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Investigating The President

694. Lewinsky 8/13/98 Int. at 5. Many of Ms. Lewinsky's previous visits with the President had occurred on holidays. See, e.g., Lewinsky 7/30/98 Int. at 3, 13, 17 (describing visits on New Year's Eve, Presidents' Day, Easter Sunday, and July 4).

695. 837-DC-00000008(courier receipt).

696. DB-DC-00000022. Ms. Lewinsky produced a draft of this letter to the OIC on July 31, 1998. See also Lewinsky 7/31/98 Int. at 1 (confirming that she delivered a substantially similar note).

697. DB-DC-00000022.

698. Lewinsky 8/13/98 Int. at 5-6. On November 12, 1997, the President responded to Paula Jones's Third Set of Interrogatories. In response to an interrogatory that asked the President to provide information about all individuals who have discoverable and relevant information regarding the disputed facts at issue in the case, the President provided a list of names that did not include Ms. Lewinsky. 849-DC-0000090 - 97.

699. 1037-DC-00000318 (email retrieved from Catherine Davis's computer).

700. 1037-DC-00000318 (spelling corrected). Lewinsky 8/13/98 Int. at 6. On November 13, Ms. Hernreich was testifying before Congress. Walsh, "Democratic Donor Chung Invokes 5th Amendment; House Members Informally Interview Businessman Edward Walsh," Washington Post, November 15, 1997, at A6.

701. MSL-1249-DC-0140; Lewinsky 8/13/98 Int. at 6.

702. 1037-DC-00000318 (email retrieved from Catherine Davis's computer).

703. Lewinsky 8/13/98 Int. at 6; 1234-DC-00000050 (movement log); 986-DC-00003799 (Kearney Diary).

704. Lewinsky 8/13/98 Int. at 6.

705. Lewinsky 8/13/98 Int. at 6; 1037-DC-00000318 (email to Catherine Davis).

706. In a note to the President the next week, Ms. Lewinsky would write of the gifts: "I forgot to tell you: . . . The Gingko Blowjoba or whatever it is called and the Zinc lozenges were from me." MSL-55-DC-0140 (spelling and grammar corrected).

707. Lewinsky 8/6/98 GJ at 183-85; Lewinsky 8/2/98 Int. at 4. Ms. Lewinsky also saw a clipping of the Valentine's Day ad she had placed in the Washington Post on the President's desk. Lewinsky 8/6/98 GJ at 183-84. In a document composed soon after this visit, Ms. Lewinsky wrote: "When I was hiding out in your office for a half-hour, I noticed you had the new Sarah McLachlan CD. I have it, too, and it's wonderful. Whenever I listen to song #5 I think of you. That song and Billie Holiday's version of 'I'll be Seeing You' are guaranteed to put me to tears when it comes to you!" MSL-1249-DC-0140-41 (deleted file from Ms. Lewinsky's home computer) (spelling and grammar corrected).

708. 1037-DC-00000318 (email to Catherine Davis).

709. Lewinsky 8/13/98 Int. at 6.

710. OIC 8/27/98 Memo.

711. 968-DC-00000187 (presidential schedule); 968-DC-00000303 (Kearney Diary). Ms. Currie initially testified that she could not recall Ms. Lewinsky's November 13 visit. Currie 5/6/98 GJ at 12, 15. After viewing documentary evidence, she recalled that this was the only time she surreptitiously escorted Ms. Lewinsky into the White House. Id. at 85.

712. Lewinsky 8/11/98 Int. at 1; Lewinsky 7/31/98 Int. at 1-2; 837-DC-00000011 (courier receipt); MSL-1249-DC-0140-41 (document recovered from Ms. Lewinsky's home computer).

On November 17, 1997, the President responded to Paula Jones's First Set of Requests for Production of Documents and Things. One request sought documents sent to President Clinton by any woman (other than Mrs. Clinton) with whom President Clinton had sexual relations. V002-DC-00000056 - 92. President Clinton objected to this request as one designed "solely to harass, embarrass, and humiliate the President and the Office he occupies." V002-DC-00000075. Nonetheless, the President answered that he did not have any documents responsive to that request.

713. Lewinsky 8/6/98 GJ at 105.

714. Lewinsky 8/6/98 GJ at 105. Phone and pager records corroborate these contacts. 1205-DC-00000016; V004-DC-00000143; 831-DC-00000011. (Note that Ms. Lewinsky's pager records reflect Pacific Time; throughout this referral, time has been adjusted to Eastern Standard Time.)

715. MSL-1249-DC-0140 (spelling and punctuation corrected).

716. MSL-1249-DC-0139 (spelling and punctuation corrected).

717. 849-DC-00000128.

718. 849-DC-00000121-37

719. See infra at Section XI.F. See also Lewinsky 8/6/98 GJ at 121-26.

720. Clinton 8/17/98 GJ at 84-85. In his Jones deposition, the President acknowledged that he may have heard of the witness list before he actually saw it. Clinton 1/17/98 Depo. at 70.

721. 833-DC-00003207 (Travel Voucher DOD).

722. Lewinsky 8/6/98 GJ at 107; Lewinsky 7/31/98 Int. at 1.

723. V006-DC-00000521 (guest list); VOO6-DC-00001859 (photograph of Ms. Lewinsky and the President at the reception).

724. Lewinsky 7/31/98 Int. at 1.

725. Lewinsky 7/31/98 Int. at 2; MSL-55-DC-0177. The wording of the letter resembles, in part, a message on a cassette found during the consensual search of Ms. Lewinsky's apartment: "Hi. [Sniffling, crying.] I was so sad seeing you last night. I was so angry with you that once again you had rejected me. . . . I wanted to feel the warmth of you and the smell of you and the touch of you. And it made me sad. And I -- you confuse me so much. I mean I [sigh]. I thought I -- I thought I fell in love with this person that -- that I really felt was such a good -- such a good person, such a good heart, someone who's had a life with a lot of experiences.(726)

726. Search.001 transcript at 2. [get cite for tape itself]

727. MSL-55-DC-0177 (punctuation corrected).

728. MSL-55-DC-0177 (punctuation corrected).

729. MSL-DC-55-0177 (punctuation corrected).

730. MSL-55-DC-0177 (punctuation corrected).

731. Lewinsky 8/6/98 GJ at 108-09; Lewinsky 8/6/98 GJ at 27-29 & Exh. ML-7. The cigar holder, the tie, the mug, and the book have been produced to the OIC. V002-PHOTOS-0011 (holder, tie, and book); V002-PHOTOS-0005 (mug).

732. Lewinsky 8/6/98 GJ at 111-12.

733. Bryan Hall 5/21 98 Int. at 2; Bryan Hall 7/23/98 GJ at 10-11, 15-16; Niedzwiecki 7/30/98 GJ at 12-13; Lewinsky 8/6/98 GJ at 109-11.

734. Lewinsky 8/6/98 GJ at 110-11; Niedzwiecki 7/30/98 GJ at 13-14.

735. Byran Hall 7/23/98 GJ at 12-13; Niedzwiecki 7/30/98 GJ at 13, 15. Officer Hall recognized Ms. Lewinsky from a previous occasion, when she was greeted by, and delivered something to, Ms. Currie. Byran Hall 7/23/98 GJ at 6-10.

736. Tyler 7/28/98 GJ at 40; Chinery 7/23/98 GJ at 8.

737. Lewinsky 8/6/98 GJ at 111-12. Ms. Mondale recalled visiting the President that morning. Mondale 7/16/98 Int. at 1. See also 843-DC-00000004 (Epass records reflect that Ms. Mondale entered the White House at 9:33 a.m.).

738. Lewinsky 8/6/98 GJ at 111-12. See also Currie 7/22/98 GJ at 88-89. Ms. Lewinsky suspected that Ms. Mondale was romantically involved with the President. (739)

739. In a conversation on November 11, Ms. Lewinsky speculated that Ms. Mondale was and the President were starting a "relationship." Ms. Lewinsky noted with bitterness: "Maybe she's not sleeping with him yet. Anyway, there's the excitement. It's the President." LT16 at 91. -

740. Lewinsky 8/6/98 GJ at 112-13. Ms. Currie testified that Ms. Lewinsky angrily told her: "'You had lied to me, that the President is in the office, and he's meeting with someone.' And I said, 'Yeah, you're right.' She was not too happy about it, and words were exchanged." Currie 1/27/98 GJ at 37.

741. Keith Williams 7/23/98 GJ at 24. See also Chinery 7/23/98 GJ at 10; Purdie 7/23/98 GJ at 13.

742. Keith Williams 7/23/98 GJ at 12. Some testimony indicates that the President directly told Sergeant Williams about the Northwest Gate incident. Three officers testified that Sergeant Williams told them that the President had spoken to him and had indicated that he wanted the officer responsible for the disclosure of information fired. Niedzwiecki 7/30/98 GJ at 29, 37; Byran Hall 7/23/98 GJ at 25-26; Porter 8/13/98 GJ at 16-18. For example, Officer Niedzwiecki testified that soon after the incident, Sergeant Williams came to the Northwest Gate and said, "[t]he President wants somebody's job." Niedzwiecki 7/30/98 GJ at 29. Sergeant Williams testified, however, that the President did not speak to him directly about the incident. Keith Williams 7/23/98 GJ at 31-32. According to Sergeant Williams, when he met alone with Ms. Currie, he noticed that the door leading to the Oval Office was at first shut but then was cracked open. Keith Williams 7/23/98 GJ at 22, 30. Sergeant Williams testified that he heard what he assumed to be a male voice coming from within the Oval Office saying "[t]his person needs to be fired." Keith Williams 7/30/98 GJ at 10-11. Sergeant Williams told the officers at the gate that he spoke to the President only to get their attention. Keith Williams 7/30/98 GJ at 16-17. However, Sergeant Williams also told the supervisor who replaced him that afternoon that the President had spoken to him directly about the incident at the Northwest Gate. Deardoff 9/3/98 Depo. at 8-9.

743. Purdie 7/23/98 GJ at 13, 18-19. Captain Purdie testified that he thought that the remedy of firing was "out of proportion to the incident . . . [e]specially without doing an investigation or a fact-finding mission."(744)

744. Purdie 7/23/98 GJ at 19.

745. Lewinsky 8/6/98 GJ at 113.

746. Lewinsky 8/6/98 GJ at 113-14.

747. Lewinsky 8/6/98 GJ at 114.

748. Lewinsky 8/6/98 GJ at 114.

749. 827-DC-00000018. Secret Service logs reflect that the President was in the area of the Oval Office throughout this period. V006-DC-00002158.

750. Lewinsky 8/6/98 GJ at 115-16. Specifically, Ms. Lewinsky told the President "that I was supposed to get in touch with Mr. Jordan the previous week and that things didn't work out and that nothing had really happened yet." Id.

751. Lewinsky 8/6/98 GJ at 116. The President also told Ms. Lewinsky that he had already gotten a Christmas present for her and that he would give that to her during another visit. Lewinsky 8/1/98 Int. at 2.

752. Lewinsky 8/6/98 GJ at 115.

753. 1037-DC-00000011 (spelling corrected).

754. Keith Williams 7/23/98 GJ at 25. Ms. Currie confirmed that she told an officer, "Okay. Fine. This never happened." However, she testified that she said this so that no officer would get in trouble. Currie 7/22/98 GJ at 91-92.

When Ms. Currie left work that day, she stopped by a Secret Service post and told an officer that "she spoke to the President . . . and . . . they decided that the incident never happened, they weren't going to pursue . . . discipline actions against them, that they just wanted it to go away." Chinery 7/23/98 GJ at 22-23. Later that week, Ms. Currie told that officer to inform one of his supervisors "that everything was okay and just to keep quiet about it." Keith Williams 7/23/98 GJ at 27-28.

755. Purdie 7/23/98 GJ at 32; Purdie 7/17/98 GJ at 3.

756. Purdie 7/17/98 GJ at 6; Bryan Hall 7/23/98 GJ at 31-32; Chinery 7/23/98 GJ at 21.

757. Porter 8/13/98 GJ at 12.

758. Niedzwiecki 7/30/98 GJ at 30-31.

759. Niedzwiecki 7/30/98 GJ at 31, 44. See also Niedzwiecki 8/5/98 GJ at 4-6 (text of Niedzwiecki notes).

760. Purdie 7/23/98 GJ at 35.

761. Purdie 7/23/98 GJ at 34-36. While Deputy Chief O'Malley testified that Captain Purdie notified him of the incident, Deputy Chief O'Malley did not recall Captain Purdie discussing with him, at any time, a decision not to generate an incident report or a memorandum. Charles O'Malley 9/8/98 Depo. at 44, 47-48.

762. O'Malley 9/8/98 Depo. at 22, 40-41.

763. Clinton 8/17/98 GJ at 84-85, 87. Ms. Mondale stated that she met with the President alone in the Oval Office study that day. Mondale 7/16/98 Int. at 1.

764. Clinton 8/17/98 GJ at 86.

765. Clinton 8/17/98 GJ at 88-89.

766. Clinton 8/17/98 GJ at 89-90.

767. Clinton 8/17/98 GJ at 91-92.

768. Lewinsky 8/6/98 GJ at 151-52; Lewinsky 2/1/98 Statement at 6. On December 23, Paula Jones's attorneys issued a subpoena to the Secret Service.

769. Lindsey 3/12/98 GJ at 64-66; Lindsey 2/19/98 GJ at 9-10. WAVES records reflect that Robert Bennett entered the White House at 4:39 p.m. on Saturday, December 6. 1407-DC-00000005.

770. Lindsey 3/12/98 GJ at 65.

771. 964-DC-00000862 (Presidential mail notes).

772. Lindsey 3/12/98 GJ at 63-64. Mr. Lindsey refused to answer questions about his December 6 meeting with the President, claiming attorney-client privilege and Executive (presidential communications) Privilege.(773)

773. Lindsey 3/12/98 GJ at 66. The U.S. District Court for the District of Columbia Circuit rejected Mr. Lindsey's claim of privilege, In re Grand Jury Proceedings, 5 F. Supp.2d 21 (D.D.C. 1998), and the Court of Appeals denied Mr. Lindsey's appeal, In re Lindsey, __ F.3d __, 1998 WL 418780 (D.C. Cir. 1998). A petition for Supreme Court review is currently pending. __ U.S.L.W. __ (U.S. Aug. 21, 1998) (No. 98-316).

774. WAVES records reflect that Mr. Jordan entered the White House at 5:21 p.m. on Sunday, December 7. 1178-DC-00000026.

775. Jordan 5/5/98 GJ at 83. He later testified that the conversation was "[a]bsolutely not" about Ms. Lewinsky. Jordan 5/5/98 GJ at 116.

776. V004-DC-00000171 (Akin, Gump visitor records) (recording visit of "Malensky"). Ms. Lewinsky recalled arranging the meeting on December 8 or 9. Lewinsky 8/1/98 Int. at 3. See also 833-DC-00017886 (reflecting Ms. Lewinsky's call to Mr. Jordan on December 8).

On December 8, Ms. Lewinsky sent Mr. Jordan a hat, a box of chocolates, and a note gently reminding him of his promise to help her find a job. Lewinsky 7/31/98 Int. at 15. She also sent the President a note and some peach candies. Lewinsky 8/1/98 Int. at 2; Lewinsky 8/1/98 Int. at 2; 837-DC-00000017; 837-DC-00000020 (courier receipts).

777. Jordan 3/3/98 GJ at 41-42.

778. V004-DC-00000148 (Akin, Gump phone records). See also Jordan 3/3/98 GJ at 54, 62-63, 70.

Mr. Halperin testified that Mr. Jordan had told him that Ms. Lewinsky "was a bright young woman who was energetic and enthusiastic and . . . encouraged me to meet with her." Halperin 4/23/98 GJ at 13. Similarly, Ms. Fairbairn stated that Mr. Jordan had told her that he "would like to send [her] a resume of a talented young lady and see if she matches up with any company openings." Fairbairn 1/29/98 Int. at 1. Mr. Georgescu, however, stated that Mr. Jordan "did not engage in a 'sales pitch' about [Ms.] Lewinsky." Georgescu 3/25/98 Int. at 2.

779. Lewinsky 8/6/98 GJ at 121. Ms. Lewinsky left the meeting with Mr. Jordan on December 8 with the impression that Mr. Jordan was going to get her a job. Lewinsky 8/1/98 Int. at 4.

780. Lewinsky 8/6/98 GJ at 119.

781. Lewinsky 8/6/98 GJ at 120.

782. Lewinsky 8/6/98 GJ at 120.

783. Lewinsky 8/6/98 GJ at 120. In her handwritten proffer, Ms. Lewinsky gave a very similar account of her second meeting with Mr. Jordan: "Ms. L. met again with Mr. Jordan in the beginning of December '97, at which time he provided Ms. L. with a list of three people to contact and suggested language to use in her letters to them. At some point, Mr. Jordan remarked something about Ms. L. being a friend of the Pres. of the United States. Ms. L. responded that she never really saw him as "the President"; she spoke to him like a normal man and even got angry with him like a normal man. Mr. Jordan asked what Ms. L. got angry about. Ms. L. replied that the Pres. doesn't see or call her enough. Mr. Jordan said Ms. L. should take her frustrations out on him -- not the President.(784)

784. Lewinsky Proffer at 3-4. -

785. Lewinsky 8/6/98 GJ at 120.

786. Jordan 3/3/98 GJ at 154.

787. Jordan 3/3/98 GJ at 64-65.

788. Jordan 3/3/98 GJ at 65.

789. Jordan 3/3/98 GJ at 65.

790. 1414-DC-00001534 - 46 (Plaintiff's Second Request for Production of Documents and Things).

791. Lewinsky 8/6/98 GJ at 121-26.

792. Lewinsky 8/6/98 GJ at 126. Ms. Lewinsky testified that the call came as a surprise because Mrs. Clinton was in town. Id. at 122. See also 968-DC-00003479 (Mrs. Clinton's schedule reflects that she was in Washington, D.C. on December 17).

793. Lewinsky 8/6/98 GJ at 122-23.

794. Lewinsky 8/6/98 GJ at 123.

795. Lewinsky 2/1/98 Statement at 4.

796. Lewinsky 8/6/98 GJ at 123.

797. Lewinsky 2/1/98 Statement at 4.

798. Lewinsky 8/6/98 GJ at 123-24. Ms. Lewinsky testified that, "on [s]everal occasions," they had resolved to use this cover story to conceal their relationship. Id.

799. Lewinsky 8/6/98 GJ at 232.

800. Lewinsky 8/6/98 GJ at 126.

801. Lewinsky 8/6/98 GJ at 126.

802. Clinton 8/17/98 GJ at 116.

803. Clinton 8/17/98 GJ at 119. The President himself gave this explanation of Ms. Lewinsky's visits to the Oval Office at his Jones deposition. Clinton 1/17/98 Depo. at 50-51.

804. Clinton 8/17/98 GJ at 119-20.

805. Clinton 8/17/98 GJ at 119-20.

806. Clinton 8/17/98 GJ at 120.

807. Halperin 1/26/98 Int. at 2.

808. Berk 3/31/98 Int. at 1-2. In her proffer, Ms. Lewinsky stated that, during the week following her December 11 meeting with Mr. Jordan, she "had two interviews in NY in response to her letters." Lewinsky 2/1/98 Statement at 4.

809. Schick 1/29/98 Int. at 2.

810. Lewinsky 8/6/98 GJ at 128; Harte 4/17/98 Int. at 1.

811. 902-DC-000000135 - 138 (Lewinsky subpoena).

812. 902-DC-000000137.

813. Lewinsky 8/6/98 GJ at 128-29; Lewinsky 7/27/98 Int. at 6; 8/1/98 Int. at 6-7. In the late-night December 17 call, the President told Ms. Lewinsky that, if she were subpoenaed, she should call Ms. Currie. Ms. Lewinsky did not do so on December 19 because Ms. Currie's brother had recently died and Ms. Lewinsky did not want to bother her. Lewinsky 8/6/98 GJ at 126.

814. Jordan 3/3/98 GJ at 92-93. Mr. Jordan said that he did not contemplate representing Ms. Lewinsky himself because "I represent companies. I don't represent individuals." Jordan 3/3/98 GJ at 101.

815. V004-DC-00000172 (Akin, Gump visitor logs).

816. V004-DC-00000151 (Akin, Gump telephone records, indicating the call ended at 5:05 p.m.); 1178-DC-00000014 (Presidential call logs, reflecting the call ended at 5:08 p.m.). Presidential call logs are recorded by hand, and thus are likely to be less accurate. The President may have been returning a call that Mr. Jordan had placed at 3:51 p.m.

817. Lewinsky 8/6/98 GJ at 131; V004-DC-00000151 (Akin, Gump telephone records). Mr. Jordan asked whether he could bring a potential client to Mr. Carter's office on Monday morning.(818)

818. Jordan 5/5/98 GJ at 154-55. See also Carter 6/18/98 GJ at 10. Although Mr. Jordan was adamant that Ms. Lewinsky was not in his office when he spoke with the President, he was uncertain whether Ms. Lewinsky was in the office when the 5:06 p.m. call was placed to Mr. Carter. Jordan 5/5/98 GJ at 154. - -

819. Lewinsky 8/6/98 GJ at 131.

820. Jordan 5/5/98 GJ at 140, 152-53.

821. Jordan 5/5/98 GJ at 145.

822. Jordan 5/5/98 GJ at 145.

823. Jordan 5/5/98 GJ at 147.

824. Jordan 5/5/98 GJ at 147.

825. Jordan 3/3/98 GJ at 102.

826. Jordan 3/3/98 GJ at 103.

827. Lewinsky 8/6/98 GJ at 131-32.

828. Lewinsky 8/6/98 GJ at 132.

829. Lewinsky 8/6/98 GJ at 132. In her handwritten proffer, Ms. Lewinsky described her meeting with Mr. Jordan that afternoon: "Ms. L expressed anxiety with respect to her subpoena requesting production of any gifts from the Pres., specifically citing hat pins which the Pres. had in fact given her. Mr. Jordan allayed her concerns by telling her it was standard language." Lewinsky 2/1/98 Statement at 5.

830. Lewinsky 8/6/98 GJ at 133.

831. Jordan 3/3/98 GJ at 150. Ms. Lewinsky confirmed that she had such a conversation with Mr. Jordan, although she believed it took place after a breakfast meeting on December 31. Lewinsky 8/6/98 GJ at 188; Lewinsky 2/1/98 Statement at 8.

832. Jordan 3/3/98 GJ at 123.

833. Jordan 3/3/98 GJ at 122. He also said: "I did not get graphic, I did not get specific, I didn't ask her if they kissed, I didn't ask if they caressed, all of which, as I understand it, is a part of the act of sex." Id. at 130.

834. Jordan 3/3/98 GJ at 126.

835. Jordan 3/3/98 GJ at 122-24. See also Lewinsky 8/6/98 GJ at 133-35.

836. Lewinsky 8/6/98 GJ at 134.

837. Lewinsky 8/6/98 GJ at 134.

838. Lewinsky 8/6/98 GJ at 135. According to Ms. Lewinsky, Mr. Jordan responded, "I don't hug men." Id.

839. Jordan 3/3/98 GJ at 167-8.

840. Jordan 3/3/98 GJ at 169. According to Mr. Jordan, the President listened with "some amazement" when Mr. Jordan recounted the conversation. Id. at 170.

841. Jordan 3/3/98 GJ at 173-74.

842. Jordan 3/3/98 GJ at 170.

843. Jordan 3/3/98 GJ at 171.

844. Jordan 3/3/98 GJ at 172. In the days that followed, Mr. Jordan informed the President that he had succeeded in engaging Francis Carter to represent Ms. Lewinsky. Jordan 3/5/98 GJ at 27.

845. Clinton 8/17/98 GJ at 64.

846. Clinton 8/17/98 GJ at 65-66.

847. Jordan 3/3/98 GJ at 164-66, 183-84.

848. Lewinsky 8/6/98 GJ at 138.

849. Lewinsky 8/6/98 GJ at 138.

850. Lewinsky 8/6/98 GJ at 138-39.

851. Lewinsky 8/6/98 GJ at 139.

852. Lewinsky 8/6/98 GJ at 139. Mr. Jordan asked what "phone sex" was. Lewinsky 8/6/98 GJ at 139. Ms. Lewinsky stated that she may have explained it this way: "He's taking care of business on one end and I'm taking care of business on another." Lewinsky 8/6/98 GJ at 143.

853. Lewinsky 8/6/98 GJ at 139-140. In her proffer, Ms. Lewinsky wrote that she "showed Mr. Jordan the items she was producing in response to the subpoena. Ms. L believes she made it clear that this was not everything she had that could respond to the subpoena, but she thought it was enough to satisfy." Lewinsky 2/1/98 Statement at 6.

854. Jordan 3/3/98 GJ at 153.

855. The diaries of both Mr. Carter and Mr. Jordan reflect an 11:00 a.m. appointment on December 22, 1997. 902-DC-00000231 (Mr. Carter's diary) and 1034-DC-00000103 (Mr. Jordan's diary).

856. Carter 6/18/98 GJ at 12, 14. According to Mr. Carter, although Mr. Jordan had previously referred clients to him, Mr. Jordan had never personally driven them to his office. Id. at 160-61.(857)

857. CITE

858. Carter 6/18/98 GJ at 158-60, 15, 75.

859. According to Mr. Carter's bill, he met with Ms. Lewinsky for 1.1 hours. 902-DC-00000037.

860. Lewinsky 8/6/98 GJ at 146; Carter 6/18/98 GJ at 25.

861. Lewinsky 8/6/98 GJ at 146-47; Carter 6/18/98 GJ at 25.

862. Lewinsky 8/6/98 GJ at 146. Somewhat at odds with Ms. Lewinsky, Mr. Carter testified, "I thought I needed to develop an affidavit recounting what she said to me." Carter 6/18/98 GJ at 65.

863. Lewinsky 8/6/98 GJ at 147.

864. Lewinsky 8/6/98 GJ at 147.

865. Carter 6/18/98 GJ at 29-30; 902-DC-00000038.

866. Carter 6/18/98 GJ at 39.

867. Carter 6/18/98 GJ at 42-43.

868. V002-DC-000000052 - 54 (President Clinton's Supplemental Responses to Plaintiff's Second Set of Interrogatories); 1414-DC-00000512 - 17 (same).

869. Lewinsky 8/6/98 GJ at 149.

870. Lewinsky 8/6/98 GJ at 149.

871. V0006-DC-00000009 (WAVES records).

872. Lewinsky 8/6/98 GJ at 150-51. In his grand jury testimony, the President recalled giving her many of these gifts and acknowledged that it was "probably true" that these were more gifts than he had ever given her in a single day. Clinton 8/17/98 GJ at 36.

873. Lewinsky 8/26/98 Depo. at 53.

874. Lewinsky 8/6/98 GJ at 151.

875. Lewinsky 8/6/98 GJ at 151-52.

876. Lewinsky 8/6/98 GJ at 152. In her handwritten statement of February 1, 1998, Ms. Lewinsky wrote: "Ms. L. asked [the President] how he thought the attorneys for Paula Jones found out about her. He thought it was probably 'that woman from the summer . . . with Kathleen Willey' (Linda Tripp) who lead [sic] them to Ms. L or possibly the uniformed agents. He shared Ms. L's concern about the hat pin. He asked Ms. L if she had told anyone that he had given it to her and she replied 'no.'" Lewinsky 2/1/98 Statement at 6.

877. Lewinsky 8/20/98 GJ at 66.

878. Lewinsky 8/6/98 GJ at 152. Ms. Lewinsky acknowledged in the grand jury that she had in fact told others about the hat pin. Lewinsky 8/6/98 GJ at 152.

879. Lewinsky 8/6/98 GJ at 152.

880. Lewinsky 8/6/98 GJ at 152. See also Lewinsky 8/20/98 GJ at 66.

881. Lewinsky 8/6/98 GJ at 168.

882. Clinton 1/17/98 Depo. at 68.

883. Clinton 8/17/98 GJ at 33.

884. Clinton 8/17/98 GJ at 39. He further testified that he did not remember that Ms. Lewinsky's subpoena specifically called for a hat pin. Clinton 8/17/98 GJ at 45.

885. Clinton 8/17/98 GJ at 39.(886)

886. Clinton 8/17/98 GJ at 45.

887. Catherine Davis 3/17/98 GJ at 77-79.

888. Lewinsky 8/6/98 GJ at 154-55.

889. Lewinsky 8/6/98 GJ at 155.

890. Lewinsky 8/6/98 GJ at 155-56.

891. Lewinsky 8/6/98 GJ at 156-58. Ms. Currie could remember only one other occasion in which she had driven to Ms. Lewinsky's Watergate apartment. Currie 5/6/98 GJ at 108.

892. Lewinsky 8/6/98 GJ at 158-59.

893. Lewinsky 8/6/98 GJ at 159.

894. Lewinsky 8/6/98 GJ at 159. See also Lewinsky 8/1/98 Int. at 12.

895. Lewinsky 2/1/98 Statement at 7 (punctuation corrected).

896. Ms. Currie stated, at various times, that the transfer occurred sometime in late December 1997 or early January 1998. Currie 1/24/98 Int. at 3; Currie 1/27/98 GJ at 56-57; Currie 5/6/98 GJ at 103-07.

897. Currie 5/6/98 GJ at 105-06.

898. Currie 5/6/98 GJ at 126.

899. Currie 1/27/98 GJ at 58. In her first grand jury appearance in January, Ms. Currie was asked whether she knew who had been asking the questions about the gifts. She testified: "Sir, no, I don't." Id. In a May grand jury appearance, Ms. Currie responded to a similar question by saying that she understood that Newsweek reporter Michael Isikoff (who had earlier written about Kathleen Willey) was asking about the gifts. Currie 5/6/98 GJ at 107, 114, 120. Ms. Lewinsky testified that she never spoke to Mr. Isikoff. Lewinsky 8/24/98 Int. at 9.

900. Currie 5/6/98 GJ at 107-08. See also Currie 1/27/98 GJ at 57-58.

901. Currie 5/6/98 GJ at 110. When the OIC later obtained the box from Ms. Currie by subpoena, it contained various items that the President had given to Ms. Lewinsky, including (a) a hat pin; (b) a brooch; (c) an official copy of the 1996 State of the Union Address inscribed "To Monica Lewinsky with best wishes, Bill Clinton"; (d) a photograph of the President in the Oval Office with a handwritten note, "To Monica -- Thanks for the tie Bill Clinton"; (e) a photograph of the President and Ms. Lewinsky inscribed "To Monica -- Happy Birthday! Bill Clinton 7-23-97"; (f) a sun dress, two t-shirts, and a baseball cap with a Black Dog logo on them; and (g) a facsimile copy of a Valentine's Day message to "Handsome" that Ms. Lewinsky placed in the Washington Post in 1996.

902. Currie 5/6/98 GJ at 106-07.

903. Clinton 8/17/98 GJ at 51.

904. Clinton 8/17/98 GJ at 115.

905. Clinton 8/17/98 GJ at 46.

906. Lewinsky 8/6/98 GJ at 186. Ms. Tripp, like Ms. Lewinsky, had been subpoenaed in the Jones case.

907. Lewinsky 8/6/98 GJ at 186-87. Although Mr. Jordan testified that he never had breakfast with Ms. Lewinsky, see Jordan 3/5/98 GJ at 60, there is strong circumstantial evidence supporting Ms. Lewinsky's testimony that she had breakfast with Mr. Jordan on December 31. Compare Lewinsky 8/6/98 GJ at 187-89 (describing breakfast) with 916-DC-00000003 (Park Hyatt receipt reflecting breakfast as described by Ms. Lewinsky).

908. Lewinsky 8/6/98 GJ at 186-89.

909. Lewinsky 8/6/98 GJ at 187.

910. Lewinsky 8/6/98 GJ at 187.

911. Lewinsky 8/6/98 GJ at 188; 8/26/98 Int. at 2; 8/1/98 Int. at 13.

912. Lewinsky 8/1/98 Int. at 13.

913. Lewinsky 8/6/98 GJ at 190.

914. Lewinsky 8/6/98 GJ at 190-91.

915. Lewinsky 8/2/98 Int. at 1.

916. 902-DC-00000232 (Mr. Carter's day-planner); 902-DC-00000037 (Mr. Carter's bill).

917. Lewinsky 8/6/98 GJ at 192. Mr. Carter agreed that, during one of his meetings with Ms. Lewinsky, he asked her sample questions. Carter 6/18/98 GJ at 110-12.

918. Lewinsky 8/6/98 GJ at 192-93.

919. Carter 6/18/98 GJ at 67-68; Lewinsky 8/6/98 GJ at 194, 199.

920. Lewinsky 8/6/98 GJ at 195.

921. Lewinsky 8/6/98 GJ at 195; Lewinsky 8/2/98 Int. at 3; Lewinsky 2/1/98 Statement at 9 ("That evening Ms. L placed a phone call to Ms. Currie asking her to tell the Pres. that she wanted to speak with him before she signed something the next day. He returned Ms. L's call a few hours later.").

922. Lewinsky 8/6/98 GJ at 196.

923. Lewinsky 8/2/98 Int. at 3. See also Lewinsky 2/1/98 Statement at 9 ("The Pres. told Ms. L. not to worry about the affidavit as he had seen 15 others.").

924. Lewinsky 8/6/98 GJ at 197.

925. Lewinsky 8/6/98 GJ at 197; Lewinsky 2/1/98 Statement at 9 ("Ms. L told him Mr. Carter had asked some sample questions that might be asked of her in the deposition and she didn't know how to answer them.").

926. Clinton 8/17/98 GJ at 126

927. Clinton 8/17/98 GJ at 129.

928. Lewinsky 9/3/98 Int. at 2.

929. Lewinsky 8/6/98 GJ at 198.

930. Lewinsky 8/6/98 GJ at 198.

931. Clinton 8/17/98 GJ at 48-49.

932. Clinton 8/17/98 GJ at 50.

933. Clinton 8/17/98 GJ at 127, 49-50.

934. Lewinsky 8/6/98 GJ at 199-200; Carter 6/18/98 GJ at 70-73. A draft copy of the affidavit, with minor revisions, was found in Ms. Lewinsky's apartment in the course of a consensual search on January 22, 1998.(935)

935. cite

936. Lewinsky 8/6/98 GJ at 200; Lewinsky 2/1/98 Statement at 6 ("After Ms. L received a draft of the affidavit, she called Mr. Jordan to ask that he look it over before she sign it. He instructed her to drop off a copy at his office. They spoke later by phone about the affidavit agreeing to make some changes.").

937. Lewinsky 8/6/98 GJ at 194-95.

938. Lewinsky 8/6/98 GJ at 202.

939. As originally drafted, Paragraph 6 of the affidavit stated: "In the course of my employment at the White House, I met with the President on several occasions. I do not recall ever being alone with the President, although it is possible that while working in the White House Office of Legislative Affairs I may have presented him with a letter for his signature while no one else was present. This would only have lasted a few minutes and would not have been a private meeting, that is, not behind closed doors.(940)

940. 849-DC-00000634. --

941. 849-DC-00000634-35 (emphasis added).

942. Lewinsky 8/6/98 GJ at 202.

943. 849-DC-00000635.

944. Lewinsky 8/6/98 GJ at 202.

945. Jordan 3/5/98 GJ at 11.

946. Jordan 3/5/98 GJ at 11.

947. See Telephone Calls, Table 35. Catalogs of relevant phone calls are included in Appendix G as a Phone Log, Tables 1 through 50.

948. Carter 6/18/98 GJ at 76-77, 92-93.

949. 902-DC-00000030 (Mr. Carter's bill to Ms. Lewinsky).

950. Jordan 5/5/98 GJ at 210, 214.

951. Jordan 5/5/98 GJ at 218-20.

952. 902-DC-00000232 (Mr. Carter's day-planner).

953. Lewinsky 8/6/98 GJ at 204-05. As to the sentence, "I have never had a sexual relationship with the President," she testified that this was not true.(954)

954. Lewinsky 8/6/98 GJ at 204. (955)

955. Lewinsky 8/6/98 GJ at 205.

956. Carter 6/18/98 GJ at 108.

957. Jordan 5/5/98 GJ at 222. See also Jordan 3/3/98 GJ at 192; Jordan 3/5/98 GJ at 11; Jordan 5/28/98 GJ at 62. Ms. Lewinsky testified that she told Mr. Jordan on January 6, that she would be signing an affidavit the next day. On January 13, she showed him a copy. Lewinsky 8/6/98 GJ at 200, 220.

958. See Telephone Calls, Table 36.

959. Jordan 3/5/98 GJ at 24-26.

960. Jordan 5/5/98 GJ at 223-25.

961. Jordan 5/5/98 GJ at 225.

962. Jordan 5/5/98 GJ at 226.

963. Clinton 1/17/98 Depo. at 72.

964. Clinton 8/17/98 GJ at 74.

965. Clinton 8/17/98 GJ at 75.

966. Durnan 3/27/98 Int. at 1.

967. Durnan 3/27/98 Int. at 2.

968. Durnan 3/27/98 Int. at 2.

969. Lewinsky 8/6/98 GJ at 206.

970. Lewinsky 8/6/98 GJ at 207-08.

971. See Telephone Calls, Table 37, Call 6.

972. Jordan 5/5/98 GJ at 230.

973. Jordan 5/5/98 GJ at 231. Asked whether he had ever spoken with Mr. Perelman in the past in the context of a job referral, Mr. Jordan could remember three persons for whom he had made referrals: David Dinkins, the former Mayor of New York City;(974)

974. Jordan 3/5/98 GJ at 56.

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