MR. APPERSON: Mr. Wisenberg, the grand jury is in
session. There is a quorum. There are
no unauthorized persons in the grand jury room and
they are prepared to receive the testimony
of the President.
MR. WISENBERG: Thank you, Mr. Apperson. If we could proceed with the oath, please?
WHEREUPON,
WILLIAM JEFFERSON CLINTON having been called for
examination by the Independent
Counsel, and having been first duly sworn, was examined
and testified as follows:
EXAMINATION BY THE INDEPENDENT COUNSEL BY MR. WISENBERG:
Q Good afternoon, Mr. President.
A Good afternoon.
Q Could you please state your full name for the record, sir?
A William Jefferson Clinton.
Q My name is Sol Wisenberg and I'm a Deputy Independent
Counsel with the Office of
Independent Counsel. With me today are some other
attorneys from the Office of Independent
Counsel.
At the courtroom are the ladies and gentlemen of
the grand jury prepared to receive your
testimony as you give it. Do you understand, sir?
A Yes, I do.
Q This proceeding is subject to Rule 6(e) of the
Federal Rules of Criminal Procedure as
modified by Judge Johnson's order. You are appearing
voluntarily today as a part of an
agreement worked out between your attorney, the
Office of the Independent Counsel, and with
the approval of Judge Johnson.
Is that correct, sir?
A That is correct.
MR. KENDALL: Mr. Wisenberg, excuse me. You referred
to Judge Johnson's order. I'm not
familiar with that order. Have we been served that,
or not?
MR. WISENBERG: No. My understanding is that that
is an order that the Judge is going to
sign today. She didn't have the name of a WHCA person.
And basically my understanding is
that it will cover all of the attorneys here today
and the technical people in the room, so that
they will be authorized persons permitted to hear
grand jury testimony that they otherwise
wouldn't be authorize to hear.
MR. KENDALL: Thank you.
BY MR. WISENBERG:
Q The grand jury, Mr. President, has been empaneled
by the United States District Court for
the District of Columbia. Do you understand that,
sir?
A I do.
Q And, among other things, is currently investigating
under the authority of the Court of
Appeals upon application by the Attorney General,
whether Monica Lewinsky or others
obstructed justice, intimidated witnesses, or committed
other crimes related to the case of
Jones v. Clinton.
Do you understand that, sir?
A I do.
Q And today, you will be receiving questions not
only from attorney. on the OIC staff, but
from some of the grand jurors, too. Do you understand
that?
A Yes, sir, I do.
Q I'm going to talk briefly about your rights and
responsibilities as a grand jury witness.
Normally, grand jury witnesses, while not allowed
to have attorneys in the grand jury room
with them, can stop and consult with their attorneys.
Under our arrangement today, your
attorneys are here and present for consultation
and you can break to consult with them as
necessary, but it won't count against our total
time.
Do you understand that, sir?
A I do understand that.
Q You have a privilege against self-incrimination.
If a truthful answer to any question would
tend to incriminate you, you can invoke the privilege
and that invocation will not be used
against you. Do you understand l that?
A I do.
Q And if you don't invoke it, however, any answer
I that you do give can and will be used
against you. Do you understand that, sir?
A I do.
Q Mr. President, you understand that your testimony here today is under oath?
A I do.
Q And do you understand that because you have sworn
to tell the truth, the whole truth, and
nothing but the truth, that if you were to lie or
intentionally mislead the grand jury, you could
be prosecuted for perjury and/or obstruction of
justice?
A I believe that's correct.
Q Is there anything that you -- I've stated to you
regarding your rights and responsibilities that
you would like me to clarify or that you don't understand?
A No, sir.
Q Mr. President, I would like to read for you a portion
of Federal Rule of Evidence 603, which
discusses the important function the oath has in
our judicial system. It says that the purpose of
the oath is one, "calculated to awaken the witness'
conscience and impress the witness' mind
with the duty" to tell the truth.
Could you please tell the grand Jury what that oath means to you for today' a testimony?
A I have sworn an oath to tell the grand jury the truth, and that' a what I intend to do.
Q You understand that it requires you to give the
whole truth, that is, a complete answer to
each question, sir?
A I will answer each question as accurately and fully as I can.
Q Now, you took the same oath to tell the truth,
the whole truth, and nothing but the truth on
January 17th, l998 in a deposition in the Paula
Jones litigation; is that correct, sir?
A I did take an oath then.
Q Did the oath you took on that occasion mean the same to you then as it does today?
A I believed then that I had to answer the questions truthfully, that is correct.
Q I'm sorry. I didn't hear you, sir.
A I believed that I had to answer the questions truthfully. That 's correct.
Q And it meant the same to you then as it does today?
A Well, no one read me a definition then and we didn't
go through this exercise then. I swore
an oath to tell the truth, and I believed I was
bound to be truthful and I tried to be.
Q At the Paula Jones deposition, you were represented
by Mr. Robert Bennett, your counsel,
is that correct?
A That is correct.
Q He was authorized by you to be your representative there, your attorney, is that correct?
A That is correct.
Q Your counsel, Mr. Bennett, indicated at page 5
of the deposition, lines 10 through 12, and
I'm quoting, "the President intends to give full
and complete answers as Ms. Jones is entitled to
have".
My question to you is, do you agree with your counsel
that a plaintiff in a sexual harassment
case is, to use his words, entitled to have the
truth?
A I believe that I was bound to give truthful answers, yes, sir.
Q But the question is, sir, do you agree with your
counsel that a plaintiff in a sexual harassment
case is entitled to have the truth?
A I believe when a witness is under oath in a civil
case, or otherwise under oath, the witness
should do everything possible to answer the questions
truthfully.
MR. WISENBERG: I'm going to turn over questioning
now to Mr. Bittman of our office, Mr.
President.
BY MR. BITTMAN:
Q Good afternoon, Mr. President.
A Good afternoon, Mr. Bittman.
Q My name is Robert Bittman. I'm an attorney with the Office of Independent Counsel.
Mr. President, we are first going to turn to some
of the details of your relationship with Monica
Lewinsky that follow up on your deposition that
you provided in the Paula Jones case, as was
referenced, on January 17th, 1998.
The questions are uncomfortable, and I apologize
for that in advance. I will try to be as brief
and direct as possible.
Mr. President, were you physically intimate with Monica Lewinsky?
A Mr. Bittman, I think maybe I can save the -- you
and the grand jurors a lot of time if I read
a statement, which I think will make it clear what
the nature of my relationship with Ma.
Lewinsky was and how it related to the testimony
I gave, what I was trying to do in that
testimony. And I think it will perhaps make it possible
for you to ask even more relevant
questions from your point of view.
And, with your permission, I'd like to read that statement.
Q Absolutely. Please, Mr. President.
A When I was alone with Ma. Lewinsky on certain occasions
in early 1996 and once in early
1997, I engaged in conduct that was wrong. These
encounters did not consist of sexual
intercourse. They did not constitute sexual relations
as I understood that term to be defined at
my January 17th, 1998 deposition. But they did involve
inappropriate intimate contact.
These inappropriate encounters ended, at my insistence,
in early 1997. I also had occasional
telephone conversations with Ms. Lewinsky that included
inappropriate sexual banter.
I regret that what began as a friendship came to
include this conduct, and I take full
responsibility for my actions.
While I will provide the grand jury whatever other
information I can, because of privacy
considerations affecting my family, myself, and
others, and in an effort to preserve the dignity
of the office I hold, this is all I will say about
the specifics of these particular matters.
I will try to answer, to the best of my ability,
other questions including questions about my
relationship with Ms. Lewinsky; questions about
my understanding of the term "sexual
relations", as I understood it to be defined at
my January 17th, 1998 deposition; and questions
concerning alleged subornation of perjury, obstruction
of justice, and intimidation of witnesses.
That, Mr. Bittman, is my statement.
Q Thank you, Mr. President. And, with that, we would like to take a break.
A Would you like to have this?
Q Yes, please. As a matter of fact, why don't we
have that marked as Grand Jury Exhibit
WJC-1.
(Grand Jury Exhibit WJC-1 was marked for identification.)
THE WITNESS: So, are we going to take a break?
MR. KENDALL: Yes. We will take a break. Can we have
the camera off, now, please? And
it's 1:14.
(Whereupon, the proceedings were recessed from 1:14 p.m. until 1:30 p.m.)
MR. KENDALL: 1:30, Bob.
MR. BITTMAN: It's 1:30 and we have the feed with the grand jury
BY MR. BITTMAN:
Q Good afternoon again, Mr. President.
A Good afternoon, Mr. Bittman. (Discussion off the record.)
BY MR. BITTMAN:
Q Mr. President, your statement indicates that your
contacts with Ms. Lewinsky did not
involve any inappropriate, intimate contact.
MR. KENDALL: Mr. Bittman, excuse me. The witness --
THE WITNESS: No, sir. It indicates --
MR. KENDALL: The witness does not have –
THE WITNESS: -- that it did involve inappropriate and intimate contact.
BY MR. BITTMAN:
Q Pardon me. That it did involve inappropriate, intimate contact.
A Yes, sir, it did.
MR. KENDALL: Mr. Bittman, the witness – the witness
dose not have a copy of the
statement. We just have the one copy.
MR. BITTMAN: If he wishes --
MR. KENDALL: Thank you.
MR. BITTMAN: -- his statement back?
BY MR. BITTMAN:
Q Was this contact with Ms. Lewinsky, Mr. President,
did it involve any sexual contact in any
way, shape, or form?
A Mr. Bittman, I said in this statement I would like
to stay to the terms of the statement. I
think it's clear what inappropriately intimate is.
I have said what it did not include. I -- it did not
include sexual intercourse, and I do not believe
it included conduct which falls within the
definition I was given in the Jones deposition.
And I would like to stay with that
characterization.
Q Let us then move to the definition that was provided
you during your deposition. We will
have that marked as Grand Jury Exhibit WJC-2.
(Grand Jury Exhibit WJC-2 we' marked for identification.)
BY MR. BITTMAN:
Q This is an exact copy, Mr. President, of the exhibit
that was provided you during that
deposition. And I'm sure you remember from the deposition
that paragraph (1) of the definition
remained in effect. Judge Wright ruled that that
was to be the guiding definition, and that
paragraph (2) and (3) were stricken.
Do you remember that, Mr. President?
A Yes. Specifically what I remember is there were
two different discussions, I think, of this.
There was guise an extended one in the beginning,
and everybody was entering into it. And in
the end, the Judge said that she would take the
first definition and strike the rest of it. That 'a
my memory.
Q Did you -- well, at page 19 of your deposition
in that case, the attorney who provided you
with the definition asked you, "Would you please
take whatever time you need to I read this
definition". And later on in the deposition, you
did, of course, refer to the definition several
times.
Were you, during the deposition, familiar with the definition?
A Yes, sir. My -- let me just ask a question. If
you are going to ask me about my deposition,
could I have a copy of it? Does anybody have a copy
of it?
Q Yes. We have a copy. We'll provide you with a copy.
BY MS. WIRTH: We will mark it as Grand Jury Exhibit WJC-3.
(Grand Jury Exhibit WJC-3 was marked for identification.)
THE WITNESS: Now, did you say that was on page 19,
Mr. Bittman?
BY MR. BITTMAN:
Q It was at page 19, Mr. President, beginning at
line 21, and I'll read it in full. This is from the
Jones attorney. "Would you please take whatever
time you need to read this definition, because
when I use the term 'sexual relations', this is
what I mean today".
A All right. Yes, that starts on 19. But let me say
that there is a -- just for the record, my
recollection was accurate. There is a long discussion
here between the attorney and the Judge.
It goes on until page 23. And in the end the Judge
says, "I'm talking only about part one in the
definition", and "Do you understand that"? And I
answer, "I do".
The judge says part one, and then the lawyer for
Ms. Jones says he's only talking about part
one and asked me if I understand it. And I say,
I do, and that was my understanding.
I might also note that when I was given this and
began to ask questions about it, I actually
circled number one. This is my circle here. I remember
doing that so I could focus only on
those two lines, which is what I did.
Q Did you understand the words in the first portion
of the exhibit, Mr. President, that is, "For
the purposes of this deposition, a person engages
in 'sexual relations' when the person
knowingly engages in or causes"?
Did you understand, do you understand the words there in that phrase?
A Yes. My -- I can tell you what my understanding of the definition is, if you want me to --
Q Sure.
A -- do it. My understanding of this definition as
it covers contact by the person being deposed
with the enumerated areas, if the contact is done
with an intent to arouse or gratify. That' a my
understanding of the definition.
Q What did you believe the definition to include and exclude? What kinds of activities
A I thought the definition included any activity
by the person being deposed, where the person
was the actor and came in contact with those parts
of the bodies with the purpose or intent or
gratification, and excluded any other activity.
For example, kissing is not covered by that, I don't think.
Q Did you understand the definition to be limited to sexual activity?
A Yes, I understood the definition to be limited
to, to physical contact with those areas of the
bodies with the specific intent to arouse or gratify.
That's what I understood it to be.
Q What specific acts did the definition include,
as you understood the definition on January 17,
1998?
A Any contact with the areas there mentioned, sir.
If you contacted, if you contacted those
parts of the body with an intent to arouse or gratify,
that is covered.
Q What did you understand -
A The person being deposed. If the person being deposed
contacted those parts of another
person's body with an intent to arouse or gratify,
that was covered.
Q What did you understand the word "causes", in the
first phrase? That is, "For the purposes
of this deposition, a person engaged in 'sexual
relations', when the person knowingly" causes
contact?
A I don't know what that means. It doesn't make any
l sense to me in this context, because -- I
think what I thought there was since this was some
sort of -- as I , remember, they said in the
previous discussion -- and I'm only remembering
now, so if I make a mistake you can correct I
me. As I remember from the previous discussion,
this was I some kind of definition that had
something to do with sexual harassment. So, that
implies it's forcing to me, and I --and there
was never any issue of forcing in the case involving,
well, any of these questions they were
asking me.
They made it clear in this discussion I just reviewed
that what they were referring to was
intentional sexual conduct, not some sort of forcible
abusive behavior.
So, I basically -- I don't think I paid any attention
to it because it appeared to me that that was
something that had no reference to the facts that
they admitted they were asking me about.
Q So, if I can be clear, Mr. President, was it your
understanding back in January that the
definition, now marked as Grand Jury Exhibit 2,
only included consensual sexual activity?
A No. My understanding -- let me go back and say
it. My understanding -- I'll tell you what it
did include. My understanding was, what I was giving
to you, was that what was covered in
those first two lines was any direct contact by
the person being deposed with those parts of
another person's body, if the contact was done with
an intent to arouse or gratify. That's what I
believed it meant.
That's what I believed it meant then reading it. That's what I believe it means today.
Q I'm just trying to understand, Mr. President. You
indicated that you put the definition in the
context of a sexual harassment case.
A No, no. I think it was not in the context of sexual
harassment. I just reread those four pages,
which obviously the grand jury doesn't have. But
there was some reference to the fact that this
definition apparently bore some, had some connection
to some definition in another context,
and that this was being used not in that context,
not necessarily in the context of sexual
harassment.
So, I would think that this "causes" would be, would
mean to force someone to do something.
That 's what I read it. That's the only point I'm
trying to make.
Therefore, I did not believe that anyone had ever
suggested that I had forced anyone to do
anything, and that I -- and I did not do that. And
so that could not have had any bearing on any
questions related to Ms. Lewinsky.
Q I suppose, since you have now read portions of
the transcript again, that you were reminded
that you did not ask for any clarification of the
terms. Is that correct? Of the definition?
A No, sir. I thought it was a rather -- when I read.
it, I thought it was a rather strange
definition. But it was the one the Judge decided
on and I was bound by it. So, I took it.
Q During the deposition, you remember that Ms. Lewinsky's
name came up and you were
asked several questions about her. Do you remember
that?
A Yes, sir, I do.
Q During those -- or before those questions actually
got started, your attorney, Mr. Bennett,
objected to any questions about Ms. Lewinsky, and
he represented to Judge Wright, who was
presiding -- that was unusual, wasn't it, that a
federal judge would come and actually -- in your
experience -- that a federal judge would come and
preside at a deposition?
MR. KENDALL: Mr. Bittman, excuse me. Could you identify
the transcript page upon which
Mr. Bennett objected to all testimony about Ms.
Lewinsky before it got started?
MR. BITTMAN: The objection, this quote that I'm referring
to, is going to begin at page 54 of
the deposition.
MR. KENDALL: That is into the testimony though, after
the testimony about Ms. Lewinsky
has begun, is it not?
BY MR. BITTMAN:
Q Mr. President, is it unusual for a federal judge to preside over a civil deposition?
A I think it is, but this was an unusual case. I believe I know why she did it.
Q Your attorney, Mr. Bennett, objected to the questions about Ms. Lewinsky, didn't he?
A What page is that on, sir?
Q Page 54, where he questions whether the attorneys
for Ms. Jones had a good faith basis to
ask some of the questions that they were posing
to you. His objections actually begin on page
53.
Since, as the President pointed out that the grand
jurors correctly do not have a copy of the
deposition, I will read the portion that I am referring
to. And this begins at line 1 on page 54.
"I question the good faith of counsel, the innuendo
in the question. Counsel is fully aware that
Ms. Lewinsky has filed, has an affidavit which they
are in possession of saying that there is
absolutely no sex of any kind in any manner, shape
or form, with President Clinton".
A Where is that?
Q That is on page 54, Mr. President, beginning at line 1, about midway through line 1.
A Well, actually, in the present tense that is an
accurate statement. That was an, that was an
accurate statement, if -- I don't -- I think what
Mr. Bennett was concerned about, if I -- maybe
it would be helpful to you and to the grand jurors,
quite apart from these comments, if I could
tell you what his state of mind was, what my state
of mind was, and why I think the Judge was
there in the first place.
If you don't want me to do it, I won't. But I think it will help to explain a lot of this.
Q Well, we are interested, and I know from the questions
that we've received from the grand
jurors they are interested in knowing what was going
on in your mind when you were reading
Grand Jury Exhibit 2, and what you understood that
definition to include.
Our question goes to whether -- and you were familiar,
and what Mr. Bennett was referring to
obviously is Ms. Lewinsky's affidavit. And we will
have that marked, Mr. President, as Grand
Jury Exhibit WJC-4. (Grand Jury Exhibit WJC-4 was
marked for identification.)
BY MR. BITTMAN:
Q And you remember that Ms. Lewinsky's affidavit
said that she had had no sexual
relationship with you. Do you remember that?
A I do.
Q And do you remember in the deposition that Mr.
Bennett asked you about that. This is at
the end of the -- towards the end of the deposition.
And you indicated, he asked you whether
the statement that Ms. Lewinsky made in her affidavit
was -
A Truthful.
Q -- true. And you indicated that it was absolutely correct.
A I did. And at the time that she made the statement,
and indeed to the present day because, as
far as I know, she was never deposed since the Judge
ruled she would not be permitted to
testify in a case the Judge ruled had no merit;
that is, this case we're talking about.
I believe at the time that she filled out this affidavit,
if she believed that the definition of sexual
relationship was two people having intercourse,
then this is accurate. And I believe that is the
definition that most ordinary Americans would give
it.
If you said Jane and Harry have a sexual relationship,
and you're not talking about people being
drawn into a lawsuit and being given definitions,
and then a great effort to trick them in some
way, but you are just talking about people in ordinary
conversations, I'll bet the grand jurors, if
they were talking about two people they know, and
said they have a sexual relationship, they
meant they were sleeping together; they meant they
were having intercourse together.
So, I'm not at all sure that this affidavit is not
true and was not true in Ms. Lewinsky's mind at
the time she swore it out.
Q Did you talk with Ms. Lewinsky about what she meant to write in her affidavit?
A I didn't talk to her about her definition. I did
not know what was in this affidavit before it
was filled out specifically. I did not know what
words were used specifically before it was filled
out, or what meaning she gave to them.
But I'm just telling you that it's certainly true
what she says here, that we didn't have -- there
was no employment, no benefit in exchange, there
was nothing having anything to do with
sexual harassment. And if she defined sexual relationship
in the way I think most Americans
do, meaning intercourse, then she told the truth.
Q My question -
A And that depends on what was in her mind. I don't
know what was in her mind. You'll have
to ask her that.
Q But you indicated before that you were aware of
what she intended by the term "sexual
relationship".
A No, sir. I said I thought that this could be a
truthful affidavit. And when I read it, since that's
the way I would define it, since -- keep in mind,
she was not, she was not bound by this sexual
relations definition, which is highly unusual; I
think anybody would admit that. When she used
a different term, sexual relationship, if she meant
by that what most people mean by it, then
that is not an untruthful statement.
Q So, your definition of sexual relationship is intercourse only, is that correct?
A No, not necessarily intercourse only. But it would
include intercourse. I believe, I believe
that the common understanding of the term, if you
say two people are having a sexual
relationship, most people believe that includes
intercourse. So, if that's what Ms. Lewinsky
thought, then this is a truthful affidavit. I don't
know what was in her mind. But if that's what
she thought, the affidavit is true.
Q What else would sexual relationship include besides intercourse?
A Well, that -- I think -- let me answer what I said
before. I think most people when they use
that term include sexual relationships and whatever
other sexual contact is involved in a
particular relationship. But they think it includes
intercourse as well. And I would have thought
so. Before I got into this case and heard all I've
heard, and seen all I've seen, I would have
thought that that's what nearly everybody thought
it meant.
Q Well, I ask, Mr. President, because your attorney,
using the very document, Grand Jury
Exhibit 4, WJC-4, represented to Judge Wright that
his understanding of the meaning of that
affidavit, which you've indicated you thought Ms.
Lewinsky thought was, she was referring
just to intercourse, he says to Judge Wright that
it meant absolutely no sex of any kind in any
manner, shape or form.
A Well, let me say this. I didn't have any discussion
obviously at this moment with Mr.
Bennett. I'm not even sure I paid much attention
to what he was saying. I was thinking, I was
ready to get on with my testimony here and they
were having these constant discussions all
through the deposition. But that statement in the
present tense, at least, is not inaccurate, if
that's what Mr. Bennett meant. That is, at the time
that he said that, and for some time before,
that would be a completely accurate statement.
Now, I don't believe that he was -- I don't know
what he meant. You'd have to talk to him,
because I just wasn't involved in this, and I didn't
pay much attention to what was being said. I
was just waiting for them to get back to me. So,
I can't comment on, or be held responsible
for, whatever he said about that, I don't think.
Q Well, if you -- do you agree with me that if he
mislead Judge Wright in some way that you
would have corrected the record and said, excuse
me, Mr. Bennett, I think the Judge is getting
a misimpression by what you're saying?
A Mr. Bennett was representing me. I wasn't representing
him. And I wasn't even paying much
attention to this conversation, which is why, when
you started asking me about this, I asked to
see the deposition. I was focusing on my answers
to the questions. And I've told you what I
believe about this deposition, which I believe to
be true.
And it's obvious, and I think by your questions you
have betrayed that the Jones lawyers'
strategy in this case had nothing to do with uncovering
or proving sexua1 harassment.
By the time this discovery started, they knew they
had a bad case on the law and they knew
what our evidence was. They knew they had a lousy
case on the facts. And so their strategy,
since they were being funded by my political opponents,
was to have this dragnet of discovery.
They wanted to cover everybody. And they convinced
the Judge, because she gave them strict
orders not to leak, that they should be treated
like other plaintiffs in other civil cases, and how
could they ever know whether there had been any
sexual harassment, unless they first knew
whether there had been any sex.
And so, with that broad mandate limited by time and
employment in the federal or state
government, they proceeded to cross the country
and try to turn up whatever they could; not
because they thought it would help their case. By
the time they did this discovery, they knew
what this deal was in their case, and they knew
what was going to happen and
Judge Wright subsequently threw it out. What they -
Q With all respect, Mister -
A Now, let me finish, Mr. Bennett [sic]. I mean, you brought this up. Excuse me, Mr. Bittman.
What they wanted to do, and what they did do, and
what they had done by the time I showed
up here, was to find any negative information they
could on me, whether it was true or not; get
it in a deposition; and then leak it, even though
it was illegal to do so. It happened repeatedly.
The Judge gave them orders.
One of the reasons she was sitting in that deposition
was because she was trying to make sure
that it didn't get out of hand.
But that was their strategy, and they did a good
job of it, and they got away with it. I've been
subject to quite a lot of illegal leaking, and they
had a very determined deliberate strategy,
because their real goal was to hurt me. When they
knew they couldn't win the lawsuit, they
thought, well, maybe we can pummel him. Maybe they
thought I'd settle. Maybe they just
thought they would get some political advantage
out of it. But that's what was going on here.
Now, I'm trying to be honest with you, and it hurts
me. And I'm trying to tell you the truth
about what happened between Ms. Lewinsky and me.
But that does not change the fact that
the real reason they were zeroing in on anybody
was to try to get any person in there, no
matter how uninvolved with Paula Jones, no matter
how uninvolved with sexual harassment,
so they could hurt me politically. That's what was
going on.
Because by then, by this time, this thing had been
l going on a long time. They knew what our
evidence was. They knew what the law was in the
circuit in which we were bringing this case.
And so they just thought they would take a wrecking
ball to me and see if they could do some
damage.
Q Judge Wright had ruled that the attorneys in the
Jones case were permitted to ask you
certain questions, didn't she?
A She certainly did. And they asked them and I did
my best to answer them. I'm just trying to
tell --
Q And was it your responsibility -
A -- you what my state of mind was.
Q -- to answer those questions truthfully, Mr. President?
A It was.
Q And was -
A But it was not my responsibility, in the face of
their repeated illegal leaking, it was not my
responsibility
to volunteer a lot of information. There are many
cases in this deposition where I gave -- and
keep in mind, I prepared, I treated them, frankly,
with respect. I prepared very well for this
deposition on the Jones matters. I prepared very
well on that. I did not know that Linda Tripp
had been involved in the preparation of this deposition,
or that all of you -
Q Do you know that now?
A No, I don't. I just know that -- what I read in
the papers about it But I had no way of
knowing that they would ask me all these detailed
questions. I did the best I could to answer
them.
Q Did you prepare -
A But in this deposition, Mr. Biteman, I was doing
my best to be truthful. I was not trying to
be particularly helpful to them, and I didn't think
I had an obligation to be particularly helpful to
them to further a -- when I knew that there was
no evidence here of sexual harassment, and I
knew what they wanted to do was to leak this, even
though it was unlawful to do so. That's -
Q Did you believe, Mr. President -
A -- what I knew.
Q -- that you had an obligation to make sure that
the presiding federal judge was on board and
had the correct facts? Did you believe that was
your obligation?
A Sir, I was trying to answer my testimony. I was
thinking about my testimony. I don't believe
I ever even focused on what Mr. Bennett said in
the exact words he did until I started reading
this transcript carefully for this hearing. That
moment, that whole argument just passed me by.
I was a witnesa. I was trying to focua on what I
said and how I said it.
And, believe me, I knew what the purpose of the deposition
was. And, sure enough, by the
way, it did all leak, just like I knew it would.
Q Let me ask you, Mr. President, you indicate in
your statement that you were alone with Ms.
Lewinsky. Is that right?
A Yes, sir.
Q How many times were you alone with Ms. Lewinsky?
A Let me begin with the correct answer. I don't know
for sure. But if you would like me to
give an educated guess, I will do that, but I do
not know for sure. And I will tell you what I
think, based on what I remember. But I can't be
held to a specific time, because I don't have
records of all of it.
Q How many times do you think?
A Well, there are two different periods here. There
'a the period when she worked in the White
House until April of '96. And then there's the period
when she came back to visit me from
February '97 until late December `97.
Based on our records -- let' s start with the records,
where we have the best records and the
closest in time. Based on our records, between February
and December, it appears to me that
at least I could have seen her approximately nine
times. Although I do not believe I saw her
quite that many times, at least it could have happened.
There were -- we think there were nine or 10 times
when she was in, in the White House when
I was in the Oval Office when I could have seen
her. I do not believe I saw her that many
times, but I could have.
Now, we have no records for the time when she was
an employee at the White House,
because we have no records of that for any of the
employees at the White House, unless there
was some formally scheduled meeting that was on
the, on the calendar for the day.
I remember -- I'll tell you what I remember. I remember
meeting her, or having my first real
conversation with her during the government shutdown
in November of '95, when she -- as I
explained in my deposition, during the government
shutdown, the -- most federal employees
were actually prohibited from coming to work, even
in the White House. Most people in the
White House couldn't come to work. The Chief of
Staff could come to work. My National
Security Advisor could come to work. I could.
Therefore, interns were assigned to all offices And
I believe it was her last week as an intern.
Anyway, she worked in the Chief of Staff's Office.
One night she brought me some pizza. We
had some remarks.
Now, the next time I remember seeing her alone was
on a couple of occasions when she was
working in the Legislative Affairs Office as a full-time
employee. I remember specifically, I
have a specific recollection of two times. I don't
remember when they were, but I remember
twice when, on Sunday afternoon, she brought papers
down to me, stayed, and we were alone.
And I am frankly quite sure -- although I have no
specific memory, I am quite sure there were
a couple of more times, probably two times more,
three times more. That's what I would say.
That's what I can remember. But I do not remember
when they were, or at what time of day
they were, or what the facts were. But I have a
general memory that would say I certainly saw
her more than twice during that period between January
and April of 1996, when she worked
there.
Q So, if I could summarize your testimony, approximately
five times you saw her before she
left the White House, and approximately nine times
after she left the employment of the White
House?
A I know there were several times in ,97. I've told
you that I've looked at my calendar and I
tell you what I think the outer limits are. I would
think that would sound about right. There
could be, in that first four-month period, there,
maybe there' a one or two more, maybe there
there's one less. I just don't know. I don't remember.
I didn't keep records.
But I'm giving you what I specifically remember and
then what I generally remember. I'm
doing the beat to be helpful to you.
Q Have you reviewed the records for December 28th, 1997, Mr. President?
A Yes, sir, I have.
Q Do you believe that Ms. Lewinsky was at the White
House and saw you on December 28th,
1997?
A Yes, sir, I do.
Q And do you remember talking with Ms. Lewinsky about
her subpoena that she received for
the Paula Jones case on that day?
A I remember talking with Ms. Lewinsky about her
testimony, or about the prospect that she
might have to give testimony. And she, she talked
to me about that. I remember that.
Q And you also gave her Christmas gifts, is that not correct, Mr. President?
A That is correct. They were Christmas gifts and
they were going-away gifts. She was moving
to New York to, taking a new job, starting a new
life. And I gave her some gifts
Q And you actually requested this meeting, is that not correct?
A I don't remember that, Mr. Bittman, but it's quite
possible that I invited her to come by
before she left town. But usually when we met, she
requested the meetings. And my l
recollection is, in 1997, she asked to meet with
me several times when I could not meet with
her and did not do so. But it's quite possible that
I -- that because she had given me a
Christmas gift, and because she was leaving, that
I invited her to come by the White House and
get a couple of gifts before she left town.
I don't remember who requested the meeting though. I'm sorry, I don't.
Q You were alone with her on December 28, 1997, --
A Yes, sir.
Q -- right?
A I was.
Q The gifts that you gave her were a canvas bag from
The Black Dog restaurant at Martha's
Vineyard, is that right?
A Well, that was just, that was just something I
had in the place to, to contain the gifts. But I
believe that the gifts I gave her were -- I put
them in that bag. That's what I had there, and I
knew she liked things from The Black Dog. So, I
gave her -- I think that's what I put the
presents in.
I remember what the presents were. I don't remember what the bag was I gave them in.
Q Did you also give her a marble bear's head carving from Vancouver, Canada?
A I did do that. I remember that.
Q And you also gave her a Rockettes blanket; that is, the famous Rockettes from New York?
A I did do that. I had that, I had had that in my
possession for a couple of years but had never
used it, and she was going to New York. So, I thought
it would be a nice thing to give her.
Q You gave her a box of cherry chocolates, is that right?
A I don't remember that, sir. I mean, there could
have been. I, I just don't remember. I
remember giving the bear and the throw. I don't
remember what else. And it seems to me like
there was one other thing in that bag. I didn't
remember the cherry chocolates.
Q How about a pin of the New York skyline? Did you give -
A That -
Q -- her that?
A That could have been in there. I seem to remember I gave her some kind of pin.
Q What about a pair of joke sunglasses?
A I don't remember that. I'm not denying it. I just
-- I'm telling you what I remember and what
I don't.
Q You had given Ms. Lewinsky gifts on other occasions though, is that right, Mr. President?
A Yes, I had.
Q This, though, was -- you gave her the most gifts
that you had ever given her in a single day,
is that right?
A Well, that's probably true. It was sort of like
a going-away present and a Christmas present
as well. And she had given me a particularly nice
book for Christmas, an antique book on
Presidents. She knew that I collected old books
and it was a very nice thing. And I just thought
I ought to get up a few things and give them to
her before she left.
Q You mentioned that you discussed her subpoena in
the Paula Jones case. Tell us specifically,
what did you discuss?
A No, sir, that' a not what I said. I said, my recollection
is I knew by then, of course, that she
had gotten a subpoena. And I knew that she was,
therefore, was slated to testify. And she
mentioned to me -- and I believe it was at this
meeting. She mentioned -- I remember a
conversation about the possibility of her testifying.
I believe it must have occurred on the 25th.
She mentioned to me that she did not want to testify.
So, that' a how it came up. Not in the
context of, I heard you have a subpoena, let's talk
about it.
She raised the issue with me in the context of her
desire to avoid testifying, which I certainly
understood; not only because there were some embarrassing
facts about our relationship that
were inappropriate, but also because a whole lot
of innocent people were being traumatized and
dragged through the mud by these Jones lawyers with
their dragnet strategy. They -
Q So -
A And so I -- and since she didn't know Paula Jones
and knew nothing about sexual
harassment, and certainly had no experience with
that, I, I clearly understood why she didn't
want to be a part of it.
Q And you didn't want her to testify, did you? You
didn't want her to disclose these
embarrassing facts of this inappropriate intimate
relationship that you had, is that correct?
A 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.
Q Did you want those facts, not only the fact that
she would testify, but did you want the facts
that she had, about your embarrassing inappropriate
intimate relationship to be disclosed?
A Not there, but not in any context. However, I,
I never had any high confidence that they
wouldn't be.
Q Did anyone, as far as you knew, know about your
embarrassing inappropriate intimate
relationship that you had with Ms. Lewinsky?
A At that time, I was unaware that she had told anyone
else about it. But if, if I had known
that, it would not have surprised me.
Q Had you told anyone?
A Absolutely not.
Q Had you tried, in fact, not to let anyone else know about this relationship?
A Well, of course.
Q What did you do?
A Well, I never said anything about it, for one thing.
And I did what people do when they do
the wrong thing. I tried to do it where nobody else
was looking at it.
Q How many times did you do that?
A Well, if you go back to my statement, I remember
there were a few times in '96, I can't say
with any certainty. There was once in early '97.
After she left the
White House, I do not believe I ever had any inappropriate
contact with her in the rest of '96.
There was one occasion in '97 when, regrettably,
that we were together for a few minutes, I
think about 20 minutes, and there was inappropriate
contact. And after that, to the best of my
memory and belief, it did not occur again.
Q Did you tell her in the conversation about her
being subpoenaed -- she was upset about it,
you acknowledge that?
(Witness nodded indicating an affirmative response.)
Q I'm sorry, you have to respond for the record.
Yes or no? Do you agree that she was upset
about being subpoenaed?
A Oh, yes, sir, she was upset. She -- well, she -we
-- she didn't -- we didn't talk about a
subpoena. But she was upset. She said, I don't want
to testify; I know nothing about this; I
certainly know nothing about sexual harassment;
why do they want me to testify. And I
explained to her why they were doing this, and why
all these women were on these lists, people
that they knew good and well had nothing to do with
any sexual harassment.
I explained to her that it was a political lawsuit.
They wanted to get whatever they could under
oath that was damaging to me, and then they wanted
to leak it in violation of the Judge's
orders, and turn up their nose and say, well, you
can't prove we did it. Now, that was their
strategy. And that they were very frustrated because
everything they leaked so far was old
news. So, they desperately were trying to validate
this massive amount of money they'd spent
by finding some new news. And -
Q You were familiar -
A -- she didn't want to be caught up in that, and I didn't blame her.
Q You were familiar, weren't you, Mr. President,
that she had received a subpoena. You've
already acknowledged that.
A Yes, sir, I was.
Q And Mr. Jordan informed you of that, is that right?
A No, sir. I believe -- and I believe I testified
to this in my deposition. I think the first person
who told me that she had been subpoenaed was Bruce
Lindsey. I think the first -- and I was --
in this deposition, it's a little bit cloudy, but
I was trying to remember who the first person who
told me was, because the question was, again as
I remember it -- could we go to that in the
deposition, since you asked me that?
Q Actually, I think you're -- with all respect, I
think you may be confusing when Mr. Lindsey
-- well, perhaps Mr. Lindsey did tell you she was
subpoenaed, I don't know. But in your
deposition, you were referring to Mr. Lindsey notifying
you that she had been identified as a
witness.
A Where is that, sir? I don't want to get -- I just want -- what page is that?
Q Well, actually -
A No, it had to be, because I saw a witness list much earlier than that.
Q Much earlier than December 28?
A Oh, sure. And it had been earlier than -- she would -- I believe Monica -
MR. KENDALL: Page 69.
THE WITNESS: I believe Monica Lewinsky's name was
on a witness list earlier than she was
subpoenaed.
BY MR. BITTMAN:
Q Yes.
A So, I believe when I was answering this question,
at least I thought I was answering when I
found out -- yes. See, there's -- on page 68, "Did
anyone other than your attorneys ever tell
you that Monica Lewinsky had been served with a
subpoena in this case?. Then I said, "I don't
think so.. Then I [sic] said, "Did you ever talk.
to Monica about the possibility that she might
be asked to testify in this case?"
Then I gave an answer that was non-responsive, that
really tried to finish the answer above. I
said, "Bruce Lindsey, I think Bruce Lindsey told
me
that she was, I think maybe that's the first
person told me she was. I want to be as accurate
as I can..
And that -- I believe that Bruce is the first person
who told me that Monica had gotten a
subpoena.
Q Did you, in fact, have a conversation with Mr.
Jordan on the evening of December 19,
1997, in which he talked to you about Monica being
in Mr. Jordan's office, having a copy of
the subpoena, and being upset about being subpoenaed?
A I remembered that Mr. Jordan was in the White House
on December 19th and for an event
of some kind. That he came up to the Residence floor
and told me that he had, that Monica
had gotten a subpoena and, or that Monica was going
to have to testify. And I think he told me
he recommended a lawyer for her. I believe that's
what happened. But it was a very brief
conversation. He was there for some other reason.
Q And if Mr. Jordan testified that he had also spoken
to you at around 5 p.m., and the White
House phone logs reflect this, that he called you
at around the time he met with Ms. Lewinsky
and informed you then that she had been subpoenaed,
is that consistent with your memory?
Also on the 19th?
A I had a lot of phone conversations with Vernon
about this. I didn't keep records of them. I
now have some records. My memory is not clear and
my testimony on that was not clear. I
just knew that I talked to Vernon at some time.
but I thought that Bruce was the first person
who told me.
Q But Mr. Jordan had also told you, is that right?
A Yes. I now know I had a conversation with Mr. Jordan
about it where he said something to
me about that.
Q And that was probably on the 19th, December 19th?
A Well, I know I saw him on the 19th. So, I'm quite
sure. And if he says he talked to me on
the l9th, I believe he would have better records
and I certainly think he's a truthful person.
Q Getting back to your meeting with Ms. Lewinsky
on December 28, you are aware that she's
been subpoenaed. You are aware, are you not, Mr.
President, that the subpoena called for the
production of, among other things, all the gifts
that you had given Ms. Lewinsky? You were
aware of that on December 28th, weren't you?
A I'm not sure. And I understand this is an important
question. I did have a conversation with
Ms. Lewinsky at some time about gifts, the gift.
I'd given her. I do not know whether it
occurred on the 28th, or whether it occurred earlier.
I do not know whether it occurred in
person or whether it occurred on the telephone.
I have searched my memory for this, because I
know it's an important issue. Perhaps if you --
I can tell you what I remember about the
conversation and you can see why I'm having trouble
placing the date.
Q Please.
A The reason I'm not sure it happened on the 28th
is that my recollection is that Ms. Lewinsky
said something to me like, what if they ask me about
the gifts you've given me. That's the
memory I have. That's why I question whether it
happened on the 28th, because she had a
subpoena with her, I request for production.
And I told her that if they asked her for gifts,
she'd have to give them whatever she had, that
that's what the law was. And let me also tell you,
Mr. Bittman, if you go back and look at my
testimony here, I actually asked the Jones lawyers
for help on one occasion, when they were
asking me what gifts I had given her, so they could
-- I was never hung up about this gift issue.
Maybe it's because I have a different experience.
But, you know, the President gets hundreds
of gifts a year, maybe more. I have always given
a lot of gifts to people, especially if they give
me gifts. And this was no big deal to me. I mean,
it's nice. I enjoy it. I gave dozens of personal
gifts to people last Christmas. I give gifts to
people all the time. Friends of mine give me gifts all
the time, give me ties, give me books, give me other
things. So, it was just not a big deal. And I
told Ms. Lewinsky that, just -- I said, you know,
if they ask you for this, you'll have to give
them whatever you have. And I think, Mr. Bittman,
it must have happened before then,
because -- either that, or Ms. Lewinsky didn't want
to tell me that she had the subpoena,
because that was the language I remember her using.
Q Well, didn't she tell you, Mr. President, that
the subpoena specifically called for a hat pin
that you had produced, pardon me, that you had given
her?
A I don't remember that. I remember -- sir, I've
told you what I remember. That doesn't mean
that my memory is accurate. A lot of things have
happened in the last several months, and a lot
of things were happening then. But my memory is
she asked me a general question about gifts.
And my memory is she asked me in the hypothetical.
So, it's possible that I had a conversation
with her before she got a subpoena. Or it's possible
she didn't want to tell me that was part of
the subpoena. I don't know.
But she may have been worried about this gift business.
But it didn't bother me. My experience
was totally different. I told her, I said, look,
the way these things work is, when a person get a
subpoena, you have to give them whatever you have;
that's what's the rule, that's what the law
is.
And when I was asked about this in my deposition,
even though I was not trying to be helpful
particularly to these people that I thought were
not well-motivated, or being honest or even
lawful in their conduct via-a-via me, that is, the
Jones legal team, I did ask them specifically to
enumerate the gifts. I asked them to help me because
I couldn't remember the specifics.
So, all I'm saying is, it didn't -- I wasn't troubled by this gift issue.
Q And your testimony is that Ms. Lewinsky was concerned
about her turning over any gifts
that you had given her, and that your recommendation
to her was, absolutely, Monica, you
have to produce everything that I have given you.
Is that your teatimony?
A My testimony is what I have said, and let me I
reiterate it. I don't want to agree to a
characterization of it. I want to just say what
it was.
My testimony is that my memory is that on some day
in December, and I'm sorry I don't
remember when it was, she said, well, what if they
ask me about the gifts you have given me.
And I said, well, if you get a request to produce
those, you have to give them whatever you
have.
And it just, to me, it -- I don't -- I didn't then,
I don't now see this as a problem. And if she
thought it was a problem, I think it -- it must
have been from a, really, a misapprehension of
the circumstances. I certainly never encouraged
her not to, to comply lawfully with a
subpoena.
Q Mr. President, if your intent was, as you have
earlier testified, that you didn't want anybody
to know about this relationship you had with Ms.
Lewinsky, why would you feel comfortable
giving her gifts in the middle of discovery in the
Paula Jones case?
A Well, sir, for one thing, there was no existing
improper relationship at that time. I had, for
nearly a year, done my best to be a friend to Ms.
Lewinsky, to be a counselor to her, to give
her good advice, and to help her. She had, for her
part, most of the time, accepted the changed
circumstances. She talked to me a lot about her
life, her job ambitions, and she continued to
give me gifts. And I felt that it was a right thing
to do to give her gifts back.
I have always given a lot of people gifts. I have
always been given gifts. I do not think there is
anything improper about a man giving a woman a gift,
or a woman giving I a man a gift, that
necessarily connotes an improper relationship. So,
it didn't bother me.
I wasn't -- you know, this was December 28th. I was
-- I gave her some gifts. I wasn't worried
about it. I , thought it was an all right thing
to do.
Q What about notes and letters, cards, letters and
notes to Ms. Lewinsky? After this
relationship, this inappropriate intimate relationship
between you and Ms. Lewinsky ended, she
continued to send you numerous intimate notes and
cards, is that right?
A Well, they were -- some of them were, were somewhat
intimate. I'd say most of them, most
of the notes and cards were, were affectionate all
right, but, but she had clearly accepted the
fact that there could be no contact between us that
was in any way inappropriate.
Now, she, she sent cards sometimes that were just
funny, even a little bit off-color, but they
were funny. She liked to send me cards, and I got
a lot of those cards; several, anyway, I don't
know a lot. I got a few.
Q She professed her love to you in these cards after the end of the relationship, didn't she?
Well, -
A She said she loved you?
Sir, the truth is that most of the time, even when
she was expressing her feelings for me in
affectionate terms, I believed that she had accepted,
understood my decision to stop this
inappropriate contact. She knew from the very beginning
of our relationship that I was
apprehensive about it. And I think that in a way
she felt a little freer to be affectionate, because
she knew that nothing else was going to happen.
I can't explain entirely what was in her mind.
But most of these messages were not what you would
call over the top. They weren't things
that, if you read them, you would say, oh, my goodness,
these people are having some sort of
sexual affair.
Q Mr. President, the question - -
A But some of them were quite affectionate
Q My question was, did she or did she not profess
her love to you in those cards and letters
that she sent to you after the relationship ended?
A Most of them were signed, "Love", you know, "Love,
Monica." I don't know that I would
consider -- I don't believe that in most of these
cards and letters she professed her love, but she
might well have. I -- but, you know, love can mean
different things, too, Mr. Bittman. I have --
there are a lot of women with whom I have never
had any inappropriate conduct who are
friends of mine, who will say from time to time,
I love you. And I know that they don't mean
anything wrong by that.
Q Specifically, Mr. President, do you remember a
card she sent you after she saw the movie
'Titanic,' in which she said that she reminisced
or dreamed about the romantic feelings that
occurred in the movie, and how that reminded her
of you two? Do you remember that?
A No, sir, but she could have sent it. I -- just
because I don't remember it doesn't mean it
wasn't there.
Q You're not denying that, that -
A Oh, no. I wouldn't deny that. I just don't remember
it. You asked me if I remembered. I
don't. She might have done it.
Q Do you ever remember telling her, Mr. President,
that she should not write some of the
things that she does in those cards and letters
that she sends to you because it reveals, if
disclosed, this relationship that you had, and that
she shouldn't do it?
A 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. I don't remember when I
said that. I don't remember whether it was in '96
or when it was. I don't remember.
Q Embarrassing, in that it was revealing of the intimate
relationship that you and she had, is
that right?
A I do not know when I said this. So, I don't know
whether we did have any sort of
inappropriate relationship at the time I said that
to her. I don't remember. But it's obvious that
if she wrote things that she should not have written
down and someone else read it, that it
would be embarrassing.
Q She certainly sent you something like that after
the relationship began, didn't she? And so,
therefore, there was, at the time she sent it, something
inappropriate going on?
A Well, my recollection is that she -- that maybe
because of changed circumstances in her own
life in 1997, after there was no more inappropriate
contact, that she sent me more things in the
mail, and that there was sort of a disconnect sometimes
between what she was saying and the
plain facts of our relationship. And I don't know
what caused that. But it may have been
dissatisfaction with the rest of her life. I don't
know.
You know, she had, from the time I first met her
talked to me about the rest of her personal
life, and it may be that there was some reason for
that. It may be that when I did the right thing
and made it stick, that in a way she felt a need
to cling more closely, or try to get closer to me,
even though she knew nothing improper was happening
or was going to happen. I don't know
the answer to that.
Q After you gave her the gifts on December 28th,
did you speak with your secretary, Ms.
Currie, and ask her to pick up a box of gifts that
were some compilation of gifts that Ms.
Lewinsky would have -
A No, sir, I didn't do that.
Q -- to give to Ms. Currie?
A I did not do that.
Q When you testified in the Paula Jones case, this
was only two and a half weeks after you
had given her these six gifts, you were asked, at
page 75 in your deposition, lines 2 through 5,
"Well, have you ever given any gifts to Monica Lewinsky?"
And you answer, "I don't recall."
And you were correct. You pointed out that you --
I actually asked them, for prompting, "Do
you know what they were?"
A I think what I meant there was I don't recall what
they were, not that I don't recall whether I
had given them. And then if you see, they did give
me these specifics, and I gave them quite a
good explanation here. I remembered very clearly
what the facts were about The Black Dog.
And I said that I could have given her a hat pin
and a Walt Whitman book; that I did not
remember giving her a gold broach, which was true.
I didn't remember it. I may have given it
to her, I but I didn't remember giving her one.
They didn't ask me about the, about the Christmas
gifts, and I don't know why I didn't think to
say anything about them. But I have to tell you
again, I even invited them to have a list. It was
obvious to me by this point in the definition, in
this deposition, that they had, these people had
access to a lot of information from somewhere, and
I presume it came from Linda Tripp. And
I had no interest in not answering their questions
about these gifts. I do not believe that gifts are
incriminating, nor do I think they are wrong. I
think it was a good thing to do. I'm not, I'm still
not sorry I gave Monica Lewinsky gifts.
Q Why did you assume that that information came from Linda Tripp?
A I didn't then?
Q Well, you didn't? I thought you just testified you did then?
A No, no, no. I said I now assume that because -
Q You now assume?
A -- of all of the subsequent events. I didn't know. I just knew that --
Q Let me ask you about -
A -- that somebody had access to some information
and they may have known more about this
than I did.
Q Let me ask you about the meeting you had with Betty
Currie at the White House on
Sunday, January 18 of this year, the day after your
deposition. First of all, you didn't -Mrs.
Currie, your secretary of six-some years, you never
allowed her, did you, to watch whatever
intimate activity you did with Ms. Lewinsky, did
you?
A No, sir, not to my knowledge.
Q And as far as you know, she couldn't hear anything either, is that right?
A There were a couple of times when Monica was there
when I asked Betty to be places
where she could hear, because Monica was upset and
I -- this was after there was -- all the
inappropriate contact had been terminated.
Q No, I'm talking -
A But ---
Q -- about the times that you actually had the intimate contact.
A She was -- I believe that -- well, first of all,
on that one occasion in 1997, I do not know
whether Betty was in the White House after the radio
address in the Oval Office complex. I
believe she probably was, but I'm not sure. But
I'm certain that someone was there. I always
–always someone was there. In 1996, I think most
of the times that Ms. Lewinsky was there,
there may not have been anybody around except maybe
coming in and out, but not
permanently so. I--that's correct. I never -- I
didn't try to involve Betty in that in any way.
Q Well, not only did you not try to involve her,
you specifically tried to exclude her and
everyone else, isn't that right?
A Well, yes. I've never -- I mean, it's almost humorous,
sir. I'd, I'd, I'd have to be an
exhibitionist not to have tried to exclude everyone
else.
Q So, if Ms. Currie testified that you approached
her on the 18th, or you spoke with her and
you said, you were always there when she was there,
she wasn't was she? That is Mrs. Currie?
A She was always there in the White House, and I was concerned -- let me back up and say --
Q What about the radio address, Mr. President?
A Let me back up a second, Mr. Bittman. I knew about
the radio address. 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. On that night, she didn't.
I was more concerned about the times after that when
Ms. Lewinsky was upset, and I wanted
to establish at least that I had not -- because
these questions were -- some of them were off the
wall. Some of them were way out of line, I thought.
And what I wanted to establish was that
Betty was there at all other times in the complex,
and I wanted to know what Betty's memory
was about what she heard, what she could hear. And
what I did not know was -- I did not
know that. And I was trying to figure out, and I
was trying to figure out in a hurry because I
knew something was up.
Q So, you wanted -
A After that deposition.
Q --to check her memory for what she remembered, and that is --
A That's correct.
Q -- whether she remembered nothing, or whether she remembered an inappropriate intimate –
A Oh, no, no, no, no.
Q -- relationship?
A No. I didn't ask her about it in that way. asked
her about what the -- what I was trying to
determine was whether my recollection was right
and that she was always in the office complex
when Monica was there, and whether she thought she
could hear any conversations we had, or
did she hear any. And then I asked her specifically
about a couple of times when - -once when
I asked her to remain in the dining room, Betty,
while I met with Monica in my study. And
once when I took Monica in the, the small office
Nancy Hernreich occupies right next to
Betty's and talked to her there for a few minutes.
That's my recollection of that.
I was trying to -- I knew, Mr. Bittman, to a reasonable
certainty that I was going to be asked
more questions about this. I didn't really expect
you to be in the Jones case at the time. I
thought what would happen is that it would break
in the press, and I was trying to get the facts
down. I was trying to understand what the facts
were.
Q If Ms. Currie testified that these were not really
questions to her, that they were more like
statements, is that not true?
A Well, I can't testify as to what her perception
was. I can tell you this. I was trying to get
information in a hurry. I was downloading what I
remembered. I think Ms. Currie would also
testify that I explicitly told her, I once I realized
that you were involved in the Jones case --
you, the Office of Independent Counsel -- and that
she might have to be called as a witness,
that she should just go in there and tell the truth,
tell what she knew, and be perfectly truthful.
So, I was not trying to get Betty Currie to say something
that was untruthful. I was trying to
get as much information as quickly as I could.
Q What information were you trying to get from her
when you said, I was never alone with
her, right?
A I don't remember exactly what I did say with her. That's what you say I said
Q If Ms. Currie testified to that, if she says you told her, I was never alone with her, right?
A Well, I was never alone with her -
Q Did you not say that, Mr. President?
A Mr. Bittman, just a minute. I was never alone with
her, right, might be a question. And what
I might have meant by that is, in the Oval Office
complex. Could--
Q Well, you knew the answer to that, didn't you?
A We've been going for more than an hour. Would you
mind if we took a break? I need to go
to the restroom.
MR. BITTMAN: Let's take a break.
MR. KENDALL: It's 2:38.
(Whereupon, the proceedings were recessed from 2:38 p.m. until 2:48 p.m.)
MR. KENDALL: It is 2:38 -- sorry, 2:48.
BY MR. WISENBERG:
Q Mr. President, I want to, before I go into a new
subject area, briefly go over something you
were talking about with Mr. Bittman.
The statement of your attorney, Mr. Bennett, at the
Paula Jones deposition, "Counsel is fully
aware" -- it's page 54, line 5 – "Counsel is fully
aware that Ms. Lewinsky has filed, has an
affidavit which they are in possession of saying
that there is absolutely no sex of any kind in
any manner, shape or form, with President Clinton..
That statement is made by your attorney in front of Judge Susan Webber Wright, correct?
A That's correct.
Q That statement is a completely false statement.
Whether or not Mr. Bennett knew of your
relationship with Ms. Lewinsky, the statement that
there was "no sex of any kind in any
manner, shape or form, with President Clinton,"
was an utterly false statement. Is that correct?
A It depends on what the meaning of the word "is"
is. If the –if he – if "is" means is and never
has been, that is not--- that is one thing. If it
means there is none, that was a completely true
statement.
But, as I have testified, and I'd like to testify
again, this is -- it is somewhat unusual for a client
to be asked about his lawyer's statements, instead
of the other way around. I was not paying a
great deal of attention to this exchange. I was
focusing on my own testimony.
And if you go back and look at the sequence of this,
you will see that the Jones lawyers
decided that this was going to be the Lewinsky deposition,
not the Jones deposition. And, given
the facts of their case, I can understand why they
made that decision. But that is not how I
prepared for it. That is not how I was thinking
about it.
And I am not sure, Mr. Wisenberg, as I sit here today,
that I sat there and followed all these
interchanges between the lawyers. I'm quite sure
that I didn't follow all the interchanges
between the lawyers all that carefully. And I don't
really believe, therefore, that I can say Mr.
Bennett's testimony or statement is testimony and
is imputable to me. I didn't -- I don't know
that I was even paying that much attention to it.
Q You told us you were very well prepared for the deposition.
A No. I said I was very well prepared to talk about
Paula Jones and to talk about Kathleen
Willey, because she had made a related charge. She
was the only person that I think I was
asked about who had anything to do with anything
that would remotely approximate sexual
harassment. The rest of this looked to me like it
was more of a way to harass me.
Q You are the President of the United States and
your attorney tells a United States District
Court Judge that there is no sex of any kind, in
any way, shape or form, whatsoever. And you
feel no obligation to do anything about that at
that deposition, Mr. President?
A I have told you, Mr. Wisenberg, I will tell you
for a third time. I am not even sure that when
Mr. Bennett made that statement that I was concentrating
on the exact words he used.
Now, if someone had asked me on that day, are you
having any kind of sexual relations with
Ms. Lewinsky, that is, asked me a question in the
present tense, I would have said no. And it
would have been completely true.
Q Was Mr. Bennett aware of this tense-based distinction you are making now -
A I don't -
MR. KENDALL: I'm going to object to any questions
about communications with private
counsel.
MR. WISENBERG: Well, the witness has already testified,
I think, that Mr. Bennett didn't
know about the inappropriate relationship with Ms.
Lewinsky. I guess -
THE WITNESS: Well, you'll have to ask him that. you
know. He was not a sworn witness
and I was not paying that close attention to what
he was saying. I've told you that repeatedly. I
was -- I don't -- I never even focused on that until
I read it in this transcript in preparation for
this testimony.
When I was in there, I didn't think about my I lawyers.
I was, frankly, thinking about myself
and my testimony and trying to answer the questions.
BY MR. WISENBERG:
Q I just want to make sure I understand, Mr. President.
Do you mean today that because you
were not I engaging in sexual activity with Ms.
Lewinsky during the deposition that the
statement of Mr. Bennett might be literally true?
A No, sir. I mean that at the time of the deposition,
it had been -- that was well beyond any
point of improper contact between me and Ms. Lewinsky.
So that anyone generally speaking in
the present tense, saying there is not an improper
relationship, would be telling the truth if that
person said there was not, in the present tense;
the present tense encompassing many months.
That's what I meant by that.
Not that I was -- I wasn't trying to give you a cute
answer, that I was obviously not involved in
anything improper during a deposition. I was trying
to tell you that generally speaking in the
present tense, if someone said that, that would
be true. But I don't know what Mr. Bennett had
in his mind. I don't know. I didn't pay any attention
to this colloquy that went on. I was waiting
for my instructions as a witness to go forward.
I was worried about my own testimony.
Q I want to go back to some questions about Mr. Jordan
and we are going to touch a little bit
on the December 19th meeting and some others. Mr.
Jordan is a long-time friend of yours, is
that correct, Mr. President?
A Yes, sir. We've been friends probably 20 years, maybe more.
Q You said you consider him to be a truthful person, correct?
A I do.
Q If Mr. Jordan has told us that he visited you in
the Residence on the night of the 19th, after
a White House holiday dinner, to discuss Monica
Lewinsky and her subpoena with you, do
you have any reason to doubt it?
A No. I've never known him to say anything that wasn't
true. And his memory of these events,
I think, would be better than mine because I had
a lot of other things going on.
Q We have WAVE records that will show that, but in
the interest of time I'm not going to
-since you don't dispute that, I'm not going to
show them right now. And, in fact, that was the
very day Monica Lewinsky was subpoenaed, wasn't
it, the night that he came to see you?
A I don't have an independent memory of that, but
you would probably know that. I mean,
I'm sure there is a record of when she got her subpoena.
Q If Mr. Jordan has told us that he spoke with you
over the phone within about an hour of
Monica receiving her subpoena, and later visited
you that very day, the night at the White
House, to discuss it, again you'd have no reason
to doubt him, is that correct?
A I've already -- I believe I've already testified
about that here today, that I had lots of
conversations with Vernon. I'm sure that I had lots
of conversations with him that included
comments about this. And if he has a specific memory
of when 1 had some conversation on a
certain day, I would be inclined to trust his memory
over mine, because under the present
circumstances my head's probably more cluttered
than his, and my schedule is probably busier.
He's probably got better records.
Q And when Mr. Jordan met with you at the Residence
that night, sir, he asked you if you'd
been involved in a sexual relationship with Monica
Lewinsky, didn't he?
A 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, and I don't believe
I've ever met Mr. Carter. I don't think I
know him.
Q Mr. President, if Mr. Jordan has told us that he
had a very disturbing conversation with Ms.
Lewinsky that day, then went over to visit you at
the White House, and that before he asked
you the question about a sexual relationship, related
that disturbing conversation to you, the
conversation being that Ms. Lewinsky had a fixation
on you and thought that perhaps the First
Lady would leave you at the end of --that you would
leave the First Lady at the end of your
term and come be with Ms. Lewinsky, do you have
any reason to doubt him that it was on that
night that that conversation happened?
A All I can tell you, sir, is I, I certainly don't
remember him saying that. Now, he could have
said that because, as you know, a great many things
happened in the ensuing two or three
days. And I could have just forgotten it. But I
don't remember him ever saying that.
Q At any time?
A No, I don't remember him saying that. What I remember
was that he said that Monica came
to see him, that she was upset that she was going
to have to testify, that he had referred her to
a lawyer.
Q In fact, she was very distraught about the subpoena, according to Mr. Jordan, wasn't she?
A Well, he said she was upset about it. I don't remember
-- I don't remember any, at any time
when he said this, this other thing you just quoted
me. I'm sorry. I just don't remember that.
Q That is something that one would be likely to remember, don't you think, Mr. President?
A I think I would, and I'd be happy to share it with
you if I did. I only had one encounter with
Ms. Lewinsky, I seem to remember, which was somewhat
maybe reminiscent of that. But not
that, if you will, obsessive, if that's the way
you want to use that word.
Q Do you recall him at all telling you that he was
concerned about her fascination with you,
even if you don't remember the specific conversation
about you leaving the First Lady?
A I recall him saying he thought that she was upset
with -- somewhat fixated on me, that she
acknowledged that she was not having a sexual relationship
with me, and that she did not want
to be drug into the Jones lawsuit. That's what I
recall. And I recall getting, saying that he had
recommended a lawyer to her and she had gone to
see the lawyer. That's what I recall.
I don't remember the other thing you mentioned. I
just -- I might well remember it if he had
said it. Maybe he said it and I've forgotten it,
but I don't -- I can't tell you that I remember that.
Q Mr. President, you swore under oath in the Jones
l case that you didn't think anyone other
than your lawyers had ever told you that Monica
Lewinsky had been subpoenaed. Page 68,
line 22 [sic] through page 69, line 3. Here's the
testimony, sir.
Question -- we've gone over it a little bit before:
Did anyone other than your attorneys ever tell
you that Monica Lewinsky had been served with a
subpoena in this case?. Answer, I don't
think so..
Now, this deposition was taken just three and a half
weeks after, by your own testimony,
Vernon Jordan made a trip at night to the White
House to tell you, among other things, that
Monica Lewinsky had been subpoenaed and was upset
about it. Why did you give that
testimony under oath in the Jones case, sir?
A Well, Mr. Wisenberg, I think you have to - again,
you have to put this in the context of the
flow of questions, and I've already testified to
this once today. I will testify to it again.
My answer to the next question, I think, is a way
of finishing my answer to the question and
the answer you've said here. I was trying to remember
who the first person, other than Mr.
Bennett -- I don't think Mr. Bennett -- who the
first person told me that, who told me Paula
Jones had, I mean, excuse me, Monica Lewinsky had
a subpoena. And I thought that Bruce
Lindsey was the first person. And that's how I was
trying to remember that.
Keep in mind, sort of like today, these questions
are being kind of put at me rapid-fire. But,
unlike today, I hadn't had the opportunity to prepare
at this level of detail. I didn't -- I was
trying to keep a lot of things in my head that I
had remembered with regard to the Paula Jones
case and the Kathleen Willey matter, because I knew
I would be asked about them. And I gave
the best answers I could. Several of my answers
are somewhat jumbled.
But this is an honest attempt here -- if you read
both these answers, it's obvious they were both
answers to that question you quoted, to remember
the first person, who was not Mr. Bennett,
who told me. And I don't believe Vernon was the
first person who told me. I believe Bruce
Lindsey was.
Q Let me read the question, because I want to talk
I about the first person issue. The question
on line 25 of page 68 is, "Did anyone other than
your attorneys ever tell you that Monica
Lewinsky had been served with a subpoena in this
case?" Answer, "I don~t think so."
You would agree with me, sir, that the question doesn't
say, the question doesn't say anything
about who was the first person. It just says, did
anyone tell you. Isn't that correct?
A That's right. And I said Bruce Lindsey, because
I was trying to struggle with who -- where I
had heard this. And they were free to ask a follow-up
question, and they didn't.
Q Mr. President, three and a half weeks before, Mr.
Jordan had made a special trip to the
White House to tell you Ms. Lewinsky had been subpoenaed;
she was distraught; she had a
fixation over you. And you couldn't remember that,
three and a half weeks later?
A Mr. Wisenberg, if -- they had access to all this
information from their conversations with
Linda Trip, if that was the basis of it. They were
free to ask me more questions. They may
have been trying to trick me.
Now, they knew more about the details of my relationship
with Monica Lewinsky. I'm not sure
everything they knew was true, because I don't know.
I've not heard these tapes or anything.
But they knew a lot more than I did. And instead
of trying to trick me, what they should have
done is to ask me specific questions, and I invited
them on more than one occasion to ask
follow-up questions.
This is the third or fourth time that you seem to
be complaining that I did not do all their work
for them. That just setting here answering answering
questions to the beat of my memory, with
limited preparation, was not enough. That I should
have actually been doing all their work for
them.
Now, they~d been up all night with Linda Trip, who
had betrayed her friend, Monica
Lewinsky, autoed her in the back and given them
all this information. They could have helped
more. If they wanted to ask me follow-up questions,
they could. They didn't. I'm sorry. I did
the beat I could.
Q Can you tell the grand jury what ia tricky about
the question, ~Did anyone other than your
attorneys ever tell you. -
A No, there'squestion nothing -- I'm just telling
-- I have explained. I will now explain for the
third time, sir. I was being asked a number of question
here. I was struggling to remember
then. There were lot of things that had gone on
during this time period that had nothing to do
with Monica Lewinsky.
You know, I believed then, I believe now that Monica
Lewinsky could have sworn out an
honest affidavit, that under reasonable circumstances,
and without the benefit of what Linda
Tripp did to her, would have given her a chance
not to be a witness in this case.
So, I didn't have perfect memory of all these events
that have now, in the last seven months,
once Ms. Lewinsky was kept for several hours by
four or five of your lawyers and four or five
FBI agents, as if she were a serious felon, these
things have become the most important
matters in the world. At the moment they were occurring,
many other things were going on.
I honestly tried to remember when -- you know, if
somebody asked you, has anybody ever
talked to you about this, you normally think, well,
where was the first time I heard that. That's
all I was trying to do here. I was not trying to
say not Vernon Jordan, but Bruce Lindsey.
everybody knows Vernon Jordan is a friend of mine.
I probably would have talked to Vernon
Jordan about the Monica Lewinsky problem if he had
never been involved in it. But, I was not
trying to mislead them. I was trying to answer this
l question with the first person who told me
that.
Now, I realize that wasn't the specific question.
They were free to ask follow-ups, just like
you're asking follow-ups today. And I can't explain
why I didn't answer every question in the
way you seem to think I should have, and I certainly
can't explain why they didn't ask what
seemed to me to be logical follow-ups, especially
since they spent all that time with Linda Tripp
the night before.
Q You've told us that you understand your obligation
then, as it is now, is to tell the whole
truth, sir. Do you recall that?
A I took the oath here.
Q If Vernon Jordan -
A You even read me a definition of the oath.
Q If Vernon Jordan has told us that you have an extraordinary
memory, one of the greatest
memories he's ever seen in a politician, would that
be something you would care to dispute?
A No, I do have a good memory. At least, I have had a good memory in my life.
Q Do you understand that if you answered, "I don't
think so", to the question, has anyone
other than your attorneys told you that Monica Lewinsky
has been served with a subpoena in
this case, that if you answered, "I don't think
so", but you really knew Vernon Jordan had been
telling you all about it, you understand that that
would be a false statement, presumably
perjurious?
A Mr. Wisenberg, I have testified about this three
times. Now, I will do it the fourth time. I am
not going to answer your trick questions.
I -- people don't always hear the same questions
in the same way. They don't always answer
them in the same way. I was so concerned about the
question they asked me that the next
question I was asked, I went back to the previous
question, trying to give an honest answer
about the first time I heard about the Lewinsky
subpoena.
I -- look. I could have had no reasonable expectation
that anyone would ever know that, that
-or not, excuse me, not know if this thing -- that
I would talk to Vernon Jordan about nearly
everything. I was not interested in -- if the implication
of your question is that somehow I didn't
want anybody to know I had ever talked to Vernon
Jordan about this, that's just not so.
It's also -- if I could say one thing about my memory.
I have been blessed and advantaged in
my life with a good memory. Now, I have been shocked,
and so have members of my family
and friends of mine, at how many things that I have
forgotten in the last six years, I think
because of the pressure and the pace and the volume
of events in the President's life,
compounded by the pressure of your four year inquiry,
and all the other things that have
happened, I'm amazed there are lots of times when
I literally can't remember last week.
If you ask me, did you talk to Vernon -when was the
last time you talked to Vernon Jordan,
what time of day was it, when did you see him, what
did you ask, my answer was the last --
you know, if you answered [sic] me, when was the
last time you saw a friend of yours in
California, if you asked me a lot of questions like
that, my memory is not what it was when I
came here, because my life is so crowded.
And now that -- as I said, you have made this the
most important issue in America. I mean,
you have made it the most important issue in America
from your point of view. At the time this
was occurring, even though I was concerned about
it, and I hoped she didn't have to testify,
and I hoped this wouldn't come out, I felt -- I
will say again -- that she could honestly fill out
an affidavit that, under reasonable circumstances,
would relieve her of the burden of testifying.
I am not trying to exclude the fact that I talked
to Vernon here. I just -- all I can tell you is I
believe this answer reflects I was trying to remember
the first person who told me who was not
Mr. Bennett, and I believe it was Bruce Lindsey.
Q As you yourself recalled, just recalled, Mr. President,
Vernon Jordan not only discussed the
subpoena with you that night, but discussed Prank
Carter, the lawyer he had often for Ms.
Lewinsky. And also Mr. Jordan discussed with you
over the next few weeks, after the 19th of
December, in addition to the job aspects of Ms.
Lewinsky's job, he discussed with you her
affidavit that she was preparing in the case. Is
that correct, sir?
A I believe that he did notify us, I think, when
she signed her affidavit. I have a memory of
that. Or it seems like he said that she had signed
her affidavit.
Q If he's told us that he notified you around January
7th, when she signed her affidavit, and
that you generally understood that it would deny
a sexual relationship, do you have any reason
to doubt that?
A No.
Q So, that's the affidavit, the lawyer, and the subpoena.
And yet when you were asked, sir, at
the Jones deposition about Vernon Jordan, and specifically
about whether or not he had
discussed the lawsuit with you, you didn't reveal
that to the Court. I want to refer you to page
72, line 16.
It's -- It's going to go down, it might go down Line
16. Question, Has it ever been reported to
you that he. -- and that's referring to Mr. Jordan.
At line l 12 you were asked, "You know a
man named Vernon Jordan?, and you answer, "I know
him well."
Going down to 16, "Has it ever been reported to you
that he met with Monica Lewinsky and
talked about this case?"
This is your answer, or a portion of it: "I knew
that he met with her. I think Betty suggested
that he meet with her. Anyway, he met with her.
I, I thought that he talked to her about
something else".
Why didn't you tell the Court, when you were under
oath and sworn to tell the truth, the whole
truth, and nothing but the truth, that you had been
talking with Vernon Jordan about the case,
about the affidavit, the lawyer, the subpoena
A Well, that's not the question I was asked. I was
not asked any question about -- I was asked,
"Has it ever been reported to you that he met with
Monica Lewinsky and talked about this
case." I believe -- I may be wrong about this --
my impression was that at the time, I was
focused on the meetings. I believe the meetings
he had were meetings about her moving to
New York and getting a job.
I knew at some point that she had told him that she
needed some help, because she had gotten
a subpoena. I'm not sure I know whether she did
that in a meeting or a phone call. And I was
not, I was not focused on that. I know that, I know
Vernon helped her to get a lawyer, Mr.
Carter. And I, I believe that he did it after she
had called him, but I'm not sure. But I knew that
the main source of their meetings was about her
move to New York and her getting a job.
Q Are you saying, sir, that you forgot when you were
asked this question that Vernon Jordan
had come on December 19th, just three and a half
weeks before, and said that he had met that
day, the day that Monica got the subpoena?
A It's quite possible -- it's a sort of a jumbled
answer. It's quite possible that I had gotten mixed
up between whether she had met with him or talked
to him on the telephone in those three and
a half weeks.
Again, I say, sir, just from the tone of your voice
and the way you are asking questions here,
it's obvious that this is the most important thing
in the world, and that everybody was focused
on all the details at the time. That's not the way
it worked. I was, I was doing my best to
remember.
Now, keep in mind, I don't know if this is true,
I but the news reports are that Linda Tripp
talked to you, then went and talked to the Jones
lawyers, and, you know, that she prepared
them for this. Now, maybe -- you seem to be criticizing
me because they didn't ask better
questions and, as if you didn't prepare them well
enough to sort of set me up or something. I
don't know what's going on here.
All I can tell you is I didn't remember all the details
of all this. I didn't remember what -when
Vernon talked to me about Monica Lewinsky, whether
she talked to him on the telephone or
had a meeting. I didn't remember all those details.
I was focused on the fact that Monica went
to meet with Vernon after Betty helped him set it
up, and had subsequent meetings to talk
about her move to New York.
Now, keep in mind at this time, at this time, until
this date here when it's obvious that
something funny~s going on here and there's some
sort of a gotcha game at work in this
deposition, until this date, I didn't know that
Ms. Lewinsky's deposition [sic] wasn't going to be
sufficient for her to avoid testifying. I didn't,
you know -
MR. KENDALL: Excuse me, Mr. President, I think -
THE WITNESS: So, all these details -
MR. KENDALL: -- you mean her affidavit.
BY MR. WISENBERG:
Q You mean her affidavit
A Excuse me. I'm sorry. Her affidavit. Thank you.
So, I don't necessarily remember all the details
of all these questions you're asking me, because
there was a lot of other things going on, and at
the time they were going on, until all this came
out, this was not the most important thing in my
life. This was just another thing in my life.
Q But Vernon Jordan met with you, sir, and he reported
that he had met with Monica
Lewinsky, and the discussion was about the lawsuit,
and you didn't inform, under oath, the
Court of that in your deposition?
A I gave the best answer I could, based on the best
memory I had at the time they asked me
the question. That's the only answer I can give
you, sir.
Q And before -
A And I think I may have been confused in my memory,
because I've also talked to him on the
phone about what he said about whether he talked
to her or met with her. That's all I can tell
you.
But, let me say again, I don't have the same view
about this deposition -- I mean, this affidavit
-- that I think you do. I felt very strongly that
Ms. Lewinsky and everybody else that didn't
know anything about Paula Jones and anything about
sexual harassment, that she and others
were themselves being harassed for political purposes,
in the hope of getting damaging
information that the Jones lawyers could unlawfully
leak.
Now, I believed then, I believe today, that she could
execute an affidavit which, under
reasonable circumstances with fair-minded, non politically-oriented
people, would result in her
being relieved of the burden to be put through the
kind of testimony that, thanks to Linda
Tripp's work with you and with the Jones lawyers,
she would and I have been put through. I
don't think that's dishonest. I don't think that's
illegal. I think what they were trying to do to her
and all these other people, who knew nothing about
sexual harassment, was outrageous, just so
they could hurt me politically.
So, I just don't have the same attitude about it that you do.
Q Well, you're not telling our grand jurors that
because you think the case was a political case
or a setup, Mr. President, that that would give
you the right to commit perjury or
A No, sir.
Q -- not to tell the full truth?
A In the face of their, the Jones lawyers the people
that were questioning me, in the face of
their illegal leaks, their constant, unrelenting
illegal leaks in a lawsuit that I knew and, by the
time this deposition and this discovery started,
they knew was a bogus suit on the law and a
bogus suit on the facts.
Q The question is -
A In the face of that, I knew that in the face of
their illegal activity, I still had to behave
lawfully. I wanted to be legal without being particularly
helpful. I thought that was, that was
what I was trying to do. And this is the first --
you are the first person who ever suggested to
me that, that I should have been doing their lawyers'
work for them, when they were perfectly
free to ask follow-up questions. On one or two occasions,
Mr. Bennett invited them to ask
follow-up questions.
It now appears to me they didn't because they were
afraid I would give them a truthful answer,
and that there had been some communication between
you and Ms. Tripp and them, and they
were trying to set me up and trick me. And now you
seem to be complaining that they didn't
do a good enough job.
I did my best, sir, at this time. I did not know
what I now know about this. A lot of other
things were going on in my life. Did I want this
to come out? No. Was I embarrassed about it?
Yes. Did I ask her to lie about it? No. Did I believe
there could be a truthful affidavit?
Absolutely.
Now, that's all I know to say about this. I will continue to answer your questions as best I can.
Q You're not going back on your earlier statement
that you understood you were sworn to tell
the truth, the whole truth, and nothing but the
truth to the folks at that deposition, are you, Mr.
President?
A No, sir, but I think we might as well put this
out on the table. You tried to get me to give a
broader interpretation to my oath than just my obligation
to tell the truth. In other words, you
tried to say, even though these people are treating
you in an illegal manner in illegally leaking
these depositions, you should be a good lawyer for
them. And if they don't have enough sense
to write -- to ask a question, and even if Mr. Bennett
invited them to ask follow-up questions,
if they didn't do it, you should have done all their
work for them.
Now, I will admit this, sir. My goal in this deposition
was to be truthful, but not particularly
helpful. I did not wish to do the work of the Jones
lawyers. I deplored what they were doing. I
deplored the innocent people they were tormenting
and traumatizing. I deplored their illegal
leaking. I deplored the fact that they knew, once
they knew our evidence, that this was a bogus
lawsuit, and that because of the funding they had
from my political enemies, they were putting
ahead. I deplored it. But I was determined to walk
through the mine field of this deposition
without violating the law, and I believe I did.
Q You are not saying, are you, Mr. President, in
terms of doing the work for the Jones folks,
the Jones lawyers, that you could, you could say,
as part of your not helping them, "I don't
know" to a particular question, when you really
knew, and that it was up to them -- even if you
really knew the answer, it was up to them to do
the followup, that you kind of had a one free
"I don't know".
A No, sir.
Q If I could finish up? I've been very patient, Mr. President, in letting you finish.
You didn't think you had a free shot to say, "I don't
know", or "I don't recall", but when you
really did know and you did recall, and it was just
up to them, even if you weren't telling the
truth, to do a follow-up and to catch you?
A No, sir, I'm not saying that. And if I could give
you one example? That's why I felt that I
had to come back to that question where I said,
I don~t know that, and talk about Bruce
Lindsey, because I was trying, I was honestly trying
to remember how I had first heard this. I
wasn't hung up about talking about this.
All I'm saying is, the -- let me say something sympathetic
to you. I've been pretty tough. So, let
me say something sympathetic. All of you are intelligent
people. You've worked hard on this.
You've worked for a long time. You've gotten all
the facts. You've seen a lot of evidence that I
haven't seen. And it's, it's an embarrassing and
personally painful thing, the truth about my
relationship with Ms. Lewinsky.
So, the natural assumption is that while all this
was going on, I must have been focused on
nothing but this; therefore, I must remember everything
about it in the sequence and form in
which it occurred. All I can tell you is, I was
concerned about it. I was glad she saw a lawyer. I
was glad she was doing an affidavit. But there were
a lot of other things going on, and I don't
necessarily remember all. And I don't know if I
can convince you of that.
But I tried to be honest with you about my mindset,
about this deposition. And I'm just trying
to explain that I don't have the memory that you
assume that I should about some of these
things.
Q I want to talk to you for a bit, Mr. President,
about the incident that happened at the
Northwest Gate of the White House on December 5th
-- sorry, December 6th, 1997. If you
would give me just a moment?
That was a -- let me ask you first. In early nineteen
-- in early December 1997, the Paula Jones
case was pending, correct?
A Yes, sir.
Q You were represented by Mr. Bennett, of course?
A That's correct.
Q In that litigation?
A Yes, I did.
Q How -
A He was.
Q I'm sorry. Go ahead.
A No, no. Yes, he was representing me.
Q How often did you talk to him or meet with him, if you can just recal