C. January 6: The Draft Affidavit

According to Ms. Lewinsky, in the afternoon of January 6, 1998, she visited Mr. Carter's office and picked up a draft of the affidavit.⁽⁹³⁴⁾ Later that day, according to Ms. Lewinsky, she and Mr. Jordan discussed the draft by telephone.⁽⁹³⁶⁾ Ms. Lewinsky testified that having Mr. Jordan review the affidavit was like getting it "blessed" by the President.⁽⁹³⁷⁾ Ms. Lewinsky testified that she told Mr. Jordan that she was worried about a sentence that implied that she had been alone with the President and thus might incline Paula Jones's attorneys to question her.⁽⁹³⁸⁾ She eventually deleted it.⁽⁹³⁹⁾

In addition, Paragraph 8 of the draft affidavit provided in part:

I have never had a sexual relationship with the President. . . . The occasions that I saw the President, with crowds of other people, after I left my employment at the White House in April, 1996 related to official receptions, formal functions or events related to the U.S. Department of Defense, where I was working at the time.⁽⁹⁴¹⁾

Deeming the reference to "crowds" "too far out of the realm of possibility,"⁽⁹⁴²⁾ Ms. Lewinsky deleted the underscored phrase and wrote the following sentence at the end of this paragraph: "There were other people present on all of these occasions."⁽⁹⁴³⁾ She discussed this proposed sentence, as well as her general anxiety about Paragraph 8, with Mr. Jordan.⁽⁹⁴⁴⁾

When questioned in the grand jury, Mr. Jordan acknowledged that Ms. Lewinsky called him with concerns about the affidavit,⁽⁹⁴⁵⁾ but maintained that he told her to speak with her attorney.⁽⁹⁴⁶⁾

Phone records for January 6 show that Mr. Jordan had a number of contacts with Ms. Lewinsky, the President, and Mr. Carter. Less than thirty minutes after Mr. Jordan spoke by phone to Ms. Lewinsky, he talked with the President for thirteen minutes. Immediately after this call, at 4:33 p.m., Mr. Jordan called Mr. Carter. Less than an hour later, Mr. Jordan placed a four-minute call to the main White House number. Over the course of the day, Mr. Jordan called a White House number twice, Ms. Lewinsky three times, and Mr. Carter four times.⁽⁹⁴⁷⁾

Mr. Carter testified that his phone conversations with Mr. Jordan this day and the next "likely" related to Ms. Lewinsky and his litigation strategy for her.⁽⁹⁴⁸⁾ In fact, Mr. Carter billed Ms. Lewinsky for time for "[t]elephone conference with Atty Jordan."⁽⁹⁴⁹⁾

When questioned in the grand jury, Mr. Jordan testified that he could not specifically remember the January 6 calls. He said he "assumed" that he talked with Ms. Lewinsky about her job search, and he believed that he called Mr. Carter to see "how he was dealing with this highly emotional lady."⁽⁹⁵⁰⁾ He said that he might have talked with the President about Ms. Lewinsky, but he maintained that "there [was] no connection" between his 13-minute conversation with the President and the call he placed immediately thereafter to Mr. Carter.⁽⁹⁵¹⁾

D. January 7: Ms. Lewinsky Signs Affidavit

Ms. Lewinsky set an appointment with Mr. Carter to finalize the affidavit for 10 a.m. on January 7, 1998.⁽⁹⁵²⁾ She signed the affidavit; however, she acknowledged in the grand jury that statements in it were false.⁽⁹⁵³⁾ Mr. Carter indicated to her that he "intend[ed] to hold onto this until after I talk to plaintiff's lawyers." He told her to "keep in touch," and said: "Good luck on your job search."⁽⁹⁵⁶⁾

According to Mr. Jordan, Ms. Lewinsky came to his office on January 7 and showed him the signed affidavit.⁽⁹⁵⁷⁾ Over the course of the day, Mr. Jordan placed three calls of significant duration to the White House.⁽⁹⁵⁸⁾ He testified: "I knew the President was concerned about the affidavit and whether it was signed or not."⁽⁹⁵⁹⁾ When asked whether the President understood that the affidavit denied a sexual relationship, Mr. Jordan testified: "I think that's a reasonable assumption."⁽⁹⁶⁰⁾ According to Mr. Jordan, when he informed the President that Ms. Lewinsky had signed the affidavit, the President said, "Fine, good."⁽⁹⁶¹⁾ Mr. Jordan said he was continuing to work on her job, and the President responded, "Good."⁽⁹⁶²⁾

Ten days after this conversation, in the Jones deposition, President Clinton was asked whether he knew that Ms. Lewinsky had met with Vernon Jordan and talked about the Jones case. He answered:

I knew he met with her. I think Betty suggested that he meet with her. Anyway, he met with her. I, I thought that he talked to her about something else. I didn't know that -- I thought he had given her some advice about her move to New York. Seems like that's what Betty said.⁽⁹⁶³⁾

In his grand jury appearance, however, President Clinton testified that Mr. Jordan informed "us" on January 7 that Ms. Lewinsky had signed an affidavit to be used in connection with the Jones case.⁽⁹⁶⁴⁾ The President defended his deposition testimony by stating:

[M]y impression was that, at the time, I was focused on the meetings. I believe the meetings he had were meetings about her moving to New York and getting a job.

I knew at some point that she had told him that she needed some help, because she had gotten a subpoena. I'm not sure I know whether she did that in a meeting or a phone call. And I was not, I was not focused on that. I know that, I know Vernon helped her get a lawyer, Mr. Carter. And I, I believe that he did it after she had called him, but I'm not sure. But I knew that the main source of their meetings was about her move to New York and her getting a job.⁽⁹⁶⁵⁾

E. January 8: The Perelman Call

The day after she signed the affidavit, January 8, 1998, Ms. Lewinsky interviewed in New York with Jaymie Durnan, Senior Vice President and Special Assistant to the Chairman at MacAndrews & Forbes Holdings, Inc. (MFH).⁽⁹⁶⁶⁾ Mr. Durnan testified that, although impressive, Ms. Lewinsky was not suited for any MFH opening.⁽⁹⁶⁷⁾ He told her that he would pass on her resume to Revlon, an MFH company.⁽⁹⁶⁸⁾ Ms. Lewinsky called Mr. Jordan and reported that she felt that the interview had gone "very poorly."⁽⁹⁶⁹⁾ Mr. Jordan indicated in response that "he'd call the chairman."⁽⁹⁷⁰⁾

At 4:54 p.m., Mr. Jordan called Ronald Perelman, chairman and chief executive officer of MFH.⁽⁹⁷¹⁾ Mr. Jordan told the grand jury with respect to Mr. Perelman, one "[c]an't get any higher -- or any richer."⁽⁹⁷²⁾ Asked why he chose to call Mr. Perelman, Mr. Jordan responded: "I have spent a good part of my life learning institutions and people, and, in that process, I have learned how to make things happen. And the call to Ronald Perelman was a call to make things happen, if they could happen."⁽⁹⁷³⁾

According to Mr. Perelman, Mr. Jordan spoke of "this bright young girl, who I think is terrific," and said that he wanted "to make sure somebody takes a look at her."⁽⁹⁷⁷⁾ Mr. Perelman testified that, in the roughly twelve years that Mr. Jordan had been on Revlon's Board of Directors, he did not recall Mr. Jordan ever calling to recommend someone.⁽⁹⁷⁸⁾

After he spoke with Mr. Perelman, Mr. Jordan telephoned Ms. Lewinsky and told her, "I'm doing the best I can to help you out."⁽⁹⁸²⁾ Ms. Lewinsky soon received a call from Revlon, inviting her to another interview.⁽⁹⁸⁴⁾

Over the course of January 8, Mr. Jordan placed three calls to the White House -- twice to a number at the White House Counsel's Office, once to the main White House number.⁽⁹⁸⁵⁾ As to the Counsel's Office calls, Mr. Jordan speculated that he was trying to reach Cheryl Mills, Deputy White House Counsel, to express his "frustration" about Ms. Lewinsky.⁽⁹⁸⁶⁾ According to Mr. Jordan, Ms. Mills knew who Ms. Lewinsky was: "[T]hat was no secret, I don't think, around the White House, that I was helping Monica Lewinsky."⁽⁹⁸⁷⁾

F. January 9: "Mission Accomplished"

On the morning of Friday, January 9, 1998, Ms. Lewinsky interviewed with Allyn Seidman, Senior Vice President of MFH, and two individuals at Revlon.⁽⁹⁸⁸⁾ Ms. Lewinsky testified that the interviews went well and that Ms. Seidman called her back that day and "informally offered [her] a position, and [she] informally accepted."⁽⁹⁸⁹⁾

Ms. Lewinsky then called Mr. Jordan and relayed the good news.⁽⁹⁹⁰⁾ When shown records of a seven-minute call at 4:14 p.m., Mr. Jordan testified: "I have to assume that if she got the job and we have a seven-minute conversation and the day before I had talked to the chairman [Ronald Perelman], I have to assume the Jordan magic worked."⁽⁹⁹¹⁾

According to Mr. Jordan, he believed that he notified Ms. Currie and the President as soon as he learned that Ms. Lewinsky had obtained an offer: "I am certain that at some point in time I told Betty Currie, 'Mission accomplished.'"⁽⁹⁹²⁾ Mr. Jordan testified that he also told the President directly that, "'Monica Lewinsky's going to work for Revlon,' and his response was, 'Thank you very much.'"⁽⁹⁹³⁾

G. January 12: Pre-Trial Hearing in Jones Case

On January 12, 1998, Judge Wright held a hearing in the Jones case to discuss pre-trial issues, including the President's upcoming deposition.⁽⁹⁹⁴⁾ At that hearing, Judge Wright required Ms. Jones's counsel to list all the witnesses that they planned to call at trial. Ms. Jones's witness list named many women, among them Ms. Lewinsky, to support her theory that the President had a pattern of rewarding women based on their willingness to engage in sexual relations with him. At the hearing, Judge Wright indicated that she would permit Ms. Jones to call as witnesses some of the women she listed in support of her case.

H. January 13: References from the White House

On Tuesday, January 13, 1998, Jennifer Sheldon, Manager of Corporate Staffing of Revlon, called Ms. Lewinsky and formally extended her a position as a public relations administrator. Asked whether this was a relatively quick hiring process, Ms. Sheldon responded, "In totality of how long open positions normally stay open, yes. This was pretty fast."⁽⁹⁹⁵⁾ Ms. Sheldon told Ms. Lewinsky that she needed to send her some references.⁽⁹⁹⁶⁾

According to Ms. Lewinsky, she then called Ms. Currie because she was "concerned that if I put [Mr. Hilley] down as a reference, he might not say flattering things about me."⁽⁹⁹⁷⁾ At 11:11 a.m. on January 13, Ms. Currie paged Ms. Lewinsky and left the following message: "Will know something this afternoon. Kay."⁽⁹⁹⁸⁾

That day, January 13, the President talked with Chief of Staff Erskine Bowles about a reference for Ms. Lewinsky.⁽⁹⁹⁹⁾ The President told Mr. Bowles that Ms. Lewinsky "had found a job in the . . . private sector, and she had listed John Hilley as a reference, and could we see if he could recommend her, if asked." Mr. Bowles assured the President that Mr. Hilley would give Ms. Lewinsky a recommendation commensurate with her job performance.⁽¹⁰⁰⁰⁾

Thereafter, Mr. Bowles took the President's request to Mr. Podesta, the Deputy Chief of Staff, who in turn spoke with Mr. Hilley.⁽¹⁰⁰¹⁾ Mr. Hilley responded that, because he did not know Ms. Lewinsky personally, he would have his office write a recommendation.⁽¹⁰⁰²⁾ It would be a generic letter, simply confirming the dates of employment, because of the less than favorable circumstances surrounding Ms. Lewinsky's departure from the White House.⁽¹⁰⁰³⁾

Ms. Lewinsky testified that Ms. Currie called later that day and told her that "Mr. Podesta took care of it and everything would be fine with Mr. Hilley."⁽¹⁰⁰⁴⁾ At 11:17 a.m. the next day, Wednesday, January 14, Ms. Lewinsky faxed her acceptance to Revlon and listed John Hilley and her Defense Department supervisor as references.⁽¹⁰⁰⁶⁾

The President was asked in the grand jury whether he ever spoke to Mr. Bowles about obtaining a reference from Mr. Hilley for Ms. Lewinsky. He testified that he did, at Ms. Lewinsky's request, although he thought he had done so earlier than January 13 or 14.⁽¹⁰⁰⁷⁾

I. January 13: Final Jordan Meeting

According to Ms. Lewinsky, on Tuesday, January 13, she stopped by Mr. Jordan's office to drop off some thank-you gifts for helping her find a job. Ms. Lewinsky offered to show him a copy of her signed affidavit in the Jones case, but he indicated that he did not need to see it.⁽¹⁰⁰⁸⁾

J. January 13-14: Lewinsky-Tripp Conversation and Talking Points

In a face-to-face conversation on January 13, Ms. Lewinsky told Linda Tripp: "This is what my lawyer taught me. You really don't -- you don't very often say 'no' unless you really need to. The best is, 'Well, not that I recall, not that I really remember. Might have, but I don't really remember.'"⁽¹⁰⁰⁹⁾ Ms. Lewinsky said that, if asked in a deposition, "Were you ever alone with the President?" she could say, "Um, it's possible I may have taken a letter on the weekend, but, you know -- I might have, but I don't really. . . ."⁽¹⁰¹⁰⁾

Ms. Lewinsky and Ms. Tripp then discussed the situation:

Ms. Lewinsky: I don't think the way that man thinks, I don't think he thinks of lying under oath. . . .

Ms. Tripp: Yes, he is because he's the one who said, "Deny, deny, deny." Of course he knows.

Ms. Lewinsky: Right. But it's -- hard to explain this. It's like -- (sigh)

Ms. Tripp: You know what I mean. I mean, I don't know -- do I think he is consciously --

Ms. Lewinsky: If-- if -- if I said, if somebody said to him, "Is Monica lying under oath," he would say yes. But when he on his own thinks about it, he doesn't think about it in those terms. Okay?

Ms. Tripp: Probably.

Ms. Lewinsky: Okay? He thinks of it as, "We're safe. We're being smart." Okay? "We're being smart, we're being safe, it's good for everybody."⁽¹⁰¹¹⁾

On January 14, Ms. Lewinsky gave Ms. Tripp a three-page document regarding "points to make in [Ms. Tripp's] affidavit."⁽¹⁰¹²⁾ Ms. Lewinsky testified that she wrote the document herself, although some of the ideas may have been inspired by conversations with Ms. Tripp.⁽¹⁰¹³⁾