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?


    WILLIAM JEFFERSON CLINTON having been called for examination by the Independent
    Counsel, and having been first duly sworn, was examined and testified as follows:


    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

    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.


    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

    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.


    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

    (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


    Q Good afternoon again, Mr. President.

    A Good afternoon, Mr. Bittman. (Discussion off the record.)


    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.


    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?


    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

    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.)


    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

    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?


    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,

    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

    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

    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?


    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

    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.)


    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

    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

    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

    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

    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

    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

    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,

    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

    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


    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

    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

    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

    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

    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.


    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

    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

    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.


    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

    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

    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

    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

    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.


    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

    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?

    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.

    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

    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 recall, at that time in the

    A Well, we met, I would say -- I wish Mr. Ruff were answering this question, instead of me.
    His memory would be better. We met probably, oh, for a long time we didn't meet all that
    often, maybe once a month. And then the closer we got to the deposition, we would meet more
    frequently. So, maybe by this time we were meeting more.

    We also -- there was a period when we had been approached about -

    MR. KENDALL: Again, the question only goes to the number of meetings and not the content
    of any conversations with your lawyer.

    THE WITNESS: I understand. We're not talking about the content.

    There was a, there was a period in which we, I think back in the summer before this, when we
    had met more frequently. But I would say normally once a month. Sometimes something
    would be happening and we'd meet more. And then, as we moved toward the deposition, we
    would begin to meet more.


    Q A witness list came out on December 5th of 1997, with Monica Lewinsky's name on it. Mr.
    President, when did you find out that Monica's name was on that witness list?

    A I believe that I found out late in the afternoon on the 6th. That's what I believe. I've tried to
    remember with great precision, and because I thought you would ask me about this day, I've
    tried to remember the logical question, which is whether, whether I knew it on the 6th and, if
    so, at what time.

    I don't -- I had a meeting in the late afternoon on the 5th, on the 6th -- excuse me, on the 6th --
    and I believe that's when I learned about it.

    Q Now, on the morning of the 6th, Monica Lewinsky came to the Northwest Gate and found
    out that you were being visited by Eleanor Mondale at the time, and had an extremely angry
    reaction. You know that, sir, now, don't you?

    A I have, I have -- I know that Monica Lewinsky came to the gate on the 6th and apparently
    directly called in and wanted to see me and couldn't, and was angry about it. I know that.

    Q And she expressed that anger to Betty Currie over the telephone, isn't that correct, sir?

    A That, Betty told me that.

    Q And she then later expressed her anger to you in one of her telephone conversations with
    Betty Currie, is that correct?

    A You mean did I talk to her on the phone?

    Q Monica Lewinsky, that day, before she came in to visit in the White House?

    A Mr. Wisenberg, I remember that she came in to visit that day. I remember that she was
    upset. I don't recall whether I talked to her on the phone before she came in t visit, but I well
    may have. I'm not denying it that I did. I just don't recall that.

    Q And Mrs. Currie and yourself were very irate that Ms. Lewinsky had overheard that you
    were in the Oval Office with a visitor on that day, isn't that correct, that you and Mrs. Currie
    were very irate about that?

    A Well, I don't remember all that. What I remember is that she was very -- Monica was very
    upset. She got upset from time to time. And, and I was, you know, I couldn't see her. I had, I
    was doing, as I remember, I had some other work to do that morning and she had just sort of
    showed up and wanted to be let in, and wanted to come in at a certain time and she wanted
    everything to be that way, and we couldn't see her. Now, I did arrange to see her later that
    day. And I was upset about her conduct.

    I'm not sure that I knew or focused on at that moment exactly the question you asked. I
    remember I was, I thought her conduct was inappropriate that day.

    Q I want to go back and I want to take them one at a time. Number one, did you find out at
    some point during that day that Monica had overheard from somebody in the Secret Service
    that you were meeting with Ms. Mondale, and that Monica got very irate about that?

    A I knew that at some point. I don't know whether I found out that, that day. I knew that day,
    I knew that somehow she knew that among, that, that Eleanor Mondale was in to see us that
    day. I knew that. I don't know that I knew how she knew that on that day. I don't remember

    Q That leads into my second question, which is, weren't you irate at the Secret Service
    precisely because they had revealed this information to Ms. Lewinsky on that very day, so irate
    that you told several people, or at least one person, that somebody should be fired over this, on
    that very day?

    A I don't remember whether it happened on that very day. But, let me tell you that the
    Uniformed Secret Service, I if that ia in fact what happened and I will stipulate that that is, that
    no one should be telling anybody, not anybody, not a member of my staff, who the President
    ia meeting with. That's an inappropriate thing to do.

    So, I would think that if that, in fact, ia what I heard when I heard it, I would have thought.that
    was a bad thing. I don't know that I said that. I don~t, I don't remember what I said, and I
    don't remember to whom I said it.

    Q It would be an inappropriate thing, sir, and that leads into my next question ia that why did
    Mrs. Currie, on your instructions, later that day tell many of the Secret Service Officers
    involved that it never happened, to forget about it?

    A That what never happened?

    Q The incident that you were so irate about earlier; the incident of somebody disclosing to Ms.
    Lewinsky that Ms. Mondale was in the Oval Office?

    A I don't know the answer to that. I think maybe, you know, I don't know. I don't know the

    Q You don't recall that you later gave orders to the effect that we are going to pretend this
    never happened, or something --

    A No, sir.

    Q -- like that?

    A No, sir. I don't recall it. First of all, I don't recall that I gave orders to fire anybody, if that
    was the implication of your first statement.

    Q It wasn't an implication. Actually, the question was that you initially wanted somebody fired.
    You were so mad that you wanted somebody fired.

    A I don't remember that, first of all. I remember l thinking it was an inappropriate thing to do.
    And I, I, I remember, as I usually do when I'm mad, after awhile I wasn't so mad about it, and
    I'm quite aware that Ms. Lewinsky has a way of getting information out of people when she's
    either charming or determined. And it -- I could have just said, well, I,m not so mad about it
    any more.

    But I don't remember the whole sequence of events you'rere talking to me about now, except I
    do remember that somehow Monica found out Eleanor Mondale was there. I learned either
    that day or later that one of the Uniformed Division personnel had told her. I do -- I thought
    then it was a mistake. I think now it was a mistake. I'm not sure it~s a mistake someone should
    be terminated over. I think that, you know, you could just tell them not to do that any more.

    Q In fact, it would kind of be an overreaction, to get irate or terminate somebody for revealing
    to a former White House staffer who visits where the President is, don't you think, sir?

    A Well, it would depend upon the facts. I think on the whole people in the Uniformed Secret
    Service who are working on the gate have no business telling anybody anything about the
    President '~ schedule, just as a general principal. I didn't mind anybody knowing that she was
    there, if that's what you're saying. I could care less about that. But I think that the schedule
    itself -- these uniformed people, you know, somebody shouldn't just be able to come up on the
    street and, because they know who the Secret Service agent is, he says who the President's
    with. I don't think that's proper.

    Q I agree, Mr. President.

    A But, on the other hand, I didn't, you know, I, I wanted to know what happened. I think we
    found out what happened. And then they were, I think,'told not to let it happen again, and I
    think that's the way it should have been handled. I think it was handled in the appropriate way.

    Q You have no knowledge of the fact that Secret Service officers were told later in the day
    something to the effect of, this never happened, this event never happened? You have no
    knowledge of that?

    A I'm not sure anybody ever told that to me. I mean, I thought you were asking -- let me just
    say, my interpretation of this, of your previous question was different than what you're asking

    What I remember was being upset that this matter would be discussed that -- by anybody. It's
    incidental it happened to be Monica Lewinsky. And that, that whatever I said, I don't recall.
    But then thinking that the appropriate thing to do was to say, look, just this, this is not an
    appropriate thing for you to be talking about, the President's schedule, and it shouldn't happen

    Now, the question you seem to be asking me now -- I just want to be sure I'm getting the right
    question -- is whether I gave instructions, in effect, to pretend that Monica Lewinsky was
    never at the gate. And if --

    Q To the effect of pretend --

    A And if that is the question you are asking me, I don't believe I ever did that, sir. I certainly
    have no memory of doing that.

    Q Or anything to that effect?

    A I don't know what that means.

    Q Is that your testimony?

    A What does that mean, anything to that effect?

    Q Well, Mr. President, you've told us that you were not going to try to help the Jones
    attorneys, and I think it's clear from your testimony that you were pretty literal at times. So,
    that's why I'm saying, I don't neceeearily know the exact words. The question was, do you
    have any knowledge of the fact --

    A Of that?

    Q -- of the fact that later in the day, on Saturday, the 6th of December, 1997, Secret Service
    people were then, were told something to this effect: This event never happened, let's just
    pretend This event did not happen. Do you have knowledge of it, or not?

    A No, sir. And I, I didn't instruct the Secret Service in that regard. I have no memory of saying
    anything to anybody in the Secret Service that would have triggered that kind of instruction.

    Q Did you tell Captain Purdy, while you were standing in the doorway between the Oval
    Office and Betty Currie's office, did you tell Captain Purdy of the Uniformed Division, I hope I
    can count on your discretion in this matter? At the end of the day when you all were talking
    about that earlier incident, did you tell him that or anything like that, sir?

    A I don't remember anything I said to him in that regard. I have no recollection of that

    MR. WISENBERG: Let's take a break now.

    MR. KENDALL: Thank you, 3:38.

    (Whereupon, the proceedings were recessed from 3:38 p.m. l until 4:01 p.m.)

    MR. KENDALL: It is 4:01.


    Mr. President, the next series of questions are from the grand jurors. And let me tell you that
    the grand jurors want you to be more specific about the inappropriate conduct.

    The first question was, one of the grand jurors has said that you referred to what you did with
    Ms. Lewinsky as inappropriate contact; what do you mean by that?

    A I mean just what I said. But I would like to ask the grand jury, because I think I have been
    quite specific and I think I've been willing to answer some specific questions that I haven't been
    asked yet, but I do not want to discuss something that is intensely painful to me. This has been
    tough enough already on me and on my family, although I take responsibility for it. I have no
    one to blame but myself.

    What I meant was, and what they can infer that I meant was, that I did things that were --
    when I was alone with her, that were inappropriate and wrong. But that they did not include
    any activity that was within the definition of sexual relations that I was given by Judge Wright
    in the deposition. I said that I did not do those things that were in that, within that definition,
    and I testified truthfully to that. And that's all I can say about it.

    Now, you know, if there's any doubt on the part of the grand jurors about whether I believe
    some kind of activity falls within that definition or outside that definition, I'd be happy to try to
    answer that.

    Q Well, I have a question regarding your definition then. And my question is, is oral sex
    performed on you within that definition as you understood it, the definition in the Jones

    A As I understood it, it was not, no.

    Q The grand jurors would like to know upon what basis, what legal basis you are declining to
    answer more specific questions about this? I've mentioned to you that obviously you have
    privileges, privileges against self-incrimination. There's no general right not to answer questions.

    And so one of the questions from the grand jurors is what basis, what legal basis are you
    declining to answer these questions?

    A I'm not trying to evade my legal obligations or my willingness to help the grand jury achieve
    their legal obligations. As I understand it, you want to examine whether you believe I told the
    truth in my deposition, whether I asked Ms. Lewinsky not to tell the truth, and whether I did
    anything else with evidence, or in any other way, amounting to an obstruction of justice or a
    subornation of perjury. And I'm prepared to answer all questions that the grand jury needs to
    draw that conclusion.

    Now, respectfully, I believe the grand jurors can ask me if I believe -- just like that grand juror
    did - could ask me, do you believe that this conduct falls within that definition. If it does, then
    you are free to conclude , that my testimony is that I didn't do that. And I believe that you can
    achieve that without requiring me to say and do things that I don't think are necessary and that
    I think, frankly, go too far in trying to criminalize my private life.

    Q If a person touched another person, if you touched another person on the breast, would that
    be, in your view, and was it within your view, when you took the deposition, within the
    definition of sexual relations?

    A If the person being deposed -

    Q Yes.

    A -- in this case, me, directly touched the breast of another person, with the purpose to arouse
    or gratify, under that definition that would be included.

    Q Only directly, sir, or would it be directly or through clothing?

    A Well, I would -- I think the common sense definition would be directly. That's how I would
    infer what it means.

    Q If the person being deposed kissed the breast of another person, would that be in the
    definition of sexual relations as you understood it when you were under oath in the Jones case?

    A Yes, that would constitute contact. I think that would. If it were direct contact, I believe it
    would. I -- maybe I should read it again, just to make sure.

    Because this basically says if there was any direct contact with an intent to arouse or gratify, if
    that was the intent of the contact, then that would fall within the definition. That's correct.

    Q So, touching, in your view then and now -- the person being deposed touching or kissing the
    breast of another person would fall within the definition?

    A That's correct, sir.

    Q And you testified that you didn't have sexual relations with Monica Lewinsky in the Jones
    deposition, under that definition, correct?

    A That's correct, sir.

    Q If the person being deposed touched the genitalia of another person, would that be -- and
    with the intent to arouse the sexual desire, arouse or gratify, as defined in definition (1), would
    that be, under your understanding then and now -

    A Yes. sir.

    Q -- sexual relations7

    A Yes, sir.

    Q Yes, it would?

    A Yes, it would. If you had a direct contact with any of these places in the body, if you had
    direct contact with intent to arouse or gratify, that would fall within the definition.

    Q So, you didn't do any of those three things -

    A You -

    Q -- with Monica Lewinsky7

    A You are free to infer that my testimony is that I did not have sexual relations, as I
    understood this term to be defined.

    Q Including touching her breast, kissing her breast, or touching her genitalia?

    A That's correct.

    Q Would you agree with me that the insertion of an object into the genitalia of another person
    with the desire to gratify sexually would fit within the definition used in the Jones case as sexual

    A There's nothing here about that, is there? I don't know that I ever thought about that one
    way or the other.

    Q The question is, under the definition as you understood it then, under the definition as you
    understand it now -- pardon me just a minute.

    Pardon me, Mr. President.


    Deposition Exhibit 1, question 1, under the -- in the Jones case, Definition of Sexual Relations -

    MR. KENDALL: Do you have that before you, Mr. President? Excuse me.

    THE WITNESS: I do, sir.

    MR. KENDALL: Good.

    THE WITNESS: I've got it right here. I'm looking at it.


    Q As you understood the definition then, and as you understood it now, would it include
    sticking an object into the genitalia of another person in order to arouse or gratify the sexual
    desire of any person? Would it constitute, in other words, contact with the genitalia?

    A I don't know the answer to that. I suppose you could argue that since section 2, paragraph
    (2) was eliminated, and paragraph (2) actually dealt with the object issue, that perhaps whoever
    wrote this didn't intend for paragraph (1) to cover an object, and basically meant direct contact.

    So, if I were asked -- I've not been asked this question before. But I guess that's the way I
    would read it.

    Q If it -- that it would not be covered? That activity would not be covered?

    A That's right. If the activity you just mentioned would be covered in number (2), and number
    (2) were stricken, I think you can infer logically that paragraph (l) was not intended to cover it.
    But, as I said, I've not been asked this before. I'm just doing the best I can.

    Q Well, if someone were to hold or a judge were to hold that you are incorrect and that
    definition (1) does include the hypo I've given to you -- because we're talking in hypos, so that
    you don't -- under your request here, if someone were to tell you or rule that you are wrong,
    that the insertion of an object into somebody else's genitalia with the intent to arouse or gratify
    the sexual desire of any person is within definition (1)

    MR. KENDALL: Mr. Wisenberg, excuse me. I have not objected heretofore to any question
    you've asked. I must tell you, I cannot understand that question. I think it's improper. And, if
    the witness can understand it, he may answer.


    MR. WISENBERG: I'll be happy to rephrase it.


    Q If you're wrong and it's within definition (1), did you engage in sexual relations under the
    definition, with Monica Lewinsky?

    A But, Mr. Wisenberg, I have said all along that I would say what I thought it meant, and you
    can infer that I didn't. This is an unusual question, but it's a slippery slope. We can -- I have
    tried to deal with some very delicate areas here, and, and in one case I've given you a very
    forthright answer about what I thought was not within here.

    All I can tell you is, whatever I thought was covered, and I thought about this carefully. And let
    me just point out, this was uncomfortable for me. I had to acknowledge, because of this
    definition, that under this definition I had actually had sexual relations once with Gennifer
    Flowers, a person who had spread all kinds of ridiculous, dishonest, exaggerated stories about
    me for money. And I knew when I did that, it would be leaked. It was. And I was
    embarrassed. But I did it.

    So, I tried to read this carefully. I can tell you what I thought it covered, and I can tell you that
    I do not believe I did anything that I thought was covered by this.

    Q As I understand your testimony, Mr. President, touching somebody's breast with the intent
    to arouse, with the intent to arouse or gratify the sexual desire of any person is covered; kissing
    the breast is covered; touching the genitalia is covered; correct?

    MR. KENDALL: In fairness, the witness said directly in each one of those cases.


    Q Directly, is covered, correct?

    A I believe it is, yes, sir.

    Q Ora1 sex, in your view, is not covered, correct?

    A If performed on the deponent.

    Q Is not covered, correct?

    A That's my reading of this number (1).

    Q And you are declining to answer the hypothetical about insertion of an object.

    I need to inform you, Mr. President -- we'll go on at least for now. But I need to inform you
    that the grand jury will consider your not answering the questions more directly in their
    determination of whether or not they are going to issue another subpoena.

    Let me switch the topic and talk to you about John Podesta and some of the other aides you've
    met with and spoke to after this story became public on January 21st, 1998, the day of The
    Washington Post story.

    Do you recall meeting with him around January 23rd, 1998, a Friday a.m. in your study, two
    days after The Washington Post story, and extremely explicitly telling him that you didn't have,
    engage in any kind of sex, in any way, shape or form, with Monica Lewinsky, including oral

    A I meet with John Podesta almost every day. I meet with a number of people. The only thing
    I -what happened in the couple of days after what you did was revealed, is a blizzard to me.
    The only thing I recall is that I met with certain people, and a few of them I said I didn't have
    sex with Monica Lewinsky, or I didn't have an affair with her or something like that. I had a
    very careful thing I said, and I tried not to say anything else.

    And it might be that John Podesta was one of them. But I do not remember this specific
    meeting about which you asked, or the specific comments to which you refer. And -

    Q You don't remember

    A -- seven months ago, I'd have no way to remember, no.

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

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

    Q Surely, if you told him that, that would be a falsehood, correct7

    A No, I didn't say that, sir. I didn't say that at all. That is not covered by the definition and I
    did not address it in my statement.

    Q Well, let me ask you then. If you told him - perhaps he thought it was covered, I don't
    know. But if you told him, if you denied to him sex in any way, shape or form, kind of similar
    to what Mr. Bennett did at the deposition, including oral sex, wouldn't that have been a

    A Now, Mr. Wisenberg, I told you in response to a grand juror's question, you asked me did I
    believe that oral sex performed on the peraon being deposed was covered by that definition,
    and I said no. I don't believe it's covered by the definition.

    I said you are free to conclude that I did not do things that I believe were covered by the
    definition, and you have asked me a number of questions and I have acknowledged things that
    I believe are covered by the definition. Since that was not covered by the definition, I want to
    fall back on my statement.

    Look, I'm not trying to be evasive here. I'm trying to protect my privacy, my family's privacy,
    and I'm trying to stick to what the deposition was about. If the deposition wasn't about this and
    didn't cover it, then I don't believe that I should be required to go beyond my statement.

    Q Mr. President, it's not our intent to embarrass you. But since we have to look, among other
    things, at obstruction of justice, questions of obstruction of justice and perjury, the answer to
    some of these delicate and unfortunate questions are absolutely required. And that is the
    purpose that we have to ask them for.

    A It's not -

    Q I'm unaware of any -

    A Mr. Wisenberg, with respect, you don't need to know the answer for that, if the answer, no
    matter what the answer is, wouldn't constitute perjury because it wasn't sexual relations as
    defined by the Judge.

    Q Mister -

    A The only reason you need to know that is for some other reason. It couldn't have anything
    to do with perjury.

    Q Mr. President, one of the, one of the nice things about -- one of the normal things about an
    investigation and a grand jury investigation is that the grand jurors and the prosecutors get to
    ask the questions unless they are improper, and unless there is a legal basis.

    As I understand from your answers, there is no legal basis for which you decline to answer
    these questions. And I'll ask you again to answer the question. I'm unaware of any legal basis
    for you not to. If you told -

    MR. KENDALL: Mr. Wisenberg, could you just restate the question, please?


    Q The question is, if you told John Podesta two days after the story broke something to this
    effect, that you didn't have any kind of sex in any way, shape or form, including oral sex with
    Ms. Lewinsky, were you telling him the truth?

    A And let me say again, with respect, this is an indirect way to try to get me to testify to
    questions that have no bearing on whether I committed perjury. You apparently agree that it
    has no bearing--

    Q Oh, I don't -

    A -- no bearing on whether I -

    Q I don't agree.

    A -- committed perjury.

    Q Mr. President, I'm sorry, with respect, I don't agree with that. I'm not going to argue with
    you about it. I just am going to ask you again, in fact direct you to answer the question.

    A I'm not going to answer that question, because I believe it's a question about conduct that,
    whatever the answer to it is, would, does not bear on the perjury because oral sex performed
    on the deponent under this definition is not sexual relations. It is not covered by this definition

    MR. KENDALL: The witness is not declining to tell you anything he said to John Podesta.


    Q You denied the

    MR. WISENBERG: The witness is not declining to tell me anything?


    Q Did you deny oral sex in any way, shape or form, to John Podesta?

    A I told you, sir, before, and I will say again, in the aftermath of this story breaking, and what
    was told about it, the next two days, next three days are just a blur to me. I don't remember to
    whom I talked, when I talked to them, or what I said.

    Q So, you are not declining to answer, you just don't remember?


    I honestly don't remember, no.

    Q Okay.

    A I'm not saying that anybody who had a contrary memory is wrong. I do not remember.

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

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

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

    A No. The -- let me say this. It's no secret to anybody that I hoped that this relationship would
    never become public. It's a matter of fact that it had been many, many months since there had
    been anything improper about it, in terms of improper contact.

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

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

    Q Well, you knew they might be -

    A And so -

    Q -- witnesses, didn't you?

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

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

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

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

    Q If all of these people -- let's leave out Mrs. Currie for a minute. Vernon Jordan, Sid
    Blumenthal, John Podesta, Harold Ickes, Erakine Bowles, Harry Thomasson, after the story
    broke, after Judge Starr's involvement was known on January 21st, have said that you denied a
    sexual relationship with them. Are you denying that?

    A No.

    Q And you've told us that you -

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

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

    A It might have been. Since we have seen this four year, $40-million-investigation come down
    to parsing the definition of sex, I think it might have been. I don't think at the time that I
    thought that's what this was going to be about.

    In fact, if you remember the headlines at the time, even you mentioned the Post story. All the
    headlines were -and all the talking, people who talked about this, including a lot who have been
    quite sympathetic to your operation, said, well, this is not really a story about sex, or this is a
    story about subornation of perjury and these talking points, and all this other stuff.

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

    Q I want to go over some questions again. I don't think you are going to answer them, sir. And
    so I don't need a lengthy response, just a yes or a no. And I understand the basis upon which
    you are not answering them, but I need to ask them for the record.

    If Monica Lewinsky says that while you were in the Oval Office area you touched her breasts,
    would she be lying?

    A Let me say something about all this.

    Q All I really need for you, Mr. President -

    A I know.

    Q -- is to say -

    A But you -

    Q -- I won't answer under the previous grounds, or to answer the question, you see, because
    we only have four hours, and your answers -

    A I know.

    Q -- have been extremely lengthy.

    A I know that. I'll give you four hours and 30 seconds, if you'll let me say something general
    about this. I will answer to your satisfaction that I won't -- based on my statement, I will not
    answer. I would like 30 seconds at the end to make a atatement, and you can have 30 seconds
    more on your time, if you'll let me say this to the grand jury and to you. And I don't think it's
    disrespectful at all. I've had a lot of time to think about this.

    But, go ahead and ask your questions.

    Q The question is, if Monica Lewinsky says that while you were in the Oval Office area you
    touched her breasts, would she be lying?

    A That is not my recollection. My recollection is that I did not have sexual relations with Ms.
    Lewinsky and I'm staying on my former statement about that.

    Q If she said -

    A My, my statement is that I did not have sexual relations as defined by that.

    Q If she says that you kissed her breasts, would she be lying7

    A I'm going to revert to my former statement.

    Q Okay. If Monica Lewinsky says that while you were in the Oval Office area you touched
    her genitalia, would she be lying? And that calls for a yes, no, or reverting to your former

    A I will revert to my statement on that.

    Q If Monica Lewinsky says that you used a cigar as a sexual aid with her in the Oval Office
    area, would she be lying? Yes, no, or won't answer?

    A I will revert to my former statement.

    Q If Monica Lewinsky says that you had phone sex with her, would she be lying?

    A Well, that is, at least in general terms, I think, is covered by my statement. I addressed that
    in my statement, and that, I don't believe, is -

    Q Let me define phone sex for purposes of my question. Phone sex occurs when a party to a
    phone conversation masturbates while the other party is talking in a sexually explicit manner.
    And the question is, if Monica Lewinsky says that you had phone sex with her, would she be

    A I think that is covered by my statement.

    Q Did you, on or about January the 13th, 1998, Mr. President, ask Erskine Bowles to ask
    John Hilley if he would give a recommendation for Monica Lewinsky?

    A In 1998?

    Q Yes. On or about January 13t'h, 1998, did you ask Erskine Bowles, your Chief of Staff, if
    he would ask John Hilley to give a recommendation for Monica Lewinsky?

    A At some point, sir, I believe I talked to Erskine Bowles about whether Monica Lewinsky
    could get a recommendation that was not negative from the Legislative Affairs Office. I believe
    I did.

    Q I just didn't hear the very last part.

    A I think the answer is, I think, yes. At some point I talked to Erskine Bowles about this.

    Q Okay.

    A I do not know what the date was. At some point I did talk to him.

    Q And if Erskine Bowles has told us that he told John Podesta to carry out your wishes, and
    John Podesta states, that it was three or four days before your deposition, which would be the
    13th or the 14th, are you in a position to deny that?

    A The 13th or 14th of?

    Q January, as to date.

    A I don't know. I don't know when the date was

    Q Okay.

    A I'm not in a position to deny it. I won't deny it. I'm sure that they are both truthful men. I
    don't know when the date was.

    Q Do you recall asking Erskine Bowles to do that?

    A I recall talking to Erskine Bowles about that, and my recollection is, sir, that Ms. Lewinsky
    was moving to New York, wanted to get a job in the private sector; was confident she would
    get a good recommendation from the Defense Department; and was concerned that because
    she had been moved from the Legislative Affairs Office, transferred to the Defense
    Department, that her ability to get a job might be undermined by a bad recommendation from
    the Legislative Affairs Office.

    So, I asked Erskine if we could get her a recommendation that just was at least neutral, so that
    if she had a good recommendation from the Defense Department it wouldn't prevent her from
    getting a job in the private sector.

    Q If Mr. Bowles had told us that, in fact, you told him that she already had a job and had
    already listed Mr. Hilley as a reference and wanted him to be available as a recommendation,
    would you be in -is that inconsistent with your memory?

    A A little bit, but I think -- my memory is that when you're, when you get a job like that you
    have to give them a resume, which says where you've worked and who your supervisor was.
    And I think that that's my recollection. My recollection is that -- slightly different from that.

    Q And who was it that asked you to do that on Monica Lewinsky's behalf?

    A I think she did. You know, she tried for months and months to get a job back in the White
    House, not so much in the West Wing but somewhere in the White House complex, including
    the Old Executive Office Building. And she talked to Marsha Scott, among others. She very
    much wanted to come back. And she interviewed for some jobs but never got one. She was,
    from time to time, upset about it.

    And I think what she was afraid of is that she couldn't get a -- from the minute she left the
    White House she was worried about this. That if she didn't come back to the White House and
    work for awhile and get a good job recommendation, that no matter how well she had done at
    the Pentagon it might hurt her future employment prospects.

    Well, it became obvious that, you know, her mother had moved to New York. She wanted to
    go to New York. She wasn't going to get a job in the White House. So, she wanted to get a job
    in the private sector, and said, I hope that I won't get a letter out of the Legislative Affairs
    office that will prevent my getting a job in the private sector. And that's what I talked to
    Erskine about.

    Now, that's my entire memory of this.

    Q All right. I want to go back briefly to the December 28th conversation with Ms. Lewinsky. I
    believe you testified to the effect that she asked you, what if they ask me about gifts you gave
    me. My question to you is, after that statement by her, did you ever have a conversation with
    Betty Currie about gifts, or picking something up from Monica Lewinsky?

    A I don't believe I did, sir. No.

    Q You never told her anything to this effect, that Monica has something to give you?

    A No, sir.

    Q That is to say, Betty Currie?

    A No, sir, I didn't. I don't have any memory of that whatever.

    Q And so you have no knowledge that, or you had no knowledge at the time, that Betty Currie
    went and picked up, your secretary went and picked up from Monica Lewinsky items that
    were called for by the Jones subpoena and hid them under her bed? You had no knowledge
    that anything remotely like that was going to happen?

    A I did not. I did not know she had those items, I believe, until that was made public.

    Q And you agree with me that that would be a very wrong thing to do, to hide evidence in a
    civil case, or any case? Isn't that true?

    A Yes. I don't know that, that Ms. Currie knew that that's what she had at all. But -

    Q I'm not saying she did. I'm just saying -

    A I had -- it is, if Monica Lewinsky did that after they had been subpoenaed and she knew
    what she was doing, she should not have done that.

    Q And if you knew, you -

    A And I -

    Q -- shouldn't have done it7

    A Indeed, I, myself, told her, if they ask you for gifts you have to give them what you have.
    And I don't understand if, in fact, she was worried about this, why she was so worried about it.
    It was no big deal.

    Q I want to talk about a December 17th phone conversation you had with Monica Lewinsky at
    approximately 2:00 a.m. Do you recall making that conversation and telling her initially about
    the death of Betty' a brother, but then, telling her that she was on the witness list, and that it
    broke your heart that she was on the witness list?

    A No, sir, I don't, but it would -- it, it would -it is quite possible that that happened, because, if
    you remember, earlier in this meeting you asked me some questions about what I'd said to
    Monica about testimony and affidavits, and I was struggling to try to remember whether this
    happened in a meeting or a phone call.

    Now, I remember I called her to tell her Betty's brother had died. I remember that. And I know
    it was in the middle of December, and I believe it was before Monica had been subpoenaed.
    So, I think it is quite possible that if I called her at that time and had not talked to her since the
    6th -- and you asked me this earlier -- I believe when I saw her on the 6th, I don't think I knew
    she was on the witness list then, then it's quite possible I would say something like that. I don't
    have any memory of it, but I certainly wouldn't dispute that I might have said that.

    Q And in that conversation, or in any conversation which you informed her she was on the
    witness list, did you tell her, you know, you can always say that you were coming to see Betty
    or bringing me letters? Did you tell her anything like that?

    A I don't remember. She was coming to see Betty. I can tell you this. I absolutely never asked
    her to lie.

    Q Sir, every time she came to see Betty and you were in the Oval Office, she was coming to
    see you, too, wasn't she, or just about every time?

    A I think just about every time. I don't think every time. I think there was a time or two where
    she came to see Betty when she didn't see me.

    Q So, do you remember telling her any time, any time when you told her, or after you told her
    that she was on the witness list, something to this effect: You know, you can always say you
    were coming to see Betty, or you were bringing me letters?

    A I don't remember exactly what I told her that night.

    Q Did you -

    A I don't remember that. I remember talking about the nature of our relationship, how she got
    in. But I also will tell you that I felt quite comfortable that she could have executed a truthful
    affidavit, which would not have disclosed the embarrassing details of the relationship that we
    had had, which had been over for many, many months by the time this incident occurred.

    Q Did you tell her anytime in December something to that effect: You know, you can always
    say that you were coming to see Betty or you were bringing me letters? Did you say that, or
    anything like that, in December '97 or January '98, to Monica Lewinsky7

    A Well, that's a very broad question. I do not recall saying anything like that in connection with
    her testimony. I could tell you what I do remember saying, if you want to know. But I don't --
    we might have talked about what to do in a non legal context at some point in the past, but I
    have no specific memory of that conversation.

    I do remember what I said to her about the possible testimony.

    Q You would agree with me, if you did say something like that to her, to urge her to say that to
    the Jones people, that that would be part of an effort to mislead the Jones people, no matter
    how evil they are and corrupt?

    A I didn't say they were evil. I said what they were doing here was wrong, and it was.

    Q Wouldn't that be misleading?

    A Well, again, you are trying to get me to characterize something that I'm -- that I don't know
    if I said or not, without knowing whether the whole,

    whether the context is complete or not. So, I would have to know, what was the context, what
    were all the surrounding facts.

    I can tell you this: I never asked Ms. Lewinsky to lie. The first time that she raised with me the
    possibility that she might be a witness or I told her -- you suggested the possibility in this
    December 17th timeframe -- I told her she had to get a lawyer. And I never asked her to lie.

    Q Did you ever say anything like that, you can always say that you were coming to see Betty
    or bringing me letters? Was that part of any kind of a, anything you said to her or a cover
    story, before you had any idea she was going to be part of Paula Jones?

    A I might well have said that.

    Q Okay.

    A Because I certainly didn't want this to come out, if I could help it. And I was concerned
    about that. I was embarrassed about it. I knew it was wrong. And, you know, of course, I
    didn't want it to come out. But -

    Q But you are saying that you didn't say anything - I want to make sure I understand. Did you
    say anything like that once you knew or thought she might be a witness in the Jones case? Did
    you repeat that statement, or something like it to her?

    A Well, again, I don't recall, and I don't recall whether I might have done something like that,
    for example, if somebody says, what if the reporters ask me this, that or l the other thing. I can
    tell you this: In the context of whether she could be a witness, I have a recollection that she
    asked me, well, what do I do if I get called as a witness, and I said, you have to get a lawyer.
    And that's all I said. And I never asked her to lie.

    Q Did you tell her to tell the truth?

    A Well, I think the implication was she would tell the truth. I've already told you that I felt
    strongly that she could issue, that she could execute an affidavit that would be factually
    truthful, that might get her out of having to testify. Now, it obviously wouldn't if the Jones
    people knew this, because they knew that if they could get this and leak it, it would serve their
    larger purposes, even if the judge ruled that she couldn't be a witness in the case. The judge
    later ruled she wouldn't be a witness in the case. The judge later ruled the case had no merit.

    So, I knew that. And did I hope she'd be able to get out of testifying on an affidavit?
    Absolutely. Did I want her to execute a false affidavit? No, I did not.

    Q If Monica Lewinsky has stated that her affidavit that she didn't have a sexual relationship
    with you is, in fact, a lie, I take it you disagree with that?

    A No. I told you before what I thought the issue was there. I think the issue is how do you
    define sexual relationship. And there was no definition imposed on her at the time she executed
    the affidavit. Therefore, she was free to give it any reasonable meaning.

    Q And if she says she was lying -

    A And I believe -

    Q -- under your common sense ordinary meaning that you talked about earlier, Mr. President,
    that most Americana would have, if she says sexual relationship, saying I didn't have one was a
    lie because I had oral sex with the President, I take it, you would disagree with that?

    A Now, we're back to where we started and I have to invoke my statement. But, let me just
    say one thing. I've read a lot, and obviously I don't know whether any of it's accurate, about
    what she said, and what purports to be on those tapes.

    And this thing -- and I searched my own memory. This reminds me, to some extent, of the
    hearings when Clarence Thomas and Anita Hill were both testifying under oath. Now, in some
    rational way, they could not have both been telling the truth, since they had directly different
    accounts of a shared set of facts. Fortunately, or maybe you think unfortunately, there was no
    special prosecutor to try to go after one or the other of them, to take sides and try to prove one
    was a liar. And so, Judge Thomas was able to go on and serve on the Supreme Court.

    What I learned from that, I can tell you that I was a citizen out there just listening. And when I
    heard both of them testify, what I believed after it was over, I believed that they both thought
    they were telling the truth.

    This is -- you're dealing with, in some ways, the most mysterious area of human life. I'm doing
    the best I can to give you honest answers.

    Q Mr. President -

    A And that's all I can say.

    Q I'm sorry.

    A And, you know, those people both testified under oath. So, if there'd been a special
    prosecutor, they could, one of them could have gone after Anita Hill, another could have gone
    after Clarence Thomas. I thank God there was no such thing then, because I don't believe that
    it was

    A proper thing.

    Q One of --

    A And I think they both thought they were telling the truth. So, maybe Ms. Lewinsky believes
    she's telling the truth, and I'm glad she got her mother and herself out of trouble. I'm glad you
    gave her that sweeping immunity. I'm glad for the whole thing. I, I, I -- it breaks my heart that
    she was ever involved in this.

    Q I want to go back to a question about Vernon Jordan. I want to go back to late December
    and early January, late December of '97 and early January of '98. During this time, Mr.
    President, you are being sued for sexual harassment by a woman who claims, among other
    things, that others got benefits that she didn't because she didn't have oral sex with you. While
    this is happening, your powerful friend, Vernon Jordan, is helping to get Monica Lewinsky a
    job and a lawyer. He's helping to get a job and a lawyer for someone who had some kind of
    sex with you, and who has been subpoenaed in the very case, the Jones case.

    Don't you see a problem with this? Didn't you see a problem with this?

    A No. Would you like to know why?

    Q Isn't that why -- I would. But isn't that why Vernon Jordan asked you on December 19th
    whether or not you had sexual relationships with Monica Lewinsky and why he asked her,
    because he knew it would be so highly improper to be helping her with a lawyer and a job if, in
    fact, she had had a relationship with you?

    A I don't know. I don't believe that at all. I don't believe that at all, particularly since, even if
    you look at the facts here in their light most unfavorable to me, no one has suggested that there
    was any sexual harassment on my part. And I don't think it was wrong to be helping her. Look

    Q A subpoenaed witness in a case against you?

    A Absolutely. Look, for one thing, I had already proved in two ways that I was not trying to
    influence her testimony. I didn't order her to be hired at the White House. I could have done
    so. I wouldn't do it. She tried for months to get in. She was angry.

    Secondly, after I -

    Q Wasn't she kept -

    A After I terminated the improper contact with her, she wanted to come in more than she did.
    She got angry when she didn't get in sometimes. I knew that that might make her more likely to
    speak, and I still did it because I had to limit the contact.

    And, thirdly, let me say, I formed an opinion really early in 1996, and again -- well, let me
    finish the sentence. I formed an opinion early in 1996, once I got into this unfortunate and
    wrong conduct, that when I stopped it, which I knew I'd have to do and which I should have
    done a long time before I did, that she would talk about it. Not because Monica Lewinsky is a
    bad person. She's basically a good girl. She's a good young woman with a good heart and a
    good mind. I think she is burdened by some unfortunate conditions of her, her upbringing. But
    she's basically a good person.

    But I knew that the minute there was no longer any contact, she would talk about this. She
    would have to. She couldn't help it. It was, it was a part of her psyche. So, I had put myself at
    risk, sir. I was not trying to buy her silence or get Vernon Jordan to buy her silence. I thought
    she was a good person. She had not been involved with me for a long time in any improper
    way, several months, and I wanted to help her get on with her life. It's just as simple as that.

    MR. WISENBERG: It's time for a break.

    MR. KENDALL: Okay. 4:49.

    (Whereupon, the proceedings were recessed from 4:49 p.m.until 5:05 p.m.)

    MR. KENDALL: Bob, we are at 2 hours and 55

    MR. BITTMAN: Two hours and 55 minutes, thank you.


    Q Mr. President.

    A Mr. Bittman.

    Q Apparently we have one hour and five minutes left, if we stick to the four-hour timeframe.

    MR. KENDALL: Plus 30 seconds.

    MR. BITTMAN: And 30 seconds, that's right.

    THE WITNESS: You gave me my 30 seconds, soliloquy. So, I owe you 30 seconds.


    Q You are very generous. That actually segues very nicely into one of the grand juror's asked,
    pointed out actually, that you indicated at the beginning of the deposition that you would, you
    would answer all the grand jurors, you wanted to answer all the grand jurors questions. And
    they wanted to know whether you would be willing to stay beyond the four-hour period to, in
    fact, answer all their questions.

    A Well, let's see how we do in the next hour, and then we'll decide.

    Q Okay. Let me draw your attention to early January of this year, after Christmas, before your
    deposition. Do you remember talking to Betty Currie about Monica, who had just called her
    and said that she, Monica, needed to talk to you before she signed something?

    A I'm not sure that I do remember that. But, go ahead .

    Q This is in early January. And then Betty Currie relayed this to you that Monica called, it's
    important, she needs to talk to you before she signs something. And then you do, indeed, talk
    to Monica that day on the telephone.

    A I did talk to her that day7

    Q Yes.

    MR. KENDALL: Mr. President, excuse me. That's a question. If you have a memory of that,
    you can answer.

    TNE WITNESS: I'm trying to remember when the last time I talked to her was. I am aware,
    sir, that she signed this affidavit about this time, sometime in the first week in January. I may
    have talked to her before she did it. I don't know. I talked to her a number of times between
    the time Betty's brother died and Christmas. Then I saw her on December 28. I may have
    talked to her, but I don't remember the specific conversation.


    Q And you would have talked about the -- she had just given you a gift actually in early
    January, a book on the Presidents of the United States. And you discussed this with her and
    she said that you said you liked it a lot.

    A I did like it a lot. I told you that. My impression, my belief was that she gave me that book
    for Christmas. Maybe that's not right. I think she had that book delivered to me for Christmas.
    And then, as I remember, I went to Bosnia and for some reason she wasn't there around
    Christmas time.

    But, anyway, maybe I didn't get it until January. My recollection was that I had gotten it right
    before Christmas.

    Q Let me see if I can jog your memory further. Monica talked to you in that phone
    conversation that told you that she had just met with her attorney that Mr. Jordan arranged
    with her, and the attorney said that if she is deposed that they were going to ask her how she
    got her job at the Pentagon. And Monica then asked you, what do you think I should say, how
    do I answer that question, how did I get the job at the Pentagon. Did you talk to Monica about
    that, about possibilities -

    A I don't believe -- no. I don't remember her asking me that. But if she, if she had asked me
    that, I would have told her to tell the truth. I -- and I didn't, you know, I don't know exactly
    how she got her job at the Pentagon. I know Evelyn Lieberman wanted to transfer her out of
    the job she had, and somebody must have arranged that. But I didn't arrange it.

    Q Now, that's actually not my question. My question is whether you remember talking to
    Monica about her being concerned that, I may have to answer some questions about how and
    why I was transferred to the Pentagon out of the White House, fearing that this would -

    A No, I don't remember that at all.

    Q -- lead to questions, or answers that would reveal your relationship?

    A Oh, no, sir. I don't remember that. Maybe somebody -- maybe she did. But I only
    remember -- well, I don't remember that. That's all I can tell you. I don't remember that.

    Q Are you saying, Mr. President, that you did not then say to Ms. Lewinsky that you could
    always say that people in Legislative Affairs got you the job, or helped you get it?

    A I have no recollection of that whatever.

    Q Are you saying you didn't say it?

    A No, sir. I'm telling you, I want to say I don't recall -- I don't have any memory of this as I sit
    here today. And I can tell you this, I never asked her to lie. I never did. And I don't have any
    recollection of the specific l thing you are saying to me.

    Now, if I could back up, there were several times when Monica Lewinsky talked to me on the
    telephone in 1996, in person in 1997, about her being concerned about what anybody would
    say about her transfer from the White House to the Pentagon. But I remember no conversation
    in which she was concerned about it for the reasons you just mentioned.

    And all my memory is, she was worried about it because she thought it would keep her from
    getting a good job down the road, and she talked to me about it constantly in 1997. She
    thought, well, I'll never have my record clear unless I work somewhere in the White House
    complex where I can get a good recommendation. But in the context that you mention it, I do
    not recall a conversation.

    Q Did you ever tell Ms. Lewinsky, or promise to her that you would do your best to get her
    back into the White House after the 1996 Presidential elections?

    A what I told Ms. Lewinsky was that I would, I would do what I could to see, if she had a
    good record at the Pentagon, and she assured me she was doing a good job and working hard,
    that I would do my best to see that the fact that she had been sent away from the Legislative
    Affairs section did not keep her from getting a job in the White House, and that is, in fact, what
    I tried to do. I had a conversation with Ms. Scott about it, and I tried to do that.

    But I did not tell her I would order someone to hire her, and I never did, and I wouldn't do
    that. It wouldn't be right.

    Q When you received the book, this gift from Monica, the Presidents of the United States, this
    book that you liked and you talked with Monica about, did it come with a note? Do you
    remember the note that it came with, Mr. President?

    A No, sir, I don't.

    Q Do you remember that in the note she wrote that, she expressed how much she missed you
    and how much she cared for you, and you and she later talked about this in this telephone
    conversation, and you said -- and she apologized for putting such emotional, romantic things in
    this note, and you said, yeah, you shouldn't have written some of those things, you shouldn't
    put those things down on paper? Did you ever say anything like that to Ms. Lewinsky?

    A Oh, I believe I did say something like that to Ms Lewinsky. I don't remember doing
    something as late as you suggest. I'm not saying I didn't. I have no recollection of l that.

    Keep in mind now, it had been quite a long time since I had had any improper contact with her.
    And she was, in a funny way, almost more attached to me than she had been . before. In '96,
    she had a long relationship, she said, with a man whom she liked a lot. And I didn't know what
    else was going on in her private life in '97. But she talked to me occasionally about people she
    was going out with.

    But normally her language at this point was, if affectionate, was, was not improperly
    affectionate, I would . say. So -- but, it could have happened. I wouldn't say it didn't. I just
    don't remember it at this late date.

    Q Let me refer back to one of the subjects we talked about at one of the earlier breaks, right
    before one of the earlier breaks, and that is your meeting with Mrs. Currie on January 18th.
    This is the Sunday after your deposition in the Paula Jones case.

    You said that you spoke to her in an attempt to refresh your own recollection about the events
    involving Monica Lewinsky, is that right?

    A Yes.

    Q How did you making the statement, I was never alone with her, right, refresh your

    A Well, first of all, let's remember the context here. I did not at that time know of your
    involvement in this case. I just knew that obviously someone had given them a lot of
    information, some of which struck me as accurate, some of which struck me as dead wrong.
    But it led them to write, ask me a whole serious of questions about Monica Lewinsky.

    Then on Sunday morning, this Drudge report came out, which used Betty's name, and I
    thought that we were going to be deluged by press comments. And I was trying to refresh my
    memory about what the facts were.

    So, when I said, we were never alone, right, I think I also asked her a number of other
    questions, because l there were several times, as I'm sure she would acknowledge, when I
    either asked her to be around. I remember once in l particular when I was talking with Ms.
    Lewinsky when I asked Betty to be in the, actually, in the next room in the dining room, and,
    as I testified earlier, once in her own office.

    But I meant that she was always in the Oval Office complex, in that complex, while Monica
    was there. And I believe that this was part of a series of questions I asked her to try to quickly
    refresh my memory. So, I wasn't trying to get her to say something that wasn't so. And, in
    fact, I think she would recall that I told her to just relax, go in the grand jury and tell the truth
    when she had been called as a witness.

    Q So, when you said to Mrs. Currie that, I was never alone with her, right, you just meant that
    you and Ms. Lewinsky would be somewhere perhaps in the Oval Office or many times in your
    back study, is that correct?

    A That's right. We were in the back study.

    Q And then -

    A Keep in mind, sir, I just want to make it -- I was talking about 1997. I was never, ever trying
    to get Betty Currie to claim that on the occasions when Monica Lewinsky was there when she
    wasn't anywhere around, that she was. I would never have done that to her, and I don't think
    she thought about that. I don't think she thought I was referring to that.

    Q Did you put a date restriction? Did you make it clear to Mrs. Currie that you were only
    asking her whether you were never alone with her after 1997?

    A Well, I don't recall whether I did or not, but I assumed -- if I didn't, I assumed she knew
    what I was talking about, because it was the point at which Ms. Lewinsky was out of the
    White House and had to have someone WAVE her in, in order to get in the White House. And
    I do not believe to this day that I was -- in 1997, that she was ever there and that I ever aww
    her unless Betty Currie was there. I don't believe she was.

    Q Do you agree with me that the statement, "I was never alone with her", is incorrect? You
    were alone with Monica Lewinsky, weren't you?

    A Well, again, it depends on how you define alone. Yea, we were alone from time to time,
    even during 1997, even when there wee absolutely no improper contact occurring. Yes, that ia

    But there were also a lot of times when, even though no one could see us, the doors were open
    to the halls, l on both ends of the halls, people could hear. The Navy stewards could come in
    and out at will, if they were around. Other things could be happening. So, there were a lot of
    times when we were alone, but I never really thought we were.

    And sometimes when we, when -- but, as far as I know, what I was trying to determine, if I
    might, is that Betty was always around, and I believe she was always around . where I could
    basically call her or get her if I needed her.

    Q When you said to Mrs. Currie, you could see and hear everything, that wasn't true either,
    was it, as far as you knew? You've already -

    A My memory of that -

    Q -- testified that Betty was not there.

    A My memory of that was that, that she had the ability to hear what was going on if she came
    in the Oval Office from her office. And a lot of times, you know, when I was in the Oval
    Office, she just had the door open to her office. Then there was -- the door was never
    completely closed to the hall. So, I think there was -- I'm not entirely sure what I meant by
    that, but I could have meant that she generally would be able to hear conversations, even if she
    couldn't see them. And I think that's what I meant.

    Now, I could have been referring not generally to every time she was there, but one, one
    particular time I remember when Ms. Lewinsky was there when I asked Betty -and I'm sorry
    to say for reasons I don't entirely remember -to actually stay in the dining room while I talked
    with Monica. I do remember one such instance.

    Q Well, you've already testified that this -- you did almost everything you could to keep this
    relationship secret. So, would it be fair to say -- even from Mrs. Currie. She didn't know about
    the nature, that is, your intimate, physically intimate relationship with Ms. Lewinsky, did she?

    A As far as I know, she is unaware of what happened on the, on the occasions when I saw her
    in 1996 when something improper happened. And she was unaware of the one time that I
    recall in 1997 when something happened.

    I think she was quite well aware that I was determined to impose the appropriate limits on the
    relationship when I was trying to do it. And the -- you know, anybody would hope that this
    wouldn't become public. Although I frankly, from 1996 on, always felt that if I severed
    inappropriate contact with Ms. Lewinsky, sooner or later it would get public. And I never
    thought it would be part of the Jones case. I never even thought about that. I never thought -- I
    certainly never thought it would be part of your responsibilities.

    Q My question was -

    A But I did believe that she would talk about it.

    O My question was more simple than that. Mrs. Currie did not know of the physically intimate
    nature of your relationship, did she?

    A I don't believe she did, no.

    Q Okay. So, you would have done -- you tried to keep that nature of the relationship from
    Mrs. Currie?

    A Absolutely. I -

    Q So, you would not have engaged in those physically intimate acts if you knew that Mrs.
    Currie could see or hear that, is that correct?

    A That 's correct. But, keep in mind, sir, I was talking about 1997. That occurred, to the -- and
    I believe that occurred only once in February of 1997. I stopped it. I never should have started
    it, and I certainly shouldn't have started it back after I resolved not to in 1996. And was
    referring to 1997

    And I -- what -- as I say, I do not know -her memory and mine may be somewhat different. I
    do not know whether I was asking her about a particular time when Monica was upset and I
    asked her to stand, stay back in the dining area. Or whether I was, had reference to the fact
    that if she kept the door open to the Oval Office, because it was always -- the door to the
    hallway was always somewhat open, that she would always be able to hear something if
    anything went on that was, you know, too loud, or whatever.

    I do not know what I meant. I'm just trying to reconcile the two statements as best I can,
    without being sure.

    Q There was at least one event where Mrs. Currie was definitely not even in the Oval Office
    area, isn't that right? And I think you began to testify about that before. That was at the radio

    A I'm not sure of that. But in that case, there was, there was certainly someone else there. I
    don't know -

    Q Well, why would you be testing Mrs. Currie's memory about whether someone else was

    A Well, I can say this. If I'm in the Oval Office - my belief is that there was someone else
    there, somewhere in the Oval Office complex. I've looked at our -- I've looked at the film.
    This, this night has become legendary now, you know. I've looked at the, I've looked at the
    film we have. I've looked at my schedules. I've seen the people that were at the radio address.

    I do believe that I was alone with her from 15 to 20 minutes. I do believe that things happened
    then which l were inappropriate. I don't remember whether Betty was there or not, but I can't
    imagine that, since all this happened more or less continuously in that time period, there must
    have been someone who was working around the radio address who stayed around
    somewhere. That would be my guess. I don't know. I'm sorry. I don't have records about who
    it would be. But I doubt very seriously if we were all alone in . that Oval Office complex then.

    Q Mr. President, if there is a semen stain belonging . to you on a dress of Ms. Lewinsky's,
    how would you explain that?

    A Well, Mr. Bittman, I, I don't -- first of all, when l you asked me for a blood test, I gave you
    one promptly. You came over here and got it. That's -- we met that night and talked. So, that's
    a question you already know the answer to. Not if, but you know whether.

    And the main thing I can tell you is that doesn't affect the opening statement I made. The
    opening statement I made is that I had inappropriate intimate contact. I take full responsibility
    for it. It wasn't her fault, it was mine. I do not believe that I violated the definition of sexual
    relations I was given by directly touching those parts of her body with the intent to arouse or
    gratify. And that's all I have to say.

    I think, for the rest, you know, you know what the evidence is and it doesn't affect that

    Q Is it possible or impossible that your semen is on a dress belonging to Ms. Lewinsky?

    A I have nothing to add to my statement about it, sir. You, you know whether -- you know
    what the facts are. There's no point in a hypothetical.

    Q Don't you know what the facts are also, Mr. President?

    A I have nothing to add to my statement, sir.

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

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

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

    A Now, Mr. Bittman, I told you, the only thing I remember is when all this stuff blew up, I
    was trying to figure out what the facts were. I was trying to remember. I was trying to
    remember every time I had seen Ms. Lewinsky. Once this thing was in Drudge, and there was
    this argument about whether it was or was not going to be in Newsweek, that was a clear signal
    to me, because Newsweek, frankly, was -had become almost a sponsoring media outlook for
    the Paula Jones case, and had a journalist who had been trying, so far fruitlessly, to find me in
    some sort of wrongdoing.

    And so I knew this was all going to come out. I was trying -- I did not know at the time -I will
    say again, I did not know that any of you were involved. I did not know that the Office of
    Independent Counsel was involved. And I was trying to get the facts and try to think of the
    best defense we could construct in the face of what I thought was going to be a media

    Once you became involved, I told Betty Currie not to worry, that, that she had been through a
    terrible time. She had lost her brother. She had lost her sister. Her mother was in the hospital. I
    said, Betty, just don't worry about me. Just relax, go in there and tell the truth. You'll be fine.
    Now, that's all there was in this context.

    Q Did the conversations that you had with Mrs. Currie, this conversation, did it refresh your
    recollection as to events involving Ms. Lewinsky?

    A Well, as I remember, I do believe, in fairness, I that, you know, she may have felt some
    ambivalence about how ; to react, because there were some times when she seemed to say yes,
    when I'm not sure she meant yes. There was a time -- it seems like there was one or two things
    where she said, well, remember this, that or the other thing, which did reflect my recollection.

    So, I would say a little yes, and a little no.

    Q Why was it then that two or three days later, given that The Washington Post article came
    out on January 21st, why would you have had another conversation with Betty Currie asking
    or making the exact same statements to her?

    A I don't know that I did. I remember having this one time. I was, I was -- I don't know that I

    Q If Mrs. Currie says you did, are you disputing that?

    A No, sir, I'm not disputing -

    MR. KENDALL: Excuse me. Is your representation that she testified that that conversation
    was – when?

    MR. BITTMAN: I'm not making a representation as to what Mrs. Currie said. I'm asking the
    President if Mrs. Currie testified two or three days later, that two or three days after the
    conversation with the President on January 18th, that he called her into the Oval Office and
    went over the exact same statements that the President made to her on the 18th.


    Q Is that accurate? Is that a Mrs. Currie, if she made it?

    A I do not remember how many times Currie or when. I don't. I can't possibly remember that.
    I do remember, when I first heard about this story breaking, trying to ascertain what the facts
    were, trying to ascertain what Betty's perception was. I remember that I was highly agitated,
    understandably, I think.

    And then I remember when I knew she was going to have to testify to the grand jury, and I, I
    felt terrible because she had been through this loss of her sister, this horrible accident Christmas
    that killed her brother, and her mother was in the hospital. I was trying to do -- to make her
    understand that I didn't want her to, to be untruthful to the grand jury. And if her memory was
    different from mine, it was fine, just go in there and tell them what she thought. . So, that's all I


    Q Mr. President, my name is Jackie Bennett. If I understand your current line of testimony,
    you are saying that your only interest in speaking with Ms. Currie in the days after your
    deposition was to refresh your own recollection?

    A Yes.

    0 It was not to impart instructions on how she was to recall things in the future?

    A No, and certainly not under oath. That -every day, Mr. Bennett, in the White House and in
    every other political organization when you are subject to a barrage of press questions of any
    kind, you always try to make the best case you can consistent with the facts; that is, while
    being truthful.

    But -- so, I was concerned for a day or two there , about this as a press story only. I had no
    idea you were l involved in it for a couple of days.

    I think Betty Currie's testimony will be that I gave her explicit instructions or encouragement to
    just go in the grand jury and tell the truth. That 'a what I told her to do and I thought she

    Q Mr. President, when did you learn about the Drudge Report reporting allegations of you
    having a sexual relationahip with someone at the White House?

    A I believe it was the morning of the 18th, I think.

    Q What time of day, sir?

    A I have no idea.

    Q Early morning hours?

    A Yeah, I think somebody called me and told me about it. Maybe Bruce, maybe someone else.
    I'm not sure. But I learned early on the l8th of the Drudge Report.

    Q Very early morning hours, sir?

    A Now, my deposition wee on the 17th, is that right?

    Q On Saturday, the 17th, sir.

    A Yeah, I think it was when I got up Sunday morning, I think. Maybe it was late Saturday
    night. I don't remember.

    Q Did you call Betty Currie, sir, after the Drudge Report hit the wire?

    A I did.

    Q Did you call her at home?

    A I did. Was that the night of the 17th?

    Q Night of the 17th, early morning hours of the 18th?

    A Okay, yes. That's because -- yes. I worked with Prime Minister Netanyahu that night until
    about midnight.

    MR. KENDALL: Wait.

    THE WITNESS: Isn't that right?

    MR. KENDALL: Excuse me. I think the question is directed -- Mr. Bennett, if you could help
    out by putting the day of the week, I think that would be helpful.


    Q Saturday night, Sunday morning.

    A Yes. I called Betty Currie as soon -- I think about as soon as I could, after I finished with
    Prime Minister Netanyahu, and in the aftermath of that meeting planning where we were going
    next in the Middle East peace process.

    MR. KENDALL: Can we take a two-minute break please?

    MR. BITTMAN: May I ask one other question first, Mr. Kendall?

    MR. KENDALL: Certainly. I think the witness is confused on dates. That's all.

    MR. BITTMAN: Okay.

    THE WITNESS: That's what -- I didn't think it was the night of the 17th.

    MR. KENDALL: Mr. President, I think we'll do it in a break.

    THE WITNESS: Can we have a break and I could get straightened out?

    MR. BITTMAN: Sure. May I ask one other guick this is a question I forgot to ask from the
    grand jurors.

    THE WITNESS: I don't want to get mixed up on these dates now. Go ahead.


    Q This is -- they wanted to know whether, they want us to clarify that the President's
    knowledge, your knowledge, Mr. President, as to the approach to our office this morning; that
    is, we were told that you would give a general statement about the nature of your relationship
    with Ms. Lewinsky, which you have done. Yet that you would -- you did not want to go in any
    of the details about the relationship. And that if we pressed on going into the details, that you
    would object to going into the details.

    And the grand jurors, before they wanted, they wanted to vote on some other matters, they
    wanted to know whether you were aware of that? That we were told that?

    MR. KENDALL: Well, Mr. Bittman, who told you that? This is, this is, this is not a fair
    question, when you say you were told. Who told you?

    MR. BITTMAN: Who told me what, the question?

    MR. KENDALL: You said, you said the grand jury was told.

    MR. BITTMAN: We have kept the grand jury informed, as we normally would, of the
    proceedings here.

    MR. KENDALL: Right. And, I'm sorry. Who, who are you representing told you or the grand
    jurors anything? Is that, is that our conversation?

    MR. BITTMAN: Yes.

    MR. STARR: Yes, our conversation.

    MR. BITTMAN: Yes. That was in substance related to the grand jurors.


    And what's your question to me, Mr. Bittman?


    Q Whether you were aware of the facts that I just described?

    A Yes, sir. Let me say this. I knew that Mr. Kendall was going to talk with Judge Starr. What
    we wanted to do was to be as helpful as we could to you on the question of whether you felt I
    was being truthful, when I said I did not have sexual relations with Ms. Lewinsky, as defined in
    that definition (1) in this, in my testimony.

    And I thought the best way to do that, and still preserve some measure of privacy and dignity,
    would be to invite all of you and the grand jurors to ask, well, would you consider this, that, or
    the other thing covered by the definition. You asked me several questions there, and I did my
    best to answer whether I thought they were covered by the definition, and said if I thought they
    were covered, you could conclude from that that my testimony is I did not do them.

    If those things, if things are not covered by the definition, and I don't believe they are covered,
    then l could not -- then they shouldn't be within this discussion one way or the other.

    Now, I know this is somewhat unusual. But I would say to the grand jury, put yourself in my
    position. This is not a typical grand jury testimony. I, I have to assume a report is going to
    Congress. There 's a videotape being made of this, allegedly because only one member of the
    grand jury is absent. This is highly unusual. And, in addition to that, I have sustained a
    breathtaking number of leaks of grand jury proceedings.

    And, so, I think I am right to answer all the questions about perjury, but not to say things
    which will be forever in the historic annals of the United States because of this unprecedented
    videotape and may be leaked at any time. I just think it's a mistake.

    And, so, I'm doing my best to cooperate with the grand jury and still protect myself, my
    family, and my office.

    MR. BITTMAN: Thank you.

    MR. KENDALL: This will be two minutes.

    (Whereupon, the proceedings were recessed from 5:37 p.m. until 5:43 p.m.)


    Q Mr. President, before we broke, we were talking about the sequencing of your conversations
    with Betty Currie following your deposition on Saturday, January 17th. Do you recall that?

    A I do.

    Q All right. And you recall contacting Betty Currie, calling her and instructing her on the
    evening of Saturday night, after your deposition, and telling her to come in the next day?

    A Yes, sir, I do.

    Q Sunday was normally her day off, isn't that so?

    A Yes, it was.

    Q And so you were making special arrangements for her to come back into the White House,
    isn't that so?

    A Well, yes. I asked her to come back in and talk to me.

    Q And it was at that time that you spoke with her, and Mr. Bittman and Mr. Wisenberg have
    asked you questions about what you said in that conversation, isn't that so?

    A Yes, they have -- I don't know whether that's the time, but they -- I did talk to her as soon
    as I realized that the deposition had become more about Monica Lewinsky than Paula Jones. I
    asked her, you know, if she knew anything about this. I said, you know, it's obvious that this is
    going to be a matter of press speculation, and I was trying to go through the litany of what had
    happened between us, and asked some questions.

    Q On fairness, it would be more than a matter of simple press speculation, isn't that so? Mr.
    President, there was a question about whether you had testified fully, completely, and honestly
    on the preceding day in your deposition.

    A Well, actually, Mr. Bennett, I didn't think that then. I – this has been a rather unprecedented
    development, and I wasn't even thinking about the Independent Counsel getting into this. So, at
    that moment, I knew nothing about it and I was more interested in what the facts were and
    whether Ms. Currie knew anything about it, knew anything about what Monica Lewinsky
    knew about it.

    Q Mr. President, you've told us at least a little bit about your understanding of how the term
    sexual relations was used, and what you understood it to mean in the context of your
    deposition. Isn't that correct?

    A That is correct.

    Q And you've told us -- I mean, that was a lawsuit Paula Jonea filed in which she alleged that
    you asked her to perform oral sex, isn't that so?

    A That was her allegation.

    Q That was her allegation. And, notwithstanding that that was her allegation, you've testified
    that you understood the term sexual relations, in the context of the questions you were being
    asked, to mean something else, at least insofar as you were the recipient rather than the

    A Sir, Paula Jonea' lawyers pulled out that definition, not me. And Judge Susan Webber
    Wright ruled on it, just as she later ruled their case had no merit in the first place, no legal
    merit, and dismissed it.

    I had nothing to do with the definition. I had nothing to do with the Judge's rulings. I was
    simply there answering the questions they put to me, under the terms of reference they

    Q Well, the grand jury would like to know, Mr. President, why it is that you think that oral sex
    performed on you does not fall within the definition of sexual relations as used in your

    A Because that is -- if the deponent is the person who has oral sex performed on him, then the
    contact is with -- not with anything on that list, but with the lips of another person. It seems to
    be self-evident that that's what it is. And I thought it was curious.

    Let me remind you, sir, I read this carefully. And I thought about it. I thought about what
    'contact' meant. I thought about what "intent to arouse or gratify" meant.

    And I had to admit under this definition that I'd actually had sexual relations with Gennifer
    Flowers. Now, I would rather have taken a whipping than done that, after all the trouble I'd
    been through with Gennifer Flowers, and the money I knew that she had made for the story
    she told about this alleged 12-year affair, which we had done a great deal to disprove.

    So, I didn't like any of this. But I had done my best to deal with it and the -- that's what I
    thought. And I think that's what most people would think reading that.

    Q Would you have been prepared, if asked by the Jones lawyers, would you have been
    prepared to answer a question directly asked about oral sex performed on you by Monica

    A If the Judge had required me to answer it, of course, I would have answered it. And I would
    have answered it truthfully, if I --

    Q By the way, do you believe that the -

    A -- had been required.

    Q -- Jones litigants had the same understanding of sexual relations that you claim you have?

    A I don't know what understanding was, sir. My belief is that they thought they'd get this
    whole thing in, and that they were going to -- what they were trying to do is do just what they
    did with Gennifer Flowers. They wanted to find anything they could get from me or anyone
    else that was negative, and then they wanted to leak it to hurt me in the press, which they did
    even though the Judge ordered them not to.

    So, I think their -

    Q Wouldn't it -- I'm sorry.

    A I think their position, Mr. Bennett – you asked the question -- their position was, we're going
    to cast the widest net we can and get as much embarrassing stuff as we can, and then dump it
    out there and see if we can make him bleed. I think that's what they were trying to do.

    Q Don't you think, sir, that they could have done more damage to you politically, or in
    whatever context, if they had understood the definition in the same way you did and asked the
    question directly?

    A I don't know, air. As I said, I didn't work with their lawyers in preparing this case. I knew
    the case was wrong. I knew what our evidence was. By the time of this deposition, they knew
    what their evidence was.

    Their whole strategy was, well, our lawsuit's not good, but maybe we can hurt him with the
    discovery. And, you know, they did some. But it didn't amount to much.

    And did I want, if I could, to avoid talking about Monica Lewinsky? Yes, I'd give anything in
    the world not to be here talking about it. I'd be giving -- I'd give anything in the world not to
    have to admit what I've had to admit today.

    But if you look at my answer in the Flowers [sic] deposition, at least you know I tried to
    carefully fit all my answers within the framework there, because otherwise there was no reason
    in the wide world for me to do anything other than make the statements I'd made about
    Gennifer Flowers since 1991, that I did not have a 12-year affair with her, and that these, the
    following accusations she made are false.

    So, that's all I can tell you. I can't prove anything.

    Q But you did have a great deal of anxiety in the hours and days following the end of your
    deposition on the 17th. Isn't that fair to say?

    A Well, I had a little anxiety the next day, of course, because of the Drudge Report. And I had
    an anxiety after the deposition because it was more about Monica Lewinsky than it was about
    Paula Jones.

    Q The specificity of the questions relating to Monica Lewinsky alarmed you, isn't that fair to

    A Yes, and it bothered me, too, that I couldn't remember the answers. It bothered me that I
    couldn't -- as Mr. Wisenberg pointed out, it bothered me that I couldn't remember all the
    answers. I did the best I could. And so I wanted to know what the deal was. Sure.

    Q Mr. President, to your knowledge, have you turned over, in response to the grand jury
    subpoenea, all gifts that Monica Lewinsky gave you?

    A To my knowledge, I have, air. As you know, on occasion, Mr. Kendall has asked for your
    help in identifying those gifts. And I think there were a couple that we came across in our
    search that were not on the list you gave us, that I remembered in the course of our search had
    been given to me by Monica Lewinsky and we gave them to you.

    So, to the best of my knowledge, we have given you everything we have.

    Q Can you explain why, on the very day that Monica Lewinsky testified in the grand jury on
    August 6th of this year, you wore a necktie that she had given you?

    A No, sir, I don't believe I did. What necktie was it?

    Q The necktie you wore on August 6th, sir.

    A Well, I don't know that it was a necktie that Monica Lewinsky gave me. Can you describe it
    to me?

    Q Well, I don't want to take time at this point, but we will provide you with photographic
    evidence of that, Mr. President.

    A If you give me -- I don't believe that's accurate, Mr. Bennett.

    Q So, let me ask the question --

    A But if you give it to me, and I look at it and I remember that she gave it to me, I'll be happy
    to produce it. I do not believe that's right.

    Q Well, if you remember that she gave it to you, why haven't you produced it to the grand

    A I don't remember that she gave it to me. That's why I asked you what the tie was. I have -

    Q Can you --

    A -- no earthly idea. I believe that, that I did not wear a tie she gave me on August the 6th.

    Q Can you tell us why Bayani Nelvis wore a tie that Monica Lewinsky had given you on the
    day he appeared in the grand jury?

    A I don't know that he did.

    Q Have you given Bayani Nelvis any ties, sir?

    Oh, yes, a lot of ties.

    Q And so if he wore the tie that you gave him, that Monica Lewinsky had given you, that
    would not have been by design, is that what you are telling us?

    A Oh, absolutely not. Let me -

    Q You are not -

    A May I explain, Mr. Bennett? It won't -

    Q Yes.

    A-- take long. Every year, since I've been President, I've gotten quite a large number of ties, as
    you might imagine. I get, I have a couple of friends, one in Chicago and one in Florida who
    give me a lot of ties, a lot of other people who send me ties all the time, or give them to me
    when I see them.

    So, I always have the growing number of ties in my closet. What I normally do, if someone
    gives me a tie as a gift, is I wear it a time or two. I may use it. But at the end of every year,
    and sometimes two times a year, sometimes more, I go through my tie closet and I think of all
    the things that I won't wear a lot or that I might give away, and I give them mostly to the men
    who work there.

    I give them to people like Glen and Nelvis, who work in the kitchen, back in the White House,
    or the gentlemen who are my stewards or the butlers, or the people who run the elevators. And
    I give a lot of ties away a year. I'll bet I -- excluding Christmas, I bet I give 30, 40, maybe
    more ties away a year, and then, of course, at Christmas, a lot.

    So, there would be nothing unusual if, in fact, Nelvis had a tie that originally had come into my
    tie closet from Monica Lewinsky. It wouldn't be unusual. It wouldn't be by design. And there
    are several other people of whom that is also true.

    Q Mr. President, I'd like to move to a different area right now. I'd like to ask you some
    questions about Kathleen Willey. You met Kathleen Willey during your 1992 campaign, isn't
    that so?

    A Yes, sir, I did.

    Q As a matter of fact, you first saw her at a rope line at the Richmond, Virginia airport on
    October 13, 1992, . is that not correct?

    A I don't believe that is correct.

    Q When did you first meet her, sir?

    A Well, let me ask you this. When was the debate in Richmond?

    Q I believe it wee October 13, 1992, sir.

    A Well, I believe that I had met her -- I believe I had met her before then, because Governor
    Wilder, I believe that was his last year as governor -- I think that's right, 92-93. I believe that I
    met her in connection with her involvement with Governor Wilder.

    And I have the impression -- it's kind of a vague memory, but I have the impression that I had
    met her once before, at least once before I came to that Richmond debate. Now, I'm not sure
    of that.

    Q Well, at least if you have met her before --

    A But I am quite sure she was at the Richmond debate and I did meet her there. I'm quite sure
    of that.

    Q Mr. President, you've seen television footage of you standing on a rope line with Donald
    Beyer, Lt. Governor Donald Beyer -

    A I have.

    Q -- asking Mr. Beyer for the name of Kathleen Willey? You've seen that footage, haven't

    A I don't know that I've seen it, but I am aware that it exists.

    Q All right. And you can see him, you can read his lips. He's saying the name Kathleen Willey
    in response to a question from you, isn't that so?

    A That's what I've heard.

    Q And, as a matter of fact, you sent Nancy Hernreich, who was present on that day, to go get
    her telephone number, didn't you, sir?

    A I don't believe so.

    Q You don't believe so?

    A Well, let me say this. If that is true, then I'm quite certain that I had met her before. I would
    never call someone out of the blue that I saw on a rope line and send Nancy Hernreich to get
    her number to do it.

    Q Even if you were just learning her name for the first time?

    A That's correct. I'm not so sure that I didn't ask Don Beyer, if he was on the rope line with
    me, who she was because I thought I had seen her before or I knew I had seen her before and
    I didn't remember her name. Now, I do that all the time. For men -

    Q Mr. President --

    A -- and women.

    Q I'm sorry. Do you recall that you sent Nancy Hernreich for her telephone number?

    A No, I don't.

    Q All right. Do you recall, having received her telephone number, calling her that night?

    A No, sir, I don't.

    Q Do you recall inviting her to meet with you at your hotel that night?

    A No, sir, I do not.

    Q Do you recall where you stayed in Richmond, Virginia during the debates you've told us

    A Well, I stayed at some hotel there, I believe.

    Q Actually, did you stay at the Williamsburg Inn, not in Richmond?

    A Yeah, that's right. We prepared in Williamsburg. That' a correct. I believe we prepared in
    Williamsburg and then went to Richmond for the debate, and then I think we spent the night in
    Richmond. And the next day, I think we had a rally before we left town. I believe that's right.

    Q Do you know of any reason Kathleen Willey's telephone number would appear on your toll
    records from your room in Williamsburg?

    A No, there - -

    Q If you didn't call her?

    A No, I'm not denying that I called her, sir. You asked me a specific question. I won't deny
    that I called her. I don't know whether I did or not.

    Q As a matter of fact, you called her twice that day, didn't you, sir?

    A I don't recall. I may well have done it and I don't know why I did it.

    Q Well, does it refresh your recollection that you called her and invited her to come to your
    room that night?

    A I don't believe I did that, sir.

    Q If Kathleen Willey has said that, she's mistaken or lying, is that correct, Mr. President?

    A I do not believe I did that. That's correct.

    Q But what is your best recollection of that conversation, those conversations7

    A I don't remember talking to her. But I -- it seems to me that at some point -- this is why I
    believe I had met her before, too. But at some point I had some actual person-to-person
    conversation with her about my sore throat, or what she thought would be good for it, or
    something like that. I have some vague memory of that. That's it.

    Q Is this the chicken soup conversation, Mr. President?

    A Well, I don't know if I would -- maybe that's what she said I should have. I don't remember.
    But I have no recollection, sir, of asking her to come to my room. I -and I -- I'm sorry, I don't.
    I can't -- I won't deny calling her. I don't know if I did call her. I don't know if she tried to call
    me first. I don't know anything about that. I, I just -- I met her and Doug Wilder. I remember
    that she

    and her husband were active for Governor Wilder, and that's about all I remember, except that
    I had a conversation with her around the Richmond debate. I do remember talking to her there.

    Q Mr. President, let's move ahead to the episode on November 29, 1993, in which Mrs. Willey
    met you in your office at the Oval, the subject matter of the '60 Minutes' broadcast a few
    months ago. You recall that episode?

    A I certainly do.

    Q Mr. President, in fact, on that date you did make sexual advances on Kathleen Willey, is that
    not correct?

    A That's false.

    Q You did grab her breast, as she said?

    A I did not.

    Q You did place your hand on her groin area, as she said?

    A No, I didn't.

    Q And you placed her hand on your genitals, did you not?

    A Mr. Bennett, I didn't do any of that, and the questions you're asking, I think, betray the bias
    of this operation that has troubled me for a long time. You know what evidence was released
    after the '60 Minutes' broadcast that I think pretty well shattered Kathleen Willey's credibility.
    You know what people down in Richmond said about her. You know what she said about
    other people that wasn't true. I don't know if you've made all of this available to the grand jury
    or not.

    She was not telling the truth. She asked for the appointment with me. She asked for it

    Q Did she make a sexual advance on you, Mr. President7

    A On that day, no, she did not. She was troubled.

    Q On some other day?

    A I wouldn't call it a sexual advance. She was always very friendly. But I never took it

    Q Mr. President, you mentioned the documents that were released and information that came
    out from people in Richmond, et cetera, after the '60 Minutes' piece was broadcast. As a
    matter of fact, you were required, under the Court's rulings, to produce those documents in
    response to document requests by the Jones litigants, isn't that correct?

    A No. I believe the Jones litigants' request for production of documents to me ran to
    documents that were in my personal files and in my personal possessions, and did not cover
    documents that were White House files. So, I don't believe we were required to produce them.

    As a matter of fact, when that story first ran, sir, before '60 Minutes', back in July or so of '97,
    I was aware that we had some letters. I didn't -- I didn't remember that she'd written to us as
    much as she had and called as much as she had, and asked to see me as often as

    she had, after this alleged incident. I didn't know the volume of contact that she had which
    undermined the story she has told. But I knew there was some of it. And I made a decision
    that I did not want to release it voluntarily after the Newsweek ran the story, because her
    friend Julie Steele was in the story saying she asked her -- she, Kathleen Willey -- asked her to
    lie. And because, frankly, her husband had committed suicide. She apparently was out of
    money. And I thought, who knows how anybody would react under that. So, I didn't. But,
    now when '60 Minutes' came with the story and everybody blew it up, I thought we would
    release it. But I do not believe we were required to release White House documents to the
    Jones lawyers.

    Q Mr. President, have you made a decision on whether to stay beyond the four hours we
    agreed to, to accept questions from the grand jury?

    MR. KENDALL: We have made an agreement, Mr. Bennett, to give you four hours. We're
    going to do that. By my watch, there are about 12 minutes left.

    MR. BENNETT: I guess that's no. Is that correct, Mr. Kendall?

    MR. KENDALL: Yes, that's correct.

    THE WITNESS: May I ask this question? Could I have a two-minute break?

    MR. BENNETT: Sure.

    THE WITNESS: I'm sorry to bother you with this. I know we're getting to the end, but I need
    a little break.

    (Whereupon, the proceedings were recessed from 6:04 p.m. until 6:09 p.m.)


    Q Mr. President, at various times in this investigation, officials have invoked executive privilege
    in response to questions that have been posed to them by the grand jury and in the grand jury.
    One of the grand jurors has posed the question, did you personally authorize the invocation of
    executive privilege?

    A If the answer is authorized, I think the answer to that would be yes. But I would like the
    grand jury to know something. In the cases where we raised the lawyer/client privilege, or
    executive privilege, or where the Secret Service raised their privilege, and when I say -- I had
    nothing to do with that. I did not authorize it, approve it, or anything else. That was something
    they asked to be free to make their decision on by themselves. In none of those cases did I
    actually have any worry about what the people involved would say. The reason those privileges
    were advanced and litigated was that I believed that there was an honest difference between
    Judge Starr and the Office of Independent Counsel, and Mr. Ruff, my counsel, and I about
    what the proper balance was in the Constitutional framework. And I did not want to put the
    Presidency at risk of being weakened as an institution without having those matters litigated.
    Now, we've lost some of those matters. Our people have testified and the grand jury is free to
    conclude whether they believe that the testimony they gave wes damaging to me. But I don't, I
    don't imagine it was and I wasn't worried about it. It was an honest difference of Constitutional
    principle between Judge Starr and the Office of Independent Counsel and the White House.

    Q Mr. President, a couple of very brief questions, given our time. The White House's outside
    counsel, Mr. Eggleston, withdrew the White House's appeal from Chief Judge Johnson's ruling
    that the invocation of executive privilege had to give way to the grand jury's right to the
    information, that ruling in connection with the testimony of Mr. Blumenthal and Mr. Lindsey.

    Were you informed of that fact that the appeal had been withdrawn?

    A I was informed of it and, as a matter of fact, I was consulted about it and I strongly
    supported it. I didn't want to appeal it.

    Q Okay.

    A It was -- I had -- my main difference, Judge Starr, as you know with you, is, and with some
    of the Court decisions, is on the extent to which members of the White House Counsel's staff,
    like Mr. Lindsey, should be able to counsel the President on matters that may seem like they
    are private, like the Jones case, but inevitably intrude on the daily work of the President. But I
    didn't really want to advance an executive privilege claim in this case beyond having it litigated,
    so that we, we had not given up on principle this matter, without having some judge rule on it.
    So, I made -

    Q Excuse me. And you are satisfied that you now have the benefit of that ruling, is that

    A Well, yes. I just didn't want to, I didn't want to -- yes. And I didn't -- I made the -- I
    actually, I think, made the call, or at least I supported the call. I did not, I strongly felt we
    should not appeal your victory on the executive privilege issue.

    MR. STARR: Thank you.


    Q Mr. President, among the many remaining questions of the grand jurors is one that they
    would like answered directly without relation to, without regard to inferences, which is the
    following: Did Monica Lewinsky perform oral sex on you? They would like a direct answer to
    that, yes or no?

    A Well, that's not the first time that question's been asked. But since I believe, and I think any
    person, reasonable person would believe that that is not covered in the definition of sexual
    relations I wee given, I'm not going to answer, except to refer to my statement. I had intimate
    contact with her that was inappropriate. I do not believe any of the contacts I had with her
    violated the definition I was given. Therefore, I believe I did not do anything but testify
    truthfully on these matters.

    Q We have a couple of photos of the tie that you wore.

    A Would you please give them to me?

    Q Yes.

    A Now, this is August 6th, is that correct?

    Q 1998, the day that Monica Lewinsky appeared at the grand jury. And my question to you on
    that is, were you sending some kind of a signal to her by wearing -

    A No, sir.

    Q -- one of the ties – let me finish, if you don't mind, sir.

    A Sure. I'm sorry. My apology.

    Q Were you sending some kind of a signal to her by wearing a tie she had given you on the
    day that she appeared in front of the grand jury?

    A No, sir. I don't believe she gave me this tie. And if I was sending a signal, I'm about to send
    a terrible signal, and maybe you ought to invite her to talk again. I don't, I don't want to make
    light about this. I don't believe she gave me this tie. I don't remember giving, her giving me this
    tie. And I had absolutely no thought of this in my mind when I wore it. If she did, I, I, I, I
    don't remember it, and this is the very first I've ever heard of it.

    Q Did you realize when you --

    MR. WISENBERG: Can I just have for the record, what are the exhibit numbers?

    MS. WIRTH: Yes. They should be WJC-5 and 6.

    (Grand Jury Exhibits WJC-5 and WJC-6 were marked for identification.)

    MR. WISENBERG: Mr. Bennett has some more questions.


    Q Mr. President, we were talking about your responses to document requests in the Jones
    litigation, and I had just asked you about turning over the Kathleen Willey correspondence. Do
    you recall that?

    A Yes, sir, I do.

    Q And, if I understand your testimony, you did not believe that the request for documents
    compelled you to search for those documents in the White House?

    A Mr. Bennett, I want to answer this question in way that is completely satisfactory to you and
    the grand jury, without violating the lawyer/client privilege, which is still intact. It was my
    understanding that in the request for production of documents, that those requests ran against
    and operated against my personal files. Now, I have some personal files in the White House.
    And, I'm sorry. In this case I'm not my own lawyer, and I don't know how the distinction is
    made between files which are the personal files of the President, and files which are White
    House files. But I do have a very clear memory that we were duty-bound to search and turn
    over evidence or, excuse me, documents that were in my personal file, but not in the White
    House files. And I believe that the letters to which you refer, Ms. Willey's letters and Ms.
    Willey's phone messages, were in the White House files. And, therefore, I was instructed at
    least that they were, that we had fully compiled with the Jones lawyers' request, and that these
    documents were outside the request.

    Q Mr. President, you're not contending that White House documents, documents stored in the
    fashion that these were stored, are beyond your care, custody or control, are you?

    A Mr. Bennett, that may be a legal term of art that don't have the capacity to answer. I can
    only tell you what I remember. I remember being told in no uncertain terms that if these were
    personal files of the President, we had to produce documents. If they were essentially White
    House files, we were not bound to do so. So, we didn't.

    Q So, you are saying somebody told you that you didn't have to produce White House

    A That's --

    MR. KENDALL: I'm going to caution the witness that this question should not invade the
    sphere of the attorney/client privilege, and any conversations with counsel are privileged.

    THE WITNESS: Let me say, and maybe, Mr. Kendall, we need a break here. I'm not trying --
    I'm trying to avoid invading the lawyer/client privilege. I can just tell you that I did, I did the
    best I could to comply with this. And eventually we did make, of course, all of this public. And
    it was damaging to Ms. Willey and her credibility. It was terribly damaging to her. And the first
    time she came out with this story, I didn't do it. I only did it when they went back on "60
    Minutes'' and they made this big deal of it. It turned out she had tried to sell this story and
    make all this money. And, I must say, when I saw how many letters and phone calls and
    messages there were that totally undercut her account, I, myself, was surprised.

    BY MR. BENNETT: But you knew there were letters?

    A I did, sir.

    Q And the White House –

    A I knew that -

    Q -- is under your control, isn't it, Mr. President?

    A Well, Mr. Bennett, again, I'm not trying to be - I think it's under my control and some days
    I'm not so sure. But, if you're asking me, as a matter of law, I don't want to discuss that
    because that's -- I mean, I'll be glad to discuss it, but I'm not the person who should make that
    decision. That decision should be made by someone who can give me appropriate advice, and I
    don't want to violate the lawyer/client privilege here.

    Q Well, Mr. President, how are the letters from Kathleen Willey that surfaced after the "60
    Minutes" episode aired any different from the correspondence and other matters, tangible
    items, tangible things, of Monica Lewinsky?

    A Well, the items you asked for from Monica Lewinsky that I produced to you, you know that
    there was a tie, a coffee cup, a number of other things I had. Then I told you there were some
    things that had been in my possession that I no longer had, I believe. I don't remember if I did
    that. There was one book, I remember, that I left on vacation last summer.

    Q The same documents that the Jones litigants had asked you for?

    A Yes. But at any rate, they were different. They were in my – the gifts were in my personal
    possession, clearly.

    Q In your office at the Oval?

    A Well, in the books, now, the Presidential books were with my other books that belong to me
    personally. They were in the Oval.

    Q Where do you draw the line, sir, between personal and White House? Now, you are talking
    about some documents that are in the Oval Office and we don't see where you are drawing the

    A Well, Mr. Bennett, I don't think these – I think the Lewinsky gifts were all non-documents.
    And you can –

    MR. KENDALL: Is that the time?

    THE WITNESS: Just a moment.

    MR. KENDALL: Excuse me, Mr. Bennett.

    THE WITNESS: Well, I'd like to –

    MR. KENDALL: You've got thirty more seconds.

    THE WITNESS: -- finish answering the question, please, because this is a legitimate question,
    I think. There is somebody in the White House, Mr. Bennett who can answer your question,
    and you could call them up and they could answer it, under oath, for you. There is some way
    of desegregating what papers are personal to the President and what papers are part of the
    White House official archives papers. And I don't know how the distinction is made. I just
    don't know.


    Q Did you direct personnel, Nancy Hernreich or anyone else, to make a search for
    correspondence from Kathleen Willey and Monica Lewinsky when those documents were
    called for in the Jones litigation, sir? Did you direct that somebody on the White House staff
    look for those documents?

    A I don't believe that I was in charge of doing that, the document search, sir. So, the strict
    answer to that question is that I didn't.

    Q So, you sat back and relied on this legalistic distinction between your personal, which you
    are in control l of, and the White House which, by the way, you are also in control of; is that
    not correct?

    MR. KENDALL: I won't object to the argumentative form of the question. We'll allow the
    witness to answer it. We're now over time, even the 30 seconds. So, this will be it.

    THE WITNESS: Mr. Bennett, I haven't said this all day long, but I would like to say it now.
    Most of my time and energy in the last five and a half years have been devoted to my job.
    Now, during that five and a half years, I have also had to contend with things no previous
    President has ever had to contend with: a lawsuit that was dismissed for lack of legal merit, but
    that cost me a fortune and was designed to embarrass me; this independent counsel inquiry,
    which has gone on a very long time and cost a great deal of money, and about which serious
    questions have been raised; and a number of other things. And, during this whole time, I have
    tried as best I could to keep my mind on the job the American people gave me. I did not make
    the legal judgment about how the documents were decided upon that should be given to the
    Jones lawyers, and ones that shouldn't. And, I might add that Ms. Willey would have been
    very happy that these papers were not turned over, because they damaged her credibility so
    much, had they not ultimately been turned over after she made, I think, the grievous error of
    going on '60 Minutes' and saying all those things that were not true. But I did not make the
    decision. It was not my job. This thing is being managed by other people. I was trying to do
    my job.


    Q Mr. President, the grand jury, I am notified, still has unanswered questions of you, and we
    appeal to you again to make yourself available to answer those questions.

    MR. KENDALL: Mr. Bennett, our agreement was for four hours and we have not counted
    the break time against that, and I think that will be -

    THE WITNESS: You know, Mr. Bennett, I wish I could do it. I wish the grand jurors had
    been allowed to come here today as we invited them to do. I wanted them down here. I
    wanted them to be able to see me directly. I wanted them to l be able to ask these questions
    directly. But, we made an agreement that was different, and I think I will go ahead and stick
    with the terms of it.


    Q The invitation was made after there was political fallout over the deposition circumstances
    with the satellite transmission and the taping. Isn't that so?

    A I don't know about the taping, Mr. Bennett. I understood that the prospect of the grand
    jurors coming down here was raised fairly early. I don't know.

    Q Just for the record --

    A But, anyway, I wish they could have. I respect the grand jury. I respect the –

    MR. WISENBERG: Just for the record, the invitation to the grand jury was contingent upon
    us not videotaping, and we had to videotape because we have an absent grand juror.

    MR. KENDALL: Is that the only reason, Mr. Wisenberg, you have to videotape?

    THE WITNESS: Well, yes. Do you want to answer that?

    MR. BITTMAN: Thank you, Mr. President.

    (Whereupon, at 6:25 p.m., the proceedings were concluded.)

                                * * * * *


    I, Elizabeth A. Eastman, the officer before whom the foregoing proceedings were taken, do
    hereby certify that the witness whose testimony appears in the foregoing was duly sworn by
    me; that the testimony of said witness was taken by me electronically and thereafter reduced to
    typewriting by me; that this is a true record of the testimony given by said witness; that I am
    neither counsel for, related to, nor employed by any of the parties to the action in which this
    deposition was taken; and, further, that I am not a relative or employee of any attorney or
    counsel employed by the parties hereto, nor financially or otherwise interested in the outcome
    of the action.


    My Commission Expires:
    July 31, 2000

    Deposition Concluded