the President was standing there with some other people discussing something. And they all came back to the office and Mr. - I think it was Mr. Toiv, somebody accidentally knocked pizza on my jacket, so I went to go use the restroom to wash it off and as I was coming out of the restroom, the President was standing in Ms. Currie's doorway and said, "You can come out this way." Ms. Lewinsky and the President went into the area of the private study, according to Ms. Lewinsky. There, either in the hallway or the bathroom, she and the President kissed. After a few minutes, in Ms. Lewinsky's recollection, she told him that she needed to get back to her desk. The President suggested that she bring him some slices of pizza. A few minutes later, she returned to the Oval Office area with pizza and told Ms. Currie that the President had requested it. Ms. Lewinsky testified: "[Ms. Currie] opened the door and said, `Sir, the girl's here with the pizza.' He told me to come in. Ms. Currie went back into her office and then we went into the back study area again." Several witnesses confirm that when Ms. Lewinsky delivered pizza to the President that night, the two of them were briefly alone. Ms. Lewinsky testified that she and the President had a sexual encounter during this visit. They kissed, and the President touched Ms. Lewinsky's bare breasts with his hands and mouth. At some point, Ms. Currie approached the door leading to the hallway, which was ajar, and said that the President had a telephone call. Ms. Lewinsky recalled that the caller was a Member of Congress with a nickname. While the President was on the telephone, according to Ms. Lewinsky, "he unzipped his pants and exposed himself," and she performed oral sex. Again, he stopped her before he ejaculated. During this visit, according to Ms. Lewinsky, the President told her that he liked her smile and her energy. He also said: "I'm usually around on weekends, no one else is around, and you can come and see me." Records corroborate Ms. Lewinsky's recollection that the President took a call from a Member of Congress with a nickname. While Ms. Lewinsky was at the White House that evening (9:38 to 10:39 p.m.), the President had one telephone conversation with a Member of Congress: From 9:53 to 10:14 p.m., he spoke with Rep. H.L. "Sonny" Callahan. In his Jones deposition on January 17, 1998, President Clinton - who said he was unable to recall most of his encounters with Ms. Lewinsky - did remember her "back there with a pizza" during the government shutdown. He said, however, that he did not believe that the two of them were alone. Testifying before the grand jury on August 17, 1998, the President said that his first "real conversation" with Ms. Lewinsky occurred during the November 1995 furlough. He testified: "One night she brought me some pizza. We had some remarks."

E. December 31 Sexual Encounter

According to Ms. Lewinsky, she and the President had their third sexual encounter on New Year's Eve. Ms. Lewinsky - by then a member of the staff of the Office of Legislative Affairs - was at the White House on Sunday, December 31, 1995, until 1:16 p.m.; her time of arrival is not shown. The President was in the Oval Office area from 12:11 p.m. until about the time that Ms. Lewinsky left, 1:15 p.m., when he went to the Residence. Sometime between noon and 1 p.m., in Ms. Lewinsky's recollection, she was in the pantry area of the President's private dining room talking with a White House steward, Bayani Nelvis. She told Mr. Nelvis that she had recently smoked her first cigar, and he offered to give her one of the President's cigars. Just then, the President came down the hallway from the Oval Office and saw Ms. Lewinsky. The President dispatched Mr. Nelvis to deliver something to Mr. Panetta. According to Ms. Lewinsky, she told the President that Mr. Nelvis had promised her a cigar, and the President gave her one. She told him her name - she had the impression that he had forgotten it in the six weeks since their furlough encounters because, when passing her in the hallway, he had called her "Kiddo." The President replied that he knew her name; in fact, he added, having lost the phone number she had given him, he had tried to find her in the phonebook. According to Ms. Lewinsky, they moved to the study. "And then... we were kissing and he lifted my sweater and exposed my breasts and was fondling them with his hands and with his mouth." She performed oral sex. Once again, he stopped her before he ejaculated because, Ms. Lewinsky testified, "he didn't know me well enough or he didn't trust me yet." According to Ms. Lewinsky, a Secret Service officer named Sandy was on duty in the West Wing that day. Records show that Sandra Verna was on duty outside the Oval Office from 7 a.m. to 2 p.m.

F. President's Account of 1995 Relationship

As noted, the President testified before the grand jury that on November 17, 1995, Ms. Lewinsky delivered pizza and exchanged "some remarks" with him, but he never indicated that anything sexual occurred then or at any other point in 1995. Testifying under oath before the grand jury, the President said that he engaged in "conduct that was wrong" involving "inappropriate intimate contact" with Ms. Lewinsky "on certain occasions in early 1996 and once in early 1997." By implicitly denying any sexual contact in 1995, the President indicated that he and Ms. Lewinsky had no sexual involvement while she was an intern. In the President's testimony, his relationship with Ms. Lewinsky "began as a friendship," then later "came to include this conduct."

January-March 1996: Continued Sexual Encounters

President Clinton and Ms. Lewinsky had additional sexual encounters near the Oval Office in 1996. After their sixth sexual encounter, the President and Ms. Lewinsky had their first lengthy conversation. On President's Day, February 19, the President terminated their sexual relationship, then revived it on March 31.

A. January 7 Sexual Encounter

According to Ms. Lewinsky, she and the President had another sexual encounter on Sunday, January 7, 1996. Although White House records do not indicate that Ms. Lewinsky was at the White House that day, her testimony and other evidence indicate that she was there. The President, according to White House records, was in the Oval Office most of the afternoon, from 2:13 to 5:49 p.m. According to Ms. Lewinsky, the President telephoned her early that afternoon. It was the first time he had called her at home. In her recollection: "I asked him what he was doing and he said he was going to be going into the office soon. I said, oh, do you want some company? And he said, oh, that would be great." Ms. Lewinsky went to her office, and the President called to arrange their rendezvous: "We made an arrangement that...he would have the door to his office open, and I would pass by the office with some papers and then...he would sort of stop me and invite me in. So, that was exactly what happened. I passed by and that was actually when I saw [Secret Service Uniformed Officer] Lew Fox who was on duty outside the Oval Office, and stopped and spoke with Lew for a few minutes, and then the President came out and said, oh, hey, Monica... come on in... And so we spoke for about 10 minutes in the [Oval] office. We sat on the sofas. Then we went into the back study and we were intimate in the bathroom. Ms. Lewinsky testified that during this bathroom encounter, she and the President kissed, and he touched her bare breasts with his hands and his mouth. The President "was talking about performing oral sex on me," according to Ms. Lewinsky. But she stopped him because she was menstruating and he did not. Ms. Lewinsky did perform oral sex on him. Afterward, she and the President moved to the Oval Office and talked. According to Ms. Lewinsky: "He was chewing on a cigar. And then he had the cigar in his hand and he was kind of looking at the cigar in... sort of a naughty way. And so... I looked at the cigar and I looked at him and I said, we can do that, too, some time." Corroborating aspects of Ms. Lewinsky's recollection, records show that Officer Fox was posted outside the Oval Office the afternoon of January 7. Officer Fox (who is now retired) testified that he recalled an incident with Ms. Lewinsky one weekend afternoon when he was on duty by the Oval Office: "The President of the United States came out, and he asked me, he says, `Have you seen any young congressional staff members here today?' I said, `No, sir.' He said, `Well, I'm expecting one.' He says, `Would you please let me know when they show up?' And I said, `Yes, sir.'

B. January 21 Sexual Encounter

On Sunday, January 21, 1996, according to Ms. Lewinsky, she and the President had another sexual encounter. Her time of White House entry is not reflected in records. She left at 3:56 p.m. The President moved from the Residence to the Oval Office at 3:33 p.m. and remained there until 7:40 p.m. On that day, according to Ms. Lewinsky, she saw the President in a hallway by an elevator, and he invited her to the Oval Office. According to Ms. Lewinsky: We had... had phone sex for the first time the week prior, and I was feeling a little bit insecure about whether he had liked it or didn't like it... I didn't know if this was sort of developing into some kind of a longer-term relationship than what I thought it initially might have been, that maybe he had some regular girlfriend who was furloughed... According to Ms. Lewinsky, she questioned the President about his interest in her. "I asked him why he doesn't ask me any questions about myself, and... is this just about sex... or do you have some interest in trying to get to know me as a person?" The President laughed and said, according to Ms. Lewinsky, that "he cherishes the time that he had with me." She considered it "a little bit odd" for him to speak of cherishing their time together "when I felt like he didn't really even know me yet." They continued talking as they went to the hallway by the study. Then, with Ms. Lewinsky in mid- sentence, "he just started kissing me." He lifted her top and touched her breasts with his hands and mouth. According to Ms. Lewinsky, the President "unzipped his pants and sort of exposed himself," and she performed oral sex. On Sunday, February 4, according to Ms. Lewinsky, she and the President had their sixth sexual encounter and their first lengthy and personal conversation. The President was in the Oval Office from 3:36 to 7:05 p.m. He had no telephone calls in the Oval Office before 4:45 p.m. Records do not show Ms. Lewinsky's entry or exit. According to Ms. Lewinsky, the President telephoned her at her desk and they planned their rendezvous. At her suggestion, they bumped into each other in the hallway, "because when it happened accidentally, that seemed to work really well," then walked together to the area of the private study. There, according to Ms. Lewinsky, they kissed. She was wearing a long dress that buttoned from the neck to the ankles. "And he unbuttoned my dress and he unhooked my bra, and sort of took the dress off my shoulders and... moved the bra... He was looking at me and touching me and telling me how beautiful I was." He touched her breasts with his hands and his mouth, and touched her genitals, first through underwear and then directly. She performed oral sex on him. After their sexual encounter, the President and Ms. Lewinsky sat and talked in the Oval Office for about 45 minutes. Ms. Lewinsky thought the President might be responding to her suggestion during their previous meeting about "trying to get to know me." It was during that conversation on February 4, according to Ms. Lewinsky, that their friendship started to blossom. When she prepared to depart, according to Ms. Lewinsky, the President "kissed my arm and told me he'd call me, and then I said, yeah, well, what's my phone number? And so he recited both my home number and my office number off the top of his head." The President called her at her desk later that afternoon and said he had enjoyed their time together.

D. President's Day (February 19) Break-up

According to Ms. Lewinsky, the President terminated their relationship (only temporarily, as it happened), on Monday, February 19, 1996 - President's Day. The President was in the Oval Office from 11 a.m. to 2:01 p.m. that day. He had no telephone calls between 12:19 and 12:42 p.m. Records do not reflect Ms. Lewinsky's presence at the White House. In Ms. Lewinsky's recollection, the President telephoned her at her Watergate apartment that day. From the tone of his voice, she could tell something was wrong. The President told her that he no longer felt right about their intimate relationship, and he had to put a stop to it. Ms. Lewinsky was welcome to continue coming to visit him, but only as a friend. He hugged her but would not kiss her. At one point during their conversation, the President had a call from a sugar grower in Florida whose name, according to Ms. Lewinsky, was something like "Fanuli." In Ms. Lewinsky's recollection, the President may have taken or returned the call just as she was leaving. After the break-up on February 19, 1996, according to Ms. Lewinsky, "there continued to sort of be this flirtation... when we'd see each other." After passing Ms. Lewinsky in a hallway one night in late February or March, the President telephoned her at home and said he was disappointed that, because she had already left the White House for the evening, they could not get together. Ms. Lewinsky testified that the call "sort of implied to me that he was interested in starting up again." On March 10, 1996, Ms. Lewinsky took a visiting friend, Natalie Ungvari, to the White House. They bumped into the President, who said to Ms. Ungvari when Ms. Lewinsky introduced them: "You must be her friend from California." Ms. Ungvari was "shocked" that the President knew where she was from. Ms. Lewinsky testified that on Friday, March 29, 1996, she was walking down a hallway when she passed the President, who was wearing the first necktie she had given him. She asked where he had gotten the tie, and he replied: "Some girl with style gave it to me." Later, he telephoned her at her desk and asked if she would like to see a movie. His plan was that she would position herself in the hallway by the White House Theater at a certain time, and he would invite her to join him and a group of guests as they entered. Ms. Lewinsky responded that she did not want people to think she was lurking around the West Wing uninvited. She asked if they could arrange a rendezvous over the weekend instead, and he said he would try. Records confirm that the President spent the evening of March 29 in the White House Theater. Mrs. Clinton was in Athens, Greece.

F. March 31 Sexual Encounter

On Sunday, March 31, 1996, according to Ms. Lewinsky, she and the President resumed their sexual contact. Ms. Lewinsky was at the White House from 10:21 a.m. to 4:27 p.m. on that day. The President was in the Oval Office from 3:00 to 5:46 p.m. His only call while in the Oval Office was from 3:06 to 3:07 p.m. Mrs. Clinton was in Ireland. According to Ms. Lewinsky, the President telephoned her at her desk and suggested that she come to the Oval Office on the pretext of delivering papers to him. She went to the Oval Office and was admitted by a plainclothes Secret Service agent. In her folder was a gift for the President, a Hugo Boss necktie. In the hallway by the study, the President and Ms. Lewinsky kissed. On this occasion, according to Ms. Lewinsky, "he focused on me pretty exclusively," kissing her bare breasts and fondling her genitals. At one point, the President inserted a cigar into Ms. Lewinsky's vagina, then put the cigar in his mouth and said: "It tastes good." After they were finished, Ms. Lewinsky left the Oval Office and walked through the Rose Garden.

April 1996: Ms. Lewinsky's Transfer to the Pentagon

A. Earlier Observations of Ms. Lewinsky in the West Wing

Ms. Lewinsky's visits to the Oval Office area had not gone unnoticed. Officer [Lewis] Fox testified that "it was pretty commonly known that she did frequent the West Wing on the weekends". Another Secret Service uniformed officer, William Ludtke III, once saw her exit from the pantry near the Oval Office; she seemed startled and possibly embarrassed to be spotted. Officer John Muskett testified that "if the President was known to be coming into the Diplomatic Reception Room, a lot of times [Ms. Lewinsky] just happened to be walking down the corridor, you know, maybe just to see the President". Ms. Lewinsky acknowledged that she tried to position herself to see the President. Although they could not date them precisely, Secret Service officers and agents testified about several occasions when Ms. Lewinsky and the President were alone in the Oval Office. William C. Bordley, a former member of the Presidential Protective Detail, testified that in late 1995 or early 1996, he stopped Ms. Lewinsky outside the Oval Office because she did not have her pass. The President opened the Oval Office door, indicated to Agent Bordley that Ms. Lewinsky's presence was all right, and ushered Ms. Lewinsky into the Oval Office. Agent Bordley saw Ms. Lewinsky leave about half an hour later.

B. Decision to Transfer Ms. Lewinsky

Ms. [Evelyn] Lieberman [former White House deputy chief of staff] testified that, because Ms. Lewinsky was so persistent in her efforts to be near the President, "I decided to get rid of her." First she consulted Chief of Staff Panetta. According to Mr. Panetta, Ms. Lieberman told him about a woman on the staff who was "spending too much time around the West Wing." Because of "the appearance that it was creating," Ms. Lieberman proposed to move her out of the White House. a transfer.

C. Ms. Lewinsky's Notification of Her Transfer

On Friday, April 5, 1996, Timothy Keating, Staff Director for Legislative Affairs, informed Ms. Lewinsky that she would have to leave her White House job. According to Mr. Keating, he told her that she was not being fired, merely "being given a different opportunity." In fact, she could tell people it was a promotion if she cared to do so. Upon hearing of her dismissal, Ms. Lewinsky burst into tears and asked if there was any way for her to stay in the White House, even without pay. No, Mr. Keating said. According to Ms. Lewinsky, "He told me I was too sexy to be working in the East Wing and that this job at the Pentagon where I'd be writing press releases was a sexier job." Ms. Lewinsky was devastated. She felt that she was being transferred simply because of her relationship with the President. And she feared that with the loss of her White House job, "I was never going to see the President again. I mean, my relationship with him would be over."

D. Conversations with the President about Her Transfer

1. Easter Telephone Conversations and Sexual Encounter

On Easter Sunday, April 7, 1996, Ms. Lewinsky told the President of her dismissal and they had a sexual encounter. Ms. Lewinsky entered the White House at 4:56 and left at 5:28 p.m. The President was in the Oval Office all afternoon, from 2:21 to 7:48 p.m. According to Ms. Lewinsky, the President telephoned her at home that day. After they spoke of the death of the Commerce Secretary the previous week, she told him of her dismissal: "I had asked him... if he was doing okay with Ron Brown's death, and then after we talked about that for a little bit I told him that my last day was Monday. And... he seemed really upset and sort of asked me to tell him what had happened. So I did and I was crying and I asked him if I could come see him, and he said that that was fine." He also indicated that she could have any job she wanted after the election. In addition, the President said he would find out why Ms. Lewinsky was transferred and report back to her. When asked if he had promised to get Ms. Lewinsky another White House job, the President told the grand jury: "What I told Ms. Lewinsky was that... I would do what I could to see, if she had a good record at the Pentagon, and she assured me she was doing a good job and working hard, that I would do my best to see that the fact that she had been sent away from the Legislative Affairs section did not keep her from getting a job in the White House, and that is, in fact, what I tried to do... But I did not tell her I would order someone to hire her, and I never did, and I wouldn't do that. It wouldn't be right." Ms. Lewinsky, when asked if the President had said that he would bring her back to the White House only if she did a good job at the Pentagon, responded: "No." After this Easter Sunday conversation, the President and Ms. Lewinsky had a sexual encounter in the hallway, according to Ms. Lewinsky. She testified that the President touched her breasts with his mouth and hands. According to Ms. Lewinsky: "I think he unzipped [his pants]... because it was sort of this running joke that I could never unbutton his pants, that I just had trouble with it." Ms. Lewinsky performed oral sex. The President did not ejaculate in her presence. During this encounter, someone called out from the Oval Office that the President had a phone call. He went back to the Oval Office for a moment, then took the call in the study. The President indicated that Ms. Lewinsky should perform oral sex while he talked on the phone, and she obliged. The telephone conversation was about politics, and Ms. Lewinsky thought the caller might be Dick Morris. White House records confirm that the President had one telephone call during Ms. Lewinsky's visit: from "Mr. Richard Morris," to whom he talked from 5:11 to 5:20 p.m. A few minutes later, according to Officer Muskett, Mr. Ickes approached and said he needed to see President Clinton. Officer Muskett admitted him through Ms. Currie's office. Less than a minute after Mr. Ickes entered Ms. Currie's reception area, according to Officer Muskett, the pantry or dining room door closed audibly. Officer Muskett stepped down the hall to check and saw Ms. Lewinsky walking away briskly. At 5:30 p.m., two minutes after Ms. Lewinsky left the White House, the President called the office of the person who had decided to transfer Ms. Lewinsky, Evelyn Lieberman.

2. April 12-13: Telephone Conversations

Ms. Lewinsky testified that the President telephoned her the following Friday, April 12, 1996, at home. They talked for about 20 minutes. According to Ms. Lewinsky, the President said he had checked on the reason for her transfer: "He had come to learn... that Evelyn Lieberman had sort of spearheaded the transfer, and that she thought he was paying too much attention to me and I was paying too much attention to him and that she didn't necessarily care what happened after the election but everyone needed to be careful before the election." According to Ms. Lewinsky, the President told her to give the Pentagon a try, and, if she did not like it, he would get her a job on the campaign. A. Pentagon Job. On April 16, 1996, Ms. Lewinsky began working at the Pentagon as Confidential Assistant to the Assistant Secretary of Defense for Public Affairs.

B. No Physical Contact

According to Ms. Lewinsky, she had no physical contact with the President for the rest of 1996. "I wasn't alone with him so when I saw him it was in some sort of event or group setting," she testified.

C. Telephone Conversations

Ms. Lewinsky and the President did talk by telephone, especially in her first weeks at the new job. By Ms. Lewinsky's estimate, the President phoned her (sometimes leaving a message) four or five times in the month after she started working at the Pentagon, then two or three times a month thereafter for the rest of 1996. During the fall 1996 campaign, the President sometimes called from trips when Mrs. Clinton was not accompanying him. During at least seven of the 1996 calls, Ms. Lewinsky and the President had phone sex. According to Ms. Lewinsky, the President telephoned her at about 6:30 a.m. on July 19, the day he was leaving for the 1996 Olympics in Atlanta, and they had phone sex, after which the President exclaimed, "Good morning!" and then said: "What a way to start a day." A call log shows that the President called the White House operator at 12:11 a.m. on July 19 and asked for a wake-up call at 7 a.m., then at 6:40 a.m., the President called and said he was already up. In Ms. Lewinsky's recollection, she and the President also had phone sex on May 21, July 5 or 6, October 22, and December 2, 1996. On those dates, Mrs. Clinton was in Denver (May 21), Prague and Budapest (July 5-6), Las Vegas (October 22), and en route to Bolivia (December 2). Ms. Lewinsky repeatedly told the President that she disliked her Pentagon job and wanted to return to the White House. In a recorded conversation, Ms. Lewinsky recounted one call: "A month had passed and - so he had called one night, and I said, `Well,' I said, `I'm really unhappy,' you know. And [the President] said, `I don't want to talk about your job tonight. I'll call you this week, and then we'll talk about it. I want to talk about other things' - which meant phone sex."

E. Ms. Lewinsky's Frustrations

Continuing to believe that her relationship with the President was the key to regaining her White House pass, Ms. Lewinsky hoped that the President would get her a job immediately after the election. "I kept a calendar with a countdown until election day," she later wrote in an unsent letter to him. The letter states: "I was so sure that the weekend after the election you would call me to come visit and you would kiss me passionately and tell me you couldn't wait to have me back. You'd ask me where I wanted to work and say something akin to `Consider it done' and it would be. Instead I didn't hear from you for weeks and subsequently your phone calls became less frequent." Ms. Lewinsky grew increasingly frustrated over her relationship with President Clinton. One friend understood that Ms. Lewinsky complained to the President about not having seen each other privately for months, and he replied, "Every day can't be sunshine." In email to another friend in early 1997, Ms. Lewinsky wrote: "I just don't understand what went wrong, what happened? How could he do this to me? Why did he keep up contact with me for so long and now nothing, now when we could be together?"

Early 1997: Resumption of Sexual Encounters

In 1997, President Clinton and Ms. Lewinsky had further private meetings, which now were arranged by Betty Currie, the President's secretary. After the taping of the President's weekly radio address on February 28, the President and Ms. Lewinsky had a sexual encounter. On March 24, they had what proved to be their final sexual encounter. Throughout this period, Ms. Lewinsky continued to press for a job at the White House, to no avail.

A. Resumption of Meetings with the President

1. Role of Betty Currie

a. Arranging Meetings

In 1997, with the presidential election past, Ms. Lewinsky and the President resumed their one-on-one meetings and sexual encounters. The President's secretary, Betty Currie, acted as intermediary. According to Ms. Currie, Ms. Lewinsky would often call her and say she wanted to see the President, sometimes to discuss a particular topic. Ms. Currie would ask President Clinton, and, if he agreed, arrange the meeting. Ms. Currie also said it was "not unusual" that Ms. Lewinsky would talk by phone with the President and then call Ms. Currie to set up a meeting. At times, Ms. Currie placed calls to Ms. Lewinsky for President Clinton and put him on the line. The meetings between the President and Ms. Lewinsky often occurred on weekends. When Ms. Lewinsky would arrive at the White House, Ms. Currie generally would be the one to authorize her entry and take her to the West Wing. Ms. Currie acknowledged that she sometimes would come to the White House for the sole purpose of having Ms. Lewinsky admitted and bringing her to see the President. According to Ms. Currie, Ms. Lewinsky and the President were alone together in the Oval Office or the study for 15 to 20 minutes on multiple occasions.

b intermediary for gifts

Ms. Lewinsky also sent over a number of packages - six or eight, Ms. Currie estimated. According to Ms. Currie, Ms. Lewinsky would call and say she was sending something for the President. The package would arrive addressed to Ms. Currie. Courier receipts show that Ms. Lewinsky sent seven packages to the White House between October 7 and December 8, 1997. Evidence indicates that Ms. Lewinsky on occasion also dropped parcels off with Ms. Currie or had a family member do so, and brought gifts to the President when visiting him. Ms. Currie testified that most packages from Ms. Lewinsky were intended for the President. Although Ms. Currie generally opened letters and parcels to the President, she did not open these packages from Ms. Lewinsky. She testified that "I made the determination not to open" such letters and packages because "I felt [they were] probably personal." Instead, she would leave the package in the President's box, and "he would pick it up." To the best of her knowledge, such parcels always reached the President.

c. Secrecy

Ms. Currie testified that she suspected impropriety in the President's relationship with Ms. Lewinsky. She told the grand jury that she "had concern." In her words: "He was spending a lot of time with a 24-year- old young lady. I know he has said that young people keep him involved in what's happening in the world, so I knew that was one reason, but there was a concern of mine that she was spending more time than most."

B. Valentine's Day Advertisement

On February 14, 1997, the Washington Post published a Valentine's Day "Love Note" that Ms. Lewinsky had placed. The ad said: HANDSOME With love's light wings did I o'er perch these walls For stony limits cannot hold love out, And what love can do that dares love attempt. - Romeo and Juliet 2:2 Happy Valentine's Day.

C. February 24 Message

On February 24, Ms. Lewinsky visited the White House on Pentagon business. She went by Ms. Currie's office. Ms. Currie sent a note to the President - the only such note turned over by the White House in response to a grand jury subpoena: "Monica Lewinsky stopped by. Do you want me to call her?"

D. February 28 Sexual Encounter

According to Ms. Lewinsky, she and the President had a sexual encounter on Thursday, February 28 - their first in nearly 11 months. White House records show that Ms. Lewinsky attended the taping of the President's weekly radio address on February 28. She was at the White House from 5:48 to 7:07 p.m. The President was in the Roosevelt Room (where the radio address was taped) from 6:29 to 6:36 p.m., then moved to the Oval Office, where he remained until 7:24 p.m. He had no telephone calls while Ms. Lewinsky was in the White House. Wearing a navy blue dress from the Gap, Ms. Lewinsky attended the radio address at the President's invitation (relayed by Ms. Currie), then had her photo taken with the President. Ms. Lewinsky had not been alone with the President since she had worked at the White House, and, she testified, "I was really nervous." President Clinton told her to see Ms. Currie after the photo was taken because he wanted to give her something. "So I waited a little while for him and then Betty and the President and I went into the back office," Ms. Lewinsky testified. (She later learned that the reason Ms. Currie accompanied them was that [presidential aide] Stephen Goodin did not want the President to be alone with Ms. Lewinsky, a view that Mr. Goodin expressed to the President and Ms. Currie.) Once they had passed from the Oval Office toward the private study, Ms. Currie said, "I'll be right back," and walked on to the back pantry or the dining room, where, according to Ms. Currie, she waited for 15 to 20 minutes while the President and Ms. Lewinsky were in the study. Ms. Currie (who said she acted on her own initiative) testified that she accompanied the President and Ms. Lewinsky out of the Oval Office because "I didn't want any perceptions, him being alone with someone." In the study, according to Ms. Lewinsky, the President "started to say something to me and I was pestering him to kiss me, because... it had been a long time since we had been alone." The President told her to wait a moment, as he had presents for her. As belated Christmas gifts, he gave her a hat pin and a special edition of Walt Whitman's Leaves of Grass. Ms. Lewinsky described the Whitman book as "the most sentimental gift he had given me... it's beautiful and it meant a lot to me." During this visit, according to Ms. Lewinsky, the President said he had seen her Valentine's Day message in the Washington Post, and he talked about his fondness for "Romeo and Juliet." Ms. Lewinsky testified that after the President gave her the gifts, they had a sexual encounter: "We went back over by the bathroom in the hallway, and we kissed. We were kissing and he unbuttoned my dress and fondled my breasts with my bra on, and then took them out of my bra and was kissing them and touching them with his hands and with his mouth. And then I think I was touching him in his genital area through his pants, and I think I unbuttoned his shirt and was kissing his chest. And then... I wanted to perform oral sex on him... and so I did. And then... I think he heard something, or he heard someone in the office. So, we moved into the bathroom. And I continued to perform oral sex and then he pushed me away, kind of as he always did before he came, and then I stood up and I said I care about you so much... I don't understand why you won't let me... make you come; it's important to me; I mean, it just doesn't feel complete, it doesn't seem right. Ms. Lewinsky testified that she and the President hugged, and "he said he didn't want to get addicted to me, and he didn't want me to get addicted to him." They looked at each other for a moment. Then, saying that "I don't want to disappoint you," the President consented. For the first time, she performed oral sex through to completion. When Ms. Lewinsky next took the navy blue Gap dress from her closet to wear it, she noticed stains near one hip and on the chest. FBI Laboratory tests revealed that the stains are the President's semen. In his grand jury testimony, the President - who, because the OIC had asked him for a blood sample (and had represented that it had ample evidentiary justification for making such a request), had reason to suspect that Ms. Lewinsky's dress might bear traces of his semen - indicated that he and Ms. Lewinsky had had sexual contact on the day of the radio address. He testified: "I was sick after it was over and I, I was pleased at that time that it had been nearly a year since any inappropriate contact had occurred with Ms. Lewinsky. I promised myself it wasn't going to happen again. The facts are complicated about what did happen and how it happened. But, nonetheless, I'm responsible for it." Later the President added, referring to the evening of the radio address: "I do believe that I was alone with her from 15 to 20 minutes. I do believe that things happened then which were inappropriate." He said of the intimate relationship with Ms. Lewinsky: "I never should have started it, and I certainly shouldn't have started it back after I resolved not to in 1996."

E. March 29 Sexual Encounter

According to Ms. Lewinsky, she had what proved to be her final sexual encounter with the President on Saturday, March 29, 1997. Records show that she was at the White House from 2:03 to 3:16 p.m., admitted by Ms. Currie. The President was in the Oval Office during this period (he left shortly after Ms. Lewinsky did, at 3:24 p.m.), and he did not have any phone calls during her White House visit. According to Ms. Lewinsky, Ms. Currie arranged the meeting after the President said by telephone that he had something important to tell her. At the White House, Ms. Currie took her to the study to await the President. He came in on crutches, the result of a knee injury in Florida two weeks earlier. According to Ms. Lewinsky, their sexual encounter began with a sudden kiss: "This was another one of those occasions when I was babbling on about something, and he just kissed me, kind of to shut me up, I think."The President unbuttoned her blouse and touched her breasts without removing her bra. "He went to go put his hand down my pants, and then I unzipped them because it was easier. And I didn't have any panties on. And so he manually stimulated me." According to Ms. Lewinsky, "I wanted him to touch my genitals with his genitals," and he did so, lightly and without penetration. Then Ms. Lewinsky performed oral sex on him, again until he ejaculated. According to Ms. Lewinsky, she and the President had a lengthy conversation that day. He told her that he suspected that a foreign embassy (he did not specify which one) was tapping his telephones, and he proposed cover stories. If ever questioned, she should say that the two of them were just friends. If anyone ever asked about their phone sex, she should say that they knew their calls were being monitored all along, and the phone sex was just a put-on. In his grand jury testimony, the President implicitly denied this encounter. He acknowledged "inappropriate intimate contact" with Ms. Lewinsky "on certain occasions in early 1996 and once in early 1997." The President indicated that "the one occasion in 1997" was the radio address.

F. Continuing Job Efforts

With the 1996 election past, meanwhile, Ms. Lewinsky had continued striving to get a job at the White House. She testified that she first broached the issue in a telephone call with the President in January 1997, and he said he would speak to Bob Nash, Director of Presidential Personnel. She understood that Mr. Nash was supposed to "find a position for me to come back to the White House." Over the months that followed, Ms. Lewinsky repeatedly asked the President to get her a White House job. In her recollection, the President replied that various staff members were working on it, including Mr. Nash and Marsha Scott, Deputy Assistant to the President and Deputy Director for Presidential Personnel. According to Ms. Lewinsky, the President told her: " `Bob Nash is handling it', `Marsha's going to handle it' and `We just sort of need to be careful.' You know, and... he would always sort of... validate what I was feeling by telling me something that I don't necessarily know is true. `Oh, I'll talk to her', `I'll - you know, I'll see blah, blah, blah,' and it was just `I'll do', `I'll do', `I'll do.' And didn't, didn't, didn't." Ms. Lewinsky came to wonder if she was being "strung along."

May 1997: Termination of Sexual Relationship

In May 1997, amid indications that Ms. Lewinsky had been indiscreet, President Clinton terminated the sexual relationship.

A. Questions about Ms. Lewinsky's Discretion

In April or May 1997, according to Ms. Lewinsky, the President asked if she had told her mother about their intimate relationship. She responded: "No. Of course not." (In truth, she had told her mother.) The President indicated that Ms. Lewinsky's mother possibly had said something about the nature of the relationship to Walter Kaye, who had mentioned it to Marsha Scott, who in turn had alerted the President. Corroborating Ms. Lewinsky's account, Mr. Kaye testified that he told Ms. Lewinsky's aunt, Debra Finerman, that he understood that "her niece was very aggressive," a remark that angered Ms. Finerman. Ms. Finerman told Mr. Kaye that the President was the true aggressor: He was telephoning Ms. Lewinsky late at night. Ms. Finerman, in Mr. Kaye's recollection, attributed this information to Marcia Lewis, Ms. Lewinsky's mother (and Ms. Finerman's sister). Mr. Kaye - who had disbelieved stories he had heard from Democratic National Committee people about an affair between Ms. Lewinsky and the President - testified that he was "shocked" to hear of the late-night phone calls.

B. May 24: Break-up

On Saturday, May 24, 1997, according to Ms. Lewinsky, the President ended their intimate relationship. Ms. Lewinsky was at the White House that day from 12:21 to 1:54 p.m. The President was in the Oval Office during most of this period, from 11:59 a.m. to 1:47 p.m. He did not have any telephone calls. According to Ms. Lewinsky, she got a call from Ms. Currie at about 11 a.m. that day, inviting her to come to the White House at about 1 p.m. Ms. Lewinsky arrived wearing a straw hat with the hat pin the President had given her, and bringing gifts for him, including a puzzle and a Banana Republic shirt. She gave him the gifts in the dining room, and they moved to the area of the study. According to Ms. Lewinsky, the President explained that they had to end their intimate relationship. Earlier in his marriage, he told her, he had had hundreds of affairs; but since turning 40, he had made a concerted effort to be faithful. He said he was attracted to Ms. Lewinsky, considered her a great person, and hoped they would remain friends. He pointed out that he could do a great deal for her. The situation, he stressed, was not Ms. Lewinsky's fault. Ms. Lewinsky, weeping, tried to persuade the President not to end the sexual relationship, but he was unyielding, then and subsequently. Although she and the President kissed and hugged thereafter, according to Ms. Lewinsky, the sexual relationship was over. Three days after this meeting, on May 27, 1997, the Supreme Court unanimously rejected President Clinton's claim that the Constitution immunized him from civil lawsuits. The Court ordered the sexual harassment case Jones v. Clinton to proceed.

June-October 1997: Continuing Meetings and Calls

Ms. Lewinsky tried to return to the White House staff and to revive her sexual relationship with the President, but she failed at both. On Friday, July 4, 1997, Ms. Lewinsky had what she characterized as a "very emotional" visit with the President. Records show that Ms. Lewinsky entered the White House at 8:51 a.m.; no exit time is recorded. Logs indicate that the President was in the Oval Office from 8:40 until after 11 a.m. In Ms. Lewinsky's recollection, their meeting began contentiously, with the President scolding her: "It's illegal to threaten the President of the United States." He then told her that he had not read her July 3 letter beyond the "Dear Sir" line; he surmised that it was threatening because Ms. Currie looked upset when she brought it to him. (Ms. Lewinsky suspected that he actually had read the whole thing.) Ms. Lewinsky complained about his failure to get her a White House job after her long wait. Although the President claimed he wanted to be her friend, she said, he was not acting like it. Ms. Lewinsky began weeping, and the President hugged her. While they hugged, she spotted a gardener outside the study window, and they moved into the hallway by the bathroom. There, the President was "the most affectionate with me he'd ever been," Ms. Lewinsky testified. He stroked her arm, toyed with her hair, kissed her on the neck, praised her intellect and beauty. In Ms. Lewinsky's recollection: "He remarked... that he wished he had more time for me. And so I said, well, maybe you will have more time in three years. And I was... thinking just when he wasn't President, he was going to have more time on his hands. And he said, well, I don't know, I might be alone in three years. And then I said something about... us sort of being together. I think I kind of said, oh, I think we'd be a good team, or something like that. And he... jokingly said, well, what are we going to do when I'm 75 and I have to pee 25 times a day? And... I told him that we'd deal with that... On Saturday, August 16, 1997, Ms. Lewinsky tried, unsuccessfully, to resume her sexual relationship with the President. She visited the White House on that day from 9:02 to 10:20 a.m. The President moved from the Residence to the Oval Office at 9:20 a.m. and remained in the Oval Office until 10:03 a.m. After a one-minute call to Betty Currie at her desk at 9:18 a.m., evidently from the Residence, the President had no calls while Ms. Lewinsky was at the White House. The next day he left for a vacation on Martha's Vineyard. Ms. Lewinsky testified that she brought birthday gifts for the President (his birthday is August 19): "I had set up in his back office, I had brought an apple square and put a candle and had put his birthday presents out. And after he came back in and I sang happy birthday and he got his presents, I asked him... if we could share a birthday kiss in honor of our birthdays, because mine had been just a few weeks before. So, he said that that was okay and we could kind of bend the rules that day. And so... we kissed. Ms. Lewinsky touched the President's genitals through his pants and moved to perform oral sex, but the President rebuffed her. In her recollection: "He said, I'm trying not to do this and I'm trying to be good... He got visibly upset. And so... I hugged him and I told him I was sorry and not to be upset." Later, in a draft note to "Handsome," Ms. Lewinsky referred to this visit: "It was awful when I saw you for your birthday in August. You were so distant that I missed you as I was holding you in my arms."

Continuing Job Efforts

Ms. Lewinsky and Ms. Scott talked by phone on September 3, 1997, for 47 minutes. According to notes that Ms. Lewinsky wrote to two friends, Ms. Scott told her that the detail slot in her office had been eliminated. Ms. Lewinsky told one friend: "So for now, there isn't any place for me to be detailed. So I should be PATIENT. I told her I was very upset and disappointed (even though I really didn't want to work for her) and then she and I got into it. She didn't understand why I wanted to come back when there were still people there who would give me a hard time and that it isn't the right political climate for me to come back... She asked me why I kept pushing the envelope on coming back there - after all, I had the experience of being there already. So it's over. I don't know what I will do now but I can't wait any more and I can't go through all of this crap anymore. In some ways I hope I never hear from him again because he'll just lead me on because he doesn't have the balls to tell me the truth." When terminating their sexual relationship on May 24, the President had told Ms. Lewinsky that he hoped they would remain friends, for he could do a great deal for her. Now, having learned that he could not (or would not) get her a White House job, Ms. Lewinsky decided to ask him for a job in New York, perhaps at the United Nations - a possibility that she had mentioned to him in passing over the summer. On the afternoon of October 6, Ms. Lewinsky spoke of this plan to Ms. Currie, who quoted the President as having said earlier: "Oh, that's no problem. We can place her in the UN like that." In a recorded conversation later on October 6, Ms. Lewinsky said she wanted two things from the President. The first was contrition: "He needed to "acknowledge... that he helped fuck up my life." The second was a job, one that she could obtain without much effort: "I don't want to have to work for this position... I just want it to be given to me." Ms. Lewinsky decided to write the President a note proposing that the two of them "get together and work on some way that I can come out of this situation not feeling the way I do." After composing the letter, she said: "I want him to feel a little guilty, and I hope that this letter did that." In this letter, which was sent via courier on October 7, Ms. Lewinsky said she understood that she would never be given a White House job, and she asked for a prompt meeting to discuss her job situation. She went on to advance a specific request: "I'd like to ask you to help me secure a position in NY beginning 1 December. I would be very grateful, and I am hoping this is a solution for both of us. I want you to know that it has always been and remains more important to me to have you in my life than to come back... Please don't let me down."

October-November 1997: United Nations' Job Offer

Having learned that she would not be able to return to the White House, Ms. Lewinsky sought the President's help in finding a job in New York City. The President offered to place her at the United Nations. After initial enthusiasm, Ms. Lewinsky cooled on the idea of working at the UN, and she prodded the President to get her a job in the private sector.

D. The President Creates Options

At some point around this time in the fall of 1997, Ms. Currie asked John Podesta, the Deputy Chief of Staff, to help Ms. Lewinsky find a job in New York. Mr. Podesta testified that, during a Presidential trip to Latin America, he approached then-UN Ambassador William Richardson while aboard Air Force One and asked the Ambassador to consider a former White House intern for a position at the U.N. At the time, Mr. Podesta could not recall the intern's name. Ambassador Richardson and the President both testified that they never discussed Ms. Lewinsky with each other. Ambassador Richardson returned from Latin America on Sunday, October 19. Within a few days, his Executive Assistant, Isabelle Watkins, called Mr. Podesta's secretary and asked whether "she knew anything about a resume that John was going to send us." Mr. Podesta's secretary knew nothing about it and asked Mr. Podesta what to do; he instructed her to call Ms. Currie. At 3:09 p.m. on October 21, Ms. Currie faxed Ms. Lewinsky's resume to the United Nations. At 7:01 p.m., a six-minute call was placed to Ms. Lewinsky's apartment from a UN telephone number identified in State Department records as "Ambassador Richardson's line." Ms. Lewinsky testified that she spoke to Ambassador Richardson. A woman called, Ms. Lewinsky testified, and said, "Hold for Ambassador Richardson." Then the Ambassador himself came on the line: "I remember, because I was shocked and I was... very nervous." The purpose of the call was to schedule a job interview at a Watergate apartment the following week. At odds with Ms. Lewinsky, the Ambassador and Ms. Watkins both testified that Ms. Watkins, not the Ambassador, spoke with Ms. Lewinsky. A few days later, according to Ms. Lewinsky, the President called her. She had been upset because no one at the White House had prepared her for the Ambassador's recent call and because she did not want the White House to railroad her into taking the UN job. She reiterated that she was eager to pursue other opportunities, especially in the private sector. The President reassured her, promising that a UN position was just one of many options. Ms. Lewinsky met with Vernon Jordan, who promised to help her find a job in New York. November proved, however, to be a month of inactivity with respect to both Ms. Lewinsky's job search and her relationship with the President. Mr. Jordan did not meet with Ms. Lewinsky again, nor did he contact anyone in New York City on her behalf. Ms. Lewinsky became increasingly anxious about her inability to see the President. Except for a momentary encounter in mid-November, Ms. Lewinsky did not meet with the President between October 11 and December 5.

A. Interrogatories Answered

On November 3, 1997, the President answered Paula Jones's Second Set of Interrogatories. Two of those interrogatories asked the President to list any woman other than his wife with whom he had "had", "proposed having", or "sought to have" sexual relations during the time that he was Attorney General of Arkansas, Governor of Arkansas, and President of the United States. President Clinton objected to the scope and relevance of both interrogatories and refused to answer them.

B. First Vernon Jordan Meeting

In mid-October, the President had agreed to involve Vernon Jordan in Ms. Lewinsky's job search. In a draft letter to Ms. Currie dated November 2, Ms. Lewinsky wrote that the President had "said he would ask you to set up a meeting between VJ and myself." According to Ms. Lewinsky, on November 3 or November 4, Ms. Currie told her to call Vernon Jordan's secretary to arrange a meeting. Ms. Currie said she had spoken with Mr. Jordan and he was expecting Ms. Lewinsky's call. In Ms. Lewinsky's account, Ms. Currie sought Mr. Jordan's aid at the President's direction. Mr. Jordan likewise testified that, in his understanding, the President was behind Ms. Currie's request. When pressed, the President testified that he did not think that he was the "precipitating force" in arranging the meeting between Mr. Jordan and Ms. Lewinsky. At 8:50 a.m. on November 5, Mr. Jordan spoke with the President by telephone for five minutes. Later that morning, Mr. Jordan and Ms. Lewinsky met in his office for about twenty minutes. She told him that she intended to move to New York, and she named several companies where she hoped to work. She showed him the "wish list" that she had sent the President on October 16. Mr. Jordan said that he had spoken with the President about her and that she came "highly recommended." Concerning her job search, Mr. Jordan said: "We're in business."

C. November 13: The Zedillo Visit

On Thursday, November 13, while Ernesto Zedillo, the President of Mexico, was in the White House, Ms. Lewinsky met very briefly with President Clinton in the private study. Ms. Lewinsky's visit, which she described in an email as a "hysterical escapade," was the culmination of days of phone calls and notes to Ms. Currie and the President. Over the course of the week that preceded November 13, Ms. Lewinsky made several attempts to arrange a visit with the President. On Monday, November 10, in addition to making frequent calls to Ms. Currie, she sent the President a note asking for a meeting. She hoped to see him on Tuesday, November 11 (Veterans Day), but he did not respond. By courier, she sent the President another note: "I asked you three weeks ago to please be sensitive to what I am going through right now and to keep in contact with me, and yet I'm still left writing notes in vain. I am not a moron. I know that what is going on in the world takes precedence, but I don't think what I have asked you for is unreasonable. She added: "This is so hard for me. I am trying to deal with so much emotionally, and I have nobody to talk to about it. I need you right now not as president, but as a man. PLEASE be my friend."

December 5-18, 1997: The Witness List and Job Search

On Friday, December 5, Paula Jones's attorneys faxed a list of their potential witnesses - including Ms. Lewinsky - to the President's personal attorneys. The following day, President Clinton saw Ms. Lewinsky in an unscheduled visit and then discussed the Jones case with his attorneys and Deputy White House Counsel Bruce Lindsey. A few days later, Ms. Lewinsky met with Mr. Jordan at his office, and he arranged interviews for Ms. Lewinsky at three companies. In the middle of the night on December 17, the President called and informed Ms. Lewinsky that she was on the witness list and that she might have to testify under oath in the Jones case.

C. December 6: The Northwest Gate Incident

1. Initial Visit and Rejection

On the morning of Saturday, December 6, Ms. Lewinsky went to the White House to deliver the letter and gifts to the President. The gifts included a sterling silver antique cigar holder, a tie, a mug, a "Hugs and Kisses" box, and an antique book about Theodore Roosevelt. Ms. Lewinsky planned to leave the parcel with Ms. Currie, who had told Ms. Lewinsky that the President would be busy with his lawyers and unable to see her. Ms. Lewinsky arrived at the White House at approximately 10:00 a.m. She told the Secret Service uniformed officers at the Northwest Gate that she had gifts to drop off for the President, but that Ms. Currie did not know she was coming. Ms. Lewinsky and the officers made several calls in an attempt to locate Ms. Currie. The officers eventually invited Ms. Lewinsky inside the guard booth. When Ms. Currie learned that Ms. Lewinsky was at the Northwest Gate, she sent word that the President "already had a guest in the `Oval', so the officers should have Ms. Lewinsky wait there for about 40 minutes. While Ms. Lewinsky was waiting, one officer mentioned that Eleanor Mondale was in the White House. Ms. Lewinsky correctly surmised that the President was meeting with Ms. Mondale, rather than his lawyers, and she was "livid." She stormed away, called and berated Ms. Currie from a pay phone, and then returned to her Watergate apartment. Hands shaking and almost crying, Ms. Currie informed several Secret Service officers that the President was "irate" that someone had disclosed to Ms. Lewinsky whom he was meeting with. Ms. Currie told Sergeant Keith Williams, a supervisory uniformed Secret Service Officer, that if he "didn't find out what was going on, someone could be fired." She also told Captain Jeffrey Purdie, the Secret Service watch commander for the uniformed division at the time, that the President was "so upset he wants somebody fired over this."

2. Ms. Lewinsky Returns to the White House

From her apartment, Ms. Lewinsky reached the President on the phone. According to Ms. Lewinsky, the President was angry that she had "made a stink" and said that "it was none of my business ... what he was doing." Then, to Ms. Lewinsky's surprise, the President invited her to visit him.She testified that "none of the other times that we had really fought on the phone did it end up resulting in a visit that day." WAVES records reflect that Ms. Lewinsky was cleared to enter the White House at 12:52 p.m. and exited at 1:36 p.m. During their meeting, Ms. Lewinsky told the President that Mr. Jordan had done nothing to help her find a job. The President responded, "Oh, I'll talk to him. I'll get on it." Ms. Lewinsky testified that, overall, she had a "really nice" and "affectionate" visit with the President. In an email to a friend a few days later, she wrote that, although "things have been crazy with the creep... I did have a wonderful visit with him on Saturday. When he doesn't put his walls up, it is always heavenly."

3. "Whatever Just Happened Didn't Happen"

Later that day (December 6), the uniformed Secret Service officers at the Northwest Gate were told that no one would be fired - so long as they remained quiet. According to Sergeant Williams, Ms. Currie said that, if the officers did not "tell a lot of people what had happened, then nothing would happen." The President told Captain Jeffrey Purdie, the Secret Service watch commander for the uniformed division at the time, "I hope you use your discretion." Ms. Lewinsky was served with a subpoena in the Jones case on Friday, December 19. She immediately called Mr. Jordan, and he invited her to his office. Mr. Jordan spoke with the President that afternoon and again that evening. He told the President that he had met with Ms. Lewinsky, that she had been subpoenaed, and that he planned to obtain an attorney for her. On Sunday, December 28, the President met with Ms. Lewinsky, who expressed concern about the subpoena's demand for the gifts he had given her. Later that day, Ms. Currie drove to Ms. Lewinsky's apartment and collected a box containing some of the subpoenaed gifts. Ms. Currie took the box home and hid it under her bed. Ms. Lewinsky testified that, after being served with the subpoena, she "burst into tears," and then telephoned Mr. Jordan from a pay phone at the Pentagon. Mr. Jordan confirmed Ms. Lewinsky's account; he said he tried to reassure Ms. Lewinsky: "Come and talk to me and I will see what I can do about finding you counsel." According to records maintained by Mr. Jordan's law firm, Ms. Lewinsky arrived at his office at 4:47 p.m. White House phone records show that, at 4:57 p.m., the President telephoned Mr. Jordan; the two men spoke from 5:01 p.m. to 5:05 p.m. At 5:06 p.m., Mr. Jordan placed a two-minute call to a Washington, D.C., attorney named Francis Carter. Ms. Lewinsky and Mr. Jordan gave somewhat different accounts of their meeting that day. According to Ms. Lewinsky, shortly after her arrival, Mr. Jordan received a phone call, and she stepped out of his office. A few minutes later, Ms. Lewinsky was invited back in, and Mr. Jordan called Mr. Carter. Mr. Jordan testified that he spoke to the President before Ms. Lewinsky ever entered his office. He told the President: "Monica Lewinsky called me up. She's upset. She's gotten a subpoena. She is coming to see me about this subpoena. I'm confident that she needs a lawyer, and I will try to get her a lawyer." Mr. Jordan told the President that the lawyer he had in mind was Francis Carter. According to Mr. Jordan, the President asked him: "You think he's a good lawyer?" Mr. Jordan responded that he was. Mr. Jordan testified that informing the President of Ms. Lewinsky's subpoena "was the purpose of [his] call." Ms. Lewinsky testified, however, that at this time she assumed that Mr. Jordan knew "with a wink and a nod that [she] was having a relationship with the President." She therefore interpreted Mr. Jordan's questions as "What are you going to say?" rather than "What are the [actual] answers . . .?" When the meeting ended, she "asked [Mr. Jordan] if he would give the President a hug." That evening, Mr. Jordan visited the President at the White House. According to Mr. Jordan, the two met alone in the Residence and talked for about ten minutes. He testified: "I told him that Monica Lewinsky had been subpoenaed, came to me with a subpoena. I told him that I was concerned by her fascination, her being taken with him. I told him how emotional she was about having gotten the subpoena. I told him what she said to me about whether or not he was going to leave the First Lady at the end of the term." Mr. Jordan asked the President "The one question that I wanted answered." That question was, "Mr. President, have you had sexual relations with Monica Lewinsky?" The President told Mr. Jordan, "No, never." Mr. Jordan told the President: "I'm trying to help her get a job and I'm going to continue to do that. I'm going to get her counsel and I'm going to try to be helpful to her as much as I possibly can, both with the lawyer, and I've already done what I could about the job, and I think you ought to know that." Mr. Jordan testified: "He thanked me for telling him. Thanked me for my efforts to get her a job and thanked me for getting her a lawyer." In his grand jury testimony, the President recalled that he met with Mr. Jordan on December 19; however, he testified that his memory of that meeting was somewhat vague: "I do not remember exactly what the nature of the conversation was. I do remember that I told him that there was no sexual relationship between me and Monica Lewinsky, which was true. And that - then all I remember for the rest is that he said he had referred her to a lawyer, and I believe it was Mr. Carter."

E. December 28: Concealment of Gifts

In the afternoon of December 28, a few hours after Ms. Lewinsky's White House visit, Ms. Currie drove to Ms. Lewinsky's Watergate apartment and collected a box containing the President's gifts. Ms. Currie then took the box home and hid it under her bed. Ms. Lewinsky, Ms. Currie, and the President were all questioned as to why Ms. Currie retrieved the box of gifts from Ms. Lewinsky. According to Ms. Lewinsky, the transfer originated in a phone call from Ms. Currie that afternoon. Ms. Lewinsky testified that Ms. Currie said, "I understand you have something to give me," or, "The President said you have something to give me." Ms. Lewinsky understood that Ms. Currie was alluding to the gifts. Ms. Currie said that she would stop by Ms. Lewinsky's apartment and pick up the items. Ms. Lewinsky testified that she put many, but not all, of her gifts from the President into a box. Ms. Currie drove by her apartment and picked it up. Ms. Lewinsky was concerned because the gifts were under subpoena; she did not throw them away, however, because "they meant a lot to [her]." The reason she gave the gifts to Ms. Currie, and not to one of her friends or her mother, was "a little bit of an assurance to the President... that everything was okay." She felt that, because the gifts were with Ms. Currie, they were within the President's control: "Not that [the gifts] were going to be in his possession, but that he would understand whatever it was I gave to Betty and that that might make him feel a little bit better." Ms. Lewinsky's account of the events of December 28 in her sworn statement of February 1, 1998, corroborates her later grand jury testimony: "Ms. L... asked if she should put away (outside her home) the gifts he had given her or, maybe, give them to someone else. Ms. Currie called Ms. L later that afternoon as said that the Pres. had told her Ms. L. wanted her to hold onto something for her. Ms. L boxed up most of the gifts she had received and gave them to Ms. Currie. It is unknown if Ms. Currie knew the contents of the box."

C. January 6: The Draft Affidavit

According to Ms. Lewinsky, in the afternoon of January 6, 1998, she visited Mr. Carter's office and picked up a draft of the affidavit. Later that day, according to Ms. Lewinsky, she and Mr. Jordan discussed the draft by telephone. Ms. Lewinsky testified that having Mr. Jordan review the affidavit was like getting it "blessed" by the President.

D. January 9: "Mission Accomplished"

On the morning of Friday, January 9, 1998, Ms. Lewinsky interviewed with Allyn Seidman, Senior Vice President of MFH, and two individuals at Revlon. Ms. Lewinsky testified that the interviews went well and that Ms. Seidman called her back that day and "informally offered [her] a position, and [she] informally accepted." Ms. Lewinsky then called Mr. Jordan and relayed the good news. When shown records of a seven-minute call at 4:14 p.m., Mr. Jordan testified: "I have to assume that if she got the job and we have a seven-minute conversation and the day before I had talked to the chairman [Ronald Perelman], I have to assume the Jordan magic worked." According to Mr. Jordan, he believed that he notified Ms. Currie and the President as soon as he learned that Ms. Lewinsky had obtained an offer: "I am certain that at some point in time I told Betty Currie, `Mission accomplished.'" Mr. Jordan testified that he also told the President directly that, " `Monica Lewinsky's going to work for Revlon,' and his response was, `Thank you very much.' "

E. January 12: Pre-Trial Hearing in Jones Case

On January 12, 1998, Judge Wright held a hearing in the Jones case to discuss pre-trial issues, including the President's upcoming deposition. At that hearing, Judge Wright required Ms. Jones's counsel to list all the witnesses that they planned to call at trial. Ms. Jones's witness list named many women, among them Ms. Lewinsky, to support her theory that the President had a pattern of rewarding women based on their willingness to engage in sexual relations with him. At the hearing, Judge Wright indicated that she would permit Ms. Jones to call as witnesses some of the women she listed in support of her case.

F. January 13: References from the White House

On Tuesday, January 13, 1998, Jennifer Sheldon, Manager of Corporate Staffing of Revlon, called Ms. Lewinsky and formally extended her a position as a public relations administrator. Asked whether this was a relatively quick hiring process, Ms. Sheldon responded, "In totality of how long open positions normally stay open, yes. This was pretty fast." Ms. Sheldon told Ms. Lewinsky that she needed to send her some references. According to Ms. Lewinsky, she then called Ms. Currie because she was "concerned that if I put [assistant to the president John Hilley] down as a reference, he might not say flattering things about me." At 11:11 a.m. on January 13, Ms. Currie paged Ms. Lewinsky and left the following message: "Will know something this afternoon. Kay." That day, January 13, the President talked with Chief of Staff Erskine Bowles about a reference for Ms. Lewinsky. The President told Mr. Bowles that Ms. Lewinsky "had found a job in the... private sector, and she had listed John Hilley as a reference, and could we see if he could recommend her, if asked." Mr. Bowles assured the President that Mr. Hilley would give Ms. Lewinsky a recommendation commensurate with her job performance. Thereafter, Mr. Bowles took the President's request to Mr. Podesta, the Deputy Chief of Staff, who in turn spoke with Mr. Hilley. Mr. Hilley responded that, because he did not know Ms. Lewinsky personally, he would have his office write a recommendation. It would be a generic letter, simply confirming the dates of employment, because of the less than favorable circumstances surrounding Ms. Lewinsky's departure from the White House. Ms. Lewinsky testified that Ms. Currie called later that day and told her that "Mr. Podesta took care of it and everything would be fine with Mr. Hilley." At 11:17 a.m. the next day, Wednesday, January 14, Ms. Lewinsky faxed her acceptance to Revlon and listed John Hilley and her Defense Department supervisor as references. The President was asked in the grand jury whether he ever spoke to Mr. Bowles about obtaining a reference from Mr. Hilley for Ms. Lewinsky. He testified that he did, at Ms. Lewinsky's request, although he thought he had done so earlier than January 13 or 14.

G. January 13: Final Jordan Meeting

According to Ms. Lewinsky, on Tuesday, January 13, she stopped by Mr. Jordan's office to drop off some thank-you gifts for helping her find a job. Ms. Lewinsky offered to show him a copy of her signed affidavit in the Jones case, but he indicated that he did not need to see it.

The President in front of the Grand Jury

The President was asked during his grand jury appearance whether he recalled denying a sexual relationship with Ms. Lewinsky to his senior aides and advisors, including Mr. Bowles, Mr. Podesta, Mr. Blumenthal, Mr. Ickes, and Mr. Jordan. The President did not recall specific details but did remember the following: I met with certain people, and [to] a few of them I said I didn't have sex with Monica Lewinsky, or I didn't have an affair with her or something like that. I had a very careful thing I said, and I tried not to say anything else... 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 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. The President testified that he had said "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 did not have sex with her as I defined it. That was true." The President qualified this answer, however: "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."

3. Initial Denials to the American Public

On the afternoon of January 21, the President made his first of a series of previously scheduled media appearances. In an interview on National Public Radio's "All Things Considered," the following colloquy took place: Q: Mr. President, . . . . "many Americans woke up to the news today that the Whitewater independent counsel is investigating an allegation that you... encouraged a young woman to lie to lawyers in the Paula Jones civil suit. Is there any truth to that allegation?"

WJC: "No, sir, there's not. It's just not true."

Q: "Is there any truth to the allegation of an affair between you and the young woman?"

WJC: "No. That's not true either... The charges are not true. And I haven't asked anybody to lie."

Captions: `I, William Jefferson Clinton': Inauguration Day, January 1993 ED REINKE/AP

Grounds for impeachment? A confident independent counsel, Kenneth Starr BUI KHUE/AP

President-in-waiting: Vice-President Al Gore with his pensive boss RUTH FREMSON/AP

Family secrets: The First Lady has the President's ear, and he has Hillary's support - for now DAN CHUNG/REUTERS

Monica Lewinsky, happy in Clinton's arms REUTERS

Gatekeeper: Betty Currie, the President's secretary, `orchestrated Ms Lewinsky's visits'

`Inappropriate': The President being wired up for the Grand Jury testimony in which he admitted the affair GREG GIBSON/AP

Demonstrators want `Slick Willy' out, but the polls still give him substantial public support JOYCE NALTCHAYAN/AFP

Whistle blower: Linda Tripp revealed the depth of the Lewinsky relationship DOUG MILLS/AP

Gennifer Flowers was the first of two dozen women to claim intimacy RICHARD DREW/AP

Cartons of Evidence: Two sets, filling 36 boxes, arrived at the Justice Committee last week LUKE FRAZZA/AFP

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