Return to Narrative IX - XIII

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. ⁽⁹⁷⁵⁾

975. Jordan 3/5/98 GJ at 56. She went on to become the "number two" person in Revlon's Washington office. Jordan 3/5/98 GJ at 56-57. ⁽⁹⁷⁶⁾

976. Jordan 3/5/98 GJ at 58. -

977. Perelman 4/23/98 Depo. at 10.

978. Perelman 4/23/98 Depo. at 11. In his testimony before the House Government and Reform Oversight Committee, Mr. Jordan testified that he helped former Associate Attorney General Webster Hubbell be retained by Revlon by introducing him to Howard Gittes, Vice Chairman and Chief Administrative Officer at MacAndrews & Forbes.⁽⁹⁷⁹⁾

979. Jordan 7/24/97 House of Representatives Testimony at 35-37. ⁽⁹⁸⁰⁾

980. Id. at 38. ⁽⁹⁸¹⁾

981. Id. -

982. Jordan 5/5/98 GJ at 232. Ms. Lewinsky similarly testified that Mr. Jordan called her back that evening and told her "not to worry."⁽⁹⁸³⁾

983. Lewinsky 8/6/98 GJ at 209.

984. Lewinsky 8/6/98 GJ at 209.

985. See Telephone Calls, Table 37. In addition, Mr. Jordan placed a two-minute call to a number at the White House Counsel's office from his limousine at 6:39 p.m.

986. Jordan 5/28/98 GJ at 19.

987. Jordan 5/28/98 GJ at 20-21. Ms. Mills does not recall having any discussions with Mr. Jordan about Ms. Lewinsky prior to January 17, 1998. Indeed, she had no recollection of hearing Ms. Lewinsky's name prior to January 17. Mills 8/11/98 GJ at 10-11.

988. Seidman 4/23/98 Depo. at 37-38.

989. Lewinsky 8/6/98 GJ at 210.

990. Lewinsky 8/6/98 GJ at 210.

991. Jordan 5/28/98 GJ at 30.

992. Jordan 5/28/98 at 39.

993. Jordan 5/28/98 GJ at 59. Mr. Jordan added that the President's response was one of "appreciation, gratitude." Id.

994. 921-DC-00000770-72 (Clerk's minutes of in-camera hearing).

995. Sheldon 4/34/98 Depo. at 22.

996. Lewinsky 8/6/98 GJ at 214.

997. Lewinsky 8/6/98 GJ at 215.

998. 831-DC-00000010. At some point, Ms. Currie and Ms. Lewinsky decided that they would use a code name -- Kay -- when leaving messages for each other. Currie 7/22/98 GJ at 175; Lewinsky 8/6/98 GJ at 215-17.

999. Bowles 4/2/98 GJ at 78-79. Mr. Bowles placed this conversation with the President at some time between January 4 and January 20. Bowles 4/2/98 GJ at 78. Mr. Podesta recalled that Mr. Bowles passed this request on to him "three or four days before the President's deposition" -- that is, January 13 or January 14, though Mr. Podesta did not know who had originated the request. Podesta 6/16/98 GJ at 21-22.

1000. Bowles 4/2/98 GJ at 78.

1001. Bowles 4/2/98 GJ at 78-79; Podesta 6/16/98 GJ at 24-28; Hilley 2/11/98 Int. at 2; Hilley 5/26/98 GJ at 7-11.

1002. Podesta 6/16/98 GJ at 24; Hilley 2/11/98 Int. at 2.

1003. Hilley 2/11/98 Int. at 2; Hilley 5/26/98 GJ at 10-11; Hilley 5/19/98 GJ at 74-76. In the grand jury, Mr. Hilley testified: "At this time, I don't recall that piece of the conversation [dealing with Ms. Lewinsky's leaving Legislative Affairs under less than favorable circumstances] with John Podesta." Id. at 76.

1004. Lewinsky 8/6/98 GJ at 215. At 2:20 p.m., Ms. Currie paged Ms. Lewinsky again: "Please call me. Kay." 831-DC-00000010. In the grand jury, Ms. Currie stated that she could not remember whether the January 13 page-messages to Ms. Lewinsky involved attempts to notify her of the status of the President's efforts to secure a letter of recommendation for her.⁽¹⁰⁰⁵⁾

1005. Currie GJ 7/22/98 at 147-148. -

1006. 830-DC-00000007.

1007. Clinton 8/17/98 GJ at 111-13.

1008. Lewinsky 8/6/98 GJ at 220-21. Mr. Jordan traveled to Florida in the early afternoon. 1034-DC-00000109 (Mr. Jordan's day-planner). Soon after arriving in Florida, he called Ms. Hernreich's line at the White House. See Telephone Calls, Table 42. Later that evening, he spoke with the President for nearly four minutes. 1064-DC-00000008 (Mr. Jordan's hotel bill). In the grand jury, Mr. Jordan testified that it is "not inconceivable" that they mentioned Ms. Lewinsky. Jordan 5/28/98 GJ at 69.

1009. T30 at 61.

1010. T30 at 114.

1011. T30 at 169-70.

1012. Lewinsky 8/6/98 GJ at 223-25; GJ Ex. ML-5.

1013. Lewinsky 8/6/98 GJ at 223-37. Ms. Tripp, in contrast, testified that she believed Ms. Lewinsky received assistance in drafting the talking points. Tripp 7/29/98 GJ at 167, 171-172.

1014. Currie 5/6/98 GJ at 120-21.

1015. Currie 5/6/98 GJ at 130.

1016. Akin, Gump records reflect that at some time this day Ms. Currie left a message for Mr. Jordan. The message slip listed the name of the caller as "Betty/Potus." The message was: "Kind of important." V005-DC-00000058.

1017. Lewinsky 8/6/98 GJ at 229. Ms. Currie had immediately informed Ms. Lewinsky of Mr. Isikoff's call. 831-DC-00000008 (Ms. Lewinsky's pager records).

1018. Jordan 3/5/98 GJ at 71.

1019. Jordan 3/5/98 GJ at 71.

1020. T22 at 12.

1021. T22 at 12-13.

1022. Ungvari 3/19/98 GJ at 61.

1023. V0002-DC-00000093-116 (President Clinton's Responses to Plaintiff's Second Set of Requests).

1024. 1441-DC-00001534-46 (Second Set of Requests From Plaintiff to Defendant Clinton for Production of Documents). Ms. Lewinsky's name was misspelled on the document request as Ms. Lewisky.

1025. 921-DC-00000775 - 778.

1026. Carter 6/18/98 GJ at 123.

1027. 921-DC-00000775. Although the motion (and affidavit) reached the Judge's chambers on January 17, the file stamp date was January 20, 1998.

1028. Clinton 1/17/98 Depo. at 1 (849-DC-00000352 et seq.).

1029. Clinton 1/17/98 Depo. at 1-2.

1030. Clinton 1/17/98 Depo. at 10.

1031. Clinton 1/17/98 Depo. at 22-23; 849-DC-00000586 (Clinton Depo. Ex. 1).

1032. Clinton 1/17/98 Depo. at 54.

1033. Clinton 1/17/98 Depo. at 54. In addition, as previously indicated, Mr. Jordan believes he informed President Clinton on January 7 that Ms. Lewinsky had signed an affidavit denying that there had been a sexual relationship. Jordan 5/5/98 GJ at 223-25.

1034. Clinton 1/17/98 Depo. at 53-56.

1035. Clinton 1/17/98 Depo. at 50-51, 58-59.

1036. Clinton 1/17/98 Depo. at 52-53, 59.

1037. Clinton 1/17/98 Depo. at 59.

1038. Clinton 1/17/98 Depo. at 62-64.

1039. Clinton 1/17/98 Depo. at 75-77.

1040. Clinton 1/17/98 Depo. at 75-76.

1041. Clinton 1/17/98 Depo. at 75.

1042. Clinton 1/17/98 Depo. at 68.

1043. Clinton 1/17/98 Depo. at 68-71.

1044. Clinton 1/17/98 Depo. at 72, 79-83.

1045. Clinton 1/17/98 Depo. at 78.

1046. Clinton 1/17/98 Depo. at 212-13.

1047. Podesta 6/16/98 GJ at 62.

1048. Lindsey 2/19/98 GJ at 12-13. Mr. Lindsey refused to reveal the content of these conversations with the President, citing the presidential communication, deliberative process, and attorney-client privileges, both officially and privately, as well as the attorney work product doctrine. Id. at 13.

1049. Lindsey 2/19/98 GJ at 14-15.

1050. See Telephone Table 46, Call 4; Currie 1/27/98 GJ at 65-66; Currie 5/7/98 GJ at 79-85; Currie 7/22/98 GJ at 154. See also Currie 1/24/98 Int. at 5-6 ("CURRIE advised that sometime late that evening, she received a telephone call from CLINTON. CURRIE advised that CLINTON said he and CURRIE needed to talk. CURRIE advised it was too late to do anything that evening, so she and CLINTON agreed to meet at the White House at 5 p.m. the following day, Sunday, January 18, 1998."). Presidential call logs reflect that the President attempted to call Ms. Currie at 7:02 p.m. on January 17, 1998, and that he spoke to her for two minutes at 7:13 p.m. 1248-DC-00000307.

1051. Currie 5/7/98 GJ at 91. Also that evening, the President called Mr. Jordan, who testified that they did not discuss the afternoon deposition. See Telephone Table 46, Call 2; Jordan 5/28/98 GJ at 94-95.

1052. Currie 1/27/98 GJ at 70.

1053. Currie 1/27/98 GJ at 67.

1054. Currie 1/27/98 GJ at 76.

1055. Currie 1/27/98 GJ at 70, 76; 7/22/98 GJ at 6, 22. Presidential call logs reflect that the President called Ms. Currie before their meeting and spoke to her from 1:11 p.m. to 1:14 p.m. on January 18. 1248-DC-00000313.

1056. Currie 1/27/98 GJ at 70.

1057. Currie 1/27/98 GJ at 73 ("[M]y impression was that he was just making statements.").

1058. Currie 1/24/98 Int. at 6-7. The President repeated these statements to Ms. Currie a few days later. See infra.

1059. Currie 1/27/98 GJ at 71-74; 7/22/98 GJ at 6-7, 10-11, 79. See also Clinton 8/17/98 GJ at 55-57. According to Ms. Currie, the way the President phrased the inquiries made them sound like both questions and statements at the same time. Currie 1/24/98 Int. at 6.

1060. Currie 1/27/98 GJ at 74-75. ⁽¹⁰⁶¹⁾

1061. Currie 1/27/98 GJ at 69-76; Currie 7/22/98 GJ at 6-16. Ms. Currie did alter a statement that she previously made to the FBI agents shortly after the events in question. Ms. Currie explained that the President's statement to her that, "She wanted to have sex with me, and I can't do that," appeared simply intended as a statement, not a statement he wanted Ms. Currie to agree with. Currie 1/27/98 GJ at 73; Currie 7/22/98 GJ at 23. - ⁽¹⁰⁶²⁾

1062. Currie 1/27/98 GJ at 75-76; Currie 7/22/98 GJ at _____.. -

1063. Currie 1/27/98 GJ at 71, 75.

1064. Currie 7/22/98 GJ at 65-66. Indeed, she testified that, at some point after January 18, she heard that Ms. Lewinsky visited the Oval Office on Saturdays, one of her days off. Currie 7/22/98 GJ at 65-66.

1065. Currie 1/27/98 GJ at 32-33; 36-38.

1066. Currie 7/22/98 GJ at 12, 15-6; Currie 1/27/98 GJ at 76.

1067. Currie 7/22/98 GJ at 14. The President, apparently, had a similar understanding of "alone." Before the grand jury, the President explained that "when I said, we were never alone, right . . . I meant that she [Ms. Currie] was always in the Oval Office complex, in that complex, while Monica was there." Clinton 8/17/98 GJ at 132.

Elsewhere in her testimony, Ms. Currie appeared to have a different understanding of "alone." She testified that, on one occasion, because others observed Ms. Lewinsky in the Oval Office complex, Ms. Currie accompanied Ms. Lewinsky into the Oval Office, where the President was working. Ms. Currie explained that she waited in the dining room while Ms. Lewinsky and the President met in the study so "[t]hey would not be alone." Currie 7/22/98 GJ at 130. See also Clinton 8/17/98 GJ at 56 ("I asked her specifically . . . to remain in the dining room, Betty, while I met with Monica in my study."). Ms. Currie testified that she did not want people who had observed Ms. Lewinsky enter the Oval Office to think that she and the President were "alone." Currie 7/22/98 GJ at 132.

1068. Currie 7/22/98 GJ at 79. Ms. Currie testified: "The way the question was phrased to me at the time, I answered, 'Right.' It seemed to me that was the correct answer for me to give . . . the '[c]ome on to me,' I considered that more of a statement as opposed to a question." Id. at 80.

1069. Currie 1/27/98 GJ at 75.

1070. Currie 1/27/98 GJ at 83.

1071. Currie 1/27/98 GJ at 72-73; 7/22/98 GJ at 7, 10-11. Ms. Currie testified that the President made this statement in a way that did not invite her agreement. Rather, "I would call it a statement, sir." Currie 1/27/98 GJ at 73.

1072. Clinton 8/17/98 GJ at 57.

1073. Clinton 8/17/98 GJ at 132.

1074. Clinton 8/17/98 GJ at 55.

1075. Clinton 8/17/98 GJ at 141.

1076. Clinton 8/17/98 GJ at 55.

1077. Clinton 8/17/98 GJ at 135-36 ("As far as I know, she is unaware of what happened on the, on the occasions when I saw her in 1996 when something improper happened. And she was unaware of the one time that I recall in 1997 when something happened.").

1078. Clinton 8/17/98 GJ at 38.

1079. Clinton 8/17/98 GJ at 57-58, 132.

1080. Clinton 8/17/98 GJ at 133.

1081. Clinton 8/17/98 GJ at 133.

1082. Clinton 8/17/98 GJ at 135.

1083. Clinton 8/17/98 GJ at 139. The President referred to a statement he delivered in the beginning of his grand jury appearance: "[B]ecause of privacy considerations affecting my family, myself, and others, and in an effort to preserve the dignity of the office I hold, this is all I will say about the specifics of these particular matters." Clinton 8/17/98 GJ at 10.

1084. At 5:12 p.m., Ms. Currie paged Ms. Lewinsky, leaving the message: "Please call Kay at home." At 6:22 p.m., Ms. Currie paged Ms. Lewinsky: "Please call Kay at home." At 7:06 p.m., Ms. Currie paged Ms. Lewinsky: "Please call Kay at home." At 8:28 p.m., Ms. Currie paged Ms. Lewinsky: "Call Kay." 831-DC-00000008 (Ms. Lewinsky's pager records) (Ms. Lewinsky's pager recorded calls in Pacific time). See also Currie 5/7/98 GJ at 96-97; 7/22/98 GJ at 156, 158.

1085. Currie 5/7/98 GJ at 99-100.

1086. Telephone Calls, Table 47, Call 11. See also Currie 7/22/98 GJ at 161-62.

1087. See Telephone Calls, Table 48. At 7:02 a.m. she paged Ms. Lewinsky, leaving the message: "Please call Kay at home at 8:00 this morning."⁽¹⁰⁸⁸⁾

1088. cite ⁽¹⁰⁸⁹⁾

1089. Ms. Currie admitted that these calls were not of a social nature. Currie 7/22/98 GJ at 161. - ⁽¹⁰⁹⁰⁾

1090. Currie 5/7/98 GJ at 104; 7/22/98 GJ at 161-62. - -

1091. Currie 7/22/98 GJ at 162-63. This time, Ms. Currie left a more urgent message: "Please call Kay re: family emergency." 831-DC-00000009 (Ms. Lewinsky's pager records). See Telephone Calls, Table 48, Call 7.

1092. Currie 7/22/98 GJ at 157-59; 164-66. ⁽¹⁰⁹³⁾

1093. Currie 7/22/98 GJ at 162.

1094. Jordan 6/9/98 GJ at 17. See also Telephone Calls, Table 48 (831-DC-00000009) (Ms. Lewinsky's pager records).

1095. Jordan 6/9/98 GJ at 38-39.

1096. Carter 6/18/98 GJ at 146.

1097. Jordan 6/9/98 GJ at 54-55.

1098. Schmidt, Baker, and Locy, "Clinton Accused of Urging Aide To Lie," Wash. Post, Jan. 21, 1998, at A1.

1099. Podesta 6/23/98 GJ at 12.

1100. See Telephone Calls, Table 50.

1101. Mr. Bennett was apparently referring to Ms. Lewinsky's affidavit.

1102. Clinton Accused at A1.

1103. Mr. Lindsey, on instructions from the President, see Lindsey 8/28/98 GJ at 23, has invoked the presidential communication privilege, the deliberative process privilege, the governmental attorney-client privilege, and President Clinton's personal attorney-client privilege with regard to conversations with the President and has thus refused to disclose what the President said to him on January 21. Lindsey 2/19/98 GJ at 42. Mr. Lindsey has testified, however, that based on the President's public statements and statements made to others in Lindsey's presence, the President misled him about the nature of his relationship with Ms. Lewinsky. Lindsey 8/28/98 GJ at 93-96, 101.

1104. Currie 5/7/98 GJ at 112-14.

1105. Lindsey 8/28/98 GJ at 90. Mr. Lindsey, citing privileges, refused to testify about the substance of this conversation.

1106. 1034-DC-00000111 (Mr. Jordan's calendar). See also Jordan 3/5/98 GJ at 79 (St. Regis Hotel), 160-61 (New York), 179 (the President's phone call); Jordan 6/9/98 GJ at 76.

1107. See Telephone Calls, Table 50, Call 6. See also Lindsey 8/28/98 GJ at 90. Mr. Lindsey asserted privileges over this conversation as well.

1108. White House Press Conference (Mike McCurry), Jan. 21, 1998.

1109. Lindsey 8/28/98 GJ at 11-12.

1110. Bowles 4/2/98 GJ at 84. See also Podesta 6/16/98 GJ at 85-86.

1111. Ickes 6/10/98 GJ at 73.

1112. Ms. Currie could not recall whether the President called her into the Oval Office to discuss Ms. Lewinsky on Tuesday, January 20, or Wednesday, January 21. Currie 1/27/98 GJ at 80-81.

1113. Currie 1/27/98 GJ at 80-81.

1114. Currie 1/27/98 GJ at 81.

1115. Currie 1/24/98 Int. at 8. The President did not specifically recall this second conversation with Ms. Currie, but did not dispute that it took place: "I do not remember how many times I talked to Betty Currie or when. I don't. I can't possibly remember that. I do remember when I first heard about this story breaking, trying to ascertain what the facts were, trying to ascertain what Betty's perception was." Clinton 8/17/98 GJ at 141-42.

1116. Blumenthal 2/26/98 GJ at 19.

1117. Blumenthal 6/4/98 GJ at 48-49. When later asked how he interpreted the President's statement, "I haven't done anything wrong," Mr. Blumenthal stated, "My understanding was that the accusations against him which appeared in the press that day were false, that he had not done anything wrong. . . . He had not had a sexual relationship with her, and had not sought to obstruct justice or suborn perjury."⁽¹¹¹⁸⁾

1118. Blumenthal 6/26/98 at 26.

1119. Blumenthal 6/4/98 GJ at 49. The President said, "I've gone down that road before, I've caused pain for a lot of people and I'm not going to do that again." Blumenthal 6/4/98 GJ at 49. Mr. Blumenthal "understood [this statement] to mean that he had had an adulterous relationship in the past, which is something he made very plain to the American people in his "60 Minutes" interview with the First Lady, which is how he introduced himself to the public . . . . And it's been very well known." Blumenthal 6/25/98 GJ at 32.

1120. Blumenthal 6/4/98 GJ at 49.

1121. Blumenthal 6/4/98 GJ at 50.

1122. Blumenthal 6/4/98 GJ at 49-50; Blumenthal 6/25/98 GJ at 15, 51.

1123. Podesta 6/16/98 GJ at 92.

1124. Podesta 6/16/98 GJ at 92. The President made another misleading statement about his relationship with Ms. Lewinsky to Mr. Podesta a few weeks later. According to Mr. Podesta, "[h]e said to me that after she [Ms. Lewinsky] left [the White House], that when she had come by, she came by to see Betty, and that he -- when she was there either Betty was with them -- either that she was with Betty when he saw her or that he saw her in the Oval Office with the door open and Betty was around -- and Betty was out at her desk."⁽¹¹²⁵⁾

1125. Podesta 6/16/98 GJ at 88.

1126. Clinton 8/17/98 GJ at 101-09.

1127. Clinton 8/17/98/ GJ at 101, 106. The President was asked specifically whether he denied telling Mr. Podesta that he did not have any kind of sex whatsoever, including oral sex, with Ms. Lewinsky. The President responded: "I'm not saying that anybody who had a contrary memory is wrong. I do not remember." Clinton 8/17/98 GJ at 105.

1128. In claiming that this statement was true, the President was apparently relying on the same tense-based distinction he made during the Jones deposition. See Clinton 8/17/98 GJ at 59-61 ("It depends on what the meaning of the word 'is' is. If the -- if he -- if 'is' means is and never has been, that is not -- that is one thing. If it means there is none, that was a completely true statement. . . . Now, if someone had asked me on that day, are you having any kind of sexual relations with Ms. Lewinsky, that is, asked me a question in the present tense, I would have said no. And it would have been completely true.")

1129. Clinton 8/17/98 GJ at 107.

1130. Clinton 8/17/98 GJ at 107.

1131. Broadcast on "All Things Considered" on National Public Radio, 5:07 p.m., Wednesday, January 21, 1998.

1132. "The News Hour with Jim Lehrer," PBS, interview with President Bill Clinton by Jim Lehrer, Wednesday, January 21, 1998. As evidenced by his grand jury testimony, the President is attentive to matters of verb tense. Clinton 8/17/98 GJ at 59.

1133. Televised Remarks by President Clinton at Photo Opportunity at the White House with Palestinian Authority Chairman Yasser Arafat, January 22, 1998, 10:22 a.m.

1134. Roll Call, Inc., January 22, 1998; transcript of press conference.

1135. "All Things Considered," January 21, 1998.

1136. "The News Hour," January 21, 1998.

1137. Televised Remarks By President Clinton at Photo Opportunity at the White House with Palestinian Authority Chairman Yasser Arafat, January 22, 1998, 10:22 a.m.

1138. Roll Call, Inc., January 22, 1998. President Clinton was extended invitations to appear before the grand jury and give his testimony on: January 28, 1998; February 4, 1998; February 9, 1998; February 21, 1998; March 2, 1998; and March 13, 1998. He declined all of these invitations. On July 16, 1998, the grand jury issued the President a subpoena. The President promptly moved for a postponement of two weeks in which to respond. At a hearing on the President's motion, Chief Judge Norma Holloway Johnson stated, "What we need to do is to move forward and move forward expeditiously. . . . [A]pparently the grand jury has determined that [they] need to hear from the [President]." In re Grand Jury Proceedings, Misc. No. 98-267, July 28, 1998, at pp. 27-28. Before Judge Johnson ruled, the President's attorneys negotiated the terms of the President's appearance.

1139. Morris 8/18/98 GJ at 6, 10, 12. Mr. Morris was questioned after the President's grand jury appearance on August 17, 1998; accordingly, the OIC never had an opportunity to question the President about this conversation.

1140. Morris 8/18/98 GJ at 14.

1141. Mr. Morris testified that he interpreted the "something" to be sexual in nature. Morris 8/18/98 GJ at 94.

1142. Morris 8/18/98 GJ at 14.

1143. Morris 8/18/98 GJ at 15.

1144. Morris 8/18/98 GJ at 15-16.

1145. Morris 8/18/98 GJ at 17.

1146. Morris 8/18/98 GJ at 28.

1147. Morris 8/18/98 GJ at 30.

1148. Morris 8/18/98 GJ at 34. Mr. Morris believed that Ms. Lewinsky's credibility was in question based on a claim by a USA Today reporter that there was an occasion when the President and Mr. Morris spoke on the telephone while they each were involved in a sexual encounter. The President was reportedly "having sex" with Ms. Lewinsky while Mr. Morris was allegedly involved with a prostitute at the Jefferson Hotel. Morris 8/18/98 GJ at 32, 34.

1149. Morris 8/18/98 GJ at 35.

1150. Thomason 8/11/98 GJ at 6.

1151. Although Mr. Thomason originally offered to stay with the President for a "couple of days," he stayed at the White House Residence for 34 days. Thomason 8/11/98 GJ at 6, 10. Mr. Thomason testified that while "not particularly an expert in media matters . . . my wife and I seem to have a feel of what the rest of America is thinking. . . ." Thomason 8/11/98 GJ at 24.

1152. Thomason 8/11/98 GJ at 15-16. Mr. Thomason said he "went on the assumption that [the allegations] were not true," but he never asked the President because he talked to his attorney, Robert Bennett (also the President's personal attorney), who advised him "to make sure you don't ask questions that will get you subpoenaed." Id. at 22, 27. Mr. Thomason also testified he did not ask the President whether the denial was true because "I wanted it to be true and I felt it not to be true." Id. at 32-33.

1153. Thomason 8/11/98 GJ at 15.

1154. Thomason 8/11/98 GJ at 27.

1155. Schmidt and Baker, "Ex-Intern Rejected Immunity Offer in Probe," Wash. Post, Jan. 24, 1998, at A1.

1156. Schmidt and Baker, "Ex-Intern Rejected Immunity Offer," at A1.

1157. Larry King Weekend, Jan. 24, 1998, Transcript No. 98012400V42.

1158. In fact, the President did draw a distinction between "is" and "was." See Clinton 8/17/98 GJ at 59.

1159. Larry King Weekend, Jan. 24, 1998, Transcript No. 98012400V42.

1160. Televised Remarks by President Clinton at the White House Education News Conference, Monday, January 26, 1998, 10:00 a.m. See Chi. Tribune, Jan. 27, 1998, at 1 ("A defiant President Clinton wagged his finger at the cameras and thumped the lectern Monday as he insisted he did not have sex with a young White House intern or ask her to deny it under oath.").