[Congressional Record (Bound Edition), Volume 145 (1999), Part 2]
[Senate]
[Pages 1817-1874]
[From the U.S. Government Publishing Office, www.gpo.gov]

                                 prayer

  The Chaplain, Dr. Lloyd John Ogilvie, offered the following prayer:
  Gracious God, these days here in the Senate are filled with crucial 
issues, differences on solutions, and eventually a vital vote in the 
impeachment trial. We begin this day's session with the question You 
asked King Solomon, ``Ask! What shall I give You?'' We empathize with 
Solomon's response. He asked for an ``understanding heart.'' We are 
moved by the more precise translation of the Hebrew words for 
``understanding heart,'' meaning ``a hearing heart.''
  Solomon wanted to hear a word from You, Lord, for the perplexities he 
faced. He longed for the gift of wisdom so he could have answers and 
direction for his people. We are moved by Your response, ``See, I have 
given you a wise and listening heart.''
  I pray for nothing less as Your answer for the women and men of this 
Senate. Help them to listen to Your guidance and grant them wisdom for 
their decisions. All through our history as a Nation, You have made 
good men and women great when they humbled themselves, confessed their 
need for Your wisdom, and listened intently to You. Speak Lord; we need 
to hear Your voice. We are listening. Amen.
  The CHIEF JUSTICE. The Senators will be seated. The Sergeant at Arms 
will make the proclamation.
  The Sergeant at Arms, James W. Ziglar, made proclamation as follows:

       Hear ye! Hear ye! Hear ye! All persons are commanded to 
     keep silent, on pain of imprisonment, while the Senate of the 
     United States is sitting for the trial of the articles of 
     impeachment exhibited by the House of Representatives against 
     William Jefferson Clinton, President of the United States.


                              The Journal

  The CHIEF JUSTICE. If there is no objection, the Journal of 
proceedings of the trial are approved to date.
  The majority leader is recognized.
  Mr. LOTT. Thank you, Mr. Chief Justice.


                           Order of Procedure

  Mr. LOTT. Mr. Chief Justice, if I could take just a moment to outline 
how the proceedings will go this afternoon, I think that would answer 
any questions that Senators may have. We will, of course, continue with 
the consideration of articles of impeachment. I am not aware of any 
objections made during the depositions which require motions to 
resolve. Therefore, I believe the House managers are prepared to go 
forward with a motion that would have three parts. The first would 
allow for the introduction of the depositions into evidence. The second 
would call Monica Lewinsky as a witness. And the third part would allow 
for a presentation period by the parties for not to extend beyond 6 
hours. This motion would be debated by the House managers and the White 
House counsel for not to exceed 2 hours.
  In addition, it is my understanding that Senator Daschle intends to 
offer a motion that would provide for going directly to the articles of 
impeachment for a vote.
  Mr. DASCHLE. Mr. Chief Justice, will the majority leader yield?
  Mr. LOTT. I am glad to yield to the minority leader, Senator Daschle.
  Mr. DASCHLE. The motion would allow for closing arguments, final 
deliberations, and then the motions on the two articles.
  Mr. LOTT. Having said that, Mr. Chief Justice, in order for the 
managers to prepare debate for the motions, I ask unanimous consent 
that the House managers and the White House counsel be allowed to make 
reference to oral depositions during this debate on pending motions.
  The CHIEF JUSTICE. Is there any objection? In the absence of 
objection, it is so ordered.
  Mr. LOTT. Consequently, four votes, then, would occur in the 4 p.m. 
timeframe today with respect to these four motions.
  We will take at least one break--maybe two--between now and then, and 
that would determine exactly when that series of votes would occur--
once we begin the process of offering and debating the motions. And we 
will make a determination as to exactly when those provisions would 
occur.
  In addition, if the motion for additional presentation time is agreed 
to by the Senate, it would be my intention to adjourn the trial after 
today's deliberations over until Saturday for the parties to make their 
preparations, then to present their presentations of evidence on 
Saturday, and the trial would then resume on Monday at 12 noon for the 
closing arguments of the parties.
  Again, I remind all of my colleagues to please remain standing at 
their desks when the Chief Justice enters the Chamber and leaves the 
Chamber.
  I thank my colleagues for their attention. I believe we are ready to 
proceed, Mr. Chief Justice.
  The CHIEF JUSTICE. The Chair recognizes Mr. Manager McCollum.


    Motion for Admission of Evidence, Appearance of Witnesses, and 
                        Presentation of Evidence

  Mr. Manager McCOLLUM. Mr. Chief Justice, I have a motion to deliver 
to the Senate.
  The CHIEF JUSTICE. The clerk will read the motion:
  The legislative clerk read as follows:

Motion of the United States House of Representatives for the Admission 
   of Evidence, the Appearance of Witnesses, and the Presentation of 
                                Evidence

       Now comes the United States House of Representatives, by 
     and through its duly authorized Managers, and respectfully 
     submits to the United States Senate its motion for the 
     admission of evidence, the appearance of witnesses, and the 
     presentation of evidence in connection with the Impeachment 
     Trial of William Jefferson Clinton, President of the United 
     States.
       The House moves that the transcriptions and videotapes of 
     the oral depositions taken pursuant to S. Res. 30, from the 
     point that each witness is sworn to testify under oath to the 
     end of any direct response to the last question posed by a 
     party, be admitted into evidence.
       The House further moves that the Senate authorize and issue 
     a subpoena for the appearance of Monica S. Lewinsky before 
     the Senate for a period of time not to exceed eight hours, 
     and in connection with the examination of that witness, the 
     House requests that either party be able to examine the 
     witness as if that witness were declared adverse, that 
     counsel for the President and counsel for the House Managers 
     be able to participate in the examination of that witness, 
     and that the House be entitled to reserve a portion of its 
     examination time to reexamine the witness following any 
     examination by the President.
       The House further moves that the parties be permitted to 
     present before the Senate, for a period of time not to exceed 
     a total of six hours, equally divided, all or portions of the 
     parts of the videotapes of the oral depositions of Monica S. 
     Lewinsky, Vernon E. Jordan, Jr., and Sidney Blumenthal 
     admitted into evidence, and that the House be entitled to 
     reserve a portion of its presentation time.

  Mr. LOTT addressed the Chair.
  The CHIEF JUSTICE. The Chair recognizes the majority leader.
  Mr. LOTT. I understand that the pending motion is divisible, and as 
is my right, I ask that the motion be divided in the following manner: 
The first paragraph be considered division I; the second paragraph be 
considered division II; and the final paragraph be considered division 
III.
  The CHIEF JUSTICE. It will be divided in the manner indicated by the 
majority leader.

[[Page 1818]]


  Mr. LOTT. I thank the Chair.
  Mr. DASCHLE. Mr. President, I suggest the absence of a quorum.
  The PRESIDING OFFICER. The clerk will call the roll.
  The legislative clerk proceeded to call the roll.
  Mr. LOTT. Mr. President, I ask unanimous consent that the order for 
the quorum call be rescinded.
  The CHIEF JUSTICE. Is there any objection? In the absence of 
objection, it is so ordered.
  Mr. LOTT. Mr. Chief Justice, I identified this as the first paragraph 
to be considered division I. Actually, that should be the second 
paragraph would be division I, the third paragraph division II, and the 
fourth paragraph would be division III. I want that clarification.
  The CHIEF JUSTICE. That will be the order.
  Mr. LOTT. Also, so that both sides will understand, the motion--there 
is one motion, but we have divided it into three parts so there will 
only be 2 hours equally divided, one on each side; not 2 hours equally 
divided on each one of the three divisions. We had one clarification I 
believe we have cleared up, and I believe now we are ready to hear from 
the managers, Mr. Chief Justice.
  The CHIEF JUSTICE. Very well. The Chair recognizes Mr. Manager 
McCollum.
  Mr. Manager McCOLLUM. Thank you, Mr. Chief Justice.
  As the first one up here today, I have to fiddle with the microphone, 
I guess; it is sort of like testing. I apologize.
  Mr. Chief Justice and Members of the Senate, what we have presented 
to you today is a three-part motion, as Mr. Lott has described it, and 
as you have heard read to you. We would like very much, as we always 
have, to have all the witnesses we want presented here live, as we 
would normally have in a trial, as the House has always believed that 
it should have.
  We came before you a few days ago recognizing the reality of that and 
went forward with your procedures to request not 5, not 6, not 12, but 
3 witnesses be deposed so that we might be able to, in the discovery 
process you have allowed us, gain the depositions of those three 
witnesses. Today we are before you with motions, first, to enter those 
depositions and the video recordings of those depositions into evidence 
formally for your consideration because they have now been 
accomplished; secondly, to request that you provide us with the 
opportunity to examine Monica Lewinsky live here as a witness on the 
floor of the Senate, and for you to allow us to present the other two 
depositions to you in some format; and, if you do not allow us the 
permission to have Ms. Lewinsky live here to examine as a witness, to 
allow us to present any or all portions of the depositions of all three 
of them.
  Now, I think that it is eminently fair that we be allowed to present 
at least one witness live to you, the central witness in the cast of 
this entire proceeding, and that is Monica Lewinsky. I am not here to 
argue all of that. My principal discussion with you is going to be on 
the part dealing with just admitting these into evidence, and then my 
colleagues, Mr. Bryant, Mr. Hutchinson, and Mr. Rogan are going to 
present some complementary discussion about the entire motion as we go 
through this.
  But in the context of all of this I think we have to recognize a 
couple of things. One is that live witnesses are preferable whether you 
have depositions or not. These were discovery depositions. We would 
have liked to have asked for all of them to be live. We were 
recognizing reality by coming down to one today, and the reasons are 
fairly straightforward. Some of you have had the privilege, and I am 
sure you have availed yourself of the opportunity, to look at the 
videotapes of these depositions, and you see that they are, indeed, 
what most depositions are. They are discovery. They have long pauses in 
them. They are not at all like it would be in a trial itself; you don't 
have the opportunity to fully see or explore with the witness the 
demeanor, the temperament, the spontaneity, all of those things that 
you normally get with an exchange. You have the camera simply focused 
on the witness. You don't get to have the interaction you get in a 
courtroom.
  And remember, again, that we are dealing here first with your 
determining whether or not the President committed the crimes of 
perjury and obstruction of justice and then the question of whether or 
not he should be removed from office. So I believe and we believe as 
House managers that you should at least let us have Monica Lewinsky 
here live for both of those reasons.
  I also want to make comments specifically about just admitting these 
into evidence. There are two obvious reasons why, beyond the question 
of whether a witness should appear live or whether we should use 
portions of them in whatever fashion to present to you, they certainly 
should be part of the record. It seems self-evident. It is part of what 
you gave us as the procedure to do, and it would seem to me that it 
should be a mere formality for me to ask, but I cannot assume 
anything--we certainly do not--that we let these depositions into 
evidence, and there are two reasons why.
  One is the historical basis for this. There has to be a record, not 
only for you but for the public and for history, of the entire 
proceeding. There is evidence in these depositions that needs to be a 
part of the official record, and that evidence is not just the cold 
transcript, but it is also the videotape with all of the limited, 
albeit not satisfactory, portion of it that you can see and observe. 
Especially if you were to conclude we weren't going to have any live 
witness here or were not going to allow us to present these 
depositions, you certainly should allow the depositions to be part of 
the record and the videotape part of it. It is evidence. It is to be 
examined. It seems self-evident.
  But the second point is, as you are going to hear more from my 
colleagues in just a moment, there is new evidence in these 
depositions. There is new factual record information that needs to be 
here for you to decide the guilt or innocence question of the perjury 
and obstruction of justice charge.
  One illustration I would give you--and I am sure my colleagues will 
give you plenty more--one of them deals with the gift question. We have 
talked about it a lot out here. If you recall with regard to the 
question of the gifts, the issue is did the President obstruct justice? 
Did he decide in the Jones case, in the Jones Court, as a part of his 
course of conduct of trying to keep from the Court the nature of his 
relationship with Monica Lewinsky to keep the gifts hidden?
  There is new information in the deposition relative to what happened 
on the day those gifts were supposedly exchanged between Monica 
Lewinsky and Betty Currie, about the telephone call. Again, I am not 
going into the details of that. I will leave that for my colleagues who 
took the depositions. They can tell you about it. The point is you 
could enumerate--and they will--new evidence. There is significant 
relevant new evidence from the Vernon Jordan deposition and from the 
Sidney Blumenthal deposition. So just on the record alone, just to put 
the depositions into the record, there can be nothing complete about 
this trial if we don't at least do that. At least do that.
  And so with that in mind, having said that and urging you to do that, 
I will yield to Mr. Manager Bryant at this point in time.
  The CHIEF JUSTICE. The Chair recognizes Mr. Manager Bryant.
  Mr. Manager BRYANT. Mr. Chief Justice, distinguished colleagues and 
Senators, I would encourage each of you to consider calling Monica 
Lewinsky as the one live witness in this proceeding. Ms. Lewinsky 
continues to be, in her own way, an impressive witness. As I spoke to 
you earlier, she does have a story to tell. After all, no one knows 
more about the majority of the allegations against the President other 
than, of course, the President himself.
  At her deposition, she appeared to be a different Monica Lewinsky 
than the Monica Lewinsky whom I had met a week earlier. Unlike before, 
she was not open to discussion or fully responsive to fair inquiry. She 
didn't volunteer her story. She didn't tell her

[[Page 1819]]

story. Rather, she was very guarded in each response and almost 
protective. Her words were carefully chosen and relatively few. At 
times, the concepts that she discussed had the familiar ring of another 
key witness to these proceedings, such as ``it wasn't a lie'' or 
``wasn't false,'' it was ``misleading or incomplete.'' ``Truth is what 
one believes it is and may be different for different people.'' ``Truth 
depends on the circumstances.''
  As we progressed through her deposition Monday, I felt more and more 
like one of the characters in the classic movie ``Witness For The 
Prosecution.'' I was Charles Laughton. Ms. Lewinsky was Marlene 
Dietrich. And the President was Tyrone Power. If you are familiar with 
this movie, you will understand, and if you aren't, you should see the 
movie.
  However, there was and there still remains truth in her testimony. 
Sometimes, though, just like the President, and now Ms. Lewinsky, it is 
the literal truth only, the most restricted and stretched definition 
one could reach. And we all know that the law frowns upon manipulations 
such as this to avoid telling the complete truth. Her testimony is 
clearly tinted, some might even say tainted, by a mixture of her 
continued admiration for the President, her desire to protect him, and 
her own personal views of right and wrong.
  And she was well represented in the deposition by some of 
Washington's finest defense attorneys who had thoroughly prepared her 
for all questions, as they should have, as well as being present 
throughout the deposition to assist her. In fact, the Senator in charge 
of this particular deposition had to warn these counsel not to coach 
and not to whisper to her while she was attempting to answer the 
questions.
  If you have seen this deposition, you have witnessed an effective 
effort by a loyal supporter of the President to provide the very 
minimum of truth in order to be consistent with her own grand jury 
testimony, which is legally necessary for her to fulfill the terms of 
her immunity agreement.
  On the perjury article of impeachment, she reaffirmed the specific 
facts which happened between her and the President on more than one 
occasion, including November 15, 1995, their first encounter, when the 
President's conduct fit squarely within the four corners of the term 
``sexual relationship'' as defined in the Jones lawsuit, and this is in 
opposition to the President's own sworn testimony of denial. But this 
is one of the clearest examples of the President's guilt of this charge 
of perjury. It is not about this twisted definition the President 
assigned to the term ``sexual relations.'' Rather, it is his word 
against her word as to whether this specific conduct occurred. Even 
under his own reading of this definition, he agrees that that specific 
conduct, if it occurred, would make him guilty of sexual relations 
within that definition. But he simply says I did not do that; she says 
you did do that--a ``he said/she said'' case.
  But this is why it is important for you to be able to see Ms. 
Lewinsky in person. In the deposition you will observe her as having to 
affirm her prior testimony. She had to affirm her prior testimony 
because that was what was in the grand jury, and because of this, she 
could not back away at all on her testimony. She couldn't bend it here 
or there, she couldn't shade it in the President's favor. So what you 
have is a person, who you may well conclude is still wanting to help 
the President, having to admit to testimony that would do damage to the 
President, a very difficult situation for her. But, yet, this same 
difficulty lends this portion of her testimony great credibility.
  With respect to the other article of impeachment on obstruction of 
justice, her credibility is again bolstered by her reluctance to do 
legal harm to this President. In the end, though, she does admit that 
he called her early one morning in December of 1997--actually it was 2 
o'clock in the morning--and told her that she was on the witness list. 
And he told her that she might be able to file an affidavit to avoid 
testifying. And he told her that she could always use the story that 
she was bringing papers to him, or coming up to see Ms. Currie.
  Now, we know that she did not carry papers to him on these visits 
other than personal, private notes from her to him. And Ms. Lewinsky 
indicated in the deposition that she didn't carry him official papers, 
although she did pass along this cover story--of carrying papers--to 
her attorney, Mr. Carter. She testified also that she discussed the 
draft affidavit with Mr. Jordan, changes were made, she offered the 
President the opportunity to review it, he declined, and, according to 
Ms. Lewinsky, he never suggested any way that she could file a truthful 
affidavit, sufficient to skirt--avoid having to testify. This, in spite 
of his answer to this Senate where he told you that he might have had a 
way for her to file a truthful affidavit and still avoid testifying in 
the Jones case.
  Yes, you can parse the words and you can use legal gymnastics, but 
you cannot get around the filing of a false affidavit in an effort to 
avoid appearing in the Jones case and possibly providing damaging 
testimony against the President.
  Ms. Lewinsky confirmed positively that Ms. Currie initiated a 
telephone call to her on December 28, 1997, stating words--and this is 
about the gifts--``I understand you have something for me.'' Then Ms. 
Currie drove over to Ms. Lewinsky's home and picked up the box of 
gifts.
  Now, remember, this occurred on the heels of Ms. Lewinsky's 
conversation with the President that very morning about what she might 
do with the gifts. Now, the only--the only explanation is that the 
President is directly involved, himself, in the obstruction of justice 
by telling Ms. Currie, who otherwise knew nothing about this earlier 
conversation, to retrieve these items from Ms. Lewinsky. Ms. Lewinsky 
said there was no doubt that Ms. Currie initiated the call to retrieve 
the gifts.
  Also recall that the President's testimony from his side was that 
this conversation occurred earlier in the day with Ms. Lewinsky but 
that he had told her she would have to turn over whatever gifts that 
she had. Now, with that advice from the President, it would be totally 
illogical for Ms. Lewinsky to have then called Ms. Currie that same day 
and ask her to come pick up and hold these gifts. By calling Ms. 
Currie, Ms. Lewinsky would have been going against the direct 
instruction of the President to surrender any and all gifts. The facts, 
the logic, and common sense tell us all that the President's version is 
not true and that he obstructed justice here.
  Ms. Lewinsky also testified at the deposition about the job at Revlon 
and obtaining a job offer within 2 days of signing the affidavit. She 
also denied that she was a stalker, as the President had described her 
in a conversation with Mr. Blumenthal in January of 1998. She also 
denied that she threatened the President or attempted to threaten the 
President into having an affair. She denied that he rebuffed her on the 
occasion of their first encounter on November 15, 1995. Again, all 
false statements that the President made to Mr. Blumenthal about her, 
with knowledge that Mr. Blumenthal would be testifying in a grand jury, 
thereby obstructing justice.
  Now, the former lawyers and judges among us are familiar with what is 
called the best evidence rule. Stated simply, the court always prefers 
the best available evidence to be used. In-person testimony is better 
than a video deposition, which itself is better than the written 
transcript of a deposition. When all three forms of testimony are 
available, as they are in this situation, the court will most often 
require the witness to testify in person over the video deposition or 
over the written transcript of the deposition.
  In closing, I know we all want to work within the Senate rules and we 
all want to ensure that these proceedings are concluded in a 
constitutional fashion by the end of next week. It is with this in mind 
that we propose that Ms. Lewinsky be called as a live witness, the only 
person called to testify in person, and, further, that we use the two 
depositions, the video depositions of Mr. Jordan and Mr. Blumenthal, in 
lieu of their personal

[[Page 1820]]

attendance. In the event the Senate does not call Ms. Lewinsky, we also 
ask that we be permitted to use all or portions of her deposition, just 
as we would the other two depositions.
  And finally, several Senators have sent out a letter to the President 
inviting him to come here and to provide his testimony, if he so 
chooses. In the event he should accept, Ms. Lewinsky, likewise, should 
be afforded the same opportunity. They continue to be the two most 
important and essential witnesses for you and the American people to 
hear in order to finally--finally--resolve this matter.
  Permit us all to return to our districts, and you to your States, and 
tell our constituents that we considered the full and complete case, 
including live witnesses and, in your case, made your vote accordingly.
  At this time, I yield to my colleague from Arkansas, Mr. Hutchinson.
  The CHIEF JUSTICE. The Chair recognizes Mr. Manager Hutchinson.
  Mr. Manager HUTCHINSON. Thank you, Mr. Chief Justice.
  Ladies and gentlemen of the Senate, in an effort to be helpful, I 
have asked the pages to distribute to you some exhibits that I will be 
referring to as I consider the testimony that we are presenting to you.
  There are two aspects to an impeachment trial. There is the truth-
seeking responsibility, which is the trial, in my judgment, and then 
there is the conclusion, the judgment, the verdict, the conviction or 
the acquittal. If you look at those two phases of a trial, the latter 
is totally your responsibility. We leave that completely in your 
judgment.
  But the first responsibility of the factfinding of the truth-seeking 
endeavor, I feel some responsibility in that regard. Hopefully, our 
presentation is helpful in seeking the truth. I know, as Mr. Bryant 
mentioned, that we all want to bring this matter to a conclusion. We 
want to see the end of this story. We want to have a final chapter in 
this national drama. I understand that and agree with that. But let's 
not, because we are in a hurry to get to the judgment phase, let's not 
let that detract, let's not let that shortchange, nor diminish the 
importance of the presentation and consideration of the facts, and that 
is what I think is very important as we consider this motion that is 
before us.
  It is my responsibility to talk about Mr. Vernon Jordan--and the need 
for your consideration of his testimony--whom we recently deposed. I 
deposed Mr. Vernon Jordan, Jr., and I recommend that that be received 
in evidence as part of the Senate record.
  I took this deposition under the able guidance of Senator Thompson 
and Senator Dodd. The questioning took place over almost 3 hours with 
numerous and extraneous objections on behalf of the President's 
lawyers, most of which were resolved.
  I believe that the testimony of Mr. Jordan goes to the key element in 
the obstruction of justice article, and even though it is just one 
element that we are dealing with, it is a very important element 
because it goes to the connection between the job search, the benefit 
provided to a witness, and the solicited false testimony from that 
witness.
  I believe the testimony of Mr. Jordan is dramatic in that it shows 
the control and direction of the President of the United States in the 
effort to obstruct justice. I believe the testimony of Mr. Jordan 
provides new evidence supporting the charges of obstruction and 
verifying the credibility of Ms. Lewinsky.
  The testimony, in addition, is the most clear discussion of the facts 
reflecting Mr. Jordan's actions in behalf of the President and the 
President's direction and control of the activities of Mr. Jordan, and 
therefore they support the allegations under the articles of 
impeachment. Let me make the case for you.
  If you have the President of the United States personally directing 
the effort to obtain a job for Ms. Lewinsky, which is a benefit to a 
witness, and simultaneously Ms. Lewinsky is under subpoena as a witness 
in the case, and thirdly, in addition, the President is suggesting 
means to that witness to avoid truthful testimony, as evidenced by the 
December 17 conversation and the suggestion of the affidavit, the 
conclusion is that you have a corrupt attempt to impede the 
administration of justice and the seeking of truth and the facts in the 
civil rights case.
  Now, let me go to the testimony of Mr. Jordan. Has that been 
distributed now? Good. Let me give a caveat here, particularly to my 
colleagues, the counselors for the President, that this summary of the 
portions of the testimony of Mr. Jordan are based upon my handwritten 
notes. So, please don't blow it up in a chart if there is some 
discrepancy. I believe this is, in good faith, accurate, but I did not 
have a copy of the transcript. I was required to go to the Senate 
Chamber and actually take notes in order to prepare this.
  There are a number of areas that I think are relevant and new 
information and are very important for your consideration. Let me just 
touch upon five areas.
  The first one is the job search and Mr. Jordan being an agent of the 
President. In the deposition, Mr. Jordan testified that:

       There is no question but that through Betty Currie I was 
     acting on behalf of the President to get Ms. Lewinsky a job.

  He goes on to say:

       I interpreted [the request, referring from Betty Currie] it 
     as a request from the President.

  Then he testified:

       There was no question that he asked me to help [referring 
     to the President] and that he asked others to help. I think 
     that is clear from everybody's grand jury testimony.

  So the question is as to whether the information, the request, came 
from Betty Currie or whether it came directly from the President, there 
is no question but that Mr. Jordan was acting at the request of the 
President of the United States and no one else. In fact, he goes on to 
say:

       The fact is I was running the job search, not Ms. Lewinsky, 
     and therefore, the companies that she brought or listed were 
     not of interest to me. I knew where I would need to call.

  This is very important. There has been a reference, ``Well, he was 
simply getting a job referral, making a referral for routine employment 
interview by this person, Ms. Lewinsky.'' But, in fact, it is clear 
that Mr. Jordan knew whom he wanted to contact. He was running the job 
search as he testified to.
  Then he testified:

       Question: You're acting in behalf of the President when you 
     are trying to get Ms. Lewinsky a job and you were in control 
     of the job search?

  The answer is:

       Yes.

  So that is one area, and it is important to establish that he was an 
agent for the President.
  Secondly, there was a witness list that came out December 5. The 
President knew about it, at the latest, on December 6, and yet he had 
two meetings with Mr. Jordan, on December 7 and December 11. In neither 
one of those meetings was it disclosed to Mr. Jordan that Monica 
Lewinsky was a witness. I am referring to the second page of the 
exhibits I have handed you in which Mr. Jordan testified to that 
effect:

       Question: And on either of these conversations that I've 
     referenced, that you had with the President after the witness 
     list came out, your conversation on 12/7 and your 
     conversation sometime after the 11th, did the President tell 
     you that Ms. Monica Lewinsky was on the witness list in the 
     Jones case?
       Answer: He did not.
       Question: Would you have expected the President to tell you 
     if he had any reason to believe that Ms. Lewinsky would be 
     called as a witness in the Paula Jones case?
       Answer: That would have been helpful.
       Question: So it would have been helpful and it was 
     something you would have expected?
       Answer: Yes.

  Even though it would have been helpful, he would have expected the 
President to tell him the information, it was not disclosed to him. The 
materiality, the relevance, of that is that you have the President 
controlling a job search, knowing this is a witness in which we are 
trying to provide a benefit for, and yet the person he is directing to 
get the job for Ms. Lewinsky, he fails to tell Mr. Jordan the key fact 
that she

[[Page 1821]]

is, in fact, a witness, an adverse witness in that case. I think that 
is an important area of his testimony.
  The third area, keeping the President informed--very clear testimony 
about the development of the job search, the Lewinsky affidavit that 
was being prepared, and the fact that it was signed. On the third page 
I have provided to you, Mr. Jordan's testimony:

       I was keeping him [the President] informed about what was 
     going on and so I told him.

  He goes on further to say:

       He [referring to the President] was obviously interested in 
     it.

  Then the question, I believe, was:

       What did you tell the President when the affidavit was 
     signed?

  And his answer:

       Mr. President, she signed the affidavit, she signed the 
     affidavit.

  So was there any connection between the job benefit that was provided 
and the affidavit that was signed in reference to her testimony? 
Clearly, it was something the President not only directed the job 
search, but he was clearly interested, obviously concerned, receiving 
regular reports about the affidavit.
  Then the fourth area is the information at the Park Hyatt that was 
developed. To lay the stage for this--and I will do this very briefly--
if you look at page 4, you see the previous testimony of Mr. Jordan 
before the grand jury in March. At that time, the question was asked of 
him:

       Did you ever have breakfast or any meal, for that matter, 
     with Monica Lewinsky at the Park Hyatt?

  His answer was:

       No.

  It was not equivocally, it was indubitably no.
  And he was further asked, and he testified:

       I've never had breakfast with Monica Lewinsky.

  And then on page 5 he goes on, in the May 28 grand jury testimony:

       Did you at any time have any kind of a meal at the Park 
     Hyatt with Monica Lewinsky?

  His answer was:

       No.

  So that sets the stage, because in Ms. Lewinsky's testimony, as 
evidenced by page 6 of your exhibits, she testified in August, after 
the last time Mr. Jordan testified, very clearly about this meeting on 
December 31 at the Park Hyatt with Mr. Jordan where they had breakfast. 
And the discussion was about Linda Tripp. And then the discussion went 
to the notes from the President, and she said, ``No, [it was] notes 
from me to the President.'' And Mr. Jordan told her, according to her 
testimony, ``Go home and make sure they're not there.'' That is Ms. 
Lewinsky's testimony.
  It was important to ask Mr. Jordan about this. And I assumed that we, 
of course, would get simply a denial, sticking with the previous grand 
jury testimony, that unequivocally, no, that meeting never happened: we 
never had breakfast at the Hyatt.
  On page 7, you will notice that Ms. Lewinsky, in her testimony, 
specifically identified even what they had for breakfast. And so the 
investigation required us to go out and get the receipt at the Park 
Hyatt, which is page 8. And the receipt showed that there was a charge 
on December 31 by Mr. Jordan that included every item for breakfast, 
that corroborated the testimony of Ms. Lewinsky as to her memory; that 
is, the omelette they had for breakfast.
  And so it is tightening here. The evidence is becoming more clear, 
unequivocally, that this meeting occurred. And so we had to ask this of 
Mr. Jordan. And this is page 9. And, of course, I presented the Park 
Hyatt receipt, I presented the testimony of Ms. Lewinsky, and his 
testimony, which is page 9:

       It is clear, based on the evidence here, that I was at the 
     Park Hyatt on Dec 31st. So I do not deny, despite my 
     testimony before the grand jury, that on [December] 31 that I 
     was there with Ms. Lewinsky, but I did testify before the 
     Grand Jury that I did not remember having a breakfast with 
     her on that date and that was the truth.

  But what amazed me was, as you go through the questions with him, all 
of a sudden he remembered the breakfast but all of a sudden he 
remembered the conversation in which he before said it never happened 
at all. And his testimony was, when asked about the notes:

       I am certain that Ms. Lewinsky talked to me about [the] 
     notes.

  And so I think there are a number of relevant points here. First of 
all, you reflect back on the testimony of Ms. Lewinsky in this same 
deposition in which she was asked the question, getting Mr. Jordan's 
approval was basically the same as getting the President's approval? 
Her answer: Yes.
  And so that is how Ms. Lewinsky viewed this. And this is what was 
told to her at this meeting at the Park Hyatt. It goes to credibility, 
it goes to what happened, it goes to the obstruction of justice. It is 
extraordinarily relevant. It is new information. It is what was 
developed because this Senate granted us the opportunity to take this 
further deposition of Mr. Jordan and the other witnesses.
  And there are other, you know--the fifth point is that the testimony 
goes to the interconnection between the job help and the testimony that 
was being solicited from Ms. Lewinsky.
  So why is the presentation necessary? Some of you might even think, 
``Well, thank you very much for that explanation you have given to us. 
Now we have all the facts. Let's go on and vote.'' Well, I do think 
there is some merit. First of all, this is not all. There is much more 
there. I just have a moment to develop a portion of Mr. Jordan's 
testimony that I believe is helpful, but, secondly, it tells a story 
that has never been told before.
  Now, I went and saw the videotape and I was underwhelmed by my 
questioning, because it is just not the same. I thought we had a 
dynamic exchange. But then I saw it on videotape and I am nowhere to be 
found. You get to look at Mr. Jordan, a distinguished gentleman. But it 
is still helpful not withstanding the difficulty of a video 
presentation. I respectfully request this body to develop the facts 
fully, to hear the testimony of Mr. Jordan, to allow him to explain 
this that tells the story, start to finish, on this one aspect of 
obstruction of justice that is critical to your determination. And so I 
would ask your concurrence in the approval of the motion that has been 
offered to you, and at this time I yield to Manager Rogan.
  The CHIEF JUSTICE. The Chair recognizes Mr. Manager Rogan.
  Mr. Manager ROGAN. Mr. Chief Justice, Members of the Senate, 
yesterday, along with Mr. Manager Graham, I had the privilege of 
conducting the deposition of Sidney Blumenthal, assistant to the 
President. That deposition was presided over by the senior Senator from 
Pennsylvania and the junior Senator from North Carolina. And on behalf 
of the House managers, and I am also sure the White House counsel, we 
thank them for the able job that they did.
  This deposition must be played for Members of the U.S. Senate, and if 
one Senator has failed to personally sit through this deposition--and 
every deposition--that Senator is not equipped to render a verdict on 
the impeachment trial of the President of the United States.
  Now, I will address very briefly just a couple of the reasons why I 
believe Mr. Blumenthal's deposition warrants being played before this 
body. But to do it, it needs to be put in perspective. Remember what 
the President of the United States testified to on the day he was sworn 
in as a witness before the grand jury. He said that in dealing with his 
aides, he knew there was a potential that they could become witnesses 
before the grand jury, and that is why he told them the truth. That is 
the President's own word: the ``truth.'' Mr. Blumenthal's deposition 
paints a totally different picture and gives a terribly different 
interpretation of what the President was doing in passing along false 
stories to his aides.
  Now, we have been treated to a number of euphemisms by the 
distinguished White House counsel during their presentation as to what 
the President was doing during his grand jury. They described his 
testimony as ``maddening.'' They have described his testimony as 
``misleading'' and ``unfortunate.'' But the one thing they have never 
described it as is a lie.

[[Page 1822]]

  Mr. Blumenthal gave a totally different take on that. Because he 
testified under oath that, upon reflection, he believes the President 
was not maddening to him, the President lied to him. And he testified 
so for a very good reason.
  Remember, Sidney Blumenthal testified three times before the grand 
jury in 1998. He testified in February and twice in June. But that 
testimony was in a vacuum because each time he testified before the 
grand jury we were still in a national state of, at least 
presumptively, believing that the President had told the truth. The 
President had made an emphatic denial as to the Monica Lewinsky story. 
There was no physical evidence presented to the FBI lab at the time Mr. 
Blumenthal testified. And Monica Lewinsky was not cooperating with the 
grand jury. So we know that certain questions were not asked of him 
during his grand jury testimony because of the status of the facts as 
we thought they were. But Mr. Blumenthal shed some incredible new light 
on the testimony that we received yesterday from him.
  He said, first of all: After I was subpoenaed, but before I testified 
before the grand jury, once in February and twice in June--with the 
President knowing he was about to become a witness before the grand 
jury, a criminal grand jury investigation--the President never came to 
him and said, ``Mr. Blumenthal, before you go and provide information 
in a criminal grand jury investigation, I need to recant the false 
stories I told you about my relationship with Monica Lewinsky.''
  And he testified about those false stories. He corroborated his own 
testimony from earlier proceedings. You will recall from the record 
that the day the Monica Lewinsky story broke in the national press Mr. 
Blumenthal was called to the Oval Office by the President. The door was 
closed. They were alone. And this is what the President told Sidney 
Blumenthal about the revelations that were breaking that day on the 
national press wire:

       He said, ``Monica Lewinsky came at me and made a sexual 
     demand on me.''

  The President said he rebuffed her. He said:

       I've gone down that road before, I've caused pain for a lot 
     of people and I'm not going to do that again.

  The President said Monica Lewinsky threatened him:

       She said that she would tell people they'd had an affair, 
     that she was known as the stalker among her [colleagues], and 
     that she hated it and if she had an affair or said she had an 
     affair then she wouldn't be the stalker any more.

  And the testimony goes on. You are all familiar with it at this 
point.
  The President of the United States allowed his aide to appear three 
times before a Federal grand jury conducting a criminal investigation, 
and never once did the President of the United States inform that aide 
before providing that information to the investigatory body--never 
once--asked or told the aide that that was false information. Mr. 
Blumenthal's testimony demonstrates that the President of the United 
States used a White House aide as a conduit for false information 
before the grand jury in a criminal investigation.
  I just want to make one other brief point before I close this 
presentation because I think it needs to be said. I am in no position 
to lecture any of the distinguished Members of this body on what the 
founders intended in drafting the Constitution. I believe all of us in 
this room have an abiding respect for that. But there are a couple of 
points that need to be made. I believe there is a reason the founders 
drafted a document that allows us the opportunity in every trial 
proceeding in America to confront and cross-examine live witnesses. It 
is because that gives the trier of fact the opportunity to gauge the 
credibility and the demeanor of the witnesses. We have discussed that 
at length during these proceedings.
  But one thing we haven't discussed and one thing that I think is 
important--not from the House managers' perspective, but from the 
perspective of history and the history that will be written on the 
ultimate verdict in this case--and that is the idea of open trials. 
There is a reason why the founders looked askance on the concept of 
secret trials and closed trials. There is a reason why in every 
courtroom across the land trials are open. They are open. It is an open 
process. The light of truth is allowed to be shown on the courtroom and 
from the courtroom because we don't trust the credibility of a verdict 
if it is done in secret. What would be the verdict on this proceeding 
if the judgment of this body is based upon testimony and witnesses, on 
videotapes, locked in a room somewhere, available only to the triers of 
fact without the public being privy to what was made available?
  Ladies and gentlemen of the Senate, I would urge you, not for the 
sake of the managers and not for the sake of the presentation of the 
case, but for the sake of this body and for the verdict of history that 
will be written, to please allow this to be a public trial in the real 
sense. If the witnesses will not be brought here live before the 
Senate, please allow the doors of the Senate to be open so that the 
testimony upon which each of you must base your verdict will be made 
available not only to all 100 Senators, but will be made available to 
those who will make the ultimate judgment as to the appropriateness of 
the verdict, the American people.
  Mr. Chief Justice, I yield to Mr. Manager Graham.
  The CHIEF JUSTICE. The Chair recognizes Mr. Manager Graham.
  Mr. Manager GRAHAM. Mr. Chief Justice, how much time?
  The CHIEF JUSTICE. Your colleagues have consumed 37 minutes.
  Mr. Manager GRAHAM. Ladies and gentlemen of the Senate, not a whole 
lot to add, but I would like to recognize this thought: That we have 
learned a great deal in these depositions. Thank you for letting us 
have them. We didn't get everything we wanted--and I think that is a 
fair statement--but who does in life? But we do appreciate you giving 
us the opportunity to explore the testimony of these witnesses because 
I think it would be helpful in setting the historical record straight.
  Mr. Blumenthal, to his credit, said the President of the United 
States lied to him. The President of the United States did lie to him. 
The President of the United States, in his grand jury testimony, denied 
ever lying to me. That should be historically significant and should be 
legally significant. Mr. Blumenthal, to his credit, said the President 
of the United States tried to paint himself as a victim to Ms. 
Lewinsky. That would be legally and historically relevant and it will 
mean a lot in our arguments and it will be something you should 
consider.
  This has been a good exercise. Thank you very much for letting us 
depose these witnesses.
  I was not at the other two depositions, but I was at Mr. Blumenthal's 
deposition, and I can assure you we know more now about what the truth 
is than before we started this process. I hope at the end of the day it 
is our desire to get to the truth that guides us all. We are asking for 
one live witness, Ms. Lewinsky.
  Let me tell you, I know how difficult it is to want this to go on 
given where everybody is at in the country. Trust me, I want this to 
end as much as you do. However, there is a signal we will send if we 
don't watch it. We will make the independent counsel report the 
impeachment trial, and I am not so sure that is what the statute was 
written for.
  The key difference between the House and the Senate is that the White 
House never disputed the facts over in the House. They never disputed 
the facts. They called 15 witnesses to talk about process and about the 
interpretations that you would want to put on those facts. In their 
motion to the Senate, everything is in dispute. It is a totally 
different ball game here. That is why we need witnesses, ladies and 
gentlemen, to clarify who said what, who is being honest, who is not, 
and what really did happen in this sordid tale.
  Ms. Lewinsky comes before us because the allegations arise that the 
President of the United States, with an intern, had an inappropriate 
workplace sexual relationship that was discovered in a lawsuit where he 
was a defendant. This was not us or anyone else trying

[[Page 1823]]

to look into the President's private life for political reasons or any 
other reason. It was a defendant in a lawsuit asking to look at the 
behavior of that defendant in the workplace, something that goes on 
every day in courtrooms throughout the country.
  And is it uncomfortable? Yes, it is uncomfortable. If you have ever 
tried a sexual harassment case, an assault case, or a rape case, it is 
very much uncomfortable to have to listen to these things. But the 
reason that people are asked to do what you are asked to do by the 
House managers is that the folks that are involved represented 
themselves much better than lawyers talking about what happened. And if 
you find it uncomfortable listening to Ms. Lewinsky, think how juries 
feel, think how the victims feel, think how somebody like Ms. Jones 
must feel not to be able to tell the story of the person they are 
suing.
  That is a signal that is going to be sent here that will be a 
devastating and bad signal. If we can't stomach it, if we can't stomach 
listening to inappropriate sexual conduct, why do we put that burden on 
anyone else?
  Give us this witness. We will do it in a professional manner. We will 
focus on the obstruction. We will try to do it in a way not to demean 
the Senate. We will try to do it in a way not to demean Ms. Lewinsky. 
We will try to do it in a way to get to the truth. Please give us a 
chance to present our case in a persuasive fashion, because unlike the 
House, everything is in dispute here.
  Thank you very much. I reserve the balance of my time.
  The CHIEF JUSTICE. The House managers reserve the balance of their 
time.
  The Chair recognizes Counsel Craig.
  Mr. Counsel CRAIG. Mr. Chief Justice, ladies and gentlemen of the 
Senate, I have divided my presentation into three parts that 
fortunately correspond to the three parts of the motion that is before 
you today.
  I would like, first, to argue against admitting videotape evidence 
into the record of this trial. Secondly, I would like to argue against 
calling live witnesses to this trial. And thirdly, I would like to 
argue against the proposed presentation of videotape and deposition 
testimony for Saturday.
  I sound rather negative. I don't mean to be negative. But we don't 
find much to recommend the three proposals that the House managers have 
brought before you today.
  Let me begin by saying that we support the idea of admitting written 
transcripts of deposition testimony of these three witnesses into the 
record of this trial. But we believe that it would be a terrible 
mistake and wholly redundant to put the videotape testimony into that 
record as well, particularly if that means releasing any of this 
videotaped material to the public.
  We can only call the Senate's attention to section 206 of Senate 
Resolution 30, which instructs the Secretary of the Senate ``to 
maintain the videotaped and transcribed records of the deposition as 
confidential proceedings of the Senate.'' That was the intention of the 
Senate when you first passed Resolution 30. If this decision as 
proposed today will result in overruling that rule, if there is any 
risk or danger of a wholesale, unconditional, and unlimited release of 
these videotapes for the public through the national media, just as was 
done by the House of Representatives when it released all the Starr 
materials, we think it is a bad idea.
  In retrospect, most people believe that it was a mistake for the 
House to release those materials--and those materials included 
videotaped grand jury testimony--and we believe it would be a mistake 
for the Senate, at the request of the House managers, to do the same 
thing with these videotaped materials now. To release these videotapes 
generally to the public--which will happen if they are put into the 
record--inevitably will surely cause consternation among those members 
of the public, particularly parents who do not choose to spend one more 
moment, much less hours and even days, thinking about the President's 
relationship with Monica Lewinsky and explaining it again to the 
children. Placing these videotapes in the formal record of this trial 
will be one step closer to releasing the tapes to the public for 
immediate broadcast. And if that release occurs, it will produce an 
avalanche of unwelcome deposition testimony into the public domain.
  The videotaped testimony of Ms. Lewinsky, Mr. Jordan, and Mr. 
Blumenthal will be forced, hour after hour, unbidden and uninvited, 
into the living rooms and family rooms of the Nation. Make no mistake 
about what would happen; we have seen it before. We can expect to see 
the networks play these tapes, wall-to-wall, nonstop, and without 
interruption, over the airwaves. This would be a repeat of what 
happened when the case first came to the House of Representatives. For 
the Senate to decide to include the videotapes of this deposition 
testimony, as opposed to the written transcripts in the formal record 
of this trial, would have the same effect and could result in this kind 
of release. The picture, voices, and words on these tapes would flow 
directly and irreversibly into the life of the Nation. In addition, 
these videotapes will, no doubt, be edited and excerpted and cut and 
spliced, and the materials will not only be overused, they will also be 
inevitably abused.
  To take advantage of these witnesses, I submit to you, in this way is 
wrong--whether in the context of the grand jury proceeding where 
confidentiality is promised, or whether testifying under subpoena in an 
impeachment trial in the Senate. It is unfair to the witnesses, unfair 
to the public, unfair to the Senate and, we submit, unfair to the 
President as well.
  We do not object to release of the written transcripts of this 
testimony; we support that release. And we believe that that satisfies 
any reasonable requirement of public access to the information. The 
public's right to know and understand what is happening in this 
impeachment trial would be respected. But we should learn a lesson from 
America's experience in the House of Representatives: More is not 
always better.
  It is not wise or right for the House or the Senate to perform the 
function of a mere conveyor belt simply and automatically transmitting 
unfiltered evidence into the public domain. It is not wise or right to 
suspend judgment and turn over for public viewing the videotaped 
testimony of private witnesses who are forced to appear and testify 
under compulsion. It is simply wrong to release videotapes of such 
testimony for cable news networks or for friends or foes to use as they 
want. This, I submit, is profoundly unfair to the witnesses.
  One can only ask, who really benefits from this kind of practice? Is 
it really in the public interest for the Senate to issue and serve a 
subpoena on private individuals like Monica Lewinsky, or Vernon Jordan, 
to summon these citizens before the Senate to compel their testimony 
before video cameras and then to take that videotaped testimony, 
without any consideration or thought about the legitimate personal 
concerns or interests of those witnesses, and release those videotapes 
of that testimony for the national media? Is it really in Ms. 
Lewinsky's interest to do this, or in the interest of her family or her 
future? Is it fair to Mr. Jordan or to his family to subject him to 
this kind of treatment? Is it really in the Senate's interest? Is it in 
the interest of the Constitution, or the Presidency, or of the American 
people to have a videotape of Monica Lewinsky readily available for all 
the world to see and to hear?
  What about those individuals who are, in fact, truly innocent but who 
will surely suffer if these videotapes are released to the public for 
permanent residence in the public domain? What about the members of the 
President's immediate family? How can the Senate contemplate releasing 
Ms. Lewinsky's videotaped testimony, discussing her relationship with 
the President, without giving at least some thought to the impact that 
this might have on the members of that family? You can be sure that the 
release of this testimony and of this videotape will only add to their 
agony, embarrassment, and humiliation.
  I only hope that those who purport to be concerned about the moral 
damage

[[Page 1824]]

that can be attributed to the President's conduct and example are 
equally mindful of the hurt that will be inflicted on innocent people 
by the mere broadcasting of these videotapes and of their existence in 
perpetuity in the public record and the public domain.
  We think it is perfectly appropriate and, no doubt, helpful to many 
Senators and staffers to be able to watch the deposition testimony of 
these three witnesses on videotape as part of the Senate's trial 
proceeding, but that function has now been satisfied. There is no need 
for these tapes to be broadcast to the public. And the public knows 
better than anyone. It is for that precise reason that one suspects 
that three-quarters of those polled, according to a survey reported in 
yesterday's New York Times, oppose releasing the videotaped testimony 
of Ms. Lewinsky and Mr. Jordan and Mr. Blumenthal to the public.
  I urge you to not vote to place these materials into the record of 
this trial without giving careful consideration to these interests and 
to these concerns. These are not just the interests and concerns of the 
President and the members of his family. They are not just the 
interests and concerns of these three witnesses and the members of 
their families. I think they are also the interests and concerns of the 
American people as well.
  The bottom line, ladies and gentlemen of the Senate, is simple: You 
do not need these videotapes released to do your constitutional duty, 
and the people we all work for do not want these videotapes released to 
them. Please draw the line.
  As for the issue of witnesses, we believe that there is no useful 
purpose served by calling live witnesses to testify before the Senate 
in this trial. Live witnesses will not advance the factual record. We 
have known the facts for many months. Nor will live witnesses give us 
new insight into the witnesses themselves. Sidney Blumenthal's fourth 
appearance, Vernon Jordan's seventh appearance, and Monica Lewinsky's 
twenty-third appearance told us really very little that was new. I take 
issue with the presentation of the managers. Why should we expect Mr. 
Blumenthal's fifth appearance, Mr. Jordan's eighth appearance, and Ms. 
Lewinsky's twenty-fourth appearance to add anything more? Live 
witnesses will simply not serve the interests of fairness. They will 
not serve the interests of the American people, and they will not serve 
the interests of the Senate. In fact, live testimony from these three 
individuals--or from Ms. Lewinsky alone--will be worse than an exercise 
in redundancy and will be an exercise in excess. It will only postpone 
the end of the trial that nobody wants anymore and that no one wants to 
prolong any longer. There is every reason, finally and at long last, to 
bring the trial to a close. And calling live witnesses, I submit, will 
not be quick, and it will not be easy. It will prevent the Senate from 
keeping its pledge to bring this trial to a conclusion by February 12.
  Because live witnesses are unnecessary for the resolution of this 
matter, perhaps the most important question for the Senate to consider 
and resolve itself is whether calling live witnesses might, in fact, 
tarnish the Senate as an institution. This is a question that only you 
can resolve, the Members of the Senate. And you certainly need not take 
instructions from me or from any of us at this table on that subject. 
But the question is worth asking: Will the public's respect for the 
Senate and for the Members of this body be enhanced by calling live 
witnesses? Does the Senate really feel a need or an obligation or some 
requirement to bring Ms. Lewinsky to sit here and testify in the well 
of this historic Chamber?
  The managers first argued that live witnesses were necessary to 
resolve conflicts of testimony, that the only way to reconcile 
disparities and differences in testimony was to bring in live 
witnesses. Today we know that is not true. You gave the managers an 
opportunity to resolve those conflicts and find new facts. But most of 
the critical conflicts that existed a week ago still exist today.
  Calling Monica Lewinsky to testify a 24th time is not likely to 
resolve those conflicts. Then we were told that we must look into the 
eyes of the witnesses and observe their demeanor to make a judgment as 
to credibility. But you now have the opportunity to observe almost 
every major witness as he or she testifies. Precious little is left to 
the imagination or to guess or to question the credibility, and you 
certainly have a better chance of observing demeanor through the 
videotape than you do with a witness here on the floor of the Senate.
  We are now given a third reason why live witnesses are absolutely 
necessary to this trial to go forward; that is to ``validate'' the 
testimony of these witnesses.
  According to Mr. Manager Hyde, the depositions have been successful, 
but ``what we need now is to validate the record that already exists 
under oath about obstruction of justice and perjury.''
  Ladies and gentlemen of the Senate, we on this side of the House have 
never challenged that record. We have always agreed that the witnesses 
said what the record says they said, and that record needs no further 
validation through the live testimony of individual witnesses.
  Those of us who have made a career of being lawyers and trying cases 
probably understand better than anyone else why the House managers are 
so adamant in their desire to call live witnesses. It keeps the door 
open if only for a few more days. As Mr. Kendall observed last week, 
like Mr. Micawber in David Copperfield, they hope against hope that 
something may turn up.
  As an abstract proposition, the importance of live witnesses cannot 
be disputed. They are important to prosecutors who are trying to make a 
case. They are important to defense lawyers who are trying to defend a 
case. Trial lawyers know better than anyone that live witnesses can 
make all the difference in a trial. There is just no disputing that 
point.
  But that abstract question is not the real live question that the 
Senate has before it today. The issue before the Senate today is 
different. It is more specifically whether these three witnesses, each 
one of whom has testified on multiple occasions under oath before the 
Federal grand jury, or have been interviewed on multiple occasions by 
lawyers and law enforcement officers, would have anything whatsoever to 
add to this trial if they were to appear before you in person. The 
answer to that question is clearly no.
  The answer is no--not because Ms. Lewinsky has already been 
interviewed so many times and has testified so many times, not because 
she was just interviewed a few weekends ago, and not because she 
appeared and answered the House managers' questions under oath for many 
hours just 4 days ago. The answer is no because if you watch the 
videotape of her testimony, and if you look at the videotape of the 
testimony of Mr. Jordan and Mr. Blumenthal, you realize and you know 
deep in your bones that calling these witnesses to testify personally 
before you in the Senate in detail would simply be a massive waste of 
this Senate's time.
  You already know the facts. You have already read what they have had 
to say on many different occasions. And you have already seen and read 
their most recent testimony under oath. It simply can no longer be 
credibly argued that you need testimony from these witnesses to 
``flesh'' out the factual record or to resolve conflicts or to fill in 
the evidentiary gaps or to look the witnesses in the eye and assess 
their credibility. All that has been done many times before by many 
lawyers before and by many law enforcement officers many months ago. 
And then it was done just recently again by House managers as they took 
their deposition testimony last week.
  The Senate has given the managers every opportunity to persuade the 
Senate and the Nation to see this case the same way they see it. And 
the managers have run a vigorous and energetic campaign aimed at 
capturing the Senate and changing American public opinion. How many 
times do you know of where the prosecutors base their case on a 
multimillion-dollar criminal

[[Page 1825]]

investigation involving multiple interrogations of witnesses, producing 
60,000 pages of documents, generating 19 boxes of evidence, when the 
prosecutors are allowed to go back to those witnesses again and again 
and again in an effort to maybe--somehow maybe--in some way to make 
their case, covering the same territory, presenting the same evidence, 
hour after hour? In fact, in our view, the Senate has indulged the 
managers. And despite the misgivings of many Senators, the Senate has 
leaned over backwards to accommodate the managers.
  We believe it is time for the Senate to say it is time to vote. Given 
the state of the record compiled by the Office of Independent Counsel, 
given the discovery that has already been given to the managers, the 
evidence is as it is, and it is not likely to change in any significant 
way. The moment of truth can no longer be avoided, and the Senate 
should move to make the decision.
  President Clinton is not guilty of having committed high crimes and 
misdemeanors. He should not be removed from office. The Senate must act 
now to end this impeachment trial finally and for all time.
  Finally, as to the proposed proceedings for Saturday, Senate 
Resolution 30 gives the House managers and White House counsel an 
opportunity to ``make a presentation'' to the Senate employing all or 
portions of the videotape of the deposition testimony. And the final 
portion of the motion involves a request that the parties be permitted 
to present before the Senate for a period of time not to exceed a total 
of 6 hours equally divided all or portions of the parts of the 
videotapes of the oral depositions of Ms. Lewinsky, Mr. Jordan, and 
Sidney Blumenthal that have been admitted into evidence.
  We are convinced that such a presentation would provide no new 
information to the Senate and would only serve to delay this trial and 
further burden the service of the Senate.
  We also believe that there is a potential for unfairness that lurks 
in the process of excerpting and presenting portions of individual 
videotape testimony out of context. We remain committed to the notion 
that to be fair to all sides, the videotapes, if they are used, must be 
shown in their entirety or shown not at all. And, above all, we do not 
believe these videotapes should be released to the public in any form 
which would of course occur if they were used as part of the 
presentation on Saturday.
  Senators have themselves been reviewing the videotaped deposition 
testimony of the witnesses at great length and in great detail over the 
past 4 days. It appears to us that the Senate has been very 
conscientious in carrying out this assignment. And within a matter of 
days, Senators will listen to final arguments from each side.
  Is there really a need for an intermediate stage involving the 
playing of videotape testimony of the very same evidence? After 
conscientiously reviewing the videotape testimony and reading the 
transcripts of that testimony, should Senators now be required to sit 
and watch and listen to more of the same? Such an exercise would only 
be cumulative and causes us to ask what the point would be. We just do 
not think that additional presentations of the same evidence that 
Senators have been reviewing over the past few days will be that 
helpful to the process.
  Presumably, the House managers seek to present a collection of 
snippets--the greatest hits from the deposition testimony of Ms. 
Lewinsky, Mr. Jordan, and Mr. Blumenthal. This would be unfortunate 
because it would require a full response from the White House--
presumably our own collection of snippets aimed at putting the 
managers' excerpts into some kind of context. This would be a dual of 
snippets and excerpts, and presumably each side in the course of the 
presentation would conduct a guided tour for the Senate through that 
evidence, although I must say that the language of the motion leaves 
that open to some doubt.
  The language of the motion provides no opportunity for argument, no 
opportunity for explanation, and simply talks about playing a total of 
6 hours equally divided, all or portions of the parts of the 
videotapes.
  Is this the kind of way that your time is best used in this 
enterprise? We fully understand the House managers' desire--and even 
share it--to highlight and explain the importance of certain testimony 
that came out of the depositions over the past few days. But in truth, 
there are no bombshells in that testimony. There is no dynamite. There 
are no explosions. We believe that highlighting, explaining, and 
calling attention to those parts of that testimony that are important 
can be done with the transcripts, and the transcripts more than satisfy 
the requirement that we see, or the need to conduct that function, 
carry out that function. That is what ordinary lawyers do when they are 
trying cases or arguing in front of a jury.
  To the extent that the managers wish to call attention to various 
aspects of the testimony, we think they will have ample time to do so 
in the course of their final argument. Traditionally, that is the time 
to do that, during closing arguments, the time for advocates in a trial 
to marshal their evidence, to summarize and comment on that evidence; 
and to allow the managers to go through the deposition testimony first 
would be tantamount to giving the managers two closing arguments.
  In summary, Mr. Chief Justice, I have a point of parliamentary 
inquiry I would direct to the Chair having to do with the first 
paragraph, the first section of the proposed motion submitted by the 
House managers. Is there any way that the Senate can deal first with 
the question, the first question being bifurcated? Is there any way the 
Senate can bifurcate this first question and a separate vote be taken 
first on including the transcripts of the deposition testimony in the 
record of the trial and, second, whether the videotapes should also be 
included in the record?
  The CHIEF JUSTICE. A preemptive motion to that effect could be made 
by any Senator.
  Mr. Counsel CRAIG. Thank you.


                                 Recess

  The CHIEF JUSTICE. The majority leader.
  Mr. LOTT. Mr. Chief Justice, I ask unanimous consent that we take a 
15-minute recess. I think we can address that question during this 
recess.
  There being no objection, at 2:22 p.m. the Senate recessed until 2:44 
p.m.; whereupon, the Senate reassembled when called to order by the 
Chief Justice.
  The CHIEF JUSTICE. The Chair recognizes the majority leader.
  Mr. LOTT. Mr. Chief Justice, I believe that there is time remaining 
for arguments by the White House counsel, and then at their conclusion, 
by the House managers. After that, I will make an attempt to explain to 
the Senate exactly what is in the motions, because there seems to be 
some degree of question about that. Then we will be prepared to have a 
series of votes at that time. I still believe we should be able to 
start that around 4 o'clock. I yield the floor.
  The CHIEF JUSTICE. The Chair recognizes Mr. Craig.
  Mr. Counsel CRAIG. Mr. Chief Justice, we have completed our 
presentation. Thank you.
  The CHIEF JUSTICE. The House managers have 19 minutes remaining.
  The Chair recognizes Mr. Manager Bryant.
  Mr. Manager BRYANT. Mr. Chief Justice, I will respond briefly, to be 
followed by Mr. Manager McCollum, who will be followed by Mr. Manager 
Hutchinson.
  Let me first talk quickly about Mr. Craig's argument about 
disagreeing on the admission of the video depositions. He cited the 
House proceedings, and we want to be clear as to our belief of our 
position in the House in this process, as the accusatory branch of the 
Government in this process, and I think that is the case because we 
vote by a majority vote, we chose to bring forward the case that we 
felt established the allegations of impeachment.
  There was no conflict of evidence brought forward from those House 
proceedings. This evidence was not challenged until we came to this 
body, the appropriate body, for resolving the evidence and trying the 
case, as you will.

[[Page 1826]]

That is evidenced by the constitutional requirement that you must vote 
conviction based on two-thirds of your body. But the actual conflict 
was not presented until we arrived here in the Senate. By allowing us 
to have this procedure of taking depositions, we have focused more 
clearly on resolving those particular conflicts.
  I might add also in response to Mr. Craig's statement that the Starr 
Report was released out to the public and, as a result of that, there 
may be danger here in releasing these video depositions. But let me 
tell you about the House vote on the Starr Report. Seventy percent of 
the Democrats supported the release of those documents; 100 percent of 
the Democratic leadership in the House supported the release of those 
documents. So it was not just one party over the other party that threw 
these out to the public. It was a decision that was a bipartisan 
decision on the part of the House.
  I might add, that is not our interest in doing this with video 
depositions. We are open to your process, but we must conclude by those 
who would argue that perhaps you should open your debate to the public, 
we don't see the consistency in trying to take a very important part of 
the evidence in this case and not opening that to the public. So we are 
at your wishes. It is our desire to make the presentation using all or 
portions of these video depositions and to use those as fully as we 
would any other evidence.
  With that said, I ask Mr. Manager McCollum to follow me.
  The CHIEF JUSTICE. The Chair recognizes Mr. Manager McCollum.
  Mr. Manager McCOLLUM. Thank you very much, Mr. Chief Justice.
  If you listen to the White House counsel, the simple fact is, they 
don't want a public display in any form of any testimony here in front 
of the Senate. They don't want the public to have an opportunity to 
have a public trial.
  Now, maybe an impeachment trial is not exactly the same as any other 
trial, but in the history of the Senate, it has been a basically open 
process, except for the voting. It has been an opportunity for 
witnesses to come before you. It has been an opportunity for people to 
be heard. It has been an opportunity for the public to hear the people 
who want to speak.
  White House counsel didn't just say, ``We don't want live witnesses 
here.'' They said, ``We don't want you to be able to admit even into 
evidence the videotape that might become public, and we don't want you 
to be able to show any portion, or all even, of the videotapes of the 
depositions that have been taken.''
  If a Republican had gotten up and said that, we would have probably 
gotten hung on some political petard for that. The reality is, the 
public has a business here. This is a trial. I suggest and submit to 
you, we need--you need--the opportunity to hear these witnesses one way 
or the other--preferably Monica Lewinsky live. We need to bring closure 
in this matter.
  How can the public come to closure? How can those who feel so 
emotionally, as we know they do, around the country come to closure on 
this--which we need for them to do as much as you need to resolve and 
we need to have you resolve the questions before you--how can they come 
to closure? How can we all come to closure without an opportunity for 
the public to participate, in one way or another, in seeing the 
credibility, judging the witnesses, judging the truth of this?
  Let me remind you, there is nothing in these depositions that 
contains any salacious material, so it has been constrained very 
delicately--nothing at all that would be offensive to anybody.
  In addition, think about this for a minute. When it comes to calling 
Monica Lewinsky live, when it comes to letting the deposition be 
presented, if you believe that the President did not break the law--not 
talking about whether he should be removed from office--if you believe 
he did not break the law, that he did not commit the crimes of perjury 
and obstruction of justice, that means you must have concluded that 
Monica Lewinsky was not telling the truth when she said about the false 
affidavit, ``I knew what he meant,'' when she said about the 
concealment of the gifts, ``Betty called me,'' when she said about the 
nature of their relationship, ``It began the night we met,'' and many 
other things.
  You, I would submit, my colleagues in the Senate, have a moral 
obligation to allow Monica Lewinsky to come here and be judged on her 
credibility, not just by you but by the public, by all of us, as a live 
witness. And certainly, barring that, you have an obligation to have 
the credibility on the issues of guilt or innocence of these crimes be 
judged by everybody, at the very least, by the presentation of these 
videos in a public, open format here in the Senate before everybody. 
And I think it is a powerful question you have to resolve.
  And I would submit one last point. For those of you who do believe 
the President is guilty of these crimes, you have an obligation to let 
the showing of these depositions, or the presentation preferably of 
Monica Lewinsky live, so those who maybe don't think the same way you 
do have an opportunity for that credibility to be judged. Only if the 
witnesses are present can they be judged that way.
  The most remarkable thing about the White House presentation may have 
been, just a moment ago, the admission that normally in trials this is 
exactly what happens. And I present to you the suggestion, this is 
exactly what should happen here today.
  I yield to Manager Hutchinson.
  The CHIEF JUSTICE. The Chair recognizes Manager Hutchinson.
  Mr. Manager HUTCHINSON. Thank you, Mr. Chief Justice.
  Very briefly, I was asked to respond to the last argument by counsel 
for the President in regard to their objections on the evidentiary 
presentation of 6 hours under the motion, which would be, I believe, on 
Saturday. After 6 days of opening statements in this trial, and after 2 
days of questions and answers, and then we had, I believe, 2 days of 
motion arguments, you have heard from all the lawyers more than you 
ever wanted to hear. And I don't think that it is too much to ask for 6 
hours of discussion of the evidentiary record that was developed from 
the deposition testimony. I think that is reasonable.
  It's been argued that, well, you know, it is going to be snippets, it 
is going to be a battle of snippets.
  If this motion is passed, it will be introduced into evidence, and 
each side will have an opportunity to discuss that evidence, to 
contrast it with other individuals' testimony, and to present it in a 
fashion that is most understandable. It is equally divided; therefore, 
both sides can present their case. That is how it is traditionally 
done. There is nothing unusual about that. And certainly the White 
House defense lawyers will be very vigilant in making sure that it is 
fairly presented.
  There was objection that was made--and this is overlapping a little 
bit--as to the public release of the video. Our motion really goes to 
introducing into evidence. It is up to you as to how that evidence is 
handled. Customarily in a trial, when something is entered into 
evidence, that is released. But there was concern expressed about the 
witnesses, about Mr. Jordan and the fact that he has testified and now 
it would be made public. I recall the White House defense lawyers, on 
this screen over here, put Mr. Jordan's video up there for the world to 
see. I believe they also brought in other witnesses on video that was 
put out there for the whole world to see. And so I think it is a little 
bit late to come in and say that that should not be subject to public 
discussion.
  And so I think that the motion that is presented is reasonable, it is 
fair. They say there is nothing of dynamite or there is nothing 
explosive. Then if that is the case, there should not be any objection 
to the discussion and the fair playing of that evidence. But in fact 
much of this is due because it was not developed after the President 
made his grand jury appearance. Many of these witnesses testified 
early. They were not able to testify again after the President's grand 
jury testimony. So I think there are new areas that have certainly been 
developed.
  With that, Mr. Chief Justice, I yield back.

[[Page 1827]]

  The CHIEF JUSTICE. Will the House managers yield back?
  Mr. Manager HUTCHINSON. Yes, Mr. Chief Justice.
  The CHIEF JUSTICE. The Chair recognizes the majority leader.
  Mr. LOTT. Mr. Chief Justice, then all time has been yielded back on 
both sides?
  The CHIEF JUSTICE. Yes.
  Mr. LOTT. We had expected this would take a little bit longer. 
(Laughter.)
  Mr. Chief Justice, I believe it would be of interest to the Senators 
that we give just a brief explanation of the motions. I believe Senator 
Daschle may have an additional motion that he would like to offer. So 
that we can make sure he has had the time to prepare that, and how we 
would go into the voting procedure, I suggest the absence of a quorum.
  The CHIEF JUSTICE. The clerk will call the roll.
  The assistant legislative clerk proceeded to call the roll.
  Mr. LOTT. Mr. President, I ask unanimous consent that the order for 
the quorum call be rescinded.
  The CHIEF JUSTICE. Without objection, it is so ordered.
  Mr. LOTT. Mr. Chief Justice, very briefly, I believe that Senator 
Daschle, or one of his Senators, will have a peremptory motion that 
they will offer, and it will be read by the clerk; then there will be a 
vote on that. And then there will be a vote on the 3 divisions that 
have been identified--the 3 votes on the one motion--and then I believe 
Senator Daschle will also have a motion that will go straight to debate 
and closing arguments and the vote on the articles of impeachment. Is 
that a correct recitation?
  I yield to Senator Daschle.
  Mr. DASCHLE. Mr. Chief Justice, I appreciate the Senator yielding. As 
I understand it, Senator Murray's motion will relate to the third 
motion, which is, as I understand it, the motion that allows for video 
excerpts to be used. Her motion would restrict both managers to 
transcripts, written transcripts. I am not sure in which order her 
motion should be offered, but since it relates to the third one, 
perhaps it would be in concert with that motion.
  The CHIEF JUSTICE. This is the motion to debate and divide the third 
motion.
  Mr. DASCHLE. That's correct.
  Mr. LOTT. We would vote on the first paragraph, the second paragraph, 
and then there would be a motion at that point by Senator Murray and a 
vote on that, and a vote then on the third division, and then a vote on 
the articles of impeachment itself.


                           Vote on Division I

  The CHIEF JUSTICE. The question is on division I. The clerk will read 
Division I.
  The legislative clerk read as follows:

       The House moves that the transcriptions and videotapes of 
     the oral depositions taken pursuant to Senate resolution 30 
     from the point that each witness is sworn to testify under 
     oath to the end of any direct response to the last question 
     posed by a party be admitted into evidence.

  The CHIEF JUSTICE. The yeas and nays are required.
  The clerk will call the roll.
  The legislative clerk called the roll.
  The yeas and nays resulted--yeas 100, nays 0, as follows:

                         [Rollcall Vote No. 9]

 [Subject: Division I of House managers motion regarding admission of 
                               evidence]

                               YEAS--100

     Abraham
     Akaka
     Allard
     Ashcroft
     Baucus
     Bayh
     Bennett
     Biden
     Bingaman
     Bond
     Boxer
     Breaux
     Brownback
     Bryan
     Bunning
     Burns
     Byrd
     Campbell
     Chafee
     Cleland
     Cochran
     Collins
     Conrad
     Coverdell
     Craig
     Crapo
     Daschle
     DeWine
     Dodd
     Domenici
     Dorgan
     Durbin
     Edwards
     Enzi
     Feingold
     Feinstein
     Fitzgerald
     Frist
     Gorton
     Graham
     Gramm
     Grams
     Grassley
     Gregg
     Hagel
     Harkin
     Hatch
     Helms
     Hollings
     Hutchinson
     Hutchison
     Inhofe
     Inouye
     Jeffords
     Johnson
     Kennedy
     Kerrey
     Kerry
     Kohl
     Kyl
     Landrieu
     Lautenberg
     Leahy
     Levin
     Lieberman
     Lincoln
     Lott
     Lugar
     Mack
     McCain
     McConnell
     Mikulski
     Moynihan
     Murkowski
     Murray
     Nickles
     Reed
     Reid
     Robb
     Roberts
     Rockefeller
     Roth
     Santorum
     Sarbanes
     Schumer
     Sessions
     Shelby
     Smith (NH)
     Smith (OR)
     Snowe
     Specter
     Stevens
     Thomas
     Thompson
     Thurmond
     Torricelli
     Voinovich
     Warner
     Wellstone
     Wyden
  The CHIEF JUSTICE. On this vote, the yeas are 100, the nays are 0. 
Division I of the motion is agreed to.


                          Vote on Division II

  The CHIEF JUSTICE. The next vote will be on Division II of the 
motion. The clerk will read Division II of the motion.
  The assistant legislative clerk read as follows:

       Division II: The House further moves that the Senate 
     authorize and issue a subpoena for the appearance of Monica 
     S. Lewinsky before the Senate for a period of time not to 
     exceed eight hours, and in connection with the examination of 
     that witness, the House requests that either party be able to 
     examine the witness as if the witness were declared adverse, 
     that counsel for the President and counsel for the House 
     Managers be able to participate in the examination of that 
     witness, and that the House be entitled to reserve a portion 
     of its examination time to reexamine the witness following 
     any examination by the President.

  The CHIEF JUSTICE. The yeas and nays are automatic. The clerk will 
call the roll.
  The assistant legislative clerk called the roll.
  The yeas and nays resulted--yeas 30, nays 70, as follow:

                         [Rollcall Vote No. 10]

[Subject: Division II of House managers motion regarding appearance of 
                               witnesses]

                                YEAS--30

     Abraham
     Ashcroft
     Bond
     Bunning
     Burns
     Cochran
     Craig
     Crapo
     DeWine
     Fitzgerald
     Frist
     Gramm
     Grams
     Hagel
     Hatch
     Helms
     Hutchinson
     Inhofe
     Kyl
     Lott
     Lugar
     Mack
     McCain
     McConnell
     Murkowski
     Nickles
     Santorum
     Smith (NH)
     Specter
     Thompson

                                NAYS--70

     Akaka
     Allard
     Baucus
     Bayh
     Bennett
     Biden
     Bingaman
     Boxer
     Breaux
     Brownback
     Bryan
     Byrd
     Campbell
     Chafee
     Cleland
     Collins
     Conrad
     Coverdell
     Daschle
     Dodd
     Domenici
     Dorgan
     Durbin
     Edwards
     Enzi
     Feingold
     Feinstein
     Gorton
     Graham
     Grassley
     Gregg
     Harkin
     Hollings
     Hutchison
     Inouye
     Jeffords
     Johnson
     Kennedy
     Kerrey
     Kerry
     Kohl
     Landrieu
     Lautenberg
     Leahy
     Levin
     Lieberman
     Lincoln
     Mikulski
     Moynihan
     Murray
     Reed
     Reid
     Robb
     Roberts
     Rockefeller
     Roth
     Sarbanes
     Schumer
     Sessions
     Shelby
     Smith (OR)
     Snowe
     Stevens
     Thomas
     Thurmond
     Torricelli
     Voinovich
     Warner
     Wellstone
     Wyden
  The CHIEF JUSTICE. The Senate will be in order.
  On this vote, the yeas are 30, the nays are 70. Division II of the 
motion is not agreed to.
  The Chair recognizes the Senator from Washington, Mrs. Murray.


                   Murray Substitute for Division III

  Mrs. MURRAY. Mr. Chief Justice, I send a substitute for division III 
to the desk.
  The CHIEF JUSTICE. The clerk will report.
  The legislative clerk read as follows:

       The Senator from Washington, Mrs. Murray, moves that the 
     following shall be substituted for division III:
       I move that the parties be permitted to present before the 
     Senate, for a period of time not to exceed a total of six 
     hours, equally divided, all or portions of the parts of the 
     written transcriptions of the depositions of Monica S. 
     Lewinsky, Vernon E. Jordan, Jr., and Sidney Blumenthal.

  The CHIEF JUSTICE. Very well.
  The Parliamentarian advises me that there are 2 hours of argument on 
this motion. Who is the proponent?
  Mr. DASCHLE. Mr. Chief Justice, I ask unanimous consent that the time 
be yielded back.
  The CHIEF JUSTICE. Without objection, it is so ordered.
  I think the clerk should read division III, having read the proposed 
substitute.
  The legislative clerk read as follows:

       The House further moves that the parties be permitted to 
     present before the Senate, for a period of time not to exceed 
     a total of six hours, equally divided, all or portions of the 
     parts of the videotapes of the oral depositions of Monica S. 
     Lewinsky, Vernon E. Jordan, Jr., and Sidney Blumenthal 
     admitted

[[Page 1828]]

     into evidence, and that the House be entitled to reserve a 
     portion of its presentation time.

  The CHIEF JUSTICE. Now the clerk will read the substitute again.
  The legislative clerk read as follows:

       I move that the parties be permitted to present before the 
     Senate for a period of time not to exceed a total of six 
     hours, equally divided, all or portions of the parts of the 
     written transcriptions of the depositions of Monica S. 
     Lewinsky, Vernon E. Jordan, Jr., and Sidney Blumenthal.

  The CHIEF JUSTICE. The yeas and nays are automatic. The question is 
on the substitute. The clerk will call the roll.
  The legislative clerk called the roll.
  The yeas and nays resulted--yeas 27, nays 73, as follows:

                         [Rollcall Vote No. 11]

[Subject: Murray motion to substitute division III of the House motion]

                                YEAS--27

     Akaka
     Biden
     Bingaman
     Boxer
     Campbell
     Conrad
     Daschle
     Dodd
     Dorgan
     Harkin
     Inouye
     Johnson
     Kennedy
     Kerrey
     Landrieu
     Lautenberg
     Levin
     Lincoln
     Mikulski
     Murray
     Reed
     Reid
     Robb
     Rockefeller
     Sarbanes
     Snowe
     Torricelli

                                NAYS--73

     Abraham
     Allard
     Ashcroft
     Baucus
     Bayh
     Bennett
     Bond
     Breaux
     Brownback
     Bryan
     Bunning
     Burns
     Byrd
     Chafee
     Cleland
     Cochran
     Collins
     Coverdell
     Craig
     Crapo
     DeWine
     Domenici
     Durbin
     Edwards
     Enzi
     Feingold
     Feinstein
     Fitzgerald
     Frist
     Gorton
     Graham
     Gramm
     Grams
     Grassley
     Gregg
     Hagel
     Hatch
     Helms
     Hollings
     Hutchinson
     Hutchison
     Inhofe
     Jeffords
     Kerry
     Kohl
     Kyl
     Leahy
     Lieberman
     Lott
     Lugar
     Mack
     McCain
     McConnell
     Moynihan
     Murkowski
     Nickles
     Roberts
     Roth
     Santorum
     Schumer
     Sessions
     Shelby
     Smith (NH)
     Smith (OR)
     Specter
     Stevens
     Thomas
     Thompson
     Thurmond
     Voinovich
     Warner
     Wellstone
     Wyden
  The CHIEF JUSTICE. On this vote the yeas are 27, the nays are 73, and 
the motion is not agreed to.


                          Vote On Division III

  The CHIEF JUSTICE. The vote is now on the division III of the motion. 
The clerk will read division III.
  The assistant legislative clerk read as follows:

       Division III. The House further moves that the parties be 
     permitted to present before the Senate, for a period of time 
     not to exceed a total of six hours, equally divided, all or 
     portions of the parts of the videotapes of the oral 
     depositions of Monica S. Lewinsky, Vernon E. Jordan, Jr., and 
     Sidney Blumenthal admitted into evidence, and that the House 
     be entitled to reserve a portion of its presentation time.

  The CHIEF JUSTICE. The yeas and nays are automatic. The clerk will 
call the roll.
  The assistant legislative clerk called the roll.
  The yeas and nays resulted--yeas 62, nays 38, as follows:

                         [Rollcall Vote No. 12]

     [Subject: Division III of the House managers motion regarding 
                       presentation of evidence]

                                YEAS--62

     Abraham
     Allard
     Ashcroft
     Bennett
     Bond
     Breaux
     Brownback
     Bryan
     Bunning
     Burns
     Byrd
     Campbell
     Chafee
     Cochran
     Collins
     Coverdell
     Craig
     Crapo
     DeWine
     Domenici
     Enzi
     Feingold
     Fitzgerald
     Frist
     Gorton
     Gramm
     Grams
     Grassley
     Gregg
     Hagel
     Hatch
     Helms
     Hollings
     Hutchinson
     Hutchison
     Inhofe
     Kyl
     Lieberman
     Lott
     Lugar
     Mack
     McCain
     McConnell
     Moynihan
     Murkowski
     Nickles
     Roberts
     Roth
     Santorum
     Sessions
     Shelby
     Smith (NH)
     Smith (OR)
     Specter
     Stevens
     Thomas
     Thompson
     Thurmond
     Voinovich
     Warner
     Wellstone
     Wyden

                                NAYS--38

     Akaka
     Baucus
     Bayh
     Biden
     Bingaman
     Boxer
     Cleland
     Conrad
     Daschle
     Dodd
     Dorgan
     Durbin
     Edwards
     Feinstein
     Graham
     Harkin
     Inouye
     Jeffords
     Johnson
     Kennedy
     Kerrey
     Kerry
     Kohl
     Landrieu
     Lautenberg
     Leahy
     Levin
     Lincoln
     Mikulski
     Murray
     Reed
     Reid
     Robb
     Rockefeller
     Sarbanes
     Schumer
     Snowe
     Torricelli
  The CHIEF JUSTICE. On this vote, the yeas are 62, the nays are 38. 
Division III of the motion is agreed to.
  The CHIEF JUSTICE. The Chair recognizes the minority leader.


                 Motion to Proceed to Closing Arguments

  Mr. DASCHLE. I send a motion to the desk.
  The CHIEF JUSTICE. The clerk will report the motion.
  The legislative clerk read as follows:

       The Senator from South Dakota [Mr. Daschle] moves that the 
     Senate now proceed to closing arguments; that there be 2 
     hours for the White House Counsel followed by 2 hours for the 
     House Managers; and that at the conclusion of this time the 
     Senate proceed to vote, on each of the articles, without 
     intervening action, motion or debate, except for 
     deliberations, if so decided by the Senate.

  The CHIEF JUSTICE. The minority leader.
  Mr. DASCHLE. I ask unanimous consent that all time be yielded back.
  The CHIEF JUSTICE. In the absence of objection, it is so ordered. The 
yeas and nays are automatic. The clerk will call the roll.
  The legislative clerk called the roll.
  The yeas and nays resulted--yeas 44, nays 56, as follows:

                         [Rollcall Vote No. 13]

       [Subject: Daschle motion to proceed to closing arguments]

                                YEAS--44

     Akaka
     Baucus
     Bayh
     Biden
     Bingaman
     Boxer
     Breaux
     Bryan
     Byrd
     Cleland
     Conrad
     Daschle
     Dodd
     Dorgan
     Durbin
     Edwards
     Feinstein
     Graham
     Harkin
     Hollings
     Inouye
     Johnson
     Kennedy
     Kerrey
     Kerry
     Kohl
     Landrieu
     Lautenberg
     Leahy
     Levin
     Lieberman
     Lincoln
     Mikulski
     Moynihan
     Murray
     Reed
     Reid
     Robb
     Rockefeller
     Sarbanes
     Schumer
     Torricelli
     Wellstone
     Wyden

                                NAYS--56

     Abraham
     Allard
     Ashcroft
     Bennett
     Bond
     Brownback
     Bunning
     Burns
     Campbell
     Chafee
     Cochran
     Collins
     Coverdell
     Craig
     Crapo
     DeWine
     Domenici
     Enzi
     Feingold
     Fitzgerald
     Frist
     Gorton
     Gramm
     Grams
     Grassley
     Gregg
     Hagel
     Hatch
     Helms
     Hutchinson
     Hutchison
     Inhofe
     Jeffords
     Kyl
     Lott
     Lugar
     Mack
     McCain
     McConnell
     Murkowski
     Nickles
     Roberts
     Roth
     Santorum
     Sessions
     Shelby
     Smith (NH)
     Smith (OR)
     Snowe
     Specter
     Stevens
     Thomas
     Thompson
     Thurmond
     Voinovich
     Warner
  The CHIEF JUSTICE. On this vote the yeas are 44, the nays are 56, and 
the motion is not agreed to.
  The Chair recognizes the majority leader.
  Mr. LOTT. Mr. Chief Justice, I believe that was the last of the 
motions that had been offered.
  I am ready to go to the closing script unless there is some other 
motion pending or to be offered.
  Mr. Counsel RUFF. May I ask, Mr. Chief Justice, for indulgence for 
just a couple minutes to consult with my colleagues?
  Mr. LOTT. Mr. Chief Justice, I suggest the absence of a quorum.
  The CHIEF JUSTICE. The clerk will call the roll.
  The assistant legislative clerk proceeded to call the roll.
  Mr. LOTT. Mr. Chief Justice, I ask unanimous consent that the order 
for the quorum call be rescinded.
  The CHIEF JUSTICE. Without objection, it is so ordered.
  Mr. LOTT. Mr. Chief Justice, I believe that it is in order for White 
House counsel to offer a motion at this point. If they wish to do so, 
then I believe they could, then we would vote on that motion.
  The CHIEF JUSTICE. The Chair recognizes Mr. White House Counsel Ruff.
  Mr. Counsel RUFF. Thank you, Mr. Chief Justice.


              Motion to Provide Written Notice to Counsel

  Mr. Counsel RUFF. Mr. Majority Leader, I want to hand up to the desk 
a brief motion dealing with the presentation of videotape evidence on 
Saturday pursuant to the motion that has just been voted on by the 
Senate. If I may, I hand it up to the clerk.
  The CHIEF JUSTICE. The clerk will read the motion.
  The legislative clerk read as follows:

       Mr. Ruff moves that no later than 2:00 P.M. on Friday, 
     February 5, 1999, the Managers

[[Page 1829]]

     shall provide written notice to counsel for the President 
     indicating the precise page and line designations of any 
     video excerpts from the depositions of Monica Lewinsky, 
     Vernon Jordan or Sidney Blumenthal that they plan to use 
     during their three-hour presentation on Saturday, or during 
     their closing argument.

  The CHIEF JUSTICE. There are 2 hours equally divided on the motion.
  Mr. Counsel RUFF. Mr. Chief Justice, we won't use but a small 
percentage of that. I will turn the matter over, if I may, to my 
colleague, Mr. Kendall.
  The CHIEF JUSTICE. The Chair recognizes Mr. Counsel Kendall.
  Mr. Counsel KENDALL. Thank you, Mr. Chief Justice.
  Ladies and gentlemen of the Senate, House managers, I will be brief. 
This is simply a procedural motion which I think will make for a fairer 
hearing and a more efficient use of the Senate's time on Saturday.
  Fascinating though these depositions are, I don't think there is any 
need to inflict them on you repeatedly. What we are asking in this 
motion is simply a procedure that would be normal in a civil trial, and 
that is by a fair time tomorrow for the House managers to designate the 
portions of the three depositions that they intend to use. That will 
allow us not to repeat those portions, and it will give us some fair 
chance to organize our responsive presentation.
  The burden is on the House managers. I think this is not an extensive 
set of transcripts. I think it can be easily done. You have all, many 
of you, watched the depositions this week, read the transcripts. So I 
think if we can simply have this designation by 2 o'clock tomorrow, it 
will enable Saturday, perhaps, to be a shorter proceeding.
  The CHIEF JUSTICE. Counsel for House managers? The Chair recognizes 
Mr. Manager Rogan.
  Mr. Manager ROGAN. Mr. Chief Justice, thank you.
  I will imitate my colleague at the bar Mr. Kendall's brevity, if not 
his eloquence.
  I simply suggest this is somewhat a unique opportunity that counsel 
is inviting the House managers to engage in, to give counsel notice of 
page and line of transcripts for the presentation of evidence that we 
are going to make. It is our prerogative to put on our evidence; it is 
White House counsel's opportunity to put on their evidence. Asking us 
to choreograph that for them and with them is something that I am 
unfamiliar with, except for one time.
  I remember during my days as a judge in California that a similar 
request was made for me, and a law clerk pointed out to me language 
from one of the late great justices of the California Supreme Court, 
Otto Kaus. Apparently, a similar request was made to Justice Kaus to do 
the same thing in a case, and Justice Kaus looked at the lawyer making 
the request and he said, ``I believe the appropriate legal response to 
your request is that it is none of your damn business what the other 
side is going to put on.''
  With that, Mr. Chief Justice, we will yield back the balance of our 
time.
  The CHIEF JUSTICE. Mr. Kendall.
  Mr. Counsel KENDALL. That philosophy might want to be emulated at 
some point by the drafters of the Federal Civil Rules, but it is not. 
In every Federal civil trial, this procedure is followed, the 
designation, the identifying, and designating of deposition excerpts.
  Again, I think it will make for a fairer and more efficient 
proceeding. I don't think trial by surprise has a place here.
  The CHIEF JUSTICE. The vote is on the motion.
  The clerk will read the motion.
  The legislative clerk read as follows:

       Mr. Ruff moves that no later than 2:00 P.M. on Friday, 
     February 5, 1999, the Managers shall provide written notice 
     to counsel for the President indicating the precise page and 
     line designations of any video excerpts from the depositions 
     of Monica Lewinsky, Vernon Jordan or Sidney Blumenthal that 
     they plan to use during their three-hour presentation on 
     Saturday, or during their closing argument.

  Mr. BYRD. Mr. Chief Justice, may we have order.
  The CHIEF JUSTICE. I fully agree with the Senator.
  Mr. BYRD. Would the clerk read that again.
  The CHIEF JUSTICE. Let the Senate remain in order and let the clerk 
read the motion again.
  The legislative clerk read as follows:

       Mr. Ruff moves that no later than 2:00 P.M. on Friday, 
     February 5, 1999, the Managers shall provide written notice 
     to counsel for the President indicating the precise page and 
     line designations of any video excerpts from the depositions 
     of Monica Lewinsky, Vernon Jordan or Sidney Blumenthal that 
     they plan to use during their three-hour presentation on 
     Saturday, or during their closing argument.

  The CHIEF JUSTICE. The yeas and nays are automatic. The clerk will 
call the roll.
  The assistant legislative clerk called the roll.
  (Disturbance in the Visitors' Galleries.)
  The CHIEF JUSTICE. The Sergeant at Arms will restore order to the 
gallery.
  The assistant legislative clerk continued with the call of the roll.
  The yeas and nays resulted--yeas 46, nays 54, as follows:

                         [Rollcall Vote No. 14]

                [Subject: White House Counsels' motion]

                                YEAS--46

     Akaka
     Baucus
     Bayh
     Biden
     Bingaman
     Boxer
     Breaux
     Bryan
     Byrd
     Cleland
     Conrad
     Daschle
     Dodd
     Dorgan
     Durbin
     Edwards
     Feingold
     Feinstein
     Graham
     Harkin
     Hollings
     Inouye
     Jeffords
     Johnson
     Kennedy
     Kerrey
     Kerry
     Kohl
     Landrieu
     Lautenberg
     Leahy
     Levin
     Lieberman
     Lincoln
     Mikulski
     Moynihan
     Murray
     Reed
     Reid
     Robb
     Rockefeller
     Sarbanes
     Schumer
     Torricelli
     Wellstone
     Wyden

                                NAYS--54

     Abraham
     Allard
     Ashcroft
     Bennett
     Bond
     Brownback
     Bunning
     Burns
     Campbell
     Chafee
     Cochran
     Collins
     Coverdell
     Craig
     Crapo
     DeWine
     Domenici
     Enzi
     Fitzgerald
     Frist
     Gorton
     Gramm
     Grams
     Grassley
     Gregg
     Hagel
     Hatch
     Helms
     Hutchinson
     Hutchison
     Inhofe
     Kyl
     Lott
     Lugar
     Mack
     McCain
     McConnell
     Murkowski
     Nickles
     Roberts
     Roth
     Santorum
     Sessions
     Shelby
     Smith (NH)
     Smith (OR)
     Snowe
     Specter
     Stevens
     Thomas
     Thompson
     Thurmond
     Voinovich
     Warner
  The CHIEF JUSTICE. On this vote, the yeas are 46, the nays are 54. 
The motion is rejected.


      Orders for Saturday, February 6 and Monday, February 8, 1999

  Mr. LOTT. Mr. Chief Justice, I believe that completes all the 
motions. Therefore, I ask unanimous consent that when the Senate 
completes its business today, it stand in adjournment until 10 a.m. on 
Saturday, February 6, and at 10 a.m. on Saturday, immediately following 
the prayer, the Senate will resume consideration of the articles of 
impeachment. I further ask consent that on Saturday there be 6 hours 
equally divided between the House managers and White House counsel for 
presentations. I further ask that following those presentations on 
Saturday, the Senate then adjourn until 1 p.m. on Monday, February 8. I 
finally ask consent that on Monday, immediately following the prayer, 
the Senate resume consideration of the articles of impeachment, and 
there then be 6 hours equally divided between the managers and White 
House counsel for final arguments.
  Mr. LEAHY. Mr. Chief Justice, reserving the right to object, and I 
shall not, I ask the distinguished leader this. We have had exhibits 
handed out today to be printed in the Congressional Record, referring 
to depositions which, I understand under rule XXIX, are still 
confidential. Are those to be printed in the Record?
  Mr. LOTT. I will ask consent that the transcripts of the depositions 
be printed in the Record of today's date.
  Mr. LEAHY. The exhibits were handed out today in debate. Were they 
handed out under rule XXIX?
  Mr. LOTT. I believe we got approval that they be used in the oral 
presentations at the beginning of the session today.
  Mr. LEAHY. I withdraw any objection.

[[Page 1830]]


  Mr. CHIEF JUSTICE. Objection has been heard.
  Mr. LEAHY. Mr. Chief Justice, I withdrew any objection.
  Mr. KERRY addressed the Chair.
  The CHIEF JUSTICE. The Senator from Massachusetts, Mr. Kerry, is 
recognized.
  Mr. KERRY. Mr. Chief Justice, reserving the right to object. I ask 
the majority leader, is there an assumption that if White House counsel 
were to want sufficient time on Saturday in order to be able to present 
video testimony countering whatever surprise video--and there may or 
may not be a surprise--would they have time to be able to provide that 
on Saturday--not to carry over, but merely if they choose to, to do 
that on Saturday?
  Mr. LOTT. I am not sure I understand the question, except that we 
will come in at 10, and we will have 6 hours equally divided. I presume 
that the House would make a presentation first and then the White House 
and then close. There would be time during that 6-hour period for the 
White House to use it as they see fit. Are you asking that there would 
be some sort of break so they would be able to consider that?
  Mr. KERRY. Clearly, the purpose of the trial and the purpose of this 
effort is to have a fair presentation of evidence. The Senate now 
having denied notice to White House counsel of what areas may be the 
subject of video, it might be that the voice of the witnesses 
themselves is the best response to whatever it is that the House were 
to present. If they were to decide----
  Mr. BROWNBACK. Mr. Chief Justice, I call for the regular order.
  The CHIEF JUSTICE. The regular order has been called for. There is a 
unanimous consent request pending. Is there objection?
  Mr. LOTT. Mr. Chief Justice, briefly, if I could say on behalf of my 
unanimous consent, and in brief response to the question, we have all 
worked hard and bent over backward trying to be fair. I am sure if 
there is something that would be needed on Saturday, it would be 
carefully considered by both sides.
  Mr. KERRY. Mr. Chief Justice, I suggest the absence of a quorum.
  Mr. GRAMM. A quorum is present.
  The CHIEF JUSTICE. The majority leader has the floor.
  Mr. LOTT. Mr. Chief Justice, I believe it would be appropriate to go 
ahead and get this unanimous consent agreement. We will continue to 
work with both sides to try to make sure there is a fair way to proceed 
on Saturday. We will have the remainder of today and tomorrow to work 
on that. So I would like to renew my unanimous consent request.
  The CHIEF JUSTICE. Is there objection?
  Mr. BOND. Mr. Chief Justice, reserving the right to object. May I 
inquire of the majority leader if that Saturday time schedule gives 
both parties adequate time to prepare for the presentation of the 
evidence? Have both sides agreed that they will be prepared?
  Mr. LOTT. Mr. Chief Justice, as best I can respond to that, I just 
say that hopefully both sides have had more than adequate time 
allocated on Saturday. One of the reasons we are doing it this way--
Saturday instead of tomorrow--is so both sides will have an opportunity 
to review everything and hopefully communicate with each other. We will 
do that Friday during the day so that an orderly presentation can be 
made by both sides on Saturday. I believe we are seeing a problem here 
where there may not be one.
  But if one develops certainly we would take it into consideration.
  Mr. Chief Justice, I renew my request.
  The CHIEF JUSTICE. Is there objection? In the absence of objection, 
it is so ordered.
  Mr. LOTT. Mr. Chief Justice, I ask unanimous consent that those parts 
of the transcripts of the depositions admitted into evidence be printed 
in the Congressional Record of today's date.
  I further ask consent that the deposition transcripts of Monica 
Lewinsky, Vernon Jordan, and Sidney Blumenthal, and the videotapes 
thereof, be immediately released to the managers on the part of the 
House and the counsel to the President for the purpose of preparing 
their presentations, provided, however, that such copies shall remain 
at all times under the supervision of the Sergeant at Arms to ensure 
compliance with the confidentiality provisions of S. Res. 30.
  The CHIEF JUSTICE. In the absence of objection, it is so ordered.
  The material follows:

    In the Senate of the United States Sitting for the Trial of the 
   Impeachment of William Jefferson Clinton, President of the United 
                                 States


           excerpts of video deposition of monica s. lewinsky

              (Monday, February 1, 1999, Washington, D.C.)

       SENATOR DeWINE: If not, I will now swear the witness.
       Ms. Lewinsky, will you raise your right hand, please?
       Whereupon, MONICA S. LEWINSKY was called as a witness and, 
     after having been first duly sworn by Senator DeWine, was 
     examined and testified as follows:
       SENATOR DeWINE: The House Managers may now begin your 
     questioning.
       MR. BRYANT: Thank you, Senator.
       Good morning to all present.


                     examination by house managers

       BY MR. BRYANT:
       Q. Ms. Lewinsky, welcome back to Washington, and I wanted 
     to just gather a few of our friends here to have this 
     deposition now. We do have quite a number of people present, 
     but we--in spite of the numbers, we do want you to feel as 
     comfortable as possible because I think we--everyone present 
     today has an interest in getting to the truth of this matter, 
     and so as best as you can, we would appreciate your answers 
     in a--in a truthful and a fashion that you can recall. I know 
     it's been a long time since some of these events have 
     occurred.
       But for the record, would you state your name once again, 
     your full name?
       A. Yes. Monica Samille Lewinsky.
       Q. And you're a--are you a resident of California?
       A. I'm--I'm not sure exactly where I'm a resident now, but 
     I--that's where I'm living right now.
       Q. Okay. You--did you grow up there in California?
       A. Yes.
       Q. I'm not going to go into all that, but I thought just a 
     little bit of background here.
       You went to college where?
       A. Lewis and Clark, in Portland, Oregon.
       Q. And you majored in--majored in?
       A. Psychology.
       Q. Tell me about your work history, briefly, from the time 
     you left college until, let's say, you started as an intern 
     at the White House.
       A. Uh, I wasn't working from the time I--
       Q. Okay. Did you--
       A. I graduated college in May of '95.
       Q. Did you work part time there in--in Oregon with a--with 
     a District Attorney--
       A. Uh--
       Q. --in his office somewhere?
       A. During--I had an internship or a practicum when I was in 
     school. I had two practicums, and one was at the public 
     defender's office and the other was at the Southeast Mental 
     Health Network.
       Q. And those were in Portland?
       A. Yes.
       Q. Okay. What--you received a bachelor of science in 
     psychology?
       A. Correct.
       Q. Okay. As a part of your duties at the Southeast Health 
     Network, what did you--what did you do in terms of working? 
     Did you have direct contact with people there, patients?
       A. Yes, I did. Um, they referred to them as clients there 
     and I worked in what was called the Phoenix Club, which was a 
     socialization area for the clients to--really to just hang 
     out and, um, sort of work on their social skills. So I--
       Q. Okay. After your work there, you obviously had occasion 
     to come to work at the White House. How did--how did you come 
     to decide you wanted to come to Washington, and in particular 
     work at the White House?
       A. There were a few different factors. My mom's side of the 
     family had moved to Washington during my senior year of 
     college and I wanted--I wasn't ready to go to graduate school 
     yet. So I wanted to get out of Portland, and a friend of our 
     family's had a grandson who had had an internship at the 
     White House and had thought it might be something I'd enjoy 
     doing.
       Q. Had you ever worked around--in politics and campaigns or 
     been very active?
       A. No.
       Q. You had to go through the normal application process of 
     submitting a written application, references, and so forth 
     to--to the White House?
       A. Yes.
       Q. Did you do that while you were still in Oregon, or were 
     you already in D.C.?
       A. No. The application process was while I was a senior in 
     college in Oregon.
       Q. Had you ever been to Washington before?
       A. Yes.
       Q. Obviously, you were accepted, and you started work when?

[[Page 1831]]

       A. July 10th, 1995.
       Q. Where--where were you assigned?
       A. The Chief--
       Q. Physically, where were you located?
       A. Oh, physically?
       Q. Yes.
       A. Room 93 of the Old Executive Office Building.
       Q. Were you designated in any particular manner in terms 
     of--were all interns the same, I guess would be my question?
       A. Yes and no. We were all interns, but there were a select 
     group of interns who had blue passes who worked in the White 
     House proper, and most of us worked in the Old Executive 
     Office Building with a pink intern pass.
       Q. Now, can you explain to me the significance of a pink 
     pass versus a blue pass?
       A. Sure.
       Q. Okay. Is it--is it access?
       A. Yes.
       Q. To what?
       A. A blue pass gives you access to anywhere in the White 
     House and a pink intern pass gives you access to the Old 
     Executive Office Building.
       Q. Did interns have blue passes?
       A. Yes, some.
       Q. Some did, and some had pink passes?
       A. Correct.
       Q. And you had the pink?
       A. Correct.
       Q. How long was your internship?
       A. It was from July 'til the end of August, and then I 
     stayed on for a little while until the 2nd.
       Q. Are most interns for the summertime--you do part of the 
     summer or the entire summer?
       A. I believe there are interns all year-round at the White 
     House.
       Q. Now, you as an intern, you are unpaid.
       A. Correct.
       Q. And tell--tell me how you came to, uh, through your 
     decisionmaking process, to seek a paid position and stay in 
     Washington.
       A. Uh, there were several factors. One is I came to enjoy 
     being at the White House, and I found it to be interesting. I 
     was studying to take the GREs, the entrance exam for graduate 
     school, and needed to get a job. So I--since I had enjoyed my 
     internship, my supervisor at the time, Tracy Beckett, helped 
     me try and secure a position.
       Q. Now, you mentioned the pink pass that you had. So you 
     were able to--I don't want to presume--you were able to get 
     into the White House on occasion even with a pink pass?
       A. The--do you mean the White House proper, or--
       Q. Yes, the White House--
       A. --the complex?
       Q. Yes. Let me be clear. When I--I tend to say ``White 
     House''--I mean the actual building itself. And I know 
     perhaps you think of the whole complex in terms of the 
     whole--
       A. I'm sorry. Just to be clear--
       Q. Yes.
       A. --do you mean the West Wing and the residence and--
       Q. Right.
       A. --the East Wing when you say the White House?
       Q. Right. The White House where the President lives, and 
     works, I guess, right.
       A. I'm sorry. Can you repeat the question?
       Q. Yes, yes. I mean that White House. As an intern, you had 
     a pink pass that did allow you to have access to that White 
     House where the President was on occasion?
       A. No.
       Q. Did not. Did you have--did you ever get in there as an 
     intern?
       A. Yes.
       Q. And under--under what circumstances?
       A. It--
       Q. Did you have to be accompanied by someone, or--
       A. Exactly; someone with a blue pass.
       Q. So how did you--once you decided you wanted to stay in 
     Washington and find a paying job, you sought out some help 
     from friends there, people you knew, contacts, and you were--
     you did--you were successful?
       A. Correct.
       Q. And you were hired where--where in the White House?
       A. In Legislative Affairs.
       Q. Now, again, to educate me on this, in that group, in 
     that section, department, you would have worked where, 
     physically?
       A. Physically, in the East Wing.
       Q. Okay, and as an intern before, you worked in the Old 
     Executive Office Building?
       A. Correct.
       Q. But you moved about and occasionally would go into the 
     White House, if escorted?
       A. Correct.
       Q. It takes a while, but I'll get there with you; I'll 
     catch up.
       When did you actually--what was your first day on the job 
     with the Legislative Affairs, uh, group?
       A. Um, first day on the job was sometime after the 
     furlough. I was hired right before the furlough, but the 
     paperwork hadn't gone through, so first day on the job was 
     some point after the furlough. I don't remember the exact 
     date.
       Q. So you remained, uh, on as an intern during the 
     furlough--
       A. Correct.
       Q. --the Government shutdown period.
       A. Correct.
       Q. And that was in November of 1995, some date during that?
       A. Yes.
       Q. Okay. Um, tell me how you, um, began--I guess the--the--
     we're going to talk about a relationship with the President. 
     Uh, when you first, uh, I guess, saw him, I think there was 
     some indication that you didn't speak to him maybe the first 
     few times you saw him, but you had some eye contact or sort 
     of smiles or--
       A. I--I believe I've testified to that in the grand jury 
     pretty extensively.
       Q. Uh-huh.
       A. Is--is there something more specific?
       Q. Well, again, I'm wanting to know times, you know, how 
     soon that occurred and sort of what happened, you know, if 
     you can--you know, there are going to be occasions where 
     you--obviously, you testified extensively in the grand jury, 
     so you're going to obviously repeat things today. We're doing 
     the deposition for the Senators to view, we believe, so 
     it's--
       MR. CACHERIS: May I note an objection. The Senators have 
     the complete record, as you know, Mr. Bryant, and she is 
     standing on her testimony that she has given on the occasions 
     that Mr. Stein alluded to at the introduction of this 
     deposition.
       MR. BRYANT: Well, I appreciate that, but, uh, if this is 
     going to be the case, we don't even need the deposition, 
     because we're limited to the record and everything is in the 
     record. So I think, uh, to be fair, we're--we're obviously 
     going to have to talk about, uh, some things for 8 hours 
     here, or else we can go home.
       THE WITNESS: Sounds good to me.
       [Laughter.]
       MR. BRYANT: I think we probably all would like to do that.
       SENATOR DeWINE: Counsel, are you objecting to the question?
       MR. CACHERIS: Yes. I'm objecting to him asking specific 
     questions that are already in the record that--he has said 
     they are limited to the record, and so we accept his, his 
     designation. We're limited to the record.
       SENATOR DeWINE: We're going to go off the record for just a 
     moment.
       THE VIDEOGRAPHER: We're going off the record at 9:37 a.m.
       [Recess.]
       THE VIDEOGRAPHER: We are going back on the record at 9:45 
     a.m.
       SENATOR DeWINE: We are now back on the record.
       The objection is noted, but it's overruled, and the witness 
     is instructed to answer the question.
       Senator Leahy?
       SENATOR LEAHY: And I had noted during the break that 
     obviously, the witness has 48 hours to correct her 
     deposition, and would also note that when somebody has 
     testified to some of these things 20 or more times that it is 
     not unusual to have some nuances different, and that could 
     also be reflected in time to correct her testimony.
       And I had also noted when we were off the record Mr. 
     Manager Bryant's comment on January 26th, page S992 in the 
     Congressional Record, in which he said: ``If our motion is 
     granted, I want to make this very, very clear. At no point 
     will we ask any questions of Monica Lewinsky about her 
     explicit sexual relationship with the President, either in 
     deposition or, if we are permitted on the floor of the 
     Senate, they will not be asked.''
       And I should add also, to be fair to Mr. Bryant, another 
     sentence in that: ``That, of course, assumes that White House 
     Counsel does not enter into that discussion, and we doubt 
     that they would.'' Period, close quote.
       SENATOR DeWINE: Let me just add something that I stated to 
     counsel and to Ms. Lewinsky off the record, and I think I 
     will briefly repeat it, and that is that counsel is entitled 
     to an answer to the question, but Ms. Lewinsky certainly can 
     reference previous testimony if she wishes to do that. But 
     counsel is entitled to a new explanation of--of what 
     occurred.
       Counsel, you may--why don't you re-ask the question, and we 
     will proceed.
       MR. BRYANT: May I, before I do that, ask a procedural 
     question in terms of timekeeping?
       SENATOR DeWINE: The time is not counted--any of the time 
     that you have--once there is an objection, none of the time 
     is counted until we rule on the objection and until you then 
     have the opportunity to ask the question again. So the time 
     will start now.
       MR. BRYANT: Very good.
       BY MR. BRYANT:
       Q. Ms. Lewinsky, again, let me--I know this is difficult, 
     but let me apologize that, uh, that it is going to be 
     necessary that I ask you these questions because we're 
     limited to the record and if we--we can't ask you any new 
     questions outside that record, so I have to talk about what's 
     in the record. And I realize you've answered all these 
     questions several times before, but it's, uh--I'm sincere 
     that we really wouldn't need to take your deposition if we 
     couldn't ask you those kinds of questions. So it's not 
     motivated to cause you uncomfort or to make you sit here in 
     Washington when you'd rather be in California. We'll try to 
     get through this as quickly as we can.
       But we were talking about when you were first assigned 
     there at the White House and those initial contacts, and I 
     mean, again, when you were--you would see the President.

[[Page 1832]]

     I think you've mentioned you would--there was some mild 
     flirting going on; you would smile or you would make eye 
     contact. It was something of this nature?
       A. Yes.
       Q. And the first--was the first time you actually spoke to 
     the President or he spoke to you, other than perhaps a hello 
     in the hallway, was that on November the 15th, 1995?
       A. Yes.
       Q. And that was--that was the day, uh, of the first so-
     called salacious encounter, the same day?
       A. Yes.
       Q. Now, when the President gave a statement testifying 
     before the grand jury, he--he described that relationship as 
     what I considered sort of an evolving one. He says: ``I 
     regret that what began as a friendship came to include this 
     conduct.'' And he goes on to take full responsibility for his 
     actions. But that almost sounds as if this was an evolving--
     something from a friendship evolving over time to a sexual 
     relationship. That was not the case, was it?
       A. I--I can't really comment on how he perceived it. My 
     perception was different.
       Q. Okay--
       A. But I--I--I mean, I don't feel comfortable saying that 
     he didn't, that he didn't see it that way, or that's wrong; 
     that's how he saw it. I--
       Q. But you saw it a different way?
       A. Yes.
       Q. Now, on November the 15th, had you already accepted this 
     job with Legislative Affairs?
       A. Yes.
       Q. And, uh, was--that was during the shutdown, so you had 
     no job to go to because the Government was shut down.
       A. No. I accepted it on the Friday before the furlough.
       Q. And that--
       A. But the paperwork hadn't gone through.
       Q. Okay. Did, uh--when you first met with the President on 
     November the 15th, did he say anything to you that would 
     indicate that he knew you were an intern?
       A. No.
       Q. Did he make a comment about your, your pink security 
     badge?
       A. Can I ask my counsel a question real quickly, please?
       [Witness conferring with counsel.]
       MR. CACHERIS: Okay, Mr Bryant.
       THE WITNESS: Sorry. It was--that occurred in the second 
     encounter of that evening.
       BY MR. BRYANT:
       Q. Okay. On November--
       A. So, not the first encounter.
       Q. On November the 15th, 1995?
       A. Correct.
       Q. What--do you recall what he said or what he did in 
     regard to the intern pass?
       A. He tugged on my pass and said: ``This is going to be a 
     problem.''
       Q. And what did, uh--did he say anything else about what he 
     meant by ``problem''?
       A. No.
       Q. Tell me about your job at Legislative Affairs. Did that 
     involve going into the White House itself?
       A. Yes. My job was in the White House.
       Q. You were in one wing, but did that involve going--did it 
     give you access--
       A. Yes.
       Q. --pretty well throughout the White House?
       A. Yes.
       Q. What did you do primarily?
       A. I worked under Jocelyn Jolly, who supervised the letters 
     that came from the Hill; so the opening of those letters and 
     reading them and vetting them and preparing responses for the 
     President's signature--responding.
       Q. Now, you've indicated through counsel at the beginning 
     that you are willing to affirm, otherwise adopt, your sworn 
     testimony of August the 6th and August the 20th, I think, 
     which would be grand jury, and the deposition of August the 
     26th, 1998.
       A. Correct.
       Q. So you're saying that that information is accurate, and 
     it is truthful?
       A. Yes.
       Q. Well, thank you. That--that will save us a little bit of 
     time, but certainly we will ask you some of that information 
     also.
       At some point, you were transferred to the Pentagon, to the 
     Department of Defense. When did that occur?
       A. I found out I was being transferred on April 5th, 1996.
       Q. Did you want to go--
       A. No.
       Q. --to the Department of Defense? Did you have a 
     discussion with the President about this?
       A. Yes.
       Q. What was your reaction to being transferred?
       A. I started to cry.
       Q. Did you talk to anyone else at the White House other 
     than the President about the transfer at that time?
       A. Yes.
       Q. And who--who was that?
       A. I spoke with several people. I--I can't--I know I--I 
     spoke with, uh, Jocelyn about it. I spoke with people with 
     whom I was friendly at the White House. I spoke to Betty, 
     Nancy Hernreich, several people.
       Q. Did you--did you find out why you were being 
     transferred?
       A. Uh, I was told why I was being transferred by Mr. 
     Keating on Friday, the 5th of April.
       Q. And that was why?
       A. Uh, he said that the--the Office of Administration, I 
     think it was, was not pleased with the way the correspondence 
     was being handled, and they were, quote-unquote, ``blowing 
     up'' the Correspondence Office, and that I was being 
     transferred and it had nothing to do with my work.
       Q. Did you have any understanding that it might have been 
     other reasons that you were being moved?
       A. Not at that point.
       Q. Did the--what did the President say about your transfer 
     at that point?
       A. He thought it had something to do with our relationship.
       Q. What else did he say about--about your transfer, if 
     anything? Did he give you any assurances that you might be 
     back, or--
       A. Yes.
       Q. Back after what time period?
       A. He promised me he'd bring me back after the election.
       Q. So this was, again, in early 19--April of 1996, and he 
     was up for reelection--
       A. Yes.
       Q. --in November of 1996.
       A. Yes.
       Q. Did you attach any significance to being transferred 
     away before the election and then him assuring you he would 
     bring you back after the election? Did you attach any 
     significance to the election and your having to leave?
       A. Emotional significance, yes.
       Q. Your emotion? I'm--I'm not sure I follow you. You were--
       A. Well, yes, I attached significance to it.
       Q. And that was emotional--
       A. But that was emotional.
       Q. But the reason you both felt--again, I'm not trying to 
     put words in your mouth, but you both felt you were leaving 
     until after the election was because of your relationship and 
     perhaps people finding out?
       A. No. I--I--first, I can only speak for myself. I mean, I, 
     uh, my understanding initially was that it was, um, for work-
     related issues, but not my work, and I came to understand 
     later that it was having to do with my relationship with the 
     President.
       Q. Okay. Did, uh, you have a conversation--and it may be 
     the same one with the President on April the 12th--which 
     determined that Ms. Lieberman maybe spearheaded your transfer 
     because you were paying too much attention--you were all--you 
     were both paying too much attention to each other and she was 
     worried that it was close to election time? And I think 
     you've testified to that, haven't you?
       A. Yes.
       Q. Okay, good. You started, uh, with the Department of 
     Defense at the Pentagon in mid-April, April the 17th, 1996?
       A. Yes.
       Q. What did you do there?
       A. I was the confidential assistant to Mr. Bacon, who is 
     the Assistant Secretary of Defense for Public Affairs.
       Q. Did, uh--after the 1996 election, did you still want to 
     go back to the White House?
       A. Yes.
       Q. You had not fallen in love with the job at the Pentagon 
     that much?
       A. No.
       Q. Was that, in fact, a frustrating period of time?
       A. Yes. No offense to Mr. Bacon, of course.
       Q. I understand; I'm sure he would take none.
       I would like--I don't think it's been mentioned, but you 
     helped in preparing a chart which we have listed as one of 
     our exhibits, ML Number 2, which I assume might have a 
     different number for now, but it's a chart of contacts--
       A. Right.
       Q. --that you had with the President. And do you have a 
     copy of that chart? It--
       [Witness conferring with counsel.]
       MR. BRYANT: In the--yes, in the record, it's at page 1251.
       MR. BURTON: May we have an extra copy for counsel, please?
       BY MR. BRYANT:
       Q. Have you had occasion to review this document?
       A. Yes.
       Q. And very--very simply, I would like for you to, uh, if 
     you can, to affirm that document as an accurate 
     representation and a truthful representation of all the 
     contacts that you had with the President from approximately 
     August 9th, 1995 until January of 1998. It includes in-person 
     contacts, telephone calls, gifts and notes exchanged, I think 
     are the categories.
       A. Yes. I believe there might have been one or two changes 
     that were made and noted in the grand jury or my deposition, 
     and I adopt those as well.
       MR. BRYANT: Okay, good.
       I am not going to at this point make her--the information 
     she adopts and affirms exhibits to this deposition. I don't 
     want to clutter it any more unless someone wants to make this 
     an exhibit in terms of your deposition testimony, your grand 
     jury testimony, and now the charts that you have affirmed, so 
     I just want you to specifically affirm it but not make it an 
     exhibit, because it's already a part of the record.

[[Page 1833]]

       MR. CACHERIS: We defer to the White House.
       MS. SELIGMAN: I just wanted to make clear on the record, 
     then, what the app. or sub-cite is of anything we're adopting 
     so that we all know what particular pages it is.
       MR. BRYANT: Okay. And that, again, was, I think, page 1251 
     of--right, of the record.
       SENATOR LEAHY: I don't--I don't understand.
       MS. MILLS: Can you cite the ending page?
       SENATOR DeWINE: Counsel, is that where this appears?
       MR. BRYANT: It appears in the record, uh--
       SENATOR DeWINE: You need to designate also if you're 
     talking about the Senate record or--I think at this point 
     we'll go off the record.
       THE VIDEOGRAPHER: We're going off the record at 10:01 a.m.
       [Recess.]
       THE VIDEOGRAPHER: We are going back on the record at 10:11 
     a.m.
       SENATOR DeWINE: Let me--we're now back on the record.
       Let me advise counsel, the Managers, that they have used 25 
     minutes so far.
       You may resume questioning, and if you could begin by 
     identifying the exhibit for the record, please.
       MR. BRYANT: Tom, let me also for clarification purposes--
     Tom, on the referral to the Senate record, you're saying that 
     the appendices are numbered 3, but the numbers are the same. 
     The page numbers are the same.
       MR. GRIFFITH: Yes.
       MR. BRYANT: And the supplemental materials are your Volume 
     IV, but, again, the pages are the same.
       MR. GRIFFITH: That's our understanding.
       MR. BRYANT: Okay. For the record, then, using the Senate 
     volumes, if this is an appendices, Volume III, and the chart 
     that we just alluded to before the break is--appears at pages 
     116 through 126 of the Senate record, Volume III.
       BY MR. BRYANT:
       Q. Ms. Lewinsky, did you tell a number of people in varying 
     details about your relationship with the President?
       A. Yes.
       Q. Can you tell us who did you tell?
       A. Catherine Allday Davis, Neysa Deman Erbland, Natalie 
     Ungvari, Ashley Raines, Linda Tripp, Dr. Kathy Estep, Dr. 
     Irene Kassorla, Andy Bleiler, my mom, my aunt. Who else has 
     been subpoenaed?
       Q. Okay. Let me suggest Dale--did you mention Dale Young?
       A. Dale Young. I'm sorry.
       Q. Thank you.
       Now, in the floor presentation, Mr. Craig, who was one of--
     is one of the counsel for the President, adopted an argument 
     that had been raised in some of the previous hearings, uh, 
     and he adopted this argument in the Senate that--that you 
     have--have or had, I think, both past and present, the 
     incentive to not tell the truth about how the President--this 
     relationship with him because you wanted to avoid--and again, 
     I use the quote from Mr. Craig's argument--the demeaning 
     nature of providing wholly un-reciprocated sex.
       Did, uh--did you lie before the grand jury and to your 
     friends about the nature of that relationship with the 
     President--
       A. No.
       Q. --so as to avoid what Mr. Craig says? Okay, and I'll 
     break it down.
       SENATOR DeWINE: Counsel, do you want to just--just rephrase 
     the question?
       MR. BRYANT: Okay. We'll break it down into two questions.
       BY MR. BRYANT:
       Q. Did you not tell the truth before the grand jury as to 
     how the President touched you because of what Mr. Craig 
     alleges as the demeaning nature of the wholly un-reciprocated 
     sex?
       MR. CACHERIS: Well, that--may I register an objection, 
     gentlemen? This witness is not here to comment on what some 
     lawyer said on the floor of the Senate. He can ask her direct 
     questions. She will answer them, but what Mr. Craig said or 
     didn't say would have happened after her grand jury 
     testimony. So it's totally inappropriate that he's--
       SENATOR DeWINE: Mr. Bryant, why don't you--
       MR. CACHERIS: --marrying those two concepts. We object.
       SENATOR DeWINE: Mr. Bryant, why don't you just rephrase the 
     question?
       MR. BRYANT: Well, we--we have had presented on behalf of 
     the President a defense, an incentive, a reason why she would 
     not tell the truth, and I think she should have the 
     opportunity to respond to that--that allegation.
       MR. CACHERIS: We--we don't, uh--
       SENATOR LEAHY: Ask her a direct question.
       MR. CACHERIS: We welcome you asking her if her testimony 
     was truthful, and she will tell you that it is truthful. We 
     don't have any problem with that. We don't have any brief 
     with what the White House did or didn't do through their 
     counsel. That's their business. We don't represent the White 
     House.
       MS. SELIGMAN: So, for the record, I'd like to object to the 
     characterization of what Mr. Craig says, which obviously 
     speaks for itself, but I certainly don't want my silence to 
     be construed as accepting the Manager's characterization of 
     it.
       SENATOR DeWINE: Mr. Bryant, why don't you--why don't you 
     ask the question?
       MR. BRYANT: Okay.
       SENATOR DeWINE: Go ahead and ask your question.
       BY MR. BRYANT:
       Q. In regard to your testimony at the grand jury about 
     your--your relationship and the physical contact that you 
     have said occurred in some of these, uh, visits with the 
     President, it has been characterized in a way that would give 
     you an excuse not to tell the truth. Did you tell the truth 
     in the grand jury about what actually happened and how the 
     President touched--the President touched you?
       A. Yes.
       Q. And did you likewise tell the truth to your friends in 
     connection with the same matters?
       A. Yes.
       Q. Did your relationship with the President involve giving 
     gifts, exchanging gifts?
       A. Yes.
       Q. And you mentioned earlier that in reference to this 
     chart that it was, uh, subject to certain corrections you've 
     made in later testimony. It was an accurate representation or 
     an accurate compilation of the gifts that, uh, you gave the 
     President and the President gave you. Is that correct?
       A. Yes.
       Q. Approximately how many gifts did you give the President?
       A. I believe I've testified to that number. I don't recall 
     right now.
       Q. About 30? Would that be--
       A. If that's what I testified to, then I accept that.
       Q. That's the number I have, and do you recall how many 
     gifts approximately the President gave you?
       A. It would be the same situation.
       Q. Okay, and you've previously testified in your grand jury 
     that he gave you about 18 gifts.
       A. I accept that.
       Q. Okay, good. What types of gifts did you give the 
     President?
       A. They varied. I think they're listed on this chart, and 
     I've testified to them.
       Q. Okay, and--
       MR. CACHERIS: Do you want her to read the list that's on 
     this chart?
       MR. BRYANT: No. I was just, again, looking for just a--I 
     think maybe a little broader category, but that's--that's 
     okay. That's an acceptable answer there.
       BY MR. BRYANT:
       Q. After leaving the White House and going to the Pentagon, 
     did you continue to visit the President?
       A. Yes.
       Q. How would you--how would you be transported from the 
     Pentagon over to the White House? How did you get there?
       A. I drove or took a taxi.
       Q. Do you have your own car?
       A. No.
       Q. Whose--whose car would you drive?
       A. Either my mom's or my brother's.
       Q. So you did have access to a vehicle?
       A. Correct.
       Q. Okay. How were these meetings arranged when you would 
     want to go from the Pentagon to the White House? How did--how 
     did these--how were they set up? Did you get an appointment?
       [The witness conferring with counsel.]
       SENATOR DeWINE: Counsel--if you have to ask counsel, you 
     can stop and ask us--
       THE WITNESS: Okay.
       SENATOR DeWINE: --to do that.
       BY MR. BRYANT:
       Q. How were these meetings arranged?
       A. Through Ms. Currie.
       Q. Would--would you call her and set the meeting up, or 
     would she call you on behalf of the President and set the 
     meeting up?
       A. It varied.
       Q. Both--both situations occurred?
       A. Correct.
       Q. Now, Ms. Currie is the President's--that's Betty Currie, 
     we're talking about, the President's secretary?
       A. Yes.
       Q. Why was this done? Why was that procedure used?
       A. It was my understanding that Ms. Currie took care of the 
     President's guests who were coming to see him, making those 
     arrangements.
       Q. Was, uh--was this--were these visits done sort of off 
     the record, so to speak, so it wouldn't necessarily be a 
     record?
       A. I believe so.
       Q. In other words, you wouldn't be shown on Betty Currie's 
     calendar or schedule book for the President?
       A. I don't know.
       Q. Did--who suggested this type of arrangement for setting 
     up meetings?
       A. I believe the President did.
       Q. During this time that you were at the Department of 
     Defense at the Pentagon, uh, how--how was it working out 
     about you being transferred back to the White House? How was 
     the job situation coming?
       A. Well, I waited until after the election and then spoke 
     with the President about it on several occasions.
       Q. And what would he say in response?
       A. Various things; ``I'm working on it,'' usually.

[[Page 1834]]

       Q. In July, uh, particularly around the--the 3rd and 4th of 
     July, there--there--you wrote the President a letter, I 
     think.
       A. Which year?
       Q. July of '90--it would have been '97 that you wrote the 
     President a letter expressing some frustrations about the job 
     situation in terms of--is that, uh--can you tell us about 
     that?
       A. Yes. I had had a--well, I guess I was--I know I've 
     testified about this, I mean, in the grand jury, but I was 
     feeling at that point that I was getting the runaround on 
     being brought back to the White House. So I sent a letter to 
     the President that was probably the harshest I had sent.
       Q. Did you get a response?
       A. Sort of.
       Q. Would you explain?
       A. Um, Betty called me and told me to come to the White 
     House the next morning, on July 4th, at 9:00 a.m.
       Q. And what happened when you--I assume you went to the 
     White House on July the 4th. What happened?
       A. I know I--I--do you have a specific question? I know I 
     testified, I mean, extensively about this whole day, that 
     whole--
       Q. Well, in regards to--let's start with the job.
       A. Well, I started crying. We were in the back office and, 
     um--and when the subject matter came up, the President was 
     upset with me and then I began to cry. So--
       Q. Did he encourage you about you coming back? Did he make 
     a promise or commitment to you that he would make sure you 
     came back to work at the White House?
       A. I don't know that he reaffirmed his promise or 
     commitment. I remember leaving that day thinking that, as 
     usual, he was going to work on it and had a renewed sense of 
     hope.
       Q. Did he comment on your letter, the tone of your letter?
       A. Yes.
       Q. What did he say?
       A. He was upset with me and told me it was illegal to 
     threaten the President of the United States.
       Q. Did you intend the letter to be interpreted that way?
       A. No.
       Q. Did you explain why you wrote the letter to him about 
     reminding him that you were a good girl and you left the 
     White House? Did you have that type of conversation?
       A. Yes. That's what made me start to cry.
       Q. Did you, uh--did you ever explain to him that you didn't 
     intend to threaten him?
       A. I believe so.
       Q. What was the intent of the letter?
       A. First, I felt the letter was going to him as a man and 
     not as President of the United States. Um, second, I think I 
     could see how he could interpret it as a threat, but my 
     intention was to sort of remind him that I had been waiting 
     patiently and what I considered was being a good girl, about 
     having been transferred.
       Q. And the threat we're talking about here would not have 
     been interpreted as a threat to do physical injury or bodily 
     injury to him. It was to expose your relationship to the--to 
     your parents--
       A. Correct.
       Q. --explain to them why you were not going back to the 
     White House--
       A. Correct.
       Q. --after the election?
       And certainly the President did not encourage you to expose 
     that relationship, did he?
       A. I don't believe he made any comment about it at that 
     point.
       Q. His only comment about the so-called threat was that 
     it's a---it's--you can't do that, it's against the law to 
     threaten the President?
       A. Exactly.
       Q. That meeting turned into--I guess you've testified that 
     that meeting did turn into a more positive meeting toward the 
     end. It was not all emotional and accusations being made?
       A. Correct.
       Q. At some point, uh--well, let me--let me back up and ask 
     this. There was a subsequent meeting on July the 14th, and I 
     believe the President had been out of town and this was the 
     follow-up meeting to the July 4th meeting where you had 
     originally discussed the possibility of a newspaper reporter 
     or a magazine writer, I believe, writing a story about Ms. 
     Willey?
       A. Correct.
       Q. And you, uh--did you have any instructions from the 
     President, from either of these meetings, about doing 
     something for the President, specifically about having Ms. 
     Tripp call White House counsel--
       A. I don't know--
       Q. --Mr. Lindsey?
       A. --that I'd call them instructions.
       Q. Okay. What did he tell you? I don't want to 
     mischaracterize.
       A. He asked me if I would try to have Ms. Tripp contact Mr. 
     Lindsey.
       Q. Okay, and if you were to be successful in doing that, 
     what were you supposed to do? Were you supposed to contact 
     Ms. Currie, his secretary?
       A. Yes.
       Q. And what were you supposed to tell her?
       A. In an innocuous way that I had been able to convey that 
     to Ms. Tripp or get her to do that.
       Q. Now, in--at some point in October of that year, 1997, 
     did your job focus change?
       A. Yes.
       Q. And how was that? What were you doing?
       A. Uh, it really changed on October 6th, 1997, as a result 
     of a conversation with Linda Tripp.
       Q. Uh, in that, as I understand, you sort of got secondhand 
     information that you were probably never going back to work 
     at the White House.
       A. Correct.
       Q. Did you understand what that meant? Did you accept that? 
     And I guess why would you accept it at that point? Why would 
     you give up on the White House?
       MR. CACHERIS: Those are three questions, Mr. Bryant. Will 
     you--would you break it down, please?
       MR. BRYANT: Well, yeah, it's true.
       BY MR. BRYANT:
       Q. Do you understand? I guess I'm trying to clarify.
       A. Not really. I'm sorry.
       Q. Why would you accept at that point in October that you 
     were never going back to the White House?
       A. I don't really remember, I mean, what--what--what was 
     going through my mind at that point as to--to answer that 
     question. Is that--
       Q. Okay.
       A. I'm sorry.
       Q. Certainly, if you don't remember, that's a--that's a 
     good answer.
       A. Okay.
       Q. So you don't recall anything had really changed other 
     than you had heard secondhand that you weren't going to go 
     back. You have no independent recollection of anything else 
     other than what somebody told you that would have changed--
       A. My recollection is--
       Q. --changed your focus?
       A. --that it was this--it was this conversation, what Linda 
     Tripp told me from whom this information was coming, the way 
     it was relayed to me that--that shifted everything that day.
       Q. And you didn't feel it was necessary to go back to the 
     President and perhaps confront the President and say, ``why 
     am I not coming back, I want to come back?''
       A. I mean, I had a discussion with the President, but I had 
     made a decision from that based on that information, and I 
     guess my--my experience of it coming up on a year from the 
     election, having not been brought back, that it probably 
     wasn't going to happen.
       Q. But you--you did call the President about that time and 
     then--but the focus had been changed toward perhaps a job in 
     another location.
       A. Yes and no. I didn't call him, but I, um--
       Q. You called Betty--
       A. --but we did have a discussion about that.
       Q. You called Betty Currie, his secretary.
       A. Yes.
       Q. Okay, and then through her, he contacted you and you had 
     a discussion?
       A. Yes.
       Q. And what did you tell him at that time about the job?
       A. I believe I testified to that, so that my testimony is 
     probably more accurate. The gist of it was, um, that I wanted 
     to move to New York and that I was accepting I wasn't going 
     to be able to come back to the White House, and I asked for 
     his help.
       Q. Did you bring up Vernon Jordan's name as perhaps 
     somebody that could help you?
       A. It's possible it was in that conversation.
       Q. What was the President's comments back to you about your 
     deciding to go to New York?
       A. I don't remember his exact comments. He was accepting of 
     the concept.
       Q. In regards to your--your, uh, decision to search for a 
     job in New York, in your comments to the President, did he 
     ever tell you that that was good, that perhaps the Jones 
     lawyers could not easily find you in New York?
       A. I'm sorry. I don't--I--I--
       MR. CACHERIS: Excuse me again, Mr. Bryant. That's a 
     compound question. He could--she could answer it was good, 
     and then she could answer maybe the Jones lawyer couldn't get 
     her, but I think you'd want an answer to each question.
       BY MR. BRYANT:
       Q. Okay. Let me ask it this way. There has been some 
     reference to that fact throughout the proceedings, and I 
     recall seeing something somewhere in your--your testimony 
     that you said it or he said it. Do you recall anything being 
     said about you going to Washington--to New York and that the 
     effect of that might be that you would be more difficult to 
     find?
       A. I believe that might have been mentioned briefly on the 
     28th of December, but not as a reason to go to New York, but 
     as a possible outcome of being there. Does that--does that 
     make sense?
       Q. It does.
       A. Okay.
       Q. What, uh--what would have been the context of that? And 
     we're jumping ahead to December the 28th, but what would have

[[Page 1835]]

     been the context of that particular conversation about the 
     New York and being perhaps--the result being it might be 
     difficult to find you, or more difficult? What was the 
     context?
       A. Um, I--I--if I remember correctly, it came sort of at 
     the tail-end of a very short discussion we had about the 
     Jones case.
       Q. At this November the 11th meeting, did the President ask 
     you to prepare a list, sort of a wish list for jobs?
       A. I'm sorry. Which--
       Q. I'm sorry. Did I say October? We're back to the October 
     the 11th meeting. Did the President ask you to prepare a wish 
     list?
       A. Okay. We haven't gone to the October 11th meeting yet. 
     I--I haven't said anything about that meeting yet.
       Q. Okay.
       A. The phone call was on the 9th.
       Q. Okay, and you subsequently had a meeting, then, with the 
     President on the 11th?
       A. Correct.
       Q. Face--face-to-face meeting?
       A. Correct.
       Q. And at that meeting, did he suggest you give him a wish 
     list or Betty Currie a wish list?
       A. Yes.
       Q. Again, I asked a compound question there.
       Who did he suggest you give the wish list to?
       MR. CACHERIS: We're getting used to that.
       MR. BRYANT: I'm getting good. I'm making my own objections 
     now.
       [Laughter.]
       THE WITNESS: Um, we sustain those. No, I'm sorry.
       [Laughter.]
       MR. BRYANT: I can do that, too. I'll be doing that in a 
     minute. Overruled. Okay.
       THE WITNESS: Um, I--I believe he--he said I should get him 
     a list, and the implication was through Betty.
       BY MR. BRYANT:
       Q. And obviously you prepared a list of--
       A. Correct.
       Q. --the people you'd like to work for in New York City.
       A. Correct.
       Q. And you sent that list--
       A. Yes.
       Q. --to Betty Currie or to the President?
       A. I sent it to Ms. Currie.
       Q. And also during this time--and I'm probably going to 
     speed this up a little bit, but, uh, you did interview for 
     the job at the United Nations?
       A. Yes.
       Q. And, uh--and through a process of several months there, 
     or weeks at least, you did--made an offer to take a job at 
     the United Nations and eventually declined it. Is that 
     correct?
       A. Correct.
       Q. Did you in early November have the occasion to meet with 
     Vernon Jordan about the job situation?
       A. Yes.
       Q. And how did you learn about that meeting?
       A. I believe I asked Ms. Currie to check on the status of--
     I guess of finding out if I could have this meeting, and then 
     she let me--she let me know to call Mr. Jordan's secretary?
       Q. And you set up an appointment with Mr. Jordan, or did 
     she, Ms. Currie, do that?
       A. No. I set up an appointment. I think that was after a 
     phone--well, I guess I don't--I don't know that, so sorry.
       Q. But that appointment was November the 5th?
       A. Yes.
       Q. Prior to going to the meeting with Vernon Jordan, did 
     you tell the President that you had a meeting with Mr. 
     Jordan?
       A. I don't think so. I don't remember.
       Q. Did you carry any documents or any papers with you to 
     the meeting with Mr. Jordan?
       A. Yes.
       Q. What were those?
       A. My resume and a list of public relations firms in New 
     York.
       Q. Did Mr. Jordan ask you why you were there?
       A. Yes.
       Q. And what did you say?
       A. I was hoping to move to New York and that he could 
     assist me in securing a job there.
       Q. Did he ask you why you wanted to leave Washington?
       A. Yes.
       Q. And what was your answer?
       A. I gave him the vanilla story of, um, that I--I think I--
     I don't remember exactly what I said. I--I believe I've 
     testified to this. I think it was something about wanting to 
     get out of Washington.
       Q. The vanilla story. You mean sort of an innocuous set of 
     reasons, not really the true reasons you wanted to leave?
       A. Yes.
       Q. And what were the true reasons you wanted to leave?
       A. Because I couldn't go back to the White House.
       Q. Did--did you think Mr. Jordan accepted--did you think he 
     would accept that vanilla story, or did you feel like he 
     understood the real story?
       A. No, I felt he accepted it.
       Q. Did Mr. Jordan tell you during this meeting that he had 
     already spoken with the President?
       A. It was--I believe so.
       Q. And that you had come highly recommended, I think?
       A. Yes.
       Q. Did he, Mr. Jordan, review your list of job preferences 
     and suggest anything?
       A. Yes.
       Q. And what did he suggest?
       A. He said the names of the--he looked at the list of 
     public relations firms and I think sort of said, ``oh, I've 
     heard of them, I haven't heard of these people, have you 
     heard of so and so,'' that I hadn't heard of.
       Q. Your meeting lasted about 20 minutes?
       A. If that's what I've testified to, then I accept that.
       Q. It is, or close to it. I know this is an approximation, 
     but thereabouts. You weren't there all day.
       A. I had--well, I don't--I don't remember how long it was 
     right now. I know I've testified to that. So if I said 20 
     minutes, then--
       Q. Did you have a conversation with the President on--about 
     a week later on November the 12th and by telephone?
       A. Yes.
       Q. And did you indicate there you had spoken with Mr. 
     Jordan about a job?
       A. Yes.
       Q. After you met with Mr. Jordan, did you--did you have an 
     impression that you would get, uh--get a job, get favorable 
     results in your job search?
       A. Yes.
       Q. Did anything favorable happen to--in your job search 
     from that November the 5th, 1997, meeting until Thanksgiving?
       A. No, but I believe Mr. Jordan was out of town for a week 
     or two.
       Q. During the weeks after this November the 5th interview, 
     did you try to contact Mr. Jordan?
       A. Yes.
       Q. How?
       A. First, I sent him a thank-you note for the initial 
     meeting, and I believe I placed some phone calls right before 
     Thanksgiving--maybe a phone call. I don't remember if it was 
     more than one.
       Q. What--what happened with respect to the job search, uh, 
     through there, through Thanksgiving? Was there anything? I 
     mean, I know he--you said he was out of down, but did 
     anything, to your knowledge, occur? Could you see any results 
     up to Thanksgiving?
       A. From my meeting with Mr. Jordan?
       Q. Yes.
       A. No.
       Q. Did you contact Betty Currie after you received no 
     response from Mr. Jordan?
       A. Yes.
       Q. And did she page you? I think you were in Los Angeles at 
     the time.
       A. Correct.
       Q. Okay. What--what did she tell you as a result of that 
     telephone call?
       A. She asked me to place a call to Mr. Jordan, which I did.
       Q. And this would have been, again, around November the 
     26th, shortly--well, around Thanksgiving?
       A. It was before Thanksgiving.
       Q. And I assume you found Mr. Jordan.
       A. Yes.
       Q. And what did he tell you?
       A. That he was working on it.
       Q. Did he tell you to call him back?
       A. Yes.
       Q. Did you indeed call him back
       A. I didn't actually get ahold of him; he was out-of-town 
     that day. I think it was December 5th.
       Q. Did you try to meet with the President during this time?
       A. Yes.
       Q. How did you do that?
       A. I was a pest. I sent a note to Ms. Currie and asked her 
     to pass it along to the President, requesting that I meet 
     with him.
       Q. Were you successful in having a meeting as a result of 
     those efforts?
       A. I don't know if it was a result of those efforts, but 
     yes, I ended up having a meeting with the President.
       Q. And when would that have been; what day?
       A. On the 6th of December 1997.
       Q. Again you are going through Betty Currie; is that, 
     again, the standard procedure at that time?
       A. Yes.
       Q. Did you go--I think you spoke also perhaps to Betty 
     Currie on December the 5th, the day before the meeting--
       A. Yes.
       Q. --and this was something about attending the President's 
     speech. Was that when that occurred--or the radio address, or 
     something? Does that ring any bells?
       A. No.
       Q. Did--you did attend the Christmas party that day--
       A. Yes.
       Q. --and the White House. And you saw the President?
       A. Yes.
       Q. Just socially, speak to him, and that's it?
       A. Yes.
       Q. Picture, handshaking, and that?
       A. [Nodding head.]
       Q. Okay. That's a yes?
       A. Yes. Sorry.
       Q. Prior to December 6th, 1997, had you purchased a 
     Christmas gift for the President?

[[Page 1836]]

       A. Yes.
       Q. Which was?
       A. An antique standing cigar holder.
       Q. And had you purchased any other additional gifts for 
     him?
       A. Yes.
       Q. And what were those?
       A. Uh, a Starbucks mug that said ``Santa Monica''; a 
     necktie that I got in London; a little box--I call it a 
     ``chochki''--from, uh--and an antique book on Theodore 
     Roosevelt.
       Q. Was it your intention to, to carry those Christmas 
     presents to the President home that Saturday, December the 
     6th?
       A. If I were to have a meeting with him, yes.
       Q. Did you attempt to have a meeting?
       A. Yes.
       Q. Did you go through Betty Currie?
       A. Yes. I sent her the letter to, to give to the President.
       Q. And when you went to the White House that day, you also 
     attempted to, to have the meeting through calling Betty 
     Currie and telephoning her; I believe you had to go to--
       A. Which day? I'm sorry.
       Q. On the 6th.
       A. No.
       Q. The Saturday.
       A. [No response.]
       Q. No?
       A. I--I attempted to give the presents to Betty, but I 
     didn't call and attempt to have a meeting there--well, I 
     guess I called in the morning, so that's not true--I'm sorry. 
     Yes, I called Ms. Currie in the morning trying to see if I 
     could see the President and apologize.
       Q. And--were you--did you see the President, then, on the 
     6th?
       A. Yes, I did.
       Q. Tell us about that meeting--that was a long--was that, 
     uh--did you have a telephone conversation with him that day 
     also?
       A. Yes.
       Q. And that was the long telephone conversation?
       A. It--it was.
       Q. Okay. I think there has been some indication it may have 
     been 56 minutes, something approximating an hour-long 
     conversation; does that sound right?
       A. Right. That would--that might include some conversation 
     time with Ms. Currie as well.
       Q. Okay. Was he interrupted by Ms. Currie--could you tell--
     did he have to take a break from the telephone call to talk 
     to Ms. Currie, or do you recall any, any--
       A. I don't recall that.
       Q. --do you recall any breaks to talk to anybody else?
       A. I don't recall that. Doesn't mean it didn't happen; I 
     just don't remember it.
       Q. What else did you--did you arrange in that telephone 
     conversation, or did he invite you in that telephone 
     conversation to come to the White House that day?
       A. Yes, he did.
       Q. What happened during, during that conversation in terms 
     of--I understand that it was again an emotional day, some 
     sort of a word fight; is that right?
       A. Yes.
       Q. Could you tell me--he was, uh--again, to perhaps save 
     some time--he was angry about an earlier incident, and, uh, 
     he felt like you were intruding on his lawyer time?
       A. Uh, he was upset that I hadn't accepted that he just 
     couldn't see me that day.
       Q. And what was your response to that?
       A. Probably not positive. Uh, that's why it was a fight.
       Q. Again, I want to be careful that I don't put words in 
     your mouth, but you were dealing with this relationship from 
     an emotional standpoint of wanting to spend time with him--
       A. Yes.
       Q. --not as President, but as a man?
       A. Correct.
       Q. And this was at a point when you didn't feel like you 
     were spending enough time with him?
       A. Correct.
       Q. And he obviously felt he had to do other things, too, 
     talk to lawyers and do those kinds of things--be the 
     President--is that right?
       A. Yes.
       Q. Okay. Now, was some of this discussion that we term 
     ``the fight,'' was that over the telephone?
       A. Yes. It was all over the telephone.
       Q. So by the time you arrived and had the face-to-face 
     meeting with him, that was over?
       A. Correct.
       Q. Was that during the time that you exchanged--exchanged 
     some of the Christmas presents with him?
       A. In--in the meeting?
       Q. Yes.
       A. Yes. I gave him my Christmas presents.
       Q. Did you discuss the job search with him also at that 
     time?
       A. I believe I mentioned it.
       Q. Did you tell him that, uh, your job search with Mr. 
     Jordan was not going well?
       A. I don't know if I used those words. I don't, I don't 
     remember exactly--
       Q. If your grand jury testimony said yes--I mean, words to 
     that effect--that would--you could have used those words if 
     they're in your grand jury--
       A. If my grand jury testimony says that--if that's what I 
     said in my grand jury testimony, then I accept that.
       Q. I'm not trying to--I'm not trying to trick you.
       A. Okay.
       Q. Did he make any comment to you about what he might do to 
     aid in your job search at that time, if you recall?
       A. I think he--I think he said, oh, let me see about it, 
     let me see what I can do--his usual.
       Q. Did, uh, did the President say anything to you at that 
     time about your name appearing on a witness list in the Paula 
     Jones case?
       A. No.
       Q. Did you later learn that your name had appeared on such 
     a list?
       A. Yes.
       Q. And did you later learn that that witness list had been 
     faxed to the White House-- to the President's lawyers on 
     December the 5th?
       A. Much later, as in last year.
       Q. Okay. Yes--that's what I mean--later.
       A. I, I mean--
       Q. Yes.
       A. --post this investigation.
       Q. Okay. All right. Let's go forward another week or so to 
     December the 11th and a lunch that you had with Vernon 
     Jordan, I believe, in his office.
       A. Yes.
       Q. How did--how was that meeting set up.
       A. Through his secretary.
       Q. Did you instigate that, or did he call through his 
     secretary?
       A. I don't remember.
       Q. What was the purpose of that meeting?
       A. Uh, it was to discuss my job situation.
       Q. And what, what--how was that discussed?
       A. Uh, Mr. Jordan gave me a list of three names and 
     suggested that I contact these people in a letter that I 
     should cc him on, and that's what I did.
       Q. Did he ask you to copy him on the letters that you sent 
     out?
       A. Yes.
       Q. During this meeting, did he make any comments about your 
     status as a friend of the President?
       A. Yes.
       Q. What--what did he say?
       A. In one of his remarks, he said something about me being 
     a friend of the President.
       Q. And did you respond?
       A. Yes.
       Q. How?
       A. I said that I didn't, uh--I think I--my grand jury 
     testimony, I know I talked about this, so it's probably more 
     accurate. My memory right now is I said something about, uh, 
     seeing him more as, uh, a man than as a President, and I 
     treated him accordingly.
       Q. Did you express your frustration to Mr. Jordan with, uh, 
     with the President?
       A. I expressed that sometimes I had frustrations with him, 
     yes.
       Q. And what was his response to you about, uh--after you 
     talked about the President?
       A. Uh, he sort of jokingly said to me, You know what your 
     problem is, and don't deny it--you're in love with him. But 
     it was a sort of light-hearted nature.
       Q. Did you--did you have a response to that?
       A. I probably blushed or giggled or something.
       Q. Do you still have feelings for the President?
       A. I have mixed feelings.
       Q. What, uh--maybe you could tell us a little bit more 
     about what those mixed feelings are.
       A. I think what you need to know is that my grand jury 
     testimony is truthful irrespective of whatever those mixed 
     feelings are in my testimony today.
       Q. I know in your grand jury you mentioned some of your 
     feelings that you felt after he spoke publicly about the 
     relationship, but let me ask you more about the positive--you 
     said there were mixed feelings. What about--do you still, uh, 
     respect the President, still admire the President?
       A. Yes.
       Q. Do you still appreciate what he is doing for this 
     country as the President?
       A. Yes.
       Q. Sometime back in December of 1997, in the morning of 
     December the 17th, did you receive a call from the President?
       A. Yes.
       Q. What was the purpose of that call? What did you talk 
     about?
       A. It was threefold--first, to tell me that Ms. Currie's 
     brother had been killed in a car accident; second, to tell me 
     that my name was on a witness list for the Paula Jones case; 
     and thirdly, he mentioned the Christmas present he had for 
     me.
       Q. This telephone call was somewhere in the early morning 
     hours of 2 o'clock to 2:30.
       A. Correct.
       Q. Did it surprise you that he called you so late?
       A. No.
       Q. Was this your first notice of your name being on the 
     Paula Jones witness list?
       A. Yes.
       Q. I realize he, he commented about some other things, but 
     I do want to focus on the witness list.
       A. Okay.
       Q. Did he say anything to you about how he felt concerning 
     this witness list?
       A. He said it broke his heart that, well, that my name was 
     on the witness list.

[[Page 1837]]

       Can I take a break, please? I'm sorry.
       SENATOR DeWINE: Sure, sure. We'll take a 5-minute break at 
     this point.
       THE VIDEOGRAPHER: This marks the end of Videotape Number 1 
     in the deposition of Monica S. Lewinsky. We are going off the 
     record at 10:56 a.m.
       [Recess.]
       THE VIDEOGRAPHER: This marks the beginning of Videotape 
     Number 2 in the deposition of Monica S. Lewinsky. The time is 
     11:10 a.m.
       SENATOR DeWINE: We are now back on the record.
       I will advise the House Managers that they have used one 
     hour and 8 minutes.
       Mr. Bryant, you may proceed.
       MR. BRYANT: Thank you.
       By MR. BRYANT:
       Q. Did--did we get your response? We were talking about the 
     discussion you were having with the President over the 
     telephone, early morning of the December 17th phone call, and 
     he had, uh, mentioned that it broke his heart that you were 
     on that list.
       A. Correct.
       Q. And I think you were about to comment on that further, 
     and then you need a break.
       A. No.
       Q. No.
       A. I just wanted to be able to focus--I know this is an 
     important date, so I felt I need a few moments to be able to 
     focus on it.
       Q. And you're comfortable now with that, with your--you are 
     ready to talk about that?
       A. Comfortable, I don't know, but I'm ready to talk about.
       Q. Well, I mean comfortable that you can focus on it.
       A. Yes, sir.
       Q. Good. Now, with this discussion of the fact that your 
     name appeared as a witness, had you--had you been asleep that 
     night when the phone rang?
       A. Yes.
       Q. So were you wide awake by this point? It's the President 
     calling you, so I guess you're--you wake up.
       A. I wouldn't say wide awake.
       Q. He expressed to you that your name--you know, again, you 
     talked about some other things--but he told you your name was 
     on the list.
       A. Correct.
       Q. What was your reaction to that?
       A. I was scared.
       Q. What other discussion did you have in regard to the fact 
     that your name was on the list? You were scared; he was 
     disappointed, or it broke his heart. What other discussion 
     did you have?
       A. Uh, I believe he said that, uh--and these are not 
     necessarily direct quotes, but to the best of my memory, that 
     he said something about that, uh, just because my name was on 
     the list didn't necessarily mean I'd be subpoenaed; and at 
     some point, I asked him what I should do if I received a 
     subpoena. He said I should, uh, I should let Ms. Currie know. 
     Uh--
       Q. Did he say anything about an affidavit?
       A. Yes.
       Q. What did he say?
       A. He said that, uh, that I could possibly file an 
     affidavit if I--if I were subpoenaed, that I could possibly 
     file an affidavit maybe to avoid being deposed.
       Q. How did he tell you you would avoid being deposed by 
     filing an affidavit?
       A. I don't think he did.
       Q. You just accepted that statement?
       A. [Nodding head.]
       Q. Yes?
       A. Yes, yes. Sorry.
       Q. Are you, uh--strike that. Did he make any representation 
     to you about what you could say in that affidavit or--
       A. No.
       Q. What did you understand you would be saying in that 
     affidavit to avoid testifying?
       A. Uh, I believe I've testified to this in the grand jury. 
     To the best of my recollection, it was, uh--to my mind came--
     it was a range of things. I mean, it could either be, uh, 
     something innocuous or could go as far as having to deny the 
     relationship. Not being a lawyer nor having gone to law 
     school, I thought it could be anything.
       Q. Did he at that point suggest one version or the other 
     version?
       A. No. I didn't even mention that, so there, there wasn't a 
     further discussion--there was no discussion of what would be 
     in an affidavit.
       Q. When you say, uh, it would be--it could have been 
     something where the relationship was denied, what was your 
     thinking at that point?
       A. I--I--I think I don't understand what you're asking me. 
     I'm sorry.
       Q. Well, based on prior relations with the President, the 
     concocted stories and those things like that, did this come 
     to mind? Was there some discussion about that, or did it come 
     to your mind about these stories--the cover stories?
       A. Not in connection with the--not in connection with the 
     affidavit.
       Q. How would--was there any discussion of how you would 
     accomplish preparing or filing an affidavit at that point?
       A. No.
       Q. Why--why didn't you want to testify? Why would not you--
     why would you have wanted to avoid testifying?
       A. First of all, I thought it was nobody's business. Second 
     of all, I didn't want to have anything to do with Paula Jones 
     or her case. And--I guess those two reasons.
       Q. You--you have already mentioned that you were not a 
     lawyer and you had not been to law school, those kinds of 
     things. Did, uh, did you understand when you--the potential 
     legal problems that you could have caused yourself by 
     allowing a false affidavit to be filed with the court, in a 
     court proceeding?
       A. During what time--I mean--I--can you be--I'm sorry--
       Q. At this point, I may ask it again at later points, but 
     the night of the telephone--
       A. Are you--are you still referring to December 17th?
       Q. The night of the phone call, he's suggesting you could 
     file an affidavit. Did you appreciate the implications of 
     filing a false affidavit with the court?
       A. I don't think I necessarily thought at that point it 
     would have to be false, so, no, probably not. I don't--I 
     don't remember having any thoughts like that, so I imagine I 
     would remember something like that, and I don't, but--
       Q. Did you know what an affidavit was?
       A. Sort of.
       Q. Of course, you're talking at that time by telephone to 
     the President, and he's--and he is a lawyer, and he taught 
     law school--I don't know--did you know that? Did you know he 
     was a lawyer?
       A. I--I think I knew it, but it wasn't something that was 
     present in my, in my thoughts, as in he's a lawyer, he's 
     telling me, you know, something.
       Q. Did the, did the President ever tell you, caution you, 
     that you had to tell the truth in an affidavit?
       A. Not that I recall.
       Q. It would have been against his interest in that lawsuit 
     for you to have told the truth, would it not?
       A. I'm not really comfortable--I mean, I can tell you what 
     would have been in my best interest, but I--
       Q. But you didn't file the affidavit for your best 
     interest, did you?
       A. Uh, actually, I did.
       Q. To avoid testifying.
       A. Yes.
       Q. But had you testified truthfully, you would have had 
     no--certainly, no legal implications--it may have been 
     embarrassing, but you would have not had any legal problems, 
     would you?
       A. That's true.
       Q. Did you discuss anything else that night in terms of--I 
     would draw your attention to the cover stories. I have 
     alluded to that earlier, but, uh, did you talk about cover 
     story that night?
       A. Yes, sir.
       Q. And what was said?
       A. Uh, I believe that, uh, the President said something--
     you can always say you were coming to see Betty or bringing 
     me papers.
       Q. I think you've testified that you're sure he said that 
     that night. You are sure he said that that night?
       A. Yes.
       Q. Now, was that in connection with the affidavit?
       A. I don't believe so, no.
       Q. Why would he have told you you could always say that?
       A. I don't know.
       Mr. BURTON: Objection. You're asking her to speculate on 
     someone else's testimony.
       MR. BRYANT: Let me make a point here. I've been very 
     patient in trying to get along, but as I alluded to earlier, 
     and I said I am not going to hold a hard line to this, but I 
     don't think the President's--the witness' lawyers ought to be 
     objecting to this testimony. If there's an objection here, it 
     should come from the White House side, nor should they be--
       SENATOR DeWINE: Counsel, why don't you rephrase the 
     question?
       MR. BRYANT: Do we have a clear ruling on whether they can 
     object?
       SENATOR DeWINE: We'll go off the record for a moment.
       THE VIDEOGRAPHER: We're going off the record at 11:20 a.m.
       [Recess.]
       THE VIDEOGRAPHER: We are going back on the record at 11:30 
     a.m.
       SENATOR DeWINE: We are now back on the record.
       It's our opinion that counsel for Ms. Lewinsky do have the 
     right to make objections. We would ask them to be as short 
     and concise as humanly possible. So we will now proceed.
       Mr. Bryant?
       MR. BRYANT: Thank you, Senator.
       BY MR. BRYANT:
       Q. Let's kind of bring this back together again, and I'll 
     try to ask sharper questions and avoid these objections.
       We're at that point that we've got a telephone conversation 
     in the morning with you and the President, and he has among 
     other things mentioned to you that your name is on the Jones 
     witness list. He has also mentioned to you that perhaps you 
     could file an affidavit to avoid possible testifying in that 
     case. Is that right?
       A. Correct.
       Q. And he has also, I think, now at the point that we were 
     in our questioning, referenced the cover story that you and 
     he had had, that perhaps you could say that you were coming 
     to my office to deliver papers or to see Betty Currie; is 
     that right?

[[Page 1838]]

       A. Correct. It was from the entire relationship, that 
     story.
       Q. Now, when he alluded to that cover story, was that 
     instantly familiar to you?
       A. Yes.
       Q. You knew what he was talking about?
       A. Yes.
       Q. And why was this familiar to you?
       A. Because it was part of the pattern of the relationship.
       Q. Had you actually had to use elements of this cover story 
     in the past?
       A. I think so, yes.
       Q. Did the President ever tell you what to say if anyone 
     asked you about telephone conversations that you had had with 
     him?
       A. Are we--are we still focused on December 17th?
       Q. No, no.
       A. Okay.
       Q. It did not have to be that night. Did he ever?
       A. If I could just--I--I'm pretty date-oriented, so if you 
     could just be more specific with the date. If we're staying 
     on a date or leaving that date, it would just help me. I'm 
     sorry.
       Q. Well, my question was phrased did he ever do that, but--
       A. Okay.
       Q. Well, I--I'm sorry. I'm playing guessing games with you. 
     Was there a conversation on March 29th of 1997 when the 
     President told you he thought perhaps his telephone 
     conversations were being tapped or taped--either way, or 
     both--by a foreign embassy?
       A. Yes.
       Q. And was there some reference to some sort of cover story 
     there in the event that his line was tapped?
       A. Yes.
       Q. And what was that?
       A. That--I think, if I remember it correctly, it was that 
     we--that he knew that we were sort of engaging in those types 
     of conversations, uh, knowing that someone was listening, so 
     that it was not for the purposes that it might have seemed.
       Q. Did you find it a little strange that he would express 
     concern about possible eavesdropping and still persist in 
     these calls to you?
       A. I don't think phone calls of that nature occurred and 
     happened right after, or soon after that discussion. I think 
     it was quite a few months until that resumed.
       Q. I think my question was more did you not find it a 
     little strange that he felt that perhaps his phone was being 
     tapped and conversations taped by a foreign embassy, and he--
       A. I--I thought it was strange, but if--I mean, I wasn't 
     going to question what he was saying to me.
       Q. But that he also continued to make the calls--you're 
     saying he didn't make any calls after that?
       A. No. My understanding was it was referencing a certain 
     type of phone call, certain nature of phone call, uh, and 
     those--
       Q. Let me direct your attention back to a point I did not 
     mention a couple--a few days before the December--early 
     December telephone call, the lengthy telephone call from the 
     President. We had talked about how that was a heated 
     conversation.
       A. Correct.
       Q. At--did at some point during that telephone 
     conversation--did the tone--did the President's tone change 
     to a more receptive, friendly conversation?
       A. Yes.
       Q. Do you know why that happened?
       A. No, nor do I remember whose tone changed first. I mean, 
     we made up, so--
       Q. Okay. Now let me go back again to the December 11th 
     date--I'm sorry--the 17th. This is the conversation in the 
     morning. What else--was there anything else you talked about 
     in terms of--other than your name being on the list and the 
     affidavit and the cover story?
       A. Yes. I had--I had had my own thoughts on why and how he 
     should settle the case, and I expressed those thoughts to 
     him. And at some point, he mentioned that he still had this 
     Christmas present for me and that maybe he would ask Mrs. 
     Currie to come in that weekend, and I said not to because she 
     was obviously going to be in mourning because of her brother.
       Q. In--in that--in that relationship with the President, I 
     think you have expressed in your testimony somewhere that you 
     weren't necessarily jealous of those types of people like 
     Kathleen Willey or Paula Jones, and perhaps you didn't even 
     believe those stories occurred as--as they alleged.
       A. That's correct. I don't--I don't know, jealous or not 
     jealous. I don't think I've testified to my feelings of 
     jealousy, but the latter half of the question is true.
       Q. I--I saw it. I mean, it's not a major point. I thought I 
     saw that in your testimony, that particular word.
       A. Okay. If I said that, then I--I don't.
       Q. Was it your belief that the Paula Jones case was not a 
     valid lawsuit? Was that part of that discussion that night, 
     or your strategy?
       A. Uh, can I separate that--that into two questions?
       Q. Any way, any way you want to.
       A. Okay. I don't believe it was a valid lawsuit, and I 
     don't think whether I believed it was a valid lawsuit or not 
     was the topic of the conversation.
       Q. Okay, that's a fair answer.
       You believe the President's version of the Paula Jones 
     incident?
       A. Is that relevant to--
       Q. I--I just asked you the question.
       A. I don't believe Paula Jones' version of the story.
       Q. Okay, good. That's a fair answer.
       You have testified previously that you tried to maintain 
     secrecy regarding this relationship--and we're talking about 
     obviously with the President. Is that true?
       A. Yes.
       Q. And to preserve the secrecy and I guess advance this 
     cover story, you would bring papers to the President and 
     always use Betty Currie for the excuse for you to be WAVE'd 
     in. Is that right?
       A. Papers when I was working at the White House and Mrs. 
     Currie after I left the White House. So Mrs. Currie wasn't 
     involved when I was working at the White House.
       Q. Were these papers you carried in to the President--were 
     they--were they business documents, or were they more 
     personal papers from you to him?
       A. They--they weren't business documents.
       Q. So, officially, you were not carrying in official 
     papers?
       A. Correct.
       Q. You were carrying in personal papers that would not have 
     entitled you ordinarily to go see the President?
       A. Correct.
       Q. When--in this procedure where Betty Currie was always 
     the one that WAVE'd you in to the White House--and I--I don't 
     know if the people who may be watching this deposition, the 
     Senators, understand that the WAVES process is just the--to 
     give the guards the okay for you to come in. Is that a short 
     synopsis?
       A. I'm not really versed on--
       Q. I'm not either. You know more than I do, probably, since 
     you worked there, but--
       A. Well, I know you had to go, you had to type in a thing 
     in at WAVES, and now you have to give a Social Security, 
     birth date, have to show ID.
       Q. Is there a record kept of that?
       A. I believe so.
       Q. Was it always Betty Currie that WAVE'd you in to the--
     access to the White House? I'm talking about now after you 
     left and went to work at the Pentagon.
       A. No.
       Q. Other people did that?
       A. There were other reasons that I came to the White House 
     at times.
       Q. Did you ever ask the President if he would WAVE you in?
       A. Yes.
       Q. Did he ever do that?
       A. No, not to my--not to my knowledge.
       Q. Was there a reason? Did he express anything to you why 
     he would or would not?
       A. Yes. He said that, uh--I believe he said something about 
     that there's a specific list made of people that he requests 
     to come in and--and there are people who have access to that 
     list.
       Q. So, obviously, he didn't want your name being on that 
     list?
       A. Correct.
       Q. Now, some of those people--
       A. I think--well, that's my understanding.
       Q. Would some of those people be the people that worked 
     outside his office, Ms. Lieberman and those--those folks?
       A. I--I believe so, but I'm not really sure.
       Q. Did you not want those people to know that you were 
     inside the White House?
       A. I didn't.
       Q. Why is that?
       A. Because they didn't like me.
       Q. Would they have objected, do you think--if you know.
       A. I don't know.
       Q. Did you work with Betty Currie on occasions to--to get 
     in to see the President, perhaps bypass some of these people?
       A. Yes.
       Q. And that would be another way that you would conceal the 
     meeting with the President, by using Betty Currie to get you 
     in?
       A. I--I think, yes, be cautious of it.
       Q. Did--well, I think we've covered that, about some 
     papers, and I think we've covered that after you left your 
     job inside the White House with Legislative Affairs and went 
     to the Pentagon, you developed a story, a cover story to the 
     effect that you were going to see Betty, that's how you would 
     come in officially?
       A. Correct.
       Q. And during that time that you were at the Pentagon, you 
     would more likely visit him on weekends or during the week? 
     Which would--which would--
       A. Weekends.
       Q. Weekends. And why--why the weekends?
       A. First, I think he had less work, and second of all, 
     there were--I believe there were less people around.
       Q. Now, whose idea was it for you to come on weekends?
       A. I believe it was the President's.
       Q. When you--when the President was in his office, was your 
     purpose to go there and see him? If he was in the office, you 
     would go see him?
       A. What--I'm sorry.
       Q. No--that's not clear. I'll withdraw that question.
       Was Ms. Currie, the President's secretary--was she in the 
     loop, so to speak, in keeping

[[Page 1839]]

     this relationship and how you got in and out of the White 
     House, keeping that quiet?
       A. I think I actually remember reading part of my grand 
     jury testimony about this and that it was more specific in 
     that she was in the loop about my friendship with the 
     President, but I just want to not necessarily--there was a 
     clarification, I believe, in that about knowledge of the 
     complete relationship or not. So--
       Q. She would help with the gifts and notes and things like 
     that--the passing?
       A. Yes.
       Q. Would you agree that these cover stories that you've 
     just testified to, if they were told to the attorneys for 
     Paula Jones, that they would be misleading to them and not be 
     the whole story, the whole truth?
       A. They would--yes, I guess misleading. They were literally 
     true, but they would be misleading, so incomplete.
       Q. As I understand your testimony, too, the cover stories 
     were reiterated to you by the President that night on the 
     telephone--
       A. Correct.
       Q. --and after he told you you would be a witness--or your 
     name was on the witness list, I should say?
       A. Correct.
       Q. And did you understand that since your name was on the 
     witness list that there would be a possibility that you could 
     be subpoenaed to testify in the Paula Jones case?
       A. I think I understood that I could be subpoenaed, and 
     there was a possibility of testifying. I don't know if I 
     necessarily thought it was a subpoena to testify, but--
       Q. Were you in fact subpoenaed to testify?
       A. Yes.
       Q. And that was what--
       A. December 19th, 1997.
       Q. December 19th.
       Now, you have testified in the grand jury. I think your 
     closing comments was that no one ever asked you to lie, but 
     yet in that very conversation of December the 17th, 1997 when 
     the President told you that you were on the witness list, he 
     also suggested that you could sign an affidavit and use 
     misleading cover stories. Isn't that correct?
       A. Uh--well, I--I guess in my mind, I separate necessarily 
     signing affidavit and using misleading cover stories. So, 
     does--
       Q. Well, those two--
       A. Those three events occurred, but they don't--they 
     weren't linked for me.
       Q. But they were in the same conversation, were they not?
       A. Yes, they were.
       Q. Did you understand in the context of the conversation 
     that you would deny the--the President and your relationship 
     to the Jones lawyers?
       A. Do you mean from what was said to me or--
       Q. In the context of that--in the context of that 
     conversation, December the 17th--
       A. I--I don't--I didn't--
       Q. Okay. Let me ask it. Did you understand in the context 
     of the telephone conversation with the President that early 
     morning of December the 17th--did you understand that you 
     would deny your relationship with the President to the Jones 
     lawyers through use of these cover stories?
       A. From what I learned in that--oh, through those cover 
     stories, I don't know, but from what I learned in that 
     conversation, I thought to myself I knew I would deny the 
     relationship.
       Q. And you would deny the relationship to the Jones 
     lawyers?
       A. Yes, correct.
       Q. Good.
       A. If--if that's what it came to.
       Q. And in fact you did deny the relationship to the Jones 
     lawyers in the affidavit that you signed under penalty of 
     perjury; is that right?
       A. I denied a sexual relationship.
       Q. The President did not in that conversation on December 
     the 17th of 1997 or any other conversation, for that matter, 
     instruct you to tell the truth; is that correct?
       A. That's correct.
       Q. And prior to being on the witness list, you--you both 
     spoke--
       A. Well, I guess any conversation in relation to the Paula 
     Jones case. I can't say that any conversation from the--the 
     entire relationship that he didn't ever say, you know, ``Are 
     you mad? Tell me the truth.'' So--
       Q. And prior to being on the witness list, you both spoke 
     about denying this relationship if asked?
       A. Yes. That was discussed.
       Q. He would say something to the effect that--or you would 
     say that--you--you would deny anything if it ever came up, 
     and he would nod or say that's good, something to that 
     effect; is that right?
       A. Yes, I believe I testified to that.
       Q. Let me shift gears just a minute and ask you about--and 
     I'm going to be delicate about this because I'm conscious of 
     people here in the room and my--my own personal concerns--but 
     I want to refer you to the first so-called salacious 
     occasion, and I'm not going to get into the details. I'm 
     not--
       A. Can--can we--can you call it something else?
       Q. Okay.
       A. I mean, this is--this is my relationship--
       Q. What would you like to call it?
       A. --so, I mean, is--
       Q. This is the--or this was--
       A. It was my first encounter with the President, so I don't 
     really see it as my first salacious--that's not what this 
     was.
       Q. Well, that's kind of been the word that's been picked up 
     all around. So--
       A. Right.
       Q. --let's stay on this first--
       A. Encounter, maybe?
       Q. Encounter, okay.
       A. Okay.
       Q. So we all know what we're talking about. You had several 
     of these encounters, perhaps 10 or 11 of these encounters; is 
     that right?
       A. Yes.
       Q. Okay. Now, with regard to the first one on November the 
     15th, 1995, you have testified to a set of facts where the 
     President actually touched you in certain areas--is that 
     right--and that's--that's where I want to go. That's as far 
     as I want to go with that question.
       MR. CACHERIS: If that's as far as it goes, we will not 
     object--
       MR. BRYANT: Okay.
       MR. CACHERIS: --and if it goes any further, we will object.
       MR. BRYANT: Okay.
       BY MR. BRYANT:
       Q. You have testified to that?
       A. Yes.
       Q. And I have the excerpts out, and I don't--but they've 
     been adopted and affirmed as true. So I'm not going to get--
     get you looking at--have you read those excerpts.
       A. I appreciate that.
       Q. Now, in the--in later testimony before the grand jury, 
     you were given a definition, and in fact it was the same 
     definition that was used in the Paula Jones lawsuit, of 
     ``sexual relations.'' Do you recall the--
       A. So I've read.
       Q. Yes.
       A. I was not shown that definition.
       Q. But you were asked a question that incorporated that 
     definition.
       A. Not prior to this whole--not prior to the Independent 
     Counsel getting involved.
       Q. But--no--it was the Independent Counsels themselves who 
     asked you this question.
       A. Right. Oh, so you're--you're saying in the grand jury, I 
     was shown a definition of--
       Q. Right.
       A. Yes, that's correct.
       Q. And you admitted in that answer to that question that 
     the conduct that you were involved in, the encounter of 
     November the 15th, 1995, fit within that definition of 
     ``sexual relations''?
       A. The second encounter of that evening did.
       Q. Right.
       And were there other similar encounters later on with the 
     President, not that day, but other occasions that would have 
     likewise fit into that definition of ``sexual relations'' in 
     the Paula Jones case?
       A. Yes. And--yes.
       Q. There was more than one occasion where that occurred?
       A. Correct.
       Q. So, if the President testifies that he did not--he was 
     not guilty of having a sexual relationship under the Paula 
     Jones definition even, then that testimony is not truthful, 
     is it?
       MR. CACHERIS: Objection. She should not be called upon to 
     testify what was in the mind of another person. She's 
     testifying to the facts, and she has given the facts.
       MR. BRYANT: I would ask that she answer the question.
       SENATOR DeWINE: Go ahead.
       SENATOR LEAHY: The objection is noted for the record.
       SENATOR DeWINE: The objection is noted. She may answer the 
     question.
       THE WITNESS: I--I really--
       SENATOR LEAHY: If she can.
       THE WITNESS: --don't feel comfortable characterizing 
     whether what he said was truthful or not truthful. I know 
     I've testified to what I believe is true.
       BY MR. BRYANT:
       Q. Well, truth is not a wandering standard.
       A. Well--
       Q. I would hope not. But you have testified, as I've told 
     you, that what you and he did together on November the 15th, 
     1995 fit that definition of the Paula Jones, and you've 
     indicated that there were other occasions that likewise--
       A. Yes, sir.
       Q. --that that occurred.
       But now the President has indicated as a part of his 
     specific defense--he has filed an answer with this Senate 
     denying that this occurred, that he did these actions.
       A. I know. I'm not trying to be difficult, but there is a 
     portion of that definition that says, you know, with intent, 
     and I don't feel comfortable characterizing what someone 
     else's intent was.
       I can tell you that I--my memory of this relationship and 
     what I remember happened fell within that definition.
       If you want to--I don't know if there's another way to 
     phrase that, but I'm just not comfortable commenting on 
     someone else's intent or state of mind or what they thought.
       Q. Let's move forward to December the 19th, 1997, at that 
     point you made reference to earlier.
       A. I'm sorry. Can you repeat the date again? I'm sorry.

[[Page 1840]]

       Q. Yes. December the 19th, 1997.
       A. Okay, sorry.
       Q. At that point where you testified that you received a 
     subpoena in the Paula Jones case, and that was, of course, on 
     December the 19th, 1997.
       Do you recall the specific time of day and where you were 
     when you were served with the subpoena?
       A. I was actually handed the subpoena at the Metro entrance 
     of the Pentagon--at the Pentagon, and the time--I think it 
     was around 4:30--4--I--I--if I've testified to something 
     different, then, I accept whatever I testified to, closer to 
     the date. Sometime in the late afternoon.
       Q. Did they call you, and you had to come out of your 
     office and go outside--
       A. Correct.
       Q. --and do that?
       Okay. And what did you do after you accepted service of the 
     subpoena?
       A. I started crying.
       Q. Did he just give it to you and walk away, or did he give 
     you any kind of explanation?
       A. I think I made a stink. I think I was trying to hope 
     that he would convey to the Paula Jones attorneys that I 
     didn't know why they were doing this, and this is ridiculous, 
     and he said something or another, there is a check here for 
     witness fee. And I said I don't want their stinking money, 
     and so--
       Q. What did you do after, after you got through the 
     emotional part?
       A. I went to a pay phone, and I called Mr. Jordan.
       Q. Any reason you went to a pay phone, and why did you call 
     Mr. Jordan? Two questions, please.
       A. First is because my office in the Pentagon was probably 
     a room this size and has--let's see, one, two, three, four--
     four other people in it, and there wasn't much privacy. So 
     that I think that's obvious why I wouldn't want to discuss it 
     there.
       And the second question was why Mr. Jordan--
       Q. Why did you call Mr. Jordan; yes.
       A. Because I couldn't call Mrs. Currie because it was--I 
     hadn't expected to be subpoenaed that soon. So she was 
     grieving with her brother's passing away, and I didn't know 
     who else to turn to. So--
       Q. And what--what occurred with that conversation with Mr. 
     Jordan?
       A. Well, I remember that--that he couldn't understand me 
     because I was crying. So he kept saying: ``I don't understand 
     what you're saying. I don't understand what you're saying.''
       And I just was crying and crying and crying. And so all I 
     remember him saying was: ``Oh, just come here at 5 o'clock.''
       So I did.
       Q. You went to see Mr. Jordan, and you were inside his 
     office after 5 o'clock, and you did--is that correct?
       A. Yes.
       Q. Were--were you interrupted, in the office?
       A. Yes. He received a phone call.
       Q. And you testified that you didn't know who that was that 
     called?
       A. Correct.
       Q. Did you excuse yourself?
       A. Yes.
       Q. What--after you came back in, what--what occurred? Did 
     he tell you who he had been talking to?
       A. No.
       Q. Okay. What happened next?
       A. I know I've testified about this--
       Q. Yes.
       A. --so I stand by that testimony, and my recollection 
     right now is when I came back in the room, I think shortly 
     after he had placed a phone call to--to Mr. Carter's office, 
     and told me to come to his office at 10:30 Monday morning.
       Q. Did you know who Mr. Carter was?
       A. No.
       Q. Did Mr. Jordan tell you who he was?
       A. No--I don't remember.
       Q. Did you understand he was going to be your attorney?
       A. Yes.
       Q. Did you express any concerns about the--the subpoena?
       A. I think that happened before the phone call came.
       Q. Okay, but did you express concerns about the subpoena?
       A. Yes, yes.
       Q. And what were those concerns?
       A. In general, I think I was just concerned about being 
     dragged into this, and I was concerned because the subpoena 
     had called for a hatpin, that I turn over a hatpin, and that 
     was an alarm to me.
       Q. How--in what sense was it--in what sense was it an alarm 
     to you?
       A. The hatpin being on the subpoena was evidence to me that 
     someone had given that information to the Paula Jones people.
       Q. What did Mr. Jordan say about the subpoena?
       A. That it was standard.
       Q. Did he have any--did he have any comment about the 
     specificity of the hatpin?
       A. No.
       Q. And did you--
       A. He just kept telling me to calm down.
       Q. Did you raise that concern with Mr. Jordan?
       A. I don't remember if--if I've testified to it, then yes. 
     If--I don't remember right now.
       Q. Did--would you have remembered then if he made any 
     comment or answer about the hatpin?
       A. I mean, I think I would.
       Q. And you don't remember?
       A. I--I remember him saying something that it was--you 
     know, calm down, it's a standard subpoena or vanilla 
     subpoena, something like that.
       Q. Did you ask Mr. Jordan to call the President and advise 
     him of the subpoena?
       A. I think so, yes. I asked him to inform the President. I 
     don't know if it was through telephone or not.
       Q. And you did that because the President had asked you to 
     make sure you let Betty know that?
       A. Well, sure. With Betty not being in the office, I 
     couldn't--there wasn't anyone else that I could call to get 
     through to him.
       Q. Did Mr. Jordan say to you when he might see the 
     President next?
       A. I believe he said he would see him that evening at a 
     holiday reception.
       Q. Did Mr. Jordan during that meeting make an inquiry about 
     the nature of the relationship between you and the President?
       A. Yes, he did.
       Q. What was that inquiry?
       A. I don't remember the exact wording of the questions, but 
     there were two questions, and I think they were something 
     like did you have sex with the President or did he--and if--
     or did he ask for it or some--something like that.
       Q. Did you--what did you suspect at that point with these 
     questions from Mr. Jordan in terms of did he know or not know 
     about this?
       A. Well, I wasn't really sure. I mean, two things. I think 
     there is--I know I've testified to this, that there was 
     another component to all of this being Linda Tripp and her--
     what she might have led me to believe or led me to think and 
     how that might have characterized how I was perceiving the 
     situation.
       I--I sort of felt that I didn't know if he was asking me as 
     what are you going to say because I--I don't know these 
     answer to these questions, or he was asking me as I know the 
     answer to these questions and what are you going to say. So, 
     either way, for me, the answer was no and no.
       Q. And that's just what I wanted to ask you--you did answer 
     no to both of those, but--
       A. Yes.
       Q. --as you explained--you didn't mention this directly, 
     but you mentioned in some of your earlier testimony about it, 
     that this was kind of a wink and--you thought this might be a 
     wink-and-nod conversation, where he really knew what was 
     going on, but--
       A. Well, I think that's what I just said.
       Q. --he was testing you to see what you would say?
       A. --that I wasn't--I--that was one of the--that was one of 
     the things that went through my mind. I mean, it was not--I 
     think that's what I just testified to, didn't I?
       Q. You didn't use the term ``wink-and-nod,'' though.
       A. Oh.
       Q. Did you have any conversation with Mr. Jordan during 
     that meeting about the specifics of an affidavit?
       A. No.
       Q. Do you know if the subject of an affidavit even came up?
       A. I don't think so.
       Q. What happened next? Is that when he made the call to Mr. 
     Carter, after this conversation?
       A. No. He made the call to Mr.--I think--well, I think he 
     made the call to Mr. Carter, uh, shortly after I came back 
     into the room, but I could be wrong.
       Q. And then the meeting concluded after that--after the 
     appointment was set up with Mr. Carter, the meeting 
     concluded?
       A. Yes.
       SENATOR DeWINE: Mr. Bryant, we're going to need to break 
     sometime in the next 5 minutes. Is this a good time, or do 
     you want to complete--
       MR. BRYANT: This is a good time.
       SENATOR DeWINE: Okay. We'll take a 5-minute break.
       THE VIDEOGRAPHER: We're going off the record at 12:04 p.m.
       [Recess.]
       THE VIDEOGRAPHER: We are going back on the record at 12:16 
     p.m.
       SENATOR DeWINE: We are back on the record.
       Let me advise House Managers that they have consumed one 
     hour and 54 minutes.
       Mr. Bryant, you may proceed.
       MR. BRYANT: Thank you, sir.
       BY MR. BRYANT:
       Q. Ms. Lewinsky, let me just cover a couple of quick 
     points, and then I'll move on to another area, at least the 
     next meeting with Mr. Jordan and eventual meeting with Mr. 
     Carter.
       Back when issues of--we were discussing the issues of cover 
     stories, uh, would you tell me about the, uh, code name with 
     Betty Currie, the President's secretary and how that worked 
     in terms of the use--I guess the word ``Kay,'' the name 
     ``Kay,'' and were there other code names, and when did this 
     start?
       A. Sure. First, let me say there's--from my experience with 
     working with Independent

[[Page 1841]]

     Counsel on this subject area, there--my initial memory of 
     things and then what I came to learn from, from other 
     evidence, I think, are sort of two different things. So I 
     initially hadn't remembered when that had happened or what 
     had happened.
       The name ``Kay'' was used because Betty and I first came to 
     know each other and know--or, I guess I came to know of Mrs. 
     Currie through Walter Kaye, who was a family friend, and I 
     think that that--I don't remember when we started using it, 
     but I know that by January at some point--by let's just say 
     January, I think, 12th or 13th, we were doing that. So I know 
     I was beyond paranoid at this point.
       Q. Was ``Kay'' your code name, so to speak?
       A. I believe--yes, yes. So she was ``Kay'' and I was 
     ``Kay.''
       Q. So any time, uh--not any time--so you used the ``Kay'' 
     name interchangeably between the two--just between the two of 
     you?
       A. Just for paging messages.
       Q. And, uh, when we're talking about that Ms. Currie would 
     WAVE you into the White House, would that occur when the 
     President was there? I mean, you went in--
       A. There--there were times that I went to see Mrs. Currie 
     when the President wasn't there.
       Q. Right. And she would WAVE you in.
       A. Correct.
       Q. And there were times other people WAVE'd you in when the 
     President wasn't there?
       A. Correct.
       Q. But when the President was there, and you were going to 
     see the President, Ms. Currie was the one that always WAVE'd 
     you in?
       A. Yes, and I think, unless--maybe on the occasions of the 
     radio address or it was an official function.
       Q. Now, I think we talked a little bit about this. During 
     your December the 19th meeting with Mr. Jordan, uh, he did 
     schedule you a time to meet, uh, and introduce you to Mr. 
     Carter?
       A. Correct.
       Q. And that--when was that meeting with Mr. Carter 
     scheduled?
       A. Uh, I believe for--it was Monday morning. I think it was 
     11 o'clock, around--sometime around that time.
       Q. And my notes say that would have been December the 22nd, 
     1997.
       A. Correct.
       Q. Did you, uh, call to meet him earlier, and if so, why?
       A. Yes. I had--I had had some concerns over the weekend 
     that I didn't know if--if Mr. Jordan knew about the 
     relationship or didn't know about the relationship. I was 
     concerned about--I'm sure you can understand that I was 
     dealing with a set of facts that were very different from 
     what the President knew about being pulled into this case in 
     that I had, in fact, disclosed information. So I was very 
     paranoid, and, uh, I, uh, I--I was trying to--trying to see 
     what Mr. Jordan knew was--was trying to inform him, was 
     trying to just get a better grasp of what was going on.
       Is that--is that clear? No?
       Q. You were--you were worried that Mr. Jordan didn't have 
     a--did not have a grasp of what was really going on?
       A. Correct.
       Q. And that would be in terms of actually knowing the real 
     relationship between you and the President?
       A. Correct.
       Q. So how did you attempt to correct that?
       A. Well, I--I sort of--I think the way it came up was I 
     said, uh--I think I said to Mr. Jordan--I know I've testified 
     to this, uh, that--something about what about if someone 
     overheard the phone calls that I had with him. And Mr. 
     Jordan, I believe, said something like: So what? The 
     President's allowed to call people.
       And then--well.
       Q. Now, was this at a meeting on December the 22nd, before 
     you went to see Mr. Carter?
       A. Correct.
       Q. I assume you--you went to Mr. Jordan's office first, and 
     then he was going to escort you over and turn you over to Mr. 
     Carter?
       A. Correct.
       Q. And it was at that meeting that you brought up the 
     possibility of someone overhearing a conversation with the 
     President and you--between the two of you?
       A. Yes.
       Q. What else was said at that meeting with Mr. Jordan?
       A. I think it covered a topic that I thought we weren't 
     discussing here.
       Q. Uh, okay. All right. I'm not sure.
       A. Okay. Well, I--I know I've testified to this in my--I 
     think in all three, if not both of my grand jury appearances, 
     and I'm very happy to stand by that testimony.
       Q. All right. I'm going to go around this a little bit 
     without getting into details. You had a conversation with Mr. 
     Jordan to detail--to give him more specific details of your 
     relationship with the President.
       A. Uh, to give him more details of some of the types of 
     phone calls that we had.
       Q. Okay. Uh, did you ask Mr. Jordan had he spoken with the 
     President during that conversation?
       A. Yes, I believe so.
       Q. And why was this--why did you need to know that, or why 
     was it important that you know that?
       A. I wanted the President to know I'd been subpoenaed.
       Q. Did, uh--in your, uh, proffer, you say that you made it 
     clear to Mr. Jordan that you would deny the sexual 
     relationship. Do you recall saying that in your proffer?
       A. Uh, I know--I know that was written in my proffer.
       Q. Okay. Well, I guess the better question is did you--did 
     you in fact make that clear to Mr. Jordan that you would deny 
     a sexual relationship with the President?
       A. I--I'm not really sure. I--this is sort of an area that, 
     uh, has been difficult for me. I think, as I might have 
     discussed in the grand jury, that when I originally wrote 
     this proffer, it was to be a road map and, really, something 
     to help me to get immunity and not necessarily--it's not 
     perfect.
       Uh, so, I think that was my intention--I know that was my 
     intention of--or at least what I thought I was doing--but I 
     never really thought that this would become the be-all and 
     end-all, my proffer.
       Q. Did, uh, did you bring with you to the meeting with Mr. 
     Jordan, and for the purpose of carrying it, I guess, to Mr. 
     Carter, items in response to this request for production?
       A. Yes.
       Q. Did you discuss those items with Mr. Jordan?
       A. I think I showed them to him, but I'm not 100 percent 
     sure. If I've testified that I did, then I'd stand by that.
       Q. Okay. How did you select those items?
       A. Uh, actually, kind of in an obnoxious way, I guess. I--I 
     felt that it was important to take the stand with Mr. Carter 
     and then, I guess, to the Jones people that this was 
     ridiculous, that they were--they were looking at the wrong 
     person to be involved in this. And, in fact, that was true. I 
     know and knew nothing of sexual harassment. So I think I 
     brought the, uh, Christmas cards, that I'm sure everyone in 
     this room has probably gotten from the President and First 
     Lady, and considered that correspondence, and some innocuous 
     pictures and--they were innocuous.
       Q. Were they the kind of items that typically, an intern 
     would receive or, like you said, any one of us might receive?
       A. I think so.
       Q. In other words, it wouldn't give away any kind of 
     special relationship?
       A. Exactly.
       Q. And was that your intent?
       A. Yes.
       Q. Did you discuss how you selected those items with 
     anybody?
       A. I don't believe so.
       Q. Did Mr. Jordan make any comment about those items?
       A. No.
       Q. Were any of these items eventually turned over to Mr. 
     Carter?
       A. Yes.
       Q. And did you tell Mr. Jordan at that meeting that morning 
     that these were not all of the gifts?
       A. I think I--I know I sort of alluded to that in my 
     proffer, and I don't, uh--it's possible. I don't have a 
     specific recollection of that.
       Q. And do you have a recollection of any response he may 
     have made if you said that?
       A. No.
       Q. That--did you tell Mr. Jordan that day that the, uh, 
     President gave you a hatpin and that the hatpin was mentioned 
     in the subpoena?
       A. No.
       Q. Did you discuss the hatpin with Mr. Jordan?
       A. On the 22nd?
       Q. Yes.
       A. No.
       Q. Any other time?
       A. Yes.
       Q. When was that?
       A. On the 19th.
       Q. Okay, and what was--I think I may have missed that, 
     going through that. Tell me about it.
       A. Actually, I think we--we went through it.
       Q. You just maybe mentioned it.
       A. I mentioned it when I first mentioned to him the 
     subpoena that the hatpin had concerned me.
       Q. What was the significance of that hatpin to you? That 
     seems to stand out. Was that--was that a--
       A. Right. I think, as I mentioned before, it was an alarm 
     to me because it was a specific item--
       Q. Right.
       A. --in this list of generalities--I don't know 
     generalities, but of general things--you sort of go--hatpin?
       Q. Right. I recall that, but I--I think my question was, 
     was it of any special significance to you.
       A. Sure.
       Q. Was it, like, the first gift or something, that it 
     really stood out above the others?
       A. Yes. It--it was--it was the first gift he gave me. It 
     was a thoughtful gift. It was beautiful.
       Q. And was the hatpin in that list, that group of items 
     that you carried to surrender to Mr. Carter?
       A. No.
       Q. And the hatpin was not in that list of items that you 
     showed Mr. Jordan?

[[Page 1842]]

       A. I--I didn't show Mr. Jordan a list of items.
       Q. No--I thought you said you showed him the items.
       A. Correct.
       Q. And the hatpin was not in that group--I may have 
     ``list''--
       A. Oh.
       Q. --but the hatpin was not in that group of items--
       A. No, it was not.
       Q. --that you showed Mr. Jordan. Okay.
       Tell us, if you would, how you arrived at Mr. Carter's. I 
     know you rode in a car, but Mr. Jordan was with you--
       A. Yes.
       Q. --you went in--and tell us what happened.
       A. Uh, in the car, we spoke about job things. I know he 
     mentioned something about, I think, getting in touch with 
     Howard Pastor, and I mentioned to Mr. Jordan that Mr. Bacon 
     knew Mr. Pastor and had already gotten in touch with him, and 
     so he should--I just wanted Mr. Jordan to be aware of that.
       Uh, we talked about--it was really all about the job stuff 
     because Mr. Jordan--the man driving the car--I didn't want to 
     discuss anything with the case.
       Q. But once you arrived, and Mr. Jordan made the 
     introduction--
       A. Correct.
       Q. --between the two of you. And did he explain to Mr. 
     Carter your situation, or did he go beyond just the 
     perfunctory introduction?
       A. No.
       Q. Did he leave?
       A. Yes.
       Q. Did you, uh--I guess, generally, what did you discuss 
     with Mr. Carter?
       A. The same vanilla story I had kind of--well, actually, 
     not even that. I discussed with Mr. Carter the, uh, that this 
     was ridiculous, that I was angry, I didn't want to be 
     involved with this, I didn't want to be associated with Paula 
     Jones, with this case.
       Q. Did you, uh--
       A. I asked if I could sue Paula Jones. [Laughing.]
       Q. Did you discuss an affidavit?
       A. Yes, I believe I mentioned an affidavit.
       Q. Did you mention, uh, the, uh--well, was there discussion 
     about how you could sign an affidavit that might be--allow 
     you to skirt being called as a witness?
       A. Mr. Carter said that was a possibility but that there 
     were other things that we should try first; that he, uh, 
     thought--well, actually, can I ask my attorneys a question 
     for a moment?
       MR. BRYANT: Uh, sure.
       [Witness conferring with counsel.]
       SENATOR DeWINE: Counsel, Ms. Lewinsky's mike is carrying; 
     it's picking up, so we don't want to--
       THE WITNESS: Sorry. I was only saying nice things about you 
     all.
       SENATOR DeWINE: Thank you.
       [Laughter.]
       MR. CACHERIS: So that you'll know what we're discussing 
     here, as you know, Ms. Lewinsky is not required to give up 
     her lawyer-client privileges, and the question we don't know 
     the answer to and would like to address after lunch is 
     whether in fact Mr. Carter has testified to this 
     conversation.
       Therefore, perhaps--
       SENATOR DeWINE: All right. Maybe counsel at this point 
     could--could you rephrase--rephrase the question or ask 
     another question, and after lunch, we can come back--
       MR. CACHERIS: Or come back.
       SENATOR DeWINE: Well, I don't want--I don't think he has to 
     move off the general area if he can--I'll leave that up to 
     counsel.
       MR. BRYANT: There may be some misunderstanding or--
       SENATOR DeWINE: Why don't you rephrase the question, and 
     we'll see where we are.
       MR. BRYANT: --on this issue of--well, on this issue of the 
     attorney-client privilege. It is our understanding that she 
     is able to testify. But again, I don't know, uh, if we're 
     going to resolve that right now.
       SENATOR DeWINE: Why don't we try to resolve that issue over 
     lunch, and--
       MR. BRYANT: Because I do have other questions that would 
     relate to this area.
       SENATOR DeWINE: --you can stay in this general area.
       MR. BRYANT: Well, I'm not sure I can stay in this area too 
     far without other questions that might arguably be involved 
     in that privilege. I can ask them, and you can object if you 
     think they're within that range.
       MR. CACHERIS: Well, as I said, it's our understanding that 
     under her agreement with the Independent Counsel, she has not 
     been required to waive her lawyer-client privilege, and we 
     don't want to do so here. That's that simple. And, Mr. 
     Bryant, I want to check to see if Mr. Carter has testified 
     about this. If he has, then we might be objecting--
       MR. BRYANT: Well, she has already, I think, waived that 
     privilege through talking with the FBI and those folks. I 
     mean, we have statements that concern those conversations--
       SENATOR DeWINE: Well, let's, instead of MR. BRYANT: And the 
     302's.
       SENATOR DeWINE: Counsel, let me just--if I could interrupt 
     both of you, to keep moving here, Mr. Bryant, you have a 
     choice. You can continue on this line of questioning, and we 
     will have to deal with that, or you can move off of it, and 
     in 20 minutes we'll be at a lunch break and then we can try 
     to resolve that.
       MR. BRYANT: To be clear and fair, let's just--let me 
     postpone the rest of this--
       SENATOR DeWINE: That will be fine.
       MR. BRYANT: --exam, and we'll move over to December 28th, 
     and we'll come back if it's appropriate.
       SENATOR DeWINE: That will be fine.
       THE WITNESS: I'm sorry. I'm not trying to be difficult. I'm 
     sorry.
       MR. BRYANT: No. That's a valid concern; it really is.
       Let's talk a minute--I just don't want to forget to do 
     this; unless I make notes, I forget.
       SENATOR LEAHY: You've got enough people here making notes; 
     I don't think it'll be--I don't think it'll be forgotten.
       BY MR. BRYANT:
       Q. We're going to move in the direction of the December 
     28th, 1997 meeting, and I'm going to ask you at some point 
     did you meet with the President later in December.
       A. Yes.
       Q. Okay, and what date was that?
       A. December 28th, 1997.
       Q. Thank you. How did the meeting come about?
       A. Uh, I contacted Mrs. Currie after Christmas and asked 
     her to find out if the President still wanted to give me his 
     Christmas present, or my Christmas present.
       Q. Did Ms. Currie get back to you?
       A. Yes, she did.
       Q. And what was her response?
       A. To come to the White House at 8:30 a.m. on the 28th.
       Q. And that would have been Sunday?
       A. Yes.
       Q. Did you in fact go to the White House on that date?
       A. Yes.
       Q. And how did you get in?
       A. I believe the Southwest Gate.
       Q. Did Ms. Currie WAVE you in?
       A. I think so.
       Q. You've testified to that previously.
       A. Okay, then I accept that.
       Q. This, uh, meeting on the 28th was a Sunday, and Ms. 
     Currie--again, according to your prior testimony--WAVE'd you 
     in. This was all consistent with what the President had told 
     you to do about, number one, coming on weekends; is that 
     correct?
       A. I--I--I don't think me coming in on that Sunday had--I 
     mean, for me, my memory of it was that it was a holiday time, 
     so it could have been any day. It's pretty quiet around the 
     White House from Christmas to New Year's.
       Q. And it would have been consistent with her WAVEing you 
     in when she was there at work on Sunday?
       A. Yes.
       Q. That was unusual, though, for her to be in on Sunday, 
     wasn't it?
       A. I--I--I--I think so, but I mean, that's her--I think 
     that's something you'd have to ask her.
       MR. BRYANT: I'm concerned about the time. I'm going to go 
     ahead and continue with this, and we'll just stop wherever we 
     have a--whenever you tell us to stop. This will take a little 
     bit longer than another 15 minutes or so; but it's 
     appropriate, I think, for us to continue.
       SENATOR DeWINE: Well, frankly, it's up to you.
       MR. BRYANT: Okay.
       SENATOR DeWINE: Do you have a problem in breaking it?
       MR. BRYANT: No; no, I don't think so.
       SENATOR DeWINE: I mean, if you do, we can take lunch now. 
     I'll leave that up to you.
       MR. BRYANT: Uh, why don't we take the lunch now--
       SENATOR DeWINE: All right. No one has any objection to 
     that, we will do that.
       THE WITNESS: I never object to food.
       SENATOR DeWINE: Let me just announce to counsel you have 
     used 2 hours and 14 minutes. It is now 20 minutes until 1. 
     We'll come back here at 20 minutes until 2. And we need 
     during this break also to see counsel and try to resolve the 
     other issue prior to going back in. This is the privilege 
     issue.
       SENATOR LEAHY: Did counsel for Ms. Lewinsky have to make a 
     couple phone calls first, before we have that discussion? I 
     think--
       SENATOR DeWINE: My suggestion would be we do that at the 
     last 15 minutes of the break.
       SENATOR LEAHY: I think he said he wanted to call Mr. 
     Carter; that's why--
       MR. CACHERIS: Meet you back up here?
       SENATOR DeWINE: Yes. I would also--the sergeant-at-arms has 
     asked me to announce that the food is on this floor, and 
     since we have a very limited period of time, we suggest you 
     try to stay on the floor.
       MS. HOFFMANN: We were planning to go back--
       SENATOR DeWINE: Except--I understand. I know that you're--
       MR. CACHERIS: We have our own arrangements.
       SENATOR DeWINE: I know that you have your room, and you've 
     made your own arrangements, and that's fine.
       So we will start back in one hour.
       THE VIDEOGRAPHER: We are going off the record at 12:39 p.m.
       [Whereupon, at 12:39 p.m., the deposition was recessed, to 
     reconvene at 1:39 p.m. this same day.]

[[Page 1843]]




                           afternoon session

       THE VIDEOGRAPHER: We are going back on the record at 13:43 
     hours.
       SENATOR DeWINE: We are now back on the record.
       As we broke for lunch, there was an objection that had been 
     made by Ms. Lewinsky's counsel. Let me call on them at this 
     point for statements.
       MR. CACHERIS: Yes. We have examined the record during the 
     course of the break, and while we know that the immunity 
     agreement does provide for Ms. Lewinsky to maintain her 
     lawyer-client privilege, we think in this instance, the 
     matter has been testified so fully that it has been waived. 
     So the objection that we lodged is withdrawn.
       SENATOR DeWINE: Thank you very much.
       Mr. Bryant, you may proceed.
       MR. BRYANT: Thank you, Mr. Senator.
       BY MR. BRYANT:
       Q. We've got you to the point where Mr. Jordan has escorted 
     you to Mr. Carter's office and has departed, and you and Mr. 
     Carter have conversations.
       Generally, what did you discuss with Mr. Carter?
       A. I guess the--the reasons why I didn't think I should be 
     called in this matter.
       Q. Did he ask you questions?
       A. Yes.
       Q. What type of questions did he ask you?
       A. Um, they ranged from where I lived and where I was 
     working to did I have a relationship with the President, 
     did--everything in between.
       Q. When he--when he asked you about the relationship, did 
     you understand he meant a sexual-type relationship?
       A. He asked me questions that--that indicated he was being 
     specific.
       Q. And did--did you deny such a relationship?
       A. Yes, I did.
       Q. Did he ask you questions about if you were ever alone 
     with the President?
       A. Yes, he did.
       Q. And did you deny that?
       A. I think I mentioned that I might have brought the 
     President papers on occasion, may have had an occasion to be 
     alone with him, but not--not anything I considered 
     significant.
       Q. But that was not true either, was it?
       A. No.
       Q. And in fact, that--the fact that you brought him papers, 
     that was part of the cover-up story?
       A. Correct.
       Q. I'm unclear on a point I want to ask you. Also, did Mr. 
     Carter ask you about how you perhaps were pulled into this 
     case, and you gave some answer about knowing Betty Currie 
     and--and Mr. Kaye? Does that ring bells? You gave that 
     testimony in your deposition.
       A. That that's how I got pulled into the case?
       Q. Right. Did--
       A. May I see that, please?
       Q. It's about your denying the relationship with the 
     President, and you think maybe you got pulled into the case. 
     It's--certainly, it's--it's in your grand jury--okay. It's--
     it's in the August 1 interview, page 9. This was a 302 exam 
     from the FBI.
       A. Um--
       MR. BRYANT: Let me give that to her. Let me just give it to 
     her to refresh her memory. I'm not going to put it in 
     evidence, although it's--it should be there.
       [Handing document.]
       [Witness perusing document.]
       THE WITNESS: I don't think that's an accurate 
     representation of what I might have said in this interview.
       BY MR. BRYANT:
       Q. Okay. Would you--how would you have related Walter Kaye 
     in that interview? How would his name have come up?
       A. In this interview or with Mr. Carter?
       Q. Well, in the interview with Mr. Carter that I assume was 
     sort of summarized in that--
       A. Right.
       Q. --302, but, yes, with Mr. Carter.
       A. Uh, I think I mentioned that I was friendly with Betty 
     Currie, the President's secretary.
       Q. And how would Mr. Kaye's name have come up in the 
     conversation?
       A. Because of how I met Ms. Currie was through--that's how 
     I came to know of Ms. Currie and--and first introduced myself 
     to her. Excuse me.
       Q. Let's go back now and resume where we were before the 
     lunch break. We were talking about the December visit to the 
     White House and the conversation with the President. You had 
     discussed--well, I think we're to the point where perhaps 
     you--or I'll ask you to bring up your discussion with the 
     President about the subpoena and the request for production.
       A. Um, part way into my meeting with the President, I 
     brought up the concern I had as to how I would have been 
     put--how I might have been alerted or--not alerted, but how I 
     was put on the witness list and how I might have been alerted 
     to the Paula Jones' attorneys, and that that was--I was sort 
     of concerned about that. So I discussed that a little, and 
     then I said, um, that I was concerned about the hatpin. And 
     to the best of my memory, he said that that had concerned him 
     as well, and--
       Q. Could he have said that bothered him?
       A. He--he could have. I--I mean, I don't--I know that 
     sometimes in the--in my grand jury testimony, they've put 
     quotations around things when I'm attributing statements to 
     other people, and I didn't necessarily mean that those were 
     direct quotes. That was the gist of what I remembered him 
     saying. So, concern, bothered, it doesn't--
       Q. Was--was there a discussion at that point as to how 
     someone might have--may have discovered the--the hatpin and 
     why?
       A. Well, he asked me if I had told anybody about it, and I 
     said no.
       Q. But the two of you reached no conclusion as to how that 
     hatpin came--
       A. No.
       Q. --to appear on the motion?
       A. No.
       Q. Did he appear at all, I think, probably surprised that--
     that you had received a request for production of documents 
     or the--the hatpin was on that document?
       A. I didn't discuss--we didn't discuss documents, request 
     for documents, but with regard to the hatpin, um, I don't 
     remember him being surprised.
       Q. Mm-hmm. How long did the discussion last about the--this 
     request for production of--of the items?
       A. The topic of the Paula Jones case, maybe 5 minutes. Not 
     very much.
       Q. What else was said about that?
       A. About the case?
       Q. Yes.
       A. There was--then, at some point in this discussion--I 
     think it was after the hatpin stuff--I had said to him that I 
     was concerned about the gifts and maybe I should put them 
     away or possibly give them to Betty, and as I've testified 
     numerously, his response was either ranging from no response 
     to ``I don't know'' or ``let me think about it.''
       Q. Did the conversation about the--the gifts that you just 
     mentioned, did that immediately follow and tie into, if you 
     will, the conversation about the request for production of 
     items, the hatpin and so forth? Did one lead to the other?
       A. I don't remember. I know the gift conversation was 
     subsequent to the hatpin comment, but I--I don't remember if 
     one led to the other.
       Q. What else happened after that?
       A. Hmm, I think we went back to sort of--we left that 
     topic, kind of went back to the visit.
       Q. Did--which included exchanging the Christmas gifts?
       A. Correct.
       Q. Okay.
       A. I had already--he had already given me my presents at 
     this point.
       Q. Okay. Did--he gave you some gifts that day, and my 
     question to you is what went through your mind when he did 
     that, when you knew all along that you had just received a 
     subpoena to produce gifts. Did that not concern you?
       A. No, it didn't. I was happy to get them.
       Q. All right. Why did it--beyond your happiness in 
     receiving them, why did the subpoena aspect of it not concern 
     you?
       A. I think at that moment--I mean, you asked me when he 
     gave me those gifts. So, at that moment, when I was there, I 
     was happy to be with him. I was happy to get these Christmas 
     presents. So I was nervous about the case, but I had made a 
     decision that I wasn't going to get into it too much--
       Q. Well--
       A. --with a discussion.
       Q. --have you in regards to that--you've testified in the 
     past that from everything that the President had told you 
     about things like this, there was never any question that you 
     were going to keep everything quiet, and turning over all the 
     gifts would prompt the Jones attorneys to question you. So 
     you had no doubt in your mind, did you not, that you weren't 
     going to turn these gifts over that he had just given you?
       A. Uh, I--I think the latter half of your statement is 
     correct. I don't know if you're reading from my direct 
     testimony, but--because you said--your first statement was 
     from everything the President had told you. So I don't know 
     if that was--if those were my words or not, but I--no, I 
     was--I--it--I was concerned about the gifts. I was worried 
     someone might break into my house or concerned that they 
     actually existed, but I wasn't concerned about turning them 
     over because I knew I wasn't going to, for the reason that 
     you stated.
       Q. But the pattern that you had had with the President to 
     conceal this relationship, it was never a question that, for 
     instance, that given day that he gave you gifts that you were 
     not going to surrender those to the Jones attorneys because 
     that would--
       A. In my mind, there was never a question, no.
       Q. I'm just actually looking at your deposition on page--
     no, I'm sorry--your grand jury proceedings of August the 6th, 
     just to be clear, since you raised that question.
       1004 in the book, appendices.
       You indicate that in response to a question, ``What do you 
     think the President is thinking when he is giving you gifts 
     when there is a subpoena covering gifts. I mean, does he 
     think in any way, shape or form that you're going to be 
     turning these gifts over?'' And your answer is, ``You know, I 
     can't answer what he was thinking, but, to me, it

[[Page 1844]]

     was--there was never a question in my mind, and I--from 
     everything he said to me, I never questioned him that we were 
     ever going to do anything but keep this private. So that 
     meant deny it, and that meant do whatever appropriate--take 
     whatever appropriate steps needed to be taken, you know, for 
     that to happen, meaning that if--if I had to turn over every 
     gift--if I had turned over every gift he had given me--first 
     of all, the point of the affidavit and the point of 
     everything was to try to avoid a deposition. So where I'd 
     have to sort of--you know, I wouldn't have to lie as much as 
     I would necessarily in an affidavit how I saw it,'' and you 
     continue on, just one short paragraph.
       A. Right.
       Q. ``So, by turning over all of these gifts, it would at 
     best prompt him to want to question me about what kind of 
     friendship I had with the President, and they would want to 
     speculate and they'd leak it, and my name would be trashed 
     and he would be in trouble.''
       So you recall giving that testimony?
       A. Yes. I accept--I accept what's said here.
       Q. Okay.
       A. It's a little different from what you said, but very 
     close.
       Q. Thank you.
       Did the President ever tell you to turn over the gifts?
       A. Not that I remember.
       Q. Now, is that--does that bring us to the end of this 
     conversation with the President, or did other things occur?
       A. I think that the aspect of where this case is related, 
     yes.
       Q. Okay. And then you left, and where did you go when you 
     left the White House?
       A. I think I went home.
       Q. This is at--at your apartment?
       A. My mother's apartment.
       Q. Mother's apartment.
       Did you later that day receive a call from Betty Currie?
       A. Yes, I did.
       Q. Tell us about that.
       A. I received a call from--from Betty, and to the best of 
     my memory, she said something like I understand you have 
     something for me or I know--I know I've testified to saying 
     that--that I remember her saying either I know you have 
     something for me or the President said you have something for 
     me. And to me, it's a--she said--I mean, this is not a direct 
     quote, but the gist of the conversation was that she was 
     going to go visit her mom in the hospital and she'd stop by 
     and get whatever it was.
       Q. Did you question Ms. Currie or ask her, what are you 
     talking about or what do you mean?
       A. No.
       Q. Why didn't you?
       A. Because I assumed that it meant the gifts.
       Q. Did--did you have other telephone calls with her that 
     day?
       A. Yes.
       Q. Okay. What was the purpose of those conversations?
       A. I believe I spoke with her a little later to find out 
     when she was coming, and I think that I might have spoken 
     with her again when she was either leaving her house or 
     outside or right there, to let me know to come out.
       Q. Do--at that time, did you have the caller 
     identification--
       A. Yes, I did.
       Q. --on your telephone?
       A. Yes.
       Q. And did you at least on one occasion see her cell phone 
     number on your caller-ID that day?
       A. Yes, I did.
       Q. Now, Ms. Currie has given different versions of what 
     happened there, but I recall one that she mentioned about 
     Michael Isikoff, that you had called her and said Michael 
     Isikoff is calling around or called me--
       A. Mm-hmm.
       Q. --about some gifts.
       Did Mr. Isikoff ever call you about the gifts?
       A. No.
       Q. Okay. Would there have been--would there have been any 
     reason for you not to have carried the gifts to Ms. Currie 
     had you wanted her--had you called her, would you have had 
     her come over to get them from you, or does that--
       A. Probably not.
       Q. I mean, is there--is there any doubt in your mind that 
     she called you to come pick up the gifts?
       A. I don't think there is any doubt in my mind.
       Q. Okay. Let me ask was--I think you did something special 
     for her, as I recall, too, or her mother. Did you prepare a 
     plant or something for her to pick up?
       A. Um, no. I just--
       Q. To take to her mother?
       A. I bought a small plant and a balloon.
       Q. Okay. What was your understanding about her mother, and 
     was--
       A. Oh, I--I knew her mom was in--was in the hospital and 
     was sick, and I think this was her second trip to the 
     hospital in several months, and it had been a tough year.
       Q. And was she--was Mrs. Currie coming by your place on her 
     way to visit her mother in the hospital? Do you know that?
       A. That's what I remember her saying.
       Q. So you prepared--and you bought a gift for her mother?
       A. Correct.
       Q. Okay. Do you know what kind of time frame this covered? 
     First of all, it was the same day, December the 28th, 1997?
       A. Seven, yes.
       Q. Do you know what kind of time frame it covered?
       A. I think it was afternoon. I know I've testified to 
     around 2 o'clock.
       Q. Could it have been later?
       A. Sure.
       Q. So, when Betty Currie came, what--what did you have 
     prepared for her?
       A. I had a box from the Gap with some of the presents the 
     President had given me, taped up in it.
       Q. What happened when she arrived?
       A. Uh, I think I walked out to the car and asked her to 
     hold onto this, and I think we talked about her mom for a few 
     minutes. Um--
       Q. Did she call you right before she arrived, or did you 
     just go wait for her in the building?
       A. I think she called me right before she--at some point, I 
     think, before she--either when she was leaving or she was 
     outside.
       Q. Do you know--did you have any indication from Ms. Currie 
     what she was going to do with that box of gifts?
       A. Um, I know I've testified to this. I don't--I don't 
     remember. I think maybe she said something about putting it 
     in a closet, but whatever I--I stand by whatever I've said in 
     my testimony about it.
       Q. But she was supposed to keep these for you?
       A. Well, I had asked her to.
       Q. Okay. Did Ms. Currie ask you at any time about what was 
     in the box?
       A. No, or not that I recall, I guess I should say.
       Q. What was the--in your mind, what was the purpose of 
     having Ms. Currie retain these gifts as opposed to another 
     friend of yours?
       A. Hmm, I know I've testified to this, and I can't--can I 
     look at my grand jury--I mean, I don't really remember 
     sitting here right now, but if I could look at my grand jury 
     testimony, I--or I'd just stand by it.
       Q. We will pass that to you.
       A. Okay. Thank you.
       [Witness handed documents.]
       BY MR. BRYANT:
       Q. The answer I'm looking for is--if this refreshes your 
     recollection is that turning these over was a reassurance to 
     the President that everything was okay. Is that--
       A. Can I read it in context, please?
       Q. Sure, sure.
       A. Thank you.
       [Witness perusing document.]
       THE WITNESS: I--I--I stand by this testimony. I mean, I'd 
     just note that it--what I'm saying here about giving it to 
     the President or the assurance to the President is how I saw 
     it at that point, not necessarily how I felt then. So I think 
     you asked me what--why I didn't at that point, and I'm just--
     that's what's a little more clear there, just to be precise. 
     I'm sorry.
       BY MR. BRYANT:
       Q. Okay. Did you have any later conversations with either 
     Ms. Currie or the President about these gifts in the box?
       A. No.
       Q. Let me direct your attention to your meeting with Vernon 
     Jordan on December the 31st of 1997. Was that to go back and 
     talk about the job again?
       A. Little bit, but the--the--for me, the point of that 
     meeting was I had gotten to a point where Linda Tripp wasn't 
     returning my phone calls, and so I felt that I needed to 
     devise some way, that somehow--to kind of cushion the shock 
     of what would happen if Linda Tripp testified all the facts 
     about my relationship, since I had never disclosed that to 
     the President. So that was sort of my intention in meeting 
     with Mr. Jordan, was hoping that I could give a little 
     information and that would get passed on.
       Q. This was at a meeting for breakfast at the Park Hyatt 
     Hotel?
       A. Yes.
       Q. Were just the two of you present?
       A. Yes.
       Q. Did you discuss other things, other than Linda Tripp and 
     your job search?
       A. I think we talked about what each of us were doing New 
     Year's Eve.
       Q. Specifically about some notes that you had at your 
     apartment?
       A. Oh, yes. I'm sorry.
       Um, well, I mean, that really was in relation to discussing 
     Linda Tripp. So--
       Q. And the Jones lawyers, too. Was that right?
       A. Um, I--I don't know that I discussed the Jones lawyers. 
     If I've testified that I discussed the Jones lawyers, then I 
     did, but--
       Q. Okay. Well, tell us about the notes.
       A. Well, the--sort of the--I don't know what to call it, 
     but the story that I gave to Mr. Jordan was that I was trying 
     to sort of alert to him that, gee, maybe Linda Tripp might be 
     saying these things about me having a relationship with the 
     President, and right now, I'm explaining this to you. These 
     aren't the words that I used or how I said it to him, and 
     that, you know, maybe she had seen drafts of notes, trying to 
     obviously give an excuse as to how Linda Tripp could possibly 
     know about my relationship with the President without me 
     having been the one to have told her. So that's what I said 
     to him.

[[Page 1845]]

       Q. And what was his response?
       A. I think it was something like go home and make sure--oh, 
     something about a--I think he asked me if they were notes 
     from the President to me, and I said no. I know I've 
     testified to this. I stand by that testimony, and I'm just 
     recalling it, that I said no, they were draft notes or notes 
     that I sent to the President, and then I believe he said 
     something like, well, go home and make sure they're not 
     there.
       Q. And what did you do when you went home?
       A. I went home and I searched through some of my papers, 
     and--and the drafts of notes I found, I sort of--I got rid of 
     some of the notes that day.
       Q. So you threw them away?
       A. Mm-hmm.
       THE REPORTER: Is that a ``yes''?
       THE WITNESS: Yes. Sorry.
       BY MR. BRYANT:
       Q. On your way home, you were with Mr. Jordan? I mean, he 
     carried--did he carry you someplace or take you home, drop 
     you off?
       A. Yes, he dropped me off.
       Q. Okay. On the way home--
       A. It wasn't on the way to my home, but--
       Q. Okay. Did he--did you tell him that you had had an 
     affair with the President?
       A. Yes.
       Q. What was his response?
       A. No response.
       Q. When was the next time--well, let me direct your 
     attention to Monday, January the 5th, 1998. You had an 
     occasion to meet with your lawyer, Mr. Carter, about your 
     case, possible depositions, and so forth.
       Did you have some concern at that point about those 
     depositions and how you might answer questions in the Paula 
     Jones case?
       A. Yes.
       Q. Did you reach any sort of determination or resolution of 
     those concerns by talking to Mr. Carter?
       A. No.
       Q. What's the status of the affidavit at this point? Is 
     there one?
       A. No.
       Q. Do you recall any other concerns or questions that 
     either you or Mr. Carter may have presented to each other 
     during that meeting?
       A. I think I--I think it was in that meeting I brought up 
     the notion of having my family present, if I had to do a 
     deposition, and he went through what--I believe we 
     discussed--at this point, I think I probably knew at this 
     point I was going to sign an affidavit, but it wasn't created 
     yet, and I believe we discussed what--if the affidavit 
     wasn't, I guess, successful--I don't know how you'd say 
     legally--say that legally--but what a deposition would be 
     like, sitting at a table.
       Q. I'll bet he never told you it would be like this, did 
     he?
       A. No.
       Q. Did you try to contact the President after you left the 
     meeting with Mr. Carter?
       A. Yes.
       Q. And you reached Betty Currie?
       A. Yes.
       Q. And you told her to pass along to the President that you 
     wanted--it was important to talk with him?
       A. Yes.
       Q. You may have mentioned to her something about signing 
     something?
       A. Right; I might have.
       Q. What response did you get from that telephone call?
       A. Uh, Betty called me back, maybe an hour or two later, 
     and put the President through.
       Q. And what was that conversation?
       A. I know I've testified to this, and it was sort of two-
     fold. On the one hand, I was, uh, upset, so I was sort of in 
     a pissy mood and a little bit contentious. Uh, but more 
     related to the case, uh, I had concerns that from questions 
     Mr. Carter had asked me about how I got my job at the 
     Pentagon and transferred and, and, uh, I was concerned as to 
     how to answer those questions because those questions 
     involved naming other people who I thought didn't like me at 
     the White House, and I was worried that those people might 
     try and--just to get me in trouble because they didn't like 
     me--so that if they were then--I mean, I had no concept of 
     what exactly happens in these legal proceedings, and I 
     thought, well, maybe if I say Joe Schmo helped me get my job, 
     then they'd go interview Joe Schmo, and so, if Joe Schmo 
     said, ``No, that's not true,'' because he didn't like me, 
     then I didn't want to get in trouble. So--
       Q. Did there appear to be a question possibly about how 
     you--how you got the job at the Pentagon? Did you fear for 
     some questions there?
       A. Yes. I think I tend to be sort of a detail-oriented 
     person, and so I think it was, uh, my focusing on the details 
     and thinking everything had to be a very detailed answer and 
     not being able to kind of step back and look at how I could 
     say it more generally. So that's what concerned me.
       Q. Mm-hmm. This--
       A. Because clearly, I mean, I would have had to say, ``Gee, 
     I was transferred from the Pentagon because I had this 
     relationship that I'm not telling you about with the 
     President.'' So there was--there was that concern for me 
     there.
       Q. And what did the President tell you that you could say 
     instead of saying something like that?
       A. That the people in Legislative Affairs helped me get the 
     job--and that was true.
       Q. Okay, but it was also true, to be complete, that they 
     moved you out into the Pentagon because of the relationship 
     with the President?
       A. Right.
       Q. Did--did the subject of the affidavit come up with the 
     President?
       A. Yes, towards the end of the conversation.
       Q. And how did--tell us how that occurred.
       A. I believe I asked him if he wanted to see a copy of it, 
     and he said no.
       Q. Well, I mean, how did you introduce that into the 
     subject--into the conversation?
       A. I don't really remember.
       Q. Did he ask you, well, how's the affidavit coming or--
       A. No, I don't think so.
       Q. But you told him that you had one being prepared, or 
     something?
       A. I think I said--I think I said, you know, I'm going to 
     sign an affidavit, or something like that.
       Q. Did he ask you what are you going to say?
       A. No.
       Q. And this is the time when he said something about 15 
     other affidavits?
       A. Correct.
       Q. And tell us as best as you can recall what--how that--
     how that part of the conversation went.
       A. I think that was the--sort of the other half of his 
     sentence as, No, you know, I don't want to see it. I don't 
     need to--or, I've seen 15 others.
       It was a little flippant.
       Q. In his answer to this proceeding in the Senate, he has 
     indicated that he thought he had--might have had a way that 
     he could have you--get you to file a--basically a true 
     affidavit, but yet still skirt these issues enough that you 
     wouldn't be called as a witness.
       Did he offer you any of these suggestions at this time?
       A. He didn't discuss the content of my affidavit with me at 
     all, ever.
       Q. But, I mean, he didn't make an offer that, you know, 
     here's what you can do, or let me send you over something 
     that can maybe keep you from committing perjury?
       A. No. We never discussed perjury.
       Q. On--well, how did that conversation end? Did you talk 
     about anything else?
       A. I said goodbye very abruptly.
       Q. The next day--well, on January the 6th--I'm not sure 
     exactly what day we are--1998, did you pick up a draft of the 
     affidavit from Mr. Carter?
       A. Yes, I did.
       Q. What did you do with that draft?
       A. I read it and went through it.
       Q. How did it look?
       A. I don't really remember my reaction to it. I know I had 
     some changes. I know there's a copy of this draft affidavit 
     that's part of the record, but--
       Q. Were portions of it false?
       A. Incomplete and misleading.
       Q. Did you take that affidavit to Mr. Jordan?
       A. I dropped off a copy in his office.
       Q. Did you have any conversation with him at that point or 
     some later point about that affidavit?
       A. Yes, I did.
       Q. And tell us about that.
       A. I had gone through and had, I think, as it's marked--can 
     I maybe see? Isn't there a copy of the draft?
       [Witness handed document.]
       [Witness perusing document.]
       The WITNESS: Thank you.
       SENATOR DeWINE: Mr. Bryant, can you reference for the 
     record at this point?
       MR. BRYANT: Okay.
       SENATOR DeWINE: If you can.
       MR. BRYANT: It would be--
       MR. SCHIPPERS: 1229.
       SENATOR DeWINE: 1229?
       MR. SCHIPPERS: Yes.
       SENATOR DeWINE: All right. Thank you.
       BY MR. BRYANT:
       Q. Okay. Have you had an opportunity to review the draft of 
     your affidavit?
       A. I--yes.
       Q. Okay. What--do you have any comment or response?
       A. I received it. I made the suggested changes, and I 
     believe I spoke with Mr. Jordan about the changes I wanted to 
     make.
       Q. Did he have any comment on your proposed changes?
       A. I think he said the part about Lewis & Clark College was 
     irrelevant. I'd have to see the--I don't believe it's in the 
     final copy in the affidavit, so--but I could be mistaken.
       Q. At this point, of course, you had a lawyer, Mr. Carter, 
     who was representing your interest. Mr. Jordan was--I'm not 
     sure if he--how you would characterize him, but would it--
     would it be that you view Mr. Jordan as, in many ways, Mr.--
     the President--if Mr. Jordan knew it, the President knew it, 
     or something of that nature?
       A. I think I testified to something similar to that. I felt 
     that, I guess, that Mr. Jordan might have had the President's 
     best interest at heart and my best interest at heart, so that 
     that was sort of maybe a--some sort of a blessing.
       Q. I think, to some extent, what you--what you had said was 
     getting Mr. Jordan's approval was basically the same thing as 
     getting the President's approval. Would you agree with that?

[[Page 1846]]

       A. Yeah. I believe that--yes, I believe that's how I 
     testified to it.
       Q. The fact that you assume that Mr. Jordan was in contact 
     with the President--and I believe the evidence would support 
     that through his own testimony that he had talked to the 
     President about the signed affidavit and that he had kept the 
     President updated on the subpoena issue and the job search--
       A. Sir, I'm not sure that I knew he was having contact with 
     the President about this. I--I think what I said was that I 
     felt that it was getting his approval. It didn't necessarily 
     mean that I felt he was going to get a direct approval from 
     the President.
       I'm sorry to interrupt you.
       Q. Oh, that's fine. At any time you need to clarify a 
     point, please--please feel free to do so.
       Did--did--did you have any indication from Mr. Jordan that 
     he--when he discussed the signed affidavit with the 
     President, they were discussing some of the contents of the 
     affidavit? Did you have--
       A. Before I signed it or--
       Q. No; during the drafting stage.
       A. No, absolutely not--either/or. I didn't. No, I did not.
       Q. Now, the changes that you had proposed, did Mr. Jordan 
     agree to those changes?
       A. I believe so.
       Q. And then you somehow reported those changes back to Mr. 
     Carter or to someone else?
       A. No. I believe I spoke with Mr. Carter the next morning, 
     before I went in to see him, and that's when I--I believe 
     that's--I dictated the changes.
       Q. Okay. Mr. Jordan did not relay the changes to Mr. 
     Carter--you did?
       A. I know I relayed the changes, these changes to Mr. 
     Carter.
       Q. Specifically, the concerns that you had about--about the 
     draft, what did they include, the changes?
       A. I think one of the--I think what concerned me--and I 
     believe I've testified to this--was--was in Number 6. Even 
     just mentioning that I might have been alone with the 
     President, I was concerned that that would give the Jones 
     people enough ammunition to want to talk to me, to think, oh, 
     well, maybe if she was alone with him that--that he 
     propositioned me or something like that, because I hadn't--of 
     course, I mean, you remember that at this point, I had no 
     idea the amount of knowledge they had about the relationship. 
     So--
       Q. Did--Mr. Carter, I assume, made those changes, and then 
     you subsequently signed the affidavit?
       A. We worked on it in his office, and then, yes, I signed 
     the affidavit.
       Q. Is this the same day--
       A. Yes.
       Q. --at this point?
       A. This was the 7th?
       Q. Yes.
       A. Correct.
       Q. Did--did you take the signed--or a copy of the signed 
     affidavit, I should say--did you take a copy--did you keep a 
     copy?
       A. Yes, I did.
       Q. Did you give it to anyone or give anyone else a copy?
       A. No.
       Q. Now, did you, the next day on the 8th, go to New York 
     for some interviews for jobs?
       A. It was--it--I either went later on the 7th or on the 
     8th, but around that time, yes.
       Q. Was this a place that you had already interviewed?
       A. Yes.
       Q. And I assume this was at McAndrews and Forbes?
       A. Yes.
       Q. How did you feel that the interview went?
       A. I--I know I characterized it in my grand jury testimony 
     as having not gone very well.
       Q. Okay. I think you also mentioned it went very poorly, 
     too. Does that sound--does that ring a bell?
       A. Sure.
       Q. Why? Why would you so characterize it?
       A. Well, as I've had a lot of people tell me, I'm a 
     pessimist, but also I--I wasn't prepared. I was in a waiting 
     room downstairs at McAndrews and Forbes, and--or at least, I 
     thought it was a waiting room--and Mr. Durnan walked into the 
     room unannounced, and the interview began. So I felt that I 
     started on the wrong foot, and I just didn't feel that I was 
     as articulate as I could have been.
       Q. Did you call Mr. Jordan after that?
       A. Yes, I did.
       Q. Did you express those same concerns?
       A. Yes, I did.
       Q. What did he say?
       A. And this is a little fuzzy for me. I know that I had a 
     few phone calls with him in that day. I think in this call, 
     he said, you know, ``Don't worry about it.'' I--my testimony 
     is probably more complete on this. I'm sorry.
       Q. What--what other phone calls did you have with him that 
     day?
       A. I remember talking to--I know that at some point, he 
     said something about that he'd call the chairman, and then I 
     think he said just at some point not to worry. He was always 
     telling me not to worry because I always--I overreact a 
     little bit.
       Q. All total, how many calls did you have with him that 
     day--your best guess?
       A. I have no idea.
       Q. More than two?
       A. I--I don't know.
       Q. Can you think of any other subjects the two of you would 
     have talked about?
       A. I don't think so.
       Q. Did he, Mr. Jordan, tell you that he had talked to the 
     chairman, or Mr. Perelman, whatever his title is?
       A. I'm sorry. I know I've testified to this. I don't--I 
     think so.
       Q. And you had--did you have additional interviews at this 
     company or a subsidiary?
       A. Yes, I--well, I had with the sort of, I guess, 
     daughter--daughter company, Revlon. I had an interview with 
     Revlon the next day.
       Q. And you were offered a job?
       A. Yes, I was.
       Q. About the 9th or so? That would have been 2 days after 
     the affidavit?
       A. Oh. Actually, no. I think I was offered a position, 
     whatever that Friday was. Oh, yes, the 9th. I'm sorry. You're 
     right.
       Oh, wait. It was either the 9th or the 13th--or the 12th--
     the 9th or the 12th.
       Q. Okay. Now, I'm--I was looking away. I'm confused.
       A. That's okay. I--my interview was on the 9th, and I don't 
     remember right now--I know I've testified to this--whether I 
     found out that afternoon or it was on Monday that I got the 
     informal offer.
       Q. Mm-hmm.
       A. So, if you want to tell me what I said in my grand jury 
     testimony, I'll be happy to affirm that.
       Q. I think we may be talking about perhaps an informal 
     offer. Does that--on the 9th?
       A. Yes. I know it was--okay. Was it on the--I don't--
       Q. Yes.
       A. --remember if it was the 9th or the 13th--
       A. Okay.
       Q. --but I know Ms. Sideman called me to extend an informal 
     offer, and I accepted.
       Q. Okay. Now, in regard to the affidavit--do you still have 
     your draft in front of you?
       A. Yes, sir.
       Q. In paragraph number 3, you say: ``I can not fathom any 
     reason--fathom any reason why--that the plaintiff would seek 
     information from me for her case.''
       A. Yes, sir.
       Q. Did Mr. Carter at all go into the gist of the Paula 
     Jones lawsuit, the sexual harassment part of it, and tell you 
     what it was about?
       A. I think I knew what it was about.
       Q. All right. And then you indicated that you didn't like 
     the part about the doors, being behind closed doors, but on 
     the sexual relationship, paragraph 8, the first sentence, 
     ``I've never had a sexual relationship with the President''--
       A. Mm-hmm.
       Q. --that's not true, is it?
       A. No. I haven't had intercourse with the President, but--
       Q. Was that the distinction you made when you signed that 
     affidavit, in your own mind?
       A. That was the justification I made to myself, yes.
       Q. Let me send you the final affidavit. It might be a 
     little easier to work from--
       A. Okay.
       Q. --than the--than the original.
       MR. BRYANT: Do we have all the--1235.
       [Witness handed document.]
       SENATOR DeWINE: Congressman?
       MR. BRYANT: Yes.
       SENATOR DeWINE: We're down to 3 minutes on the tape. Would 
     now be a good time to have him switch tapes and then we'll go 
     right back in?
       MR. BRYANT: Okay, that would be fine.
       SENATOR DeWINE: I think we'll hold right at the table, and 
     we'll get the tapes switched.
       THE VIDEOGRAPHER: Okay, we will do that now.
       This marks the end of Videotape Number 2 in the deposition 
     of Monica S. Lewinsky.
       We are going off the record at 14:31 hours.
       [Recess.]
       THE VIDEOGRAPHER: This marks the beginning of Videotape 
     Number 3 in the deposition of Monica S. Lewinsky. The time is 
     14:44 hours.
       SENATOR DeWINE: We are back on the record.
       Let me advise counsel that you have used 3 hours and 2 
     minutes.
       Congressman Bryant, you may continue.
       MR. BRYANT: Thank you, sir.
       BY MR. BRYANT:
       Q. Ms. Lewinsky, let me just follow up on some points here, 
     and then I'll move toward the conclusion of my direct 
     examination very, very quickly, I hope.
       In regard to the affidavit--I think you still have it in 
     front of you--the final copy of the affidavit--I wanted to 
     revisit your answer about paragraph 8--
       A. Yes, sir.
       Q. --and also refer you to your grand jury testimony of 
     August the 6th. This begins on--actually, it is on page 1013 
     of the--it should be the Senate record, in the appendices, 
     but it's your August 6th, 1998, grand jury testimony.
       And it's similar to the--my question about paragraph 8 
     about the sexual relationship-- and I notice you--you now 
     carve out an exception to that by saying you didn't have

[[Page 1847]]

     intercourse, but I would direct your attention to a previous 
     answer and ask if you can recall being asked this question in 
     your grand jury testimony and ask--giving the answer--the 
     question is: ``All right. Let me ask you a straightforward 
     question. Paragraph 8, at the start, says, quote, 'I have 
     never had a sexual relationship with the President,' unquote. 
     Is that true?,'' and your answer is, ``No.''
       Now, do you have any comment about why your answer still 
     would not be no, that that is not a true statement in 
     paragraph 8?
       A. I think I was asked a different question.
       Q. Okay.
       A. My recollection, sir, was that you asked me if that was 
     a lie, if paragraph 8 was--I--I'm not trying to--
       Q. Okay. Well, if--if I ask you today the same question 
     that was asked in your grand jury, is your statement, quote, 
     ``I have never had a sexual relationship with the 
     President,'' unquote, is that a true statement?
       A. No.
       Q. Okay, that's good.
       Now, also in paragraph 8, you mention that there were 
     occasions after you left--I think it looks like the--the last 
     sentence in paragraph 8, ``The occasions that I saw the 
     President after I left my employment at the White House in 
     April 1996 were official receptions, formal functions, or 
     events related to the United States Department of Defense, 
     where I was working at the time,'' period-- actually the last 
     sentence, ``There were other people present on those 
     occasions.'' Now, that also is not a truthful statement; is 
     that correct?
       A. It--I think I testified that this was misleading. It's 
     incomplete--
       Q. Okay. It's not a truthful statement?
       A. --and therefore, misleading.
       Well, it--it is true; it's not complete.
       Q. Okay. All right. Now, I will accept that.
       A. Okay. Thank you.
       Q. Thank you.
       Going back to the gift retrieval of December the 28th, I 
     want to be clear that we're on the same sheet of music on 
     this one. As I understand, there's no doubt in your mind that 
     Betty Currie called you, initiated the call to you to pick up 
     the gifts? She--
       A. That's how I remember this event.
       Q. And you went through that process, and at the very end, 
     you were sitting out in the car with her, with a box of 
     gifts, and it was only at that time that you asked her to 
     keep these gifts for you?
       A. I don't think I said ``gifts.'' I don't--
       Q. Or keep this package?
       A. I think I said--gosh, was it in the car that I said that 
     or on the phone? I think it was in the car. I--I'm--I don't 
     know if that makes a difference.
       Q. But this was at the end of a process that Betty Currie 
     had initiated by telephone earlier that day to come pick up 
     something that you have for her?
       A. Yes.
       Q. Okay. Now, were you ever under the impression from 
     anything that the President said that you should turn over 
     all the gifts to the Jones lawyers?
       A. No, but where this is a little tricky--and I think I 
     might have even mentioned this last weekend--was that I had 
     an occasion in an interview with one of the--with the OIC--
     where I was asked a series of statements, if the President 
     had made those, and there was one statement that Agent Phalen 
     said to me--I--there were--other people, they asked me these 
     statements--this is after the President testified and they 
     asked me some statements, did you say this, did you say this, 
     and I said, no, no, no. And Agent Phalen said something, and 
     I think it was, ``Well, you have to turn over whatever you 
     have.'' And I said to you, ``You know, that sounds a little 
     bit familiar to me.''
       So that's what I can tell you on that.
       Q. That's in the 302 exam?
       A. I don't know if it's in the 302 or not, but that's what 
     happened.
       Q. Uh-huh.
       A. Or, that's how I remember what happened.
       Q. Okay. And your response to the question in the 
     deposition that I just asked you--were you ever under the 
     impression from anything the President said that you should 
     have--that you should turn over all the gifts to the Jones 
     lawyers--your answer in that deposition was no.
       A. And which date was that, please?
       Q. The deposition was August the 26th.
       A. Oh, the 26th.
       Q. Yes.
       A. It might have been after that, or maybe it was--I 
     don't--
       Q. Okay. I wanted to ask you, too, about a couple of other 
     things in terms of your testimony. Regarding the affidavit--
     and this appears to be, again, grand jury testimony--
       A. Sir, do you have a copy that I could look at if you're 
     going to--
       Q. Sure. August, the August 6th--233--it's the--it's this 
     page here.
       While we're looking at that, let me ask you a couple other 
     things here. I wanted to ask you--I talked to you a little 
     bit about the President today and your feelings today that 
     persist that you think he's a good President, and I assume 
     you think he's a very intelligent man?
       A. I think he's an intelligent President.
       [Laughter.]
       MR. BRYANT: Okay. Thank goodness, this is confidential; 
     otherwise, that might be the quote of the day. I know we 
     won't see that in the paper, will we?
       BY MR. BRYANT:
       Q. Referring to January the 18th, 1998, the President had a 
     conversation with Betty Currie, and he made five statements 
     to her. One was that ``I was never really alone with Monica; 
     right?'' That's one. That's not true, is it, that ``I was 
     never alone with''--
       A. Sir, I was not present for that conversation. I don't 
     feel comfortable--
       Q. Let me ask you, though--I realize none of us were 
     there--but that statement, ``I was never really alone with 
     Monica; right?''--that was not--he was alone with you on many 
     occasions, was he not?
       A. I--I'm not trying to be difficult, but I feel very 
     uncomfortable making judgments on what someone else's 
     statement when they're defining things however they want to 
     define it. So if you--if you ask me, Monica, were you alone 
     with the President, I will say yes, but I'm not comfortable 
     characterizing what someone else says--
       Q. Okay.
       A. --passing judgment on it. I'm sorry.
       Q. Were you--was Betty Currie always with you when the 
     President was with you?
       A. Betty Currie was always at the White House when I went 
     to see the President at the White House after I left working 
     at the White House.
       Q. But was--at all times when you were alone with the 
     President, was Betty Currie always there with you?
       A. Not there in the room.
       Q. Okay. Did--did--did you come on to the President, and 
     did he never touch you physically?
       A. I guess those are two separate questions, right?
       Q. Yes, they are.
       A. Did I come on to him? Maybe on some occasions.
       Q. Okay.
       A. Not initially.
       Q. Okay. Not initially.
       A. I--
       Q. Did he ever--did he ever touch you?
       A. Yes.
       Q. Okay. Could Betty Currie see and hear everything that 
     went on between the two of you all the time?
       A. I can't answer that. I'm sorry.
       Q. As far as you know, could she see and hear everything 
     that went on between the two of you?
       A. Well, if I was in the room, I couldn't--I--I couldn't be 
     in the room and being able to see if Betty Currie could see 
     and hear what was--
       Q. I think I--
       MR. STEIN: Wouldn't it be a little speedier--if I may make 
     this observation, you have her testimony; you have the 
     evidence of--
       SENATOR DeWINE: Counsel, is this an objection?
       MR. STEIN: I just would ask him to draw whatever inferences 
     there were to speed this up.
       SENATOR DeWINE: I'll ask him to rephrase the question.
       MR. BRYANT: I would just stop at that point. I think, uh, 
     that's enough of that.
       BY MR. BRYANT:
       Q. The President also had conversations with Mr. Blumenthal 
     on January the 21st, 1998, and indicated that you came on to 
     the President and made a sexual demand. At the initial part 
     of this, did you come on to the President and make a sexual 
     demand on the President?
       A. No.
       Q. At the initial meeting on November the 15th, 1995, did 
     he ever rebuff you from these advances, or from any kind of--
       A. On November 15th?
       Q. November 15th. Did he rebuff you?
       A. No.
       Q. Did you threaten him on November 15th, 1995?
       A. No.
       Q. On January 23rd, 1998, the President told John Podesta 
     that--many things. I'll--I'll withdraw that. Let me go--kind 
     of wind this down. I'd like to save some time for redirect.
       You've indicated that with regard to the affidavit and 
     telling the truth, there is some testimony I'd like to read 
     you from your deposition that we started out--August the 
     6th--I'm sorry--the grand jury, August 6th, 1998--
       MS. MILLS: What internal page number?
       MR. SCHIPPERS: 1021 internal, 233.
       MR. BRYANT: Okay, we need to get her a copy.
       MR. SCHIPPERS: Do you have the August 6th still over there?
       THE WITNESS: I can share with Sydney--if you don't mind.
       [Witness perusing document.]
       BY MR. BRYANT:
       Q. Beginning--do you have page 233--
       A. Uh-huh.
       Q. --okay--beginning at line 6--
       A. Okay.
       Q. --it reads--would you prefer to read that? Why don't you 
     read--
       A. Out loud?
       Q. Would you read it out loud?
       A. Okay.
       Q. Through line 16--6 through 16. This is your answer.
       A. ``Sure. Gosh. I think to me that if--if the President 
     had not said the Betty and letters cover, let's just say, if 
     we refer to that,

[[Page 1848]]

     which I'm talking about in paragraph 4, page 4, I would have 
     known to use that. So to me, encouraging or asking me to lie 
     would have--you know, if the President had said, Now, listen, 
     you'd better not say anything about this relationship, you'd 
     better not tell them the truth, you'd better not--for me, the 
     best way to explain how I feel what happened was, you know, 
     no one asked or encouraged me to lie, but no one discouraged 
     me, either.''
       Q. Okay. That--that statement, is that consistent in your 
     view with what you've testified to today?
       A. Yes.
       Q. Okay. Look at page 234, which is right below there.
       A. Okay. [Perusing document.]
       Q. Beginning with the--your answer on line 4, and read 
     down, if you could, to line 14--4 through 14.
       A. ``Yes and no. I mean, I think I also said that Monday 
     that it wasn't as if the President called me and said, You 
     know, Monica, you're on the witness list. This is going to be 
     really hard for us. We're going to have to tell the truth and 
     be humiliated in front of the entire world about what we've 
     done, which I would have fought him on, probably. That was 
     different. And by him not calling me and saying that, you 
     know, I knew what that meant. So I, I don't see any 
     disconnect between paragraph 10 and paragraph 4 on the page. 
     Does that answer your question?''
       Q. Okay. Now, has that--has your testimony today been 
     consistent with that provision?
       A. I--I think so.
       Q. Okay.
       A. I've intended for my testimony to be consistent with my 
     grand jury testimony.
       Q. Okay. And one final read just below that, line 16 
     through 24.
       A. ``Did you understand all along that he would deny the 
     relationship also?''
       ``Mm-hmm, yes.''
       Q. And 19 through 24--the rest of that.
       A. Oh, sorry.
       ``And when you say you understood what it meant when he 
     didn't say, Oh, you know you must tell the truth, what did 
     you understand that to mean?''
       ``That, that, as we had on every other occasion and in 
     every other instance of this relationship, we would deny 
     it.''
       MR. BRYANT: Okay.
       Could we have just--go off the record here a minute?
       SENATOR DeWINE: Sure. Let's go off the record at this 
     point.
       THE VIDEOGRAPHER: We're going off the record at 1459 hours.
       [Recess.]
       THE VIDEOGRAPHER: We're going back on the record at 1504 
     hours.
       SENATOR DeWINE: Manager Bryant, you may proceed.
       MR. BRYANT: Thank you, Senator.
       BY MR. BRYANT:
       Q. Ms. Lewinsky, I have just a few more questions here.
       With regard to the false affidavit, you do admit that you 
     filed an untruthful affidavit with the court in the Jones 
     case; is that correct?
       A. I think I--I--yes--I mean, it was incomplete and 
     misleading, and--
       Q. Okay. With regard to the cover stories, on December the 
     6th, you and the President went over cover stories, and in 
     the same conversation he encouraged you to file an affidavit 
     in the Jones case; is that correct?
       A. No.
       MS. SELIGMAN: I think that misstates the record.
       BY MR. BRYANT:
       Q. All right. On December the 17th. Let's try December 17; 
     all right?
       A. Okay.
       Q. You and the President went over cover stories--that's 
     the telephone conversation--
       A. Okay--I'm sorry--can you repeat the question?
       Q. Okay. On December 17th, you and the President went over 
     cover stories in a telephone conversation.
       A. Correct.
       Q. And in that same telephone conversation, he encouraged 
     you to file an affidavit in the Jones case?
       A. He suggested I could file an affidavit.
       Q. Okay. With regard to the job, between your meeting with 
     Mr. Jordan in early November and December the 5th when you 
     met with Mr. Jordan again, you did not feel that Mr. Jordan 
     was doing much to help you get a job; is that correct?
       MS. SELIGMAN: Objection. Misstates the record.
       BY MR. BRYANT:
       Q. Okay. You can answer that.
       A. It--
       Q. Let me repeat it. Between your meeting with Mr. Jordan 
     in early November and December the 5th when you met with Mr. 
     Jordan again, you did not feel that Mr. Jordan was doing much 
     to help you get a job; is that correct?
       MS. SELIGMAN: Same objection.
       THE WITNESS: Do you mean when I met with him again on 
     December 11th? I don't--
       MR. BRYANT: The--
       THE WITNESS: --I didn't meet with Mr. Jordan on December 
     5th. I'm sorry--
       MR. BRYANT: Okay.
       THE WITNESS: --am I misunderstanding something?
       MR. BRYANT: We're getting our numbers wrong here.
       THE WITNESS: Okay.
       BY MR. BRYANT:
       Q. Between your meeting with Mr. Jordan in early November 
     and December the 11th when you met with Mr. Jordan again, you 
     did not feel that Mr. Jordan was doing much to help you get a 
     job; is that correct?
       A. I hadn't seen any progress.
       Q. Okay. After you met with Mr. Jordan in early December, 
     you began to interview in New York and were much more active 
     in your job search; correct?
       A. Yes.
       Q. In early January, you received a job offer from Revlon 
     with the help of Vernon Jordan; is that correct?
       A. Yes.
       Q. Okay. With regard to gifts, regarding the gifts that 
     were subpoenaed in the Jones case, you are certain that Ms. 
     Currie called you and that she understood you had something 
     to give her; is that correct?
       A. That's my recollection.
       Q. You never told Ms. Currie to come pick up the gifts or 
     that Michael Isikoff had called about them; is that correct?
       A. I don't recall that.
       Q. Regarding stalking, you never stalked the President; is 
     that correct?
       A. I--I don't believe so.
       Q. Okay. You and the President had an emotional 
     relationship as well as a physical one; is that right?
       A. That's how I'd characterize it.
       Q. Okay. He never rebuffed you?
       A. I--I think that gets into some of the intimate details 
     of--no, then, that's not true. There were occasions when he 
     did.
       Q. Uh-huh. Okay. But he never rebuffed you initially on 
     that first day, November the 15th, 1995?
       A. No, sir.

                           *   *   *   *   *

                                                    Law Offices of


                                               Plato Cacheris,

                                 Washington, DC, February 2, 1999.
     Re February 1, 1999, Monica S. Lewinsky deposition 
         transcript.

       Dear Ms. Jardim and Mr. Bitsko: Upon our review of the 
     videotape and transcript of Monica S. Lewinsky's deposition 
     transcript, we have noted the following errors or omissions:

------------------------------------------------------------------------
  Page     Line                         Corrections
------------------------------------------------------------------------
     19    14      The oath and affirmation are not transcribed.
     24     9      ``second . . .'' should replace ``2d''
     44     6      Comments by counsel are not transcribed.
     61  11-13     Delete quotation marks. These are not direct quotes
                    in this instance.
     62    23      ``town'' should replace ``down''
     63    17      ``called'' should replace ``found''
     63    23      ``after Thanksgiving'' should follow ``back.''
     63    24      Insert following line 23:
                     A: Yes I did.
                     Q: What did he tell you then?
     65    21      ``tchotchke'' should replace ``chochki''
     65    24      ``on'' should replace ``home''
     66    20      The line should read:
                     ``see if I could see the President. I apologize,''
                    not
                     ``see if I could see the President and apologize.''
     75     1      ``needed'' should replace ``need''
     90     5      ``the'' should replace ``some''
    116    16      ``said'' should precede ``list''
    128     9      ``that's'' should replace ``of''
    154     5      Delete quotation marks.
    156     6      ``Seidman'' should replace ``Sideman''
    161    15      ``Fallon'' should replace ``Phalen''
------------------------------------------------------------------------

       Provided these changes are made, we will waive signature on 
     behalf of Ms. Lewinsky.
       We understand from Senate Legal Counsel that copies of this 
     letter will be made available to the parties and Senate.
       Thank you for your assistance.
           Sincerely,
     Plato Cacheris.
     Preston Burton.
     Sydney Hoffmann.

    In the Senate of the United States Sitting for the Trial of the 
   Impeachment of William Jefferson Clinton, President of the United 
                                 States


         excerpts of video deposition of vernon e. jordan, jr.

             (Tuesday, February 2, 1999, Washington, D.C.)

       SENATOR THOMPSON: All right. If there are no further 
     questions from the parties or counsel for the witness, I'll 
     now swear in the witness. Mr. Jordan, will you please raise 
     your right hand?
       Do you, Vernon E. Jordan, Jr., swear that the evidence you 
     shall give in this case now pending between the United States 
     and William Jefferson Clinton, President of the United 
     States, shall be the truth, the whole truth, and nothing but 
     the truth, so help you, God?
       THE WITNESS: I do.
       Whereupon, VERNON E. JORDAN, JR., was called as a witness 
     and, after having been first duly sworn by Senator Fred 
     Thompson, was examined and testified as follows:
       SENATOR THOMPSON: All right. The House Managers may begin 
     their questioning of the witness.
       MR. HUTCHINSON: Thank you, Senator Thompson and Senator 
     Dodd.


                     examination by house managers

       BY MR. HUTCHINSON:
       Q. Good morning, Mr. Jordan. For the record, would you 
     state your name, please?
       A. Good morning, Congressman. My name is Vernon E. Jordan, 
     Jr.
       Q. And, Mr. Jordan, we have not had the opportunity to meet 
     previously, is that correct?
       A. That is correct.
       Q. And I do appreciate--I have met your counsel, Mr. 
     Hundley, in his office, and so

[[Page 1849]]

     I've looked forward to this opportunity to meet you. Now, you 
     have--
       A. I can't say that the feeling is mutual.
       [Laughter.]
       BY MR. HUTCHINSON:
       Q. I certainly understand.
       You have testified, I believe, five times previously before 
     the Federal grand jury?
       A. That is correct.
       Q. And so I know that probably about every question that 
     could be asked has been asked, but there are a number of 
     reasons I want to go over additional questions with you, and 
     some of them will be repetitious of what's been asked before.
       Prior to coming in today, though, have you had the 
     opportunity to review your prior testimony in those five 
     appearances before the grand jury?
       A. I have done some preparation, Congressman.
       Q. And let me start with the fact that the oath that you 
     took today is the same as the oath that you took before the 
     Federal grand jury?
       A. I believe that's correct.
       Q. And, Mr. Jordan, what is your profession?
       A. I am a lawyer.
       Q. And where do you practice your profession?
       A. I am a senior partner at the law firm of Akin, Gump, 
     Strauss, Hauer & Feld, here in Washington, D.C., with offices 
     in Texas, California, Pennsylvania and New York, three 
     offices in Europe, London, Brussels and Moscow.
       Q. And how long have you been a senior partner?
       A. I have been a senior partner--well, I didn't start out 
     as a senior partner. I started out as a partner, and at some 
     point--I don't know when, but not long thereafter I was 
     elevated to this position of senior partner.
       Q. And what type of law do you practice?
       A. I am a corporate international generalist at Akin, Gump.
       Q. And does Akin, Gump have about 800 lawyers?
       A. We have about 800 lawyers, yes.
       Q. Which is an incredible number for lawyers from someone 
     who practiced law in Arkansas.
       How do all of those lawyers--
       A. We have some members of our law firm who are from 
     Arkansas, so it's not unusual for them.
       Q. And how is it that you are able to obtain enough 
     business for 800 lawyers?
       A. I don't think that's my entire responsibility. I'm just 
     one of 800 lawyers, and that is what I do in part, but I'm 
     not alone in that process of making rain.
       Q. When you say ``making rain,'' that's the terminology of 
     being a rainmaker?
       A. I think even in Arkansas, you understand what rainmaking 
     is.
       Q. We've read Grisham books.
       And so, when you say making rain or being a rainmaker, that 
     is to bring in business so that you can keep the lawyers busy 
     practicing law?
       A. Well, that is--that is part and parcel of the practice 
     of law.
       Q. And do you bill by the hour?
       A. I do not.
       Q. And I understand you used to, but you do not anymore?
       A. I graduated.
       Q. A fortunate graduation.
       And when the--when you did bill by the hour, what was your 
     billable rate the last time you had to do that?
       A. I believe my billable rate at the last time was 
     somewhere between 450 and 500 an hour.
       Q. Now, would you describe--
       A. Not bad for a Georgia boy. I'm from Georgia. You've 
     heard of that State, I'm sure.
       Q. It's probably not bad from Washington standards.
       Would you describe the nature of your relationship with 
     President Clinton?
       A. President Clinton has been a friend of mine since 
     approximately 1973, when I came to your State, Arkansas, to 
     make a speech as president of the National Urban League about 
     race and equal opportunity in our Nation, and we met then and 
     there, and our friendship has grown and developed and matured 
     and he is my friend and will continue to be my friend.
       Q. And just to further elaborate on that friendship, it's 
     my understanding that he and his--and the First Lady has had 
     Christmas Eve dinner with you and your family for a number of 
     years?
       A. Every year since his Presidency, the Jordan family has 
     been privileged to entertain the Clinton family on Christmas 
     Eve.
       Q. And has there been any exceptions in recent years to 
     that?
       A. Every year that he has been President, he has had, he 
     and his family, Christmas Eve with my family.
       Q. And have you vacationed together with the Clinton 
     family?
       A. Yes. I think you have seen reels of us playing golf and 
     having fun at Martha's Vineyard.
       Q. And so you vacation together, you play golf together on 
     a semi-regular basis?
       A. Whenever we can. We've not been doing it recently, for 
     reasons that I think are probably very obvious to you, 
     Counsel.
       Q. Well, explain that to me.
       A. Just what I said, for a time, I was going before the 
     grand jury, and under the advice of counsel and I'm sure 
     under advice of the President's counsel, it was thought best 
     that we not play golf together.
       So, from the time that I first went to the grand jury, I 
     don't think--we have not played golf this year, 
     unfortunately, together.
       Q. Since you--I think your first appearance at the grand 
     jury was March 3 of '98. Then you went March 5, and then in 
     May, I believe you were two times before the grand jury and 
     then one in June of '98.
       Since your last testimony before the grand jury in June of 
     '98, have you been in contact with the President of the 
     United States?
       A. Yes, I have.
       Q. And are these social occasions or for business purposes?
       A. Social occasions. I was invited to the Korean State 
     Dinner. I forget when that was. I think that was the first 
     time I was in the White House since Martin Luther King Day of 
     last year.
       I saw the President at Martha's Vineyard. I was there when 
     he got off Air Force One to greet him and welcome him to--to 
     the Vineyard, and I was at the White House for one of the 
     performances about music. The Morgan State Choir sang, and so 
     I've been to the White House only for social occasions in the 
     last year since Martin Luther King's birthday, I believe.
       Q. Have you had any private conversations with the 
     President?
       A. Yes, I have, as a matter of fact.
       Q. And has this been on the telephone or in person?
       A. I've talked to him on the telephone, and I talked to him 
     at the Vineyard. He was at my house on Christmas Eve. There 
     were a lot of people around, but, yes, I've talked to the 
     President.
       Q. And did you discuss your testimony before the grand jury 
     or his testimony before the grand jury?
       A. I did not.
       Q. There was one reference that he made in his Federal 
     grand jury testimony, and I'll refer counsel, if they would 
     like. It was on page 77 of the President's testimony in his 
     appearance before the grand jury on August 17th.
       And he referenced discussions with you, and he said, ``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 had talked to her or met with her. That's all I can tell 
     you,'' and I believe the ``her'' is a reference to Ms. 
     Lewinsky.
       And it appeared to me from reading that, that there might 
     have been some conversations with you by the President, 
     perhaps in reference to your grand jury testimony or your 
     knowledge of when and how you talked to Ms. Lewinsky.
       A. If I understand your question about whether or not the 
     President of the United States and I talked about my 
     testimony before the grand jury or his testimony before the 
     grand jury, I can say to you unequivocally that the President 
     of the United States and I have not discussed our testimony. 
     I was advised by my counsel, Mr. Hundley, not to discuss that 
     testimony, and I have learned in this process, Mr. 
     Hutchinson, to--to take the advice of counsel.
       Q. I would certainly agree that that is good counsel to 
     take, but going back to the question--and I will try to 
     rephrase it because it was a very wordy question that I asked 
     you--and it's clear from your testimony that you have not 
     discussed your grand jury testimony--
       A. That is correct.
       Q. --but did you, subsequent to your last testimony before 
     the grand jury, talk to the President in which you discussed 
     conversation that you have had with Monica Lewinsky?
       A. I have not discussed a conversation that I have had with 
     Monica Lewinsky with the President of the United States.
       Q. And have you had any discussions about Monica Lewinsky 
     with the President of the United States since your last 
     testimony before the grand jury?
       A. I have not.
       Q. Now, going back to your relationship with the President, 
     you have been described as a friend and advisor to the 
     President. Is that a fair terminology?
       A. I think that's fair.
       Q. And in the advisor capacity, had you served as co-
     chairman of the Clinton-Gore transition team in 1992?
       A. I believe I was chairman.
       Q. That is an important distinction.
       And have you served in any other official or semi-official 
     capacities for this administration?
       A. I have not, except that I was asked by the President to 
     lead the American delegation to the inauguration of President 
     Li in Taiwan, and that was about as official as you can get, 
     but beyond that, I have not--not had any official capacity.
       For a very brief moment, very early in the administration, 
     I was appointed to the Foreign Intelligence Advisory 
     Committee, and I went to one meeting and stayed half that 
     meeting, went across the street and told Bruce Lindsey that 
     that was not for me.
       Q. Now, let's move on. After we've established to a certain 
     degree your relationship with the President, let's move on to 
     January

[[Page 1850]]

     20th of 1998, and just to put that in clearer terms, this is 
     a Tuesday after the January 17 deposition of President 
     Clinton in the Paula Jones civil rights case. Do you recall 
     that time frame?
       A. [Nodding head up and down.]
       Q. This is in the afternoon of January 20th, again, after 
     the President's deposition. You contacted Mr. Howard Gittis, 
     who I believe is General Counsel of McAndrews & Forbes 
     Holdings?
       A. Howard Gittis is Vice Chairman of McAndrews, Forbes, and 
     he is not the General Counsel. He is a lawyer, but he is not 
     the General Counsel.
       Q. And what was the purpose of you contacting Mr. Howard 
     Gittis on January 20th?
       A. If I talked to Howard Gittis on the 20th, I don't recall 
     exactly what my conversation with Howard Gittis was about. I 
     think it was a telephone call, maybe.
       Q. And that's difficult. Let me see if I can't help you in 
     that regard.
       A. Right.
       Q. Was the purpose of that call with Mr. Gittis to arrange 
     breakfast the next morning on January 21st?
       A. Yeah. I was in New York, and I did call Mr. Gittis and 
     say--and as I remember, I had breakfast with him on the 21st, 
     I believe. Yes, I did.
       Q. And this is a breakfast that you had set up?
       A. Yes.
       Q. And what was the reason you made the decision to request 
     a breakfast meeting with Mr. Gittis?
       A. Yes. As I remember, I had gotten a telephone call from 
     David Bloom at 1 o'clock in the morning at the St. Regis 
     Hotel about the matter that was about to break having to do 
     with the entire Lewinsky matter, and I had not at any time 
     discussed the Lewinsky matter with--with Howard Gittis. And 
     so I had breakfast with him to tell him that reporters were 
     calling, that this would obviously involve Revlon, which had 
     responded to my--my efforts to find Ms. Lewinsky employment, 
     and so Howard Gittis is a friend of mine. Howard Gittis is a 
     fellow board member with me at Revlon. He is the Vice 
     Chairman of McAndrews & Forbes, and I thought it--I thought I 
     had--it was incumbent upon me to stop and say, ``Listen, 
     there's trouble a-brewing.''
       Q. And just--you've mentioned McAndrews & Forbes and 
     Revlon. McAndrews & Forbes, am I correct, is the parent 
     company of--
       A. It's the holding company.
       Q. The holding company of Revlon and presumably other 
     companies.
       And you sit on the board of McAndrews & Forbes?
       A. I do not. I sit on the board of Revlon.
       Q. All right. And that is a position that brings you an 
     annual salary--
       A. There is a director's fee.
       Q. You receive a director's fee, and in addition, your law 
     firm receives--from business from--
       A. We do--
       Q. --Revlon?
       A. We do. We do business. We've represented Revlon, and we 
     represented Revlon before I was elected a director.
       Q. And you mention that things were breaking that you felt 
     like you needed to advise Mr. Gittis concerning. At the time 
     that you made the arrangements for the breakfast on January 
     21st, had you become aware of the Drudge Report?
       A. Yes, I had.
       Q. And you had had lunch with Bruce Lindsey on January 
     20th?
       A. No. I don't think it was on January--it was on Sunday. 
     No, that was not the 20th.
       Q. And during that luncheon, did you become aware of the 
     Drudge Report--
       A. That is correct.
       Q. --and receive a copy of it?
       A. That is correct.
       Q. And that was from Bruce Lindsey?
       A. That is correct.
       Q. And that Drudge Report, did it mention your name?
       A. I don't think so, but I don't remember.
       Q. Was there some news stories that had mentioned your name 
     in reference to Ms. Lewinsky and the President?
       A. I believe that my name has been an integral part of this 
     process from the beginning.
       Q. And did you in fact have the breakfast meeting with Mr. 
     Gittis?
       A. Yes, I did.
       Q. And what information did you convey to Mr. Gittis 
     concerning Ms. Lewinsky at that breakfast meeting?
       A. I just simply said that the press was calling about Ms. 
     Lewinsky; that while I had not dealt with him, I had dealt 
     with Richard Halperin, I had dealt with Ronald Perelman. I 
     had not dealt with him, but that he ought to know and that I 
     was sorry about this.
       And I also said that it would probably be even more 
     complicated because early on I had referred Webb Hubbell to 
     them to be hired as counsel.
       Q. And I want to get to that in just a moment, but you 
     indicated that you said you were sorry. Were you referring to 
     the problems that this might create for the company?
       A. Well, I was obviously concerned. I am a director. I am 
     their counsel. They're my friends. And publicity was 
     breaking. I thought I had some responsibility to them to give 
     them a heads-up as to what was going on.
       Q. Now, is it true that your efforts to find a job for Ms. 
     Lewinsky that you referenced in that meeting with Mr. 
     Gittis--were your efforts carried out at the request of the 
     President of the United States?
       A. There is no question but that through Betty Currie, I 
     was acting on behalf of the President to get Ms. Lewinsky a 
     job. I think that's clear from my grand jury testimony.
       Q. Okay. And I just want to make sure that that's firmly 
     established. And in reference to your previous grand jury 
     testimony, you indicated, I believe, on May 28th, 1998, at 
     page 61, that ``She''--referring to Betty Currie--''was the 
     one that called me at the behest of the President.''
       A. That is correct, and I think, Congressman, if in fact 
     the President of the United States' secretary calls and asks 
     for a request that you try to do the best you can to make it 
     happen.
       Q. And you received that request as a request coming from 
     the President?
       A. I--I interpreted it as a request from the President.
       Q. And then, later on in June of '98 in the grand jury 
     testimony at page 45, did you not reference or testify that 
     ``The President asked me to get Monica Lewinsky a job''?
       A. There was no--there was no question but that he asked me 
     to help and that he asked others to help. I think that is 
     clear from everybody's grand jury testimony.
       Q. And just one more point in that regard. In the same 
     grand jury testimony, is it correct that you testified that 
     ``He''--referring to the President--''was the source of it 
     coming to my attention in the first place''?
       A. I may--if that is--if you--if it's in the--
       Q. It's at page 58 of the grand jury--
       A. I stand on my grand jury testimony.
       Q. All right. Now, during your efforts to secure a job for 
     Ms. Lewinsky, I think you mentioned that you talked to Mr. 
     Richard Halperin.
       A. Yes.
       Q. And he is with McAndrews & Forbes?
       A. Yes.
       Q. And you also at one point talked to Mr. Ron Perelman; is 
     that correct?
       A. I made a call to Mr. Perelman, I believe, on the 8th of 
     January.
       Q. And he is the--
       A. He is the chairman/CEO of McAndrews Forbes. He is a 
     majority shareholder in McAndrews Forbes. This is his 
     business.
       Q. Now, at the time that you requested assistance in 
     obtaining Ms. Lewinsky a job, did you advise Mr. Perelman or 
     Mr. Halperin of the fact that the request was being carried 
     out at the request of the President of the United States?
       A. I don't think so. I may have.
       Q. Well, the first answer you gave was ``I don't think 
     so.'' Now, in fact, you did not advise either Mr. Perelman or 
     Mr. Halperin of that fact because am I correct that Mr. 
     Perelman--or, excuse me, Mr. Gittis--expressed some concern 
     that Revlon was never advised of that fact?
       A. Then, uh, I cannot say, I guess, precisely that I told 
     that ``I am doing this for the President of the United 
     States.''
       I do believe, on the other hand, that given the fact that 
     she was in the White House, given the fact that she had been 
     a White House intern, I would not be surprised if that was 
     their understanding.
       Q. Well, in your conversation with Mr. Halperin.
       A. Yes--I'm certain I did not say that to Richard Halperin.
       Q. Okay. So there's no question that you did not tell Mr. 
     Halperin that you were acting at the request of the 
     President?
       A. I'm fairly certain I did not.
       Q. And in your conversation with Mr. Perelman, did you 
     indicate to him that you were calling--or you were seeking--
     employment for Ms. Lewinsky at the request of the President?
       A. Yes--I don't think that I, that I made that explicit in 
     my conversation with Mr. Perelman, and I'm not sure I thought 
     it necessary to say ``This is for the President of the United 
     States.''
       By the same token, I would have had no hesitance in doing 
     that.
       Q. Now, at the time that you had called Mr. Perelman, which 
     I believe you testified was in January of '98--
       A. That's right.
       Q. --I think you said January 8th--
       A. Right.
       Q. --you were aware at that time, were you not, that Ms. 
     Lewinsky had received a subpoena to give a deposition in the 
     Jones versus Clinton case?
       A. That is correct.
       Q. At the time that you talked to Mr. Perelman requesting 
     his assistance for Monica Lewinsky, did you advise Mr. 
     Perelman of the fact that Ms. Lewinsky was under subpoena in 
     the Jones case?
       A. I did not.
       Q. And when you--did Mr. Perelman, Mr. Gittis or Mr. 
     Halperin ever express to you disappointment that they were 
     not told of two facts--either of these two facts--one, that 
     Ms. Lewinsky was being helped at the request of the 
     President; and secondly, that she was known by you and the 
     President to be under subpoena in that case?

[[Page 1851]]

       A. No.
       Q. Now, you are on the board of directors of Revlon.
       A. I am.
       Q. And how long have you been on the board of Revlon?
       A. I forget. Ten years, maybe.
       Q. And as a member of the board of directors, do you not 
     have a fiduciary responsibility to the company?
       A. I do.
       Q. And how would you define a fiduciary responsibility?
       A. I define my fiduciary responsibility to the company 
     about company matters.
       Q. And how would you define fiduciary responsibility in 
     reference to company matters?
       A. Anything that has to do with the company, that I believe 
     in the interest of the company, I have some fiduciary 
     responsibility to protect the company, to help the company in 
     any way that I--that is possible.
       Q. And is fiduciary responsibility sometimes considered a 
     trust relationship in which you owe a degree of trust and 
     responsibility to someone else?
       A. I think--I think that ``trust'' and ``fiduciary'' are 
     probably synonymous.
       Q. Okay. Do you believe that you were acting in the 
     company's interest or the President's interest when you were 
     trying to secure a job for Ms. Lewinsky?
       A. Well, what I knew was that the company would take care 
     of its own interest. This is not the first time that I 
     referred somebody, and what I know is, is that if a person 
     being referred does not meet the standards required for that 
     company, I have no question but that that person will not be 
     hired. And so the referral is an easy thing to do; the 
     judgment about employment is not a judgment as a person 
     referring that I make. But I do have confidence in all of the 
     companies on whose boards that I sit that, regardless of my 
     reference, that as to their needs and as to their 
     expectations for their employees that they will make the 
     right decisions, as happened in the American Express 
     situation.
       American Express called and said: We will not hire Ms. 
     Lewinsky. I did not question it, I did not challenge it, 
     because they understood their needs and their needs in 
     comparison to her qualifications. They made a judgment. 
     Revlon, on the other hand, made another judgment.
       I am not the employer, I am the referrer, and there is a 
     major difference.
       Q. Now, going back to what you knew as far as information 
     and what you conveyed to Revlon, you indicated that you did 
     not tell Mr. Halperin that you were making this request or 
     referral at the request of the President of the United 
     States.
       A. Yes, and I didn't see any need to do that.
       Q. And then, when you talked to Mr.--
       A. Nor do I believe not saying that, Counselor, was a 
     breach of some fiduciary relationship.
       Q. And when you had your conversation with Mr. Perelman--
       A. Right.
       Q. --at a later time--
       A. Right.
       Q. --you do not remember whether you told him--you do not 
     believe you told him you were calling for the President--
       A. I believe that I did not tell him.
       Q. --but you assumed that he knew?
       A. No. I did not make any assumptions, let me say. I said: 
     Ronald, here is a young lady who has been interviewed. She 
     thinks the interview has not gone well. See what you can do 
     to make sure that she is properly interviewed and evaluated--
     in essence.
       Q. And did you reference her as a former White House 
     intern?
       A. Probably. I do not have a recollection of whether I 
     described her as a White House intern, whether I described 
     her as a person who had worked for the Pentagon. I said this 
     is a person that I have referred.
       I think, Mr. Hutchinson, that I have sufficient, uh, 
     influence, shall we say, sufficient character, shall we say, 
     that people have been throughout my career able to take my 
     word at face value.
       Q. And so you didn't need to reference the President. The 
     fact that you were calling Mr. Perelman--
       A. That was sufficient.
       Q. --and asking for a second interview for Ms. Lewinsky, 
     that that should be sufficient?
       A. I thought it was sufficient, and obviously, Mr. Perelman 
     thought it was sufficient.
       Q. And so there is no reason, based on what you told him, 
     for him to think that you were calling at the request of the 
     President of the United States?
       A. I think that's about right.
       Q. And so, at least with the conversation with Mr. Halperin 
     and Mr. Perelman, you did not reference that you were acting 
     in behalf of the President of the United States. Was there 
     anyone else that you talked to at Revlon in which they might 
     have acquired that information?
       A. The only persons that I talked to in this process, as I 
     explained to you, was Mr. Halperin and Mr. Perelman about 
     this process. And it was Mr. Halperin who put the--who got 
     the process started.
       Q. So those are the only two you talked about, and you made 
     no reference that you were acting in behalf of the President?
       A. Right.
       Q. Now, the second piece of information was the fact that 
     you knew and the President knew that Ms. Lewinsky was under 
     subpoena in the Jones case, and that information was not 
     provided to either Mr. Halperin or to Mr. Perelman; is that 
     correct?
       A. That's correct.
       Q. Now, I wanted to read you a question and answer of Mr. 
     Howard Gittis in his grand jury testimony of April 23, 1998.
       The question was: ``Now, you had mentioned before that one 
     of the responsibilities of director is to have a fiduciary 
     duty to the company. If it was the case that Ms. Lewinsky had 
     been noticed as a witness in the Paula Jones case, and Vernon 
     Jordan had known that, is that something that you believe as 
     a person who works for McAndrews & Forbes, is that something 
     that you believe that Mr. Jordan should have told you, or 
     someone in the company, not necessarily you, but someone in 
     the company, when you referred her for employment?''
       His answer was ``Yes.''
       Do you disagree with Mr. Gittis'' conclusion that that was 
     important information for McAndrews & Forbes?
       A. I obviously didn't think it was important at the time, 
     and I didn't do it.
       Q. Now, in your previous answers, you reference the fact 
     that you----
       A. I think, on the other hand, that had she been a 
     defendant in a murder case and I knew that, then I probably 
     wouldn't have referenced her. But her being a witness in a 
     civil case I did not think important.
       Q. Despite the fact that you were acting at the request of 
     the President, and this witness was potentially adverse to 
     the President's interest in that case?
       A. I didn't know that. I mean, I don't--I don't know what 
     her position was or whether it was adverse or not.
       Q. All right. Mr. Jordan, prior to you answering that, did 
     you get an answer from your attorney?
       A. My attorney mumbled something in my ear, but I didn't 
     hear him.
       MR. HUNDLEY: It was a spontaneous remark. I'll try to 
     refrain.
       MR. HUTCHINSON: I know that--
       THE WITNESS: He does have a right to mumble in my ear, I 
     think.
       MR. HUNDLEY: I mumble too loud because I don't hear too 
     well myself.
       BY MR. HUTCHINSON:
       Q. Now, going back to a complicating factor in your 
     conversation with Mr. Gittis and this embarrassing situation 
     of the Lewinsky job, the complicating fact was that you had 
     also helped Webb Hubbell get a job or consulting contracts 
     with the same company; is that--
       A. Yes. You use the word ``complicated.'' I did not view it 
     as a complication. I viewed it as a, as another something 
     that happened, and that that caused some embarrassment to the 
     company, and here again, we were back for another 
     embarrassment for the company, and I thought I had a 
     responsibility to say that.
       Q. Would you explain how you helped Webb Hubbell secure a 
     job or a contract with Revlon?
       A. Yes. Webb Hubbell came to me after his resignation from 
     the Justice Department. Webb and I got to be friends during 
     the transition, and Webb came to me and he said, ``I'm 
     leaving the Justice Department,'' or ``I've left the Justice 
     Department''--I'm not sure which--and he said, ``I really 
     need work.''
       And I said, ``Webb, I will do what I can to help you.''
       I called New York, made arrangements. I took Webb Hubbell 
     to New York. We had lunch. I took him the headquarters of 
     McAndrews & Forbes at 62nd Street. I introduced him to Howard 
     Gittis, Ronald Perelman, and I left.
       Q. And did, subsequently, Mr. Hubbell obtain consulting 
     contracts with Revlon?
       A. Subsequently, Mr. Hubbell was hired, as I understand it, 
     as outside counsel to McAndrews & Forbes, or Revlon, or some 
     entity within the Perelman empire.
       Q. And was that consulting contracts of about $100,000 a 
     year?
       A. I--I think so, I think so.
       Q. And did you make other contacts with other companies in 
     which you had friends for assistance for Webb Hubbell?
       A. I did not.
       Q. And was the effort to assist Mr. Webb Hubbell during 
     this time--was it after he left the Department of Justice and 
     prior to the time that he pled guilty to criminal charges?
       A. That is correct.
       Q. And at the time you assisted Webb Hubbell by securing a 
     job with Revlon for him, was he a potential adverse witness 
     to the President in the ongoing investigation by the 
     Independent Counsel?
       A. I don't know whether he was an adverse witness or not. 
     What he was was my friend who had just resigned from the 
     Justice Department, and he was out of work, and he asked for 
     help, and I happily helped him.
       Q. And did you know at the time that he was a potential 
     witness in the investigation by the OIC?
       A. I don't know whether I knew whether he was a potential 
     witness or not. I simply responded to Webb Hubbell who was a 
     friend in trouble and needing work.

[[Page 1852]]

       Q. Now, let's backtrack to the time when you first had any 
     contact with Ms. Lewinsky. We've talked about this January 
     20-21st meeting with Mr. Gittis and covered a little bit of 
     the tail end of this entire episode. Now I would like to go 
     back in time to your first meetings with Ms. Lewinsky.
       Now, when was the first time that you recall that you met 
     with Monica Lewinsky?
       A. If you've read my grand jury testimony--
       Q. I have.
       A. --and I'm sure that you have--there is testimony in the 
     grant jury that she came to see me on or about the 5th of 
     November. I have no recollection of that. It was not on my 
     calendar, and I just have no recollection of her visit. There 
     is a letter here that you have in evidence, and I have to 
     assume that in fact that happened. But as I said in my grand 
     jury testimony, I'm not aware of it, I don't remember it--but 
     I do not deny that it happened.
       Q. And Ms. Lewinsky has made reference to a meeting that 
     occurred in your office on November 5, and that's the meeting 
     that you have no recollection of?
       A. That is correct. We have no record of it in my office, 
     and I just have no recollection of it.
       Q. And in your first grand jury appearance, you were firm, 
     shall I say, that the first time you met with Ms. Lewinsky, 
     that it was on December 11th?
       A. Yes. It was firm based on what my calendar told me, and 
     subsequently to that, there has been a refreshing of my 
     recollection, and I do not deny that it happened. By the same 
     token, I will tell you, as I said in my grand jury testimony, 
     that I did not remember that I had met with her.
       Q. And in fact today, the fact that you do not dispute that 
     that meeting occurred is not based upon your recollection but 
     is simply based upon you've seen the records, and it appears 
     that that meeting occurred?
       A. That is correct.
       Q. Okay. And you've made reference to my first exhibit 
     there, which is front of you, and I would refer you to this 
     at this time, which is Exhibit 86.
       Now, this is captioned as a ``Letter from Ms. Lewinsky to 
     Mr. Vernon Jordan dated November 6, 1997,'' and it appears 
     that this letter thanks you for meeting with her in reference 
     to her job search. And do you recall this--
       MR. KENDALL: Mr. Hutchinson, excuse me. May I ask--this is 
     an unsigned copy. Do you have a signed copy of this letter?
       MR. HUTCHINSON: Let me go through my questions if I might.
       BY MR. HUTCHINSON:
       Q. Do you recall receiving this letter?
       A. I do not.
       Q. Do you ever recall seeing this letter before?
       A. The first time I saw this letter was when I was before 
     the grand jury.
       Q. And am I correct that it's your testimony that the first 
     time you ever recall hearing the name ``Monica Lewinsky'' was 
     in early December of '97?
       A. That's correct. I--I may have heard the name before, but 
     the first time I remember seeing her and having her in my 
     presence was then.
       Q. Well, regardless of whether you met with her in November 
     or not, the fact is you did not do anything in November to 
     secure a job for Ms. Lewinsky until your activities on 
     December 11 of '97?
       A. I think that's correct.
       Q. And on December 11, I think you made some calls for Ms. 
     Lewinsky on that particular day?
       A. I believe I did. I have some--it's all right for me to 
     refresh my recollection?
       Q. Certainly.
       A. Thank you. [Perusing documents.] I did make calls for 
     her on the 11th, yes.
       Q. And may I just ask what you're referring to?
       A. I'm referring here to telephone logs prepared by counsel 
     here for me to refresh my recollection about calls.
       MR. HUNDLEY: You are welcome to have a copy of that.
       THE WITNESS: You are welcome to see it.
       MR. HUTCHINSON: Do you have an extra copy?
       THE WITNESS: Yes--in anticipation.
       MR. HUNDLEY: There are a few calls.
       SENATOR THOMPSON: Might this be a good time to take a 5-
     minute break?
       MR. HUTCHINSON: Certainly.
       SENATOR THOMPSON: All right. Let's adjourn for 5 minutes.
       THE VIDEOGRAPHER: We are going off the record at 10:03 a.m.
       [Recess.]
       THE VIDEOGRAPHER: We're going back on the record at 10:16 
     a.m.
       SENATOR THOMPSON: All right. Counsel has consumed 38 
     minutes.
       Counsel, would you proceed?
       MR. HUTCHINSON: Thank you, Senator Thompson.
       At this time, I would offer as Jordan Deposition Exhibit 
     86, if you don't mind me going by that numerology--
       SENATOR THOMPSON: Would it be better to do that or make it 
     Jordan Exhibit Number 1? Does counsel have any preference on 
     that--is that--
       MR. HUTCHINSON: One is fine.
       SENATOR THOMPSON: Let's do it that way. It will be made a 
     part of the record, Jordan Deposition Number 1.
       [Jordan Deposition Exhibit No. 1 marked for 
     identification.]
       BY MR. HUTCHINSON:
       Q. Mr. Jordan, let me go back to that meeting on December 
     11th. I believe we were discussing that. My question would 
     be: How did the meeting on December 11 of 1997 with Ms. 
     Lewinsky come about?
       A. Ms. Lewinsky called my office and asked if she could 
     come to see me.
       Q. And was that preceded by a call from Betty Currie?
       A. At some point in time, Betty Currie had called me, and 
     Ms. Lewinsky followed up on that call, and she came to my 
     office, and we had a visit.
       Q. Ms. Lewinsky called, set up a meeting, and at some point 
     sent you a resume, I believe.
       A. I believe so.
       Q. And did you receive that prior to the meeting on 
     December 11th?
       A. I--I have to assume that I did, but I--I do not know 
     whether she brought it with her or whether--it was at some 
     point that she brought with her or sent to me--somehow it 
     came into my possession--a list of various companies in New 
     York with which she had--which were here preferences, by the 
     way--most of which I did not know well enough to make any 
     calls for.
       Q. All right. And I want to come back to that, but I 
     believe--would you dispute if the record shows that you 
     received the resume of Ms. Lewinsky on December 8th?
       A. I would not.
       Q. And presumably, the meeting on December 11th was set up 
     somewhere around December 8th by the call from Ms. Lewinsky?
       A. I--I would not dispute that, sir.
       Q. All right. Now, you mentioned that she had sent you a--I 
     guess some people refer to it--a wish list, or a list of jobs 
     that she--
       A. Not jobs--companies.
       Q. --companies that she would be interested in seeking 
     employment with.
       A. That's correct.
       Q. And you looked at that, and you determined that you 
     wanted to go with your own list of friends and companies that 
     you had better contacts with.
       A. I'm sure, Congressman, that you too have been in this 
     business, and you do know that you can only call people that 
     you know or feel comfortable in calling.
       Q. Absolutely. No question about it. And let me just 
     comment and ask you response to this, but many times I will 
     be listed as a reference, and they can take that to any 
     company. You might be listed as a reference and the name 
     ``Vernon Jordan'' would be a good reference anywhere, would 
     it not?
       A. I would hope so.
       Q. And so, even though it was a company that you might not 
     have the best contact with, you could have been helpful in 
     that regard?
       A. Well, the fact is I was running the job search, not Ms. 
     Lewinsky, and therefore, the companies that she brought or 
     listed were not of interest to me. I knew where I would need 
     to call.
       Q. And that is exactly the point, that you looked at 
     getting Ms. Lewinsky a job as an assignment rather than just 
     something that you were going to be a reference for.
       A. I don't know whether I looked upon it as an assignment. 
     Getting jobs for people is not unusual for me, so I don't 
     view it as an assignment. I just view it as something that is 
     part of what I do.
       Q. You're acting in behalf of the President when you are 
     trying to get Ms. Lewinsky a job, and you were in control of 
     the job search?
       A. Yes.
       Q. Now, going back--going to your meeting that we're 
     talking about on December 11th, prior to the meeting did you 
     make any calls to prospective employers in behalf of Ms. 
     Lewinsky?
       A. I don't think so. I think not. I think I wanted to see 
     her before I made any calls.
       Q. And so if they were not before, after you met with her, 
     you made some calls on December 11th?
       A. I--I believe that's correct.
       Q. And you called Mr. Richard Halperin of McAndrews & 
     Forbes?
       A. That's right.
       Q. You called Mr. Peter--
       A. Georgescu.
       Q. --Georgescu. And he is with what company?
       A. He is chairman and chief executive officer of Young & 
     Rubicam, a leading advertising agency on Madison Avenue.
       Q. And did you make one other call?
       A. Yes. I called Ursie Fairbairn, who runs Human Resources 
     at American Express, at the American Express Company, where I 
     am the senior director.
       Q. All right. And so you made three calls on December 11th. 
     You believe that they were after you met with Ms. Lewinsky--
       A. I doubt very seriously if I would have made the calls in 
     advance of meeting her.
       Q. And why is that?
       A. You sort of have to know what you're talking about, who 
     you're talking about.
       Q. And what did you basically communicate to each of these 
     officials in behalf of Ms. Lewinsky?
       A. I essentially said that you're going to hear from Ms. 
     Lewinsky, and I hope that you will afford her an opportunity 
     to come in and be interviewed and look favorably upon her

[[Page 1853]]

     if she meets your qualifications and your needs for work.
       Q. Okay. And at what level did you try to communicate this 
     information?
       A. By--what do you mean by ``what level''?
       Q. In the company that you were calling, did you call the 
     chairman of human resources, did you call the CEO--who did 
     you call, or what level were you seeking to talk to?
       A. Richard Halperin is sort of the utility man; he does 
     everything at McAndrews & Forbes. He is very close to the 
     chairman, he is very close to Mr. Gittis. And so at McAndrews 
     & Forbes, I called Halperin.
       As I said to you, and as my grand jury testimony shows, I 
     called Young & Rubicam, Peter Georgescu as its chairman and 
     CEO. I have had a long-term relationship with Young & Rubicam 
     going back to three of its CEOs, the first being Edward Ney, 
     who was chairman of Young & Rubicam when I was head of the 
     United Negro College Fund, and it was during that time that 
     we developed the great theme, ``A mind is a terrible thing to 
     waste.'' So I have had a long-term relationship with Young & 
     Rubicam and with Peter Georgescu, so I called the chairman in 
     that instance.
       At American Express, I called Ms. Ursie Fairbairn who is, 
     as I said before, in charge of Human Resources.
       So that is the level--in one instance, the chairman; in one 
     instance a utilitarian person; and in another instance, the 
     head of the Human Resources Department.
       Q. And the utilitarian connection, Mr. Richard Halperin, 
     was sort of an assistant to Mr. Ron Perelman?
       A. That's correct. He's a lawyer.
       Q. Now, going to your meeting on December 11th with Ms. 
     Lewinsky, about how long of a meeting was that?
       A. I don't--I don't remember. You have a record of it, 
     Congressman.
       Q. And actually, I think you've testified it was about 15 
     to 20 minutes, but don't hold me to that, either.
       During the course of the meeting with Ms. Lewinsky, what 
     did you learn about her?
       A. Uh, enthusiastic, quite taken with herself and her 
     experience, uh, bubbly, effervescent, bouncy, confident, uh--
     actually, I sort of had the same impression that you House 
     Managers had of her when you met with her. You came out and 
     said she was impressive, and so we come out about the same 
     place.
       Q. And did she relate to you the fact that she liked being 
     an intern because it put her close to the President?
       A. I have never seen a White House intern who did not like 
     being a White House intern, and so her enthusiasm for being a 
     White House intern was about like the enthusiasm of White 
     House interns--they liked it.
       She was not happy about not being there anymore--she did 
     not like being at the Defense Department--and I think she 
     actually had some desire to go back. But when she actually 
     talked to me, she wanted to go to New York for a job in the 
     private sector, and she thought that I could be helpful in 
     that process.
       Q. Did she make reference to someone in the White House 
     being uncomfortable when she was an intern, and she thought 
     that people did not want her there?
       A. She felt unwanted--there is no question about that. As 
     to who did not want her there and why they did not want her 
     there, that was not my business.
       Q. And she related that--
       A. She talked about it.
       Q. --experience or feeling to you?
       A. Yes.
       Q. Now, your meeting with Ms. Lewinsky was on December 
     11th, and I believe that Ms. Lewinsky has testified that she 
     met with the President on December 5--excuse me, on December 
     6--at the White House and complained that her job search was 
     not going anywhere, and the President then talked to Mr. 
     Jordan.
       Do you recall the President talking to you about that after 
     that meeting?
       A. I do not have a specific recollection of the President 
     saying to me anything about having met with Ms. Lewinsky. The 
     President has never told me that he met with Ms. Lewinsky, as 
     best as I can recollect. I--I am aware that she was in a 
     state of anxiety about going to work. She was in a state of 
     anxiety in addition because her lease at Watergate, at the 
     Watergate, was to expire December 31st. And there was a part 
     of Ms. Lewinsky, I think, that thought that because she was 
     coming to me, that she could come today and that she would 
     have a job tomorrow. That is not an unusual misapprehension, 
     and it's not limited to White House interns.
       Q. I mentioned her meeting with the President on the same 
     day, December 6th. I believe the record shows the President 
     met with his lawyers and learned that Ms. Lewinsky was on the 
     Jones witness list. Now, did you subsequently meet with the 
     President on the next day, December 7th?
       A. I may have met with the President. I'd have to--I mean, 
     I'd have to look. I'd have to look. I don't know whether I 
     did or not.
       Q. If you would like to confer--I believe the record shows 
     that, but I'd like to establish that through your testimony.
       MS. WALDEN: Yes.
       THE WITNESS: Yes.
       BY MR. HUTCHINSON:
       Q. All right. So you met with the President on December 
     7th. And was it the next day after that, December 8th, that 
     Ms. Lewinsky called to set up the job meeting with you on 
     December 11th?
       A. I believe that is correct.
       Q. And sometime after your meeting on December 11th with 
     Ms. Lewinsky, did you have another conversation with the 
     President?
       A. Uh, you do understand that conversations between me and 
     the President, uh, was not an unusual circumstance.
       Q. And I understand that--
       A. All right.
       Q. --and so let me be more specific. I believe your 
     previous testimony has been that sometime after the 11th, you 
     spoke with the President about Ms. Lewinsky.
       A. I stand on that testimony.
       Q. All right. And so there's two conversations after the 
     witness list came out--one that you had with the President on 
     December 7th, and then a subsequent conversation with him 
     after you met with Ms. Lewinsky on the 11th.
       Now, in your subsequent conversation after the 11th, did 
     you discuss with the President of the United States Monica 
     Lewinsky, and if so, can you tell us what that discussion 
     was?
       A. If there was a discussion subsequent to Monica 
     Lewinsky's visit to me on December the 11th with the 
     President of the United States, it was about the job search.
       Q. All right. And during that, did he indicate that he knew 
     about the fact that she had lost her job in the White House, 
     and she wanted to get a job in New York?
       A. He was aware that--he was obviously aware that she had 
     lost her job in the White House, because she was working at 
     the Pentagon. He was also aware that she wanted to work in 
     New York, in the private sector, and understood that that is 
     why she was having conversations with me. There is no doubt 
     about that.
       Q. And he thanked you for helping her?
       A. There's no question about that, either.
       Q. And on either of these conversations that I've 
     referenced that you had with the President after the witness 
     list came out, your conversation on December 7th, and your 
     conversation sometime after the 11th, did the President tell 
     you that Ms. Monica Lewinsky was on the witness list in the 
     Jones case?
       A. He did not.
       Q. And did you consider this information to be important in 
     your efforts to be helpful to Ms. Lewinsky?
       A. I never thought about it.
       Q. Was there a time that you became aware that Ms. Lewinsky 
     had been subpoenaed to give a deposition in the Jones versus 
     Clinton case?
       A. On December 19th when she came to my office with the 
     subpoena--I think it's the 19th.
       Q. That's right. Now, you indicated you never thought about 
     it, because of course, at that point, you didn't know that 
     she was on the witness list, according to your testimony.
       A. [Nodding head up and down.]
       Q. Now, you said that she came to see you on December 
     19th--I'm sorry. I've been informed you didn't respond out 
     loud, so--
       A. Well, if you'd ask the question, I'd be happy to 
     respond.
       Q. I was afraid you would ask me to ask the question again.
       Well, let's go to the December 19th meeting.
       A. Fine.
       Q. How did it come about that you met with Ms. Lewinsky on 
     December 19th?
       A. Ms. Lewinsky called me in a rather high emotional state 
     and said that she needed to see me, and she came to see me.
       Q. And she called you on the telephone on December 19th, in 
     which she indicated she had received a subpoena?
       A. That's right, and was emotional about it and asked, and 
     so I said come over.
       Q. And what was your reaction to her having received a 
     subpoena in the Jones case?
       A. Surprise, number one; number two, quite taken with her 
     emotional state.
       Q. And did you see that she had a problem?
       A. She obviously had a problem--she thought--
       THE VIDEOGRAPHER: We have to go off the record.
       SENATOR THOMPSON: Off the record.
       [Recess due to power failure.]
       THE VIDEOGRAPHER: We're going back on the record at 10:49 
     a.m.
       SENATOR THOMPSON: All right, let the record reflect that 
     we've been down for 20 to 25 minutes due to a power failure, 
     but we are ready to proceed now, counsel.
       MR. HUTCHINSON: Thank you, Senator Thompson.
       And Mr. Jordan, before we go back to my line of 
     questioning, I have been informed that we have that question 
     in which we did not get an audible response, and so I'm going 
     to ask the court reporter to read that question back.
       [The court reporter read back the requested portion of the 
     record.]
       THE WITNESS: I did not know that she was on the witness 
     list, Congressman. And let me say parenthetically here that 
     our side had nothing to do with the power outage.

[[Page 1854]]

       [Laughter.]
       THE WITNESS: As desirable as that may have been.
       [Laughter.]
       BY MR. HUTCHINSON:
       Q. Thank you, Mr. Jordan. And again, we're talking about 
     the fact you never thought about the President not telling 
     you that Ms. Lewinsky was on the witness list because you 
     didn't know it at the time.
       A. I--I did not know it.
       Q. All right. Now, before we go back to December 19th, I've 
     also been informed that I've been neglectful, and sometimes 
     you will give a nod of the head, and I've not asked you to 
     give an audible response. So I'm going to try to be mindful 
     of that, but at the same time, Mr. Jordan, if you can try to 
     give an audible response to a question rather than what we 
     sometimes do in private conversation, which is a nod of the 
     head. Fair enough?
       A. I'm happy to comply.
       Q. Now, we're talking about December 19th, that you had 
     received a call from Monica Lewinsky; she had been subpoenaed 
     in the Jones case. She was upset. You said, Come to my 
     office.
       Now, when she got to the office, I asked you, actually, 
     before that, what was your reaction to her having this 
     subpoena, and she had a problem because of the subpoena.
       A. Yes.
       Q. And I believe you previously indicated that any time a 
     witness gets a subpoena, they've got a problem that they 
     would likely need legal assistance.
       A. That's been my experience.
       Q. And in fact she did subsequently come to see you at the 
     office on that December 19th, is that correct?
       A. That's correct.
       Q. And what happened at that meeting in your office with 
     Ms. Lewinsky on the 19th?
       A. She, uh, as I said, was quite emotional. She was--she 
     was disturbed about the subpoena. She was disturbed about not 
     having, in her words, heard from the President or talked to 
     the President.
       It was also in that meeting that it became clear to me that 
     the--that her eyes were wide and that she, uh, that--let me--
     for lack of a better way to put it, that she had a ``thing'' 
     for the President.
       Q. And how long was that meeting?
       A. I don't know, uh, but it's in the record.
       MR. HUNDLEY: You testified 45 minutes.
       THE WITNESS: Forty-five minutes. Thank you.
       MR. HUTCHINSON: Thank you.
       MR. HUNDLEY: Is that okay if I--
       MR. HUTCHINSON: That's all right, and that's helpful, Mr. 
     Hundley.
       MR. HUNDLEY: Thank you. I'm trying to be helpful.
       BY MR. HUTCHINSON:
       Q. And during this meeting, did she in fact show you the 
     subpoena that she had received in the Jones litigation?
       A. I'm sure she showed me the subpoena.
       Q. And the subpoena that was presented to you asked her to 
     give a deposition, is that correct?
       A. As I recollect.
       Q. But did it also ask Ms. Lewinsky or direct her to 
     produce certain documents and tangible objects?
       A. I think, if I'm correct in my recollection, it asked 
     that she produce gifts.
       Q. Gifts, and some of those gifts were specifically 
     enumerated.
       A. I don't remember that. I do remember gifts.
       Q. And did you discuss any of the items requested under the 
     subpoena?
       A. I did not. What I said to her was that she needed 
     counsel.
       Q. Now, just to help you in reference to your previous 
     grand jury testimony of March 3, '98--and if you would like 
     to refer to that, page 121, but I believe it was your 
     testimony that you asked her if there had been any gifts 
     after you looked at the subpoena.
       A. I may have done that, and if I--if that's in my 
     testimony, I stand by it.
       Q. And did she--from your conversation with her, did you 
     determine that in your opinion, there was a fascination on 
     her part with the President?
       A. No question about that.
       Q. And I think you previously described it that she had a 
     ``thing'' for the President?
       A. ``Thing,'' yes.
       Q. And did you make any specific inquiry as to the nature 
     of the relationship that she had with the President?
       A. Yes. At some point during that conversation, I asked her 
     directly if she had had sexual relationships with the 
     President.
       Q. And is this not an extraordinary question to ask a 24-
     year-old intern, whether she had sexual relations with the 
     President of the United States?
       A. Not if you see--not if you had witnessed her emotional 
     state and this ``thing,'' as I say. It was not.
       Q. And her emotional state and what she expressed to you 
     about her feelings for the President is what prompted you to 
     ask that question?
       A. That, plus the question of whether or not the President 
     at the end of his term would leave the First Lady; and that 
     was alarming and stunning to me.
       Q. And she related that question to you in that meeting on 
     December 19th?
       A. That's correct.
       Q. Now, going back to the question in which you asked her 
     if she had had a sexual relationship with the President, what 
     was her response?
       A. No.
       Q. And I'm sure that that was not an idle question on your 
     part, and I presume that you needed to know the answer for 
     some purpose.
       A. I wanted to know the answer based on what I had seen in 
     her expression; obviously, based on the fact that this was a 
     subpoena about her relationship with the President.
       Q. And so you felt like you needed to know the answer to 
     that question to determine how you were going to handle the 
     situation?
       A. No. I thought it was a factual data that I needed to 
     know, and I asked the question.
       Q. And why did you need to know the answer to that 
     question?
       A. I am referring this lady, Ms. Lewinsky, to various 
     companies for jobs, and it seemed to me that it was important 
     for me to know in that process whether or not there had been 
     something going on with the President based on what I saw and 
     based on what I heard.
       Q. And also based upon your years of experience--I mean 
     your--
       A. I don't understand that question.
       Q. Well, you have children?
       A. I have four children; six grandchildren.
       Q. And you've raised kids, you've had a lot of experiences 
     in life, and do you not apply that knowledge and experience 
     and wisdom to circumstances such as this?
       A. Yes. I've been around, and I've seen young people, both 
     men and women, overly excited about older, mature, successful 
     individuals, yes.
       Q. Now, let me just go back as to what signals that you 
     might have had at this particular point that there was a 
     sexual relationship between Ms. Lewinsky and the President. 
     Was one of those the fact that she indicated that she had a 
     fascination with the President?
       A. Yes.
       Q. And did she relate that ``He doesn't call me enough''?
       A. Yes.
       Q. And was the fact that there was an exchange of gifts a 
     factor in your consideration?
       A. Well, I was not aware that there had been an exchange of 
     gifts. I thought it a tad unusual that there would be an 
     exchange of gifts, uh, but it was just clear that there was a 
     fixation by this young woman on the President of the United 
     States.
       Q. And was it also a factor that she had been issued a 
     subpoena in a case that was rooted in sexual harassment?
       A. Well, it certainly helped.
       Q. And that was an ingredient that you factored in and 
     decided this is a question that needed to be asked?
       A. There's no question about that.
       Q. Now, heretofore, the questions or the discussions with 
     Ms. Lewinsky had simply been about a job?
       A. Had been about a job.
       Q. And I think you indicated that you didn't have to be an 
     Einstein to know that this was a question that needed to be 
     asked after what you learned on this meeting?
       A. Yes, based on my own judgment, that is correct.
       Q. Now, at this point, you're assisting the President in 
     obtaining a job for a former intern, Monica Lewinsky?
       A. Right.
       Q. It comes to your attention from Ms. Lewinsky that she 
     has a subpoena in a civil rights case against the President. 
     And did this make you consider whether it was appropriate for 
     you to continue seeking a job for Ms. Lewinsky?
       A. Never gave it a thought.
       Q. Despite the fact that you were seeking the job for Ms. 
     Lewinsky at the request of the President when she is under 
     subpoena in a case adverse to the President?
       A. I--I did not give it a thought. I had committed that I 
     was going to help her, and I was going to--and I kept my 
     commitment.
       Q. And so, however she would have answered that question, 
     you would have still prevailed upon your friends in industry 
     to get a job for her?
       A. Congressman, that is a hypothetical question, and I'm 
     not going to answer a hypothetical question.
       Q. Well, I thought you had answered it before, but if--so 
     you don't know whether it would have made a difference or 
     not, then?
       A. I asked her whether or not she had had sexual 
     relationships with the President. Ms. Lewinsky told me no.
       MR. HUNDLEY: I'd just like to interject. My recollection, 
     Congressman, is that in the grand jury, he gave basically the 
     same answer, that it was a hypothetical question, and that he 
     really didn't know what he would have done had the answer 
     been different. You could double-check it if you want, but 
     I'm sure I'm right.
       BY MR. HUTCHINSON:
       Q. Okay, I'm not asking you a hypothetical question. I want 
     to ask it in this phrase, in this way. Did her answer make 
     you consider whether it was appropriate for you to continue 
     seeking a job for Ms. Lewinsky at the request of the 
     President?
       A. I did not see any reason why I should not continue to 
     help her in her job search.

[[Page 1855]]

       Q. Now, was the fact that she was under subpoena important 
     information to you?
       A. It was additional information, certainly.
       Q. If you were trying to get Ms. Lewinsky a job, did you 
     expect her to tell you if she had any reason to believe she 
     might be a witness in the Jones case?
       A. She did in fact tell me by showing me the subpoena. I 
     had no expectations one way or the other.
       Q. Well, I refer you to your grand jury testimony of March 
     3, '98 at page 96. Do you recall the answer: ``I just think 
     that as a matter of openness and full disclosure that she 
     would have done that.''
       A. And she did.
       Q. Precisely. She disclosed to you, of course, when she 
     received the subpoena, and that's information that you 
     expected to know and to be disclosed to you?
       A. Fine.
       Q. Is--
       A. Yes. Fine.
       Q. And in fact, if Ms. Currie--I'm talking about Betty 
     Currie--if she had known that Ms. Lewinsky was under 
     subpoena, you would have expected her to tell you that 
     information as well since you were seeking employment for Ms. 
     Lewinsky?
       A. Well, it would have been fine had she told me. I do make 
     a distinction between being a witness on the one hand and 
     being a defendant in some sort of criminal action on the 
     other. She was a witness in the civil case, and I don't 
     believe witnesses in civil cases don't have a right for--to 
     employment.
       Q. Okay. I refer you to page 95 of your grand jury 
     testimony, in which you said: ``I believe that had Ms. Currie 
     known, that she would have told me.''
       And the next question: ``Let me ask the question again, 
     though. Would you have expected her to tell you if she 
     knew?''
       And do you recall your answer?
       A. I don't.
       Q. ``Yes, sure.''
       A. I stand by that answer.
       Q. And so it's your testimony that if Ms. Currie had known 
     that Ms. Lewinsky was under subpoena, you would have expected 
     her to tell you that information?
       A. It would have been helpful.
       Q. And likewise, would you have expected the President to 
     tell you if he had any reason to believe that Ms. Lewinsky 
     would be called as a witness in the Paula Jones case?
       A. That would have been helpful, too.
       Q. And that was your expectation, that he would have done 
     that in your conversations?
       A. It--it would certainly have been helpful, but it would 
     not have changed my mind.
       Q. Well, being helpful and that being your expectation is a 
     little bit different, and so I want to go back again to your 
     testimony on March 3, page 95, when the question is asked to 
     you--question: ``If the President had any reason to believe 
     that Ms. Lewinsky could be called a witness in the Paula 
     Jones case, would you have expected him to tell you that when 
     you spoke with him between the 11th and the 19th about her?''
       And your answer: ``And I think he would have.''
       A. My answer was yes in the grand jury testimony, and my 
     answer is yes today.
       Q. All right. So it would have been helpful, and it was 
     something you would have expected?
       A. Yes.
       Q. And yet, according to your testimony, the President did 
     not so advise you of that fact in the conversations that he 
     had with you on December 7th and December 11th after he 
     learned that Ms. Lewinsky was on the witness list?
       A. As I testified--
       MR. KENDALL: Objection. Misstates the record with regard to 
     December 11th.
       MR. HUTCHINSON: I--I will restate the question. I believe 
     it accurately reflects the record, and I'll ask the question.
       BY MR. HUTCHINSON:
       Q. And yet, according to your testimony, the President did 
     not so advise you of the fact that Ms. Lewinsky was on the 
     witness list despite the fact that he had conversations with 
     you on two occasions, on December 7th and December 11th?
       A. I have no recollection of the President telling me about 
     the witness list.
       Q. And during this meeting with Ms. Lewinsky on the 11th, 
     did you take some action as a result of what she told you?
       A. On the 11th or the 18th?
       Q. Excuse me. I'm sorry. Let me go to the 19th.
       A. Nineteenth.
       Q. Thank you for that correction.
       Did you refer her to an attorney?
       A. Yes, I did.
       Q. Okay, and who was the attorney that you referred her to?
       A. Frank Carter, a very able local attorney here.
       Q. And did you give her two or three attorneys to select 
     from, or did you just give her one recommendation?
       A. I made a recommendation of Frank Carter. That was the 
     only recommendation.
       Q. Now, let me go to I believe it's the next three exhibits 
     that are in front of you, if you'd just turn that first page, 
     and I believe they are marked 29, 31, 32 and 33. And these 
     are, I believe, exhibits that you have seen before and are 
     summaries and documents relating to telephone conversations 
     on this particular day of December 19th.
       [Witness perusing documents.]
       SENATOR DODD: How are these going to be marked--as Jordan 
     Deposition Exhibits--
       MR. HUTCHINSON: These should be marked as Exhibits 2, 3, 
     and 4.
       SENATOR DODD: Okay.
       MR. KENDALL: Excuse me, Mr. Manager. Are you offering these 
     in evidence?
       MR. HUTCHINSON: Not at this time.
       I guess it's 2, 3, 4 and 5.
       SENATOR THOMPSON: Are we referring to the next four 
     exhibits in the package here?
       MR. HUTCHINSON: Yes, sir.
       SENATOR THOMPSON: Well, we'll just--identify them one at a 
     time, and we'll--
       MR. HUTCHINSON: All right.
       BY MR. HUTCHINSON:
       Q. Let's go to Exhibit 29 as it's marked, but for our 
     purpose, we're going to refer to it as Deposition Exhibit 2.
       SENATOR THOMPSON: All right. For identification for right 
     now, we'll call that Jordan Exhibit Number 2 for 
     identification, which is marked as, I assume, Grand Jury 
     Exhibit Number 29.
       [Jordan Deposition Exhibit No. 2 marked for 
     identification.]
       BY MR. HUTCHINSON:
       Q. And from this record, would you agree that you received 
     a call from Ms. Lewinsky at 1:47 p.m.?
       A. For 11 seconds.
       Q. All right. And subsequent to that, you placed a call to 
     talk to the President at 3:51 p.m. and talked to Deborah 
     Schiff?
       A. Yes.
       Q. And what was the purpose of that call to Deborah Schiff?
       A. I--I'm certain that I did not call Deborah Schiff. I had 
     no reason to call Deborah Schiff. My suspicion was that if I 
     in fact called 1414, that somehow Deborah Schiff was 
     answering the telephone.
       Q. Were you trying to get hold of the President?
       A. I think maybe I was.
       Q. All right. And then, subsequent to that, Ms. Lewinsky 
     arrived in your office at 4:47 p.m.--and I believe that would 
     be reflected on Exhibit 3--excuse me--Exhibit 4.
       MR. HUNDLEY: Four.
       THE WITNESS: Yes.
       BY MR. HUTCHINSON:
       Q. And does it also reflect, going back to the call 
     records, that you talked to the President during the course 
     of your meeting with Ms. Lewinsky at approximately 5:01 p.m.?
       A. I beg your pardon?
       MR. HUTCHINSON: This would be Exhibit 5.
       SENATOR THOMPSON: All right. Let's mark these for 
     identification purposes.
       We have already identified Deposition Exhibit Number 29 as 
     Exhibit Number 2 for identification in Mr. Jordan's 
     deposition.
       The next one would be Grand Jury Exhibit Number 31, and we 
     will mark that as Exhibit Number 3 for identification 
     purposes. Following that will be Grand Jury Exhibit Number 
     32, that we will identify as Exhibit Number 4 to Mr. Jordan's 
     deposition for identification purposes; and Grand Jury 
     Exhibit Number 33 will be Exhibit Number 5 to Mr. Jordan's 
     deposition for identification purposes.
       Now, do we need to go any further at this time?
       MR. HUTCHINSON: No. Thank you.
       SENATOR THOMPSON: All right.
       [Jordan Deposition Exhibit Nos. 3, 4 and 5 marked for 
     identification.]
       BY MR. HUTCHINSON:
       Q. Mr. Jordan--
       A. Yes.
       Q. --under Exhibit--
       A. Yes.
       Q. --according to these records, specifically Exhibit 5, 
     does it reflect that you talked to the President during the 
     course of your meeting with Ms. Lewinsky at approximately 
     5:01 p.m.?
       MR. KENDALL: Object to the form of the question.
       MR. HUTCHINSON: You may answer.
       THE WITNESS: I'm confused.
       MR. HUTCHINSON: There's an objection as to the form of the 
     question.
       THE WITNESS: Oh.
       SENATOR THOMPSON: We can resolve it.
       MR. KENDALL: The question was do these records indicate 
     this. If he offers Number 2, I'm going to object to it. It's 
     not the best evidence. It's a chart. I don't know who 
     prepared it--
       SENATOR THOMPSON: He's referring to 5 now, I believe, isn't 
     he?
       MR. HUTCHINSON: Yes.
       SENATOR THOMPSON: I believe this had to do with 5.
       MR. HUTCHINSON: All right.
       THE WITNESS: Would you ask your question?
       BY MR. HUTCHINSON:
       Q. Mr. Jordan, I'm simply trying to establish, and using 
     Exhibit 5 to refresh your recollection--
       MR. KENDALL: I withdraw the objection, I withdraw the 
     objection.
       SENATOR THOMPSON: All right, sir; very fine.
       MR. HUTCHINSON: Thank you.
       BY MR. HUTCHINSON:
       Q. --that this record, Exhibit 5, reflects that you talked 
     to the President during the

[[Page 1856]]

     course of your meeting with Ms. Lewinsky at approximately 
     5:01 p.m.
       A. Yes. I--I have never had a conversation with the 
     President while Ms. Lewinsky was present. The wave-in sheet 
     from my office said that she came in at 5:47--
       Q. Four forty-seven.
       A. --4:47. She may have been in the reception area, or she 
     may have been outside my office, but Ms. Lewinsky was not in 
     my office during the time that I had a conversation with the 
     President.
       Q. And the other alternative would be that she came into 
     your office, and then you excused her while you received a 
     call from the President?
       A. That's a possibility, too--
       Q. All right.
       A. --but she was not present in my office proper during the 
     time that I was having a conversation with the President.
       Q. Absolutely, and that is clear.
       Now, because we got a little bogged down in the records, 
     let me just go back for a moment. Is it your understanding, 
     based upon the records and recollection, that you received a 
     call from Ms. Lewinsky about 1:47; you talked to Deborah 
     Schiff trying to get hold of the President about 3:51 that 
     afternoon; Ms. Lewinsky arrived at about 4:47 p.m.
       A. Yes.
       Q. Am I correct so far?
       A. Yes.
       Q. And then you received a call from the President at about 
     5:01 p.m.?
       A. That's correct.
       MR. HUTCHINSON: I want to say ``Your Honor''--I've wanting 
     to do this all day, Senator--I would offer these Exhibits 2, 
     3, 4 and 5 at this time.
       MR. KENDALL: I would object to the admission of Exhibit 
     Number 2.
       SENATOR THOMPSON: Mr. Hutchinson, could you identify what 
     this exhibit is from?
       MR. HUTCHINSON: Well, this exhibit is a summary exhibited 
     based upon the original records that establish this. Now, 
     we've established it clearly through the testimony, so it's 
     not of earth-shattering significance whether this is in the 
     record or not, because the witness has established it.
       SENATOR THOMPSON: All right. But this is a compilation of 
     what you contend--
       MR. HUTCHINSON: Yes.
       SENATOR THOMPSON: --is otherwise in the record?
       MR. HUTCHINSON: Yes.
       SENATOR THOMPSON: Counsel, do we really have a problem with 
     that?
       MR. KENDALL: Senator Thompson, I don't know who prepared 
     this or what records it's based on. I have not objected to 
     any of the original records, and I'll continue my objection.
       SENATOR THOMPSON: I think in light of that we will sustain 
     it, if Mr. Hutchinson thinks it's otherwise in the record 
     anyway, and not make an issue out of that.
       So we will, then, make as a part of the record Exhibits 
     Numbers 3, 4 and 5 that have previously been introduced for 
     identification purposes; they will now be made a part of the 
     record.
       MR. HUTCHINSON: Thank you, Senator.
       [Jordan Deposition Exhibit Nos. 3, 4 and 5 received in 
     evidence.]
       BY MR. HUTCHINSON:
       Q. Now, Mr. Jordan, you indicated you had this conversation 
     with the President at about 5:01 p.m. out of the presence of 
     Ms. Lewinsky. Now, during this conversation with the 
     President, what did you tell the President in that 
     conversation?
       A. That Lewinsky--I'm sure I told him that Ms. Lewinsky was 
     in my office, in the reception area, that she had a subpoena 
     and that I was going to visit with her.
       Q. And did you advise the President as well that you were 
     going to recommend Frank Carter as an attorney?
       A. I may have.
       Q. And why was it necessary to tell the President these 
     facts?
       A. I don't know why it was not unnecessary to tell him 
     these facts. I was keeping him informed about what was going 
     on, and so I told him.
       Q. Why did you make the judgment that you should call the 
     President and advise him of these facts?
       A. I just thought he ought to know. He was interested it--
     he was obviously interested in it--and I felt some 
     responsibility to tell him, and I did.
       Q. All right. And what was the President's response?
       A. He said thank you.
       Q. Subsequent to your conversation with the President about 
     Monica Lewinsky, did you advise Ms. Lewinsky of this 
     conversation with the President?
       A. I doubt it.
       Q. And if she indicates that she was not aware of that 
     conversation, would you dispute her testimony in that regard?
       A. I would not.
       Q. And you say that you doubt it. Was there a reason that 
     you would not disclose to her the fact that you talked to the 
     President when she was the subject of that conversation?
       A. No. I--I didn't feel any particular obligation to tell 
     her or not to tell her, but I did not tell her.
       Q. Now, we have discussed to a limited extent the gifts 
     that were mentioned in the subpoena in this discussion that 
     you had with Ms. Lewinsky. Did she in fact tell you about the 
     gifts she had received from the President?
       A. I think she told me that she had received gifts from the 
     President.
       Q. Did she also indicate that there had been an exchange of 
     gifts?
       A. She did.
       Q. And did you think that it was somewhat unusual that 
     there had been an exchange of gifts?
       A. Uh, a tad unusual, I thought.
       Q. These--
       A. Which again occasioned the question.
       Q. Pardon?
       A. Which again occasioned the ultimate question.
       Q. On--on whether there was a sexual relationship?
       A. That is correct.
       Q. And so that was a significant fact in determining 
     whether that question should be asked?
       A. It was an additional fact.
       Q. Now, the subpoena also references ``documents 
     constituting or containing communications between you''--
     which would have been Ms. Lewinsky under the subpoena--``and 
     the Defendant Clinton, including letters, cards, notes, et 
     cetera.''
       Did you ask Ms. Lewinsky at all whether there were any 
     kinds of cards or communications between them?
       A. Uh, I did not, but she may have volunteered that.
       Q. And did she tell you about telephone conversations with 
     the President?
       A. She did tell me that she and the President talked on the 
     telephone.
       Q. And did she express it in a way that it was frustrating 
     because the President didn't call her sufficiently?
       A. Well, that--that is correct, and she was disappointed, 
     uh, and disapproving of the fact that she was not hearing 
     from the President of the United States on a regular basis.
       Q. During this conversation with Ms. Lewinsky, she also 
     made reference to the First Lady?
       A. Yes.
       Q. And that was another question of concern when she asked 
     if you thought that the President would leave the First Lady 
     at the end of his term?
       A. That is correct.
       Q. And what was your reaction to this statement?
       A. My reaction to the statement after I got over it was 
     that--no way.
       Q. Did it send off alarm bells in your mind as to her 
     relationship with the President?
       A. I think it's safe to say that she was not happy.
       Q. You're speaking of Ms. Lewinsky?
       A. That's the only person we're talking about, Congressman.
       Q. Now, based upon all of this, was it your conclusion the 
     subpoena meant trouble?
       A. Beg your pardon?
       Q. Based upon all of these facts and your conversation with 
     Ms. Lewinsky, was it your conclusion that the subpoena meant 
     trouble?
       A. Well, I always, based on my experience with the grand 
     jury, believe that subpoenas are trouble.
       Q. I think you've used the language, ``ipso facto'' meant 
     trouble?
       A. Yes, yes, right.
       Q. Now, subsequent to your meeting with Ms. Lewinsky on 
     this occasion, did you in fact set up an appointment with Mr. 
     Frank Carter?
       A. Yes--for the 22nd, I believe.
       Q. Which I believe would have been the first part of the 
     next week?
       A. That's right.
       Q. And still on December 19th, after your meeting with Ms. 
     Lewinsky, did you subsequently see the President of the 
     United States later that evening?
       A. I did.
       Q. And is this when you went to the White House and saw the 
     President?
       A. Yes.
       Q. At the time that Ms. Lewinsky came to see you on 
     December 19th, did you have any plans to attend any social 
     function at the White House that evening?
       A. I did not.
       Q. And in fact there was a social invitation that you had 
     at the White House that you declined?
       A. I had--I had declined it; that's right.
       Q. And subsequent to Ms. Lewinsky visiting you, did you 
     change your mind and go see the President that evening?
       A. After the--a social engagement that Mrs. Jordan and I 
     had, we went to the White House for two reasons. We went to 
     the White House to see some friends who were there, two of 
     whom were staying in the White House; and secondly, I wanted 
     to have a conversation with the President.
       Q. And this conversation that you wanted to have with the 
     President was one that you wanted to have with him alone?
       A. That is correct.
       Q. And did you let him know in advance that you were coming 
     and wanted to talk to him?
       A. I told him I would see him sometime that night after 
     dinner.
       Q. Did you tell him why you wanted to see him?
       A. No.
       Q. Now, was this--once you told him that you wanted to see 
     him, did it occur the same

[[Page 1857]]

     time that you talked to him while Ms. Lewinsky was waiting 
     outside?
       A. It could be. I made it clear that I would come by after 
     dinner, and he said fine.
       Q. Now, let me backtrack for just a moment, because 
     whenever you talked to the President, Ms. Lewinsky was not 
     inside the room--
       A. That's correct.
       Q. --and therefore, you did not know the details about her 
     questions on the President might leave the First Lady and 
     those questions that set off all of these alarm bells.
       A. [Nodding head up and down.]
       Q. And so you were having--is the answer yes?
       A. That's correct.
       Q. And so you were having this discussion with the 
     President not knowing the extent of Ms. Lewinsky's fixation?
       A. Uh--
       Q. Is that correct?
       A. Correct.
       Q. And, regardless, you wanted to see the President that 
     night, and so you went to see him. And was he expecting you?
       A. I believe he was.
       Q. And did you have a conversation with him alone?
       A. I did.
       Q. No one else around?
       A. No one else around.
       Q. And I know that's a redundant question.
       A. It's okay.
       Q. Now, would you describe your conversation with the 
     President?
       A. We were upstairs, uh, in the White House. Mrs. Jordan--
     we came in by way of the Southwest Gate into the Diplomatic 
     Entrance--we left the car there. I took the elevator up to 
     the residence, and Mrs. Jordan went and visited at the party. 
     And the President was already upstairs--I had ascertained 
     that from the usher--and I went up, and I raised with him the 
     whole question of Monica Lewinsky and asked him directly if 
     he had had sexual relations with Monica Lewinsky, and the 
     President said, ``No, never.''
       Q. All right. Now, during that conversation, did you tell 
     the President again that Monica Lewinsky had been subpoenaed?
       A. Well, we had established that.
       Q. All right. And did you tell him that you were concerned 
     about her fascination?
       A. I did.
       Q. And did you describe her as being emotional in your 
     meeting that day?
       A. I did.
       Q. And did you relate to the President that Ms. Lewinsky 
     asked about whether he was going to leave the First Lady at 
     the end of the term?
       A. I did.
       Q. And as--and then, you concluded that with the question 
     as to whether he had had sexual relations with Ms. Lewinsky?
       A. And he said he had not, and I was satisfied--end of 
     conversation.
       Q. Now, once again, just as I asked the question in 
     reference to Ms. Lewinsky, it appears to me that this is an 
     extraordinary question to ask the President of the United 
     States. What led you to ask this question to the President?
       A. Well, first of all, I'm asking the question of my friend 
     who happens to be the President of the United States.
       Q. And did you expect your friend, the President of the 
     United States, to give you a truthful answer?
       A. I did.
       Q. Did you rely upon the President's answer in your 
     decision to continue your efforts to seek Ms. Lewinsky a job?
       A. I believed him, and I continued to do what I had been 
     asked to do.
       Q. Well, my question was more did you rely upon the 
     President's answer in your decision to continue your efforts 
     to seek Ms. Lewinsky a job.
       A. I did not rely on his answer. I was going to pursue the 
     job in any event. But I got the answer to the question that I 
     had asked Ms. Lewinsky earlier from her, and I got the answer 
     from him that night as to the sexual relationships, and he 
     said no.
       Q. It would appear to me that there's two options. One, you 
     asked the question in terms of idle conversation, and that 
     does not seem logical in view of the fact that you made a 
     point to go and visit the President about this alone.
       A. Yes. I never said that--I never talked about options. I 
     told you I went to ask him that question.
       Q. Well, was it idle conversation, or was there a purpose 
     in you asking him that question?
       A. It obviously, Congressman, was not idle conversation.
       Q. All right.
       A. For him nor for me.
       Q. There was a purpose in it--and would you describe it as 
     being important, the question that you asked to him?
       A. I wanted to satisfy myself, based on my visit with her, 
     that there had been no sexual relationships, and he said no, 
     as she had said no.
       Q. And why was it important to you to satisfy yourself on 
     that particular point?
       A. I had seen this young lady, and I had seen her reaction, 
     uh, and it raised a presumption, uh, and I wanted to satisfy 
     myself, as I had done with her, that there had been no sexual 
     relationship between them.
       Q. If you had--
       A. And I did satisfy myself.
       Q. And if you had--well, let me rephrase it. If you 
     believed the presumption, or if you had evidence that Ms. 
     Lewinsky did have sexual relations with the President, would 
     this have affected your decision to act in the President's 
     interest in locating her a job when she had been subpoenaed 
     in a case adverse to the President?
       A. I do not think it would have affected my decision.
       Q. Now, you mentioned that you set up an appointment for 
     Ms. Lewinsky at the office of Frank Carter for December 22nd.
       A. Right.
       Q. Prior to that appointment with Mr. Carter, did Ms. 
     Lewinsky come to see you in your office?
       A. I took Ms. Lewinsky from my office, in my Akin Gump, 
     chauffeur-driven car, to Frank Carter's office.
       Q. And when she arrived at your office, did you have a 
     discussion with her?
       A. I think I got my coat, she got her--she had on her 
     coat--and we left.
       Q. While in your office before going to see Mr. Carter, did 
     Ms. Lewinsky ask about her job?
       A. Every conversation that I had with Ms. Lewinsky had at 
     some point to do with pending employment.
       Q. And I take that as a ``yes'' answer, but I would also 
     refer you to page 184 of your previous testimony in which 
     that answer was ``yes.''
       A. Yes.
       Q. And so prior to going to see Mr. Carter, you met with 
     Ms. Lewinsky and--where she asked about her job?
       A. Well, as I'm putting on my coat, I mean, we did not sit 
     down and have a conference. We had an appointment.
       Q. Now, you last testified before the grand jury in June of 
     1998, and you have not had the opportunity to address some 
     issues that Ms. Lewinsky raised when she testified before the 
     grand jury in August of 1998, and I would like to--there will 
     be a number of questions as we go through this today relating 
     to some things that she testified to, because it's important 
     that we hear your responses to it, and so I'd like to ask you 
     about a couple of these particular areas.
       During this meeting--and you say it was a short meeting, 
     that you really didn't sit down--but during this time, did 
     Ms. Lewinsky ask if you had told the President that she had 
     been subpoenaed in the Jones case?
       A. She may have, and--and if she did, I answered yes.
       Q. Even though you did not tell her about the conversation 
     on December 19th that you had with the President in which you 
     told the President she had been subpoenaed?
       A. If she had asked, I would have told her. If she asked me 
     on the 22nd, I answered yes.
       Q. And did Ms. Lewinsky show you any gifts that she was 
     bringing to Mr. Frank Carter?
       A. Yeah--I'm not aware that Ms. Lewinsky showed me any 
     gifts. I have no--I have no recollection of her having shown 
     me gifts given her by the President. And my best recollection 
     is that she came to my office, I got myself together, and 
     that we left. I have no recollection of her showing me gifts 
     given her by the President.
       Q. Would you dispute if she in fact had gifts with her on 
     that occasion?
       A. I don't know whether she had gifts with her or not. I do 
     have--I have no recollection of her showing me, saying, 
     ``This is a gift given me by the President of the United 
     States.''
       Q. And if she testifies that she showed you the gifts she 
     was bringing Mr. Carter, you would dispute that testimony?
       A. I have not any recollection of her showing me any gifts.
       Q. And I take that as not denying it--
       MR. KENDALL: Objection to form.
       BY MR. HUTCHINSON:
       Q. --but that you have no recollection.
       A. Uh, I don't know how else to say it to you, Mr. 
     Congressman.
       Q. Well--
       A. I have no recollection of Ms. Lewinsky coming to my 
     office and showing me gifts given her by the President of the 
     United States.
       Q. Let me go on. Did Ms. Lewinsky tell you that she and the 
     President had had phone sex?
       A. I think Ms.--I know Ms. Lewinsky told me about, uh, 
     telephone conversations with the President. If Ms. Lewinsky 
     had told me something about phone sex, I think I would have 
     remembered that.
       Q. And therefore, if she testifies that she told you that 
     Ms. Lewinsky and the President had phone sex, then you'd 
     simply deny her testimony in that regard?
       A. I--
       MR. KENDALL: Object to the form.
       THE WITNESS: I have no recollection, Congressman, of Ms. 
     Lewinsky telling me about phone sex--but given my age, I 
     would probably have been interested in what that was all 
     about.
       SENATOR THOMPSON: We'll overrule the objection. It's a 
     leading question, but I think that it will be permissible for 
     these purposes.
       MR. HUTCHINSON: It's my understanding, Senator, that under 
     the Senate rule, that the witness would be considered an 
     adverse witness.

[[Page 1858]]

       SENATOR THOMPSON: That's correct.
       BY MR. HUTCHINSON:
       Q. Well, I don't mean to engage in disputes over fine 
     points, but I guess--
       A. Well, you obviously, Congressman, have Ms. Lewinsky 
     saying one thing and me saying another. I stand by what I 
     said.
       Q. Which is that you have no recollection of that 
     discussion taking place.
       A. But I do think that I would have remembered it had it 
     happened.
       Q. All right. Now, after your brief encounter or meeting 
     with Ms. Lewinsky in your office, did you take Ms. Lewinsky 
     in your vehicle to Mr. Carter's office?
       A. Yes.
       Q. And when you arrived at Mr. Carter's office, did you 
     meet with Mr. Carter in advance, while Ms. Lewinsky waited 
     outside?
       A. I said a brief hello to him. We talked about lunch. I 
     never took off my coat. I did take off my hat, because it was 
     inside. And I left them, and I got a piece of his candy.
       Q. Now, I was looking at the testimony of Mr. Carter. Now, 
     do you recall a meeting with Mr. Carter in his office while 
     Ms. Lewinsky waited outside, even if it might have been a 
     brief meeting?
       A. Yes, I think maybe I went in. I just don't know--I was 
     there for a very short time.
       Q. Did you explain to Mr. Carter that you were seeking Ms. 
     Lewinsky a job at the request of the President?
       A. No, I did not, but I think he knew that.
       Q. And why do you think he knew that?
       A. I must have told him.
       Q. So at some point, you believe that you told Mr. Carter 
     that you were seeking Ms. Lewinsky a job at the request of 
     the President?
       A. I think I may have done that.
       Q. Now, you have referred other clients to Mr. Carter 
     during your course of practice here in Washington, D.C.?
       A. Yes, I have.
       Q. About how many have you referred to him?
       A. Oh, I don't know. Maggie Williams is one client that I--
     I remember very definitely.
       I like Frank Carter a lot. He's a very able young lawyer. 
     He's a first-class person, a first-class lawyer, and he's one 
     of my new acquaintances amongst lawyers in town, and I like 
     being around him. We have lunch, and he's a friend.
       Q. And is it true, though, that when you've referred other 
     clients to Mr. Carter that you never personally delivered and 
     presented that client to him in his office?
       A. But I delivered Maggie Williams to him in my office. I 
     had Maggie Williams to come to my office, and it was in my 
     office that I introduced, uh, Maggie Williams to Mr. Carter, 
     and she chose other counsel. I would have happily taken 
     Maggie Williams to his office.
       Q. But this is the only occasion that you took your Akin, 
     Gump-chauffeured vehicle and delivered the client to Mr. 
     Carter in his office?
       A. It was.
       Q. Now, we're not going to go through, probably to your 
     relief, each day's phone calls, but is it safe to say that 
     Ms. Lewinsky called you regularly, both keeping you posted on 
     her interviews and contacts, but also asking you what you 
     knew about her job desires?
       A. That is correct.
       Q. And it is also true that during this process, you kept 
     the President informed?
       A. That, too, is correct.
       Q. And did the President ever give you any other 
     instruction other than to find Ms. Lewinsky a job in New 
     York?
       A. I do not view the President as giving me instructions. 
     The President is a friend of mine, and I don't believe 
     friends instruct friends. Our friendship is one of parity and 
     equality.
       Q. Let me rephrase it, and that's--
       A. Thank you.
       Q. That's a fair comment that you certainly made.
       Did you ever receive any other request from the President 
     in reference to your dealing with Monica Lewinsky other than 
     the request to find her a job in New York?
       A. That is correct.
       MR. HUTCHINSON: I've been informed that there's a few 
     minutes left on the tape. Do you want to break?
       THE VIDEOGRAPHER: Yes.
       SENATOR THOMPSON: All right. Let's take a 5-minute break at 
     this point.
       Also, if it's not objectionable to anyone, let's move a 
     little closer to 1 o'clock, after all, for lunch, if that's 
     okay. We have a conference that that will coincide with a 
     little better, but for right now, let's take a 5-minute 
     break.
       SENATOR DODD: Just before we do, just to make it--and the 
     admonition about these--these--this matter being in--
     confidential.
       SENATOR THOMPSON: Right.
       SENATOR DODD: And I'm going to restate that over and over 
     again today, so that people understand the rules under which 
     we're operating here, and this is confidential and no one is 
     to reveal anything they hear, except to the people that was 
     listed in Senator Thompson's opening remarks.
       SENATOR THOMPSON: Absolutely.
       We'll be in recess.
       THE VIDEOGRAPHER: This marks the end of Videotape Number 1 
     in the deposition of Vernon E. Jordan, Jr. We are going off 
     the record at 11:35 a.m.
       [Recess.]
       THE VIDEOGRAPHER: This marks the beginning of Videotape 
     Number 2 in the deposition of Vernon E. Jordan, Jr. We are 
     going back on the record at 11:49 a.m.
       SENATOR THOMPSON: All right, Mr. Hutchinson, and you have 
     consumed an hour and 40 minutes.
       MR. HUTCHINSON: Thank you, Senator Thompson.
       BY MR. HUTCHINSON:
       Q. Mr. Jordan, I was reminded that the last question I 
     asked you received an answer that I didn't, at least, 
     understand, so I'm going to reask that question, and the 
     question that I had asked, I believe, was: Did you ever 
     receive any other request from the President in reference to 
     your dealings with Ms. Lewinsky other than the request to 
     find her a job in New York? And I think your answer was: 
     That's correct. And that confuses me a little bit, so let me 
     rephrase the question.
       Did you ever receive--not rephrase it, but restate the 
     question. Did you ever receive any other request from the 
     President in reference to your dealings with Monica Lewinsky 
     other than the request to find her a job in New York?
       A. I did not.
       Q. Now, let me go to December 31, 1997, in reference to 
     another issue that Ms. Lewinsky has testified about in her 
     August grand jury appearance and in which you have not had 
     the opportunity to discuss in detail.
       Ms. Lewinsky has testified that she met you for breakfast 
     at the Park Hyatt--
       MR. HUNDLEY: Excuse me. I think you misspoke yourself. You 
     said '97.
       MR. HUTCHINSON: This is '97, right?
       MR. HUNDLEY: It is? I apologize.
       MR. HUTCHINSON: Okay. Thank you, Mr. Hundley. The years are 
     confusing, but I believe this is December 31, 1997.
       BY MR. HUTCHINSON:
       Q. And Ms. Lewinsky has testified that she met you for 
     breakfast at the Park Hyatt, and even specifically as to what 
     she had for breakfast on that particular occasion when she 
     met with you and as to the conversation that she had.
       And I want to show you, in order to hopefully refresh your 
     recollection, an exhibit which I'm going to mark as the next 
     exhibit number, which will be 6, I believe?
       SENATOR THOMPSON: Yes. What--
       MR. HUTCHINSON: And it's in the binder as Exhibit 42. It is 
     not there, but it is in the binder as Exhibit 42.
       SENATOR THOMPSON: Let's take a moment so everyone can refer 
     to that.
       BY MR. HUTCHINSON:
       Q. Have you located that, Mr. Jordan?
       A. [Nodding head up and down.]
       Q. And this receipt, is this a receipt for a charge that 
     you had at the Park Hyatt on December 31st?
       A. That's an American Express receipt for breakfast.
       Q. And is the date December 31st?
       A. That is correct.
       Q. And does it reflect the items that were consumed at that 
     breakfast?
       A. It reflects the items that were paid for at that 
     breakfast.
       [Laughter.]
       BY MR. HUTCHINSON:
       Q. Does it appear to you that this is a breakfast for two 
     people?
       A. The price suggests that it was a breakfast for two 
     people.
       Q. All right. And the fact that there's two coffees, there 
     is one omelet, one English muffin, one hot cereal, and can 
     you identify from that what you ordinarily eat at breakfast?
       A. What I ordinarily eat at breakfast varies. This morning, 
     it was fish and grits.
       Q. All right. Now, Ms. Lewinsky in her testimony, I think, 
     referenced as to what she ate, which I believe would be 
     confirmed in this record.
       Do you recall a meeting with Ms. Lewinsky at the Park Hyatt 
     on December 31st of--
       A. If you--
       Q. --1997?
       A. If you would refer to my testimony before the grand jury 
     when asked about a breakfast with Ms. Lewinsky on December 
     31st, I testified that I did not have breakfast with Ms. 
     Lewinsky on December 31st because I did not remember having 
     had breakfast with Ms. Lewinsky on December 31st. It was not 
     on my calendar. It was New Year's Eve. I have breakfast at 
     the Park Hyatt Hotel three or four times a week if I am in 
     town, and so I really did not remember having breakfast with 
     Ms. Lewinsky. And that's an honest statement, I did not 
     remember, and I told that to the grand jury.
       It is clear, based on the evidence here, that I was at the 
     Park Hyatt on December 31st. So I do not deny, despite my 
     testimony before the grand jury, that on December 31st that I 
     was there with Ms. Lewinsky, but I did testify before the 
     grand jury that I did not remember having a breakfast with 
     her on that date, and that was the truth.
       My recollection has subsequently been refreshed, and--and 
     so it is--it is undeniable that there was a breakfast in my 
     usual breakfast place, in the corner at the Park Hyatt. I'm 
     there all the time.

[[Page 1859]]

       Q. All right. And so--and that would be with Ms. Lewinsky?
       A. Yes.
       Q. And so the--so your memory has been refreshed, and I 
     appreciate the statement that you just made.
       Let me go to that meeting with her and ask whether during 
     this occasion that you met her for breakfast that there was a 
     discussion about Ms. Linda Tripp and Ms. Lewinsky's 
     relationship with her and conversations with her.
       A. I also testified in my grand jury testimony that I never 
     heard the name ``Linda Tripp'' until such time that I saw the 
     Drudge Report. I did not have a conversation with Ms. 
     Lewinsky at the breakfast at the Park Hyatt Hotel on December 
     31st about Linda Tripp. I never heard the name ``Linda 
     Tripp,'' knew nothing about Linda Tripp until I read the 
     Drudge Report.
       Q. All right. And do you recall a discussion with Ms. 
     Lewinsky at the Park Hyatt on this occasion in which there 
     were notes discussed that she had written to the President?
       A. I am certain that Ms. Lewinsky talked to me about notes.
       Q. On this occasion?
       A. Yes.
       Q. And would these have been notes that she would have sent 
     to the President?
       A. I think that there was--these notes had to do with 
     correspondence between Ms. Lewinsky and the President.
       Q. And would have she mentioned the retention or copies of 
     some of that correspondence on her computer in her apartment?
       A. She may have done that.
       Q. And did you ask her a question, were these notes from 
     the President to you?
       A. I understood from our conversation that she and the 
     President had correspondence that went back and forth.
       Q. And did you make a statement to her, ``Go home and make 
     sure they're not there''?
       A. Mr. Hutchinson, I'm a lawyer and I'm a loyal friend, but 
     I'm not a fool, and the notion that I would suggest to 
     anybody that they destroy anything just defies anything that 
     I know about myself. So the notion that I said to her go home 
     and destroy notes is ridiculous.
       Q. Well, I appreciate that reminder of ethical 
     responsibilities. It was--
       A. No, it had nothing to do with ethics, as much as it's 
     just good common sense, mother wit. You remember that in the 
     South.
       Q. And so--and let me read a statement that she made to the 
     grand jury on August 6th, 1998. This is the testimony of Ms. 
     Lewinsky, referring to a conversation with you at the Park 
     Hyatt that, ``She,'' referring to Linda Tripp, ``was my 
     friend. I didn't really trust her. I used to trust her, but I 
     didn't trust her anymore, and I was a little bit concerned 
     because she had spent the night at my home a few times, and I 
     thought--I told Mr. Jordan. I said, 'Well, maybe she's heard 
     some'--you know, I mean, maybe she saw some notes lying 
     around, and Mr. Jordan said, 'Notes from the President to 
     you?,' and I said, 'No. Notes from me to the President,' and 
     he said, 'Go home and make sure they're not there.'''
       A. And, Mr. Hutchinson, I'm saying to you that I never 
     heard the name ``Linda Tripp'' until I read the Judge--Drudge 
     Report.
       Secondly, let me say to you that I, too, have read Ms. 
     Lewinsky's testimony about that breakfast, and I can say to 
     you, without fear of contradiction on my part, maybe on her 
     part, that the notion that I told her to go home and destroy 
     notes is just out of the question.
       Q. And so this is not a matter of you not recalling whether 
     that occurred or not--
       A. I am telling you--
       Q. Well, let me--
       A. --emphatically--
       Q. Mr. Jordan, let me finish the question.
       A. Okay, all right.
       Q. Please, sir.
       A. Okay.
       Q. It's sort of important for the record.
       This is a statement by Ms. Lewinsky that you flatly and 
     categorically deny?
       A. Absolutely.
       Q. Now, you talked about ``mother wit,'' I think it was; 
     that you knew at the time that you had this discussion with 
     Ms. Lewinsky that these notes would have been covered by the 
     subpoena based upon your discussion of that on December 19th?
       A. Ask that question again.
       Q. All right. This is a meeting on December 31st at the 
     Park Hyatt.
       A. Right.
       Q. A discussion about the notes, correspondence between Ms. 
     Lewinsky and the President.
       A. Right.
       Q. You are aware, based upon your discussion of the 
     subpoena on December 19th, that these were covered under the 
     subpoena?
       A. Yes.
       Q. And did you tell Ms. Lewinsky that you need to make sure 
     you tell your attorney, Mr. Carter, and that these are turned 
     over under the subpoena?
       A. What I did not tell her was to destroy the notes. 
     Whether I told her to give them to Mr. Carter or not, I have 
     no recollection of that.
       Q. But you knew at the time that these notes were a matter 
     of evidence?
       A. I think that's a valid assumption.
       Q. But you knew that?
       A. It's a valid assumption.
       Q. Now, during this meeting at the Park Hyatt, did Ms. 
     Lewinsky also make it clear to you that she was in love with 
     the President?
       A. That, I had already concluded.
       Q. And if Ms.--now, was there anything else at the Park 
     Hyatt at this meeting on December 31st that you recall 
     discussing with Ms. Lewinsky?
       A. Job, work, in New York, in the private sector.
       Q. And that was the--was this a meeting that was set up at 
     her request or your request?
       A. I'm certain it was at her request. I am fairly certain 
     that I did not call Ms. Lewinsky and say will you join me at 
     the Park Hyatt for breakfast on December 31st, on New Year's 
     Eve.
       Q. All right. And did you also talk about her situation 
     under the subpoena and the fact that she was going to have to 
     give testimony, it looked like?
       A. I am not Ms. Lewinsky's lawyer, and I did not view it as 
     my responsibility to give Ms. Lewinsky advice and counsel.
       I had found her very able, competent counsel.
       Q. Respectfully, I am simply asking whether that was 
     discussed.
       A. And I am simply saying to you, I did not provide her 
     legal counsel.
       Q. Okay. Was it discussed in--not in terms of legal 
     representation, but in terms of Mr. Jordan to Monica Lewinsky 
     about any emotional concerns she might have about pending 
     testimony?
       A. I have no recollection of talking to her about pending 
     testimony.
       Q. Fair enough. Now, let's go back to Mr. Carter's 
     representation of Ms. Lewinsky that you referred to. Were you 
     aware that Mr. Carter was preparing an affidavit for Ms. 
     Lewinsky to sign in the Jones case?
       A. Yes.
       Q. And on or about the 6th or 7th of January, did you 
     become aware that she in fact had signed the affidavit and 
     that Mr. Carter had filed a motion to quash her subpoena in 
     the case?
       A. She told me that she had signed the affidavit.
       Q. And did in fact Mr. Carter also relate to you that that 
     had occurred?
       A. Yes.
       Q. And I think you made a statement in your March grand 
     jury testimony that there was no reason for accountability, 
     that he reassured me that he had things under control?
       A. That is correct. I stand by that testimony.
       Q. And now, if you would, look at the next exhibit, which 
     is in that stapled bunch of exhibits that have been provided 
     to you.
       MR. HUTCHINSON: This will be Exhibit No. 7, we'll mark for 
     your deposition.
       And, Senator, did we put Exhibit No. 6 in?
       SENATOR THOMPSON: No, we didn't.
       MR. HUTCHINSON: I would like to offer that as an exhibit to 
     this deposition.
       SENATOR THOMPSON: It will be made a part of the record.
       [Jordan Deposition Exhibit Nos. 6 and 7 marked for 
     identification.]
       [Witness perusing document.]
       SENATOR DODD: That is Number 6?
       MR. HUTCHINSON: Six. That's the Park Hyatt.
       SENATOR DODD: Oh, that is going to be Number 6, the Park 
     Hyatt, not the--
       MR. HUTCHINSON: Yes.
       SENATOR THOMPSON: Now, what is 7?
       MR. HUTCHINSON: Now, 7 is the affidavit of Jane Doe Number 
     6, which in the--I think everybody has found that in the 
     book.
       SENATOR THOMPSON: What is the grand jury number?
       MR. HUTCHINSON: It's 85, the grand jury number.
       This will be Deposition Exhibit Number 7.
       BY MR. HUTCHINSON:
       Q. Now, Mr. Jordan, I think you're reviewing that.
       This affidavit bears the signature on the last page of 
     Monica S. Lewinsky, is that correct?
       A. Yes.
       Q. And have you ever seen this signed affidavit before?
       A. I don't think so.
       Q. Do you not recall that Ms. Lewinsky brought this in and 
     showed it to you?
       A. She may have.
       Q. And I'd be glad to refresh you. I know that some of 
     this--
       A. Yeah, if it's in the testimony, Congressman.
       Q. Page 192 of your previous grand jury testimony. Is it 
     your recollection that she showed this to you in a meeting in 
     your office after she had signed it?
       A. I stand by that testimony.
       Q. And so the date of that signature of Ms. Lewinsky, is 
     that January 7?
       A. January 7th, 1998.
       Q. All right. Now, whenever she presented this signed 
     affidavit to you, did you read it sufficiently to know that 
     it stated that Ms. Lewinsky did not have a sexual 
     relationship with the President?
       A. I was aware that that was in the affidavit.
       Q. And I believe you previously testified that you're a 
     quick reader and you skimmed it and familiarized yourself 
     with it?

[[Page 1860]]

       A. Skimmed it.
       Q. And prior to seeing the signed affidavit that she 
     brought to you, the day after it was signed, was there a time 
     that Ms. Lewinsky called you concerning the affidavit and 
     said that she had some questions about the draft of the 
     affidavit?
       A. Yes. I do recollect her calling me and asking me about 
     the affidavit, and I said to her that she should talk to 
     the--talk to Frank Carter, her counsel, about the affidavit 
     and not to me.
       Q. And if I could go into, again, some areas that had not 
     been previously asked to you, and since Ms. Lewinsky 
     testified to the grand jury on August 6th.
       Ms. Lewinsky has testified that she dropped a copy of the 
     affidavit to you, and that you--and that you and she had a 
     telephone conversation in which you discussed changes to the 
     affidavit. Does this refresh your recollection, and do you 
     agree with Ms. Lewinsky's recollection of a discussion on 
     changes in the affidavit?
       A. I do agree with the assumption--I mean, I do agree with 
     the statement that Ms. Lewinsky dropped the affidavit off and 
     called me up about the affidavit and was quite verbose about 
     it, and I sort of listened and said to her, ``You need to 
     talk to Frank Carter.''
       She was not satisfied with that, and so she kept talking 
     and I kept doodling and listening as she went on in sort of 
     a, for lack of a better word, babble about this--about this 
     thing, but it was not my job to advise her about an 
     affidavit. I don't do affidavits.
       Q. Now, if I may show you, which would be Exhibit--
       MR. HUTCHINSON: First, let me go ahead and offer 7.
       SENATOR THOMPSON: It's made a part of the record.
       [Jordan Deposition Exhibit No. 7 received in evidence.]
       MR. HUTCHINSON: It's part of the record.
       And then go to Exhibit 8, which was marked as Exhibit 39 as 
     your previous grand jury testimony.
       [Jordan Deposition Exhibit No. 8 marked for 
     identification.]
       [Witness perusing document.]
       BY MR. HUTCHINSON:
       Q. Now, Exhibit 8 is a summary of telephone calls on 
     January 6th, which would be the day before the affidavit was 
     signed by Ms. Lewinsky on the 7th.
       Now, you can reflect on that for a moment, but in reviewing 
     these calls, it appears that Mr. Carter was paging Ms. 
     Lewinsky early on in the day, 11:32 a.m., and then at 3:26, 
     you had a telephone call with Mr. Carter for 6 minutes and 42 
     seconds.
       And then there was--call number 6 was to Ms. Lewinsky, 
     which was obviously a 24-second short call, and then a 
     subsequent call for almost 6 minutes at 3:49 p.m. to Ms. 
     Lewinsky.
       Was this last call for 5 minutes to Ms. Lewinsky the call 
     that you just referenced in which the draft affidavit was 
     discussed?
       A. I think that is correct. The 24-second call, I think, 
     was voice mail.
       Q. Was--was--pardon?
       A. Voice mail.
       Q. Certainly.
       And subsequent to your conversation with Ms. Lewinsky for 5 
     minutes and 54 seconds, did you have two calls to Mr. Carter, 
     which would be No. 9 and 10?
       [Witness perusing document.]
       THE WITNESS: Yes.
       BY MR. HUTCHINSON:
       Q. Do you know why you would have been calling Mr. Carter 
     on three occasions, the day before the affidavit was signed?
       A. Yeah. I--my recollection is--is that I was exchanging or 
     sharing with Mr. Carter what had gone on, what she had asked 
     me to do, what I refused to do, reaffirming to him that he 
     was the lawyer and I was not the lawyer. I mean, it would be 
     so presumptuous of me to try to advise Frank Carter as to how 
     to practice law.
       Q. Would you have been relating to Mr. Carter your 
     conversations with Ms. Lewinsky?
       A. I may have.
       Q. And if Ms. Lewinsky expressed to you any concerns about 
     the affidavit, would you have relayed those to Mr. Carter?
       A. Yes.
       Q. And if Mr. Carter was a good attorney that was concerned 
     about the economics of law practice, he would have likely 
     billed Ms. Lewinsky for some of those telephone calls?
       A. You have to talk to Mr. Carter about his billing.
       Q. It wouldn't surprise you if his billing did reflect a--a 
     charge for a telephone conversation with Mr. Jordan?
       A. Keep in mind that Mr. Carter spent most of his time in 
     being a legal services lawyer. I think his concentration is 
     primarily on service, rather than billing.
       Q. But, again, based upon the conversations you had with 
     him, which sounds like conversations of substance in 
     reference to the affidavit, that it would be consistent with 
     the practice of law if he charged for those conversations?
       A. That's a question you'd have to ask Mr. Carter.
       Q. They were conversations of substance with Mr. Carter 
     concerning the affidavit?
       A. And they were likely conversations about more than Ms. 
     Lewinsky.
       Q. But the answer was yes, that they were conversations of 
     substance in reference to the affidavit?
       A. Or at least a portion of them.
       Q. In other words, other things might have been discussed?
       A. Yes.
       Q. In your conversation with Ms. Lewinsky prior to the 
     affidavit being signed, did you in fact talk to her about 
     both the job and her concerns about parts of the affidavit?
       A. I have never in any conversation with Ms. Lewinsky 
     talked to her about the job, on one hand, or job being 
     interrelated with the conversation about the affidavit. The 
     affidavit was over here. The job was over here.
       Q. But the--in the same conversations, both her interest in 
     a job and her discussions about the affidavit were contained 
     in the same conversation?
       A. As I said to you before, Counselor, she was always 
     interested in the job.
       Q. Okay. And she was always interested in the job, and so, 
     if she brought up the affidavit, very likely it was in the 
     same conversation?
       A. No doubt.
       Q. And that would be consistent with your previous grand 
     jury testimony when you expressed that you talked to her both 
     about the job and her concerns about parts of the affidavit?
       A. That is correct.
       Q. Now, on January 7th, the affidavit was signed. 
     Subsequent to this, did you notify anyone in the White House 
     that the affidavit in the Jones case had been signed by Ms. 
     Lewinsky?
       A. Yeah. I'm certain I told Betty Currie, and I'm fairly 
     certain that I told the President.
       Q. And why did you tell Betty Currie?
       A. I'm--I kept them informed about everybody else that 
     was--everything else. There was no reason not to tell them 
     about that she had signed the affidavit.
       Q. And why did you tell the President?
       A. The President was obviously interested in her job 
     search. We had talked about the affidavit. He knew that she 
     had a lawyer. It was in the due course of a conversation. I 
     would say, ``Mr. President, she signed the affidavit. She 
     signed the affidavit.''
       Q. And what was his response when you informed him that she 
     had signed the affidavit?
       A. ``Thank you very much.''
       Q. All right. And would you also have been giving him a 
     report on the status of the job search at the same time?
       A. He may have asked about that, and--and part of her 
     problem was that, you know, she was--there was a great deal 
     of anxiety about the job. She wanted the job. She was 
     unemployed, and she wanted to work.
       Q. Now, I think you indicated that he was obviously 
     concerned about--was it her representation and the affidavit?
       A. I told him that I had found counsel for her, and I told 
     him that she had signed the affidavit.
       Q. Okay. You indicated that he was concerned, obviously, 
     about something. What was he obviously concerned about in 
     your conversations with him?
       A. Throughout, he had been concerned about her getting 
     employment in New York, period.
       Q. And he was also concerned about the affidavit?
       A. I don't know that that was concern. I did tell him that 
     the affidavit was signed. He knew that she had counsel, and 
     he knew that I had arranged the counsel.
       Q. Do you know whether or not the President of the United 
     States ever talked to her counsel, Mr. Carter?
       A. I have--I have no knowledge of that.
       Q. Did you ever relate to Mr. Carter that you were having 
     discussions with the President concerning his representation 
     of Ms. Lewinsky and whether she had signed the affidavit?
       A. I don't know whether I told him that she had--he had--I 
     don't know whether I told Mr. Carter that I told the 
     President he had signed the affidavit. It is--it is not 
     beyond reasonableness.
       Q. Now let's go on. After the affidavit was signed, were 
     you ultimately successful in obtaining Ms. Lewinsky a job?
       A. Yes.
       Q. And in fact, the day after Ms. Lewinsky signed the 
     affidavit, you placed a personal call to Mr. Ron Perelman of 
     Revlon, encouraging him to take a second look at Ms. 
     Lewinsky?
       A. That is correct, based on the fact that Ms. Lewinsky 
     thought that her interview had not gone well, when in fact it 
     had gone well.
       Q. Okay. And in fact, Ms. Lewinsky had called you on a 
     couple of occasions after the interview and finally got a 
     hold of you and told you she thought the interview went 
     poorly?
       A. That's correct.
       Q. And as a response to that information, you did not call 
     Mr. Halperin back, who you had previously talked to about the 
     issue, but you called Mr. Perelman?
       A. That's right.
       Q. Was there a reason that you called Mr. Perelman in 
     contrast to Mr. Halperin?
       A. Well, the same reason I would have called you about a 
     committee if you were chairman of it, as opposed to calling 
     to a member of the committee.

[[Page 1861]]

       Q. All right. You wanted to go to the top?
       A. When it's necessary.
       Q. And I remember a phrase you used. I might not have it 
     exactly right, but you don't get any richer or more powerful 
     than Mr. Perelman?
       A. Certainly not much richer.
       Q. Okay. And--and so you had a conversation with Mr. 
     Perelman, and did you tell him something like, make it happen 
     if it can happen?
       A. I said, ``This young lady''--I mean, I think I said, 
     ``This young lady has been interviewed. She thinks it did not 
     go well. Would you look into it?''
       Q. And what was his response?
       A. That he would look into it.
       Q. Now I'd like to show you the next exhibit, and before I 
     do that, I would go back and offer Number 7.
       SENATOR THOMPSON: Seven is the last.
       This would be Number 8 that you--that you have been 
     discussing. The compilation of the telephone call record?
       MR. HUTCHINSON: Yes.
       MR. KENDALL: I object. Same ground as before. It's not best 
     evidence. We don't know who compiled these. These are not 
     primary records.
       SENATOR THOMPSON: Mr. Jordan has verified several of these 
     items, but I do notice there are some items here that do not 
     have to do with Mr. Jordan, that we could not expect him to 
     be able to verify.
       So I would ask counsel, if he needs to identify any more of 
     these conversations and use this to reflect Mr. Jordan's 
     memory, he's free to do so, but as an exhibit, I think the 
     objection is probably well taken.
       MR. HUTCHINSON: Let me just state, Senator, that this is a 
     compilation of calls based upon the records that have been in 
     the Senate record, and this has been--this compilation has 
     been in there some time.
       Now, I, quite frankly, understand the objection, and it 
     might have meritorious if this was being introduced into 
     evidence in the actual trial, and so I would suggest perhaps, 
     since he's identified most of the calls already, that this 
     could be referenced as a deposition exhibit because he's 
     referred to it and that's helpful, without--obviously, there 
     might in a more--it might not be entered into evidence as 
     such.
       SENATOR THOMPSON: Could I ask you if it's been in the 
     record as a compilation?
       MR. HUTCHINSON: Yes, it has.
       SENATOR THOMPSON: In this form? I notice that it has a 
     grand jury--
       MR. HUTCHINSON: It's--Senator, it's Volume III of the 
     Senate record, page 161, and so it's all in there, anyway.
       SENATOR THOMPSON: I notice in the record here, counsel is 
     informing me that it is in the record, but there are several 
     redactions. Is that correct?
       MR. HUTCHINSON: That is correct, and for that reason--in 
     fact, a number of these summaries are not redacted in our 
     form and they're redacted in the record, and we'd like to 
     have the opportunity to redact it in the form of taking out 
     the personal telephone numbers.
       MR. KENDALL: Senator Thompson, if I may be heard, my 
     objection is--to this is a summary. We don't know who did it. 
     We don't know what it's based on.
       The witness has testified, and his testimony is in the 
     record, so far as his recollection is refreshed.
       I have no objection to original phone records, but I do 
     object to the summary.
       SENATOR THOMPSON: Counsel, could I suggest that maybe you 
     just make a reference specifically to where it is in the 
     existing record? I think it would serve your same purpose and 
     to keep you from having--
       MR. HUTCHINSON: Sure.
       SENATOR THOMPSON: --to go through and redact everything. 
     Would that be satisfactory?
       MR. HUTCHINSON: I think that would be satisfactory, and 
     what I can do is that I can withdraw this exhibit and 
     reference in the transcript of this deposition that the 
     exhibit is found in Table 35 of Senate record, Volume III, at 
     page 161.
       SENATOR DODD: Let me just ask the House Manager, if I can 
     as well. Are these from the Senate record? I'm told that some 
     of these are not from the Senate record, and we're kind of 
     confined to the Senate record, as I understand it.
       MR. HUTCHINSON: Well, other than the redactions, this 
     summary itself is in the Senate record.
       SENATOR THOMPSON: Yes.
       Counsel informs me, it's already in. It refers to 
     evidentiary record Volume IV.
       MS. BOGART: Is it IV or III?
       SENATOR THOMPSON: It says IV here, Part 2 of--Part 2 of 3.
       So, for the record, this would be pages 1884 and 1885 of 
     the evidentiary record, Volume IV, Part 2 of 3, all right?
       MR. HUTCHINSON: Thank you.
       SENATOR THOMPSON: All right. So the record will be--the 
     objection will be sustained, and reference has been made.
       SENATOR DODD: And can we just--because I presume you may 
     have more of these coming along, and it seems to me you might 
     want to have staff or others begin to work so we don't go 
     through this every time, particularly with the unredacted 
     material that may be included in here, which is not part of 
     the Senate record.
       The unredacted information comes out of the House record, 
     as I understand, and that is a distinction.
       MR. HUNDLEY: I would just add that Mr. Jordan--the last 3 
     days of his grand jury testimony, they asked him about every 
     phone call, and if you want to use those, you know, go to his 
     grand jury testimony, you know, I think it would move things 
     along.
       There isn't a phone call. We produced like a telephone book 
     of phone calls that Mr. Jordan made, and they called them all 
     out, after they got through asking about who's that, who's 
     that and who's the--you've got a pretty good record of calls 
     that might have some relevance in this.
       SENATOR THOMPSON: All right, sir. All right.
       SENATOR DODD: Let me also just suggest on the earlier--
     Senator Thompson, in the earlier objection raised by Counsel 
     Kendall, sustained the objection, but had made reference to 
     the fact that since this material had been brought into the 
     record that those--if any documentation is included there, 
     that we--we do use the Senate documents with the redacted 
     information, rather than the House records for the purposes 
     of this deposition.
       SENATOR THOMPSON: All right, sir.
       MR. HUTCHINSON: Thank you.
       SENATOR THOMPSON: Proceed.
       BY MR. HUTCHINSON:
       Q. And I will handle it this way, Mr. Jordan, and let me 
     say that I was sort of constructing my questioning, so as not 
     to get bogged down in an extraordinary number of telephone 
     calls, but let me go to the chart in front of you which is 
     Grand Jury Exhibit 44, which is marked for our purposes as 
     Exhibit 9 for identification purposes.
       [Jordan Deposition Exhibit No. 9 marked for 
     identification.]
       [Witness perusing document.]
       BY MR. HUTCHINSON:
       Q. And I'm going to--I'd like for you to refer that--refer 
     you to that for purposes of putting this particular day, 
     January 8th, in context and asking you some questions about 
     some of those telephone calls.
       SENATOR THOMPSON: I'm sorry. What was the question? Are you 
     making reference for identification purposes?
       MR. HUTCHINSON: Yes. This is Exhibit 9, which is Grand Jury 
     Exhibit 44.
       SENATOR THOMPSON: All right, for identification purposes.
       MR. HUTCHINSON: Yes.
       SENATOR THOMPSON: All right.
       BY MR. HUTCHINSON:
       Q. Now, this is the day, January 8th, which is the day that 
     Ms. Lewinsky felt like she had a poor job interview. Does 
     this reflect calls from the Peter Strauss residence to your 
     office?
       A. I see a call number 3, 11:50 a.m., Peter Strauss 
     residence. The number is here to my office.
       Q. All right.
       A. And it says length of call, one minute.
       Q. All right. And, in fact, calls 3, 4 and 5 and 9 are 
     calls from the Peter Strauss residence to your office?
       A. That is correct.
       Q. And Peter Strauss is the residence in which Ms. Lewinsky 
     was staying while in New York?
       A. I just know that Peter Strauss, my old friend, is Monica 
     Lewinsky's stepfather.
       MR. HUNDLEY: But he wasn't there.
       THE WITNESS: You know, where she was and all of that, I 
     don't know. I'm just--
       BY MR. HUTCHINSON:
       Q. You received calls from Ms. Lewinsky on this particular 
     day?
       A. From this number, according to this piece of paper.
       Q. And does this time reference coincide with your 
     recollection as to when you received calls from Ms. Lewinsky 
     on this particular day?
       A. Yes.
       Q. And during these calls is when she related the 
     difficulty of the job interview; is that correct?
       A. I believe so--that it had not gone well.
       Q. All right. And then, subsequently, you put in a call to 
     Mr. Perelman at Revlon?
       A. Yes.
       Q. And that was to encourage him to take a second look. Is 
     that call number 6 on this summary?
       A. Call number 6; it lasted one minute and 42 seconds.
       Q. And is that the call that you placed to Mr. Perelman?
       A. I believe that is correct.
       Q. And this was subsequent to the calls that you received 
     from Ms. Lewinsky?
       A. That is correct.
       Q. And then you let Ms. Lewinsky know that you had called 
     Mr. Perelman; and do you recall what you would have told her 
     at that time?
       A. I think I told her that I had spoken with, uh--with, uh, 
     Mr. Perelman, the chairman, and that I was hopeful that 
     things would work out.
       Q. All right. And, in fact, they did work out because the 
     next day you were informed that a temporary job--or a 
     preliminary job offer had been made to Ms. Lewinsky?
       A. That's right.
       Q. So she was able to secure the job based upon your call 
     to Mr. Perelman?

[[Page 1862]]

       A. Based upon my call, from the time that I called Halperin 
     through to Mr. Perelman.
       Q. All right.
       A. I take credit for that.
       Q. All right. Now, in fact, you've used terms like ``the 
     Jordan magic worked''?
       A. It--it has from time to time.
       Q. And it did on this occasion?
       A. I believe so.
       Q. And then, you also informed Ms. Betty Currie that the 
     mission was accomplished?
       A. Yes.
       Q. And after securing the job for Ms. Lewinsky, you did 
     inform Betty Currie of that fact?
       A. And the President.
       Q. All right. And was the purpose of letting Betty Currie 
     know so that she could tell the President?
       A. She saw the President much more often that I did.
       Q. And--but you wanted to inform the President personally 
     that you were successful in getting Ms. Lewinsky a job?
       A. Yes.
       Q. And you did that, uh--was it on the--what, the day after 
     she secured the job or the day--the day that she secured the 
     job?
       A. I don't know the answer to that.
       Q. Well, shortly thereafter is it fair to say that you 
     informed the President personally?
       A. I certainly told him.
       Q. All right. Now, at this point, you had successfully 
     obtained a job for Ms. Lewinsky at the request of the 
     President, and you had been successful in obtaining an 
     attorney for Ms. Lewinsky. Did you see your responsibilities 
     in regard to Ms. Lewinsky as continuing or completed?
       A. I don't know, uh, that I saw them as, uh, necessary 
     completed. There is--as you know from your own experience in 
     helping young people with work, there tends to be some sense 
     of responsibility to follow through, that they get to work on 
     time, that they work hard, and that they succeed. So I don't 
     think that I felt that my responsibility had terminated. I 
     felt like I had a continuing responsibility to just make sure 
     that it happened and that she--that it worked out all right. 
     But I don't think I acted on that responsibility.
       Q. Well, this is--the job was completed--I believe it was 
     January 8th when she secured the job?
       A. That was the day that I called Ronald Perelman.
       Q. Okay, so it would have been the 9th that she would have 
     been informed that she had the job.
       A. That's right.
       Q. So this is the 9th of January, and that mission had been 
     accomplished. Now, I want you to recall your testimony of May 
     28th before the grand jury in which the question was asked to 
     you--and this is at page 81; the question begins at the 
     bottom of page 80.
       Question: ``When you introduced Monica Lewinsky to Frank 
     Carter on December 22, 1997, what further involvement did you 
     expect to have with Monica Lewinsky and Frank Carter?''
       Answer: ``Beyond getting her the job, I thought it was 
     finished, done''--and what's that last word you used?
       A. ``Fini.''
       Q. ``Fini.'' And so that was the basis on the question, was 
     your previous testimony that after you got Ms. Lewinsky a job 
     and after you secured her attorney, there was really no other 
     need for involvement or continued meetings with her?
       A. That is correct. That does not mean, on the other hand, 
     that, uh, if you go to a meeting at the board, that you don't 
     stop in and see how--how people are doing. In this 
     circumstance, that process was short-circuited very quickly.
       Q. I'm sorry?
       A. She never ended up working there. You--you--you do 
     remember that.
       Q. Now, but you had described your frequent telephone calls 
     from Ms. Lewinsky as being bordering on annoyance, I think. 
     Is that a fair characterization?
       A. That's a fair characterization.
       Q. And you're a busy man. You stopped billing at $450 an 
     hour. You're having calls from Ms. Lewinsky. Were you glad at 
     this point to have this ``bordering on annoyance'' situation 
     completed?
       A. ``Glad'' is probably the wrong word. ``Relieved'' is 
     maybe a better word.
       Q. All right. Now, during the time that you were helping 
     Ms. Lewinsky secure a job, this was widely known at the White 
     House, is that correct?
       A. I--I don't know the extent to which it was widely known. 
     I dealt with Ms. Currie and with the President.
       Q. In fact, Ms. Cheryl Mills, sitting here at counsel 
     table, knew that you were helping Ms. Lewinsky?
       A. I believe that's true.
       Q. And Betty Currie knew that you were helping Ms. 
     Lewinsky?
       A. Yes.
       Q. The President knew it?
       A. Yes.
       Q. And you presumed that Bruce Lindsey knew it?
       A. I presumed that. That's a very small number, given the 
     number of people who work at the White House.
       Q. Now, after that December 19 meeting--and I'm 
     backtracking a little bit--the meeting that you had with Ms. 
     Lewinsky in which she covered with you the fact that she had 
     been subpoenaed, after that, you had numerous conversations 
     with Ms. Betty Currie; is that correct?
       A. I'm not sure I had numerous conversations with Ms. Betty 
     Currie, but I have always during this administration been in 
     touch with Ms. Currie.
       Q. And during those conversations with Ms. Betty Currie, 
     did you let her know that Ms. Lewinsky had been subpoenaed?
       A. I think I've testified to that.
       Q. All right, and so would that have been fairly shortly 
     after the meeting on December 19th with Ms. Lewinsky that you 
     notified Betty Currie that Ms. Lewinsky had in fact been 
     subpoenaed?
       A. I--I think that's safe to say, Counselor.
       MR. HUTCHINSON: Senator, I--this would be a good time for a 
     break, if that would meet with your approval, for lunch.
       SENATOR THOMPSON: All right, sir.
       MR. HUTCHINSON: And I'm--it's hard to estimate, and you 
     probably don't trust lawyers when they tell you how long it's 
     going to take after lunch, but--
       SENATOR THOMPSON: Try your best. Do you want to make an 
     estimate, or you'd rather not?
       MR. HUTCHINSON: Oh, I think it would be less than an hour 
     that I would have remaining, and most likely much shorter 
     than that.
       SENATOR THOMPSON: All right, sir.
       THE WITNESS: May I make a suggestion? It's 25 minutes to 1. 
     Do you want to go to 1 o'clock?
       MR. HUTCHINSON: I think a break would be helpful.
       THE WITNESS: To you or to me?
       [Laughter.]
       SENATOR THOMPSON: I think some of us have some scheduling 
     issues, and I do understand that, so I'm open to any 
     suggestions, Senator Dodd or anyone else, as to how long we 
     want to take. Yesterday, they took an hour. I'm not--we have 
     a conference and I could use a little extra time, I suppose, 
     in addition to the hour, but it's not of major concern to me.
       I assume you want to get back as soon as possible.
       THE WITNESS: I'm prepared to forgo lunch and stay here as 
     long as need be so we can finish. And we don't have to have 
     lunch; we can just keep going, if it's all right with 
     counsel.
       SENATOR THOMPSON: Well, we've got some scheduling issues 
     that we are going to have to take care of. So let's just make 
     it--let's just make it--
       SENATOR DODD: That clock is a little fast, I think.
       SENATOR THOMPSON: Is it?
       SENATOR DODD: Is that right? It's about 12:30?
       THE VIDEOGRAPHER: It's 12:35.
       SENATOR DODD: So an hour and 15 minutes. Is that--
       SENATOR THOMPSON: What about--what about--let's come back 
     at 1:45. That will be about, what--that's an hour and 10 
     minutes, isn't it, or 8 minutes, something like that?
       All right. Without objection, then--
       SERGEANT-AT-ARMS: Senator, we have lunch outside here. It's 
     sandwiches--
       SENATOR DODD: Can we go off the record?
       SENATOR THOMPSON: Are we off the record? Let's go off the 
     record.
       THE VIDEOGRAPHER: We're going off the record now at 12:33 
     p.m.
       [Whereupon, at 12:33 p.m., a luncheon recess was taken.]


                           AFTERNOON SESSION

       THE VIDEOGRAPHER: We are going back on the record at 1349 
     hours.
       SENATOR THOMPSON: All right. Mr. Hutchinson?
       MR. HUTCHINSON: Thank you, Senators.


             DIRECT EXAMINATION BY HOUSE MANAGERS--RESUMED

       BY MR. HUTCHINSON:
       Q. Mr. Jordan, good afternoon.
       A. Good afternoon.
       Q. You testified very clearly earlier today that you were a 
     close friend of the President. Would you also describe 
     yourself as a friend of Mr. Kendall, sitting to my left, one 
     of the attorneys for the President?
       A. Not only is Mr. Kendall my friend, Mr. Kendall has, 
     unfortunately, the distinction of graduating from Wabash 
     College, a little, small town in Indiana, and I'm a graduate 
     of DePauw University, and we have a 100-year rivalry. And Mr. 
     Kendall and I bet.
       Mr. Hutchinson, I am pleased to tell you that Mr. Kendall 
     is in debt to me for 2 years because DePauw--
       MR. KENDALL: May I object?
       [Laughter.]
       THE WITNESS: --because DePauw University has defeated 
     Wabash College two times in succession. And so, yes, we are 
     very good friends. I have great respect for him as a person, 
     as a lawyer, and despite his undergraduate degree from 
     Wabash, I respect his intellect.
       BY MR. HUTCHINSON:
       Q. May I assume from that answer that the answer to my 
     question is yes?
       A. The answer--the answer to your question is, indubitably, 
     yes.
       Q. Now I am going to ask another question in similar vein. 
     You can answer yes or no. Do you consider yourself a friend 
     of Cheryl Mills?

[[Page 1863]]

       A. That requires more than just a ``yes'' answer.
       Q. I do not want to shortchange her, but I know that--in 
     fact, I think you might have, to a certain extent, mentored 
     her. Is that a fair description?
       A. And vice versa.
       Q. All right. And Bruce Lindsey, is he also a friend of 
     yours?
       A. Yes.
       Q. Now--so when was the last time that you met with any 
     member of the President's defense team?
       A. I have not had a meeting with a member of the 
     President's defense team. They were right nextdoor to me just 
     a few minutes ago, and we said hello, but we have not had a 
     meeting. And maybe if you'd tell me about what, I can be more 
     specific.
       Q. Well--and that's a good point. Certainly, we're lawyers, 
     and we have casual conversations, and we visit and we 
     exchange pleasantries, and that's the way life should be.
       I guess I was more specifically going to the question as to 
     whether you have discussed with the President's defense team 
     any matter of substance relating to the present proceedings 
     in the United States Senate.
       A. Any matter of substance relating to these proceedings 
     here in the United States Senate have been handled very ably 
     by my lawyer, Mr. William Hundley.
       Q. And I understand that, but my question is--despite your 
     able representation by Mr. Hundley--my question is--is 
     whether you had any meetings or discussions with the 
     President's defense team in regard to these proceedings.
       A. The answer is no.
       Q. Thank you.
       And has anyone briefed you other than your attorney, Mr. 
     Hundley, on yesterday's deposition of Ms. Lewinsky?
       A. The answer is no.
       Q. Now, you know Greg Craig?
       A. I do know Greg Craig.
       Q. And he's a member of the President's defense team as 
     well?
       A. Yes.
       Q. And you have not had any meetings of substance with him 
     in regard to the present proceedings?
       A. I have not.
       Q. And have you had any meetings with any of the 
     President's defense team in regard to not just the present 
     proceedings, but prior proceedings related to your testimony 
     before the grand jury or the investigation by the OIC?
       A. I have had conversations with the President's lawyer, 
     Mr. Bennett, and a conversation or two with Mr. Kendall on 
     the issue of settlement of the Paula Jones case, and I 
     believe I testified to that before the grand jury.
       Q. All right. Thank you, Mr. Jordan, and now let me move to 
     another area.
       Do you recall an occasion in which Ms. Betty Currie came to 
     see you in your office a few days before the President's 
     deposition in the Jones case on January 17th?
       A. Yes, I do.
       Q. And I believe you have previously indicated that it was 
     on a Thursday or Friday, which would have been around the 
     15th or 16th?
       A. Yeah. I've testified to that specifically as to the date 
     in my grand jury testimony, and I stand on that testimony.
       Q. Certainly. But in general fashion, it would have been a 
     couple of days before the President's testimony on January 
     17th?
       A. I believe that is correct, sir.
       Q. And did--was this meeting with Betty Currie originated 
     by a telephone call with Ms. Betty Currie?
       A. Ms. Currie called me.
       Q. And did she explain to you why she needed to see you?
       A. Yes, she did.
       Q. And was that that she had a call from Michael Isikoff of 
     Newsweek magazine?
       A. That is correct.
       Q. And what did she say about that that caused her to call 
     you?
       A. She had said that Mr. Isikoff had called her and wanted 
     to interview her, having something to do with Monica 
     Lewinsky, and I said to her, why don't you come to see me.
       Q. And why did you ask her to come see you, rather than 
     just talking to her about it over the telephone?
       A. I felt more comfortable doing that, and I think she felt 
     comfortable or more comfortable doing that, rather than doing 
     it on the telephone. And so I asked her to come to my office, 
     and she did.
       Q. Did you consider--or did she seem upset at the time that 
     she called?
       A. I think she was concerned.
       Q. And as--you did in fact meet with her in your office?
       A. I did.
       Q. And what did she relate to you in your office?
       A. That Michael Isikoff was a friend of hers, and that 
     Michael Isikoff had called to--pursuant to a story that he 
     was about to write having to do with Ms. Lewinsky, and she--
     she was concerned about what to do. And I suggested to her 
     that she talk to Bruce Lindsey and to Mike McCurry as to what 
     she should do, Bruce Lindsey on the legal side and Mike 
     McCurry on the communications side.
       Q. Did she explain to you what it was specifically that Mr. 
     Isikoff was inquiring about in reference to Ms. Lewinsky?
       A. No. I don't remember the exact nature of Isikoff's 
     inquiry. What I do remember is that Isikoff, a Newsweek 
     magazine reporter, had called and was making these inquiries, 
     and she was at a loss as to where to turn or to what to do, 
     and I think that stemmed from the fact of some White House 
     policy saying that before you talk to anybody in the media, 
     you check it out.
       Q. And did she explain to you that she had already seen 
     Bruce Lindsey about it before she came to see you?
       A. She did not.
       Q. And so you were basically telling her to see Bruce 
     Lindsey, and if she had already seen that, then that might 
     have not been that helpful?
       A. I don't know whether I was being helpful or not. I 
     responded to her, and I gave her the advice to call Bruce 
     Lindsey and to call Mike McCurry.
       Q. Let me refer you to the testimony of Ms. Betty Currie, 
     and perhaps that will help refresh you, and if not, perhaps 
     you can respond to it.
       A. Sure.
       Q. And for reference purposes, I'm referring to the grand 
     jury testimony of Ms. Betty Currie on May 6th, 1998, at page 
     122.
       MR. HUTCHINSON: Is there a way I--
       MR. HUNDLEY: We don't have that. If you want to--if you 
     want us to read along or just--
       THE WITNESS: Wait a minute. I might have it right here. 
     What page?
       MR. HUTCHINSON: What's the exhibit number?
       MR. HUNDLEY: How long is it, Mr. Hutchinson?
       MR. HUTCHINSON: This would just be some short question-and-
     answers.
       MR. HUNDLEY: Why don't you just read it? We don't--go 
     ahead.
       THE WITNESS: Oh, fine.
       BY MR. HUTCHINSON:
       Q. I'm going to read it, and if there's--it's at page 122, 
     but this just puts it in context.
       The question: ``Ms. Currie, if I'm not mistaken, if I could 
     ask you a couple of questions. When you found out Mr. Isikoff 
     was curious about the courier receipts, you were concerned 
     enough to go visit Vernon Jordan?''
       The answer is: ``Correct.''
       And I'm skipping on down. I'm trying to point to a couple 
     of things that are of interest.
       And question: ``And you went to Bruce Lindsey because you 
     said you knew that he was working on the matter?''
       And question: ``What did Bruce tell you after you told him 
     this?''
       And answer: ``He told me not to call him back, referring to 
     Mr. Isikoff, make him work for the story. I remember that.''
       And then she refers to going to see Mr. Jordan.
       Why did you tell him, or, ``Why did you call Mr. Jordan?''
       Answer: ``Because I had a comfort level with Vernon, and I 
     wanted to see what he had to say about it.''
       MR. KENDALL: Counsel, excuse me. I object to your reading 
     of that, but my understanding that the conversation with 
     Bruce Lindsey occurred later. Are you representing that it 
     occurred before the visit to Mr. Jordan? I don't have the 
     transcript in front of me.
       MR. HUTCHINSON: Well, I'm--I'm not making a representation 
     one way or the other. I'm just representing what Ms. Currie 
     testified to, and that is the context of it, that the visit 
     to Mr. Lindsey was prior to going to see Mr. Jordan. And that 
     is at page 122 through 130 of Betty Currie's transcript of 
     May 6th, 1998.
       BY MR. HUTCHINSON:
       Q. But the first question, Mr. Jordan, is that she refers 
     to courier receipts. I believe that was referring to courier 
     records of gifts from Ms. Lewinsky to the President.
       Did Ms. Currie come to you and say specifically that Mr. 
     Isikoff was inquiring about courier records on gifts from Ms. 
     Lewinsky to the President?
       A. I have no recollection of her telling me about the 
     specific inquiry that Isikoff was making. The issue for her 
     was whether or not she should see him, and I said to her, 
     before she made any decision about that, that she should talk 
     to these two particular people on the White House staff.
       Q. Well, again, if Ms. Currie refers to the courier 
     receipts on gifts, would that be in conflict in any way with 
     your recollection as to what Mr. Isikoff was inquiring about, 
     what Ms. Currie told you?
       A. I stand on what I've just said to you.
       Q. Now, you followed this case, and, of course--
       SENATOR THOMPSON: While we're on that subject, does counsel 
     need any additional time to look over that? I don't want to 
     leave an objection on the record. If you feel like you need 
     to press it--
       SENATOR DODD: Do you have a copy of the document?
       MR. KENDALL: Senator Thompson, we don't have the full copy 
     of the Currie transcript. This was not--
       SENATOR THOMPSON: Why don't we reserve this, then, and you 
     can be looking at it, and then we'll--we'll take it up a 
     little later.
       MR. KENDALL: We're still actually missing some pages of the 
     transcript. I don't know if somebody has that.

[[Page 1864]]

       SENATOR DODD: Why don't you see if you can't get them for 
     them?
       SENATOR THOMPSON: Okay.
       SENATOR DODD: All right?
       SENATOR THOMPSON: We'll let them be doing that, if that's 
     okay with everyone and--
       SENATOR DODD: And you'll withdraw your objection as of 
     right now, or--
       MR. KENDALL: Yes. I'll withdraw it until I can scrutinize 
     the pages, but I may then renew it.
       SENATOR THOMPSON: All right, sir.
       BY MR. HUTCHINSON:
       Q. On--there's been some testimony in this case by Ms. 
     Lewinsky that on December 28th, there was a gift exchange 
     with the President; that subsequent to that, Ms. Currie went 
     out and picked up gifts from Ms. Lewinsky, and she put those 
     gifts under Ms. Currie's bed. Are you familiar with that 
     basic scenario?
       A. I read about it and heard about it. I do not know that 
     because that was told to me by Ms. Lewinsky or by Ms. Currie.
       Q. Certainly, and I'm just setting that forth as a backdrop 
     for my questioning.
       Now, you know, I guess it's--it might be difficult to 
     understand a great deal of concern about a news media call, 
     but if that news media call was about gifts or evidence that 
     was in fact under Ms. Currie's bed or involved in that 
     exchange, then that would be a little heightened concern.
       A. Yes.
       Q. Would that seem fair?
       A. I do not, as I've said to you, know specifically the 
     nature of Mr. Isikoff's inquiry to Ms. Currie, and I know 
     nothing at that particular time about Mr. Isikoff making an 
     inquiry about gifts under the bed.
       Q. All right. I refer you to your grand jury testimony of 
     March 5, 1998, at page 73, when the question was asked of you 
     about Ms. Currie's visit to you, ``What exactly did she tell 
     you?'' and your answer: ``She told me that she had a call 
     from Isikoff from Newsweek magazine, who was calling to make 
     inquiries about Monica Lewinsky and some taped conversations, 
     and I said you have to talk to Mike McCurry and you have to 
     talk to Bruce Lindsey.''
       And so, despite your statement today that you have no 
     recollection as to what she told you, going back to your 
     March testimony, you referred to her relating Isikoff 
     inquiring about taped conversations.
       A. And that's what it says, ``taped conversations,'' and I 
     stand by that.
       What was taped, I don't know.
       Q. Well, I don't think you previously today mentioned taped 
     conversations.
       MR. HUNDLEY: Well, I don't really think your question would 
     have called for that response, but I'm not going to object.
       MR. HUTCHINSON: Thank you, Mr. Hundley.
       BY MR. HUTCHINSON:
       Q. I'm trying to get to the heart of the matter. Ms. Currie 
     is concerned enough that she leaves the White House and goes 
     to see Mr. Vernon Jordan, and she raises an issue with you 
     and, according to your testimony, you told her simply, you 
     need to go see Mike McCurry or Bruce Lindsey.
       A. That is correct.
       Q. And it's your testimony that she never raised with you 
     any issue concerning the--Mr. Isikoff inquiring about gifts 
     and records of gifts by Ms. Lewinsky?
       A. I stand by what I--what you just read to me about--from 
     my testimony about tapes conversations. I have no 
     recollection about gifts or gifts under the bed.
       Q. Okay. Are you saying it did not happen, or you have no 
     recollection?
       A. I certainly have no recollection of it.
       Q. Well, do you have a specific recollection that it did 
     not happen, that she never raised the issue of gifts with 
     you?
       A. It is my judgment that it did not happen.
       Q. Did she seem satisfied with your advice to go see Mr. 
     Bruce Lindsey, who she presumably had already seen?
       A. I assumed that she took my advice.
       Q. Did she discuss in any way with you the incident on 
     December 28th when she retrieved the gifts--
       A. She did not.
       Q. --from Ms. Lewinsky?
       A. She did not.
       Q. Now, a few days later, the President of the United 
     States testified before the grand jury in the--excuse me--
     testified in his deposition in the Jones case.
       After the President's deposition, did he have a 
     conversation with you on that day?
       A. Yes. I'm sure we talked.
       Q. And then, on the next day, and without getting into the 
     entire record of telephone calls, there was, is it fair to 
     say, a flurry of telephone calls in which everyone was trying 
     to locate Ms. Monica Lewinsky?
       A. The next day being which day?
       Q. The next day would have been--well, January 18th.
       A. That's Sunday.
       Q. Correct.
       MR. HUNDLEY: I think it's the 19th.
       THE WITNESS: I think it's the 19th when there was a flurry 
     of calls.
       MR. HUTCHINSON: I think you're absolutely correct.
       THE WITNESS: We'll be glad to be helpful to you in any way 
     we can.
       MR. HUNDLEY: We're even now. I was wrong on one. You were 
     wrong.
       MR. HUTCHINSON: That's fair enough, fair enough.
       BY MR. HUTCHINSON:
       Q. And on the 19th--of course, the 18th is in the record 
     where the President visited with Ms. Betty Currie at the 
     White House--on the 19th, which would have been Monday, was 
     there on that day a flurry of activity in which there were 
     numerous telephone calls, trying to locate Monica Lewinsky?
       A. Yes. And you have a record of those telephone calls, and 
     those telephone calls, Congressman, were driven by two 
     events--first, the Drudge Report; and later in the afternoon, 
     driven by the fact that, uh, I had been informed by Frank 
     Carter, counsel to Ms. Lewinsky, that he had been relieved of 
     his responsibilities as her counsel. And that is the basis 
     for these numerous telephone calls.
       Q. And you yourself were engaged in some of those telephone 
     calls trying to locate Ms. Lewinsky?
       A. Oh, yes, to ask her--I mean, I had just found out that 
     she had been involved in these conversations with this person 
     called Linda Tripp, and that was of some curiosity and 
     concern to me.
       Q. And you had heard Ms. Tripp's name previously on 
     December 31st at the Park Hyatt?
       A. I've testified already that I never heard the name 
     ``Linda Tripp'' until I saw the Drudge Report. I did not 
     testify that I heard the name ``Linda Tripp'' on December 
     31st.
       Q. So the first time you heard Ms. Tripp's name was on 
     January 19th when the Drudge Report came out?
       A. That is correct.
       Q. And you had already secured a--
       A. The 18th, I believe it was.
       MR. HUNDLEY: Eighteenth.
       THE WITNESS: Not the 19th.
       BY MR. HUTCHINSON:
       Q. Thank you.
       You had already secured a job for Ms. Lewinsky?
       A. That is correct.
       Q. And you--
       A. Found a lawyer.
       Q. And a lawyer. And, as you had said at one point, job 
     finished--fini. Why is it that you felt like you needed to 
     join in the search for Ms. Lewinsky?
       A. If you had been sitting where I was, and all of a sudden 
     you found out, after getting her a job and after getting her 
     a lawyer, that there's a report that says that she's been--
     she's been taped by some person named Linda Tripp, I think 
     just, mother wit, common sense, judgment, would have 
     suggested that you would be interested in what that was 
     about.
       Q. And were you trying to provide assistance to the 
     President of the United States in trying to locate Ms. 
     Lewinsky?
       A. I was not trying to help the President of the United 
     States. At that point, I was trying to satisfy myself as to 
     what had gone on with this person for whom I had gotten both 
     a job and a lawyer.
       Q. Now, subsequent to this, you felt it necessary to make a 
     public statement on January 22 in front of the Park Hyatt 
     Hotel?
       A. I did make a public statement on January 22nd at the 
     Park Hyatt Hotel.
       Q. And what was the reason that you gave this public 
     statement?
       A. I gave the public statement because I was being rebuked 
     and scorned and talked about, sure as you're born, and I felt 
     some need to explain to the public what had happened.
       MR. HUTCHINSON: All right. And I have a copy of that public 
     statement that is marked as Grand Jury Exhibit 87, but we 
     will mark it as Exhibit--
       SENATOR THOMPSON: Seven, I believe.
       SENATOR DODD: We've gone through 9, haven't we? You're 
     marking it. If you're only marking it, I think we--
       SENATOR THOMPSON: We have six exhibits, didn't we?
       SENATOR DODD: We've done more than that, haven't we?
       MR. HUTCHINSON: I have nine.
       SENATOR DODD: Nine. Did you enter 9, or did you just note 
     it?
       SENATOR THOMPSON: Six were entered, two were sustained, I 
     think.
       MS. MILLS: I have seven.
       SENATOR DODD: Nine, you have here, but we didn't--I don't 
     know if you--you don't have 9 as an exhibit, or just noted?
       MR. GRIFFITH: Nine was Grand Jury 44.
       MR. HUTCHINSON: We just noted it, I believe.
       SENATOR DODD: You didn't ask that it be entered in the 
     record?
       MR. HUTCHINSON: I believe that's correct.
       SENATOR DODD: Yes.
       SENATOR THOMPSON: How about those we sustained objections 
     to? That doesn't count.
       SENATOR DODD: Well, they're still marked.
       SENATOR THOMPSON: They were marked?
       SENATOR DODD: So which one should this be? Ten?
       SENATOR THOMPSON: This will be 10?
       SENATOR DODD: This is 10, then.
       MR. HUTCHINSON: All right, Number 10.

[[Page 1865]]

       [Jordan Deposition Exhibit No. 10 marked for 
     identification.]
       BY MR. HUTCHINSON:
       Q. Do you have a copy of that, Mr. Jordan?
       A. I have a copy of it. Thank you.
       Q. Thank you. Now, prior to making this public statement, 
     did you consult with the President's attorney, Mr. Bob 
     Bennett?
       A. I did not, not about this statement.
       Q. Did you consult with the President's attorney, Mr. Bob 
     Bennett?
       A. I did not consult with him. Mr. Bennett came to my 
     office and met with me and my attorney, Mr. Hundley, in my 
     office.
       Q. All right. And that was sometime prior to making this 
     statement?
       A. That is correct.
       Q. And it would be--and it would have been between the 19th 
     and the 22nd?
       A. That is correct.
       Q. It would have been after all of the public issues--
       A. It was after--
       Q. --came up?
       A. --I returned from Washington, and it may have been--from 
     New York--and it may have been, I think, Wednesday afternoon.
       Q. Now, in this statement, you indicated that you referred 
     Ms. Lewinsky for interviews at American Express and at 
     Revlon.
       A. That is correct, and Young & Rubicam.
       Q. And in fact, as your testimony today indicates, you did 
     more than refer her for interviews, did you not?
       A. Explain what you mean, and I'll be happy to answer.
       Q. Well, in fact, when the interview went poorly, according 
     to Ms. Lewinsky, you made calls to get her a second interview 
     and to make it happen.
       A. That is safe to say.
       Q. All right. And I think you've also described your 
     involvement in the job search as running the job search?
       A. Yes.
       Q. And so it was a little bit more than simply referring 
     her for interviews. Is that a fair statement?
       A. That's a fair statement.
       Q. And then, in this statement, you also indicate that 
     ``Ms. Lewinsky was referred to me by Ms. Betty Currie''----
       A. Yes.
       Q. --is that correct?
       A. That is correct.
       Q. And in fact, you were acting, as you stated, at the 
     behest of the President?
       A. Through Ms. Currie. I'm satisfied with this statement as 
     correct.
       Q. So--but you were acting in the job search at the behest 
     of the President, as you have previously testified?
       A. I've testified to that.
       MR. HUTCHINSON: Now, we would offer this as Exhibit No. 10.
       SENATOR THOMPSON: Without objection, it will be made a part 
     of the record.
       [Jordan Deposition Exhibit No. 10 received in evidence.]
       MR. HUNDLEY: The only problem with this line of questioning 
     is I think I wrote that thing.
       [Laughter.]
       BY MR. HUTCHINSON:
       Q. After you--after you last testified before the grand 
     jury in June of '98, since then, the President testified 
     before the grand jury in August, and prior to his testimony 
     before the grand jury in August, he made his statement to the 
     Nation in which he--I believe the language was admitted to 
     ``an inappropriate relationship with Ms. Lewinsky.''
       Now, at the time that you testified in June of '98, you did 
     not have this information, did you?
       A. He had not made that statement on the 17th of August, 
     that's for sure.
       Q. And was he in fact, to your knowledge, still denying the 
     existence of that relationship?
       A. I think, as I remember the statement, he said he misled 
     the American people.
       Q. And subsequent to this admission, did you talk to your 
     friend, the President of the United States, about his false 
     statements to you?
       A. I have not spoken to him about any false statements, one 
     way or the other.
       Q. Now, you have testified that you in the job search were 
     acting at the behest of the President of the United States; 
     is that correct?
       A. I stand on that.
       Q. And there is no question but that Ms. Monica Lewinsky 
     understood that?
       A. I have to assume that she understood that.
       Q. Okay. And in the law, there is the rule of agency and 
     apparent authority. Is it safe to assume that Ms. Lewinsky 
     believed that you had apparent authority on behalf of the 
     President of the United States?
       A. I think I know enough about the law to say that the law 
     of agency is not applicable in this situation where there was 
     a potential romance and not a work situation. I think the law 
     of agency has to do with a work situation and an employment 
     situation and not having to do with some sort of romance. I 
     think that's right.
       Q. Well, let me take it out of the legal realm.
       A. You raised it--I didn't.
       Q. And let's put it in the realm of mother wit. Ms. 
     Lewinsky is looking to you as a friend of the President of 
     the United States, knowing that you're acting at the behest 
     of the President of the United States. Is it not reasonable 
     to assume that when she communicates something to you or she 
     hears something from you, that it's as if she is talking to 
     someone who is acting for the President?
       A. No. When she's talking to me, she's talking to me, and I 
     can only speak for me and act for me.
       MR. HUTCHINSON: Could I have just a moment?
       SENATOR THOMPSON: Yes.
       MR. HUTCHINSON: At this time, Your Honors, the House 
     Managers would reserve the balance of its time.
       SENATOR THOMPSON: Counsel?
       MR. HUNDLEY: Fine.
       SENATOR THOMPSON: All right.
       MR. HUTCHINSON: Thank you, Mr. Jordan.
       THE WITNESS: Thank you, Mr. Hutchinson.
       SENATOR THOMPSON: Mr. Kendall?


        EXAMINATION BY COUNSEL FOR THE PRESIDENT BY MR. KENDALL

       Q. Mr. Jordan, is there anything you think it appropriate 
     to add to the record?
       A. Mr. Hutchinson, I'd just like to----
       MR. HUTCHINSON: I'm going to object to the form of that 
     question. I think that even though--and that's not even a 
     leading question; that's an open-ended question that calls 
     for a narrative response. And I think in fairness to the 
     record that that is just simply too broad for this deposition 
     purpose.
       SENATOR THOMPSON: Mr. Kendall, is there any chance of 
     perhaps your rephrasing the question somewhat?
       MR. KENDALL: Certainly.
       BY MR. KENDALL:
       Q. Mr. Jordan, you were asked questions about job 
     assistance. Would you describe the job assistance you have 
     over your career given to people who have come to you 
     requesting help finding a job or finding employment?
       A. Well, I've known about job assistance and have for a 
     very long time. I learned about it dramatically when I 
     finished at Howard University Law School, 1960, to return 
     home to Atlanta, Georgia to look for work. In the process of 
     my--during my senior year, it was very clear to me that no 
     law firm in Atlanta would hire me. It was very clear to me 
     that, uh, I could not get a job as a black lawyer in the city 
     government, the county government, the State government or 
     the Federal Government.
       And thanks to my high school bandmaster, Mr. Kenneth Days, 
     who called his fraternity brother, Donald L. Hollowell, a 
     civil rights lawyer, and said, ``That Jordan boy is a fine 
     boy, and you ought to consider him for a job at your law 
     firm,'' that's when I learned about job referral, and that 
     job referral by Kenneth Days, now going to Don Hollowell, got 
     me a job as a civil rights lawyer working for Don Hollowell 
     for $35 a week.
       I have never forgotten Kenneth Days' generosity. And given 
     the fact that all of the other doors for employment as a 
     black lawyer graduating from Howard University were open to 
     me, that's always--that's always been etched in my heart and 
     my mind, and as a result, because I stand on Mr. Days' 
     shoulders and Don Hollowell's shoulders, I felt some 
     responsibility to the extent that I could be helpful or got 
     in a position to be helpful, that I would do that.
       And there is I think ample evidence, both in the media and 
     by individuals across this country, that at such times that I 
     have been presented with that opportunity that I have taken 
     advantage of that opportunity, and I think that I have been 
     successful at it.
       Q. Was your assistance to Ms. Lewinsky which you have 
     described in any way dependent upon her doing anything 
     whatsoever in the Paula Jones case?
       A. No.

    In the Senate of the United States Sitting for the Trial of the 
   Impeachment of William Jefferson Clinton, President of the United 
                                 States


           excerpts of video deposition of sidney blumenthal

            (Wednesday, February 3, 1999, Washington, D.C.)

       SENATOR SPECTER: If none, I will swear the witness.
       Mr. Blumenthal, will you please stand up and raise your 
     right hand?
       You, Sidney Blumenthal, do swear that the evidence you 
     shall give in this case now pending between the United States 
     and William Jefferson Clinton, President of the United 
     States, shall be the truth, the whole truth, and nothing but 
     the truth, so help you, God?
       MR. BLUMENTHAL: I do.
       Whereupon, SIDNEY BLUMENTHAL was called as a witness and, 
     after having been first duly sworn by Senator Specter, was 
     examined and testified as follows:
       SENATOR SPECTER: Thank you.
       THE WITNESS: Thank you.
       SENATOR SPECTER: The House Managers may begin their 
     questioning.
       MR. ROGAN: Thank you, Senator.


                     EXAMINATION BY HOUSE MANAGERS

       BY MR. ROGAN:
       Q. Mr. Blumenthal, first, good morning.
       A. Good morning to you.
       Q. My name is Jim Rogan. As you know, I am one of the House 
     Managers and will be conducting this deposition pursuant to 
     authority from the United States Senate.

[[Page 1866]]

       First, as a preliminary matter, we have never had the 
     pleasure of meeting or speaking until this morning, correct?
       A. That's correct.
       Q. If any question I ask is unclear or is in any way 
     ambiguous, if you would please call that to my attention, I 
     will be happy to try to restate it or rephrase the question.
       A. Thank you.
       Q. Mr. Blumenthal, where are you currently employed?
       A. At the White House.
       Q. Is that in the Executive Office of the President?
       A. It is.
       Q. What is your current title?
       A. My title is Assistant to the President.
       Q. Was that your title on January 21st, 1998?
       A. It was.
       Q. For the record, that is the date that The Washington 
     Post story appeared that essentially broke the Monica 
     Lewinsky story?
       A. Yes.
       Q. On that date, were you the Assistant to the President as 
     to any specific subject matter?
       A. I dealt with a variety of areas.
       Q. Did your duties entail any specific matter, or were you 
     essentially a jack-of-all-trades at the White House for the 
     President?
       A. Well, I was hired to help the President develop his 
     ideas and themes about the new consensus for the country, and 
     I was hired to deal with problems like the impact of 
     globalization, democracy internationally and domestically, 
     the future of civil society, and the Anglo-American Project; 
     and I also was hired to work on major speeches.
       Q. You testified previously that your duties are such as 
     the President and Chief of Staff shall decide. Would that be 
     a fair characterization?
       A. Oh, yes.
       Q. How long have you been employed in this capacity?
       A. Since August 11th, 1997.
       Q. And in the course of your duties, do you personally 
     advise the President as to the matters that you just shared 
     with us?
       A. Yes.
       Q. How often do you meet with the President personally to 
     advise him?
       A. It varies. Sometimes several times a week; sometimes I 
     go without seeing him for a number of weeks at a time.
       Q. Is dealing with the media part of your--your job?
       A. Yes. It's part of my job and part of the job of most 
     people in the White House.
       Q. Was that also one of your responsibilities on January 
     21st, 1998, when the Monica Lewinsky story broke?
       A. Yes.
       Q. You previously testified that you had a role in the 
     Monica Lewinsky matter after the story broke in The 
     Washington Post on that date, at least in reference to your 
     White House duties; is that correct?
       A. I'm unclear on what you mean by ``a role.''
       Q. Specifically, you testified that you attended meetings 
     in the White House in the Office of Legal Counsel in the 
     morning and in the evening almost every day once the story 
     broke?
       A. Yes.
       Q. And what times did those meetings occur after the story 
     broke, these regular meetings?
       A. The morning meetings occurred around 8:30, after the 
     morning message meeting, and the evening meetings occurred 
     around 6:45.
       Q. Are those meetings still ongoing?
       A. No.
       Q. Can you tell me when those meetings ended?
       A. Oh, I'd say about the time that the impeachment trial 
     started.
       Q. That would be about a month or--about a month ago?
       A. Yeah, something like that.
       Q. Thank you.
       A. I don't recall exactly.
       Q. Sure. But up until that point, were these essentially 
     regularly scheduled meetings, twice a day, 8:30 in the 
     morning and 6:45 in the evening?
       A. Right.
       Q. Did you generally attend those meetings?
       A. Generally.
       Q. Now, initially, when you testified before the grand jury 
     on February 26th, 1998, your first grand jury appearance, you 
     stated that these twice-daily meetings dealt exclusively with 
     the Monica Lewinsky matter, correct?
       A. They dealt with our press reaction, how we would respond 
     to press reports dealing with it. This was a huge story, and 
     we were being inundated with hundreds of calls.
       Q. Right.
       A. So--
       Q. What I'm--what I'm trying to decipher is that at least 
     initially, at the time of your first grand jury appearance, 
     which was about a month after the story broke--
       A. Right.
       Q. --the meetings were exclusively related to Monica 
     Lewinsky. Is that correct?
       A. Pretty much.
       Q. And then, 4 months later, when you testified before the 
     grand jury in June, you said these meetings were still 
     ongoing, and you referenced them at that time as discussing 
     the policy, political, legal and media impact of scandals and 
     how to deal with them. Do you remember that testimony?
       A. If I could see it.
       Q. Certainly. I'm happy to invite your attention to your 
     grand jury testimony of June 4th, 1998, page 25, lines 1 
     through 5.
       MR. ROGAN: And that would be, for the Senators' and 
     counsel's benefit--I believe that's in Tab 4 of the materials 
     provided.
       [Witness perusing document.]
       THE WITNESS: Right. I see it.
       BY MR. ROGAN:
       Q. You've had a chance to review that, Mr. Blumenthal?
       A. I have.
       Q. And that--that's correct testimony?
       A. Yes.
       Q. Thank you.
       At the time you spoke of--you used the word ``scandals'' in 
     the plural, and you were asked on June 4th what other 
     scandals were discussed and you said they range from the 
     Paula Jones trial to our China policy. Is that a fair 
     statement?
       A. Oh, yes, yes. I do.
       Q. Who typically attended those meetings?
       A. As I recall, there were about a dozen or so people, 
     sometimes more, sometimes less.
       Q. Do you remember the names of the people?
       A. I'll try to.
       Q. Would it be helpful if I directed your attention to a 
     couple of passages in the grand jury testimony?
       A. Sure, if you'd like.
       MR. ROGAN: Inviting the Senate and counsel's attention to 
     the February 26th grand jury testimony, page 11, lines 2 
     through 16.
       [Witness perusing document.]
       THE WITNESS: Sure. Yeah.
       BY MR. ROGAN:
       Q. That would be Tab Number 1.
       A. Right, I see that.
       What it says here is that the names listed are Charles 
     Ruff, Lanny Breuer, who is right over here, Cheryl Mills, 
     Bruce Lindsey, John Podesta, Rahm Emanuel, Paul Begala, Jim 
     Kennedy, Mike McCurry, Joe Lockhart, Ann Lewis, Adam 
     Goldberg, Don Goldberg, and that's--those are the names that 
     I--that I recall.
       Q. Thank you.
       And just for my benefit, Mr. Ruff, Mr. Breuer, Ms. Mills, 
     and Mr. Lindsey, those are all White House counsel?
       A. Yes.
       Q. Could you just briefly identify for the record the other 
     individuals that are--that are listed in your testimony?
       A. Sure. John Podesta was Deputy Chief of Staff. Rahm 
     Emanuel was a Senior Advisor. Paul Begala had the title of 
     Counselor. Jim Kennedy was in the Legal Counsel Office. Mike 
     McCurry was Press Secretary. Joe Lockhart at that time was 
     Deputy Press Secretary. Ann Lewis was Director of 
     Communications, still is. Adam Goldberg worked as a--as an 
     Assistant in the Legal Counsel Office, and Don Goldberg 
     worked in Legislative Affairs.
       Q. Thank you.
       Mr. Blumenthal, specifically inviting your attention to 
     January 21st, 1998, you testified before the grand jury that 
     on that date, you personally spoke to the President regarding 
     the Monica Lewinsky matter, correct?
       A. Yes.
       Q. When you spoke to the President, did you discuss The 
     Washington Post story about Ms. Lewinsky that appeared that 
     morning?
       A. I don't recall if we talked about that article 
     specifically.
       Q. Do you recall on June 25th testifying before the grand 
     jury, and I'm quoting, ``We were speaking about the story 
     that appeared that morning''?
       A. Right. We were--we were speaking about that story, but I 
     don't know if we referred to The Post.
       Q. Thank you.
       You are familiar with The Washington Post story that broke 
     that day?
       A. I am.
       Q. That story essentially stated that the Office of 
     Independent Counsel was investigating whether the President 
     made false statements about his relationship with Ms. 
     Lewinsky in the Jones case, correct, to the best of your 
     recollection?
       A. If you could repeat that?
       Q. Sure. The story stated that the Office of Independent 
     Counsel was investigating whether the President made false 
     statements about his relationship with Ms. Lewinsky in the 
     Jones case.
       A. Right.
       Q. And also that the Office of Independent Counsel was 
     investigating whether the President obstructed justice in the 
     Jones case. Is that your best recollection of what that story 
     was about?
       A. Yes.
       Q. How did you end up speaking to the President on that 
     specific date?
       A. I don't remember exactly whether he had summoned me or 
     whether I had asked to speak him--to him.
       Q. And I realize, by the way, I--just so you know, I'm not 
     trying to trick you or anything. I realize this is a year 
     later--
       A. Right.
       Q. --and your testimony was many months ago, and so if I 
     invite your attention to previous grand jury testimony to 
     refresh your

[[Page 1867]]

     recollection, I don't want you to feel that in any way I'm 
     trying to imply that you're not being candid in your 
     testimony.
       With that, if I may invite your--your attention to the June 
     4th grand jury testimony on page 47, lines 5 through 6.
       [Witness perusing document.]
       BY MR. ROGAN:
       Q. Let me see if this helps to refresh your recollection. 
     You said, ``It was about a week before the State of the Union 
     speech.''
       A. I see.
       Q. ``I was in my office, and the President asked me to come 
     to his office.''
       Does that help to refresh your recollection?
       A. Yes.
       Q. And so you now remember that the President asked to 
     speak with you?
       A. Yes.
       Q. Did you go to the Oval Office?
       A. Yes.
       Q. During that conversation, were you alone with the 
     President?
       A. I was.
       Q. Do you remember if the door was closed?
       A. It was.
       Q. When you met with the President, did you relate to him a 
     conversation you had with the First Lady earlier that day?
       A. I did.
       Q. What did you tell the President the First Lady told you 
     earlier that day?
       A. I believe that I told him that the First Lady had called 
     me earlier in the day, and in the light of the story in The 
     Post had told me that the President had helped troubled 
     people in the past and that he had done it many times and 
     that he was a compassionate person and that he helped people 
     also out of his religious conviction and that this was part 
     of--part of his nature.
       Q. And did she also tell you that one of the other reasons 
     he helped people was out of his personal temperament?
       A. Yes. That's what I mean by that.
       Q. And the First Lady also at least shared with you her 
     opinion that he was being attacked for political motives?
       MR. McDANIEL: Can I get a clarification, Senator--Senator 
     Specter? The earlier question, I thought, had been what Mr. 
     Blumenthal had relayed to the President had been said by the 
     First Lady.
       MR. ROGAN: That's correct.
       MR. McDANIEL: And now the questions are back--it seems to 
     me have moved to another topic--
       MR. ROGAN: No. That's--
       MR. McDANIEL: --which is what--
       MR. ROGAN: I'm--
       MR. McDANIEL: --did the First Lady say.
       MR. ROGAN: And I thank--I thank the gentleman for that 
     clarification. I'm specifically asking what the witness 
     relayed to the President respecting his conversation with--
     his earlier conversation with the First Lady.
       MR. McDANIEL: Thank you.
       Do you understand that, what he said?
       THE WITNESS: I understand the distinction, and I don't--
       BY MR. ROGAN:
       Q. I'll restate the question, if that would help.
       A. Please.
       Q. Do you remember telling the President that the First 
     Lady said to you that she felt that with--in reference to 
     this story that he was being attacked for political motives?
       A. I remember her saying that to me, yes.
       Q. And you relayed that to the President?
       A. I'm not sure I relayed that to the President. I may have 
     just relayed the gist of the conversation to him. I don't--
     I'm not sure whether I relayed the entire conversation.
       MR. ROGAN: Inviting the Senators' and counsel's attention 
     to the June 4th, 1998, testimony of Mr. Blumenthal, page 47, 
     beginning at line 5.
       BY MR. ROGAN:
       Q. Mr. Blumenthal, let me just read a passage to you and 
     tell me if this helps to refresh your memory.
       A. Mm-hmm.
       MR. ROGAN: Do you have that, Lanny?
       MR. BREUER: Yes, I do. Thank you.
       BY MR. ROGAN:
       Q. Reading at line--at line 5, ``I was in my office, and 
     the President asked me to come to the Oval Office. I was 
     seeing him frequently in this period about the State of the 
     Union and Blair's visit''--and I--that was Prime Minister 
     Tony Blair, as an aside, correct?
       A. That's right.
       Q. Thank you.
       And then again, reading at line 7, ``So I went up to the 
     Oval Office and I began the discussion, and I said that I had 
     received--that I had spoken to the First Lady that day in the 
     afternoon about the story that had broke in the morning, and 
     I related to the President my conversation with the First 
     Lady and the conversation went as follows. The First Lady 
     said that she was distressed that the President was being 
     attacked, in her view, for political motives for his ministry 
     of a troubled person. She said that the President ministers 
     to troubled people all the time,'' and then it goes on to--
       A. Right.
       Q. --relate the substance of the answer you just gave.
       Does that help to refresh your recollection with respect to 
     what you told the President, the First Lady had said earlier?
       A. Yes.
       Q. Thank you.
       And do you now remember that the First Lady had indicated 
     to you that she felt the President was being attacked for 
     political motives?
       A. Well, I remember she said that to me.
       Q. And just getting us back on track, a few moments ago, I 
     think you--you shared with us that the First Lady said that 
     the President helped troubled people and he had done it many 
     times in the past.
       A. Yes.
       Q. Do you remember testifying before the grand jury on that 
     subject, saying that the First Lady said he has done this 
     dozens, if not hundreds, of times with people--
       A. Yes.
       Q. --with troubled people?
       A. I recall that.
       Q. After you related the conversation that you had with the 
     First Lady to the President, what do you remember saying to 
     the President next about the subject of Monica Lewinsky?
       A. Well, I recall telling him that I understood he felt 
     that way, and that he did help people, but that he should 
     stop trying to help troubled people personally; that troubled 
     people are troubled and that they can get you in a lot of 
     messes and that you had to cut yourself off from it and you 
     just had to do it. That's what I recall saying to him.
       Q. Do you also remember in that conversation saying to him, 
     ``You really need to not do that at this point, that you 
     can't get near anybody who is even remotely crazy. You're 
     President''?
       A. Yes. I think that was a little later in the 
     conversation, but I do recall saying that.
       Q. When you told the President that he should avoid contact 
     with troubled people, what did the President say to you in 
     response?
       A. I'm trying to remember the sequence of it. He--he said 
     that was very difficult for him. He said he--he felt a need 
     to help troubled people, and it was hard for him to--to cut 
     himself off from doing that.
       Q. Do you remember him saying specifically, ``It's very 
     difficult for me to do that, given how I am. I want to help 
     people''?
       A. I recall--I recall that.
       Q. And when the President referred to trying to help 
     people, did you understand him in that conversation to be 
     referring to Monica Lewinsky?
       A. I think it included Monica Lewinsky, but also many 
     others.
       Q. Right, but it was your understanding that he was all--he 
     was specifically referring to Monica Lewinsky in that list of 
     people that he tried to help?
       A. I believe that--that was implied.
       Q. Do you remember being asked that question before the 
     grand jury and giving the answer, ``I understood that''?
       A. If you could point it out to me, I'd be happy to see it.
       Q. Certainly.
       MR. ROGAN: Inviting the Senators' and counsel's attention 
     to the June 25th, 1998, grand jury, page 5, I believe it's at 
     lines 6 through 8.
       [Witness perusing document.]
       THE WITNESS: Yes, I see that. Thank you.
       By MR. ROGAN:
       Q. You recall that now?
       A. Yes.
       Q. Thank you.
       Mr. Blumenthal, did the President then relate a 
     conversation he had with Dick Morris to you?
       A. He did.
       Q. What was the substance of that conversation, as the 
     President related it to you?
       A. He said that he had spoken to Dick Morris earlier that 
     day, and that Dick Morris had told him that if Nixon, Richard 
     Nixon, had given a nationally televised speech at the 
     beginning of the Watergate affair, acknowledging everything 
     he had done wrong, he may well have survived it, and that was 
     the conversation that Dick Morris--that's what Dick Morris 
     said to the President.
       Q. Did it sound to you like the President was suggesting 
     perhaps he would go on television and give a national speech?
       A. Well, I don't know. I didn't know.
       Q. And when the President related the substance of his 
     conversation with Dick Morris to you, how did you respond to 
     that?
       A. I said to the President, ``Well, what have you done 
     wrong?''
       Q. Did he reply?
       A. He did.
       Q. What did he say?
       A. He said, ``I haven't done anything wrong.''
       Q. And what did you say to that response?
       A. Well, I said, as I recall, ``That's one of the stupidest 
     ideas I ever heard. If you haven't done anything wrong, why 
     would you do that?''
       Q. Did the President then give you his account of what 
     happened between him and Monica Lewinsky?
       A. As I recall, he did.
       Q. What did the President tell you?
       A. He, uh--he spoke, uh, fairly rapidly, as I recall, at 
     that point and said that she had come on to him and made a 
     demand for sex, that he had rebuffed her, turned her down, 
     and that she, uh, threatened him. And, uh, he said that she 
     said to him, uh, that she was called ``the stalker'' by her 
     peers and that

[[Page 1868]]

     she hated the term, and that she would claim that they had 
     had an affair whether they had or they hadn't, and that she 
     would tell people.
       Q. Do you remember him also saying that the reason Monica 
     Lewinsky would tell people that is because then she wouldn't 
     be known by her peers as ``the stalker'' anymore?
       A. Yes, that's right.
       Q. Do you remember the President also saying that--and I'm 
     quoting--``I've gone down that road before. I've caused pain 
     for a lot of people. I'm not going to do that again''?
       A. Yes. He told me that.
       Q. And that was in the same conversation that you had with 
     the President?
       A. Right, in--in that sequence.
       Q. Can you describe for us the President's demeanor when he 
     shared this information with you?
       A. Yes. He was, uh, very upset. I thought he was, a man in 
     anguish.
       Q. And at that point, did you repeat your earlier 
     admonition to him as far as not trying to help troubled 
     people?
       A. I did. I--I think that's when I told him that you can't 
     get near crazy people, uh, or troubled people. Uh, you're 
     President; you just have to separate yourself from this.
       Q. And I'm not sure, based on your testimony, if you gave 
     that admonition to him once or twice. Let me--let me clarify 
     for you why my questioning suggested it was twice. In your 
     grand jury testimony on June the 4th, at page 49, beginning 
     at line 25, you began the sentence by saying, and I quote, 
     ``And I repeated to the President''--
       A. Right.
       Q. --``that he really needed never to be near people who 
     were''--
       A. Right.
       Q. --``troubled like this,'' and so forth. Do you remember 
     now if you--if that was correct? Did you find yourself in 
     that conversation having to repeat the admonition to him that 
     you'd given earlier?
       A. I'm sure I did. Uh, I felt--I felt that pretty strongly. 
     He shouldn't be involved with troubled people.
       Q. Do you remember the President also saying something 
     about being like a character in a novel?
       A. I do.
       Q. What did he say?
       A. Uh, he said to me, uh, that, uh, he felt like a 
     character in a novel. Uh, he felt like somebody, uh, 
     surrounded by, uh, an oppressive environment that was 
     creating a lie about him. He said he felt like, uh, the 
     character in the novel Darkness at Noon.
       Q. Did he also say he felt like he can't get the truth out?
       A. Yes, I--I believe he said that.
       Q. Politicians are always loathe to confess their 
     ignorance, particularly on videotape. I will do so. I'm 
     unfamiliar with the novel Darkness at Noon. Did you--do you 
     have any familiarity with that, or did you understand what 
     the President meant by that?
       A. I--I understood what he meant. I--I was familiar with 
     the book.
       Q. What--what did he mean by that, per your understanding?
       A. Uh, the book is by Arthur Koestler, who was somebody who 
     had been a communist and had become disillusioned with 
     communism. And it's an anti-communist novel. It's about, uh, 
     uh, the Stalinist purge trials and somebody who was a loyal 
     communist who then is put in one of Stalin's prisons and held 
     on trial and executed, uh, and it's about his trial.
       Q. Did you understand what the President was trying to 
     communicate when he related his situation to the character in 
     that novel?
       A. I think he felt that the world was against him.
       Q. I thought only Members of Congress felt that way.
       Mr. Blumenthal, did you ever ask the President if he was 
     ever alone with Monica Lewinsky?
       A. I did.
       Q. What was his response?
       A. I asked him a number of questions that appeared in the 
     press that day. I asked him, uh, if he were alone, and he 
     said that, uh, he was within eyesight or earshot of someone 
     when he was with her.
       Q. What other questions do you remember asking him?
       A. Uh, there was a story in the paper that, uh, there were 
     recorded messages, uh, left by him on her voice-mail and I 
     asked him if that were true.
       Q. What did he say?
       A. He said, uh, that it was, that, uh, he had called her.
       Q. You had asked him about a press account that said there 
     were potentially a number of telephone messages left by the 
     President for Monica Lewinsky. And he relayed to you that he 
     called her. Did he tell you how many times he called her?
       A. He--he did. He said he called once. He said he called 
     when, uh, Betty Currie's brother had died, to tell her that.
       Q. And other than that one time that he shared that 
     information with you, he shared no other information 
     respecting additional calls?
       A. No.
       Q. He never indicated to you that there were over 50 
     telephone conversations between himself and Monica Lewinsky?
       A. No.
       Q. Based on your conversation with the President at that 
     time, would it have surprised you to know that there were 
     over 50--there were records of over 50 telephone 
     conversations with Monica Lewinsky and the President?
       A. Would I have been surprised at that time?
       Q. Yes.
       A. Uh, I--to see those records and if he--I don't fully 
     grasp the question here. Could you--would I have been 
     surprised?
       Q. Based on the President's response to your question at 
     that time, would it have surprised you to have been told or 
     to have later learned that there were over 50 recorded--50 
     conversations between the President and Ms. Lewinsky?
       A. I did later learn that, uh, as the whole country did, 
     uh, and I was surprised.
       Q. When the President told you that Monica Lewinsky 
     threatened him, did you ever feel compelled to report that 
     information to the Secret Service?
       A. No.
       Q. The FBI or any other law enforcement organization?
       A. No.
       Q. I'm assuming that a threat to the President from 
     somebody in the White House would normally send off alarm 
     bells among staff.
       A. It wouldn't--
       MR. McDANIEL: Well, I'd like to object to the question, 
     Senator. There's no testimony that Mr. Blumenthal learned of 
     a threat contemporaneously with it being made by someone in 
     the White House. This is a threat that was relayed to him 
     sometime afterwards by someone who was no longer employed in 
     the White House. So I think the question doesn't relate to 
     the testimony of this witness.
       MR. ROGAN: Respectfully, I'm not sure what the legal basis 
     of the objection is. The evidence before us is that the 
     President told the witness that Monica Lewinsky threatened 
     him.
       [Senators Specter and Edwards conferring.]
       SENATOR SPECTER: We've conferred and overrule the objection 
     on the ground that it calls for an answer; that, however the 
     witness chooses to answer it, was not a contemporaneous 
     threat, or he thought it was stale, or whatever he thinks. 
     But the objection is overruled.
       MR. ROGAN: Thank you.
       BY MR. ROGAN:
       Q. Let me--let me restate the question, if I may. Mr. 
     Blumenthal, would a threat--
       SENATOR SPECTER: We withdraw the ruling.
       [Laughter.]
       MR. McDANIEL: I withdraw my objection, then.
       [Laughter.]
       MR. ROGAN: Senator Specter, the ruling is just fine by my 
     light. I'm just going to try to simplify the question for the 
     witness' benefit.
       SENATOR SPECTER: We'll hold in abeyance a decision on 
     whether to reinstate the ruling.
       MR. ROGAN: Thank you. Maybe I should just quit while I'm 
     ahead and have the question read back.
       BY MR. ROGAN:
       Q. Basically, Mr. Blumenthal, what I'm asking is, I mean, 
     normally, would a threat from somebody against the President 
     in the White House typically require some sort of report 
     being made to a law enforcement agency?
       A. Uh, in the abstract, yes.
       Q. This conversation that you had with the President on 
     January the 21st, 1998, how did that conversation conclude?
       A. Uh, I believe we, uh--well, I believe after that, I said 
     to the President that, uh--who was--seemed to me to be upset, 
     that you needed to find some sure footing and to be 
     confident. And, uh, we went on, I believe, to discuss the 
     State of the Union.
       Q. You went on to other business?
       A. Yes, we went on to talk about public policy.
       Q. When this conversation with the President concluded as 
     it related to Monica Lewinsky, what were your feelings toward 
     the President's statement?
       A. Uh, well, they were complex. Uh, I believed him, uh, but 
     I was also, uh--I thought he was very upset. That troubled 
     me. And I also was troubled by his association with troubled 
     people and thought this was not a good story and thought he 
     shouldn't be doing this.
       Q. Do you remember also testifying before the grand jury 
     that you felt that the President's story was a very heartfelt 
     story and that ``he was pouring out his heart, and I believed 
     him''?
       A. Yes, that's what I told the grand jury, I believe; 
     right.
       Q. That was--that was how you interpreted the President's 
     story?
       A. Yes, I did. He was, uh--he seemed--he seemed emotional.
       Q. When the President told you he was helping Monica 
     Lewinsky, did he ever describe to you how he might be helping 
     or ministering to her?
       A. No.
       Q. Did he ever describe how many times he may have tried to 
     help or minister to her?

[[Page 1869]]

       A. No.
       Q. Did he tell you how many times he visited with Monica 
     Lewinsky?
       A. No.
       Q. Did he tell you how many times Monica Lewinsky visited 
     him in the Oval Office complex?
       A. No.
       Q. Did he tell you how many times he was alone with Monica 
     Lewinsky?
       A. No.
       Q. He never described to you any intimate physical activity 
     he may have had with Monica Lewinsky?
       A. Oh, no.
       Q. Did the President ever tell you that he gave any gifts 
     to Monica Lewinsky?
       A. No.
       Q. Did he tell you that Monica Lewinsky gave him any gifts?
       A. No.
       Q. Based on the President's story as he related on January 
     21st, would it have surprised you to know at that time that 
     there was a repeated gift exchange between Monica Lewinsky 
     and the President?
       A. Well, I learned later about that, and I was surprised.
       Q. The President never told you that he engaged in 
     occasional sexual banter with her on the telephone?
       A. No.
       Q. He never told you about any cover stories that he and 
     Monica Lewinsky may have developed to disguise a 
     relationship?
       A. No.
       Q. He never suggested to you that there might be some 
     physical evidence pointing to a physical relationship between 
     he--between himself and Monica Lewinsky?
       A. No.
       Q. Did the President ever discuss his grand jury--or strike 
     that.
       Did the President ever discuss his deposition testimony 
     with you in the Paula Jones case on that date?
       A. Oh, no.
       Q. Did he ever tell you that he denied under oath in his 
     Paula Jones deposition that he had an affair with Monica 
     Lewinsky?
       A. No.
       Q. Did the President ever tell you that he ministered to 
     anyone else who then made a sexual advance toward him?
       A. No.
       Q. Mr. Blumenthal, after you testified before the grand 
     jury, did you ever communicate to the President the questions 
     that you were asked?
       A. No.
       Q. After you testified before the grand jury, did you ever 
     communicate to the President the answers which you gave to 
     those questions?
       A. No.
       Q. After you were subpoenaed to testify but before you 
     testified before the Federal grand jury, did the President 
     ever recant his earlier statements to you about Monica 
     Lewinsky?
       A. No.
       Q. After you were subpoenaed but before you testified 
     before the federal grand jury, did the President ever say 
     that he did not want you to mislead the grand jury with a 
     false statement?
       A. No. We didn't have any subsequent conversation about 
     this matter.
       Q. So it would be fair also to say that after you were 
     subpoenaed but before you testified before the Federal grand 
     jury, the President never told you that he was not being 
     truthful with you in that January 21st conversation about 
     Monica Lewinsky?
       A. Uh, he never spoke to me about that at all.
       Q. The President never instructed you before your testimony 
     before the grand jury not to relay his false account of his 
     relationship with Monica Lewinsky?
       A. We--we didn't speak about anything.
       Q. And as to your testimony on all three appearances before 
     the grand jury on February 26th, June 4th and June 25th, 
     1998--as an aside, by the way, let me just say I think this 
     question has been asked of all the witnesses, so this is not 
     peculiar to you--but as to those three grand jury 
     appearances, do you adopt as truth your testimony on all 
     three of those occasions?
       A. Oh, yes.
       MR. ROGAN: If I may have a moment?
       SENATOR SPECTER: Of course. Would you like a short break?
       MR. ROGAN: That might be convenient, Senator.
       SENATOR SPECTER: All right. It's a little past 10. We'll 
     take a 5-minute recess.
       THE VIDEOGRAPHER: We're going off the record at 10 o'clock 
     a.m.
       [Recess.]
       THE VIDEOGRAPHER: We're going back on the record at 10:12 
     a.m.
       SENATOR SPECTER: We shall proceed; Mr. Graham questioning 
     for the House Managers.
       MR. GRAHAM: Thank you, Senator.
       BY MR. GRAHAM:
       Q. Again, Mr. Blumenthal, if I ask you something that's 
     confusing, just slow me down and straighten me out here.
       A. Thank you.
       Q. Okay. I'm going to ask as direct, to-the-point questions 
     as I can so we all can go home.
       June 4th, 1998, when you testified to the grand jury, on 
     page 49--I guess it's page 185 on tab 4.
       MR. McDANIEL: Page 49?
       MR. GRAHAM: Yes, sir.
       MR. McDANIEL: Thank you.
       BY MR. GRAHAM:
       Q. That's where you start talking about the story that the 
     President told you. Knowing what you know now, do you believe 
     the President lied to you about his relationship with Ms. 
     Lewinsky?
       A. I do.
       Q. I appreciate your honesty. You had raised executive 
     privilege at some time in the past, I believe.
       MR. McDANIEL: I object, Senator. Mr. Blumenthal was a 
     passive vessel for the raising of executive privilege by the 
     President. It's not his privilege to assert, so the question, 
     I think, is misleading.
       BY MR. GRAHAM:
       Q. At any time--I'm sorry.
       [Senators Specter and Edwards conferring.]
       SENATOR SPECTER: Senator Edwards and I have conferred and 
     believe that he can answer the question if he did not raise 
     the privilege, so we will overrule the objection.
       SENATOR EDWARDS: Either he asserted it or it was asserted 
     on his behalf.
       THE WITNESS: If you could repeat it, please.
       BY MR. GRAHAM:
       Q. I believe early on in your testimony and throughout your 
     testimony to the grand jury, the idea of executive privilege 
     covering your testimony or conversations with the President 
     was raised. Is that correct?
       A. It was.
       Q. Do you believe the White House knew that this privilege 
     would be asserted in your testimony? That was no surprise to 
     them?
       A. Uh--
       MR. BREUER: I'm going to object. It's the White House's 
     privilege to assert it could not have been surprised. It's a 
     mischar-
     acterization of the facts.
       [Senators Specter and Edwards conferring.]
       SENATOR SPECTER: Senator Edwards and I believe the 
     objection is well-founded on the ground that he cannot 
     testify as to what someone else knew. So would you rephrase 
     the question? The objection will be sustained.
       BY MR. GRAHAM:
       Q. When executive privilege was asserted, do you know how 
     it came about? Do you have any knowledge of how it came 
     about?
       A. What I recall is that I--in my first appearance before 
     the grand jury, I was asked questions about my conversations 
     with the President. And I went out into the hall, asked if I 
     could go out in the hall, and I spoke with the White House 
     legal counsel who was there, Cheryl Mills, and said, ``What 
     do I say?''
       Q. And she said?
       A. And I was advised to assert privilege.
       Q. So the executive privilege assertion came about from 
     advice to you by White House counsel?
       A. Yes.
       Q. Now, you've stated, I think, very honestly, and I 
     appreciate, that you were lied to by the President. Is it a 
     fair statement, given your previous testimony concerning your 
     30-minute conversation, that the President was trying to 
     portray himself as a victim of a relationship with Monica 
     Lewinsky?
       A. I think that's the import of his whole story.
       Q. During this period of time, the Paula Jones lawsuit, 
     other allegations about relationships with the President and 
     other women were being made and found their way in the press. 
     Is that correct?
       A. Yes.
       Q. Now, when you have these morning meetings and evening 
     meetings about press strategy, I believe your previous 
     testimony goes along the lines that any time a press report 
     came out about a story between the President and a woman, 
     that you would sit down and strategize about what to do. Is 
     that correct?
       A. Well, we would, uh, talk about what the White House 
     spokesman would say about it.
       Q. Does the name ``Kathleen Willey'' mean anything to you 
     in that regard?
       MR. BREUER: I'm going to object. It's beyond the scope of 
     this deposition. In the proffer from the Managers, they 
     explicitly state the areas that they want to go into, and 
     they explicitly state that they want to speak to Mr. 
     Blumenthal about his January 21, 1998, conversation with the 
     President about Monica Lewinsky. And any aspects as to 
     Kathleen Willey are--have nothing to do with the Articles of 
     Impeachment, nor do they have anything to do with the proffer 
     made by the Managers, and it's beyond the scope of this 
     deposition.
       SENATOR SPECTER: Just wait one second.
       [Senators Specter and Edwards conferring.]
       SENATOR SPECTER: Mr. Graham, as you know, the scope of the 
     examination of Mr. Blumenthal is limited by the subject 
     matters reflected in the Senate record. Are you able to 
     substantiate the Senate record as a basis for asking the 
     question?
       MR. GRAHAM: I'm assuming, yes, Senator, that the grand jury 
     testimony of Mr. Blumenthal is part of the Senate record. And 
     on June 25th, 1998, on page 21, there's a discussion between 
     Mr. Blumenthal and the Independent Counsel's Office about 
     strategy

[[Page 1870]]

     meetings and other women, and in that testimony, he mentions 
     that ``we discussed Paula Jones, Kathleen Willey, in our 
     strategy meeting.''
       And I think the question will not be as ominous as some may 
     think it sounds. I think I can get right to the point pretty 
     quickly about what I'm trying to do with--
       SENATOR SPECTER: Well, would you make an offer of proof so 
     that we can see what the scope is that you have in mind?
       MR. GRAHAM: Basically, his testimony is that when a press 
     report came about concerning Ms. Jones or Kathleen Willey or 
     a relationship between the President and another woman, they 
     sat down and strategized about how to respond to those press 
     accounts, what to do and what to say--at least that's what 
     his testimony indicates. And I just want to ask him, once the 
     January 21st story about Ms. Lewinsky came out, how they 
     discussed her in relationship to other strategy meetings.
       SENATOR SPECTER: Mr. Breuer, how would you respond to 
     Congressman Graham's statement that as he refers to a 
     reference to Ms. Willey in the record?
       MR. BREUER: Senator, I haven't seen the one reference, but 
     I may--I would acknowledge that there may be one passing 
     reference to Ms. Willey in the voluminous materials that are 
     before us here in the grand jury, Senator. But it's clearly 
     not germane to this deposition. It's clearly not germane to 
     the proffer made by the Managers about why Mr. Sidney 
     Blumenthal was a witness. It is clearly not germane to the 
     Articles of Impeachment.
       And, indeed, in Mr. Lindsey Graham's proffer just now, he 
     said that he wants to go back and ask about the January 21 
     conversation. It's my view that Kathleen Willey is 
     tangential, at best, and is not germane to this deposition 
     and ought not to be inquired into.
       SENATOR EDWARDS: And, Senator Specter, I would ask that we 
     go off the record for this discussion, given the question of 
     whether this is within the scope of the Senate record.
       SENATOR SPECTER: We shall go off the record.
       THE VIDEOGRAPHER: We're going off the record at 10:20 a.m.
       [Discussion off the record.]
       THE VIDEOGRAPHER: We're going back on the record at 10:48 
     a.m.
       SENATOR SPECTER: Congressman Lindsey, you may proceed.
       MR. GRAHAM: Thank you, sir.
       BY MR. GRAHAM:
       Q. Thank you for your patience, Mr. Blumenthal. I 
     appreciate it.
       A. Thank you.
       Q. Let's get back to the--we'll approach this topic another 
     way and we'll try to tie it up at the end here.
       The January 21st article breaks, and I think it's in The 
     Washington Post, is that correct, the January 21st article 
     about Ms. Lewinsky being on tape, talking about her 
     relationship with the President? Are you familiar with that 
     article?
       A. I'm familiar with an article on January 21st in The 
     Washington Post.
       Q. And what--what was the essence of that article, as you 
     remember it?
       A. If you have it there, I'd be happy to look at it.
       Q. Yeah. Let's see if we can find it, what tab that is. Tab 
     7.
       [Witness perusing document.]
       THE WITNESS: Well--
       BY MR. GRAHAM:
       Q. If you'd like a chance to read it over, just take your 
     time.
       A. Yes. Thank you.
       [Witness perusing document.]
       THE WITNESS: It's a long article.
       BY MR. GRAHAM:
       Q. Yes, sir, it is, and just--
       A. Yeah.
       Q. --just take your time. I'm not going to give you a test 
     on the article. I just wanted--
       A. No. I just wanted to read it.
       Q. --to refresh your memory. Absolutely, you take your 
     time.
       A. I hope you don't mind if I took the time here.
       Q. No, sir. Are you--you're okay now?
       A. I am.
       Q. Okay. In essence, what this article is--is alleging is 
     what we now know, the allegations that Ms. Lewinsky had a 
     relationship with the President, that Mr. Jordan was trying 
     to help her secure counsel, to file an affidavit saying they 
     had no relationship, and the relationship on January 21st was 
     being exposed through some tape recordings, supposedly, the 
     Independent Counsel had access to between Ms. Lewinsky and 
     Ms. Tripp. Is that correct?
       A. Well, there are a lot of questions in there.
       Q. Okay, yeah, and I'm sorry.
       This article seems to suggest that Ms. Lewinsky is telling 
     a friend--
       A. Mm-hmm.
       Q. --that she has a relationship with the President, a 
     sexual relationship with the President.
       A. Mm-hmm.
       Q. You understand that from the article?
       A. Yes.
       Q. This article also alleges that an affidavit was filed by 
     Ms. Lewinsky denying that relationship, and Mr. Jordan sought 
     an attorney for her, a friend of the President. Is that 
     correct?
       A. It says she filed an affidavit, and I'm just looking for 
     where it says that Jordan had secured the attorney.
       Q. The very first paragraph, let me read it. ``The 
     Independent Counsel Kenneth Starr has expanded his 
     investigation of President Clinton to examine whether Clinton 
     and his close friend, Vernon Jordan, encouraged a 24-year-
     old''--
       A. Right.
       Q. --``former White House intern to lie to lawyers for 
     Paula Jones about whether the intern had an affair with the 
     President, sources close to the investigation said 
     yesterday.''
       A. Right.
       Q. So I guess that first paragraph kind of sums up the 
     accusation.
       A. I think--
       Q. What type reaction did the White House have when this--
     as you recall--when this article came to light?
       A. I--I think the White House was overwhelmed with press 
     inquiries.
       Q. Was there a sense of alarm that this was a bad story?
       A. Yes.
       Q. And wasn't there a sense of reassurance by the President 
     himself that this was an untrue story?
       A. The President did make a public statement that 
     afternoon.
       Q. And I believe White House officials on his behalf denied 
     the essence of this story; is that correct?
       A. Yes.
       Q. And basically, you were passing along what somebody you 
     trust and admire told you to be the case, and from the White 
     House point of view, that was the response to this story, 
     that we deny these allegations.
       MR. McDANIEL: Senator, I really object to the question 
     where we mix ``you'' and ``we'' and the ``White House.'' I'd 
     like, if possible, for the question--if they want to know 
     what Mr. Blumenthal did, to ask him what he did, and 
     questions about what the White House did and what we and you 
     did.
       MR. GRAHAM: That's fair enough.
       MR. McDANIEL: Okay, we thank you.
       SENATOR SPECTER: We think that's well-founded.
       MR. GRAHAM: Yes, and I agree. I agree that is well-founded.
       BY MR. GRAHAM:
       Q. Did you have any discussions with White House press 
     people about the nature of this relationship after this 
     article broke?
       A. No.
       Q. Did you have any discussions with White House lawyers 
     after this article broke about the nature of the 
     relationship?
       A. No.
       Q. After you had the conversation with the President, 
     sometime the week of the 21st--I believe that's your 
     testimony--shortly after the news story broke, this 30-minute 
     conversation where he tells you about--
       A. There's not a question.
       Q. Okay. Is that correct? When did you have this 
     conversation with the President? Do you recall?
       A. Yes. It was in the early evening of January 21st.
       Q. Early evening of January 21st?
       A. Yes.
       Q. The same day the story was reported?
       A. Yes.
       Q. Okay. So, from your point of view, this was something 
     that needed to be addressed?
       MR. McDANIEL: Your Honor, I--Senator, I object to the 
     question about ``this'' is something that needs to be 
     addressed. I don't understand what the ``this'' is, exactly, 
     that the question refers to. Does it refer to the story? Does 
     it refer to the President's statement to Mr. Blumenthal?
       SENATOR SPECTER: Well, we think--Senator Edwards and I 
     concur that the witness can answer the question. If he does 
     not understand it, he can say so and then can have the 
     question rephrased.
       BY MR. GRAHAM:
       Q. You have a conversation with the President on the same 
     day the article comes out, and the conversation includes a 
     discussion about the relationship between him and Ms. 
     Lewinsky. Is that correct?
       A. Yes.
       Q. Okay. So it was certainly on people's minds, including 
     the President, is that correct, the essence of this story?
       MR. McDANIEL: I object to the question about whether it's 
     on people's minds. I think he can answer about what he knew 
     or about what he learned from people who spoke to him, but 
     the question goes far beyond that.
       BY MR. GRAHAM:
       Q. Well, let me ask you this. We know it was on the 
     President's mind.
       SENATOR SPECTER: Senator Edwards and I think that, 
     technically, that's correct, and perhaps you can avoid it by 
     just pinpointing it just a little more.
       MR. GRAHAM: Yes. We'll try to be laser-like in these 
     questions.
       BY MR. GRAHAM:
       Q. You had a conversation with the President of the United 
     States about his relationship with Ms. Lewinsky on the same 
     day The Washington Post article came out. That's correct? Yes 
     or no?
       A. That--I--I--that's right.

[[Page 1871]]

       Q. Okay. During that period of time, that day or any day 
     thereafter, were you involved in any meeting with White House 
     lawyers or press people where the conversation--or where the 
     topic of Ms. Lewinsky's allegations or the--Ken Starr's 
     allegations about Ms. Lewinsky came up?
       A. I'm confused about which allegations you're talking 
     about.
       Q. That she had a relationship with the President, and they 
     were trying to get her to file a false affidavit. Did that 
     topic ever come up in your presence with the Press Secretary, 
     White House press people or lawyers for the White House?
       A. I think the whole story was discussed by senior staff in 
     the White House.
       Q. When did that begin to occur?
       A. I'm sure we were discussing it on January 21st.
       Q. Do you recall that every--
       A. Every--everyone in the country was talking about it.
       Q. Well, do you recall the tenor of that conversation? Do 
     you recall the flavor of it? Can you describe it the best you 
     can, about--was there a sense of alarm, shock? How would you 
     describe it?
       A. I think we felt overwhelmed by the crisis atmosphere.
       Q. Did anybody ever suggest who is Monica Lewinsky, go find 
     out about who she is and what she does?
       A. No.
       Q. So is it your testimony that this accusation comes out 
     on January 21st, and the accusation being that a White House 
     intern has an inappropriate relationship with the President, 
     filed a false affidavit on his behalf, and nobody at this 
     meeting suggested let's find out who Monica Lewinsky is and 
     what's going on here?
       A. Well, I wasn't referring to any meeting, but in any of 
     my discussions with members of the White House staff, nobody 
     discussed Monica Lewinsky's personal life or decided that we 
     had to find out who she was.
       Q. Could I turn you now to Tab 15, please? Okay.
       MR. McDANIEL: Would you like him to read this?
       MR. GRAHAM: Yes. Yes, please. Just take your time. And I am 
     now referring to an AP story by Karen G-u-l-l-o. I don't want 
     to mispronounce her name.
       [Witness perusing document.]
       THE WITNESS: I'm ready, Congressman.
       BY MR. GRAHAM:
       Q. Thank you.
       And this article--do you know this reporter, by any chance?
       A. I do know this reporter, but I did not know this 
     reporter on January 30th.
       Q. All right. Do you subsequently know--
       A. Some months later, I met this reporter.
       Q. And the basic essence of my question, Mr. Blumenthal, 
     will be this report indicates some derogatory information 
     about Ms. Lewinsky, and it also has some statements by White 
     House Press Secretary and Ms. Lewis. And I want to ask how 
     those two statements go together.
       This report indicates that a White House aide called this 
     reporter to suggest that Ms. Lewinsky's past included weight 
     problems, and she was called ``The Stalker.'' And it says 
     that ``Junior staff members, speaking on condition that they 
     not be identified, said she was known as a flirt, wore her 
     skirts too short, was `` `a little bit weird'.'' And the next 
     paragraph says: ``Little by little, ever since the 
     allegations of an affair between President Clinton and Ms. 
     Lewinsky surfaced 10 days ago, White House sources have waged 
     a behind-the-scenes campaign to portray her as an 
     untrustworthy climber obsessed with the President.''
       Do you have any direct knowledge or indirect knowledge that 
     such a campaign by White House aides or junior staff members 
     ever existed?
       A. No.
       Q. Okay. Do you ever remember hearing Ms. Lewis or Mr. 
     McCurry admonishing anyone in the White House about ``watch 
     what you say about Ms. Lewinsky''?
       A. No. I don't recall those incidents described in this 
     article, but I do note that among senior advisors at one of 
     the meetings that we held--it could have been in the morning 
     or late afternoon--we felt very firmly that nobody should 
     ever be a source to a reporter about a story about Monica 
     Lewinsky's personal life, and I strongly agreed with that and 
     that's what we decided.
       Q. When did that meeting occur?
       A. I'd say within a week of the story breaking.
       Q. Who was at that meeting?
       A. I don't recall exactly, but I would say that the list of 
     names that I mentioned before.
       Q. And that would be?
       A. I may not get them all, but I would say Chuck Ruff, 
     Cheryl Mills, Bruce Lindsey, Lanny Breuer, Jim Kennedy, Mike 
     McCurry, Joe Lockhart, Adam Goldberg, Don Goldberg, Ann 
     Lewis, Paul Begala, Rahm Emanuel, myself.
       Q. And this occurred about a week after the January 21st 
     article?
       A. I don't recall the exact date.
       Q. At least 7 days?
       A. Within a week--
       Q. Okay.
       A. --I believe.
       Q. Would it be fair to say that you were sitting there 
     during this conversation and that you had previously been 
     told by the President that he was in essence a victim of Ms. 
     Lewinsky's sexual demands, and you said nothing to anyone?
       MR. McDANIEL: Is the question, ``You said''--
       THE WITNESS: I don't--
       MR. McDANIEL: Is the question, ``You said nothing to anyone 
     about what the President told you?''?
       MR. GRAHAM: Right.
       THE WITNESS: I never told any of my colleagues about what 
     the President told me.
       BY MR. GRAHAM:
       Q. And this is after the President recants his story--
     recounts his story--to you, where he's visibly upset, feels 
     like he's a victim, that he associates himself with a 
     character who's being lied about, and you at no time 
     suggested to your colleagues that there is something going on 
     here with the President and Ms. Lewinsky you need to know 
     about. Is that your testimony?
       A. I never mentioned my conversation. I regarded that 
     conversation as a private conversation in confidence, and I 
     didn't mention it to my colleagues, I didn't mention it to my 
     friends, I didn't mention it to my family, besides my wife.
       Q. Did you mention it to any White House lawyers?
       A. I mentioned it many months later to Lanny Breuer in 
     preparation for one of my grand jury appearances, when I knew 
     I would be questioned about it. And I certainly never 
     mentioned it to any reporter.
       Q. Do you know how, over a period of weeks, stories about 
     Ms. Lewinsky being called a stalker, a fantasizer, obsessed 
     with the President, called the name ``Elvira''--do you know 
     how that got into the press?
       A. Which--which--which question are you asking me? Which 
     part of that?
       Q. Okay. Do you have any idea how White House sources are 
     associated with statements such as ``She's known as 
     `Elvira','' ``She's obsessed with the President,'' ``She's 
     known as a flirt,'' ``She's the product of a troubled home, 
     divorced parents,'' ``She's known as `The Stalker'''? Do you 
     have any idea how that got in the press?
       MR. BREUER: I'm going to object. The document speaks for 
     itself, but it's not clear that the terms that Mr. Lindsey 
     has used are necessarily--any or all of them--are from a 
     White House source. I object to the form and the 
     characterization of the question.
       MR. GRAHAM: The ones that I have indicated are associated 
     with the White House as being the source of those statements 
     and--
       SENATOR SPECTER: Senator Edwards and I think that question 
     is appropriate, and the objection is overruled.
       THE WITNESS: I have no idea how anything came to be 
     attributed to a White House source.
       BY MR. GRAHAM:
       Q. Do you know a Mr. Terry Lenzner?
       A. I--I met him once.
       Q. When did you meet him?
       A. I met him outside the grand jury room.
       Q. And who is he?
       A. He's a private investigator.
       Q. And who does he work for?
       A. He works for many clients, including the President.
       Q. Okay. Mr. Blumenthal, I appreciate your candor here.
       Do you know Mr. Harry Evans?
       A. Harold Evans?
       Q. Yes, sir.
       A. Yes, I do.
       Q. Who is Mr. Harold Evans?
       A. Harold Evans is--I don't know his exact title right now. 
     He works for Mort Zuckerman, involving his publications, and 
     he's the husband of my former editor, Tina Brown.
       Q. Has he ever worked for the New York Daily News?
       MR. BREUER: I'm going to object to this line of 
     questioning. It seems well beyond the scope of this 
     deposition. I have never heard of Mr. Harold Evans, and it's 
     not clear to me that's anywhere in this voluminous record or 
     any of these issues.
       SENATOR SPECTER: Senator Edwards and I think it would be 
     appropriate to have an offer of proof on this, Congressman 
     Graham.
       MR. GRAHAM: I'm going to ask Mr. Blumenthal if he has ever 
     at any time passed on to Mr. Evans or anyone else raw notes, 
     notes, work products from a Mr. Terry Lenzner about subjects 
     of White House investigations to members of the press, to 
     include Ms. Lewinsky.
       SENATOR SPECTER: Relating to Monica Lewinsky?
       MR. GRAHAM: Yes, and anyone else.
       MR. McDANIEL: That's a good question. I think we don't have 
     any objection to that question.
       SENATOR SPECTER: Well, we still have to rule on it. 
     Overruled. The objection is overruled.
       MR. GRAHAM: All right. Now I think I know the answer.
       [Laughter.]
       BY MR. GRAHAM:
       Q. So let's phrase it very clearly for the record here. You 
     know Mr. Evans; correct?
       A. I do.
       Q. Have you at any time received any notes, work product 
     from a Mr. Terry Lenzner about anybody?

[[Page 1872]]

       A. No.
       Q. Okay. So, therefore, you had nothing to pass on?
       A. Right.
       Q. Fair enough. Do you know a Mr. Gene Lyons?
       A. Yes, I do.
       Q. Who is Mr. Gene Lyons?
       A. He is a columnist for the Arkansas Democrat Gazette.
       Q. Are you familiar with his appearance on ``Meet the 
     Press'' where he suggests in an article he wrote later that 
     maybe the President is a victim similar to David Letterman in 
     terms of somebody following him around, obsessed with him?
       A. Is this one of the exhibits?
       Q. Yes, sir.
       A. I wonder if you could refer me to it.
       Q. Sure. I can't read my writing.
       BY MR. GRAHAM:
       Q. Well, while we are looking for the exhibit, let me ask 
     you this. Do you have any independent knowledge of him making 
     such a statement?
       A. Well, I'd like to see the exhibit so--
       Q. Okay.
       A. --so I could know exactly what he said.
       Q. Okay.
       MR. McDANIEL: If I might--Congressman, I don't know whether 
     the one you're thinking of is--I note in Exhibit 20, there 
     are--well, it's not a story by Mr. Lyons--
       MR. GRAHAM: And that's it.
       MR. McDANIEL: There are references to him in--in that 
     story.
       MR. GRAHAM: That's it. Thank you very much.
       MR. McDANIEL: You're welcome.
       MR. GRAHAM: I appreciate it.
       THE WITNESS: This is 20?
       BY MR. GRAHAM:
       Q. Yes, sir.
       A. Thank you.
       Do you mind if I just read through it?
       Q. Yes, sir. Take your time.
       A. Thank you. [Witness perusing document.] I've read this.
       Q. My question is that this article is a Boston Globe 
     article, Saturday, February the 21st, and it references an 
     appearance on ``Meet the Press'' by Mr. Gene Lyons. And I 
     believe you know who Mr. Gene Lyons is; is that correct?
       A. I do.
       Q. Did you know who he was in January of 1998?
       A. I did.
       Q. And in this press appearance, it refers to it being the 
     Sunday before the Saturday, February 21st, sometime in the 
     middle of February.
       He indicates on the show, at least this article recounts 
     that he indicates, that the President could be in fact in ``a 
     totally innocent relationship in which the President was, in 
     a sense, the victim of someone, rather like the woman who 
     followed David Letterman around.''
       Do you know how Mr. Lyons would come to that conclusion? I 
     know word travels fast, but how would he know that? Do you 
     have any independent knowledge of how he would know that?
       A. What exactly is the question?
       Q. Well, the question is Mr. Lyons is indicating in the 
     middle of February that the truth of the matter may very well 
     be that the President is in an ``innocent relationship in 
     which the President was, in a sense, the victim of someone, 
     rather like the woman who followed David Letterman around,'' 
     and the question is that scenario of the President being a 
     victim of someone obsessed seems rather like the conversation 
     you had with the President on January the 21st. Do you know 
     how Mr. Lyons would have had that take on things?
       MR. McDANIEL: Well, I object to a question that sort of 
     loads up premises, Senators. That question sort of, you know, 
     says, well, this conversation is a lot like the one you had 
     with the President, and then asks the question. And the 
     danger to the witness is that he'll--by answering the 
     question accepts the premise.
       And I ask that if you want to ask him whether it's like the 
     conversation with the President, that's a fair question, 
     he'll answer it, but it ought to be broken out of there.
       [Senators Specter and Edwards conferring.]
       SENATOR SPECTER: Senator Edwards and I disagree on the 
     ruling, so we're going to take Senator Edwards and ask you to 
     rephrase the question since it--
       [Laughter.]
       MR. GRAHAM: Fair enough.
       BY MR. GRAHAM:
       Q. The characterization embodied here indicates this could 
     be a totally innocent relationship in which the President was 
     in a sense the victim of someone. Is it fair to say, Mr. 
     Blumenthal, that is very much like the scenario the President 
     painted to you when you talked with him on January the 21st?
       A. It could be like that.
       Q. Okay. And it goes on further: ``rather like the woman 
     who followed David Letterman around.'' Is that very much like 
     the characterization the President indicated to you between 
     him and Ms. Lewinsky?
       A. Could be.
       Q. Did you ever at any time talk with Mr. Gene Lyons about 
     Ms. Lewinsky or any other person that was the subject of a 
     relationship with the President?
       A. I did talk to Gene Lyons about Monica Lewinsky.
       Q. Could you tell us what you told him?
       A. He asked me my views, and I told him, in no uncertain 
     terms, that I wouldn't talk about her personally. I talked 
     about Monica Lewinsky with all sorts of people, my mother, my 
     friends, about what was in the news stories every day, just 
     like everyone else, but when it came to talking about her 
     personally, I drew a line.
       Q. So, when you talk to your mother and your friends and 
     Mr. Lyons about Ms. Lewinsky, are you telling us that you 
     have these conversations, and you know what the President has 
     told you and you're not tempted to tell somebody the 
     President is a victim of this lady, out of his own mouth?
       A. Not only am I not tempted, I did not.
       Q. You don't know how all this information came out? You 
     have no knowledge of it at all?
       MR. McDANIEL: I don't understand the question about--
       MR. GRAHAM: About her being a stalker, her being obsessed 
     with the President, the President being like David Letterman 
     in relationship to her.
       BY MR. GRAHAM:
       Q. You had no knowledge of how that all happened in the 
     press?
       A. I have an idea how it started in the press.
       Q. Well, please share that with us.
       A. I believe it started on January 21st with the 
     publication of an article in Newsweek by Michael Isikoff that 
     was posted on the World Wide Web and faxed around to everyone 
     in the news media, in Washington, New York, everywhere, and 
     in the White House. And in that article, Michael Isikoff 
     reported the contents of what became known as the talking 
     points.
       And there was a mystery at the time about who wrote the 
     talking points. We know subsequently that Monica Lewinsky 
     wrote the talking points. And in that document, the author of 
     the talking points advises Linda Tripp that she might refer 
     to someone who was stalking the ``P'', meaning the President, 
     and after that story appeared, I believe there were a flood 
     of stories and discussions about this, starting on 
     ``Nightline'' that very night and ``Nightline'' the next 
     night and so on. And that's my understanding from observing 
     the media of how this started.
       Q. How long have you been involved in the media yourself?
       A. Before I joined the White House staff, I was a 
     journalist for 27 years.
       Q. Is it your testimony that the Isikoff article on the 
     21st explains how White House sources contact reporters in 
     late January and mid-February trying to explain that the 
     President is a victim of a stalker, an obsessed young lady, 
     who is the product of a broken home? Is that your testimony?
       A. No.
       MR. BREUER: I'm going to object to the form of the 
     question. There is no evidence that White House officials, 
     both in January and in February, if at any time, contacted 
     sources, press sources.
       MR. GRAHAM: I will introduce these articles. The articles 
     are dated with White House sources, unsolicited, calling 
     about this event, saying these things in January and 
     February.
       MR. BREUER: Well--
       SENATOR SPECTER: Senator Edwards and I agree that the 
     question may be asked and answered. Overruled.
       THE WITNESS: If you could restate it, please?
       BY MR. GRAHAM:
       Q. Is it your testimony that the White House sources that 
     are being referred to by the press are a result of the 21st 
     of January Isikoff article? That's not what you're saying, is 
     it?
       A. No.
       MR. McDANIEL: Well--
       MR. GRAHAM: Thank you.
       MR. McDANIEL: --I don't think that there ought to be 
     argument with Mr. Blumenthal. I think he ought to be asked a 
     question and given an opportunity to answer it, and that's an 
     argumentative question and followed up by, ``That's not what 
     you're saying, is it?''
       I also think the questions are remarkably imprecise, in 
     that they do not specify what information it is this 
     questioner is seeking to get Mr. Blumenthal to talk about, 
     and in that regard, I think the questions are both irrelevant 
     and unfair.
       SENATOR EDWARDS: Are you objecting to a question that's 
     already been asked and answered?
       MR. McDANIEL: I might be, Senator, and I had that feeling 
     when I heard Mr. Blumenthal say something, that I might be 
     doing that.
       MR. GRAHAM: That would be my reply. He understood what I 
     asked, and he answered, and I'll accept his answer and we'll 
     move on.
       SENATOR SPECTER: Well, I think the objection is mooted at 
     this point.
       MR. GRAHAM: Okay.
       SENATOR SPECTER: I do--I do think that to the extent you 
     can be more precise, because these articles do contain--
       MR. GRAHAM: Yes, sir.
       SENATOR SPECTER: --a lot of information. We're still 
     looking for that laser.
       MR. GRAHAM: Yes, sir.
       BY MR. GRAHAM:
       Q. And these--and the reason this comes up, Mr. Isikoff--
     excuse me--Mr. Blumenthal,

[[Page 1873]]

     is you've referenced the Isikoff article on the 21st, and my 
     question goes to White House sources indicating that Ms. 
     Lewinsky is a stalker, the January 30th article, that she's 
     obsessed with the President, that she wears tight skirts.
       What I'm trying to say is that you--you are not saying--it 
     is not your testimony--that those White House sources are 
     picking up on the 21st article, are you?
       A. I don't know about any White House sources on these 
     stories.
       Q. When you talked to Mr. Lyons, you never mentioned what 
     time at all that Ms. Lewinsky was making demands on the 
     President and he had to rebuff her?
       A. Absolutely not.
       Q. You never at one time told Mr. Lyons or anyone else that 
     the President felt like that he was a victim much like the 
     person in the novel, Darkness at Noon?
       MR. McDANIEL: Well, I object to that question. This witness 
     has testified that he told his wife and that he told White 
     House counsel at a later date, and the question included 
     anyone else. So I think it--
       MR. GRAHAM: Yes. Strike that.
       BY MR. GRAHAM:
       Q. Excluding those two people?
       A. Well, I believe I've asked--I've been asked, and 
     answered that, and I haven't told anyone else.
       Q. Was there--
       A. I didn't tell anyone else.
       Q. Was there ever an investigation at the White House about 
     how these stories came out, supposedly?
       A. No.
       Q. Was anybody ever fired?
       A. No.
       MR. GRAHAM: Thank you, Mr. Blumenthal.
       THE WITNESS: I thank you.
       MR. ROGAN: No further questions.
       MR. BREUER: Could we take a 5-minute break, Senator?
       SENATOR SPECTER: We can. We will recess for 5 minutes.
       THE VIDEOGRAPHER: We are going off the record at 11:24 a.m.
       [Recess.]
       THE VIDEOGRAPHER: We're going on the record at 11:40 a.m.
       SENATOR SPECTER: Turn to White House counsel, Mr. Lanny 
     Breuer.
       MR. BREUER: Senators, the White House has no questions for 
     Mr. Blumenthal.
       SENATOR SPECTER: We had deferred one line of questions 
     which had been subject objection and considerable conference, 
     and we put it at the end of the transcript so it could be 
     excised. Do you wish to--
       MR. GRAHAM: Yes.
       SENATOR SPECTER: --proceed further?
       MR. BREUER: May we approach off the record, Senators?
       SENATOR SPECTER: Off the record.
       THE VIDEOGRAPHER: We're going off the record at 11:41 a.m.
       [Discussion off the record.]
       THE VIDEOGRAPHER: We are going back on the record at 12:10 
     p.m.
       SENATOR SPECTER: The Senators have considered the matter, 
     and in light of the references, albeit abbreviated, in the 
     record and the generalization that answers--questions and 
     answers would be permitted, reserving the final judgment to 
     the full Senate, we will permit Congressman Graham to 
     question on pattern and practice with respect to Ms. Willey.
       MR. GRAHAM: Okay. Thank you.


                 FURTHER EXAMINATION BY HOUSE MANAGERS

       BY MR. GRAHAM:
       Q. Mr. Blumenthal, we're really close to the end here. If 
     you could turn to Tab 5, page 193.
       A. We have it.
       Q. Okay, thank you.
       And page 20, the last question, it's in the right-hand 
     corner. I'll read the question, and we'll kind of follow the 
     testimony. ``Have you ever had a discussion with people in 
     the White House or been present during any meeting where the 
     allegation has come up that other women are fabricating an 
     affair with the President?''
       Now, could you read the answer for me, please?
       A. Sure. My--my answer in the grand jury is this: ``We've 
     discussed news stories that arose out of the Jones case, 
     which was dismissed by the judge as having no basis, in which 
     there were allegations made against the President, and these 
     were stories that were in the press.''
       Q. ``And you''--''And did you discuss those with the 
     President?''
       You said, ``No.''
       And the next question is: ``So what form did you discuss 
     those news stories in?''
       And your answer was?
       A. ``In strategy meetings.''
       Q. Okay. ``And that would include the daily meetings, the 
     morning and the evening meetings?''
       A. Yes.
       Q. And your answer was ``Yes.''
       Now, within that context, I want to walk through a bit how 
     those strategy meetings came about and the purpose of the 
     strategy meetings.
       The next question goes as follows: ``And there were names 
     of the women that you discussed in that context that there 
     had been news stories about and public allegations of an 
     affair with the President?''
       And your answer was?
       A. ``As I recall, we discussed Paula Jones, Kathleen 
     Willey, we've discussed''--and the rest is redacted.
       Q. Redacted--and that's fine, that's fine.
       And the question later on, on line 24: ``When you say that 
     that was a complete and utter fraudulent allegation--'', the 
     answer is: ``In my view, yes.'' Right?
       A. Well--
       Q. About a woman?
       MR. McDANIEL: Senator, I must object to this, because I 
     believe that question, clearly from the context, refers to 
     redacted material--
       MR. GRAHAM: Right.
       MR. McDANIEL: --which has been preserved as secret by the 
     grand jury, and I think it's somewhat misleading to talk 
     about a fraudulent allegation that the grand jury heard that 
     Mr. Blumenthal testified about, which is clearly not in the 
     record before the Senate.
       SENATOR SPECTER: Well, it is unclear on the face of the 
     record. So, Congressman Graham, if you could--
       MR. GRAHAM: The point I'm trying--
       SENATOR SPECTER: --excuse me, let me just finish--
       MR. GRAHAM: Yes.
       SENATOR SPECTER: --if you could specify on what is on the 
     record that you've put in up to now.
       MR. GRAHAM: Okay. What I'm reading from, Senator, is--is a 
     question and answer and a redacted name, and the point I'm 
     trying to make is over who that person was, the allegation 
     was considered to be fraudulent based on your prior 
     testimony.
       THE WITNESS: That was--that was my testimony, that it was 
     my view.
       BY MR. GRAHAM:
       Q. And that leads to this question. Was there ever a 
     discussion in these strategy meetings where there was an 
     admission that the allegation was believed to be true against 
     the President in terms of relationship with other women?
       MR. BREUER: I'm going to object to the form of the question 
     in that it's referring to other women. Even based on the 
     discussion that went off the record, I think that what Mr. 
     Graham is doing now is certainly beyond any record in this 
     case.
       SENATOR SPECTER: Senator Edwards would like to hear the 
     question repeated.
       MR. GRAHAM: The strategy meetings--
       SENATOR SPECTER: Good idea?
       MR. GRAHAM: Yes, sir.
       BY MR. GRAHAM:
       Q. The strategy meetings involved press accounts of 
     allegations between the President and other women. The 
     question is very simple. At any of those meetings, was it 
     ever conceded that the President did have in fact a 
     relationship?
       MR. BREUER: Object. I object to the question for the 
     reasons I just previously stated.
       SENATOR SPECTER: Senator Edwards raises the concern that I 
     think he's correct on, that we have limited it to Willey, Ms. 
     Willey. So, if you would--if you would focus--
       MR. GRAHAM: Absolutely.
       SENATOR SPECTER: --there--
       MR. GRAHAM: Absolutely.
       SENATOR SPECTER: --it would be within your proffer and what 
     we have permitted.
       MR. GRAHAM: Yes, sir. Very well.
       BY MR. GRAHAM:
       Q. In regards to Ms. Willey, is it fair to say that the 
     consensus of the group was that these allegations were not 
     true?
       A. I don't know.
       Q. Do you recall Ms. Willey giving a ``60 Minutes'' 
     interview?
       A. Yes.
       Q. Do you recall any discussions after the interview at a 
     strategy meeting about Ms. Willey?
       MR. BREUER: I want the record to be clear that the White 
     House has a continuing objection as to this line of inquiry.
       SENATOR SPECTER: The record will so note.
       THE WITNESS: If you could repeat the question, please.
       MR. GRAHAM: Yes.
       THE WITNESS: Sorry.
       BY MR. GRAHAM:
       Q. After the ``60 Minutes'' interview, was there ever a 
     strategy meeting about what she said?
       A. At one of the morning or evening meetings, we discussed 
     the ``60 Minutes'' interview.
       Q. And can you--I--I know it's hard because these meetings 
     go on a lot. How--do you know who was there on that occasion, 
     who would be the players that would be there?
       A. They would be the same as before. I'd be happy to 
     enumerate them for you, if you want me to.
       Q. But the same as you previously testified to?
       A. Yes.
       Q. Okay, that's fine.
       Do you recall what the discussions were about in terms of 
     how to respond to the ``60 Minutes'' story?
       A. Yes.
       Q. Could you tell us?
       A. They were what our official spokes-people would say.

[[Page 1874]]

       Q. Did they include anything else?
       A. Yes.
       Q. Could you please tell us?
       A. There was a considerable complaining about how, in the 
     ``60 Minutes'' broadcast, Bob Bennett was not given adequate 
     time to speak and present his case, and how he was, as I 
     recall, poorly lighted.
       Q. Was there any discussion about what Ms. Willey said 
     herself and how that should be responded to?
       A. I don't recall exactly. We just spoke about what our 
     official spokespeople should respond to.
       Q. Did anybody ever discuss the fact that Ms. Willey may 
     have had a checkered past?
       A. No, absolutely not. We never discussed the personal 
     lives of any woman in those meetings.
       Q. Did it ever come up as to, well, here's what we know 
     about Kathleen Willey and the President, or let's go see what 
     we can find out about Kathleen Willey and the President?
       A. No.
       Q. Who had the letters that Kathleen Willey wrote to the 
     President?
       A. I don't know exactly. The White House had them.
       Q. Isn't it fair to say that somebody found those letters, 
     kept those letters, and was ready to respond with those 
     letters, if needed to be?
       MR. BREUER: I'm going to object to the form of the question 
     that it's outside the proffer of the Manager.
       [Senators Specter and Edwards conferring.]
       MR. McDANIEL: Yes. I object to the compound nature of the 
     question, and--
       SENATOR SPECTER: Could you rephrase the question, 
     Congressman Lindsey--
       MR. GRAHAM: Yes, sir.
       SENATOR SPECTER: --or, Graham?
       MR. GRAHAM: Yes, sir.
       SENATOR SPECTER: I think that would solve your problem.
       BY MR. GRAHAM:
       Q. There were letters written to Ms. Willey to the 
     President that were released to the media. Is that correct?
       A. Yes.
       Q. Do you know who gathered those letters up and how they 
     were gathered up?
       MR. BREUER: Objection.
       SENATOR SPECTER: Senator Edwards and I agree that the 
     Congressman may ask the question. Overruled.
       THE WITNESS: No.
       BY MR. GRAHAM:
       Q. Would it be fair to say, using common sense, that 
     somebody was planning to answer Ms. Willey by having those 
     letters to offer to the press?
       MR. BREUER: Objection.
       MR. McDANIEL: It's argumentative.
       MR. BREUER: It certainly is.
       SENATOR SPECTER: Would you repeat that question?
       BY MR. GRAHAM:
       Q. The question is: Mr. Blumenthal, do you believe it's a 
     fair assumption to make that somebody in the White House made 
     a conscious effort to go seek out the letters between the 
     President and Ms. Willey and use in response to her 
     allegations?
       [Senators Specter and Edwards conferring.]
       THE WITNESS: Well, that's an opin--
       MS. MARSH: Wait, wait, wait.
       MR. McDANIEL: Please, Mr. Blumenthal.
       THE WITNESS: Yes.
       SENATOR SPECTER: Senator Edwards says, and I agree with 
     him, that you ought to direct it to somebody with specific 
     knowledge so you don't--
       BY MR. GRAHAM:
       Q. Do you have any knowledge--
       SENATOR SPECTER: --deal totally with speculation.
       BY MR. GRAHAM:
       Q. Do you have any specific knowledge of that event 
     occurring, somebody gathering the letters up, having them 
     ready to be able to respond to Ms. Willey if she ever said 
     anything?
       A. No.
       Q. You have no knowledge whatsoever of how those letters 
     came into the possession of the White House to be released to 
     the press?
       A. No, I don't. I don't know--
       MR. GRAHAM: Thank you. I--
       THE WITNESS: --who had them--
       MR. GRAHAM: --don't have any--
       THE WITNESS: --in the White House.
       MR. GRAHAM: --further questions.

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