100. Text of President's Address to Nation, reprinted in Washington Post, August 18, 1998, at A5 (emphasis added).

101. Clinton 8/17/98 GJ at 107.

102. Following the President's public admission of an inappropriate relationship, Judge Wright stated sua sponte in an order issued on September 1, 1998: "Although the Court has concerns about the nature of the President's January 17, 1998 deposition testimony given his recent public statements, the Court makes no findings at this time regarding whether the President may be in contempt." Jones v. Clinton, No. LR-C-94-290 (September 1, 1998), Unpublished Order at 7 n.5.

103. Clinton 8/17/98 GJ at 9-10.

104. Id. at 9-10. See also Excerpt from President Clinton's Televised Address to the American People, 8/17/98, reprinted in The Washington Post, at A5 (8/18/98) ("In a deposition in January, I was asked questions about my relationship with Monica Lewinsky. While my answers were legally accurate, I did not volunteer information.").

105. Clinton 8/17/98 GJ at 23-24.

106. Id. at 93.

107. Id. at 110 (emphasis added).

108. Id. at 95-96 (emphasis added).

109. Lewinsky 8/26/98 Depo. at 69.

110. MSL-55-DC-0094; MSL-55-DC-0124.

111. Lewinsky 8/20/98 GJ at 54.

112. Clinton 1/17/98 Depo. at 26 ("If the predicates are met, we have no objection to detail").

113. See, e.g., Ungvari 3/19/98 GJ at 18, 22-24; Erbland 2/12/98 GJ at 23-25.

114. V006-DC-00003737-3744.

115. 827-DC-00000008; 1222-DC-00000156, 1222-DC-0000083-85.

116. Lewinsky 7/30/98 Int. at 6; Lewinsky 8/24/98 Int. at 5.

117. The President contended that he had only one encounter in 1997 with Ms. Lewinsky, whereas she says that there were two. The motive for making a false statement on that issue is less clear, except that perhaps the President wanted to portray the 1997 relationship as an isolated incident.

118. Ms. Jones's attorneys had earlier served President Clinton with a document request that sought documents reflecting "any communications, meetings or visits involving" President Clinton and Ms. Lewinsky. 1414-DC-00001534-46.

119. Throughout the Jones case, Judge Susan Webber Wright ruled that Ms. Jones was entitled to discover information regarding the nature of President Clinton's relationship with government employees, including Monica Lewinsky, a federal employee at the time. See, e.g., 921-DC-00000459-66; 920-DC-00000517-25; 1414-DC-00001006-14; 921-DC-00000736-44; 921-DC-00000751-52; 1414-DC-00001188-92.

120. Clinton 1/17/98 Depo. at 52-53 (emphasis added).

121. Ms. Lewinsky testified that many of her sexual encounters with the President occurred in this windowless hallway. Lewinsky 8/6/96 GJ at 34-36.

122. The President had earlier testified that during the government shutdown in November 1995, Ms. Lewinsky was working as an intern in the Chief of Staff's Office, and had brought the President and others some pizza. Clinton 1/17/98 Depo. at 58.

123. Id. at 58-59 (emphasis added).

124. Id. at 59(emphasis added).

125. Lewinsky 8/6/98 GJ at 20, 52.

126. Lewinsky 8/26/98 Depo. at 22; Lewinsky 8/6/98 GJ at 52-53.

127. Lewinsky 8/6/98 GJ at 76.

128. Id. at 52-53.

129. Id. at 35.

130. Id. at 34-36.

131. Id. at 20.

132. Currie 1/27/98 GJ at 32-33. See also Currie 5/6/98 GJ at 98. The Oval Office area includes the study, dining room, kitchen, bathroom, and hallway connecting the area. See Appendix, Exhibit D (diagram of Oval Office area).

133. Currie 1/27/98 GJ at 34-35 (recalling that after the President's radio address, the President told Ms. Lewinsky he wanted to show her his collection of political buttons and took her into the Oval Office study for 15 to 20 minutes while Ms. Currie waited nearby, in the pantry or the dining room).

134. Currie 1/27/98 GJ at 36-38 (testifying that Ms. Lewinsky came to the White House and met with the President alone for 15 or 20 minutes). See also Currie 5/14/98 GJ at 116.

135. Currie 1/27/98 GJ at 35-36 (testifying that Ms. Lewinsky and the President were in the Oval Office for "[p]erhaps 30 minutes."). Again, Ms. Currie testified that she believes no one else was present. See also Currie 5/6/98 GJ at 103-105.

136. Ferguson 7/17/98 GJ at 23-35 (alone for approximately 45 minutes); Ferguson 7/23/98 GJ at 18-24.(137)

137. Ferguson GJ, July 23, 1998 at 31-32 (testifying that he would have been notified if the President had left the Oval Office area, and he received no such notice).

138. Fox 2/17/98 GJ at 30-38 (alone for approximately 40 minutes).

139. Bordley 8/13/98 GJ at 19-30 (alone for approximately 30 to 35 minutes).

140. Garabito 7/30/98 GJ at 25-32.

141. Byrne 7/30/98 GJ at 7-12, 29-32 (alone for 15 to 25 minutes).

142. Muskett 7/21/98 GJ at 9-13, 22-32 (alone on Easter Sunday 1996).

143. The last date that White House records reflect a visit by Ms. Lewinsky is Sunday, December 28, 1997. 827-DC-00000018; V006-DC-00000009.

144. Maes 4/8/98 GJ at 84-89.

145. Clinton 8/17/98 GJ at 9-10 (emphasis added).

146. Id. at 30-33.

147. Id. at 34.

148. Id. at 54.

149. Clinton 1/17/98 Depo. at 58-59.

150. See id. at 52-53, 59.

151. Clinton 8/17/98 GJ at 118; Lewinsky 8/6/98 GJ at 53-55.

152. In criminal law, a feigned lack of memory is sufficient for a perjury conviction. See, e.g., United States v. Chapin, 515 F.2d 1274 (D.C. Cir. 1975); Behrle v. United States, 100 F.2d 174 (D.C. Cir. 1938).

153. Clinton 1/17/98 Depo. at 75 (emphasis added).

154. Clinton 8/17/98 GJ at 36.

155. Lewinsky 8/6/98 GJ at 27-28, 150-51; GJ Exhibit ML-7.

156. FBI Receipt for Property received, 7/29/98.

157. Lewinsky 8/6/98 GJ at 26-28; GJ Exhibit ML-7.

158. Lewinsky 8/6/98 GJ at 151. Ms. Lewinsky's subpoena directed in part: "Please produce each and every gift including, but not limited to, any and all dresses, accessories, and jewelry, and/or hat pins given to you by, or on behalf of, Defendant Clinton." 902-DC-00000135-38.

159. Lewinsky 8/6/98 GJ at 33, 152. See also Lewinsky 2/1/98 Statement at 7. In fact, Ms. Lewinsky had told Ms. Tripp about it. Ms. Lewinsky had also discussed the hat pin and the subpoena's request for the hat pin with Mr. Jordan. Lewinsky 8/6/98 GJ at 132, 140.

160. Currie 5/6/98 GJ at 142 (relating incident where the President asks Ms. Currie about the hat pin he gave to Ms. Lewinsky). After this criminal investigation started, Ms. Currie turned over a box of items -- including a hat pin -- that had been given to her by Ms. Lewinsky. Ms. Currie understood from Ms. Lewinsky that the box did contain gifts from the President.(161)

161. Ms. Currie confirms the transfer of gifts from Ms. Lewinsky to her. See>Currie GJ testimony, May 6, 1998, at 105-115.   -

162. Ms. Lewinsky testified that the President had given her a gold brooch, and she made near-contemporaneous statements to Ms. Erbland, Ms. Raines, Ms. Ungvari, and Ms. Tripp regarding the gift. Lewinsky 8/6/98 GJ at 26-28; GJ Exhibit ML-7; Erbland 2/12/98 GJ at 41; Raines 1/29/98 GJ at 53-55; Ungvari 3/19/98 GJ at 44; Tripp 7/29/98 GJ at 105.

163. Ms. Lewinsky testified that Leaves of Grass was "the most sentimental gift he had given me."(164)

164. Lewinsky GJ, Aug. 6, 1998, at 156.   -       (165)

165. Davis GJ 30-31; Erbland GJ 40-41; Finerman depo 15-16; Marcia Lewis GJ 2/10/98 at 51-52; Lewis GJ 2/11/98 at 10 ("[S]he liked the book of poetry very much."). Raines GJ 53-55. At the deposition, the President was asked if he had given Ms. Lewinsky a book about Walt Whitman rather than by him. WJC depo at 75-76. - - - - -

166. Lewinsky 8/6/98 GJ at 27; GJ Exhibit ML-7.

167. Lewinsky 8/26/98 Depo. at 15-16; Lewinsky 8/6/98 GJ at 27; GJ Exhibit ML-7; Finerman Depo. 3/18/98 at 13-17; Ungvari 3/19/98 GJ at 43-44.

168. Clinton 1/17/98 Depo. at 76-77 (emphasis added). (169)

169. Clinton 1/17/98 Depo. at 76-77.

170. Lewinsky 8/6/98 GJ at 27-28, GJ Exhibit ML-7; Lewinsky 7/27/98 Int. at 12-14.

171. Lewinsky 8/6/98 GJ at 235-36.

172. Id. at 27, 150; GJ Exhibit ML-7.

173. V002-DC-00000475 (Letter to OIC, 3/16/98).

174. Lewinsky 8/6/98 GJ at 27; GJ Exhibit ML-7. See also Lewinsky 7/27/98 Int. at 14.

175. Lewinsky 8/6/98 GJ at 185.

176. Letter from David Kendall to OIC, August 3, 1998.

177. V002-DC-00000471. Ms. Lewinsky testified that she bought and gave the President that book in early January 1998, and that when she talked to him on January 5, 1998, he acknowledged that he had received the book.(178)

178. Lewinsky 8/6/98 GJ at 189-192. -

179. V002-DC-0000003.

180. Lewinsky 8/6/98 GJ at 27-28, 109; GJ Exhibit ML-7.

181. Id.; Lewinsky 8/6/98 GJ at 26-28; Lewinsky 7/27/98 Int. at 13. The President did not turn over this antique book in response to a subpoena.

182. Lewinsky 8/6/98 GJ at 27-28; GJ Exhibit ML-7. The President did not produce The Notebook in response to a subpoena.

183. Lewinsky 8/6/98 GJ at 27-28, 182-183; GJ Exhibit ML-7. Ms. Lewinsky saw a copy of the book in the President's study in November 1997. Lewinsky 8/6/98 GJ at 183. White House records list Oy Vey and Vox on an October 10, 1997, catalog of books in the West Wing.(184)

184. 1361-DC-00000002 (Catalog of Books in the West Wing Presidential Study as of 10 October 1997). --

185. Lewinsky 8/6/98 GJ at 27-28, 183-84; Lewinsky 7/27/98 Int. at 13; GJ Exhibit ML-7. Ms. Lewinsky testified that she had seen the book in the President's study in November 1997.(186)

186. Lewinsky 8/6/98 GJ at 183-84. -

187. Id. at 27-28, 183-84; Lewinsky 7/27/98 Int. at 12-13; GJ Exhibit ML-7.

188. Lewinsky 8/6/98 GJ at 26-28; GJ Exhibit ML-7.

189. These included a Sherlock Holmes game sometime after Christmas 1996; a golf ball and tees on February 28, 1997; after the President injured his leg in March 1997, a care package filled with whimsical gifts, such as a magnet with the Presidential seal for his metal crutches, a license plate with "Bill" for his wheelchair, and knee pads with the Presidential seal; a Banana Republic casual shirt and a puzzle on golf mysteries on May 24, 1997; the card game "Royalty" in mid-August 1997; shortly before Halloween of 1997, a package filled with Halloween-related items, such as a pumpkin lapel pin, a wooden letter opener with a frog on the handle, and a plastic pumpkin filled with candy; and on December 6, 1997, a Starbucks Santa Monica mug and a Hugs and Kisses box. Lewinsky 8/6/98 GJ at 27-28; GJ Exhibit ML-7; Lewinsky 7/27/97 Int. at 12-15.

190. Clinton 8/17/98 GJ at 47.

191. Id. at 34-36.

192. Id. at 173 (emphasis added). The President testified that "to his knowledge" he has turned over all the gifts that Ms. Lewinsky gave him. Id. at 154-155.

193. Id. at 172-173.

194. Currie 5/6/98 GJ at 88-89; see also id. at 184; Currie 5/14/98 GJ at 78. Courier receipts show that Ms. Lewinsky sent nine packages to Ms. Currie. See 0837-DC-00000001 to 0837-DC-00000027.

195. T1 at 63-64.

196. Currie GJ 5/6/98 at 88-89; see also Currie GJ 5/14/98 at 78.

197. Currie 5/6/98 GJ at 129.

198. Currie 5/14/98 GJ at 145.

199. In his grand jury testimony, the President said that this question at his civil deposition confused him and that he thought that the questioner was asking whether he could list specific gifts he had given her rather than whether he had ever given Ms. Lewinsky a gift. Clinton 8/17/98 GJ at 51-52. Even if that explanation were credited, the President's answer to the hat pin question is inaccurate, particularly because he had discussed it with Ms. Lewinsky on December 28, according to her testimony.