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Referral

to the

United States House of Representatives

pursuant to

Title 28, United States Code, 595(c)

Submitted by

The Office of the Independent Counsel

September 9, 1998

I. Nature of President Clinton's Relationship with Monica Lewinsky

2. Ms. Lewinsky's Statements

3. Ms. Lewinsky's Confidants

1. The President's Accounts

2. Ms. Lewinsky's Accounta

E. December 31 Sexual Encounter

A. January 7 Sexual Encounter

B. January 21 Sexual Encounter

XIII. January 5-January 16, 1998: The Affidavit

B. January 5: Call from the President

D. January 7: Ms. Lewinsky Signs Affidavit

D. January 20-22: Lewinsky Story Breaks

1. President Clinton's Statements Under Oath About Monica Lewinsky

2. Monica Lewinsky's Testimony

(iv) Sunday, January 7, 1996

6. Summary

B. The President's Grand Jury Testimony

1. The President's Civil Deposition Testimony

2. Evidence That Contradicts the President's Testimony

3. The President's Grand Jury Testimony

4. Summary

1. The President's Civil Deposition Testimony About His Gifts to Monica Lewinsky

2. Evidence that Contradicts the President's Civil Deposition Testimony

3. President's Civil Deposition Testimony About Gifts from Monica Lewinsky to the President

4. Evidence that Contradicts the President's Testimony

(i) Monica Lewinsky's Testimony

6. Summary

1. President Clinton's Testimony in His Deposition

(i) Ms. Lewinsky's Testimony

(ii) The President's Grand Jury Testimony

1. Evidence

2. The President's Grand Jury Testimony

B. January 5, 1998, Note to the President

2. President Clinton's Testimony

B. Summary of President's Grand Jury Testimony

1. Saturday, January 17, 1998, Deposition

B. The President's Grand Jury Testimony

November 15, 1995 President begins sexual relationship with Lewinsky

November 1996 President Clinton reelected

January 17, 1998 President deposed in Jones case

January 18, 1998 President meets with Betty Currie to discuss President's deposition

Monica Lewinsky Former White House Intern and Employee

Ann Lewis Director, White House Communications

Bruce Lindsey Deputy White House Counsel

Charles Ruff White House Counsel

Other White House Personnel

Glen Maes White House Steward to President Clinton

Secret Service

Gary Byrne Secret Service Uniformed Officer

Daniel Carbonetti Secret Service Uniformed Officer

Brent Chinery Secret Service Uniformed Officer

Douglas Dragotta Secret Service Uniformed Officer

Nelson Garabito Secret Service Uniformed Officer

Bryan Hall Secret Service Uniformed Officer

Brian Henderson Secret Service Uniformed Officer

Reginald Hightower Secret Service Uniformed Officer

Oliver Janney Secret Service Uniformed Officer

Tim Lynn Secret Service Uniformed Officer

John Muskett Secret Service Uniformed Officer

Robert Myrick Secret Service Uniformed Officer

Barry Smith Secret Service Uniformed Officer

William Tyler Secret Service Uniformed Officer

Michael Wilson Secret Service Uniformed Officer

As required by Section 595(c) of Title 28 of the United States Code, the Office of the Independent Counsel ("OIC" or "Office") hereby submits substantial and credible information that President William Jefferson Clinton committed acts that may constitute grounds for an impeachment.(1)

The information reveals that President Clinton:

In May 1997, the Supreme Court unanimously rejected the President's legal argument. Ms. Jones's attorneys sought disclosure of this information, arguing that it was relevant to proving that the President had propositioned Ms. Jones. The President resisted the discovery requests, arguing that evidence of relationships with other women (if any) was irrelevant.

For purposes of pretrial discovery, President Clinton was required to provide certain information about his alleged relationships with other women. In mid-December 1997, the President answered one of the written discovery questions posed by Ms. Jones on this issue. The President was asked numerous questions about his relationship with Monica Lewinsky, by then a 24-year-old former White House intern, White House employee, and Pentagon employee. Under oath and in the presence of Judge Wright, the President denied that he had engaged in a "sexual affair," a "sexual relationship," or "sexual relations" with Ms. Lewinsky. The Investigation

After gathering preliminary evidence to test the information's reliability, the OIC presented the evidence to Attorney General Janet Reno. On January 28, 1998, after the allegations about the President's relationship with Ms. Lewinsky became public, the OIC filed a Motion for Limited Intervention and a Stay of Discovery in Jones v. Clinton. The OIC represented to the Court that numerous individuals then under subpoena in Jones, including Monica Lewinsky, were integral to the OIC's investigation, and that courts routinely stayed discovery in such circumstances.(11)

The Court acknowledged that "evidence concerning Monica Lewinsky might be relevant to the issues in [the Jones] case."On March 9, 1998, Judge Wright denied Ms. Jones's motion for reconsideration of the decision regarding Monica Lewinsky. After the dismissal of Ms. Jones's lawsuit, the criminal investigation continued. The first limit was imposed when the President was sued in federal court for alleged sexual harassment. The third limit is unique to the President. 1. Background of the Investigation. Vernon Jordan informed President Clinton that he was helping Mr. Hubbell.(31)

When the OIC's jurisdiction was expanded to cover the Lewinsky matter in January 1998, several matters remained under active investigation by this Office. This "Grounds" portion of the Referral summarizes the specific evidence that the President lied under oath and attempted to obstruct justice. Document Supplement A contains transcripts of the President's deposition testimony and grand jury testimony; Document Supplement B contains transcripts of Monica Lewinsky's testimony and interview statements. (c) Information relating to impeachment. 4. Jones v. Clinton, 117 S. Ct. 1636, 1652 (1997).

7. V002-DC-00000020 (President Clinton's Responses to Plaintiff's Second Set of Interrogatories at 5).

8. V002-DC-00000053 (President Clinton's Supplemental Responses to Plaintiff's Second Set of Interrogatories at 2). Witnesses called before the grand jury in the criminal investigation had been subpoenaed by both parties to the civil case; defendant's counsel had subpoenaed information from the OIC; and the plaintiff's attorneys had subpoenaed documents directly related to the criminal matter.

12. Jones v. Clinton, Order, Jan. 29, 1998, at 2.

Even Presidents have private lives. 22. Clinton 1/17/98 Depo. 31. Jordan, House Testimony, 7/24/97, at 46.

I. Nature of President Clinton's

Relationship with Monica Lewinsky

Physical evidence conclusively establishes that the President and Ms. Lewinsky had a sexual relationship. 2. Ms. Lewinsky's Statements

Ms. Lewinsky was extensively debriefed about her relationship with the President. 3. Ms. Lewinsky's Confidants

Between 1995 and 1998, Ms. Lewinsky confided in 11 people about her relationship with the President. 1. The President's Accounts

During the deposition, the President's attorney, Robert Bennett, sought to limit questioning about Ms. Lewinsky. In subsequent questioning by his attorney, President Clinton testified under oath that Ms. Lewinsky's affidavit was "absolutely true."(22)

2. Ms. Lewinsky's Account

Second, and particularly important, Ms. Lewinsky contradicts the President on a key issue. According to Ms. Lewinsky, she performed oral sex on the President on nine occasions. As the relationship developed over time, Ms. Lewinsky grew emotionally attached to President Clinton. Ms. Lewinsky and the President exchanged numerous gifts. According to Ms. Lewinsky, she sent the President a number of cards and letters. 4. Ms. Lewinsky's Notes and Letters

5. Ms. Lewinsky's Evaluation of Their Secrecy Efforts

A. Overview of Monica Lewinsky's White House Employment

B. First Meetings with the President

Ms. Lewinsky said yes. According to Ms. Lewinsky, she and the President kissed. White House records corroborate details of Ms. Lewinsky's account. Ms. Lewinsky testified:

Ms. Lewinsky and the President went into the area of the private study, according to Ms. Lewinsky. Just then, the President came down the hallway from the Oval Office and saw Ms. Lewinsky. F. President's Account of 1995 Relationship

President Clinton and Ms. Lewinsky had additional sexual encounters near the Oval Office in 1996. After their sixth sexual encounter, the President and Ms. Lewinsky had their first lengthy conversation. On President's Day, February 19, the President terminated their sexual relationship, then revived it on March 31.

According to Ms. Lewinsky, she and the President had another sexual encounter on Sunday, January 7, 1996. According to Ms. Lewinsky, the President telephoned her early that afternoon. (205) Ms. Lewinsky went to her office, and the President called to arrange their rendezvous:

On Sunday, January 21, 1996, according to Ms. Lewinsky, she and the President had another sexual encounter. According to Ms. Lewinsky, she questioned the President about his interest in her. There, according to Ms. Lewinsky, they kissed. D. President's Day (February 19) Break-up

According to Ms. Lewinsky, the President terminated their relationship (only temporarily, as it happened), on Monday, February 19, 1996 -- President's Day. In Ms. Lewinsky's recollection, the President telephoned her at her Watergate apartment that day. In the hallway by the study, the President and Ms. Lewinsky kissed. On April 7 -- Easter Sunday -- Ms. Lewinsky told the President of her dismissal. (278) Ms. Lewinsky acknowledged that she tried to position herself to see the President.(279)

(283) A short time later, Ms. Lewinsky arrived and said that "[t]he President needs me."B. Decision to Transfer Ms. Lewinsky

C. Ms. Lewinsky's Notification of Her Transfer

Ms. Lewinsky was devastated. According to Ms. Lewinsky, the President telephoned her at home that day. According to Ms. Lewinsky, the President seemed troubled about her upcoming departure from the White House:

When asked if he had promised to get Ms. Lewinsky another White House job, the President told the grand jury:

(322) Ms. Lewinsky performed oral sex. Ms. Lewinsky testified that she exited hurriedly through the dining room door.(330) That evening, the President called and asked Ms. Lewinsky why she had run off. At 5:30 p.m., two minutes after Ms. Lewinsky left the White House, the President called the office of the person who had decided to transfer Ms. Lewinsky, Evelyn Lieberman.(342)

Ms. Lewinsky testified that the President telephoned her the following Friday, April 12, 1996, at home. In the grand jury, Ms. Lieberman testified that the President asked her directly about Ms. Lewinsky's transfer:

Ms. Lewinsky repeatedly told the President that she disliked her Pentagon job and wanted to return to the White House.(361) In a recorded conversation, Ms. Lewinsky recounted one call:

Ms. Lewinsky and the President also talked about their relationship. (372) The President telephoned her that night. E. Ms. Lewinsky's Frustrations

In 1997, President Clinton and Ms. Lewinsky had further private meetings, which now were arranged by Betty Currie, the President's secretary. After the taping of the President's weekly radio address on February 28, the President and Ms. Lewinsky had a sexual encounter. The President's secretary, Betty Currie, acted as intermediary.

Ms. Lewinsky testified that after the President gave her the gifts, they had a sexual encounter:

According to Ms. Lewinsky, she and the President had a lengthy conversation that day. Over the months that followed, Ms. Lewinsky repeatedly asked the President to get her a White House job. In May 1997, amid indications that Ms. Lewinsky had been indiscreet, President Clinton terminated the sexual relationship.

A. Questions about Ms. Lewinsky's Discretion

On Saturday, May 24, 1997, according to Ms. Lewinsky, the President ended their intimate relationship. Ms. Lewinsky wrote:

On June 29, 1997, Ms. Lewinsky wrote several notes. After receiving the July 3 letter, though, the President agreed to see Ms. Lewinsky. Ms. Lewinsky began weeping, and the President hugged her. There, the President was "the most affectionate with me he'd ever been," Ms. Lewinsky testified. According to Ms. Lewinsky, the President had no telephone calls during her time with him. Ms. Lewinsky testified that the President met her in Ms. Currie's office, then took her into Ms. Hernreich's office.(529) (Records show that seven minutes after Ms. Lewinsky's entry to the White House complex, the President left the Oval Office for the appointment secretary's office.)(530) According to Ms. Lewinsky:

On Saturday, August 16, 1997, Ms. Lewinsky tried, unsuccessfully, to resume her sexual relationship with the President. Ms. Lewinsky testified that she brought birthday gifts for the President (his birthday is August 19):

Ms. Lewinsky continued trying to discuss her situation with the President. Ms. Lewinsky testified:

Later, Ms. Lewinsky and Ms. Tripp discussed their concerns about the President's involvement in Ms. Lewinsky's job search. Specifically, Ms. Lewinsky was nervous about involving the President's Chief of Staff:

D. The President Creates Options

(633) Ms. Lewinsky testified that she spoke to Ambassador Richardson. A few days later, according to Ms. Lewinsky, the President called her. Ms. Lewinsky spoke to the President again one week later. According to Ms. Lewinsky, on October 30, the night before the interview, the President did call. (651) Ms. Lewinsky also mentioned the President's promise to involve Vernon Jordan in her job search:

Ms. Lewinsky became increasingly anxious about her inability to see the President. The following morning, November 13, Ms. Lewinsky tried to arrange a visit with the President. Ms. Lewinsky waited in the rain.(704)

Ms. Lewinsky rued the brevity of her November 13 visit with the President: "All you . . . . The Christmas reception encounter heightened Ms. Lewinsky's frustration. (728) Ms. Lewinsky reminded the President of his words during their October 10 telephone argument:

Ms. Lewinsky arrived at the White House at approximately 10:00 a.m. 2. Ms. Lewinsky Returns to the White House

(797) The President's advice "was . . . instantly familiar to [Ms. Lewinsky]."A. December 19: Ms. Lewinsky Is Subpoenaed

Mr. Jordan testified that he spoke to the President before Ms. Lewinsky ever entered his office.(820) He told the President: "Monica Lewinsky called me up. (834) Ms. Lewinsky said she had not had a sexual relationship with the President.(835)

That evening, Mr. Jordan visited the President at the White House. (841) That question was, "Mr. President, have you had sexual relations with Monica Lewinsky?" The President told Mr. Jordan, "No, never."(842)

E. December 28: Final Meeting with the President

That morning, Ms. Lewinsky met with the President in the Oval Office. Ms. Lewinsky and the President also talked about the Jones case.(874) In Ms. Lewinsky's account, she asked the President "how he thought [she] got put on the witness list."Ms. Lewinsky's friend, Catherine Allday Davis, testified about a conversation with Ms. Lewinsky on January 3, 1998. Ms. Lewinsky, Ms. Currie, and the President were all questioned as to why Ms. Currie retrieved the box of gifts from Ms. Lewinsky.

Ms. Lewinsky responded: "No, notes from me to the President." On January 7, Ms. Lewinsky signed the affidavit. B. January 5: Call from the President

D. January 7: Ms. Lewinsky Signs Affidavit

(960) According to Mr. Jordan, when he informed the President that Ms. Lewinsky had signed the affidavit, the President said, "Fine, good."J. January 13-14: Lewinsky-Tripp Conversation and Talking Points

Ms. Lewinsky: Right. Ms. Lewinsky: Okay? In a recorded conversation that day, January 15, Ms. Lewinsky encouraged Ms. Tripp not to disclose her (Lewinsky's) relationship with the President. The President emphatically denied having had sexual relations with Ms. Lewinsky.(1045)

B. The President Meets with Ms. Currie

(1051) The President wanted to discuss Ms. Lewinsky's White House visits.(1052)

According to Ms. Currie, the President appeared "concerned."C. January 18-19: Attempts to Reach Ms. Lewinsky

D. January 20-22: Lewinsky Story Breaks

(1119) The President also told Mr. Blumenthal that Ms. Lewinsky had "threatened him. Q: Mr. President, . . . . The President agreed.(1145)

(1153) The President agreed: "You know, you're right. 1. Lewinsky 8/6/98 GJ at 31-32, 39-40; DB Photos 0004 (photo of dress).

8. Lewinsky 7/27/98 Int. Lewinsky 2/1/98 Statement. Lewinsky 8/20/98 GJ at 62-63. 9. Ex. ML-7 to Lewinsky 8/6/98 GJ.

10. Lewinsky 8/26/98 Depo. at 5-6; Lewinsky 8/6/98 GJ at 27-28.

11. Lewinsky 8/26/98 Depo. 12. Lewinsky 8/6/98 GJ at 59-60, 87; Lewinsky 8/20/98 GJ at 82; Lewinsky 8/24/98 Int. at 8.

Lewinsky 8/6/98 GJ at 28. Gifts from the President to Ms. Lewinsky: Id. at 75. Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7; Clinton 8/17/98 GJ at 34-36, 126-28.

23. Clinton 8/17/98 GJ at 10, 79, 81.

24. Clinton 8/17/98 GJ at 10.

25. Clinton 8/17/98 GJ at 31, 10. 26. Clinton 8/17/98 GJ at 10, 92-93.

27. Clinton 8/17/98 GJ at 22.

28. Clinton 8/17/98 GJ at 10, 12, 93-96.

29. 849-DC-00000586. Clinton 8/17/98 GJ at 19, 22. Clinton 8/17/98 GJ at 19.

30. Clinton 8/17/98 GJ at 15, 93, 100, 102.

31. Clinton 8/17/98 GJ at 151.

32. Clinton 8/17/98 GJ at 168.

33. Clinton 8/17/98 GJ at 102-105, 167-68.

34. Clinton 8/17/98 GJ at 95-96, 100, 110, 139. 35. Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7. According to Ms. Lewinsky, she and the President had three sexual encounters in 1995 (the President said he recalled none) and two sexual encounters in 1997 (not one, as the President testified). Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7; Lewinsky 8/26/98 Depo. 36. Lewinsky 8/6/98 GJ at 34-36; Lewinsky 8/20/98 GJ at 17; Lewinsky 7/27/98 Int. at 2; Lewinsky 7/31/98 Int. at 4; Catherine Davis 3/17/98 GJ at 16; Erbland 2/12/98 GJ at 27-28, 43-44; Finerman 3/18/98 Depo. 37. Lewinsky 8/6/98 GJ at 35; Lewinsky 7/27/98 Int. at 2.

38. Lewinsky 8/6/98 GJ at 12, 21; Lewinsky 2/1/98 Statement at 1. 40. Lewinsky 8/6/98 GJ at 38-39. See also Lewinsky 8/20/98 GJ at 24.

41. Lewinsky 8/6/98 GJ at 19-20, 38-39; Ungvari 3/19/98 GJ at 23-24.

42. Lewinsky 7/30/98 Int. at 5-13, 15-16; Lewinsky 8/6/98 GJ at 19-21; Lewinsky 8/20/98 GJ at 31-32, 40, 67-69; Lewinsky 8/26/98 Depo. 43. Clinton 8/17/98 GJ at 10; Lewinsky 8/26/98 Depo. Lewinsky 8/26/98 Depo. 44. Lewinsky 8/20/98 GJ at 59. at 52; Lewinsky 8/6/98 GJ at 168. Lewinsky 8/20/98 GJ at 54. 46. Lewinsky 8/20/98 GJ at 52; T1 at 101. 47. Lewinsky 8/6/98 GJ at 18.

48. Lewinsky 7/27/98 Int. at 6; Currie 5/7/98 GJ at 60; Catherine Davis 3/17/98 GJ at 27; Raines 1/29/98 GJ at 53; Ungvari 3/19/98 GJ at 45; Young 6/23/98 GJ at 47; (49)

50. Lewinsky 7/27/98 Int. at 6.

51. Lewinsky 8/26/98 Depo. at 55-57; Lewinsky 7/27/98 Int. at 6.

See also Lewinsky 8/26/98 Depo. Lewinsky 2/1/98 Statement at 8; Jordan 3/3/98 GJ at 150.

54. Lewinsky 8/6/98 GJ at 17. See also Lewinsky 8/26/98 Depo. at 24; Lewinsky 8/24/98 Int. at 6; Tripp 7/7/98 GJ at 172.

56. Lewinsky 8/6/98 GJ at 52-53.

57. Lewinsky 8/6/98 GJ at 52.

58. Lewinsky 8/6/98 GJ at 21-23; Lewinsky 7/27/98 Int. at 2. 59. Lewinsky 8/6/98 GJ at 44; Lewinsky 8/24/98 Int. at 5; Currie 5/14/98 GJ at 131-32, 136, 141; Currie 7/22/98 GJ at 35, 77.

60. Lewinsky 8/20/98 GJ at 55.

61. Lewinsky 8/6/98 GJ at 23.

62. Lewinsky 8/6/98 GJ at 23-24; Lewinsky 7/27/98 Int. at 2. Ms. Lewinsky gave the President a novel about phone sex, Vox by Nicholson Baker. Lewinsky 7/27/98 Int. at 13; 1361-DC-00000030 (White House list of books in private study, including Vox).

63. Lewinsky 7/30/98 Int. at 15.

64. Lewinsky 8/6/98 GJ at 23; Lewinsky 8/20/98 GJ at 6. Lewinsky 8/6/98 GJ at 22-23; Lewinsky 7/29/98 Int. at 3, 5; Lewinsky 8/3/98 Int. at 6.

65. Lewinsky 8/6/98 GJ at 22-23; Catherine Davis 3/17/98 GJ at 28-29; Erbland 2/12/98 GJ at 49; Kassorla 8/28/98 Int. at 4; Raines 1/29/98 GJ at 89; Tripp 7/2/98 GJ at 89; Tripp 7/9/98 GJ at 95-97, 104-105; Ungvari 3/19/98 GJ at 31-33.

66. Lewinsky 8/6/98 GJ at 67-69.

67. Lewinsky 8/6/98 GJ at 74-75.

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

69. Clinton 8/17/98 GJ at 10.

70. Clinton 8/17/98 GJ at 47, 51.

71. Clinton 8/17/98 GJ at 47, 124.

72. Lewinsky 8/6/98 GJ at 25-26.

73. Lewinsky 7/27/98 Int. at 12. 76. Lewinsky 8/11/98 Int. at 2; V006-DC-00000178 (autographed photo).

77. Few of Ms. Lewinsky's subsequent gifts were logged. 79. Lewinsky 8/26/98 Depo. Lewinsky 8/6/98 GJ at 183-84; Lewinsky 7/27/98 Int. at 13; Subpoena D1415. 1361-DC-00000030; Lewinsky 8/6/98 GJ at 183-84.

80. Lewinsky 8/26/98 Depo. 81. Lewinsky 8/20/98 GJ at 36. See also Lewinsky 8/6/98 GJ at 236; Catherine Davis 3/17/98 GJ at 153.

82. Lewinsky 8/6/98 GJ at 236; Lewinsky 8/20/98 GJ at 36; Lewinsky 8/3/98 Int. at 8; Lewinsky 8/11/98 Int. at 2-3. Lewinsky 8/5/98 Int. at 1; Lewinsky 8/11/98 Int. at 2-3.

83. Lewinsky 8/6/98 GJ at 236.

84. Clinton 8/17/98 GJ at 47. 85. Lewinsky 8/6/98 GJ at 26.

86. Lewinsky 8/6/98 GJ at 189.

87. Lewinsky 8/6/98 GJ at 26-27.

88. Clinton 8/17/98 GJ at 48-49. 89. Lewinsky 2/1/98 Statement at 10. See also Lewinsky 8/20/98 GJ at 62-63; Lewinsky 8/6/98 GJ at 141-42, 178-79. Currie 1/27/98 GJ at 63-64.

90. Lewinsky 8/6/98 GJ at 78, 97-101; Lewinsky 7/27/98 Int. at 3.

91. Lewinsky 8/20/98 GJ at 22. 92. Lewinsky 8/20/98 GJ at 4; Lewinsky 8/6/98 GJ at 166-67. See also Lewinsky 7/27/98 Int. at 9-10, 12.

93. Lewinsky 8/6/98 GJ at 234.

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

95. Clinton 8/17/98 GJ at 38, 119. 96. Clinton 8/17/98 GJ at 37.

97. Lewinsky 8/6/98 GJ at 53-54. See also Lewinsky 7/27/98 Int. at 2, 11; Lewinsky 8/19/98 Int. at 4; Lewinsky 2/1/98 Statement at 1.

98. Lewinsky 8/6/98 GJ at 53-54.

99. Lewinsky 8/6/98 GJ at 54.

100. Lewinsky 8/6/98 GJ at 54-55; Lewinsky 7/30/98 Int. at 10.

101. Lewinsky 8/6/98 GJ at 54-55.

102. Lewinsky 8/6/98 GJ at 18, 53-54.

103. Lewinsky 8/6/98 GJ at 18-19; Lewinsky 2/1/98 Statement at 1.

104. Lewinsky 8/20/98 GJ at 105; Lewinsky 2/1/98 Statement at 1.

105. Lewinsky 8/20/98 GJ at 22.

106. Lewinsky 2/1/98 Statement at 4; Lewinsky 8/6/98 GJ at 123, 233.

108. Clinton 8/17/98 GJ at 118-19.

109. Clinton 8/17/98 GJ at 119. 110. Lewinsky 8/6/98 GJ at 47. Along with weekend visits, Ms. Lewinsky sometimes saw the President on holidays: New Year's Eve, President's Day, Easter Sunday, July 4. Lewinsky 9/3/98 Int. at 2.

111. Lewinsky 8/6/98 GJ at 18. See also Lewinsky 8/20/98 GJ at 7, 22.

112. Lewinsky 8/6/98 GJ at 84-85; Lewinsky 8/20/98 GJ at 7. Tripp 6/30/98 GJ at 159-60, 164; Tripp 7/14/98 GJ at 75; T1 at 32; 1037-DC-00000318 (email from Ms. Lewinsky).

113. Lewinsky 8/6/98 GJ at 34-35; Lewinsky 8/20/98 GJ at 16-17; Lewinsky 7/31/98 Int. at 4. 114. Lewinsky 7/31/98 Int. at 4.

115. Lewinsky 8/4/98 Int. at 4.

116. Lewinsky 8/6/98 GJ at 36. See also Lewinsky 7/31/98 Int. at 4.

117. Lewinsky 8/6/98 GJ at 36-37; Lewinsky 7/27/98 Int. at 2. 118. Lewinsky 8/6/98 GJ at 56. See also Lewinsky 7/31/98 Int. at 3.

119. Lewinsky 7/31/98 Int. at 3.

120. Lewinsky 8/26/98 Depo. at 44-45; Lewinsky 7/30/98 Int. at 9; Lewinsky 7/31/98 Int. at 4. Lewinsky 8/6/98 GJ at 44-45, 57, 218; Lewinsky 8/20/98 GJ at 5-6, 18; Lewinsky 7/29/98 Int. at 2-3.

121. Clinton 8/17/98 GJ at 38. at 53 (to President's knowledge, Ms. Currie did not see intimate activity between President and Ms. Lewinsky); id. 122. Lewinsky 8/6/98 GJ at 56.

123. Lewinsky 8/6/98 GJ at 189, 198. See also Lewinsky 8/2/98 Int. at 3. 124. Lewinsky 8/24/98 Int. at 8.

125. Clinton 8/17/98 GJ at 50. 132. 828-DC-00000012 (resume); Lewinsky 7/27/98 Int. at 1; Walter Kaye 5/21/98 GJ at 34, 51-52; Marcia Lewis 4/3/98 Depo. Ms. Lewinsky turned 22 on July 23. 133. Lewinsky 8/6/98 GJ at 8; Lewinsky 8/20/98 GJ at 8; Bobowick 2/12/98 Int. at 1; Currie 1/27/98 GJ at 23-24; Panetta 1/28/98 GJ at 121-23; Palmieri 2/24/98 GJ at 12; V006-DC-00000020 (White House employee data form).

134. Lewinsky 8/3/98 Int. at 2.

135. Lewinsky 8/3/98 Int. at 2; 828-DC-00000012 (resume); V006-DC-00000225 (employment approval for the Legislative Affairs Office); V006-DC-00000198 (1995 White House intern directory); V006-DC-00002287 (record of Ms. Lewinsky's transfer).

136. Lewinsky 8/26/98 Depo. 137. Lewinsky 8/6/98 GJ at 10.

138. Lewinsky 8/6/98 GJ at 9; Lewinsky 7/27/98 Int. at 2; Lewinsky 8/3/98 Int. at 1; V006-DC-00001826 (photo showing President and Ms. Lewinsky).

139. Lewinsky 8/26/98 Depo. 143. Lewinsky 8/6/98 GJ at 10-11; Byrne 6/25/98 Depo. 144. Goodin 2/17/98 GJ at 48-50; Griffin 5/11/98 Int. at 1; Lewinsky 8/6/98 GJ at 10-11; Palmieri 2/24/98 GJ at 20-22; Raines 1/29/98 GJ at 35-36; V006-DC-00003737 - 3744 (White House photos showing President and Ms. Lewinsky during furlough).

145. Lewinsky 8/6/98 GJ at 11.

146. Lewinsky 8/3/98 Int. at 2; Barry Toiv 3/11/98 Int. at 1 (job title).

147. Lewinsky 8/6/98 GJ at 10; Lewinsky 7/27/98 Int. at 1-2. 148. 827-DC-00000008. 827-DC-00000003 - 16. 150. Lewinsky 7/27/98 Int. at 2; Lewinsky 8/24/98 Int. at 5.

151. Lewinsky 7/30/98 Int. at 5; Lewinsky 8/11/98 Int. at 7; Erbland 2/12/98 GJ at 24-25.

152. Lewinsky 8/6/98 GJ at 11; Lewinsky 7/27/98 Int. at 2; Lewinsky 7/30/98 Int. at 5.

153. Lewinsky 8/6/98 GJ at 11; Lewinsky 7/27/98 Int. at 2; Lewinsky 7/30/98 Int. at 5.

154. Lewinsky 8/6/98 GJ at 11; Lewinsky 8/26/98 Depo. 155. Lewinsky 7/30/98 Int. at 5.

156. Lewinsky 8/26/98 Depo. 157. Lewinsky 8/6/98 GJ at 12; Lewinsky 7/30/98 Int. at 5.

158. Lewinsky 8/26/98 Depo. 159. Lewinsky 8/26/98 Depo. at 7; Lewinsky 8/6/98 GJ at 12, 13.

160. Lewinsky 8/26/98 Depo. at 8; Lewinsky 7/30/98 Int. at 5.

161. Lewinsky 8/26/98 Depo. 162. Lewinsky 8/26/98 Depo. Lewinsky Int. 9/3/98 at 1.

163. Lewinsky 8/6/98 GJ at 12-14; Lewinsky 8/26/98 Depo. at 9-10; Lewinsky 7/30/98 Int. at 6.

164. Lewinsky 8/26/98 Depo. 165. Lewinsky 8/26/98 Depo. 166. Lewinsky 9/3/98 Int. at 3; Lewinsky 8/24/98 Int. at 5; Lewinsky 7/30/98 Int. at 6.

167. Lewinsky 8/6/98 GJ at 11-12; Lewinsky 8/26/98 Depo. 169. Lewinsky 7/30/98 Int. at 6.

170. 1472-DC-00000006 - 08. 173. Lewinsky 8/6/98 GJ at 14. See also Lewinsky 7/30/98 Int. at 6-7.

174. Lewinsky 8/6/98 GJ at 14-15; Lewinsky 7/30/98 Int. at 7.

175. Lewinsky 8/6/98 GJ at 15-16.

176. In Ms. Currie's recollection, Ms. Lewinsky and the President were alone together for about 30 seconds. Currie 1/27/98 GJ at 33-34; Currie 5/14/98 GJ at 36-38. 177. Lewinsky 8/6/98 GJ at 16; Lewinsky 8/26/98 GJ at 11-15; Lewinsky 7/30/98 Int. at 7.

178. Lewinsky 8/26/98 Depo. at 12-13; Lewinsky 7/30/98 Int. at 7.

179. Lewinsky 8/26/98 Depo. at 12; Lewinsky 7/30/98 Int. at 7.

180. Lewinsky 7/30/98 Int. at 7.

181. Lewinsky 8/26/98 Depo. 182. Lewinsky 8/26/98 Depo. at 13-14; Lewinsky 7/30/98 Int. at 7. 183. Lewinsky 7/30/98 Int. at 7. See also Lewinsky 8/26/98 Depo. Lewinsky 8/11/98 Int. at 5. Lewinsky 8/26/98 Depo. 186. Clinton 8/17/98 GJ at 31-32.

189. Lewinsky 8/26/98 Depo. at 15-16; Lewinsky 7/27/98 Int. at 3-4; Lewinsky 7/30/98 Int. at 8.

190. Lewinsky 8/26/98 Depo. 191. Lewinsky 8/26/98 Depo. at 16; Lewinsky 7/27/98 Int. at 3-4; Lewinsky 7/30/98 Int. at 8.

192. Lewinsky 8/26/98 Depo. 193. Lewinsky 8/26/98 Depo. See also Lewinsky 7/30/98 Int. at 8.

194. Lewinsky 7/27/98 Int. at 3-4; Lewinsky 7/30/98 Int. at 8.

195. Lewinsky 8/26/98 Depo. 196. Lewinsky 7/30/98 Int. at 3.

198. Clinton 8/17/98 GJ at 31-32.

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

Lewinsky 8/24/98 Int. at 5.

201. Clinton 8/17/98 GJ at 10.

204. Lewinsky 8/26/98 Depo. See also Lewinsky 7/30/98 Int. at 2, 8.

205. Lewinsky 8/26/98 Depo. 206. Lewinsky 8/26/98 Depo. 207. Lewinsky 8/26/98 Depo. 208. Lewinsky 8/26/98 Depo. 209. Lewinsky 8/26/98 Depo. 210. Lewinsky 8/26/98 Depo. 211. Lewinsky 8/26/98 Depo. Officer Fox testified that the President and Ms. Lewinsky were alone. Fox 2/17/98 GJ 36-37. 221. Lewinsky 7/30/98 Int. at 9; Lewinsky 8/24/98 Int. at 6.

222. Lewinsky 8/26/98 Depo. 223. Lewinsky 8/26/98 Depo. 224. Lewinsky 8/26/98 Depo. 225. Lewinsky 8/26/98 Depo. See also Lewinsky 7/30/98 Int. at 10.

226. Lewinsky 8/26/98 Depo. 227. Lewinsky 8/26/98 Depo. 228. Lewinsky 8/26/98 Depo. 229. Lewinsky 8/26/98 Depo. 230. Lewinsky 8/26/98 Depo. Ms. Lewinsky stated that the Blairs from Arkansas were visiting the President. Lewinsky 7/30/98 Int. at 10. 231. Lewinsky 8/26/98 Depo. at 27-28; Lewinsky 7/30/98 Int. at 10; Tripp 7/7/98 GJ at 124-26, 139-143; Tripp 7/9/98 GJ at 4-5; 845-DC-00000004 (Tripp notes).

234. Lewinsky 8/26/98 Depo. at 28-29; Lewinsky 8/24/98 Int. at 6.

235. Lewinsky 8/26/98 Depo. 236. Lewinsky 8/26/98 Depo. 237. Lewinsky 8/26/98 Depo. 238. Lewinsky 8/26/98 Depo. 239. Lewinsky 8/26/98 Depo. 240. Lewinsky 8/26/98 Depo. 241. Lewinsky 8/26/98 Depo. at 33-34; Lewinsky 8/24/98 Int. at 6; Tripp 7/7/98 GJ at 169-71; 845-DC-00000006 (Tripp notes).

244. Lewinsky 7/30/98 Int. at 11; Lewinsky 8/24/98 Int. at 6.

245. Lewinsky 7/30/98 Int. at 3, 11-12.

246. Lewinsky 7/30/98 Int. at 3, 11.

247. Lewinsky 8/6/98 GJ at 24; Lewinsky 7/29/98 Int. at 3.

248. Lewinsky 7/30/98 Int. at 11. 249. Lewinsky 8/24/98 Int. at 6. See also Lewinsky 7/30/98 Int. at 11.

253. 1472-DC-00000017 (call logs).

254. 1506-DC-00000017 (call logs).

256. Lewinsky 8/6/98 GJ at 90.

257. Lewinsky 8/6/98 GJ at 91. See also Lewinsky 8/26/98 Depo. Lewinsky 7/30/98 Int. at 12; Lewinsky 8/24/98 Int. at 6.

258. Ungvari 3/19/98 GJ at 29-31; Lewinsky 8/3/98 Int. at 3; Ungvari 3/18/98 Int. at 4; Verna 6/11/98 Depo. 260. Lewinsky 8/11/98 Int. at 2.

261. Lewinsky 8/20/98 GJ at 19; Lewinsky 7/30/98 Int. at 12; 845-DC-00000010 - 11 (Tripp notes).

262. Lewinsky 8/26/98 Depo. 1506-DC-00000558 (White House daily diary).

265. Lewinsky 7/29/98 Int. at 3; Lewinsky 7/30/98 Int. at 12-13.

270. Lewinsky 8/26/98 Depo. 271. Lewinsky 8/26/98 Depo. at 36; Lewinsky 7/30/98 Int. at 12.

272. Lewinsky 8/26/98 Depo. 273. Lewinsky 8/26/98 Depo. 274. Lewinsky 7/30/98 Int. at 12-13; Lewinsky 8/26/98 Depo. Clinton 8/17/98 GJ at 110-11.

275. Lewinsky 7/30/98 Int. at 13.

279. Lewinsky 8/20/98 GJ at 12.

289. Lewinsky 8/20/98 GJ at 10-11; Lewinsky 7/31/98 Int. at 6.

292. Lewinsky 8/20/98 GJ at 8.

See also T3 at 15; Lewinsky 7/31/98 Int. at 7. 304. Lewinsky 8/6/98 GJ at 61. V006-DC-00000694 (President's schedule); 968-DC-00000841 (same).

Lewinsky 8/3/98 Int. at 5. Keating 2/25/98 GJ at 76-79; Lewinsky 8/6/98 GJ at 171. 306. Keating 2/25/98 GJ at 78-79; Lewinsky 8/3/98 Int. at 3; Capps 3/23/98 Int. at 2; Fox 2/17/98 GJ at 47; Lynn 8/5/98 GJ at 14-16; Verna 7/21/98 GJ at 21-23.

307. Lewinsky 8/6/98 GJ at 171. See also Lewinsky 8/3/98 Int. at 3. Lewinsky 8/3/98 Int. at 4. 308. Lewinsky 8/26/98 Depo. 309. Lewinsky 8/6/98 GJ at 62.

312. Lewinsky 8/6/98 GJ at 62. See also Lewinsky 8/26/98 Depo. at 39; Lewinsky 7/27/98 Int. at 4; Tripp 7/9/98 GJ at 29-30.

Lewinsky 8/6/98 GJ at 91; Lewinsky 8/20/98 GJ at 42; Lewinsky 8/26/98 Depo. at 39-40; Lewinsky 7/27/98 Int. at 4; Lewinsky 7/30/98 Int. at 13; Lewinsky 7/31/98 Int. at 6.

314. Lewinsky 7/27/98 Int. at 4.

315. Lewinsky 8/6/98 GJ at 63. See also Lewinsky 8/26/98 Depo. 317. Lewinsky 8/6/98 GJ at 64.

318. Clinton 8/17/98 GJ at 130.

319. Lewinsky 8/26/98 Depo. 320. Lewinsky 8/6/98 GJ at 94-97.

321. Lewinsky 8/26/98 Depo. 322. Lewinsky 8/26/98 Depo. 323. Lewinsky 8/26/98 Depo. 324. Lewinsky 8/6/98 GJ at 20, 95-97; Lewinsky 7/30/98 Int. at 13.

325. Lewinsky 8/6/98 GJ at 95; Lewinsky 8/26/98 Depo. at 41-44; Lewinsky 7/27/98 Int. at 4-5; Lewinsky 7/30/98 Int. at 13.

326. Lewinsky 8/6/98 GJ at 92; Lewinsky 7/27/98 Int. at 4-5; Lewinsky 7/30/98 Int. at 13.

328. Lewinsky 8/6/98 GJ at 93, 97.

329. Lewinsky 8/6/98 GJ at 93. See also Lewinsky 8/26/98 Depo. at 43; Lewinsky 7/27/98 Int. at 5; Lewinsky 7/30/98 Int. at 13. Lewinsky 8/6/98 GJ at 97.

330. Lewinsky 8/6/98 GJ at 93; Lewinsky 8/26/98 Depo. at 45; Lewinsky 7/27/98 Int. at 5; Lewinsky 7/30/98 Int. at 13.

331. Lewinsky 8/6/98 GJ at 94. See also Lewinsky 7/30/98 Int. at 11; Tripp 7/9/98 GJ at 30-36; 845-DC-00000012 - 13 (Tripp notes).

338. Lewinsky 8/6/98 GJ at 36-37; Lewinsky 7/27/98 Int. at 2.

343. Lewinsky 8/6/98 GJ at 64-65. See also Lewinsky 2/1/98 Statement at 1; Lewinsky 7/31/98 Int. at 6-7; Lewinsky 8/3/98 Int. at 5; Tripp 7/9/98 GJ at 72-73; 845-DC-00000014 (Tripp notes); T2 at 17.

344. Lewinsky 8/6/98 GJ at 65; Lewinsky 7/29/98 Int. at 3-4; Lewinsky 8/3/98 Int. at 5.

348. Currie 5/7/98 GJ at 49-50.

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

350. V006-DC-00002289 (email noting departures of White House employees); Lewinsky 8/6/98 GJ at 65. 833-DC-00002880. Lewinsky 8/24/98 Int. at 3. 351. Lewinsky 7/29/98 Int. at 1.

352. Lewinsky 8/6/98 GJ at 66.

354. Lewinsky 8/6/98 GJ at 28 & Ex. ML-7.

356. Lewinsky 7/29/98 Int. at 4-5.

357. Lewinsky 7/30/98 Int. at 14. See also Lewinsky 7/29/98 Int. at 4; Lewinsky 8/6/98 GJ at 27-28; Tripp 7/9/98 GJ at 118-19 (mistakenly indicating that this occurred July 15, 1996); 845-DC-00000018 (Tripp notes).

358. 1506-DC-00000275 (call log); 1506-DC-000000638.

359. Lewinsky 7/29/98 Int. at 4-5; Lewinsky 7/30/98 Int. at 14-15; 845-DC-00000016 - 17 (Tripp notes); 845-DC-00000020 - 22 (same); Tripp 7/9/98 GJ at 102-04, 115-16; Tripp 7/14/98 GJ at 11-12, 35-37.

360. 1506-DC-00000222 (5/21/96); 1506-DC-00000264 (7/5/96); 1506-DC-00000268 (7/6/96); 1506-DC-00000328 (10/22/96); 1506-DC-00000353 (12/2/96) (President's schedules).

361. Lewinsky 7/29/98 Int. at 3; Finerman 3/18/98 Depo. Along with talking with the President, Ms. Lewinsky also contacted former White House colleagues for help returning to work there. Lewinsky 8/3/98 Int. at 5.

364. Lewinsky 7/30/98 Int. at 14; Lewinsky 8/6/98 GJ at 21; Erbland 2/12/98 GJ at 30; Tripp 7/14/98 GJ at 4-6; 845-DC-00000020 (Tripp notes).

365. Lewinsky 8/20/98 GJ at 25.

366. Lewinsky 7/29/98 Int. at 3, 16; Tripp 7/9/98 GJ at 99-100; 845-DC-00000015 (Tripp notes). 1506-DC-00000188 - 189 (President's schedules).

368. Lewinsky 8/20/98 GJ at 28-31; Lewinsky 7/29/98 Int. at 16; Lewinsky 8/24/98 Int. at 6-7; V006-DC-00000682 (President's schedule for August 18); V006-DC-00003735 (photo request from Ms. Lewinsky); MSL-DC-0000489 - 490 (event invitation); Tripp 7/9/98 GJ at 125-26; 845-DC-00000019 (Tripp notes).

369. Lewinsky 8/20/98 GJ at 28-31. See also Lewinsky 7/30/98 Int. at 17.

370. Lewinsky 7/31/98 Int. at 7. 1506-DC-00000334 - 335 (President's schedule).

372. Lewinsky 8/11/98 Int. at 2.

373. Lewinsky 8/20/98 GJ at 26-27.

374. Lewinsky 7/29/98 Int. at 5.

See also Lewinsky 2/1/98 Statement at 1-2; Tripp 7/14/98 GJ at 32-34. Ms. Lewinsky did not send this letter. Lewinsky 8/4/98 Int. at 5.

380. Currie 5/7/98 GJ at 63.

381. Currie 5/6/98 GJ at 97-98.

382. Currie 5/6/98 GJ 14-15.

383. Currie 5/6/98 GJ at 52-53, 94-96.

384. 827-DC-00000002, 827-DC-00000018 (Ms. Lewinsky's WAVES records).

385. Currie 5/6/98 GJ at 57-58.

386. Currie 5/6/98 GJ at 84-85. Currie 7/22/98 GJ at 24.

387. Currie 1/27/98 GJ at 32-33. See also Currie 5/6/98 GJ at 98; Currie 7/22/98 GJ at 25-26, 41. at 25 (agreeing that Ms. Lewinsky and President were alone together); id. 392. Lewinsky 8/20/98 GJ at 5. at 14; Lewinsky 8/19/98 Int. at 5.

393. Currie 5/6/98 GJ at 88-89. at 184; Currie 5/14/98 GJ at 78.

394. Currie 5/6/98 GJ at 88-89.

395. Currie 5/14/98 GJ at 72-74, 91; Currie 1/24/98 Int. at 3.

396. 837-DC-00000001; 837-DC-00000004; 837-DC-00000006; 837-DC-0000008; 837-DC-00000011; 837-DC-00000014; 837-DC-00000018.

397. Lewinsky 7/31/98 Int. at 13; Marcia Lewis 2/11/98 GJ at 28-30; T1 at 63-64.

399. Currie 5/14/98 GJ at 72-73.

400. Currie 5/14/98 GJ at 73-74, 86-89; Currie 7/22/98 GJ at 51-52.

401. Currie 5/14/98 GJ at 88-89. 402. Currie 5/6/98 GJ at 88-89. Currie 5/6/98 GJ at 129.

404. Currie 5/14/98 GJ at 143-45; Currie 1/24/98 Int. at 8.

405. Currie 5/6/98 GJ at 157-58.

406. Currie 5/6/98 GJ at 156; Currie 7/22/98 GJ at 42-43.

407. Currie 1/27/98 GJ at 63-64. See also Currie 5/6/98 GJ at 164; Currie 7/22/98 GJ at 31-33. Lewinsky 2/1/98 Statement at 10, 11.

408. Currie 5/14/98 GJ at 131-43. 409. Currie 7/22/98 GJ at 33-35.

Currie 7/22/98 GJ at 115. 1216-DC-00000022.

412. Currie 5/6/98 GJ at 16-17, 20-21, 68-70, 73-74, 85-86; Currie 5/7/98 GJ at 8. 413. Currie 5/6/98 GJ at 73-74, 85-86. Lewinsky 8/20/98 GJ at 15; Lewinsky 7/27/98 Int. at 4; Lewinsky 8/3/98 Int. at 5; Lewinsky 8/24/98 Int. at 7.

414. Currie 5/6/98 GJ at 84-85.

415. Lewinsky 7/31/98 Int. at 4.

416. Lewinsky 8/5/98 Int. at 3.

417. Lewinsky 7/31/98 Int. at 5. Ms. Lewinsky told confidants about Ms. Currie's role. at 39-40; Raines 1/29/98 GJ at 49; Ungvari 3/19/98 GJ at 38-40; 1037-DC-00000337 - 338 (email from Ms. Lewinsky); 1037-DC-00000001 - 02 (card from Ms. Lewinsky).

824-DC-00000013 - 14; Lewinsky 8/20/98 GJ at 71-72. 833-DC-00009446.

423. 833-DC-00001906 (email from Ms. Lewinsky to Ms. Tripp).

427. 1222-DC-00000234; 968-DC-00000073.

428. 968-DC-00003506.

429. Lewinsky 8/26/98 Depo. at 45-46, 48-49; Lewinsky 8/6/98 GJ at 30.

430. Lewinsky 8/6/98 GJ at 45-46.

431. Lewinsky 8/26/98 Depo. 432. Lewinsky 8/6/98 GJ at 30.

433. Lewinsky 8/6/98 GJ at 30-31, 46-47; Lewinsky 7/30/98 Int. at 15; Lewinsky 7/31/98 Int. at 5. Currie 1/27/98 GJ at 34; Goodin 2/17/98 GJ at 52, 55. 434. Currie 7/22/98 GJ at 130-31; Currie 1/27/98 GJ at 34-35; Lewinsky 8/6/98 GJ at 31; Lewinsky 7/30/98 Int. at 15.

435. Currie 7/22/98 GJ at 131. Ms. Currie also maintained that the President and Ms. Lewinsky were "[n]ever out of eyesight." Clinton 8/17/98 GJ at 10, 53-54.

436. Lewinsky 8/26/98 Depo. 437. Lewinsky 8/26/98 Depo. 438. Lewinsky 8/26/98 Depo. at 47; Lewinsky 8/6/98 GJ at 31. Currie 5/6/98 GJ at 142.

439. Lewinsky 8/6/98 GJ at 156. See also Lewinsky 8/20/98 GJ at 72; Lewinsky 8/26/98 Depo. Lewinsky 8/4/98 Int. at 5.

440. Lewinsky 8/24/98 Int. at 7; Finerman 3/18/98 Depo. 441. Lewinsky 8/26/98 Depo. See also Lewinsky 8/6/98 GJ at 31, 38-39.

442. Lewinsky 8/26/98 Depo. 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. 445. Lewinsky 8/6/98 GJ at 32, 39-40. Lewinsky 8/6/98 GJ at 41. Lewinsky 8/6/98 GJ at 40. See also Lewinsky 7/29/98 Int. at 17.

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.

1014-DC-00000022.

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. 454. Lewinsky 8/26/98 Depo. 455. Lewinsky 8/26/98 Depo. 456. Lewinsky 8/26/98 Depo. See also Lewinsky 8/20/98 GJ at 68-69; Lewinsky 7/30/98 Int. at 16. Lewinsky 8/26/98 Depo. 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. 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. 466. Clinton 8/17/98 GJ at 113-14. 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.

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. Dr. Kassorla, Ms. Lewinsky's therapist, told Ms. Lewinsky that the President's statement sounded rehearsed and insincere. 480. Lewinsky 8/6/98 GJ at 25. Lewinsky 8/20/98 GJ at 70.

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. 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. Clinton 8/17/98 GJ at 130.

489. Lewinsky 8/6/98 GJ at 67; Lewinsky 8/24/98 Int. at 7. Lewinsky 7/27/98 Int. at 5. Lewinsky 7/27/98 Int. at 5.

495. 833-DC-00001070.

Lewinsky 8/4/98 Int. at 6. MSL-DC-00001221; 852-DC-00000035; 929-DC-00000056; 852-DC-00000037.

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. 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. 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.

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. 515. Lewinsky 8/26/98 Depo. See also Lewinsky 7/28/98 Int. at 6.

516. Lewinsky 8/26/98 Depo. 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. 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.

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.

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

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. 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.

549. Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7; Lewinsky 8/24/98 Int. at 6.

551. 845-DC-00000190 (letter); Tripp 7/16/98 GJ at 85-88.

Secret Service Officer Steven Pape testified about Ms. Lewinsky's August 16 visit. 555. 968-DC-00003558.

556. 968-DC-00002947.

557. Lewinsky 8/26/98 Depo. See also Lewinsky 8/20/98 GJ at 70.

558. Lewinsky 8/20/98 GJ at 70; Lewinsky 8/26/98 Depo. 559. Lewinsky 8/26/98 Depo. Ms. Lewinsky said that she sent this or a similar note to the President. Lewinsky 7/31/98 Int. at 2. 565. Lewinsky 8/4/98 Int. at 5.

567. Lewinsky 8/3/98 Int. at 6-7; Lewinsky 8/11/98 Int. at 5. Lewinsky 7/31/98 Int. at 9; Lewinsky 8/13/98 Int. at 2; Lewinsky 2/1/98 Statement at 2. Lewinsky 8/13/98 Int. at 3.) Currie 5/14/98 GJ at 149-51. Lewinsky 8/24/98 Int. at 7. Lewinsky 2/1/98 Statement at 2-3; Podesta 2/5/98 GJ at 40-43; Podesta 6/16/98 GJ at 13.

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. 572. Lewinsky 7/29/98 Int. at 16; Lewinsky 8/4/98 Int. at 5.

574. Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7. 575. Lewinsky 8/13/98 Int. at 1. 1037-DC-00000168.

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. 580. Lewinsky 7/31/98 Int. at 10.

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

583. Lewinsky 8/4/98 Int. at 2-3.

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.

See also Lewinsky 7/31/98 Int. at 10. 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.

603. Lewinsky 8/6/98 GJ at 27-28 & Exh. 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. Lewinsky 8/6/98 GJ at 104.

606. Lewinsky 8/6/98 GJ at 104; Lewinsky 7/31/98 Int. at 11-12. Currie 5/6/98 GJ at 187.

611. Lewinsky 7/31/98 Int. at 12. Lewinsky 7/31/98 Int. at 3. See also Lewinsky 8/13/98 Int. at 3.

Lewinsky 7/31/98 GJ at 3.

See also Lewinsky 7/31/98 Int. at 11. CNN President Rick Kaplan is a friend of the President.

See also Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7; Lewinsky 8/11/98 Int. at 4.

See also Lewinsky 8/6/98 GJ at 121-26.

720. Clinton 8/17/98 GJ at 84-85. 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. 731. Lewinsky 8/6/98 GJ at 108-09; Lewinsky 8/6/98 GJ at 27-29 & Exh. 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.

737. Lewinsky 8/6/98 GJ at 111-12. 738. Lewinsky 8/6/98 GJ at 111-12. Ms. Lewinsky suspected that Ms. Mondale was romantically involved with the President. (739)

It's the President." 740. Lewinsky 8/6/98 GJ at 112-13. Currie 1/27/98 GJ at 37.

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. 750. Lewinsky 8/6/98 GJ at 115-16. 751. Lewinsky 8/6/98 GJ at 116. Lewinsky 8/1/98 Int. at 2.

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

Currie 7/22/98 GJ at 91-92.

763. Clinton 8/17/98 GJ at 84-85, 87. 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. 1407-DC-00000005.

1178-DC-00000026.

775. Jordan 5/5/98 GJ at 83. Jordan 5/5/98 GJ at 116.

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).

Lewinsky 7/31/98 Int. at 15. 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.

779. Lewinsky 8/6/98 GJ at 121. 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. 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.

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

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

Lewinsky 2/1/98 Statement at 4.

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. Lewinsky 8/6/98 GJ at 126.

814. Jordan 3/3/98 GJ at 92-93. Jordan 3/3/98 GJ at 101.

817. Lewinsky 8/6/98 GJ at 131; V004-DC-00000151 (Akin, Gump telephone records). 818. Jordan 5/5/98 GJ at 154-55. 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. Lewinsky 2/1/98 Statement at 5.

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

831. Jordan 3/3/98 GJ at 150. 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. 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. 839. Jordan 3/3/98 GJ at 167-8.

840. Jordan 3/3/98 GJ at 169. 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. 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. Lewinsky 8/6/98 GJ at 139. Lewinsky 8/6/98 GJ at 143.

853. Lewinsky 8/6/98 GJ at 139-140. Lewinsky 2/1/98 Statement at 6.

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

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. 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.

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

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

872. Lewinsky 8/6/98 GJ at 150-51. Clinton 8/17/98 GJ at 36.

873. Lewinsky 8/26/98 Depo. 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. 877. Lewinsky 8/20/98 GJ at 66.

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

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

884. Clinton 8/17/98 GJ at 39. Clinton 8/17/98 GJ at 45.

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

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

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. 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).

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. 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. 901. Currie 5/6/98 GJ at 110. 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. 907. Lewinsky 8/6/98 GJ at 186-87. 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.

917. Lewinsky 8/6/98 GJ at 192. 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.

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

923. Lewinsky 8/2/98 Int. at 3. 924. Lewinsky 8/6/98 GJ at 197.

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

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

940. 849-DC-00000634. 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.

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.

953. Lewinsky 8/6/98 GJ at 204-05. 954. Lewinsky 8/6/98 GJ at 204. (955)

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

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. Lewinsky 8/6/98 GJ at 200, 220.

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.

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

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

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

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

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

973. Jordan 5/5/98 GJ at 231. 974. Jordan 3/5/98 GJ at 56. (975)

975. Jordan 3/5/98 GJ at 56. Jordan 3/5/98 GJ at 56-57. (976)

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

982. Jordan 5/5/98 GJ at 232. 983. Lewinsky 8/6/98 GJ at 209.

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

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

987. Jordan 5/28/98 GJ at 20-21. 989. Lewinsky 8/6/98 GJ at 210.

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

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

993. Jordan 5/28/98 GJ at 59. 996. Lewinsky 8/6/98 GJ at 214.

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

998. 831-DC-00000010. Currie 7/22/98 GJ at 175; Lewinsky 8/6/98 GJ at 215-17.

1004. Lewinsky 8/6/98 GJ at 215. 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. Jordan 5/28/98 GJ at 69.

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

1013. Lewinsky 8/6/98 GJ at 223-37. 1014. Currie 5/6/98 GJ at 120-21.

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

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.

1025. 921-DC-00000775 - 778.

1027. 921-DC-00000775. Jordan 5/5/98 GJ at 223-25.

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. 1051. Currie 5/7/98 GJ at 91. 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. 1248-DC-00000313.

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

1059. Currie 1/27/98 GJ at 71-74; 7/22/98 GJ at 6-7, 10-11, 79. 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. 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. 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. Clinton 8/17/98 GJ at 132.

Currie 7/22/98 GJ at 130. Currie 7/22/98 GJ at 132.

1068. Currie 7/22/98 GJ at 79. 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. 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.

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. Clinton 8/17/98 GJ at 10.

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

1086. Telephone Calls, Table 47, Call 11. 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. 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.

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

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

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.

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.

Clinton 8/17/98 GJ at 141-42.

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

1127. Clinton 8/17/98/ GJ at 101, 106. Clinton 8/17/98 GJ at 105.

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

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

Clinton 8/17/98 GJ at 59.

Before Judge Johnson ruled, the President's attorneys negotiated the terms of the President's appearance.

President Clinton Committed Acts that

1. President Clinton lied under oath in his civil case when he denied a sexual affair, a sexual relationship, or sexual relations with Monica Lewinsky.

2. President Clinton lied under oath to the grand jury about his sexual relationship with Ms. Lewinsky.

4. President Clinton lied under oath in his civil deposition about his discussions with Ms. Lewinsky concerning her involvement in the Jones case.

8. President Clinton lied under oath in his civil deposition about his discussions with Vernon Jordan concerning Ms. Lewinsky's involvement in the Jones case.

I. There is substantial and credible information that President Clinton lied under oath as a defendant in Jones v. Clinton regarding his sexual relationship with Monica Lewinsky.

The President replied: "I do."The President responded, "I do."(5)

A. Evidence that President Clinton Lied Under Oath During the Civil Case

1. President Clinton's Statements Under Oath About Monica Lewinsky

Judge Wright ordered the President to answer the interrogatory, and on December 23, 1997, under penalty of perjury, President Clinton answered "None."(8)

At the January 17, 1998, deposition of the President, Ms. Jones's attorneys asked the President specific questions about possible sexual activity with Monica Lewinsky. President Clinton answered a series of questions about Ms. Lewinsky, including:

WJC: I have never had sexual relations with Monica Lewinsky. President Clinton reiterated his denial under questioning by his own attorney:

2. Monica Lewinsky's Testimony

Ms. Lewinsky testified that she met with the President on New Year's Eve, Sunday, December 31, 1995, after the President invited her to the Oval Office.(24) Once there, the President lifted Ms. Lewinsky's sweater, fondled her bare breasts with his hands, and kissed her breasts. After the President unzipped his pants, Ms. Lewinsky also performed oral sex on him.(39)

After the address, Ms. Lewinsky and the President kissed by the bathroom. Ms. Lewinsky testified that she met with President Clinton in the Oval Office study on the morning of Saturday, August 16, 1997. On Sunday, December 28, 1997, three weeks before the President's civil deposition in the Jones case, the President and Ms. Lewinsky met in the Oval Office. Ms. Lewinsky testified that she and the President engaged in "phone sex" approximately fifteen times. The President initiated each phone sex encounter by telephoning Ms. Lewinsky.(48)

Catherine Allday Davis, a college friend of Monica Lewinsky's,(53) testified that Ms. Lewinsky told her in late 1995 or early 1996 about Ms. Lewinsky's sexual relationship with the President.(54) According to Ms. Davis, Ms. Lewinsky told her that the relationship included mutual kissing and hugging, as well as oral sex performed by Ms. Lewinsky on the President. Ms. Lewinsky told another high school friend, Natalie Rose Ungvari,(65) of her sexual relationship with the President. Ashley Raines, a friend of Ms. Lewinsky who worked in the White House Office of Policy Development Operations,(69) testified that Ms. Lewinsky described the sexual relationship with the President. Dr. Irene Kassorla counseled Ms. Lewinsky from 1992 through 1997.(75) Ms. Lewinsky told her of the sexual relationship with the President. Ms. Lewinsky told Ms. Tripp that the first sexual encounter with the President had occurred on November 15, 1995, when Ms. Lewinsky performed oral sex on him. Ms. Lewinsky told Ms. Tripp that, during the course of this sexual relationship, she performed oral sex on the President, the President fondled Ms. Lewinsky's breasts, the President touched Ms. Lewinsky's genitalia, and they engaged in phone sex.(79)

Ms. Lewinsky's aunt, Debra Finerman, testified that Monica told her about her sexual relationship with President Clinton.(80) Ms. Finerman testified that Ms. Lewinsky described a particular sexual encounter with the President.(81) Ms. Finerman otherwise did not ask and was not told the specifics of the sexual activity between the President and Ms. Lewinsky.(82)

Kathleen Estep, a counselor for Ms. Lewinsky,(84) met with Ms. Lewinsky on three occasions in November 1996.(85) Based on her limited interaction with Ms. Lewinsky, Ms. Estep stated that she considered Ms. Lewinsky to be credible.(86) During their second session, Ms. Lewinsky told Ms. Estep about her sexual relationship with President Clinton.(87) Ms. Lewinsky told Ms. Estep that the physical part of the relationship involved kissing, Ms. Lewinsky performing oral sex on the President, and the President fondling her breasts.(88)

First, in his civil deposition, the President denied a "sexual affair" with Ms. Lewinsky (the term was not defined). Second, in his civil deposition, the President also denied a "sexual relationship" with Ms. Lewinsky (the term was not defined). According to President Clinton, oral sex does not constitute sexual relations.

Ms. Lewinsky testified that she performed oral sex on the President on nine occasions. The President's linguistic parsing is unreasonable. By contrast, the President's testimony strains credulity. II. There is substantial and credible information that President Clinton lied under oath to the grand jury about his sexual relationship with Monica Lewinsky.

After the President, in his January 17 deposition, denied any sexual relationship with Monica Lewinsky and otherwise minimized his overall relationship with her, the President's testimony became an additional subject of the OIC investigation.

The threshold factual question was whether the President and Monica Lewinsky in fact had a sexual relationship. B. The President's Grand Jury Testimony

Q: -- with Monica Lewinsky.

The President's grand jury testimony contradicts Ms. Lewinsky's grand jury testimony on the question whether the President touched Ms. Lewinsky's breasts or genitalia during their sexual activity. Many testified that Ms. Lewinsky had told them that the President had touched her breasts and genitalia during sexual activity. 3. Finally, the President made a third false statement to the grand jury about his sexual relationship with Monica Lewinsky. During President Clinton's deposition in the Jones case, Ms. Jones's attorneys asked the President many detailed questions about the nature of his relationship with Ms. Lewinsky, apart from whether the relationship was sexual. 1. The President's Civil Deposition Testimony

President Clinton was asked at his deposition whether he had ever been alone with Ms. Lewinsky. 2. Evidence That Contradicts the President's Testimony

Mr. Maes testified that the President and Ms. Lewinsky were alone together for approximately eight minutes, and then Ms. Lewinsky left.(144)

3. The President's Grand Jury Testimony

The President admitted to the grand jury that he had been alone with Ms. Lewinsky. During his civil deposition, the President also was asked several questions about gifts he and Monica Lewinsky had exchanged. 1. The President's Civil Deposition Testimony About His Gifts to Monica Lewinsky

During the President's deposition in the Jones case, Ms. Jones's attorneys asked several questions about whether he had given gifts to Monica Lewinsky.

2. Evidence that Contradicts the President's Civil Deposition Testimony

(159) The President's secretary Betty Currie also testified that she had previously discussed the hat pin with the President.(160)

3. President's Civil Deposition Testimony About Gifts from Monica Lewinsky to the President

When asked at his civil deposition in the Jones case whether Monica Lewinsky had ever given him gifts, President Clinton testified as follows:

Q: Has Monica Lewinsky ever given you any gifts?

4. Evidence that Contradicts the President's Testimony

(i) Monica Lewinsky's Testimony

a. Ms. Lewinsky testified before the grand jury that she gave the President six neckties.(171)

d. Ms. Lewinsky gave the President at least seven books:

The Presidents of the United States, on January 4, 1998;(177)

e. Ms. Lewinsky gave the President an antique cigar holder, on December 6, 1997.(188)

f. Ms. Lewinsky testified that she gave the President a number of additional gifts.(189) >

5. Grand Jury Testimony of the President and Ms. Currie

During the criminal investigation, the President has produced seven gifts that Ms. Lewinsky gave him. A truthful answer to the questions about gifts at the Jones deposition would have raised further questions about the President's relationship with Monica Lewinsky. Ms. Lewinsky had been subpoenaed for gifts, as the President knew. 1. President Clinton's Testimony in His Deposition

2. Evidence that Contradicts the President's Civil Deposition Testimony

(i) Ms. Lewinsky's Testimony

Ms. Lewinsky testified that President Clinton called her at about 2:00 a.m. on December 17, 1997. Ms. Lewinsky was subpoenaed on December 19. At her request, Vernon Jordan told the President that Ms. Lewinsky had been subpoenaed.(207) She then met with President Clinton nine days later on December 28, less than three weeks before the President was deposed.

(ii) The President's Grand Jury Testimony

Furthermore, had the President admitted talking to Ms. Lewinsky about her testifying, that conversation would have attracted public inquiry into the conversation and the general relationship between the President and Ms. Lewinsky.

(217) The President was asked:

(i) concealment of gifts that the President had given Ms. Lewinsky and that were subpoenaed from Ms. Lewinsky in the Jones case; and

(ii) concealment of a note sent by Ms. Lewinsky to the President on January 5, 1998.

From the beginning, President Clinton and Monica Lewinsky hoped and expected that their relationship would remain secret. On the 28th, the President also gave Ms. Lewinsky several Christmas gifts. 2. The President's Grand Jury Testimony

The President denied that he had asked Betty Currie to pick up a box of gifts from Ms. Lewinsky:

Ms. Lewinsky testified that Betty Currie called her to retrieve the gifts soon after Ms. Lewinsky's conversation with the President. 1. The witnesses disagree about whether Ms. Currie called Ms. Lewinsky or Ms. Lewinsky called Ms. Currie. Ms. Lewinsky's testimony makes more sense than Ms. Currie's testimony. The President "hoped that this relationship would never become public."(267) The President gave Ms. Lewinsky new gifts on December 28, 1997. The President knew that Ms. Lewinsky was concerned about the subpoena. B. January 5, 1998, Note to the President

2. President Clinton's Testimony

>The President remembered the book Ms. Lewinsky had given him about the Presidents and testified that he "did like it a lot."the President suggested that Monica Lewinsky file an affidavit, which he knew would be false;

the President's attorney used the affidavit to object to questions about Ms. Lewinsky at his January 17 deposition; and

Ms. Lewinsky has stated that the President never explicitly told her to lie. Mr. Jordan confirmed that President Clinton knew that Ms. Lewinsky planned to execute an affidavit denying a sexual relationship.(289) Mr. Jordan further testified that he informed President Clinton when Ms. Lewinsky signed the affidavit.(290) Ms. Lewinsky's affidavit was sent to the federal court in Arkansas on January 16, 1998 -- the day before the President's deposition -- as part of her motion to quash the deposition subpoena.

Two days before the President's deposition, his lawyer, Robert Bennett, obtained a copy of Ms. Lewinsky's affidavit from Mr. Carter.(291) At the President's deposition, Ms. Jones's counsel asked questions about the President's relationship with Ms. Lewinsky. (292) Mr. Bennett said that the President was "fully aware of Ms. Lewinsky's affidavit."The President answered: "That is absolutely true."(294)

B. Summary of President's Grand Jury Testimony

The President offered several responses.

(302) The President responded: "No, sir. (316) When asked if he was ever alone with Ms. Lewinsky in the Oval Office, the President stated:

D. The President's Grand Jury Testimony on Cover Stories

The President had an incentive to keep Ms. Lewinsky from jeopardizing the secrecy of the relationship. Mr. Jordan also telephoned President Clinton to keep him informed of the efforts to help Ms. Lewinsky. On Sunday, December 28, 1997, Monica Lewinsky and the President met in the Oval Office.(355) During that meeting, the President and Ms. Lewinsky discussed both her move to New York and her involvement in the Jones suit.(356)

On January 5, 1998, Ms. Lewinsky declined the United Nations offer.(357) On January 7, 1998, Ms. Lewinsky signed the affidavit denying the relationship with President Clinton (she had talked on the phone to the President on January 5 about it).(358) Mr. Jordan informed the President of her action.(359)

On January 16, Ms. Lewinsky's attorney sent to the District Court in the Jones case her affidavit denying a "sexual relationship" with the President.(369) The next day, on January 17, the President was deposed and his attorney used her affidavit as the President similarly denied a "sexual relationship."

The President did not act half-heartedly. A. President's Testimony in the Jones Case

Beforehand, the President was asked a general question:

B. Evidence That Contradicts the President's Civil Deposition Testimony

Vernon Jordan testified that his conversations with the President about Ms. Lewinsky's subpoena were, in fact, "a continuing dialogue."I said to the President, "Monica Lewinsky called me up. VJ: Monica Lewinsky signed the affidavit.

* * * *

The President himself testified in the grand jury that he talked to Mr. Jordan about Ms. Lewinsky's involvement in the case. In his civil deposition, the President stated that he had talked to Vernon Jordan about Ms. Lewinsky's job. President Clinton's deposition in Jones v. Clinton occurred on Saturday, January 17, 1998. During his testimony, the President referred several times to Betty Currie and to her relationship with Ms. Lewinsky. Shortly after her meeting with the President, Ms. Currie made several attempts to contact Ms. Lewinsky. B. The President's Grand Jury Testimony

The President testified:

The President referred to Ms. Currie on multiple occasions in his civil deposition when describing his relationship with Ms. Lewinsky. The President appeared "concerned," according to Ms. Currie. The President's grand jury testimony reinforces that conclusion. To the contrary, the President vehemently denied the allegations.

The President denied any kind of sexual relationship with Monica Lewinsky; said that Ms. Lewinsky had made a sexual demand on him; and denied multiple telephone conversations with Monica Lewinsky. The President's aides took the President at his word when he made these statements. The aides' testimony provided the grand jury a false account of the relationship between the President and Ms. Lewinsky. (440) The President relayed to Mr. Podesta one of the false "cover stories" that the President and Ms. Lewinsky had agreed to use.

Mr. Bowles, the White House Chief of Staff,(446) confirmed Mr. Podesta's account of the President's January 21, 1998, statement in which the President denied having a sexual relationship with Ms. Lewinsky. Sidney Blumenthal, an Assistant to the President,(449) similarly testified that the President made statements to him denying the Lewinsky allegations shortly after the first media report.

During those conversations, both the President and Mrs. Clinton offered an explanation for the President's meetings with Ms. Lewinsky, and President Clinton offered an explanation for Ms. Lewinsky's allegations of a sexual relationship.(450)

Testifying before the grand jury, Mr. Blumenthal related his discussion with President Clinton:

Mr. Blumenthal testified that the President's response was "the opposite. Mr. Ickes recalled that the President probably volunteered this information.(462) Mr. Ickes repeated the President's false statements to the grand jury.

B. The President's Grand Jury Testimony

The President testified as follows:

During the President's grand jury testimony, the President admitted that his statements to aides denying a sexual relationship with Ms. Lewinsky "may have been misleading."The President refused six invitations to testify voluntarily before the grand jury. B. The First Lady, the Cabinet, the President's staff, and the President's associates relied on and publicly emphasized the President's denial.

After the President lied to the American people, the President's associates argued that the allegations against the President were false and even scurrilous.

The President thereupon dropped his claim of Executive Privilege.

On August 17, the President testified before the grand jury. The President declined each invitation. The subpoena required the President to appear on July 28.

The President did not tell the truth. 10. Robert S. Bennett, counsel for President Clinton.

15. Lewinsky 8/26/98 Depo. Lewinsky 8/6/98 GJ at 34-35.

18. Lewinsky 8/26/98 Depo. Ms. Lewinsky testified that she had an orgasm. See Lewinsky 8/26/98 Depo. Id. at 22; Lewinsky 7/30/98 Int. at 9. 30. Lewinsky 8/26/98 Depo. As Ms. Lewinsky departed, she observed the President "manually stimulating" himself in Ms. Hernreich's office. Ms. Lewinsky testified that she had an orgasm. See Lewinsky 8/26/98 Depo. Lewinsky 7/30/98 Int. at 12-13; see also Lewinsky Depo. 38. Lewinsky 8/6/98 GJ at 91, 94-97; Lewinsky 8/26/98 Depo. 39. Lewinsky 8/26/98 Depo. Lewinsky 7/30/98 Int. at 14-15.

41. Lewinsky 8/26/98 Depo. 43. Lewinsky 8/26/98 Depo. 44. Ms. Lewinsky testified that she had multiple orgasms. 45. Id. at 50-51; Lewinsky 8/6/98 GJ at 21. On this occasion, the President ejaculated. Lewinsky 8/26/98 Depo. 46. Lewinsky 8/26/98 Depo. See also Lewinsky 8/6/98 GJ at 35-36.

48. Lewinsky 7/30/98 Int. at 11-16; Lewinsky 8/6/98 GJ at 24. Ms. Lewinsky also gave the President Vox, a novel about phone sex. See also Lewinsky 8/26/98 Depo. On nine of the ten occasions, Ms. Lewinsky performed oral sex on the President. On nine occasions, the President touched and kissed Ms. Lewinsky's bare breasts. On four occasions, the President also touched her genitalia. The President and Ms. Lewinsky also had phone sex on at least fifteen occasions.

94. Clinton 8/17/98 GJ at 151.

Clinton 8/17/98 GJ at 17. Lewinsky 7/31/98 Int. at 3.

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

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

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

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

109. Lewinsky 8/26/98 Depo. 111. Lewinsky 8/20/98 GJ at 54.

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

118. Ms. Jones's attorneys had earlier served President Clinton with a document request that sought documents reflecting "any communications, meetings or visits involving" President Clinton and Ms. Lewinsky. 121. Ms. Lewinsky testified that many of her sexual encounters with the President occurred in this windowless hallway. Lewinsky 8/6/96 GJ at 34-36.

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

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

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

132. Currie 1/27/98 GJ at 32-33. 134. Currie 1/27/98 GJ at 36-38 (testifying that Ms. Lewinsky came to the White House and met with the President alone for 15 or 20 minutes). 135. Currie 1/27/98 GJ at 35-36 (testifying that Ms. Lewinsky and the President were in the Oval Office for "[p]erhaps 30 minutes."). 151. Clinton 8/17/98 GJ at 118; Lewinsky 8/6/98 GJ at 53-55.

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

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

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

158. Lewinsky 8/6/98 GJ at 151. 159. Lewinsky 8/6/98 GJ at 33, 152. See also Lewinsky 2/1/98 Statement at 7. Lewinsky 8/6/98 GJ at 132, 140.

160. Currie 5/6/98 GJ at 142 (relating incident where the President asks Ms. Currie about the hat pin he gave to Ms. Lewinsky). Ms. Currie understood from Ms. Lewinsky that the box did contain gifts from the President.(161)

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

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

167. Lewinsky 8/26/98 Depo. at 15-16; Lewinsky 8/6/98 GJ at 27; GJ Exhibit ML-7; Finerman Depo. 170. Lewinsky 8/6/98 GJ at 27-28, GJ Exhibit ML-7; Lewinsky 7/27/98 Int. at 12-14.

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

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

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

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

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

181. Id.; Lewinsky 8/6/98 GJ at 26-28; Lewinsky 7/27/98 Int. at 13. 182. Lewinsky 8/6/98 GJ at 27-28; GJ Exhibit ML-7. 183. Lewinsky 8/6/98 GJ at 27-28, 182-183; GJ Exhibit ML-7. Ms. Lewinsky saw a copy of the book in the President's study in November 1997. Lewinsky 8/6/98 GJ at 183. 185. Lewinsky 8/6/98 GJ at 27-28, 183-84; Lewinsky 7/27/98 Int. at 13; GJ Exhibit ML-7. Ms. Lewinsky testified that she had seen the book in the President's study in November 1997.(186)

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

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

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

Lewinsky 8/6/98 GJ at 27-28; GJ Exhibit ML-7; Lewinsky 7/27/97 Int. at 12-15.

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

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

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

Clinton 8/17/98 GJ at 51-52. 10. Robert S. Bennett, counsel for President Clinton.

15. Lewinsky 8/26/98 Depo. Lewinsky 8/6/98 GJ at 34-35.

94. Clinton 8/17/98 GJ at 151.

Clinton 8/17/98 GJ at 17. Lewinsky 7/31/98 Int. at 3.

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

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

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

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

109. Lewinsky 8/26/98 Depo. 111. Lewinsky 8/20/98 GJ at 54.

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

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

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

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

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

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

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

158. Lewinsky 8/6/98 GJ at 151. 159. Lewinsky 8/6/98 GJ at 33, 152. See also Lewinsky 2/1/98 Statement at 7. Lewinsky 8/6/98 GJ at 132, 140.

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

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

167. Lewinsky 8/26/98 Depo. at 15-16; Lewinsky 8/6/98 GJ at 27; GJ Exhibit ML-7; Finerman Depo. 170. Lewinsky 8/6/98 GJ at 27-28, GJ Exhibit ML-7; Lewinsky 7/27/98 Int. at 12-14.

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

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

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

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

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

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

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

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

Lewinsky 8/6/98 GJ at 27-28; GJ Exhibit ML-7; Lewinsky 7/27/97 Int. at 12-15.

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

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

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

Clinton 8/17/98 GJ at 51-52. 201. Lewinsky 8/6/98 GJ at 167.

203. Lewinsky 8/6/98 GJ at 123; Lewinsky 8/26/98 Depo. at 57-58; Lewinsky 2/1/98 Statement at 4.

206. Lewinsky 8/6/98 GJ at 123-24.

207. Jordan 5/5/98 GJ at 136, 142, 144-45; Lewinsky 8/6/98 GJ at 133, 135.

208. Lewinsky 8/6/98 GJ at 151-52; Lewinsky 8/20/98 GJ at 65-66; Lewinsky 2/1/98 Statement at 6.

209. Lewinsky 8/6/98 GJ at 152; Lewinsky 8/20/98 GJ at 66.

210. Lewinsky 8/6/98 GJ at 152; Lewinsky 8/20/98 GJ at 66. 211. Lewinsky 8/6/98 GJ at 154-59. See also Lewinsky 8/1/98 Int. at 11-12.

212. (213)

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

219. Jordan 5/5/98 GJ at 144; Lewinsky 8/6/98 GJ at 138-39.

221. Lewinsky 8/6/98 GJ at 149-153, 191-192, 195-198; Lewinsky 8/20/98 GJ at 35-36, 47, 49, 65-66.

222. Clinton 8/17/98 GJ at 106.

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

225. Id. at 126; Lewinsky 8/20/98 GJ at 70.

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

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

Lewinsky 8/20/98 GJ at 66.

236. Lewinsky 8/26/98 Depo. 237. Lewinsky 8/6/98 GJ at 166-67 (emphasis added).

238. Id. at 154; Lewinsky 8/20/98 GJ at 71.

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

240. Lewinsky 2/1/98 Statement at 7 (emphasis added); see also Lewinsky 8/6/98 GJ at 179; Lewinsky 8/20/98 GJ at 62 ("I was truthful in my [February 1] proffer").

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

243. Currie 1/27/98 GJ at 57-58.

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

247. Lewinsky 8/6/98 GJ at 156-58.

249. Currie 5/6/98 GJ at 105, 107-08.

250. Lewinsky 8/20/98 GJ at 72-73.

251. Lewinsky 8/6/98 GJ at 158.

Currie 7/22/98 GJ at 172.

259. Lewinsky 2/1/98 Statement at 7 (emphasis added).

260. Lewinsky 8/6/98 GJ at 154-55; see also Lewinsky 8/20/98 GJ at 70-72.

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

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

Lewinsky 8/26/98 Depo. 265. Currie 5/6/98 GJ at 108.

267. Clinton 8/17/98 GJ at 106.

269. Lewinsky 8/20/98 GJ at 5 (Ms. Lewinsky could not visit the President unless Ms. Currie cleared her in); see also Lewinsky 7/31/98 Int. at 4-5 (Currie was "in the loop" when it came to keeping Lewinsky's relationship with the President discreet); Currie GJ 5/6/98 at 14-15, 57-58, 97-98.

270. Lewinsky 8/6/98 GJ at 189-91, 197-98.

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

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

276. Clinton 8/17/98 GJ at 127.

279. Lewinsky 8/6/98 GJ at 121-22.

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

282. Lewinsky 8/19/98 Int. at 4-5; see also Lewinsky 8/6/98 GJ at 123.

286. Lewinsky Affidavit, Jan. 7, 1998, 8 (849-DC-00000634).

288. Lewinsky 2/1/98 Statement at 9; see also Lewinsky 8/19/98 Int. at 4.

295. Clinton 8/17/98 GJ at 120. 296. Clinton 8/17/98 GJ at 117.

308. Lewinsky 8/6/98 GJ at 54-55.

312. Lewinsky 8/6/98 GJ at 55.

313. Clinton 8/17/98 GJ at 117.

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

320. Clinton 8/17/98 GJ at 119.

Lewinsky 8/6/98 GJ at 121-23.

324. Lewinsky 8/6/98 GJ at 67-69.

Lewinsky 7/31/98 Int. at 9-10.

329. Lewinsky 8/13/98 Int. at 2-3.

330. Lewinsky 8/6/98 GJ at 103-04.

336. Lewinsky 7/31/98 Int. at 12. 337. Lewinsky 7/31/98 Int. at 14.

338. Lewinsky 8/26/98 Depo. at 67; Lewinsky 7/31/98 Int. at 14.

339. >Lewinsky 7/31/98 Int. at 14.

341. Lewinsky 7/31/98 Int. at 14-15.

343. Lewinsky 8/6/98 GJ at 26-27 and GJ Exhibit ML-7. Lewinsky 8/4/98 Int. at 8. 346. Lewinsky 8/4/98 Int. at 2.

350. Lewinsky 8/6/98 GJ at 121-23.

351. Id. at 121; Lewinsky 8/1/98 Int. at 6, 10.

352. Lewinsky 8/6/98 GJ at 127-28.

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

356. Lewinsky 8/6/98 GJ at 151-52; Lewinsky 7/27/98 Int. at 7. at 39; Lewinsky 7/27/98 Int. at 5.

358. Lewinsky 8/6/98 GJ at 191-98, 205-06.

360. Id. at 232; Lewinsky 8/6/98 GJ at 209.

361. Lewinsky 8/6/98 GJ at 208-10.

Mr. Fisher: They would include . . . Monica Lewinsky

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

Mr. Jordan had told Ms. Lewinsky to come see him at 5:00 p.m. Lewinsky 8/6/98 GJ at 129. See also Jordan 5/5/98 GJ at 144 (relating why he wanted to tell the President about Ms. Lewinsky's subpoena).

Cf. Jordan 5/5/98 GJ at 225-26 (When President was told Ms. Lewinsky signed affidavit, "[t]here was no elation. 391. Clinton 8/17/98 GJ at 73-75.

403. Currie 1/27/98 GJ at 65-66. Clinton 8/17/98 GJ at 148-49.

Currie 5/7/98 GJ at 85. 404. Currie 5/7/98 GJ at 91. 405. Currie 1/27/98 GJ at 70.

407. Currie 1/27/98 GJ at 71, 73-74. (Currie statement)) Currie 1/27/98 GJ at 72-73.

416. Currie 1/27/98 GJ at 32-34.

419. Currie 5/7/98 GJ at 99-100. 421. Currie 5/7/98 GJ at 102.

422. 831-DC-00000009 (Lewinsky pager records). Lewinsky 8/6/98 GJ at 215-17; Currie 7/22/98 GJ at 148-49.

Currie 5/7/98 GJ at 106-07. Lewinsky 8/26/98 Depo. Lewinsky 8/26/98 Depo. Third, in late 1997, the President saw to it that Ms. Lewinsky received extraordinary job assistance. 495. President Clinton's Motion for Continuance, filed July 28, 1998.

497. Clinton 8/17/98 GJ at 7.

498. Clinton 8/17/98 GJ at 10.

Conclusion

This Referral is respectfully submitted on the Ninth day of September, 1998.

______________________________

Kenneth W. Starr

Independent Counsel