Return to Narrative III - VI
439. Lewinsky 8/6/98 GJ at 156. See also Lewinsky 8/20/98 GJ
at 72; Lewinsky 8/26/98 Depo. at 47; Currie 5/6/98 GJ at 101-102;
Catherine Davis 3/17/98 GJ 30-31; Erbland 2/12/98 GJ at 40-41;
Finerman 3/18/98 Depo. at 15-16; Marcia Lewis 2/10/98 GJ at 51-52; Raines 1/29/98 GJ at 53-55.
A draft of Ms. Lewinsky's thank-you note (to "Dear Mr. P")
was found in her apartment. It says in part:
All of my life, everyone has always said that I am a
difficult person for whom to shop, and yet, you managed to
choose two absolutely perfect presents! A little phrase
(with only eight letters) like "thank you" simply cannot
begin to express what I feel for what you have given me.
Art & poetry are gifts to my soul!
I just love the hat pin. It is vibrant, unique and a
beautiful piece of art. My only hope is that I have a hat
fit to adorn it (ahhh, I see another excuse to go shopping)!
I know that I am bound to receive compliments on it.
I have only read excerpts from "Leaves of Grass" before
-- never in its entirety or in such a beautifully bound
edition. Like Shakespeare, Whitman's writings are so
timeless. I find solace in works from the past that remain
profound and somehow always poignant. Whitman is so rich
that one must read him like one tastes a fine wine or good
cigar -- take it in, roll it in your mouth, and savor it!
I hope you know how very grateful I am for these gifts,
especially your gift of friendship. I will treasure them
all . . . always.
MSL-DC-00000621 - 622 (emphasis in original) (ellipsis in original). Ms. Lewinsky said she sent a version of this letter to the President and enclosed a necktie. Lewinsky 8/4/98 Int. at 5.
440. Lewinsky 8/24/98 Int. at 7; Finerman 3/18/98 Depo. at 22; Raines 1/29/98 GJ at 109.
441. Lewinsky 8/26/98 Depo. at 47-48. See also Lewinsky 8/6/98 GJ at 31, 38-39.
442. Lewinsky 8/26/98 Depo. at 47-48. See also Lewinsky 8/6/98 GJ at 31, 38-39.
443. Lewinsky 7/30/98 Int. at 15.
444. Lewinsky 8/26/98 Depo. at 48.
445. Lewinsky 8/6/98 GJ at 32, 39-40. Ms. Lewinsky testified that she did not keep the soiled dress as a souvenir. She said she does not ordinarily clean her clothes until she is ready to wear them again. "I was going to clean it. I was going to wear it again." Lewinsky 8/6/98 GJ at 41. She also testified that she was not certain that the stains were semen. She had dined out after the radio address, "[s]o it could be spinach dip or something." Lewinsky 8/6/98 GJ at 40. See also Lewinsky 7/29/98 Int. at 17.
446. FBI Lab Reports, 8/6/98, 8/17/98.
447. Clinton 8/17/98 GJ at 55.
448. Clinton 8/17/98 GJ at 138.
449. Clinton 8/17/98 GJ at 136-37.
450. V006-DC-00000008 (WAVES records); V006-DC-00001792 (WAVES request). Phone records indicate that Ms. Lewinsky called Ms. Currie for one minute at 8:37 a.m. that day. 1014-DC-00000022.
451. 968-DC-00000236 (presidential diary); V006-DC-00002130 (movement log); 968-DC-00003510 (phone log). Mrs. Clinton was in Africa. 968-DC-00003843 (schedule).
452. Lewinsky 7/30/98 Int. at 16; Lewinsky 8/20/98 GJ at 67-69; Lewinsky 8/24/98 Int. at 7.
453. Lewinsky 8/26/98 Depo. at 49.
454. Lewinsky 8/26/98 Depo. at 50.
455. Lewinsky 8/26/98 Depo. at 50.
456. Lewinsky 8/26/98 Depo. at 51. See also Lewinsky 8/20/98 GJ at 68-69; Lewinsky 7/30/98 Int. at 16. Ms. Lewinsky testified that their genitals only briefly touched: "[W]e sort of had tried to do that, but because he's so tall and he couldn't bend because of his knee, it didn't really work." Lewinsky 8/26/98 Depo. at 51.
457. Lewinsky 8/20/98 GJ at 68-69; Lewinsky 8/26/98 Depo. at 50; Lewinsky 7/30/98 Int. at 16.
458. Lewinsky 7/30/98 Int. at 16.
459. Clinton 8/17/98 GJ at 10.
460. Clinton 8/17/98 GJ at 54-55, 137-38.
461. Lewinsky 8/6/98 GJ at 66; Lewinsky 7/27/98 Int. at 5; Lewinsky 7/31/98 Int. at 8; Lewinsky 2/1/98 Statement at 1-2; MSL-DC-00001052; T1 at 38. Mr. Nash said he had never heard of Ms. Lewinsky before January 1998. Nash 3/19/98 Int. at 1; Nash 9/2/98 Int. at 1.
462. Lewinsky 8/6/98 GJ at 67.
463. Lewinsky 8/6/98 GJ at 66-67; Lewinsky 7/27/98 Int. at 5; Lewinsky 8/5/98 Int. at 2.
464. Lewinsky 8/6/98 GJ at 86-87.
465. Lewinsky 8/26/98 Depo. at 62.
466. Clinton 8/17/98 GJ at 113-14. Later the President said: "I didn't order her to be hired at the White House. I could have done so. I wouldn't do it."(467)
467. Clinton 8/17/98 GJ at 124.
468. Lewinsky 8/6/98 GJ at 97-99; Lewinsky 7/27/98 Int. at 3.
469. Lewinsky 8/6/98 GJ at 87; Lewinsky 7/27/98 Int. at 3.
470. Lewinsky 8/6/98 GJ at 98-99; Lewinsky 7/27/98 Int. at 3. See also Lewinsky 9/3/98 Int. at 1.
471. Kaye 5/21/98 GJ at 103-108. Ms. Finerman testified that she did have a conversation along these lines with Mr. Kaye. Finerman 3/18/98 Depo. at 52-57. Mr. Kaye testified that he could not recall having discussed Ms. Lewinsky with Ms. Scott. Kaye 5/21/98 GJ at 44. Ms. Scott testified that she could not recall talking to Mr. Kaye about Ms. Lewinsky in this period, or talking to him about phone calls between Ms. Lewinsky and the President at any time. Scott 3/31/98 GJ at 53.
472. 827-DC-00000018 (Epass records).
473. 1222-DC-00000242.
474. 968-DC-00003533.
475. Lewinsky 8/4/98 Int. at 2-3.
476. Lewinsky 8/6/98 GJ at 24-25, 101.
477. Lewinsky 8/4/98 Int. at 2; Lewinsky 7/31/98 Int. at 16.
478. Lewinsky 8/4/98 Int. at 2-3.
479. Lewinsky 8/4/98 Int. at 3. Ms. Lewinsky later told
confidants about the May 24 break-up. Catherine Davis 3/17/98 GJ
at 133-35; Erbland 2/12/98 GJ at 46-47; Kassorla 8/28/98 Int. at
4; Raines 1/29/98 GJ at 58-59; Tripp 7/14/98 GJ at 78-84; Ungvari
3/19/98 GJ at 80. Dr. Kassorla, Ms. Lewinsky's therapist, told
Ms. Lewinsky that the President's statement sounded rehearsed and
insincere. Kassorla 8/28/98 Int. at 4.
A fragment of a deleted file recovered from Ms. Lewinsky's
home computer apparently refers to the President's May 24
announcement:
. . . cannot do anything but accept that. However, I also
cannot ignore what we have shared together. I don't care
what you say, but if you were 100% fulfilled in your
marriage I never would have seen that raw, intense sexuality
that I saw a few times -- watching your mouth on my breast
or looking in your eyes while you explored the depth of my
sex. Instead, it would have been a routine encounter void
of anything but a sexual release. I do not want you to
breach your moral standard . . . .
MSL-55-DC-0094; MSL-55-DC-0124 (spelling and punctuation corrected).
480. Lewinsky 8/6/98 GJ at 25. See also Lewinsky 7/27/98 Int. at 3 (birthday kiss 8/16/97; Christmas kiss 12/28/97); id. at 7 (President told her that Christmas kiss was permissible). Ms. Lewinsky tried to initiate genital contact with the President on August 16, 1997, but he rebuffed her. Lewinsky 8/20/98 GJ at 70.
481. Clinton v. Jones, 117 S. Ct. 1636 (1997).
482. Currie 5/6/98 GJ at 31-33; Currie 5/7/98 GJ at 44, 68; Currie 5/14/98 GJ at 6-8, 148. Ms. Currie was uncertain when this occurred. Currie 5/6/98 GJ at 31.
483. Currie 5/6/98 GJ at 45; Currie 5/14/98 GJ at 146.
484. Currie 5/14/98 GJ at 146.
485. Currie GJ 5/14/98 at 121; Currie GJ 5/6/98 at 13, 81.
486. Currie 5/7/98 GJ at 43-44.
487. Currie 5/7/98 GJ at 68.
488. Currie 5/7/98 GJ at 69. Contrary to Ms. Currie's testimony, Ms. Scott testified that the President never asked her to help Ms. Lewinsky, though they may have discussed it. In
Ms. Scott's account, she met with Ms. Lewinsky as a favor to Ms. Currie. Scott 3/19/98 GJ at 20, 32, 37, 78-79, 84-85; Scott 3/26/98 GJ at 13, 15; Scott 3/31/98 GJ at 43-44. For his part, the President testified that he talked with Ms. Scott about bringing Ms. Lewinsky back to work at the White House, though he did not order her to hire Ms. Lewinsky. Clinton 8/17/98 GJ at 130.
489. Lewinsky 8/6/98 GJ at 67; Lewinsky 8/24/98 Int. at 7. Ms. Lewinsky also tried to get a White House job through other avenues. She applied for a position at the National Security Council and had interviews there on May 1 and June 11. Lewinsky 7/27/98 Int. at 5; Bailey 5/26/98 GJ at 23; Dimel 2/18/98 Int. at 1; Friedrich 7/17/98 Int. at 1; Stott 2/27/98 Int. at 2; V006-DC-00000008 (WAVES records); 827-DC-00000018 (Epass records); 833-DC-00001876 (Tripp email regarding a job announcement); V006-DC-00000221 - 224 (Dimel documents). She was not chosen for the job. V006-DC-00000223 - 224 (Dimel letter). She also pursued a job in the White House press office. Lewinsky 7/27/98 Int. at 5. At one point Ms. Lewinsky told the President that she had applied for these jobs, and he responded that he needed to know in advance if he was to help her. Lewinsky 7/27/98 Int. at 5.
490. 827-DC-00000018 (Epass records); V006-DC-00000008 (WAVES records); Scott GJ 3/19/98 at 17.
491. 1037-DC-00000265- 266 (spelling and punctuation corrected). See also Finerman 3/18/98 Depo. at 50-51 (recounting this meeting); Tripp 7/14/98 GJ at 89-91 (recounting this meeting).
492. Scott 3/19/98 GJ at 52. See also Scott 3/26/98 GJ at 16-17.
493. Scott 3/19/98 GJ at 74.
494. Scott 3/19/98 GJ at 87.
495. 833-DC-00001070.
496. Currie 5/7/98 GJ at 35; see id. at 39.
497. MSL-DC-00001176 - 1177. A revised version of the letter was also found in Ms. Lewinsky's apartment. MSL-DC-00001192. Consistent with a statement in the draft, Ms. Scott testified that "I don't hear about White House jobs." Scott 3/19/98 GJ at 90. Ms. Scott also testified that she recalled only a short thank-you note after her June 16 meeting with Ms. Lewinsky, though she did receive a "real pissy letter" from Ms. Lewinsky at some point, which she threw away. Scott 3/19/98 GJ at 77; Scott 3/26/98 GJ at 18.
498. MSL-DC-00001227 (emphasis in original). Ms. Lewinsky sent a version of the note. Lewinsky 8/4/98 Int. at 6. Records indicate that Ms. Lewinsky was in Madrid the following week and in Los Angeles later in the month. MSL-DC-00001221; 852-DC-00000035; 929-DC-00000056; 852-DC-00000037.
499. 1037-DC-00000103, 1037-DC-00000280, 1037-DC-00000296 (email from Catherine Davis to Ms. Lewinsky referring to "[y]our idea about working in another city or country") (multiple copies of same message).
500. Lewinsky 7/29/98 Int. at 8.
501. Lewinsky 8/6/98 GJ at 68, 87; Lewinsky 7/29/98 Int. at 7-8; Lewinsky 8/11/98 Int. at 6.
502. Lewinsky 8/6/98 GJ at 68, 87. See also Lewinsky 7/29/98 Int. at 7-8; Lewinsky 8/11/98 Int. at 6.
503. Lewinsky 8/6/98 GJ at 68-69, 87-89. See also Lewinsky 8/26/98 Depo. at 62-63.
504. Lewinsky 8/6/98 GJ at 68, 87; Lewinsky 7/29/98 Int. at 7-8; Lewinsky 8/11/98 Int. at 6.
505. Lewinsky 7/29/98 Int. at 8; Lewinsky 8/13/98 Int. at 1. Ms. Lewinsky said she thought of the United Nations because a former Pentagon colleague worked there and liked it. Lewinsky 8/13/98 Int. at 1.
506. Clinton 8/17/98 GJ at 124.
507. Lewinsky 8/6/98 GJ at 69. See also Lewinsky 7/29/98 Int. at 8.
508. Lewinsky 8/6/98 GJ at 69. See also Lewinsky 7/29/98 Int. at 7.
509. 827-DC-00000018.
510. V006-DC-00002140; V006-DC-00002214.
511. Lewinsky 8/6/98 GJ at 75. See also Lewinsky 7/29/98 Int. at 8; Lewinsky 8/4/98 Int. at 4.
512. Lewinsky 7/29/98 Int. at 8-9.
513. Lewinsky 8/26/98 Depo. at 54-55; Lewinsky 7/27/98 Int. at 3.
514. Lewinsky 8/26/98 Depo. at 55-56.
515. Lewinsky 8/26/98 Depo. at 56-57. See also Lewinsky 7/28/98 Int. at 6.
516. Lewinsky 8/26/98 Depo. at 56-57. See also Catherine Davis 3/17/98 GJ at 180; Tripp 7/7/98 GJ at 55-56; 845-DC-00000193 (Tripp notes).
517. Lewinsky 8/6/98 GJ at 72. See also Lewinsky 8/4/98 Int. at 4.
518. Lewinsky 8/6/98 GJ at 70-71; Tripp 7/14/98 GJ at 107-116.
519. Lewinsky GJ 8/6/98 at 72, 77; Lewinsky 302 7/29/98 at 7. According to Ms. Tripp, she had tried to alert Mr. Lindsey about the contact from Mr. Isikoff, but Mr. Lindsey, with whom she had worked at the White House, did not return her calls and pages. Ms. Tripp testified that she tried to reach him because "he was one of the protectors" of the President. Tripp 7/14/98 GJ at 111. Mr. Lindsey testified that he returned a page from Ms. Tripp, but not until July or August. Lindsey 2/18/98 GJ at 132-33.
520. Lewinsky 8/6/98 GJ at 71.
521. Lewinsky 8/6/98 GJ at 73-74; Lewinsky 7/29/98 Int. at 7.
522. Lewinsky 7/29/98 Int. at 7; Lewinsky 8/11/98 Int. at 5.
523. Lewinsky 8/6/98 GJ at 73; Lewinsky 7/29/98 Int. at 7.
524. 968-DC-00003546.
525. Lewinsky 8/6/98 GJ at 75.
526. 827-DC-00000018; see also Steven Pape 5/18/98 Depo. at
3.
527. V006-DC-00002142 (movement logs).
528. Lewinsky 8/6/98 GJ at 75-76; Lewinsky 7/29/98 Int. at 9.
Ms. Currie did not recall Ms. Lewinsky's visit of July 14.
Currie 7/22/98 GJ at 81.
529. Lewinsky 8/6/98 GJ at 76.
530. 1222-DC-00000251 (movement logs).
531. Lewinsky 8/6/98 GJ at 76. The President was referring
to the Drudge Report, carried on the Internet, which had reported
on July 4 (the day of Ms. Lewinsky's previous White House visit)
that Michael Isikoff of Newsweek was "hot on the trail" of a
story involving "a federal employee sexually propositioned by the
President on federal property." Drudge Report 7/4/97. See also
Washington Post, 8/11/97 at D1 (on Drudge Report's scoop of
Newsweek).
532. Lewinsky 8/6/98 GJ at 76-77.
533. Lewinsky 8/6/98 GJ at 77.
534. Lewinsky 8/6/98 GJ at 77-78; Tripp 7/16/98 GJ at 12.
535. Lewinsky 8/6/98 GJ at 78; Lewinsky 7/27/98 Int. at 3;
Lewinsky 7/29/98 Int. at 10; Tripp 7/14/98 GJ at 117-19; Tripp
7/16/98 GJ at 9.
536. Lewinsky 8/6/98 GJ at 78-79.
537. 968-DC-00003550.
538. Lewinsky 8/6/98 GJ at 79; Tripp 7/16/98 at 12.
539. Lewinsky 8/6/98 GJ at 79-80.
540. Lewinsky 7/29/98 Int. at 10-11. Subsequently, Ms. Tripp
did call Mr. Lindsey. He urged her to contact Robert Bennett,
but she never did so. Lindsey 3/12/98 GJ at 3, 13; Lindsey
2/18/98 GJ at 132-40; Tripp 7/16/98 GJ at 12-14, 54-67, 75-80;
Lewinsky 7/29/98 Int. at 11; T29 at 16; 880-DC-0000002 - 8.
541. Scott 3/19/98 GJ at 64-72.
542. Lewinsky 7/31/98 Int. at 9.
543. Lewinsky 2/1/98 Statement at 2.
544. Scott 3/26/98 GJ at 18-21; Currie 5/7/98 GJ at 68. Ms.
Lewinsky also conferred with her supervisor, Kenneth Bacon, about
being detailed back to the White House. He gave his approval and
sent a letter recommending her. Bailey 2/6/98 Int. at 3; Bacon
2/26/98 Int. at 2-3; 1012-DC-00000001; MSL-DC-00001230.
545. Scott 3/19/98 GJ at 78-79; Scott 3/26/98 GJ at 13-15;
Scott 3/31/98 GJ at 43-44; Currie 5/7/98 GJ at 68.
546. 827-DC-00000018 (Epass records); V006-DC-00000008 (WAVES
records); V006-DC-00001770 (WAVES request).
547. 1222-DC-00000254 (movement logs).
548. 968-DC-00003556 (phone logs).
549. Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7; Lewinsky 8/24/98
Int. at 6.
550. Newsweek, 8/11/97 at 30.
551. 845-DC-00000190 (letter); Tripp 7/16/98 GJ at 85-88.
552. T30 at 166. Ms. Tripp responded: "Oh, God. He thinks
I screwed him in the article. I'm dead." Id.
553. V006-DC-00000008 (WAVES records).
554. V006-DC-00002146 (movement logs). Secret Service
Officer Steven Pape testified about Ms. Lewinsky's August 16
visit. When Ms. Lewinsky entered the complex through the
Southwest Gate, Officer Pape, who was familiar with Ms.
Lewinsky's visits, predicted to another officer that the
President would move to the Oval Office shortly. Officer Pape's
prediction proved accurate: The President moved to the Oval
Office, according to records, 18 minutes after Ms. Lewinsky
entered the White House. Pape 8/5/98 GJ at 20-24; Myrick
8/13/98 GJ at 5-9; V006-DC-00002146 (movement logs); V006-DC-00002095 (movement logs); V006-DC-00002147 (movement logs). See
also Shegogue 8/4/98 GJ at 10-11, 14-15, 17-20 (Secret Service
officer recalling that Ms. Currie escorted Ms. Lewinsky into West
Wing the day before President left for Martha's Vineyard).
555. 968-DC-00003558.
556. 968-DC-00002947.
557. Lewinsky 8/26/98 Depo. at 52. See also Lewinsky 8/20/98
GJ at 70.
558. Lewinsky 8/20/98 GJ at 70; Lewinsky 8/26/98 Depo. at 51-53.
559. Lewinsky 8/26/98 Depo. at 52.
560. DB-DC-00000022 (note dated 11/12/97). Ms. Lewinsky said
that she sent this or a similar note to the President. Lewinsky
7/31/98 Int. at 2. See also 1037-DC-00000583 (email to Catherine
Davis).
561. 1051-DC-00000003 (Pentagon phone records).
562. 1037-DC-00000086 - 87, 1037-DC-00000167, 1037-DC-00000255 - 256, 1037-DC-00000258 - 259 (email to Catherine
Davis); 1318-DC-00000001 (card to Dale Young).
563. 1037-DC-00000086 - 87, 1037-DC-00000167, 1037-DC-00000255 - 256, 1037-DC-00000258 - 259 (email to Catherine Davis)
(spelling and punctuation corrected).
564. Scott 3/26/98 GJ at 142.
565. Lewinsky 8/4/98 Int. at 5.
566. MSL-DC-00001052 (spelling and punctuation corrected).
567. Lewinsky 8/3/98 Int. at 6-7; Lewinsky 8/11/98 Int. at 5.
See also 1037-DC-00000168 (email recounting episode). In mid or
late September, according to Ms. Lewinsky, Ms. Currie told Ms.
Lewinsky that she had spoken with Mr. Podesta. Lewinsky 7/31/98
Int. at 9; Lewinsky 8/13/98 Int. at 2; Lewinsky 2/1/98 Statement
at 2. (Ms. Lewinsky thought that the President was having Ms.
Currie do the "legwork" of getting her a job out of concern about
appearances. Lewinsky 8/13/98 Int. at 3.) Mr. Podesta testified
that he told Ms. Currie to have Ms. Lewinsky call him. Podesta
2/5/98 GJ at 35; Podesta 6/16/98 GJ at 12-19. Ms. Currie
testified that she does not remember getting that response from
Mr. Podesta, and, if she had gotten it, she would have passed it
on to Ms. Lewinsky. Currie 5/14/98 GJ at 149-51. According to
Ms. Lewinsky, Ms. Currie mentioned Mr. Podesta to her in
September 1997, but never told her to call him. Lewinsky 8/24/98
Int. at 7. Subsequently, Ms. Currie asked Mr. Podesta to help
Ms. Lewinsky get a New York job. Lewinsky 2/1/98 Statement at 2-3; Podesta 2/5/98 GJ at 40-43; Podesta 6/16/98 GJ at 13.
568. 1037-DC-00000038 - 040; 1037-DC-00000167 - 169 (email to
Catherine Davis).
569. Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7.
570. 1037-DC-00000038, 1037-DC-00000040, 1037-DC-00000167 -
169. Ms. Lewinsky told several people about the gifts.
Catherine Davis 3/17/98 (571)
571. Catherine Davis GJ 31-32, 109-111; Erbland GJ 39-42;
Finerman depo 14-15; Marcia Lewis GJ 98; Raines GJ 53-55. - -
- -
- - --
- -
572. Lewinsky 7/29/98 Int. at 16; Lewinsky 8/4/98 Int. at 5.
573. MSL-DC-00001050. Beneath the text of the document, at
the bottom of the page, Ms. Lewinsky added: "JUST A REMINDER TO
THROW THIS AWAY AND NOT SEND IT BACK TO THE STAFF SECRETARY!"
Id. The statement that Ms. Lewinsky and the President had not
spent time together in six weeks evidently refers to her August
16 visit, before his vacation.
574. Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7. On September
30, the President signed, under penalty of perjury, interrogatory
responses in the sexual harassment case, answering Ms. Jones's
allegations against him. V002-DC-00000008 - 15.
575. Lewinsky 8/13/98 Int. at 1. In email, Ms. Lewinsky
indicated that it was Ms. Currie who told her that the President
was going to talk to the Chief of Staff. 1037-DC-00000168.
576. Bowles 4/2/98 GJ at 12, 65-73.
577. Bowles 4/2/98 GJ at 67-68.
578. Bowles 4/2/98 GJ at 70, 74-75. Mr. Bowles placed this
incident in late summer or early fall of 1997. Bowles 4/2/98 GJ
at 65-66. Mr. Podesta's account largely matches Mr. Bowles's,
except that Mr. Podesta placed the incident in late spring or
summer of 1997; he understood that Ms. Lewinsky wanted a job in
the White House or an agency; and he recalled being told by Mr.
Bowles that Ms. Lewinsky, according to the President, "thought
that she hadn't been treated fairly" in being transferred to the
Pentagon. Podesta 2/5/98 GJ at 21-22.
579. Lewinsky 8/6/98 GJ at 102. See also Lewinsky GJ 8/6/98
at 102; Lewinsky 7/29/98 Int. at 13; Lewinsky 7/31/98 Int. at 9;
Tripp 7/28/98 GJ at 110-111, 125-26. Ms. Tripp's friend Kate
Friedrich, however, has denied having made the remarks that Ms.
Tripp attributed to her. Friedrich 7/17/98 Int. at 1.
580. Lewinsky 7/31/98 Int. at 10.
581. Lewinsky 8/13/98 Int. at 1.
582. MSL-55-DC-0178 (spelling and punctuation corrected).
583. Lewinsky 8/4/98 Int. at 2-3.
584. T1 at 28.
585. T1 at 24.
586. T1 at 61.
587. T1 at 25.
588. T13 at 19.
589. MSL-55-DC-00000001 (letter); 837-DC-00000001 (courier
receipts); T1 at 97.
590. MSL-55-DC-00000001.
591. Lewinsky 8/6/98 GJ at 103; Lewinsky 7/31/98 Int. at 10.
See also Lewinsky 7/29/98 Int. at 6; Lewinsky 8/6/98 GJ at 27-28
& Ex. ML-7.
592. T13 at 20.
593. T8 at 30. See also Lewinsky 7/31/98 Int. at 10. See
also MSL-55-DC-0177 (draft letter from Ms. Lewinsky to the
President referring to this remark); DB-DC-00000017 (another
draft of same letter).
594. T8 at 30.
595. T8 at 30.
596. T8 at 33.
597. Lewinsky 7/31/98 Int. at 10; Lewinsky 7/27/98 Int. at 5.
598. Lewinsky 7/31/98 Int. at 10.
599. Lewinsky 7/31/98 Int. at 10.
600. Lewinsky 7/31/98 Int. at 11.
601. 827-DC-00000018 (Epass records). Ms. Lewinsky's aunt,
Debra Finerman, wrote in a note that "Monica was called by Betty
to come at 9:30 this a.m." MSL-DC-00000456 (document found in
Ms. Lewinsky's apartment in the course of a consensual search on
January 22, 1998).
602. 952-DC-00000060 (movement logs).
603. Lewinsky 8/6/98 GJ at 27-28 & Exh. ML-7.
604. Lewinsky 8/6/98 GJ at 104; Lewinsky 8/13/98 Int. at 2-3;
T2 at 5.
605. Lewinsky 8/6/98 GJ at 104; Lewinsky 7/31/98 Int. at 11-12. Ms. Lewinsky was not certain whether it was during the
October 11 visit or their October 10 phone conversation that she
first asked the President to speak to Mr. Jordan on her behalf.
Lewinsky 8/6/98 GJ at 104.
606. Lewinsky 8/6/98 GJ at 104; Lewinsky 7/31/98 Int. at 11-12. Ms. Lewinsky later said that the President assured her that
he would call her and give "a report." T13 at 17-18.
607. T2 at 14. In the grand jury, Ms. Currie was shown a
transcript of this recorded conversation and acknowledged that
the meeting described by Ms. Lewinsky "probably happened."
Currie 5/6/98 GJ at 187.
608. T2 at 14. Although it is unclear whether the President
spoke with Mr. Bowles about a recommendation for Ms. Lewinsky in
October, there is evidence he did so on January 13, 1998. See
infra at Section XIII.H.
609. T2 at 10-11.
610. T2 at 11-12.
611. Lewinsky 7/31/98 Int. at 12. Ms. Lewinsky produced a
draft of this document to the OIC on July 31, 1998. Lewinsky
7/31/98 Int. at 3. See also Lewinsky 8/13/98 Int. at 3.
612. DB-DC-00000027 (punctuation corrected) (emphasis in
original). Ms. Lewinsky produced a draft of this document to the
OIC on July 31, 1998. Lewinsky 7/31/98 GJ at 3.
613. DB-DC-00000027. Ms. Lewinsky also indicated that she
would consider a job at one of the networks; she mentioned
"Kaplan," and added that "CNN has a NY office." DB-DC-00000027.
In a recorded conversation, Ms. Lewinsky said that she had told
the President about her interest in television during their
October 11 meeting. The President had responded, "The only one I
know in a network is Kaplan, . . . but his job is in Atlanta."
T2 at 6. See also Lewinsky 7/31/98 Int. at 11. CNN President
Rick Kaplan is a friend of the President.
614. DB-DC-00000027.
615. T7 at 26.
616. T7 at 30.
617. T2 at 21-27. See also Lewinsky 8/6/98 GJ at 27-28 & Ex.
ML-7; Lewinsky 8/11/98 Int. at 4.
618. T2 at 23. In her description, the card was "kind of
cartoony" and said: "This is a test of the emergency insanity
system." T2 at 21. See also Lewinsky 8/13/98 Int at 3.
619. T2 at 26-27.
620. T2 at 27-30. Ms. Lewinsky asked Ms. Currie to leave the
packet under the President's desk.(621)
622. Phone records reflect that, on October 17, Ms. Lewinsky placed two short calls to Ms.
Currie from the Pentagon, one at 11:10 a.m. and the second at 1:06 p.m. 833-DC-00017869 (Ms.
Lewinsky's phone records). There are no records of calls placed by Ms. Currie to Ms. Lewinsky
from the White House. See Nagy 2/19/98 Int. at 4 ("no record of local telephone calls coming
from the White House").
Ms. Currie testified in the grand jury: "I don't remember a large package, only something
with the Plum Book thing in it. And I just don't remember it being a large package." Currie
5/14/98 GJ at 52-53; see also Currie 5/14/98 GJ at 154. (The Plum Book is a government job
search book, listing political appointee and Schedule C jobs. Currie 5/6/98 GJ at 154, 169.) Ms.
Currie also recalled a list that Ms. Lewinsky had prepared about New York public relations
firms. Currie 5/14/98 GJ at 56.
623. Lewinsky 8/13/98 Int. at 4; Lewinsky 8/26/98 Depo. at
61-63.
624. Podesta 2/5/98 GJ at 40-41. See also Lewinsky 7/31/98
Int. at 10. As previously discussed, Ms. Currie had earlier
asked Mr. Podesta to help Ms. Lewinsky obtain a White House job.(625)
625. See supra at [].
626. Podesta 2/5/98 GJ at 40-45; Richardson 4/30/98 Depo. at
28. On Sunday, October 12, 1997, the President traveled to Latin
America for one week. United States President, Weekly
Compilations of Presidential Documents at 1608, 1609, 1653. On
that trip, the President was accompanied by, among others, then-U.N. Ambassador William Richardson and the Deputy Chief of Staff,
John Podesta. Richardson 4/30/98 Depo. at 28-29; Podesta 2/5/98
GJ at 44. Ambassador Richardson recalled that Mr. Podesta had
first made the request prior to the trip to Latin America.
Richardson 4/30/98 Depo. at 28.
627. Podesta 2/5/98 GJ at 45; Richardson 4/30/98 Depo. at 32.
628. Richardson 4/30/98 Depo. at 160-61; Clinton 1/17/98
Depo. at 73.
629. Richardson 4/30/98 Depo. at 26.
630. Watkins 5/27/98 Depo. at 11-12, 18.
631. Podesta 2/5/98 GJ at 46.
632. 828-DC-00000012 (faxed copy of Ms. Lewinsky's resume,
produced by the U.N.); Currie 5/6/98 GJ at 174.
633. 828-DC-00000004 (U.N. phone records).
634. Lewinsky 8/13/98 Int. at 3.
635. Lewinsky 8/26/98 Depo. at 63-64. See also Lewinsky
8/26/98 Depo. at 63-64; Lewinsky 7/31/98 Int. at 12; Lewinsky
7/27/98 Int. at 5.
636. Lewinsky 7/27/98 Int. at 5.
637. Richardson 4/30/98 Depo. at 47-48; Watkins 5/27/98 Depo.
at 27-29. Ms. Watkins further testified that she often placed
calls from the Ambassador's line. Watkins 5/27/98 Depo. at 37-38.
638. Lewinsky 8/13/98 Int. at 3-4.
639. Lewinsky 8/13/98 Int. at 4.
640. Lewinsky 8/13/98 Int. at 4. See also Lewinsky 7/31/98
Int. at 12.
641. Lewinsky 8/26/98 Depo. at 64-65; Lewinsky 7/31/98 Int.
at 13.
642. Lewinsky 8/26/98 Depo. at 65. Ms. Lewinsky wrote an
email to her friend Catherine Allday Davis: "It was nice; the big
creep called Thursday night to give me a pep talk because I was
so afraid I'd sound like an idiot." 1037-DC-00000022 (spelling
corrected).(643)
643. 1037-DC-000000022 (spelling corrected).
644. Lewinsky 7/31/98 Int. at 13. See also Lewinsky 8/26/98
Depo. at 65.
645. Clinton 1/17/98 Depo. at 74.
646. 828-DC-00000023 (Ambassador Richardson's diary
reflecting 7:30 a.m. meeting with Monica Lewinsky). See also
Ambassador Richardson 4/30/98 Depo. at 66-68; Sutphen 5/27/98
Depo. at 7; Cooper 1/27/98 Int. at 1-2; Lewinsky 7/31/98 Int. at
13-14. After meeting with Ms. Lewinsky, Ambassador Richardson
spent the remainder of the day meeting individually with Senators
and Members of Congress. 828-DC-00000023 (Ambassador
Richardson's itinerary for October 31).
647. Richardson 4/30/98 Depo. at 68; Cooper 1/27/98 Int. at
1-2.
648. Richardson 4/30/98 Depo. at 39; Sutphen 5/27/98 Depo. at
15-16; Cooper 1/27/98 Int. at 2.
649. The draft was retrieved from Ms. Lewinsky's computer in
the course of a consensual search on January 22, 1998.
650. MSL-55-DC-0179 (punctuation added)(italics in original).
651. MSL-55-DC-0179.
652. MSL-55-DC-0179. Ms. Lewinsky concluded the letter, "I
was pleased the UN interview went well, but I'm afraid it will be
like being at the Pentagon in NY. . . YUCK!" MSL-55-DC-0179
(ellipsis in original).
653. Lewinsky 8/13/98 Int. at 4-5; Lewinsky 7/31/98 Int. at
14; Lewinsky 7/27/98 Int. at 5.
654. 828-DC-00000003.
655. Lewinsky 8/26/98 Depo. at 67; Lewinsky 7/27/98 Int. at
5; Lewinsky 7/31/98 Int. at 14; Lewinsky 8/13/98 Int. at 5.
According to Ambassador Richardson, the position offered to
Ms. Lewinsky was not newly created. He testified that he
intended to expand an open position in the U.N.'s Washington
office and move it to New York. Richardson 4/30/98 Depo. at 39-40. Although Ambassador Richardson did not recall whether this
opening was publicized, he testified that it would be common for
the office not to post Schedule C (political appointment)
positions. Richardson 4/30/98 Depo. at 71-72. Peter Aronsohn,
who filled the position Ms. Lewinsky was offered, characterized
the job as a "new position." Aronsohn 8/27/98 Int. at 2.
656. Sutphen 5/27/98 Depo. at 26.
657. Richardson 4/30/98 Depo. at 90-91; Sutphen 5/27/98 Depo.
at 21-23.
658. Lewinsky 8/26/98 Depo. at 65-66; Lewinsky 8/13/98 Int.
at 4.
659. Currie 5/6/98 GJ at 174-75, 181; Currie 5/14/98 GJ at
65-66.
660. Clinton 1/17/98 Depo. at 73.
661. Sutphen 5/27/98 Depo. at 32-33; Lewinsky 8/13/98 Int. at
5.
662. Sutphen 5/27/98 Depo. at 33. See also Richardson
4/30/98 Depo. at 110-11 (recalling Ms. Lewinsky's request for
additional time to consider the offer).
663. Lewinsky 7/27/98 Int. at 5; Sutphen 5/27/98 Depo. at 38;
1013-DC-00000095 (toll records for Debra Finerman).
664. 921-DC-00000101 - 118 (Second Set of Interrogatories
from Plaintiff to Defendant Clinton).
665. V002-DC-00000016; V002-DC-00000020-21.
666. See supra at IX.B. See also Lewinsky 8/6/98 GJ at 104;
Lewinsky 7/31/98 Int. at 11-12.
667. MSL-55-DC-0179.
668. Lewinsky 7/31/98 Int. at 14.
669. Lewinsky 7/31/98 Int. at 14. Phone records reflect that
on November 4 at 3:54 p.m., Ms. Lewinsky placed a three-and-a-half-minute call to Mr. Jordan's office; at 4:09 p.m., Mr. Jordan
placed a one-minute call to Ms. Currie; and at 4:38 p.m., Mr.
Jordan placed a one-minute call to Ms. Currie. 833-DC-00017875
(Ms Lewinsky's phone records); V004-DC-00000134 (Akin, Gump phone
records).
670. T2 at 11-12. See also Lewinsky 7/31/98 Int. at 11.
671. Jordan 5/5/98 GJ at 47 (Mr. Jordan testified that he
believed the President had told Ms. Currie to "[c]all Vernon and
ask Vernon to help her").
672. Currie 5/6/98 GJ at 169-70, 176-78, 182-83, 198.
673. Clinton 1/17/98 Depo. at 81.
674. Clinton 1/17/98 Depo. at 82.
675. 1178-DC-00000011 (call logs).
676. Lewinsky 7/31/98 Int. at 14.
677. Lewinsky 7/31/98 Int. at 14-15.
678. Lewinsky 8/13/98 Int. at 3.
679. Lewinsky 8/6/98 GJ at 106; Lewinsky 7/31/98 Int. at 14-15; Lewinsky 7/27/98 Int. at 8, 10. Ms. Lewinsky later quoted
the remark in email to a friend.(680)
680. 1037-DC-00000017 (email retrieved from Ms. Davis's computer). --
681. 1037-DC-00000017 (email retrieved from Catherine Davis's
computer).
682. Jordan 3/3/98 GJ at 13.
683. V004-DC-00000135 (Akin, Gump phone records).
684. Jordan 5/5/98 GJ at 54.
685. 1178-DC-00000026 (WAVES record). Ms. Lewinsky would
learn of the meeting between the President and Mr. Jordan. In
email to a friend dated November 6, Ms. Lewinsky wrote that Mr.
Jordan had "[seen] the big creep yesterday afternoon." 1037-DC-00000017 (spelling corrected) (email to Catherine Davis).
686. Jordan 5/5/98 GJ at 34.
687. 833-DC-00000980 (letter retrieved from Ms. Lewinsky's
Pentagon computer)(spelling corrected).
688. 1037-DC-00000017 (email retrieved from Catherine Davis's
computer). Ms. Lewinsky wrote that she was "a little nervous to
do the whole name of the BF. His first name is Vernon." Id.
According to her aunt, Debra Finerman, Ms. Lewinsky used the code
name "Gwen" when discussing Mr. Jordan because "he's an important
person" and Ms. Lewinsky "always had the feeling somebody was
listening in" on their phone conversations, they did not want an
eavesdropper to know that Mr. Jordan was helping her find a job.
Finerman 3/18/98 Depo. at 60. See also Lewinsky 8/5/98 Int. at
3; Lewinksy 8/3/98 Int. at 9.
689. Jordan 3/3/98 GJ at 50.
690. Jordan 5/5/98 GJ at 26-30, 34.
691. Epass records reflect that Ms. Lewinsky entered the
White House at 6:20 p.m., admitted by Ms. Currie. 827-DC-00000018. Secret Service Movement logs show that the President
entered the State Floor at 5:23 and moved to the Oval Office at
6:34. V006-DC-00002156.
692. 1037-DC-00000318 (email retrieved from Catherine Davis's
computer).
693. Lewinsky 8/13/98 Int. at 5.
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.
Return to Narrative VII - XI