Transcripts from video deposition of Vernon E. Jordan, Jr.
Also read:
(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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Friday, February 5, 1999
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