Transcript of President Clinton's Videotape Testimony to the Starr Grand Jury Part 2

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Q Mr. President, if your intent was, as you have earlier testified, that you didn't want anybody to know about this relationship you had with Ms. Lewinsky, why would you feel comfortable giving her gifts in the middle of discovery in the Paula Jones case?

A Well, sir, for one thing, there was no existing improper relationship at that time. I had, for nearly a year, done my best to be a friend to Ms. Lewinsky, to be a counselor to her, to give her good advice, and to help her. She had, for her part, most of the time, accepted the changed circumstances. She talked to me a lot about her life, her job ambitions, and she continued to give me gifts. And I felt that it was a right thing to do to give her gifts back.

I have always given a lot of people gifts. I have always been given gifts. I do not think there is anything improper about a man giving a woman a gift, or a woman giving I a man a gift, that necessarily connotes an improper relationship. So, it didn't bother me.

I wasn't -- you know, this was December 28th. I was -- I gave her some gifts. I wasn't worried about it. I , thought it was an all right thing to do.

Q What about notes and letters, cards, letters and notes to Ms. Lewinsky? After this relationship, this inappropriate intimate relationship between you and Ms. Lewinsky ended, she continued to send you numerous intimate notes and cards, is that right?

A Well, they were -- some of them were, were somewhat intimate. I'd say most of them, most of the notes and cards were, were affectionate all right, but, but she had clearly accepted the fact that there could be no contact between us that was in any way inappropriate.

Now, she, she sent cards sometimes that were just funny, even a little bit off-color, but they were funny. She liked to send me cards, and I got a lot of those cards; several, anyway, I donít know a lot. I got a few.

Q She professed her love to you in these cards after the end of the relationship, didn't she?

Well, -

A She said she loved you?

Sir, the truth is that most of the time, even when she was expressing her feelings for me in affectionate terms, I believed that she had accepted, understood my decision to stop this inappropriate contact. She knew from the very beginning of our relationship that I was apprehensive about it. And I think that in a way she felt a little freer to be affectionate, because she knew that nothing else was going to happen. I can't explain entirely what was in her mind.

But most of these messages were not what you would call over the top. They weren't things that, if you read them, you would say, oh, my goodness, these people are having some sort of sexual affair.

Q Mr. President, the question - -

A But some of them were quite affectionate

Q My question was, did she or did she not profess her love to you in those cards and letters that she sent to you after the relationship ended?

A Most of them were signed, "Love", you know, "Love, Monica." I don't know that I would consider -- I don't believe that in most of these cards and letters she professed her love, but she might well have. I -- but, you know, love can mean different things, too, Mr. Bittman. I have -- there are a lot of women with whom I have never had any inappropriate conduct who are friends of mine, who will say from time to time, I love you. And I know that they donít mean anything wrong by that.

Q Specifically, Mr. President, do you remember a card she sent you after she saw the movie ĎTitanic,í in which she said that she reminisced or dreamed about the romantic feelings that occurred in the movie, and how that reminded her of you two? Do you remember that?

A No, sir, but she could have sent it. I -- just because I don't remember it doesn't mean it wasnít there.

Q You're not denying that, that -

A Oh, no. I wouldn't deny that. I just donít remember it. You asked me if I remembered. I don't. She might have done it.

Q Do you ever remember telling her, Mr. President, that she should not write some of the things that she does in those cards and letters that she sends to you because it reveals, if disclosed, this relationship that you had, and that she shouldn't do it?

A I remember telling her she should be careful what she wrote, because a lot of it was clearly inappropriate and would be embarrassing if somebody else read it. I donít remember when I said that. I don't remember whether it was in '96 or when it was. I don't remember.

Q Embarrassing, in that it was revealing of the intimate relationship that you and she had, is that right?

A I do not know when I said this. So, I don't know whether we did have any sort of inappropriate relationship at the time I said that to her. I don't remember. But itís obvious that if she wrote things that she should not have written down and someone else read it, that it would be embarrassing.

Q She certainly sent you something like that after the relationship began, didn't she? And so, therefore, there was, at the time she sent it, something inappropriate going on?

A Well, my recollection is that she -- that maybe because of changed circumstances in her own life in 1997, after there was no more inappropriate contact, that she sent me more things in the mail, and that there was sort of a disconnect sometimes between what she was saying and the plain facts of our relationship. And I don't know what caused that. But it may have been dissatisfaction with the rest of her life. I don't know.

You know, she had, from the time I first met her talked to me about the rest of her personal life, and it may be that there was some reason for that. It may be that when I did the right thing and made it stick, that in a way she felt a need to cling more closely, or try to get closer to me, even though she knew nothing improper was happening or was going to happen. I don't know the answer to that.

Q After you gave her the gifts on December 28th, did you speak with your secretary, Ms. Currie, and ask her to pick up a box of gifts that were some compilation of gifts that Ms. Lewinsky would have -

A No, sir, I didn't do that.

Q -- to give to Ms. Currie?

A I did not do that.

Q When you testified in the Paula Jones case, this was only two and a half weeks after you had given her these six gifts, you were asked, at page 75 in your deposition, lines 2 through 5, "Well, have you ever given any gifts to Monica Lewinsky?" And you answer, "I donít recall." And you were correct. You pointed out that you -- I actually asked them, for prompting, "Do you know what they were?"

A I think what I meant there was I donít recall what they were, not that I don't recall whether I had given them. And then if you see, they did give me these specifics, and I gave them quite a good explanation here. I remembered very clearly what the facts were about The Black Dog. And I said that I could have given her a hat pin and a Walt Whitman book; that I did not remember giving her a gold broach, which was true. I didn't remember it. I may have given it to her, I but I didn't remember giving her one.

They didn't ask me about the, about the Christmas gifts, and I donít know why I didn't think to say anything about them. But I have to tell you again, I even invited them to have a list. It was obvious to me by this point in the definition, in this deposition, that they had, these people had access to a lot of information from somewhere, and I presume it came from Linda Tripp. And I had no interest in not answering their questions about these gifts. I do not believe that gifts are incriminating, nor do I think they are wrong. I think it was a good thing to do. I'm not, I'm still not sorry I gave Monica Lewinsky gifts.

Q Why did you assume that that information came from Linda Tripp?

A I didnít then?

Q Well, you didn't? I thought you just testified you did then?

A No, no, no. I said I now assume that because -

Q You now assume?

A -- of all of the subsequent events. I didn't know. I just knew that --

Q Let me ask you about -

A -- that somebody had access to some information and they may have known more about this than I did.

Q Let me ask you about the meeting you had with Betty Currie at the White House on Sunday, January 18 of this year, the day after your deposition. First of all, you didnít -Mrs. Currie, your secretary of six-some years, you never allowed her, did you, to watch whatever intimate activity you did with Ms. Lewinsky, did you?

A No, sir, not to my knowledge.

Q And as far as you know, she couldn't hear anything either, is that right?

A There were a couple of times when Monica was there when I asked Betty to be places where she could hear, because Monica was upset and I -- this was after there was -- all the inappropriate contact had been terminated.

Q No, I'm talking -

A But ---

Q -- about the times that you actually had the intimate contact.

A She was -- I believe that -- well, first of all, on that one occasion in 1997, I do not know whether Betty was in the White House after the radio address in the Oval Office complex. I believe she probably was, but I'm not sure. But I'm certain that someone was there. I always Ėalways someone was there. In 1996, I think most of the times that Ms. Lewinsky was there, there may not have been anybody around except maybe coming in and out, but not permanently so. I--that's correct. I never -- I didn't try to involve Betty in that in any way.

Q Well, not only did you not try to involve her, you specifically tried to exclude her and everyone else, isn't that right?

A Well, yes. I've never -- I mean, it's almost humorous, sir. I'd, I'd, I'd have to be an exhibitionist not to have tried to exclude everyone else.

Q So, if Ms. Currie testified that you approached her on the 18th, or you spoke with her and you said, you were always there when she was there, she wasnít was she? That is Mrs. Currie?

A She was always there in the White House, and I was concerned -- let me back up and say --

Q What about the radio address, Mr. President?

A Let me back up a second, Mr. Bittman. I knew about the radio address. I was sick after it was over and I, I was pleased at that time that it had been nearly a year since any inappropriate contact had occurred with Ms. Lewinsky. I promised myself it wasnít going to happen again. The facts are complicated about what did happen and how it happened. But, nonetheless, I'm responsible for it. On that night, she didn't.

I was more concerned about the times after that when Ms. Lewinsky was upset, and I wanted to establish at least that I had not -- because these questions were -- some of them were off the wall. Some of them were way out of line, I thought. And what I wanted to establish was that Betty was there at all other times in the complex, and I wanted to know what Betty's memory was about what she heard, what she could hear. And what I did not know was -- I did not know that. And I was trying to figure out, and I was trying to figure out in a hurry because I knew something was up.

Q So, you wanted -

A After that deposition.

Q --to check her memory for what she remembered, and that is --

A That's correct.

Q -- whether she remembered nothing, or whether she remembered an inappropriate intimate Ė

A Oh, no, no, no, no.

Q -- relationship?

A No. I didn't ask her about it in that way. asked her about what the -- what I was trying to determine was whether my recollection was right and that she was always in the office complex when Monica was there, and whether she thought she could hear any conversations we had, or did she hear any. And then I asked her specifically about a couple of times when - -once when I asked her to remain in the dining room, Betty, while I met with Monica in my study. And once when I took Monica in the, the small office Nancy Hernreich occupies right next to Betty's and talked to her there for a few minutes. That's my recollection of that.

I was trying to -- I knew, Mr. Bittman, to a reasonable certainty that I was going to be asked more questions about this. I didn't really expect you to be in the Jones case at the time. I thought what would happen is that it would break in the press, and I was trying to get the facts down. I was trying to understand what the facts were.

Q If Ms. Currie testified that these were not really questions to her, that they were more like statements, is that not true?

A Well, I can't testify as to what her perception was. I can tell you this. I was trying to get information in a hurry. I was downloading what I remembered. I think Ms. Currie would also testify that I explicitly told her, I once I realized that you were involved in the Jones case -- you, the Office of Independent Counsel -- and that she might have to be called as a witness, that she should just go in there and tell the truth, tell what she knew, and be perfectly truthful.

So, I was not trying to get Betty Currie to say something that was untruthful. I was trying to get as much information as quickly as I could.

Q What information were you trying to get from her when you said, I was never alone with her, right?

A I donít remember exactly what I did say with her. That's what you say I said

Q If Ms. Currie testified to that, if she says you told her, I was never alone with her, right?

A Well, I was never alone with her -

Q Did you not say that, Mr. President?

A Mr. Bittman, just a minute. I was never alone with her, right, might be a question. And what I might have meant by that is, in the Oval Office complex. Could--

Q Well, you knew the answer to that, didn't you?

A Weíve been going for more than an hour. Would you mind if we took a break? I need to go to the restroom.

MR. BITTMAN: Let's take a break.

MR. KENDALL: Itís 2:38.

(Whereupon, the proceedings were recessed from 2:38 p.m. until 2:4B p.m.)

MR. KENDALL: It is 2:38 -- sorry, 2:48.

BY MR. WISENBERG:

Q Mr. President, I want to, before I go into a new subject area, briefly go over something you were talking about with Mr. Bittman.

The statement of your attorney, Mr. Bennett, at the Paula Jones deposition, "Counsel is fully aware" -- it's page 54, line 5 Ė "Counsel is fully aware that Ms. Lewinsky has filed, has an affidavit which they are in possession of saying that there is absolutely no sex of any kind in any manner, shape or form, with President Clinton..

That statement is made by your attorney in front of Judge Susan Webber Wright, correct?

A That's correct.

Q That statement is a completely false statement. Whether or not Mr. Bennett knew of your relationship with Ms. Lewinsky, the statement that there was "no sex of any kind in any manner, shape or form, with President Clinton," was an utterly false statement. Is that correct?

A It depends on what the meaning of the word "is" is. If the Ėif he Ė 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.

But, as I have testified, and I'd like to testify again, this is -- it is somewhat unusual for a client to be asked about his lawyer's statements, instead of the other way around. I was not paying a great deal of attention to this exchange. I was focusing on my own testimony.

And if you go back and look at the sequence of this, you will see that the Jones lawyers decided that this was going to be the Lewinsky deposition, not the Jones deposition. And, given the facts of their case, I can understand why they made that decision. But that is not how I prepared for it. That is not how I was thinking about it.

And I am not sure, Mr. Wisenberg, as I sit here today, that I sat there and followed all these interchanges between the lawyers. I'm quite sure that I didnít follow all the interchanges between the lawyers all that carefully. And I don't really believe, therefore, that I can say Mr. Bennett's testimony or statement is testimony and is imputable to me. I didnít -- I don't know that I was even paying that much attention to it.

Q You told us you were very well prepared for the deposition.

A No. I said I was very well prepared to talk about Paula Jones and to talk about Kathleen Willey, because she had made a related charge. She was the only person that I think I was asked about who had anything to do with anything that would remotely approximate sexual harassment. The rest of this looked to me like it was more of a way to harass me.

Q You are the President of the United States and your attorney tells a United States District Court Judge that there is no sex of any kind, in any way, shape or form, whatsoever. And you feel no obligation to do anything about that at that deposition, Mr. President?

A I have told you, Mr. Wisenberg, I will tell you for a third time. I am not even sure that when Mr. Bennett made that statement that I was concentrating on the exact words he used.

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.

Q Was Mr. Bennett aware of this tense-based distinction you are making now -

A I don't -

MR. KENDALL: I'm going to object to any questions about communications with private counsel.

MR. WISENBERG: Well, the witness has already testified, I think, that Mr. Bennett didnít know about the inappropriate relationship with Ms. Lewinsky. I guess -

THE WITNESS: Well, you'll have to ask him that. you know. He was not a sworn witness and I was not paying that close attention to what he was saying. I've told you that repeatedly. I was -- I don't -- I never even focused on that until I read it in this transcript in preparation for this testimony.

When I was in there, I didnít think about my I lawyers. I was, frankly, thinking about myself and my testimony and trying to answer the questions.

BY MR. WISENBERG:

Q I just want to make sure I understand, Mr. President. Do you mean today that because you were not I engaging in sexual activity with Ms. Lewinsky during the deposition that the statement of Mr. Bennett might be literally true?

A No, sir. I mean that at the time of the deposition, it had been -- that was well beyond any point of improper contact between me and Ms. Lewinsky. So that anyone generally speaking in the present tense, saying there is not an improper relationship, would be telling the truth if that person said there was not, in the present tense; the present tense encompassing many months. That's what I meant by that.

Not that I was -- I wasnít trying to give you a cute answer, that I was obviously not involved in anything improper during a deposition. I was trying to tell you that generally speaking in the present tense, if someone said that, that would be true. But I don't know what Mr. Bennett had in his mind. I don't know. I didnít pay any attention to this colloquy that went on. I was waiting for my instructions as a witness to go forward. I was worried about my own testimony.

Q I want to go back to some questions about Mr. Jordan and we are going to touch a little bit on the December 19th meeting and some others. Mr. Jordan is a long-time friend of yours, is that correct, Mr. President?

A Yes, sir. We've been friends probably 20 years, maybe more.

Q You said you consider him to be a truthful person, correct?

A I do.

Q If Mr. Jordan has told us that he visited you in the Residence on the night of the 19th, after a White House holiday dinner, to discuss Monica Lewinsky and her subpoena with you, do you have any reason to doubt it?

A No. I've never known him to say anything that wasnít true. And his memory of these events, I think, would be better than mine because I had a lot of other things going on.

Q We have WAVE records that will show that, but in the interest of time I'm not going to -since you don't dispute that, I'm not going to show them right now. And, in fact, that was the very day Monica Lewinsky was subpoenaed, wasnít it, the night that he came to see you?

A I donít have an independent memory of that, but you would probably know that. I mean, I'm sure there is a record of when she got her subpoena.

Q If Mr. Jordan has told us that he spoke with you over the phone within about an hour of Monica receiving her subpoena, and later visited you that very day, the night at the White House, to discuss it, again youíd have no reason to doubt him, is that correct?

A I've already -- I believe I've already testified about that here today, that I had lots of conversations with Vernon. I'm sure that I had lots of conversations with him that included comments about this. And if he has a specific memory of when 1 had some conversation on a certain day, I would be inclined to trust his memory over mine, because under the present circumstances my head's probably more cluttered than his, and my schedule is probably busier. He's probably got better records.

Q And when Mr. Jordan met with you at the Residence that night, sir, he asked you if you'd been involved in a sexual relationship with Monica Lewinsky, didn't he?

A I do not remember exactly what the nature of the conversation was. I do remember that I told him that there was no sexual relationship between me and Monica Lewinsky, which was true. And that -- then all I remember for the rest is that he said he had referred her to a lawyer, and I believe it was Mr. Carter, and I don't believe I've ever met Mr. Carter. I don't think I know him.

Q Mr. President, if Mr. Jordan has told us that he had a very disturbing conversation with Ms. Lewinsky that day, then went over to visit you at the White House, and that before he asked you the question about a sexual relationship, related that disturbing conversation to you, the conversation being that Ms. Lewinsky had a fixation on you and thought that perhaps the First Lady would leave you at the end of --that you would leave the First Lady at the end of your term and come be with Ms. Lewinsky, do you have any reason to doubt him that it was on that night that that conversation happened?

A All I can tell you, sir, is I, I certainly don't remember him saying that. Now, he could have said that because, as you know, a great many things happened in the ensuing two or three days. And I could have just forgotten it. But I don't remember him ever saying that.

Q At any time?

A No, I don't remember him saying that. What I remember was that he said that Monica came to see him, that she was upset that she was going to have to testify, that he had referred her to a lawyer.

Q In fact, she was very distraught about the subpoena, according to Mr. Jordan, wasn't she?

A Well, he said she was upset about it. I don't remember -- I don't remember any, at any time when he said this, this other thing you just quoted me. I'm sorry. I just don't remember that.

Q That is something that one would be likely to remember, don't you think, Mr. President?

A I think I would, and I'd be happy to share it with you if I did. I only had one encounter with Ms. Lewinsky, I seem to remember, which was somewhat maybe reminiscent of that. But not that, if you will, obsessive, if that's the way you want to use that word.

Q Do you recall him at all telling you that he was concerned about her fascination with you, even if you don't remember the specific conversation about you leaving the First Lady?

A I recall him saying he thought that she was upset with -- somewhat fixated on me, that she acknowledged that she was not having a sexual relationship with me, and that she did not want to be drug into the Jones lawsuit. That's what I recall. And I recall getting, saying that he had recommended a lawyer to her and she had gone to see the lawyer. That's what I recall.

I don't remember the other thing you mentioned. I just -- I might well remember it if he had said it. Maybe he said it and I've forgotten it, but I don't -- I can't tell you that I remember that.

Q Mr. President, you swore under oath in the Jones l case that you didn't think anyone other than your lawyers had ever told you that Monica Lewinsky had been subpoenaed. Page 68, line 22 [sic] through page 69, line 3. Here's the testimony, sir.

Question -- we've gone over it a little bit before: Did anyone other than your attorneys ever tell you that Monica Lewinsky had been served with a subpoena in this case?. Answer, I don't think so..

Now, this deposition was taken just three and a half weeks after, by your own testimony, Vernon Jordan made a trip at night to the White House to tell you, among other things, that Monica Lewinsky had been subpoenaed and was upset about it. Why did you give that testimony under oath in the Jones case, sir?

A Well, Mr. Wisenberg, I think you have to - again, you have to put this in the context of the flow of questions, and I've already testified to this once today. I will testify to it again.

My answer to the next question, I think, is a way of finishing my answer to the question and the answer you've said here. I was trying to remember who the first person, other than Mr. Bennett -- I don't think Mr. Bennett -- who the first person told me that, who told me Paula Jones had, I mean, excuse me, Monica Lewinsky had a subpoena. And I thought that Bruce Lindsey was the first person. And that's how I was trying to remember that.

Keep in mind, sort of like today, these questions are being kind of put at me rapid-fire. But, unlike today, I hadn't had the opportunity to prepare at this level of detail. I didn't -- I was trying to keep a lot of things in my head that I had remembered with regard to the Paula Jones case and the Kathleen Willey matter, because I knew I would be asked about them. And I gave the best answers I could. Several of my answers are somewhat jumbled.

But this is an honest attempt here -- if you read both these answers, it's obvious they were both answers to that question you quoted, to remember the first person, who was not Mr. Bennett, who told me. And I don't believe Vernon was the first person who told me. I believe Bruce Lindsey was.

Q Let me read the question, because I want to talk I about the first person issue. The question on line 25 of page 68 is, "Did anyone other than your attorneys ever tell you that Monica Lewinsky had been served with a subpoena in this case?" Answer, "I don~t think so."

You would agree with me, sir, that the question doesn't say, the question doesn't say anything about who was the first person. It just says, did anyone tell you. Isn't that correct?

A That's right. And I said Bruce Lindsey, because I was trying to struggle with who -- where I had heard this. And they were free to ask a follow-up question, and they didn't.

Q Mr. President, three and a half weeks before, Mr. Jordan had made a special trip to the White House to tell you Ms. Lewinsky had been subpoenaed; she was distraught; she had a fixation over you. And you couldn't remember that, three and a half weeks later?

A Mr. Wisenberg, if -- they had access to all this information from their conversations with Linda Trip, if that was the basis of it. They were free to ask me more questions. They may have been trying to trick me.

Now, they knew more about the details of my relationship with Monica Lewinsky. I'm not sure everything they knew was true, because I don't know. I've not heard these tapes or anything. But they knew a lot more than I did. And instead of trying to trick me, what they should have done is to ask me specific questions, and I invited them on more than one occasion to ask follow-up questions.

This is the third or fourth time that you seem to be complaining that I did not do all their work for them. That just setting here answering answering questions to the beat of my memory, with limited preparation, was not enough. That I should have actually been doing all their work for them.

Now, they~d been up all night with Linda Trip, who had betrayed her friend, Monica Lewinsky, autoed her in the back and given them all this information. They could have helped more. If they wanted to ask me follow-up questions, they could. They didn't. I'm sorry. I did the beat I could.

Q Can you tell the grand jury what ia tricky about the question, ~Did anyone other than your attorneys ever tell you. -

A No, there'squestion nothing -- I'm just telling -- I have explained. I will now explain for the third time, sir. I was being asked a number of question here. I was struggling to remember then. There were lot of things that had gone on during this time period that had nothing to do with Monica Lewinsky.

You know, I believed then, I believe now that Monica Lewinsky could have sworn out an honest affidavit, that under reasonable circumstances, and without the benefit of what Linda Tripp did to her, would have given her a chance not to be a witness in this case.

So, I didn't have perfect memory of all these events that have now, in the last seven months, once Ms. Lewinsky was kept for several hours by four or five of your lawyers and four or five FBI agents, as if she were a serious felon, these things have become the most important matters in the world. At the moment they were occurring, many other things were going on.

I honestly tried to remember when -- you know, if somebody asked you, has anybody ever talked to you about this, you normally think, well, where was the first time I heard that. That's all I was trying to do here. I was not trying to say not Vernon Jordan, but Bruce Lindsey. everybody knows Vernon Jordan is a friend of mine. I probably would have talked to Vernon Jordan about the Monica Lewinsky problem if he had never been involved in it. But, I was not trying to mislead them. I was trying to answer this l question with the first person who told me that.

Now, I realize that wasn't the specific question. They were free to ask follow-ups, just like you're asking follow-ups today. And I can't explain why I didn't answer every question in the way you seem to think I should have, and I certainly can't explain why they didn't ask what seemed to me to be logical follow-ups, especially since they spent all that time with Linda Tripp the night before.

Q You've told us that you understand your obligation then, as it is now, is to tell the whole truth, sir. Do you recall that?

A I took the oath here.

Q If Vernon Jordan -

A You even read me a definition of the oath.

Q If Vernon Jordan has told us that you have an extraordinary memory, one of the greatest memories he's ever seen in a politician, would that be something you would care to dispute?

A No, I do have a good memory. At least, I have had a good memory in my life.

Q Do you understand that if you answered, "I don't think so", to the question, has anyone other than your attorneys told you that Monica Lewinsky has been served with a subpoena in this case, that if you answered, "I don't think so", but you really knew Vernon Jordan had been telling you all about it, you understand that that would be a false statement, presumably perjurious?

A Mr. Wisenberg, I have testified about this three times. Now, I will do it the fourth time. I am not going to answer your trick questions.

I -- people don't always hear the same questions in the same way. They don't always answer them in the same way. I was so concerned about the question they asked me that the next question I was asked, I went back to the previous question, trying to give an honest answer about the first time I heard about the Lewinsky subpoena.

I -- look. I could have had no reasonable expectation that anyone would ever know that, that -or not, excuse me, not know if this thing -- that I would talk to Vernon Jordan about nearly everything. I was not interested in -- if the implication of your question is that somehow I didn't want anybody to know I had ever talked to Vernon Jordan about this, that's just not so.

It's also -- if I could say one thing about my memory. I have been blessed and advantaged in my life with a good memory. Now, I have been shocked, and so have members of my family and friends of mine, at how many things that I have forgotten in the last six years, I think because of the pressure and the pace and the volume of events in the President's life, compounded by the pressure of your four year inquiry, and all the other things that have happened, I'm amazed there are lots of times when I literally can't remember last week.

If you ask me, did you talk to Vernon -when was the last time you talked to Vernon Jordan, what time of day was it, when did you see him, what did you ask, my answer was the last -- you know, if you answered [sic] me, when was the last time you saw a friend of yours in California, if you asked me a lot of questions like that, my memory is not what it was when I came here, because my life is so crowded.

And now that -- as I said, you have made this the most important issue in America. I mean, you have made it the most important issue in America from your point of view. At the time this was occurring, even though I was concerned about it, and I hoped she didn't have to testify, and I hoped this wouldn't come out, I felt -- I will say again -- that she could honestly fill out an affidavit that, under reasonable circumstances, would relieve her of the burden of testifying.

I am not trying to exclude the fact that I talked to Vernon here. I just -- all I can tell you is I believe this answer reflects I was trying to remember the first person who told me who was not Mr. Bennett, and I believe it was Bruce Lindsey.

Q As you yourself recalled, just recalled, Mr. President, Vernon Jordan not only discussed the subpoena with you that night, but discussed Prank Carter, the lawyer he had often for Ms. Lewinsky. And also Mr. Jordan discussed with you over the next few weeks, after the 19th of December, in addition to the job aspects of Ms. Lewinsky's job, he discussed with you her affidavit that she was preparing in the case. Is that correct, sir?

A I believe that he did notify us, I think, when she signed her affidavit. I have a memory of that. Or it seems like he said that she had signed her affidavit.

Q If he's told us that he notified you around January 7th, when she signed her affidavit, and that you generally understood that it would deny a sexual relationship, do you have any reason to doubt that?

A No.

Q So, that's the affidavit, the lawyer, and the subpoena. And yet when you were asked, sir, at the Jones deposition about Vernon Jordan, and specifically about whether or not he had discussed the lawsuit with you, you didn't reveal that to the Court. I want to refer you to page 72, line 16.

It's -- It's going to go down, it might go down Line 16. Question, Has it ever been reported to you that he. -- and that's referring to Mr. Jordan. At line l 12 you were asked, "You know a man named Vernon Jordan?, and you answer, "I know him well."

Going down to 16, "Has it ever been reported to you that he met with Monica Lewinsky and talked about this case?"

This is your answer, or a portion of it: "I knew that he met with her. I think Betty suggested that he meet with her. Anyway, he met with her. I, I thought that he talked to her about something else".

Why didn't you tell the Court, when you were under oath and sworn to tell the truth, the whole truth, and nothing but the truth, that you had been talking with Vernon Jordan about the case, about the affidavit, the lawyer, the subpoena

A Well, that's not the question I was asked. I was not asked any question about -- I was asked, "Has it ever been reported to you that he met with Monica Lewinsky and talked about this case." I believe -- I may be wrong about this -- my impression was that at the time, I was focused on the meetings. I believe the meetings he had were meetings about her moving to New York and getting a job.

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

Q Are you saying, sir, that you forgot when you were asked this question that Vernon Jordan had come on December 19th, just three and a half weeks before, and said that he had met that day, the day that Monica got the subpoena?

A It's quite possible -- it's a sort of a jumbled answer. It's quite possible that I had gotten mixed up between whether she had met with him or talked to him on the telephone in those three and a half weeks.

Again, I say, sir, just from the tone of your voice and the way you are asking questions here, it's obvious that this is the most important thing in the world, and that everybody was focused on all the details at the time. That's not the way it worked. I was, I was doing my best to remember.

Now, keep in mind, I don't know if this is true, I but the news reports are that Linda Tripp talked to you, then went and talked to the Jones lawyers, and, you know, that she prepared them for this. Now, maybe -- you seem to be criticizing me because they didn't ask better questions and, as if you didn't prepare them well enough to sort of set me up or something. I don't know what's going on here.

All I can tell you is I didn't remember all the details of all this. I didn't remember what -when Vernon talked to me about Monica Lewinsky, whether she talked to him on the telephone or had a meeting. I didn't remember all those details. I was focused on the fact that Monica went to meet with Vernon after Betty helped him set it up, and had subsequent meetings to talk about her move to New York.

Now, keep in mind at this time, at this time, until this date here when it's obvious that something funny~s going on here and there's some sort of a gotcha game at work in this deposition, until this date, I didn't know that Ms. Lewinsky's deposition [sic] wasn't going to be sufficient for her to avoid testifying. I didn't, you know -

MR. KENDALL: Excuse me, Mr. President, I think -

THE WITNESS: So, all these details -

MR. KENDALL: -- you mean her affidavit.

BY MR. WISENBERG:

Q You mean her affidavit

A Excuse me. I'm sorry. Her affidavit. Thank you.

So, I don't necessarily remember all the details of all these questions you're asking me, because there was a lot of other things going on, and at the time they were going on, until all this came out, this was not the most important thing in my life. This was just another thing in my life.

Q But Vernon Jordan met with you, sir, and he reported that he had met with Monica Lewinsky, and the discussion was about the lawsuit, and you didn't inform, under oath, the Court of that in your deposition?

A I gave the best answer I could, based on the best memory I had at the time they asked me the question. That's the only answer I can give you, sir.

Q And before -

A And I think I may have been confused in my memory, because I've also talked to him on the phone about what he said about whether he talked to her or met with her. That's all I can tell you.

But, let me say again, I don't have the same view about this deposition -- I mean, this affidavit -- that I think you do. I felt very strongly that Ms. Lewinsky and everybody else that didn't know anything about Paula Jones and anything about sexual harassment, that she and others were themselves being harassed for political purposes, in the hope of getting damaging information that the Jones lawyers could unlawfully leak.

Now, I believed then, I believe today, that she could execute an affidavit which, under reasonable circumstances with fair-minded, non politically-oriented people, would result in her being relieved of the burden to be put through the kind of testimony that, thanks to Linda Tripp's work with you and with the Jones lawyers, she would and I have been put through. I don't think that's dishonest. I don't think that's illegal. I think what they were trying to do to her and all these other people, who knew nothing about sexual harassment, was outrageous, just so they could hurt me politically.

So, I just don't have the same attitude about it that you do.

Q Well, you're not telling our grand jurors that because you think the case was a political case or a setup, Mr. President, that that would give you the right to commit perjury or

A No, sir.

Q -- not to tell the full truth?

A In the face of their, the Jones lawyers the people that were questioning me, in the face of their illegal leaks, their constant, unrelenting illegal leaks in a lawsuit that I knew and, by the time this deposition and this discovery started, they knew was a bogus suit on the law and a bogus suit on the facts.

Q The question is -

A In the face of that, I knew that in the face of their illegal activity, I still had to behave lawfully. I wanted to be legal without being particularly helpful. I thought that was, that was what I was trying to do. And this is the first -- you are the first person who ever suggested to me that, that I should have been doing their lawyers' work for them, when they were perfectly free to ask follow-up questions. On one or two occasions, Mr. Bennett invited them to ask follow-up questions.

It now appears to me they didn't because they were afraid I would give them a truthful answer, and that there had been some communication between you and Ms. Tripp and them, and they were trying to set me up and trick me. And now you seem to be complaining that they didn't do a good enough job.

I did my best, sir, at this time. I did not know what I now know about this. A lot of other things were going on in my life. Did I want this to come out? No. Was I embarrassed about it? Yes. Did I ask her to lie about it? No. Did I believe there could be a truthful affidavit? Absolutely.

Now, that's all I know to say about this. I will continue to answer your questions as best I can.

Q You're not going back on your earlier statement that you understood you were sworn to tell the truth, the whole truth, and nothing but the truth to the folks at that deposition, are you, Mr. President?

A No, sir, but I think we might as well put this out on the table. You tried to get me to give a broader interpretation to my oath than just my obligation to tell the truth. In other words, you tried to say, even though these people are treating you in an illegal manner in illegally leaking these depositions, you should be a good lawyer for them. And if they don't have enough sense to write -- to ask a question, and even if Mr. Bennett invited them to ask follow-up questions, if they didn't do it, you should have done all their work for them.

Now, I will admit this, sir. My goal in this deposition was to be truthful, but not particularly helpful. I did not wish to do the work of the Jones lawyers. I deplored what they were doing. I deplored the innocent people they were tormenting and traumatizing. I deplored their illegal leaking. I deplored the fact that they knew, once they knew our evidence, that this was a bogus lawsuit, and that because of the funding they had from my political enemies, they were putting ahead. I deplored it. But I was determined to walk through the mine field of this deposition without violating the law, and I believe I did.

Q You are not saying, are you, Mr. President, in terms of doing the work for the Jones folks, the Jones lawyers, that you could, you could say, as part of your not helping them, "I don't know" to a particular question, when you really knew, and that it was up to them -- even if you really knew the answer, it was up to them to do the followup, that you kind of had a one free "I don't know".

A No, sir.

Q If I could finish up? I've been very patient, Mr. President, in letting you finish.

You didn't think you had a free shot to say, "I don't know", or "I don't recall", but when you really did know and you did recall, and it was just up to them, even if you weren't telling the truth, to do a follow-up and to catch you?

A No, sir, I'm not saying that. And if I could give you one example? That's why I felt that I had to come back to that question where I said, I don~t know that, and talk about Bruce Lindsey, because I was trying, I was honestly trying to remember how I had first heard this. I wasn't hung up about talking about this.

All I'm saying is, the -- let me say something sympathetic to you. I've been pretty tough. So, let me say something sympathetic. All of you are intelligent people. You've worked hard on this. You've worked for a long time. You've gotten all the facts. You've seen a lot of evidence that I haven't seen. And it's, it's an embarrassing and personally painful thing, the truth about my relationship with Ms. Lewinsky.

So, the natural assumption is that while all this was going on, I must have been focused on nothing but this; therefore, I must remember everything about it in the sequence and form in which it occurred. All I can tell you is, I was concerned about it. I was glad she saw a lawyer. I was glad she was doing an affidavit. But there were a lot of other things going on, and I don't necessarily remember all. And I don't know if I can convince you of that.

But I tried to be honest with you about my mindset, about this deposition. And I'm just trying to explain that I don't have the memory that you assume that I should about some of these things.

Q I want to talk to you for a bit, Mr. President, about the incident that happened at the Northwest Gate of the White House on December 5th -- sorry, December 6th, 1997. If you would give me just a moment?

That was a -- let me ask you first. In early nineteen -- in early December 1997, the Paula Jones case was pending, correct?

A Yes, sir.

Q You were represented by Mr. Bennett, of course?

A That's correct.

Q In that litigation?

A Yes, I did.

Q How -

A He was.

Q I'm sorry. Go ahead.

A No, no. Yes, he was representing me.

Q How often did you talk to him or meet with him, if you can just recall, at that time in the litigation?

A Well, we met, I would say -- I wish Mr. Ruff were answering this question, instead of me. His memory would be better. We met probably, oh, for a long time we didn't meet all that often, maybe once a month. And then the closer we got to the deposition, we would meet more frequently. So, maybe by this time we were meeting more.

We also -- there was a period when we had been approached about -

MR. KENDALL: Again, the question only goes to the number of meetings and not the content of any conversations with your lawyer.

THE WITNESS: I understand. We're not talking about the content.

There was a, there was a period in which we, I think back in the summer before this, when we had met more frequently. But I would say normally once a month. Sometimes something would be happening and we'd meet more. And then, as we moved toward the deposition, we would begin to meet more.

BY MR. WISENBERG:

Q A witness list came out on December 5th of 1997, with Monica Lewinsky's name on it. Mr. President, when did you find out that Monica's name was on that witness list?

A I believe that I found out late in the afternoon on the 6th. That's what I believe. I've tried to remember with great precision, and because I thought you would ask me about this day, I've tried to remember the logical question, which is whether, whether I knew it on the 6th and, if so, at what time.

I don't -- I had a meeting in the late afternoon on the 5th, on the 6th -- excuse me, on the 6th -- and I believe that's when I learned about it.

Q Now, on the morning of the 6th, Monica Lewinsky came to the Northwest Gate and found out that you were being visited by Eleanor Mondale at the time, and had an extremely angry reaction. You know that, sir, now, don't you?

A I have, I have -- I know that Monica Lewinsky came to the gate on the 6th and apparently directly called in and wanted to see me and couldn't, and was angry about it. I know that.

Q And she expressed that anger to Betty Currie over the telephone, isn't that correct, sir?

A That, Betty told me that.

Q And she then later expressed her anger to you in one of her telephone conversations with Betty Currie, is that correct?

A You mean did I talk to her on the phone?

Q Monica Lewinsky, that day, before she came in to visit in the White House?

A Mr. Wisenberg, I remember that she came in to visit that day. I remember that she was upset. I don't recall whether I talked to her on the phone before she came in t visit, but I well may have. I'm not denying it that I did. I just don't recall that.

Q And Mrs. Currie and yourself were very irate that Ms. Lewinsky had overheard that you were in the Oval Office with a visitor on that day, isn't that correct, that you and Mrs. Currie were very irate about that?

A Well, I don't remember all that. What I remember is that she was very -- Monica was very upset. She got upset from time to time. And, and I was, you know, I couldn't see her. I had, I was doing, as I remember, I had some other work to do that morning and she had just sort of showed up and wanted to be let in, and wanted to come in at a certain time and she wanted everything to be that way, and we couldn't see her. Now, I did arrange to see her later that day. And I was upset about her conduct.

I'm not sure that I knew or focused on at that moment exactly the question you asked. I remember I was, I thought her conduct was inappropriate that day.

Q I want to go back and I want to take them one at a time. Number one, did you find out at some point during that day that Monica had overheard from somebody in the Secret Service that you were meeting with Ms. Mondale, and that Monica got very irate about that?

A I knew that at some point. I don't know whether I found out that, that day. I knew that day, I knew that somehow she knew that among, that, that Eleanor Mondale was in to see us that day. I knew that. I don't know that I knew how she knew that on that day. I don't remember that.

Q That leads into my second question, which is, weren't you irate at the Secret Service precisely because they had revealed this information to Ms. Lewinsky on that very day, so irate that you told several people, or at least one person, that somebody should be fired over this, on that very day?

A I don't remember whether it happened on that very day. But, let me tell you that the Uniformed Secret Service, I if that ia in fact what happened and I will stipulate that that is, that no one should be telling anybody, not anybody, not a member of my staff, who the President ia meeting with. That's an inappropriate thing to do.

So, I would think that if that, in fact, ia what I heard when I heard it, I would have thought.that was a bad thing. I don't know that I said that. I don~t, I don't remember what I said, and I don't remember to whom I said it.

Q It would be an inappropriate thing, sir, and that leads into my next question ia that why did Mrs. Currie, on your instructions, later that day tell many of the Secret Service Officers involved that it never happened, to forget about it?

A That what never happened?

Q The incident that you were so irate about earlier; the incident of somebody disclosing to Ms. Lewinsky that Ms. Mondale was in the Oval Office?

A I don't know the answer to that. I think maybe, you know, I don't know. I don't know the answer.

Q You don't recall that you later gave orders to the effect that we are going to pretend this never happened, or something --

A No, sir.

Q -- like that?

A No, sir. I don't recall it. First of all, I don't recall that I gave orders to fire anybody, if that was the implication of your first statement.

Q It wasn't an implication. Actually, the question was that you initially wanted somebody fired. You were so mad that you wanted somebody fired.

A I don't remember that, first of all. I remember l thinking it was an inappropriate thing to do. And I, I, I remember, as I usually do when I'm mad, after awhile I wasn't so mad about it, and I'm quite aware that Ms. Lewinsky has a way of getting information out of people when she's either charming or determined. And it -- I could have just said, well, I,m not so mad about it any more.

But I don't remember the whole sequence of events you'rere talking to me about now, except I do remember that somehow Monica found out Eleanor Mondale was there. I learned either that day or later that one of the Uniformed Division personnel had told her. I do -- I thought then it was a mistake. I think now it was a mistake. I'm not sure it~s a mistake someone should be terminated over. I think that, you know, you could just tell them not to do that any more.

Q In fact, it would kind of be an overreaction, to get irate or terminate somebody for revealing to a former White House staffer who visits where the President is, don't you think, sir?

A Well, it would depend upon the facts. I think on the whole people in the Uniformed Secret Service who are working on the gate have no business telling anybody anything about the President '~ schedule, just as a general principal. I didn't mind anybody knowing that she was there, if that's what you're saying. I could care less about that. But I think that the schedule itself -- these uniformed people, you know, somebody shouldn't just be able to come up on the street and, because they know who the Secret Service agent is, he says who the President's with. I don't think that's proper.

Q I agree, Mr. President.

A But, on the other hand, I didn't, you know, I, I wanted to know what happened. I think we found out what happened. And then they were, I think,'told not to let it happen again, and I think that's the way it should have been handled. I think it was handled in the appropriate way.

Q You have no knowledge of the fact that Secret Service officers were told later in the day something to the effect of, this never happened, this event never happened? You have no knowledge of that?

A I'm not sure anybody ever told that to me. I mean, I thought you were asking -- let me just say, my interpretation of this, of your previous question was different than what you're asking now.

What I remember was being upset that this matter would be discussed that -- by anybody. It's incidental it happened to be Monica Lewinsky. And that, that whatever I said, I don't recall. But then thinking that the appropriate thing to do was to say, look, just this, this is not an appropriate thing for you to be talking about, the President's schedule, and it shouldn't happen again.

Now, the question you seem to be asking me now -- I just want to be sure I'm getting the right question -- is whether I gave instructions, in effect, to pretend that Monica Lewinsky was never at the gate. And if --

Q To the effect of pretend --

A And if that is the question you are asking me, I don't believe I ever did that, sir. I certainly have no memory of doing that.

Q Or anything to that effect?

A I don't know what that means.

Q Is that your testimony?

A What does that mean, anything to that effect?

Q Well, Mr. President, you've told us that you were not going to try to help the Jones attorneys, and I think it's clear from your testimony that you were pretty literal at times. So, that's why I'm saying, I don't neceeearily know the exact words. The question was, do you have any knowledge of the fact --

A Of that?

Q -- of the fact that later in the day, on Saturday, the 6th of December, 1997, Secret Service people were then, were told something to this effect: This event never happened, let's just pretend This event did not happen. Do you have knowledge of it, or not?

A No, sir. And I, I didn't instruct the Secret Service in that regard. I have no memory of saying anything to anybody in the Secret Service that would have triggered that kind of instruction.

Q Did you tell Captain Purdy, while you were standing in the doorway between the Oval Office and Betty Currie's office, did you tell Captain Purdy of the Uniformed Division, I hope I can count on your discretion in this matter? At the end of the day when you all were talking about that earlier incident, did you tell him that or anything like that, sir?

A I don't remember anything I said to him in that regard. I have no recollection of that whatever.

MR. WISENBERG: Let's take a break now.

MR. KENDALL: Thank you, 3:38.

(Whereupon, the proceedings were recessed from 3:38 p.m. l until 4:01 p.m.)

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