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

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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?

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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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