Jump to the start of individual depositions: Lewinsky, Jordan, Blumenthal

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Q. So you're saying that that information is accurate, and it is truthful?

A. Yes.

Q. Well, thank you. That--that will save us a little bit of time, but certainly we will ask you some of that information also. At some point, you were transferred to the Pentagon, to the Department of Defense. When did that occur?

A. I found out I was being transferred on April 5th, 1996.

Q. Did you want to go--

A. No.

Q. --to the Department of Defense? Did you have a discussion with the President about this?

A. Yes.

Q. What was your reaction to being transferred?

A. I started to cry.

Q. Did you talk to anyone else at the White House other than the President about the transfer at that time?

A. Yes.

Q. And who--who was that?

A. I spoke with several people. I--I can't--I know I--I spoke with, uh, Jocelyn about it. I spoke with people with whom I was friendly at the White House. I spoke to Betty, Nancy Hernreich, several people.

Q. Did you--did you find out why you were being transferred?

A. Uh, I was told why I was being transferred by Mr. Keating on Friday, the 5th of April.

Q. And that was why?

A. Uh, he said that the--the Office of Administration, I think it was, was not pleased with the way the correspondence was being handled, and they were, quote-unquote, "blowing up" the Correspondence Office, and that I was being transferred and it had nothing to do with my work.

Q. Did you have any understanding that it might have been other reasons that you were being moved?

A. Not at that point.

Q. Did the--what did the President say about your transfer at that point?

A. He thought it had something to do with our relationship.

Q. What else did he say about--about your transfer, if anything? Did he give you any assurances that you might be back, or--

A. Yes.

Q. Back after what time period?

A. He promised me he'd bring me back after the election.

Q. So this was, again, in early 19--April of 1996, and he was up for reelection--

A. Yes.

Q. --in November of 1996.

A. Yes.

Q. Did you attach any significance to being transferred away before the election and then him assuring you he would bring you back after the election? Did you attach any significance to the election and your having to leave?

A. Emotional significance, yes.

Q. Your emotion? I'm--I'm not sure I follow you. You were--

A. Well, yes, I attached significance to it.

Q. And that was emotional--

A. But that was emotional.

Q. But the reason you both felt--again, I'm not trying to put words in your mouth, but you both felt you were leaving until after the election was because of your relationship and perhaps people finding out?

A. No. I--I--first, I can only speak for myself. I mean, I, uh, my understanding initially was that it was, um, for work- related issues, but not my work, and I came to understand later that it was having to do with my relationship with the President.

Q. Okay. Did, uh, you have a conversation--and it may be the same one with the President on April the 12th--which determined that Ms. Lieberman maybe spearheaded your transfer because you were paying too much attention--you were all--you were both paying too much attention to each other and she was worried that it was close to election time? And I think you've testified to that, haven't you?

A. Yes.

Q. Okay, good. You started, uh, with the Department of Defense at the Pentagon in mid-April, April the 17th, 1996?

A. Yes.

Q. What did you do there?

A. I was the confidential assistant to Mr. Bacon, who is the Assistant Secretary of Defense for Public Affairs.

Q. Did, uh--after the 1996 election, did you still want to go back to the White House?

A. Yes.

Q. You had not fallen in love with the job at the Pentagon that much?

A. No.

Q. Was that, in fact, a frustrating period of time?

A. Yes. No offense to Mr. Bacon, of course.

Q. I understand; I'm sure he would take none. I would like--I don't think it's been mentioned, but you helped in preparing a chart which we have listed as one of our exhibits, ML Number 2, which I assume might have a different number for now, but it's a chart of contacts--

A. Right.

Q. --that you had with the President. And do you have a copy of that chart? It-- [Witness conferring with counsel.]

MR. BRYANT: In the--yes, in the record, it's at page 1251. MR. BURTON: May we have an extra copy for counsel, please?

BY MR. BRYANT:

Q. Have you had occasion to review this document?

A. Yes.

Q. And very--very simply, I would like for you to, uh, if you can, to affirm that document as an accurate representation and a truthful representation of all the contacts that you had with the President from approximately August 9th, 1995 until January of 1998. It includes in-person contacts, telephone calls, gifts and notes exchanged, I think are the categories.

A. Yes. I believe there might have been one or two changes that were made and noted in the grand jury or my deposition, and I adopt those as well.

MR. BRYANT: Okay, good. I am not going to at this point make her--the information she adopts and affirms exhibits to this deposition. I don't want to clutter it any more unless someone wants to make this an exhibit in terms of your deposition testimony, your grand jury testimony, and now the charts that you have affirmed, so I just want you to specifically affirm it but not make it an exhibit, because it's already a part of the record.

MR. CACHERIS: We defer to the White House. MS. SELIGMAN: I just wanted to make clear on the record, then, what the app. or sub-cite is of anything we're adopting so that we all know what particular pages it is.

MR. BRYANT: Okay. And that, again, was, I think, page 1251 of--right, of the record.

SENATOR LEAHY: I don't--I don't understand. MS. MILLS: Can you cite the ending page?

SENATOR DeWINE: Counsel, is that where this appears?

MR. BRYANT: It appears in the record, uh--

SENATOR DeWINE: You need to designate also if you're talking about the Senate record or--I think at this point we'll go off the record.

THE VIDEOGRAPHER: We're going off the record at 10:01 a.m. [Recess.]

THE VIDEOGRAPHER: We are going back on the record at 10:11 a.m.

SENATOR DeWINE: Let me--we're now back on the record. Let me advise counsel, the Managers, that they have used 25 minutes so far. You may resume questioning, and if you could begin by identifying the exhibit for the record, please.

MR. BRYANT: Tom, let me also for clarification purposes-- Tom, on the referral to the Senate record, you're saying that the appendices are numbered 3, but the numbers are the same. The page numbers are the same. MR. GRIFFITH: Yes.

MR. BRYANT: And the supplemental materials are your Volume IV, but, again, the pages are the same. MR. GRIFFITH: That's our understanding.

MR. BRYANT: Okay. For the record, then, using the Senate volumes, if this is an appendices, Volume III, and the chart that we just alluded to before the break is--appears at pages 116 through 126 of the Senate record, Volume III.

BY MR. BRYANT:

Q. Ms. Lewinsky, did you tell a number of people in varying details about your relationship with the President?

A. Yes.

Q. you tell us who did you tell?

A. Catherine Allday Davis, Neysa Deman Erbland, Natalie Ungvari, Ashley Raines, Linda Tripp, Dr. Kathy Estep, Dr. Irene Kassorla, Andy Bleiler, my mom, my aunt. Who else has been subpoenaed?

Q. Okay. Let me suggest Dale--did you mention Dale Young?

A. Dale Young. I'm sorry.

Q. Thank you. Now, in the floor presentation, Mr. Craig, who was one of-- is one of the counsel for the President, adopted an argument that had been raised in some of the previous hearings, uh, and he adopted this argument in the Senate that--that you have--have or had, I think, both past and present, the incentive to not tell the truth about how the President--this relationship with him because you wanted to avoid--and again, I use the quote from Mr. Craig's argument--the demeaning nature of providing wholly un-reciprocated sex. Did, uh--did you lie before the grand jury and to your friends about the nature of that relationship with the President--

A. No.

Q. --so as to avoid what Mr. Craig says? Okay, and I'll break it down.

SENATOR DeWINE: Counsel, do you want to just--just rephrase the question?

MR. BRYANT: Okay. We'll break it down into two questions.

BY MR. BRYANT:

Q. Did you not tell the truth before the grand jury as to how the President touched you because of what Mr. Craig alleges as the demeaning nature of the wholly un-reciprocated sex?

MR. CACHERIS: Well, that--may I register an objection, gentlemen? This witness is not here to comment on what some lawyer said on the floor of the Senate. He can ask her direct questions. She will answer them, but what Mr. Craig said or didn't say would have happened after her grand jury testimony. So it's totally inappropriate that he's--

SENATOR DeWINE: Mr. Bryant, why don't you--

MR. CACHERIS: --marrying those two concepts. We object.

SENATOR DeWINE: Mr. Bryant, why don't you just rephrase the question?

MR. BRYANT: Well, we--we have had presented on behalf of the President a defense,

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Friday, February 5, 1999

• Defense, prosecution plot best use of videotapes
• Transcript highlights from the witness depositions
• Bipartisan group moves to open Senate deliberations
• Straw poll focuses attention on potential women candidates
• Secret Service concerned over Chelsea Clinton cover story
• GOP told to develop post-impeachment message
• Starr lawyers discuss impeachment
• President to establish race relations office
• Is Chelsea Clinton a valid journalistic subject?

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