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

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Q. Right.

A. Yes, that's correct.

Q. And you admitted in that answer to that question that the conduct that you were involved in, the encounter of November the 15th, 1995, fit within that definition of "sexual relations"?

A. The second encounter of that evening did.

Q. Right. And were there other similar encounters later on with the President, not that day, but other occasions that would have likewise fit into that definition of "sexual relations" in the Paula Jones case?

A. Yes. And--yes.

Q. There was more than one occasion where that occurred?

A. Correct.

Q. So, if the President testifies that he did not--he was not guilty of having a sexual relationship under the Paula Jones definition even, then that testimony is not truthful, is it?

MR. CACHERIS: Objection. She should not be called upon to testify what was in the mind of another person. She's testifying to the facts, and she has given the facts.

MR. BRYANT: I would ask that she answer the question.

SENATOR DeWINE: Go ahead.

SENATOR LEAHY: The objection is noted for the record.

SENATOR DeWINE: The objection is noted. She may answer the question.

THE WITNESS: I--I really--

SENATOR LEAHY: If she can.

THE WITNESS: --don't feel comfortable characterizing whether what he said was truthful or not truthful. I know I've testified to what I believe is true.

BY MR. BRYANT:

Q. Well, truth is not a wandering standard.

A. Well--

Q. I would hope not. But you have testified, as I've told you, that what you and he did together on November the 15th, 1995 fit that definition of the Paula Jones, and you've indicated that there were other occasions that likewise--

A. Yes, sir.

Q. --that that occurred. But now the President has indicated as a part of his specific defense--he has filed an answer with this Senate denying that this occurred, that he did these actions.

A. I know. I'm not trying to be difficult, but there is a portion of that definition that says, you know, with intent, and I don't feel comfortable characterizing what someone else's intent was. I can tell you that I--my memory of this relationship and what I remember happened fell within that definition. If you want to--I don't know if there's another way to phrase that, but I'm just not comfortable commenting on someone else's intent or state of mind or what they thought.

Q. Let's move forward to December the 19th, 1997, at that point you made reference to earlier.

A. I'm sorry. Can you repeat the date again? I'm sorry.

Q. Yes. December the 19th, 1997.

A. Okay, sorry.

Q. At that point where you testified that you received a subpoena in the Paula Jones case, and that was, of course, on December the 19th, 1997. Do you recall the specific time of day and where you were when you were served with the subpoena?

A. I was actually handed the subpoena at the Metro entrance of the Pentagon--at the Pentagon, and the time--I think it was around 4:30--4--I--I--if I've testified to something different, then, I accept whatever I testified to, closer to the date. Sometime in the late afternoon.

Q. Did they call you, and you had to come out of your office and go outside--

A. Correct.

Q. --and do that? Okay. And what did you do after you accepted service of the subpoena?

A. I started crying.

Q. Did he just give it to you and walk away, or did he give you any kind of explanation?

A. I think I made a stink. I think I was trying to hope that he would convey to the Paula Jones attorneys that I didn't know why they were doing this, and this is ridiculous, and he said something or another, there is a check here for witness fee. And I said I don't want their stinking money, and so--

Q. What did you do after, after you got through the emotional part?

A. I went to a pay phone, and I called Mr. Jordan.

Q. Any reason you went to a pay phone, and why did you call Mr. Jordan? Two questions, please.

A. First is because my office in the Pentagon was probably a room this size and has--let's see, one, two, three, four-- four other people in it, and there wasn't much privacy. So that I think that's obvious why I wouldn't want to discuss it there. And the second question was why Mr. Jordan--

Q. Why did you call Mr. Jordan; yes.

A. Because I couldn't call Mrs. Currie because it was--I hadn't expected to be subpoenaed that soon. So she was grieving with her brother's passing away, and I didn't know who else to turn to. So--

Q. And what--what occurred with that conversation with Mr. Jordan?

A. Well, I remember that--that he couldn't understand me because I was crying. So he kept saying: "I don't understand what you're saying. I don't understand what you're saying." And I just was crying and crying and crying. And so all I remember him saying was: "Oh, just come here at 5 o'clock." So I did.

Q. You went to see Mr. Jordan, and you were inside his office after 5 o'clock, and you did--is that correct?

A. Yes.

Q. Were--were you interrupted, in the office?

A. Yes. He received a phone call.

Q. And you testified that you didn't know who that was that called?

A. Correct.

Q. Did you excuse yourself?

A. Yes.

Q. What--after you came back in, what--what occurred? Did he tell you who he had been talking to?

A. No.

Q. Okay. What happened next?

A. I know I've testified about this--

Q. Yes.

A. --so I stand by that testimony, and my recollection right now is when I came back in the room, I think shortly after he had placed a phone call to--to Mr. Carter's office, and told me to come to his office at 10:30 Monday morning.

Q. Did you know who Mr. Carter was?

A. No.

Q. Did Mr. Jordan tell you who he was?

A. No--I don't remember.

Q. Did you understand he was going to be your attorney?

A. Yes.

Q. Did you express any concerns about the--the subpoena?

A. I think that happened before the phone call came.

Q. Okay, but did you express concerns about the subpoena?

A. Yes, yes.

Q. And what were those concerns?

A. In general, I think I was just concerned about being dragged into this, and I was concerned because the subpoena had called for a hatpin, that I turn over a hatpin, and that was an alarm to me.

Q. How--in what sense was it--in what sense was it an alarm to you?

A. The hatpin being on the subpoena was evidence to me that someone had given that information to the Paula Jones people.

Q. What did Mr. Jordan say about the subpoena?

A. That it was standard.

Q. Did he have any--did he have any comment about the specificity of the hatpin?

A. No.

Q. And did you--

A. He just kept telling me to calm down.

Q. Did you raise that concern with Mr. Jordan?

A. I don't remember if--if I've testified to it, then yes. If--I don't remember right now.

Q. Did--would you have remembered then if he made any comment or answer about the hatpin?

A. I mean, I think I would.

Q. And you don't remember?

A. I--I remember him saying something that it was--you know, calm down, it's a standard subpoena or vanilla subpoena, something like that.

Q. Did you ask Mr. Jordan to call the President and advise him of the subpoena?

A. I think so, yes. I asked him to inform the President. I don't know if it was through telephone or not.

Q. And you did that because the President had asked you to make sure you let Betty know that?

A. Well, sure. With Betty not being in the office, I couldn't--there wasn't anyone else that I could call to get through to him.

Q. Did Mr. Jordan say to you when he might see the President next?

A. I believe he said he would see him that evening at a holiday reception.

Q. Did Mr. Jordan during that meeting make an inquiry about the nature of the relationship between you and the President?

A. Yes, he did.

Q. What was that inquiry?

A. I don't remember the exact wording of the questions, but there were two questions, and I think they were something like did you have sex with the President or did he--and if-- or did he ask for it or some--something like that.

Q. Did you--what did you suspect at that point with these questions from Mr. Jordan in terms of did he know or not know about this?

A. Well, I wasn't really sure. I mean, two things. I think there is--I know I've testified to this, that there was another component to all of this being Linda Tripp and her-- what she might have led me to believe or led me to think and how that might have characterized how I was perceiving the situation. I--I sort of felt that I didn't know if he was asking me as what are you going to say because I--I don't know these answer to these questions, or he was asking me as I know the answer to these questions and what are you going to say. So, either way, for me, the answer was no and no.

Q. And that's just what I wanted to ask you--you did answer no to both of those, but--

A. Yes.

Q. --as you explained--you didn't mention this directly, but you mentioned in some of your earlier testimony about it, that this was kind of a wink and--you thought this might be a wink-and-nod conversation, where he really knew what was going on, but--

[[Page S1222]]

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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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