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Transcripts from video deposition of Lewinsky, Jordan, and Blumenthal
[Congressional Record: February 4, 1999 (Senate)]
[Page S1199-S1254]
From the Congressional Record Online via GPO Access
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 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?
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.
[[Page S1213]]
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. 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.
[[Page S1214]]
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.
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. 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,
[[Page S1215]]
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.
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?
[[Page S1216]]
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
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?
[[Page S1217]]
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?
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--
[[Page S1218]]
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.
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
[[Page S1219]]
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?
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
[[Page S1220]]
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 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--
[[Page S1221]]
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.
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--
[[Page S1222]]
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 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.
[[Page S1223]]
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?
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.
[[Page S1224]]
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.]
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
[[Page S1225]]
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 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.
[[Page S1226]]
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.
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
[[Page S1227]]
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?
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--
[[Page S1228]]
and I notice you--you now carve out an exception to that by
saying you didn't have 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, 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
[[Page S1229]]
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 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.
[[Page S1230]]
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 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.
[[Page S1231]]
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?
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
[[Page S1232]]
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.
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.
[[Page S1233]]
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 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.
[[Page S1234]]
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.
[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.
[[Page S1235]]
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.
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
[[Page S1236]]
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 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.
[[Page S1237]]
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 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
[[Page S1238]]
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.
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
[[Page S1239]]
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.
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.
[[Page S1240]]
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?
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?
[[Page S1241]]
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.
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
[[Page S1242]]
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?
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?
[[Page S1243]]
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?
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.
[[Page S1244]]
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.
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
[[Page S1245]]
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.
[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
[[Page S1246]]
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.
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?
[[Page S1247]]
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 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.
[[Page S1248]]
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 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.
[[Page S1249]]
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?
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
mischaracterization 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?
[[Page S1250]]
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 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.
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?
[[Page S1251]]
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?
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.
[[Page S1252]]
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, 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.
[[Page S1253]]
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 ever 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.
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.
[[Page S1254]]
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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MORE STORIES:Friday, February 5, 1999
• Transcript highlights from the witness depositions • Bipartisan group moves to open Senate deliberations • Straw poll focuses attention on potential women candidates • Secret Service concerned over Chelsea Clinton cover story • GOP told to develop post-impeachment message • Starr lawyers discuss impeachment • President to establish race relations office • Is Chelsea Clinton a valid journalistic subject? | ||||||||||||||||||||||||||||
