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MR. KENDALL: It is 4:01. BY MR. WISENBERG: Mr. President, the next series of questions are from the grand jurors. And let me tell you that the grand jurors want you to be more specific about the inappropriate conduct. The first question was, one of the grand jurors has said that you referred to what you did with Ms. Lewinsky as inappropriate contact; what do you mean by that? A I mean just what I said. But I would like to ask the grand jury, because I think I have been quite specific and I think I've been willing to answer some specific questions that I haven't been asked yet, but I do not want to discuss something that is intensely painful to me. This has been tough enough already on me and on my family, although I take responsibility for it. I have no one to blame but myself. What I meant was, and what they can infer that I meant was, that I did things that were -- when I was alone with her, that were inappropriate and wrong. But that they did not include any activity that was within the definition of sexual relations that I was given by Judge Wright in the deposition. I said that I did not do those things that were in that, within that definition, and I testified truthfully to that. And that's all I can say about it. Now, you know, if there’s any doubt on the part of the grand jurors about whether I believe some kind of activity falls within that definition or outside that definition, I'd be happy to try to answer that. Q Well, I have a question regarding your definition then. And my question is, is oral sex performed on you within that definition as you understood it, the definition in the Jones A As I understood it, it was not, no. Q The grand jurors would like to know upon what basis, what legal basis you are declining to answer more specific questions about this? I've mentioned to you that obviously you have privileges, privileges against self-incrimination. There's no general right not to answer questions. And so one of the questions from the grand jurors is what basis, what legal basis are you declining to answer these questions? A I'm not trying to evade my legal obligations or my willingness to help the grand jury achieve their legal obligations. As I understand it, you want to examine whether you believe I told the truth in my deposition, whether I asked Ms. Lewinsky not to tell the truth, and whether I did anything else with evidence, or in any other way, amounting to an obstruction of justice or a subornation of perjury. And I'm prepared to answer all questions that the grand jury needs to draw that conclusion. Now, respectfully, I believe the grand jurors can ask me if I believe -- just like that grand juror did - could ask me, do you believe that this conduct falls within that definition. If it does, then you are free to conclude , that my testimony is that I didn't do that. And I believe that you can achieve that without requiring me to say and do things that I don't think are necessary and that I think, frankly, go too far in trying to criminalize my private life. Q If a person touched another person, if you touched another person on the breast, would that be, in your view, and was it within your view, when you took the deposition, within the definition of sexual relations? A If the person being deposed - Q Yes. A -- in this case, me, directly touched the breast of another person, with the purpose to arouse or gratify, under that definition that would be included. Q Only directly, sir, or would it be directly or through clothing? A Well, I would -- I think the common sense definition would be directly. That's how I would infer what it means. Q If the person being deposed kissed the breast of another person, would that be in the definition of sexual relations as you understood it when you were under oath in the Jones case? A Yes, that would constitute contact. I think that would. If it were direct contact, I believe it would. I -- maybe I should read it again, just to make sure. Because this basically says if there was any direct contact with an intent to arouse or gratify, if that was the intent of the contact, then that would fall within the definition. That's correct. Q So, touching, in your view then and now -- the person being deposed touching or kissing the breast of another person would fall within the definition? A That's correct, sir. Q And you testified that you didn’t have sexual relations with Monica Lewinsky in the Jones deposition, under that definition, correct?
A That’s correct, sir. Q If the person being deposed touched the genitalia of another person, would that be -- and with the intent to arouse the sexual desire, arouse or gratify, as defined in definition (1), would that be, under your understanding then and now -
A Yes. sir. Q -- sexual relations7 A Yes, sir. Q Yes, it would? A Yes, it would. If you had a direct contact with any of these places in the body, if you had direct contact with intent to arouse or gratify, that would fall within the definition. Q So, you didn't do any of those three things - A You - Q -- with Monica Lewinsky7 A You are free to infer that my testimony is that I did not have sexual relations, as I understood this term to be defined. Q Including touching her breast, kissing her breast, or touching her genitalia? A That's correct. Q Would you agree with me that the insertion of an object into the genitalia of another person with the desire to gratify sexually would fit within the definition used in the Jones case as aexual relations? A There's nothing here about that, is there? I don't know that I ever thought about that one way or the other. Q The question is, under the definition as you understood it then, under the definition as you understand it now -- pardon me just a minute. Pardon me, Mr. President. (Pause) Deposition Exhibit 1, question 1, under the -- in the Jones case, Definition of Sexual Relations - MR. KENDALL: Do you have that before you, Mr. President? Excuse me. THE WITNESS: I do, sir. MR. KENDALL: Good. THE WITNESS: I've got it right here. I'm looking at it. BY MR. WISENBERG: Q As you understood the definition then, and as you understood it now, would it include sticking an object into the genitalia of another person in order to arouse or gratify the sexual desire of any person? Would it constitute, in other words, contact with the genitalia? A I don't know the answer to that. I suppose you could argue that since section 2, paragraph (2) was eliminated, and paragraph (2) actually dealt with the object issue, that perhaps whoever wrote this didn't intend for paragraph (1) to cover an object, and basically meant direct contact. So, if I were asked -- I've not been asked this question before. But I guess that's the way I would read it. Q If it -- that it would not be covered? That activity would not be covered? A That's right. If the activity you just mentioned would be covered in number (2), and number (2) were stricken, I think you can infer logically that paragraph (l) was not intended to cover it. But, as I said, I’ve not been asked this before. I'm just doing the best I can. Q Well, if someone were to hold or a judge were to hold that you are incorrect and that definition (1) does include the hypo I've given to you -- because we're talking in hypos, so that you don't -- under your request here, if someone were to tell you or rule that you are wrong, that the insertion of an object into somebody else's genitalia with the intent to arouse or gratify the sexual desire of any person is within definition (1) MR. KENDALL: Mr. Wisenberg, excuse me. I have not objected heretofore to any question you've asked. I must tell you, I cannot understand that question. I think it's improper. And, if the witness can understand it, he may answer. 98 MR. WISENBERG: I'll be happy to rephrase it. BY MR. WISENBERG: Q If you're wrong and it's within definition (1), did you engage in sexual relations under the definition, with Monica Lewinsky? A But, Mr. Wisenberg, I have said all along that I would say what I thought it meant, and you can infer that I didn't. This is an unusual question, but it's a slippery slope. We can -- I have tried to deal with some very delicate areas here, and, and in one case I've given you a very forthright answer about what I thought was not within here. All I can tell you is, whatever I thought was covered, and I thought about this carefully. And let me just point out, this was uncomfortable for me. I had to acknowledge, because of this definition, that under this definition I had actually had sexual relations once with Gennifer Flowers, a person who had spread all kinds of ridiculous, dishonest, exaggerated stories about me for money. And I knew when I did that, it would be leaked. It was. And I was embarrassed. But I did it. So, I tried to read this carefully. I can tell you what I thought it covered, and I can tell you that I do not believe I did anything that I thought was covered by this. Q As I understand your testimony, Mr. President, touching somebody's breast with the intent to arouse, with the intent to arouse or gratify the sexual desire of any person is covered; kissing the breast is covered; touching the genitalia is covered; correct? MR. KENDALL: In fairness, the witness said directly in each one of those cases. BY MR. WISENBERG: Q Directly, is covered, correct? A I believe it is, yes, sir. Q Ora1 sex, in your view, is not covered, correct? A If performed on the deponent. Q Is not covered, correct? A That's my reading of this number (1). Q And you are declining to answer the hypothetical about insertion of an object. I need to inform you, Mr. President -- we'll go on at least for now. But I need to inform you that the grand jury will consider your not answering the questions more directly in their determination of whether or not they are going to issue another subpoena. Let me switch the topic and talk to you about John Podesta and some of the other aides you've met with and spoke to after this story became public on January 21st, 1998, the day of The Washington Post story. Do you recall meeting with him around January 23rd, 1998, a Friday a.m. in your study, two days after The Washington Post story, and extremely explicitly telling him that you didn't have, engage in any kind of sex, in any way, shape or form, with Monica Lewinsky, including oral sex7 A I meet with John Podesta almost every day. I meet with a number of people. The only thing I -what happened in the couple of days after what you did was revealed, is a blizzard to me. The only thing I recall is that I met with certain people, and a few of them I said I didn't have sex with Monica Lewinsky, or I didn't have an affair with her or something like that. I had a very careful thing I said, and I tried not to say anything else. And it might be that John Podesta was one of them. But I do not remember this specific meeting about which you asked, or the specific comments to which you refer. And - Q You don't remember A -- seven months ago, I'd have no way to remember, no. Q You don't remember denying any kind of sex in any way, shape or form, and including oral sex, correct? A I remember that I issued a number of denials to people that I thought needed to hear them, but I tried to be careful and to be accurate, and I do not remember what I said to John Podesta. Q Surely, if you told him that, that would be a falsehood, correct7 A No, I didn't say that, sir. I didn't say that at all. That is not covered by the definition and I did not address it in my statement. Q Well, let me ask you then. If you told him - perhaps he thought it was covered, I don't know. But if you told him, if you denied to him sex in any way, shape or form, kind of similar to what Mr. Bennett did at the deposition, including oral sex, wouldn’t that have been a falsehood? A Now, Mr. Wisenberg, I told you in response to a grand juror’s question, you asked me did I believe that oral sex performed on the peraon being deposed was covered by that definition, and I said no. I don't believe it's covered by the definition. I said you are free to conclude that I did not do things that I believe were covered by the definition, and you have asked me a number of questions and I have acknowledged things that I believe are covered by the definition. Since that was not covered by the definition, I want to fall back on my statement. Look, I'm not trying to be evasive here. I'm trying to protect my privacy, my family's privacy, and I'm trying to stick to what the deposition was about. If the deposition wasn't about this and didn't cover it, then I don’t believe that I should be required to go beyond my statement. Q Mr. President, it’s not our intent to embarrass you. But since we have to look, among other things, at obstruction of justice, questions of obstruction of justice and perjury, the answer to some of these delicate and unfortunate questions are absolutely required. And that is the purpose that we have to ask them for. A It's not - Q I'm unaware of any - A Mr. Wisenberg, with respect, you don't need to know the answer for that, if the answer, no matter what the answer is, wouldn't constitute perjury because it wasn’t sexual relations as defined by the Judge. Q Mister - A The only reason you need to know that is for some other reason. It couldn't have anything to do with perjury. Q Mr. President, one of the, one of the nice things about -- one of the normal things about an investigation and a grand jury investigation is that the grand jurors and the prosecutors get to ask the questions unless they are improper, and unless there is a legal basis. As I understand from your answers, there is no legal basis for which you decline to answer these questions. And I'll ask you again to answer the question. I'm unaware of any legal basis for you not to. If you told - MR. KENDALL: Mr. Wisenberg, could you just restate the question, please? BY MR. WISENBERG: Q The question is, if you told John Podesta two days after the story broke something to this effect, that you didn't have any kind of sex in any way, shape or form, including oral sex with Ms. Lewinsky, were you telling him the truth? A And let me say again, with respect, this is an indirect way to try to get me to testify to questions that have no bearing on whether I committed perjury. You apparently agree that it has no bearing-- Q Oh, I don't - A -- no bearing on whether I - Q I don't agree. A -- committed perjury. Q Mr. President, I'm sorry, with respect, I don’t agree with that. I'm not going to argue with you about it. I just am going to ask you again, in fact direct you to answer the question. A I'm not going to answer that question, because I believe it’s a question about conduct that, whatever the answer to it is, would, does not bear on the perjury because oral sex performed on the deponent under this definition is not sexual relations. It is not covered by this definition MR. KENDALL: The witness is not declining to tell you anything he said to John Podesta. BY MR. WISENBERG: Q You denied the MR. WISENBERG: The witness is not declining to tell me anything? BY MR. WISENBERG: Q Did you deny oral sex in any way, shape or form, to John Podesta? A I told you, sir, before, and I will say again, in the aftermath of this story breaking, and what was told about it, the next two days, next three days are just a blur to me. I don't remember to whom I talked, when I talked to them, or what I said. Q So, you are not declining to answer, you just don't remember? A I honestly don't remember, no. Q Okay. A I'm not saying that anybody who had a contrary memory is wrong. I do not remember. Q Do you recall denying any sexual relationship with Monica Lewinsky to the following people: Harry Thomasson, Erskine Bowles, Harold Ickes, Mr. Podesta, Mr. Blumenthal, Mr. Jordan, Ms. Betty Currie? Do you recall denying any sexual relationship with Monica Lewinsky to those individuals? A I recall telling a number of those people that didn’t have, either I didn't have an affair with Monica Lewinsky or didn't have sex with her. And I believe, sir, that – you’ll have to ask them what they thought. But I was using those terms in the normal way people use them. You'll have to ask them what they thought I was saying. Q If they testified that you denied sexual relations or relationship with Monica Lewinsky, or if they told us that you denied that, do you have any reason to doubt them, in the days after the story broke; do you have any reason to doubt them? A No. The -- let me say this. It's no secret to anybody that I hoped that this relationship would never become public. It's a matter of fact that it had been many, many months since there had been anything improper about it, in terms of improper contact. Q Did you deny it to them or not, Mr. President? A Let me finish. So, what -- I did not want to mislead my friends, but I wanted to find language where I could say that. I also, frankly, did not want to turn any of them into witnesses, because I -- and, sure enough, they all became witnesses. Q Well, you knew they might be -
A And so - Q -- witnesses, didn't you? A And so I said to them things that were true about this relationship. That I used -- in the language I used, I said, there's nothing going on between us. That was true. I said, I have not had sex with her as I defined it. That was true. And did I hope that I would never have to be here on this day giving this testimony? Of course. But I also didn't want to do anything to complicate this matter further. So, I said things that were true. They may have been misleading, and if they were I have to take responsibility for it, and I’m sorry. Q It may have been misleading, sir, and you knew though, after January 21st when the Post article broke and said that Judge Starr was looking into this, you knew that they might be witnesses. You knew that they might be called into a grand jury, didn't you? A That's right. I think I was quite careful what I said after that. I may have said something to all these people to that effect, but I'll also -whenever anybody asked me any details, I said, look, I don't want you to be a witness or I turn you into a witness or give you information that could get you in trouble. I just wouldn't talk. I, by and large, didn’t talk to people about this. Q If all of these people -- let's leave out Mrs. Currie for a minute. Vernon Jordan, Sid Blumenthal, John Podesta, Harold Ickes, Erakine Bowles, Harry Thomasson, after the story broke, after Judge Starr's involvement was known on January 21st, have said that you denied a sexual relationship with them. Are you denying that? A No. Q And you’ve told us that you - A I'm just telling you what I meant by it. I told you what I meant by it when they started this deposition. Q You've told us now that you were being careful, but that it might have been misleading. Is that correct? A It might have been. Since we have seen this four year, $40-million-investigation come down to parsing the definition of sex, I think it might have been. I don’t think at the time that I thought that's what this was going to be about. In fact, if you remember the headlines at the time, even you mentioned the Post story. All the headlines were -and all the talking, people who talked about this, including a lot who have been quite sympathetic to your operation, said, well, this is not really a story about sex, or this is a story about subornation of perjury and these talking points, and all this other stuff. So, what I was trying to do was to give them something they could -- that would be true, even if misleading in the context of this deposition, and keep them out of trouble, and let's deal -- and deal with what I thought was the almost ludicrous suggestion that I had urged someone to lie or tried to suborn perjury, in other words. I want to go over some questions again. I don’t think you are going to answer them, sir. And so I don't need a lengthy response, just a yes or a no. And I understand the basis upon which you are not answering them, but I need to ask them for the record. If Monica Lewinsky says that while you were in the Oval Office area you touched her breasts, would she be lying? A Let me say something about all this. Q All I really need for you, Mr. President - A I know. Q -- is to say - A But you - Q -- I won't answer under the previous grounds, or to answer the question, you see, because we only have four hours, and your answers - A I know. Q -- have been extremely lengthy. A I know that. I'll give you four hours and 30 seconds, if you'll let me say something general about this. I will answer to your satisfaction that I won't -- based on my statement, I will not answer. I would like 30 seconds at the end to make a atatement, and you can have 30 seconds more on your time, if you'll let me say this to the grand jury and to you. And I don't think it's disrespectful at all. I've had a lot of time to think about this. But, go ahead and ask your questions. Q The question is, if Monica Lewinsky says that while you were in the Oval Office area you touched her breasts, would she be lying? A That is not my recollection. My recollection is that I did not have sexual relations with Ms. Lewinsky and I'm staying on my former statement about that. Q If she said - A My, my statement is that I did not have sexual relations as defined by that. Q If she says that you kissed her breasts, would she be lying7 A I'm going to revert to my former statement. Q Okay. If Monica Lewinsky says that while you were in the Oval Office area you touched her genitalia, would she be lying? And that calls for a yes, no, or reverting to your former statement. A I will revert to my statement on that. Q If Monica Lewinsky says that you used a cigar as a sexual aid with her in the Oval Office area, would she be lying? Yes, no, or won't answer? A I will revert to my former statement. Q If Monica Lewinsky says that you had phone sex with her, would she be lying? A Well, that is, at least in general terms, I think, is covered by my statement. I addressed that in my statement, and that, I don’t believe, is - Q Let me define phone sex for purposes of my question. Phone sex occurs when a party to a phone conversation masturbates while the other party is talking in a sexually explicit manner. And the question is, if Monica Lewinsky says that you had phone sex with her, would she be lying? A I think that is covered by my statement. Q Did you, on or about January the 13th, 1998, Mr. President, ask Erskine Bowles to ask John Hilley if he would give a recommendation for Monica Lewinsky? A In 1998? Q Yes. On or about January 13t'h, 1998, did you ask Erskine Bowles, your Chief of Staff, if he would ask John Hilley to give a recommendation for Monica Lewinsky? A At some point, sir, I believe I talked to Erskine Bowles about whether Monica Lewinsky could get a recommendation that was not negative from the Legislative Affairs Office. I believe I did. Q I just didn't hear the very last part. A I think the answer is, I think, yes. At some point I talked to Erskine Bowles about this. Q Okay. A I do not know what the date was. At some point I did talk to him. Q And if Erskine Bowles has told us that he told John Podesta to carry out your wishes, and John Podesta states, that it was three or four days before your deposition, which would be the 13th or the 14th, are you in a position to deny that? A The 13th or 14th of? Q January, as to date. A I don't know. I don't know when the date was Q Okay. A I'm not in a position to deny it. I won’t deny it. I'm sure that they are both truthful men. I don’t know when the date was. Q Do you recall asking Erskine Bowles to do that? A I recall talking to Erskine Bowles about that, and my recollection is, sir, that Ms. Lewinsky was moving to New York, wanted to get a job in the private sector; was confident she would get a good recommendation from the Defense Department; and was concerned that because she had been moved from the Legislative Affairs Office, transferred to the Defense Department, that her ability to get a job might be undermined by a bad recommendation from the Legislative Affairs Office. So, I asked Erskine if we could get her a recommendation that just was at least neutral, so that if she had a good recommendation from the Defense Department it wouldn’t prevent her from getting a job in the private sector. Q If Mr. Bowles had told us that, in fact, you told him that she already had a job and had already listed Mr. Hilley as a reference and wanted him to be available as a recommendation, would you be in -is that inconsistent with your memory? A A little bit, but I think -- my memory is that when you’re, when you get a job like that you have to give them a resume, which says where you’ve worked and who your supervisor was. And I think that that’s my recollection. My recollection is that -- slightly different from that. Q And who was it that asked you to do that on Monica Lewinsky's behalf? A I think she did. You know, she tried for months and months to get a job back in the White House, not so much in the West Wing but somewhere in the White House complex, including the Old Executive Office Building. And she talked to Marsha Scott, among others. She very much wanted to come back. And she interviewed for some jobs but never got one. She was, from time to time, upset about it. And I think what she was afraid of is that she couldn't get a -- from the minute she left the White House she was worried about this. That if she didn't come back to the White House and work for awhile and get a good job recommendation, that no matter how well she had done at the Pentagon it might hurt her future employment prospects. Well, it became obvious that, you know, her mother had moved to New York. She wanted to go to New York. She wasn’t going to get a job in the White House. So, she wanted to get a job in the private sector, and said, I hope that I won’t get a letter out of the Legislative Affairs office that will prevent my getting a job in the private sector. And that's what I talked to Erskine about. Now, that's my entire memory of this. Q All right. I want to go back briefly to the December 28th conversation with Ms. Lewinsky. I believe you testified to the effect that she asked you, what if they ask me about gifts you gave me. My question to you is, after that statement by her, did you ever have a conversation with Betty Currie about gifts, or picking something up from Monica Lewinsky? A I don't believe I did, sir. No. Q You never told her anything to this effect, that Monica has something to give you? A No, sir. Q That is to say, Betty Currie? A No, sir, I didn’t. I don’t have any memory of that whatever. Q And so you have no knowledge that, or you had no knowledge at the time, that Betty Currie went and picked up, your secretary went and picked up from Monica Lewinsky items that were called for by the Jones subpoena and hid them under her bed? You had no knowledge that anything remotely like that was going to happen? A I did not. I did not know she had those items, I believe, until that was made public. Q And you agree with me that that would be a very wrong thing to do, to hide evidence in a civil case, or any case? Isn't that true? A Yes. I don't know that, that Ms. Currie knew that that's what she had at all. But - Q I'm not saying she did. I'm just saying - A I had -- it is, if Monica Lewinsky did that after they had been subpoenaed and she knew what she was doing, she should not have done that. Q And if you knew, you - A And I - Q -- shouldn't have done it7 A Indeed, I, myself, told her, if they ask you for gifts you have to give them what you have. And I don't understand if, in fact, she was worried about this, why she was so worried about it. It was no big deal. Q I want to talk about a December 17th phone conversation you had with Monica Lewinsky at approximately 2:00 a.m. Do you recall making that conversation and telling her initially about the death of Betty' a brother, but then, telling her that she was on the witness list, and that it broke your heart that she was on the witness list? A No, sir, I don't, but it would -- it, it would -it is quite possible that that happened, because, if you remember, earlier in this meeting you asked me some questions about what I'd said to Monica about testimony and affidavits, and I was struggling to try to remember whether this happened in a meeting or a phone call. Now, I remember I called her to tell her Betty's brother had died. I remember that. And I know it was in the middle of December, and I believe it was before Monica had been subpoenaed. So, I think it is quite possible that if I called her at that time and had not talked to her since the 6th -- and you asked me this earlier -- I believe when I saw her on the 6th, I don't think I knew she was on the witness list then, then it's quite possible I would say something like that. I don't have any memory of it, but I certainly wouldn't dispute that I might have said that. Q And in that conversation, or in any conversation which you informed her she was on the witness list, did you tell her, you know, you can always say that you were coming to see Betty or bringing me letters? Did you tell her anything like that? A I don't remember. She was coming to see Betty. I can tell you this. I absolutely never asked her to lie. Q Sir, every time she came to see Betty and you were in the Oval Office, she was coming to see you, too, wasn’t she, or just about every time? A I think just about every time. I don't think every time. I think there was a time or two where she came to see Betty when she didn't see me. Q So, do you remember telling her any time, any time when you told her, or after you told her that she was on the witness list, something to this effect: You know, you can always say you were coming to see Betty, or you were bringing me letters? A I don’t remember exactly what I told her that night. Q Did you - A I don't remember that. I remember talking about the nature of our relationship, how she got in. But I also will tell you that I felt quite comfortable that she could have executed a truthful affidavit, which would not have disclosed the embarrassing details of the relationship that we had had, which had been over for many, many months by the time this incident occurred. Q Did you tell her anytime in December something to that effect: You know, you can always say that you were coming to see Betty or you were bringing me letters? Did you say that, or anything like that, in December ‘97 or January ‘98, to Monica Lewinsky7 A Well, that's a very broad question. I do not recall saying anything like that in connection with her testimony. I could tell you what I do remember saying, if you want to know. But I don't -- we might have talked about what to do in a non legal context at some point in the past, but I have no specific memory of that conversation. I do remember what I said to her about the possible testimony. Q You would agree with me, if you did say something like that to her, to urge her to say that to the Jones people, that that would be part of an effort to mislead the Jones people, no matter how evil they are and corrupt? A I didn't say they were evil. I said what they were doing here was wrong, and it was. Q Wouldn’t that be misleading? A Well, again, you are trying to get me to characterize something that I'm -- that I don't know if I said or not, without knowing whether the whole, whether the context is complete or not. So, I would have to know, what was the context, what were all the surrounding facts. I can tell you this: I never asked Ms. Lewinsky to lie. The first time that she raised with me the possibility that she might be a witness or I told her -- you suggested the possibility in this December 17th timeframe -- I told her she had to get a lawyer. And I never asked her to lie. Q Did you ever say anything like that, you can always say that you were coming to see Betty or bringing me letters? Was that part of any kind of a, anything you said to her or a cover story, before you had any idea she was going to be part of Paula Jones? A I might well have said that. Q Okay. A Because I certainly didn't want this to come out, if I could help it. And I was concerned about that. I was embarrassed about it. I knew it was wrong. And, you know, of course, I didn't want it to come out. But - Q But you are saying that you didn’t say anything - I want to make sure I understand. Did you say anything like that once you knew or thought she might be a witness in the Jones case? Did you repeat that statement, or something like it to her? A Well, again, I don't recall, and I don’t recall whether I might have done something like that, for example, if somebody says, what if the reporters ask me this, that or l the other thing. I can tell you this: In the context of whether she could be a witness, I have a recollection that she asked me, well, what do I do if I get called as a witness, and I said, you have to get a lawyer. And that’s all I said. And I never asked her to lie. Q Did you tell her to tell the truth? A Well, I think the implication was she would tell the truth. I've already told you that I felt strongly that she could issue, that she could execute an affidavit that would be factually truthful, that might get her out of having to testify. Now, it obviously wouldn't if the Jones people knew this, because they knew that if they could get this and leak it, it would serve their larger purposes, even if the judge ruled that she couldn’t be a witness in the case. The judge later ruled she wouldn't be a witness in the case. The judge later ruled the case had no merit. So, I knew that. And did I hope she'd be able to get out of testifying on an affidavit? Absolutely. Did I want her to execute a false affidavit? No, I did not. Q If Monica Lewinsky has stated that her affidavit that she didn't have a sexual relationship with you is, in fact, a lie, I take it you disagree with that? A No. I told you before what I thought the issue was there. I think the issue is how do you define sexual relationship. And there was no definition imposed on her at the time she executed the affidavit. Therefore, she was free to give it any reasonable meaning. Q And if she says she was lying - A And I believe - Q -- under your common sense ordinary meaning that you talked about earlier, Mr. President, that most Americana would have, if she says sexual relationship, saying I didn’t have one was a lie because I had oral sex with the President, I take it, you would disagree with that? A Now, we're back to where we started and I have to invoke my statement. But, let me just say one thing. I've read a lot, and obviously I don’t know whether any of it’s accurate, about what she said, and what purports to be on those tapes. And this thing -- and I searched my own memory. This reminds me, to some extent, of the hearings when Clarence Thomas and Anita Hill were both testifying under oath. Now, in some rational way, they could not have both been telling the truth, since they had directly different accounts of a shared set of facts. Fortunately, or maybe you think unfortunately, there was no special prosecutor to try to go after one or the other of them, to take sides and try to prove one was a liar. And so, Judge Thomas was able to go on and serve on the Supreme Court.
What I learned from that, I can tell you that I was a citizen out there just listening. And when I heard both of them testify, what I believed after it was over, I believed that they both thought they were telling the truth. This is -- you're dealing with, in some ways, the most mysterious area of human life. I'm doing the best I can to give you honest answers. Q Mr. President - A And that's all I can say. Q I'm sorry. A And, you know, those people both testified under oath. So, if there'd been a special prosecutor, they could, one of them could have gone after Anita Hill, another could have gone after Clarence Thomas. I thank God there was no such thing then, because I don't believe that it was a proper thing. Q One of -- A And I think they both thought they were telling the truth. So, maybe Ms. Lewinsky believes she's telling the truth, and I'm glad she got her mother and herself out of trouble. I'm glad you gave her that sweeping immunity. I'm glad for the whole thing. I, I, I -- it breaks my heart that she was ever involved in this. Q I want to go back to a question about Vernon Jordan. I want to go back to late December and early January, late December of ‘97 and early January of ‘98. During this time, Mr. President, you are being sued for sexual harassment by a woman who claims, among other things, that others got benefits that she didn’t because she didn't have oral sex with you. While this is happening, your powerful friend, Vernon Jordan, is helping to get Monica Lewinsky a job and a lawyer. He's helping to get a job and a lawyer for someone who had some kind of sex with you, and who has been subpoenaed in the very case, the Jones case. Don't you see a problem with this? Didn't you see a problem with this? A No. Would you like to know why? Q Isn't that why -- I would. But isn't that why Vernon Jordan asked you on December 19th whether or not you had sexual relationships with Monica Lewinsky and why he asked her, because he knew it would be so highly improper to be helping her with a lawyer and a job if, in fact, she had had a relationship with you? A I don't know. I don't believe that at all. I don’t believe that at all, particularly since, even if you look at the facts here in their light most unfavorable to me, no one has suggested that there was any sexual harassment on my part. And I don't think it was wrong to be helping her. Look - Q A subpoenaed witness in a case against you? A Absolutely. Look, for one thing, I had already proved in two ways that I was not trying to influence her testimony. I didn't order her to be hired at the White House. I could have done so. I wouldn't do it. She tried for months to get in. She was angry. Secondly, after I - Q Wasn’t she kept - A After I terminated the improper contact with her, she wanted to come in more than she did. She got angry when she didn't get in sometimes. I knew that that might make her more likely to speak, and I still did it because I had to limit the contact. And, thirdly, let me say, I formed an opinion really early in 1996, and again -- well, let me finish the sentence. I formed an opinion early in 1996, once I got into this unfortunate and wrong conduct, that when I stopped it, which I knew I'd have to do and which I should have done a long time before I did, that she would talk about it. Not because Monica Lewinsky is a bad person. She's basically a good girl. She's a good young woman with a good heart and a good mind. I think she is burdened by some unfortunate conditions of her, her upbringing. But she's basically a good person. But I knew that the minute there was no longer any contact, she would talk about this. She would have to. She couldn't help it. It was, it was a part of her psyche. So, I had put myself at risk, sir. I was not trying to buy her silence or get Vernon Jordan to buy her silence. I thought she was a good person. She had not been involved with me for a long time in any improper way, several months, and I wanted to help her get on with her life. It's just as simple as that. MR. WISENBERG: It's time for a break. MR. KENDALL: Okay. 4:49. (Whereupon, the proceedings were recessed from 4:49 p.m.until 5:05 p.m.) MR. KENDALL: Bob, we are at 2 hours and 55 MR. BITTMAN: Two hours and 55 minutes, thank you. BY MR. BITTMAN: Q Mr. President. A Mr. Bittman. Q Apparently we have one hour and five minutes left, if we stick to the four-hour timeframe. MR. KENDALL: Plus 30 seconds. MR. BITTMAN: And 30 seconds, that’s right. THE WITNESS: You gave me my 30 seconds, soliloquy. So, I owe you 30 seconds. BY MR. BITTMAN: Q You are very generous. That actually segues very nicely into one of the grand juror's asked, pointed out actually, that you indicated at the beginning of the deposition that you would, you would answer all the grand jurors, you wanted to answer all the grand jurors questions. And they wanted to know whether you would be willing to stay beyond the four-hour period to, in fact, answer all their questions. A Well, let's see how we do in the next hour, and then we'll decide. Q Okay. Let me draw your attention to early January of this year, after Christmas, before your deposition. Do you remember talking to Betty Currie about Monica, who had just called her and said that she, Monica, needed to talk to you before she signed something? A I’m not sure that I do remember that. But, go ahead . Q This is in early January. And then Betty Currie relayed this to you that Monica called, it’s important, she needs to talk to you before she signs something. And then you do, indeed, talk to Monica that day on the telephone. A I did talk to her that day7 Q Yes. MR. KENDALL: Mr. President, excuse me. That's a question. If you have a memory of that, you can answer. TNE WITNESS: I'm trying to remember when the last time I talked to her was. I am aware, sir, that she signed this affidavit about this time, sometime in the first week in January. I may have talked to her before she did it. I don't know. I talked to her a number of times between the time Betty's brother died and Christmas. Then I saw her on December 28. I may have talked to her, but I don't remember the specific conversation. BY MR. BITTMAN: Q And you would have talked about the -- she had just given you a gift actually in early January, a book on the Presidents of the United States. And you discussed this with her and she said that you said you liked it a lot. A I did like it a lot. I told you that. My impression, my belief was that she gave me that book for Christmas. Maybe that's not right. I think she had that book delivered to me for Christmas. And then, as I remember, I went to Bosnia and for some reason she wasn’t there around Christmas time. But, anyway, maybe I didn’t get it until January. My recollection was that I had gotten it right before Christmas. Q Let me see if I can jog your memory further. Monica talked to you in that phone conversation that told you that she had just met with her attorney that Mr. Jordan arranged with her, and the attorney said that if she is deposed that they were going to ask her how she got her job at the Pentagon. And Monica then asked you, what do you think I should say, how do I answer that question, how did I get the job at the Pentagon. Did you talk to Monica about that, about possibilities - A I don't believe -- no. I don’t remember her asking me that. But if she, if she had asked me that, I would have told her to tell the truth. I -- and I didn't, you know, I don't know exactly how she got her job at the Pentagon. I know Evelyn Lieberman wanted to transfer her out of the job she had, and somebody must have arranged that. But I didn't arrange it. Q Now, that’s actually not my question. My question is whether you remember talking to Monica about her being concerned that, I may have to answer some questions about how and why I was transferred to the Pentagon out of the White House, fearing that this would - A No, I don't remember that at all. Q -- lead to questions, or answers that would reveal your relationship? A Oh, no, sir. I don't remember that. Maybe somebody -- maybe she did. But I only remember -- well, I don't remember that. That's all I can tell you. I don't remember that. Q Are you saying, Mr. President, that you did not then say to Ms. Lewinsky that you could always say that people in Legislative Affairs got you the job, or helped you get it? A I have no recollection of that whatever. Q Are you saying you didn't say it? A No, sir. I'm telling you, I want to say I don't recall -- I don't have any memory of this as I sit here today. And I can tell you this, I never asked her to lie. I never did. And I don't have any recollection of the specific l thing you are saying to me. Now, if I could back up, there were several times when Monica Lewinsky talked to me on the telephone in 1996, in person in 1997, about her being concerned about what anybody would say about her transfer from the White House to the Pentagon. But I remember no conversation in which she was concerned about it for the reasons you just mentioned. And all my memory is, she was worried about it because she thought it would keep her from getting a good job down the road, and she talked to me about it constantly in 1997. She thought, well, I'll never have my record clear unless I work somewhere in the White House complex where I can get a good recommendation. But in the context that you mention it, I do not recall a conversation. Q Did you ever tell Ms. Lewinsky, or promise to her that you would do your best to get her back into the White House after the 1996 Presidential elections? A what I told Ms. Lewinsky was that I would, I would do what I could to see, if she had a good record at the Pentagon, and she assured me she was doing a good job and working hard, that I would do my best to see that the fact that she had been sent away from the Legislative Affairs section did not keep her from getting a job in the White House, and that is, in fact, what I tried to do. I had a conversation with Ms. Scott about it, and I tried to do that. But I did not tell her I would order someone to hire her, and I never did, and I wouldn't do that. It wouldn't be right. Q When you received the book, this gift from Monica, the Presidents of the United States, this book that you liked and you talked with Monica about, did it come with a note? Do you remember the note that it came with, Mr. President? A No, sir, I don't. Q Do you remember that in the note she wrote that, she expressed how much she missed you and how much she cared for you, and you and she later talked about this in this telephone conversation, and you said -- and she apologized for putting such emotional, romantic things in this note, and you said, yeah, you shouldn't have written some of those things, you shouldn’t put those things down on paper? Did you ever say anything like that to Ms. Lewinsky? A Oh, I believe I did say something like that to Ms Lewinsky. I don’t remember doing something as late as you suggest. I'm not saying I didn't. I have no recollection of l that. Keep in mind now, it had been quite a long time since I had had any improper contact with her. And she was, in a funny way, almost more attached to me than she had been . before. In '96, she had a long relationship, she said, with a man whom she liked a lot. And I didn't know what else was going on in her private life in ‘97. But she talked to me occasionally about people she was going out with. But normally her language at this point was, if affectionate, was, was not improperly affectionate, I would . say. So -- but, it could have happened. I wouldn't say it didn’t. I just don't remember it at this late date. Q Let me refer back to one of the subjects we talked about at one of the earlier breaks, right before one of the earlier breaks, and that is your meeting with Mrs. Currie on January 18th. This is the Sunday after your deposition in the Paula Jones case. You said that you spoke to her in an attempt to refresh your own recollection about the events involving Monica Lewinsky, is that right? A Yes. Q How did you making the statement, I was never alone with her, right, refresh your recollection? A Well, first of all, let's remember the context here. I did not at that time know of your involvement in this case. I just knew that obviously someone had given them a lot of information, some of which struck me as accurate, some of which struck me as dead wrong. But it led them to write, ask me a whole serious of questions about Monica Lewinsky. Then on Sunday morning, this Drudge report came out, which used Betty's name, and I thought that we were going to be deluged by press comments. And I was trying to refresh my memory about what the facts were. So, when I said, we were never alone, right, I think I also asked her a number of other questions, because l there were several times, as I'm sure she would acknowledge, when I either asked her to be around. I remember once in l particular when I was talking with Ms. Lewinsky when I asked Betty to be in the, actually, in the next room in the dining room, and, as I testified earlier, once in her own office. But I meant that she was always in the Oval Office complex, in that complex, while Monica was there. And I believe that this was part of a series of questions I asked her to try to quickly refresh my memory. So, I wasn't trying to get her to say something that wasn’t so. And, in fact, I think she would recall that I told her to just relax, go in the grand jury and tell the truth when she had been called as a witness. Q So, when you said to Mrs. Currie that, I was never alone with her, right, you just meant that you and Ms. Lewinsky would be somewhere perhaps in the Oval Office or many times in your back study, is that correct? A That's right. We were in the back study. Q And then - A Keep in mind, sir, I just want to make it -- I was talking about 1997. I was never, ever trying to get Betty Currie to claim that on the occasions when Monica Lewinsky was there when she wasn’t anywhere around, that she was. I would never have done that to her, and I don't think she thought about that. I don't think she thought I was referring to that. Q Did you put a date restriction? Did you make it clear to Mrs. Currie that you were only asking her whether you were never alone with her after 1997? A Well, I don’t recall whether I did or not, but I assumed -- if I didn't, I assumed she knew what I was talking about, because it was the point at which Ms. Lewinsky was out of the White House and had to have someone WAVE her in, in order to get in the White House. And I do not believe to this day that I was -- in 1997, that she was ever there and that I ever aww her unless Betty Currie was there. I don't believe she was. Q Do you agree with me that the statement, "I was never alone with her", is incorrect? You were alone with Monica Lewinsky, weren't you? A Well, again, it depends on how you define alone. Yea, we were alone from time to time, even during 1997, even when there wee absolutely no improper contact occurring. Yes, that ia accurate. But there were also a lot of times when, even though no one could see us, the doors were open to the halls, l on both ends of the halls, people could hear. The Navy stewards could come in and out at will, if they were around. Other things could be happening. So, there were a lot of times when we were alone, but I never really thought we were. And sometimes when we, when -- but, as far as I know, what I was trying to determine, if I might, is that Betty was always around, and I believe she was always around . where I could basically call her or get her if I needed her. Q When you said to Mrs. Currie, you could see and hear everything, that wasn’t true either, was it, as far as you knew? You've already - A My memory of that - Q -- testified that Betty was not there.
A My memory of that was that, that she had the ability to hear what was going on if she came in the Oval Office from her office. And a lot of times, you know, when I was in the Oval Office, she just had the door open to her office. Then there was -- the door was never completely closed to the hall. So, I think there was -- I'm not entirely sure what I meant by that, but I could have meant that she generally would be able to hear conversations, even if she couldn’t see them. And I think that's what I meant. Now, I could have been referring not generally to every time she was there, but one, one particular time I remember when Ms. Lewinsky was there when I asked Betty -and I'm sorry to say for reasons I don't entirely remember -to actually stay in the dining room while I talked with Monica. I do remember one such instance. Q Well, you've already testified that this -- you did almost everything you could to keep this relationship secret. So, would it be fair to say -- even from Mrs. Currie. She didn't know about the nature, that is, your intimate, physically intimate relationship with Ms. Lewinsky, did she? A As far as I know, she is unaware of what happened on the, on the occasions when I saw her in 1996 when something improper happened. And she was unaware of the one time that I recall in 1997 when something happened. I think she was quite well aware that I was determined to impose the appropriate limits on the relationship when I was trying to do it. And the -- you know, anybody would hope that this wouldn't become public. Although I frankly, from 1996 on, always felt that if I severed inappropriate contact with Ms. Lewinsky, sooner or later it would get public. And I never thought it would be part of the Jones case. I never even thought about that. I never thought -- I certainly never thought it would be part of your responsibilities. Q My question was - A But I did believe that she would talk about it. O My question was more simple than that. Mrs. Currie did not know of the physically intimate nature of your relationship, did she? A I don't believe she did, no. Q Okay. So, you would have done -- you tried to keep that nature of the relationship from Mrs. Currie? A Absolutely. I - Q So, you would not have engaged in those physically intimate acts if you knew that Mrs. Currie could see or hear that, is that correct? A That 's correct. But, keep in mind, sir, I was talking about 1997. That occurred, to the -- and I believe that occurred only once in February of 1997. I stopped it. I never should have started it, and I certainly shouldn't have started it back after I resolved not to in 1996. And was referring to 1997 And I -- what -- as I say, I do not know -her memory and mine may be somewhat different. I do not know whether I was asking her about a particular time when Monica was upset and I asked her to stand, stay back in the dining area. Or whether I was, had reference to the fact that if she kept the door open to the Oval Office, because it was always -- the door to the hallway was always somewhat open, that she would always be able to hear something if anything went on that was, you know, too loud, or whatever. I do not know what I meant. I'm just trying to reconcile the two statements as best I can, without being sure. Q There was at least one event where Mrs. Currie was definitely not even in the Oval Office area, isn't that right? And I think you began to testify about that before. That was at the radio address. A I'm not sure of that. But in that case, there was, there was certainly someone else there. I don't know - Q Well, why would you be testing Mrs. Currie's memory about whether someone else was there? A Well, I can say this. If I'm in the Oval Office - my belief is that there was someone else there, somewhere in the Oval Office complex. I've looked at our -- I've looked at the film. This, this night has become legendary now, you know. I've looked at the, I’ve looked at the film we have. I've looked at my schedules. I've seen the people that were at the radio address. I do believe that I was alone with her from 15 to 20 minutes. I do believe that things happened then which l were inappropriate. I don't remember whether Betty was there or not, but I can’t imagine that, since all this happened more or less continuously in that time period, there must have been someone who was working around the radio address who stayed around somewhere. That would be my guess. I don't know. I'm sorry. I don't have records about who it would be. But I doubt very seriously if we were all alone in . that Oval Office complex then. Q Mr. President, if there is a semen stain belonging . to you on a dress of Ms. Lewinsky’s, how would you explain that? A Well, Mr. Bittman, I, I don't -- first of all, when l you asked me for a blood test, I gave you one promptly. You came over here and got it. That's -- we met that night and talked. So, that’s a question you already know the answer to. Not if, but you know whether. And the main thing I can tell you is that doesn’t affect the opening statement I made. The opening statement I made is that I had inappropriate intimate contact. I take full responsibility for it. It wasn’t her fault, it was mine. I do not believe that I violated the definition of sexual relations I was given by directly touching those parts of her body with the intent to arouse or gratify. And that's all I have to say. I think, for the rest, you know, you know what the evidence is and it doesn't affect that statement. Q Is it possible or impossible that your semen is on a dress belonging to Ms. Lewinsky? A I have nothing to add to my statement about it, sir. You, you know whether -- you know what the facts are. There’s no point in a hypothetical. Q Don't you know what the facts are also, Mr. President? A I have nothing to add to my statement, sir. Q Getting back to the conversation you had with Mrs. Currie on January 18th, you told her -- if she testified that you told her, Monica came on to me and I never touched her, you did, in fact, of course, touch Ms. Lewinsky, isn't that right, in a physically intimate way? A Now, I've testified about that. And that’s one of those questions that I believe is answered by the statement that I made. Q What was your purpose in making these statements to Mrs. Currie, if they weren't for the purpose to try to suggest to her what she should say if ever asked? A Now, Mr. Bittman, I told you, the only thing I remember is when all this stuff blew up, I was trying to figure out what the facts were. I was trying to remember. I was trying to remember every time I had seen Ms. Lewinsky. Once this thing was in Drudge, and there was this argument about whether it was or was not going to be in Newsweek, that was a clear signal to me, because Newsweek, frankly, was -had become almost a sponsoring media outlook for the Paula Jones case, and had a journalist who had been trying, so far fruitlessly, to find me in some sort of wrongdoing. And so I knew this was all going to come out. I was trying -- I did not know at the time -I will say again, I did not know that any of you were involved. I did not know that the Office of Independent Counsel was involved. And I was trying to get the facts and try to think of the best defense we could construct in the face of what I thought was going to be a media onslaught. Once you became involved, I told Betty Currie not to worry, that, that she had been through a terrible time. She had lost her brother. She had lost her sister. Her mother was in the hospital. I said, Betty, just don't worry about me. Just relax, go in there and tell the truth. You'll be fine. Now, that’s all there was in this context. Q Did the conversations that you had with Mrs. Currie, this conversation, did it refresh your recollection as to events involving Ms. Lewinsky? A Well, as I remember, I do believe, in fairness, I that, you know, she may have felt some ambivalence about how ; to react, because there were some times when she seemed to say yes, when I'm not sure she meant yes. There was a time -- it seems like there was one or two things where she said, well, remember this, that or the other thing, which did reflect my recollection. So, I would say a little yes, and a little no. Q Why was it then that two or three days later, given that The Washington Post article came out on January 21st, why would you have had another conversation with Betty Currie asking or making the exact same statements to her? A I don’t know that I did. I remember having this one time. I was, I was -- I don't know that I did. Q If Mrs. Currie says you did, are you disputing that? A No, sir, I'm not disputing - MR. KENDALL: Excuse me. Is your representation that she testified that that conversation was – when? MR. BITTMAN: I'm not making a representation as to what Mrs. Currie said. I'm asking the President if Mrs. Currie testified two or three days later, that two or three days after the conversation with the President on January 18th, that he called her into the Oval Office and went over the exact same statements that the President made to her on the 18th. BY MR. BITTMAN: Q Is that accurate? Is that a Mrs. Currie, if she made it? A I do not remember how many times Currie or when. I don’t. I can't possibly remember that. I do remember, when I first heard about this story breaking, trying to ascertain what the facts were, trying to ascertain what Betty's perception was. I remember that I was highly agitated, understandably, I think. And then I remember when I knew she was going to have to testify to the grand jury, and I, I felt terrible because she had been through this loss of her sister, this horrible accident Christmas that killed her brother, and her mother was in the hospital. I was trying to do -- to make her understand that I didn't want her to, to be untruthful to the grand jury. And if her memory was different from mine, it was fine, just go in there and tell them what she thought. . So, that's all I remember. BY MR. BENNETT: Q Mr. President, my name is Jackie Bennett. If I understand your current line of testimony, you are saying that your only interest in speaking with Ms. Currie in the days after your deposition was to refresh your own recollection? A Yes. 0 It was not to impart instructions on how she was to recall things in the future? A No, and certainly not under oath. That -every day, Mr. Bennett, in the White House and in every other political organization when you are subject to a barrage of press questions of any kind, you always try to make the best case you can consistent with the facts; that is, while being truthful. But -- so, I was concerned for a day or two there , about this as a press story only. I had no idea you were l involved in it for a couple of days. I think Betty Currie’s testimony will be that I gave her explicit instructions or encouragement to just go in the grand jury and tell the truth. That 'a what I told her to do and I thought she would. Q Mr. President, when did you learn about the Drudge Report reporting allegations of you having a sexual relationahip with someone at the White House? A I believe it was the morning of the 18th, I think. Q What time of day, sir? A I have no idea. Q Early morning hours? A Yeah, I think somebody called me and told me about it. Maybe Bruce, maybe someone else. I’m not sure. But I learned early on the l8th of the Drudge Report. Q Very early morning hours, sir? A Now, my deposition wee on the 17th, is that right? Q On Saturday, the 17th, sir. A Yeah, I think it was when I got up Sunday morning, I think. Maybe it was late Saturday night. I don’t remember. Q Did you call Betty Currie, sir, after the Drudge Report hit the wire? A I did. Q Did you call her at home? A I did. Was that the night of the 17th? Q Night of the 17th, early morning hours of the 18th? A Okay, yes. That's because -- yes. I worked with Prime Minister Netanyahu that night until about midnight. MR. KENDALL: Wait. THE WITNESS: Isn't that right? MR. KENDALL: Excuse me. I think the question is directed -- Mr. Bennett, if you could help out by putting the day of the week, I think that would be helpful. BY MR. BENNETT: Q Saturday night, Sunday morning. A Yes. I called Betty Currie as soon -- I think about as soon as I could, after I finished with Prime Minister Netanyahu, and in the aftermath of that meeting planning where we were going next in the Middle East peace process. MR. KENDALL: Can we take a two-minute break please? MR. BITTMAN: May I ask one other question first, Mr. Kendall? MR. KENDALL: Certainly. I think the witness is confused on dates. That's all. MR. BITTMAN: Okay. THE WITNESS: That's what -- I didn't think it was the night of the 17th. MR. KENDALL: Mr. President, I think we'll do it in a break. THE WITNESS: Can we have a break and I could get straightened out? MR. BITTMAN: Sure. May I ask one other guick this is a question I forgot to ask from the grand jurors. THE WITNESS: I don't want to get mixed up on these dates now. Go ahead. BY MR. BITTMAN: Q This is -- they wanted to know whether, they want us to clarify that the President's knowledge, your knowledge, Mr. President, as to the approach to our office this morning; that is, we were told that you would give a general statement about the nature of your relationship with Ms. Lewinsky, which you have done. Yet that you would -- you did not want to go in any of the details about the relationship. And that if we pressed on going into the details, that you would object to going into the details. And the grand jurors, before they wanted, they wanted to vote on some other matters, they wanted to know whether you were aware of that? That we were told that? MR. KENDALL: Well, Mr. Bittman, who told you that? This is, this is, this is not a fair question, when you say you were told. Who told you? MR. BITTMAN: Who told me what, the question? MR. KENDALL: You said, you said the grand jury was told. MR. BITTMAN: We have kept the grand jury informed, as we normally would, of the proceedings here. MR. KENDALL: Right. And, I'm sorry. Who, who are you representing told you or the grand jurors anything? Is that, is that our conversation? MR. BITTMAN: Yes. MR. STARR: Yes, our conversation. MR. BITTMAN: Yes. That was in substance related to the grand jurors. THE WITNESS: And what's your question to me, Mr. Bittman? BY MR. BITTMAN: Q Whether you were aware of the facts that I just described? A Yes, sir. Let me say this. I knew that Mr. Kendall was going to talk with Judge Starr. What we wanted to do was to be as helpful as we could to you on the question of whether you felt I was being truthful, when I said I did not have sexual relations with Ms. Lewinsky, as defined in that definition (1) in this, in my testimony. And I thought the best way to do that, and still preserve some measure of privacy and dignity, would be to invite all of you and the grand jurors to ask, well, would you consider this, that, or the other thing covered by the definition. You asked me several questions there, and I did my best to answer whether I thought they were covered by the definition, and said if I thought they were covered, you could conclude from that that my testimony is I did not do them. If those things, if things are not covered by the definition, and I don’t believe they are covered, then l could not -- then they shouldn't be within this discussion one way or the other. Now, I know this is somewhat unusual. But I would say to the grand jury, put yourself in my position. This is not a typical grand jury testimony. I, I have to assume a report is going to Congress. There 's a videotape being made of this, allegedly because only one member of the grand jury is absent. This is highly unusual. And, in addition to that, I have sustained a breathtaking number of leaks of grand jury proceedings. And, so, I think I am right to answer all the questions about perjury, but not to say things which will be forever in the historic annals of the United States because of this unprecedented videotape and may be leaked at any time. I just think it's a mistake. And, so, I'm doing my best to cooperate with the grand jury and still protect myself, my family, and my office. MR. BITTMAN: Thank you. MR. KENDALL: This will be two minutes. (Whereupon, the proceedings were recessed from 5:37 p.m. until 5:43 p.m.) BY MR. BENNETT: Q Mr. President, before we broke, we were talking about the sequencing of your conversations with Betty Currie following your deposition on Saturday, January 17th. Do you recall that? A I do. Q All right. And you recall contacting Betty Currie, calling her and instructing her on the evening of Saturday night, after your deposition, and telling her to come in the next day? A Yes, sir, I do. Q Sunday was normally her day off, isn't that so? A Yes, it was. Q And so you were making special arrangements for her to come back into the White House, isn't that so? A Well, yes. I asked her to come back in and talk to me. Q And it was at that time that you spoke with her, and Mr. Bittman and Mr. Wisenberg have asked you questions about what you said in that conversation, isn't that so? A Yes, they have -- I don't know whether that's the time, but they -- I did talk to her as soon as I realized that the deposition had become more about Monica Lewinsky than Paula Jones. I asked her, you know, if she knew anything about this. I said, you know, it's obvious that this is going to be a matter of press speculation, and I was trying to go through the litany of what had happened between us, and asked some questions. Q On fairness, it would be more than a matter of simple press speculation, isn't that so? Mr. President, there was a question about whether you had testified fully, completely, and honestly on the preceding day in your deposition. A Well, actually, Mr. Bennett, I didn’t think that then. I – this has been a rather unprecedented development, and I wasn’t even thinking about the Independent Counsel getting into this. So, at that moment, I knew nothing about it and I was more interested in what the facts were and whether Ms. Currie knew anything about it, knew anything about what Monica Lewinsky knew about it. Q Mr. President, you’ve told us at least a little bit about your understanding of how the term sexual relations was used, and what you understood it to mean in the context of your deposition. Isn't that correct? A That is correct. Q And you’ve told us -- I mean, that was a lawsuit Paula Jonea filed in which she alleged that you asked her to perform oral sex, isn’t that so? A That was her allegation. Q That was her allegation. And, notwithstanding that that was her allegation, you've testified that you understood the term sexual relations, in the context of the questions you were being asked, to mean something else, at least insofar as you were the recipient rather than the performer? A Sir, Paula Jonea' lawyers pulled out that definition, not me. And Judge Susan Webber Wright ruled on it, just as she later ruled their case had no merit in the first place, no legal merit, and dismissed it. I had nothing to do with the definition. I had nothing to do with the Judge's rulings. I was simply there answering the questions they put to me, under the terms of reference they imposed. Q Well, the grand jury would like to know, Mr. President, why it is that you think that oral sex performed on you does not fall within the definition of sexual relations as used in your deposition. A Because that is -- if the deponent is the person who has oral sex performed on him, then the contact is with -- not with anything on that list, but with the lips of another person. It seems to be self-evident that that's what it is. And I thought it was curious. Let me remind you, sir, I read this carefully. And I thought about it. I thought about what 'contact' meant. I thought about what "intent to arouse or gratify" meant. And I had to admit under this definition that I'd actually had sexual relations with Gennifer Flowers. Now, I would rather have taken a whipping than done that, after all the trouble I'd been through with Gennifer Flowers, and the money I knew that she had made for the story she told about this alleged 12-year affair, which we had done a great deal to disprove. So, I didn't like any of this. But I had done my best to deal with it and the -- that's what I thought. And I think that’s what most people would think reading that. Q Would you have been prepared, if asked by the Jones lawyers, would you have been prepared to answer a question directly asked about oral sex performed on you by Monica Lewinsky? A If the Judge had required me to answer it, of course, I would have answered it. And I would have answered it truthfully, if I -- Q By the way, do you believe that the - A -- had been required. Q -- Jones litigants had the same understanding of sexual relations that you claim you have? A I don’t know what understanding was, sir. My belief is that they thought they'd get this whole thing in, and that they were going to -- what they were trying to do is do just what they did with Gennifer Flowers. They wanted to find anything they could get from me or anyone else that was negative, and then they wanted to leak it to hurt me in the press, which they did even though the Judge ordered them not to. So, I think their - Q Wouldn't it -- I'm sorry. A I think their position, Mr. Bennett – you asked the question -- their position was, we’re going to cast the widest net we can and get as much embarrassing stuff as we can, and then dump it out there and see if we can make him bleed. I think that’s what they were trying to do. Q Don't you think, sir, that they could have done more damage to you politically, or in whatever context, if they had understood the definition in the same way you did and asked the question directly? A I don't know, air. As I said, I didn't work with their lawyers in preparing this case. I knew the case was wrong. I knew what our evidence was. By the time of this deposition, they knew what their evidence was. Their whole strategy was, well, our lawsuit's not good, but maybe we can hurt him with the discovery. And, you know, they did some. But it didn't amount to much. And did I want, if I could, to avoid talking about Monica Lewinsky? Yes, I'd give anything in the world not to be here talking about it. I'd be giving -- I'd give anything in the world not to have to admit what I've had to admit today. But if you look at my answer in the Flowers [sic] deposition, at least you know I tried to carefully fit all my answers within the framework there, because otherwise there was no reason in the wide world for me to do anything other than make the statements I'd made about Gennifer Flowers since 1991, that I did not have a 12-year affair with her, and that these, the following accusations she made are false. So, that’s all I can tell you. I can’t prove anything. Q But you did have a great deal of anxiety in the hours and days following the end of your deposition on the 17th. Isn’t that fair to say? A Well, I had a little anxiety the next day, of course, because of the Drudge Report. And I had an anxiety after the deposition because it was more about Monica Lewinsky than it was about Paula Jones. Q The specificity of the questions relating to Monica Lewinsky alarmed you, isn't that fair to say? A Yes, and it bothered me, too, that I couldn’t remember the answers. It bothered me that I couldn't -- as Mr. Wisenberg pointed out, it bothered me that I couldn't remember all the answers. I did the best I could. And so I wanted to know what the deal was. Sure. Q Mr. President, to your knowledge, have you turned over, in response to the grand jury subpoenea, all gifts that Monica Lewinsky gave you? A To my knowledge, I have, air. As you know, on occasion, Mr. Kendall has asked for your help in identifying those gifts. And I think there were a couple that we came across in our search that were not on the list you gave us, that I remembered in the course of our search had been given to me by Monica Lewinsky and we gave them to you. So, to the best of my knowledge, we have given you everything we have. Q Can you explain why, on the very day that Monica Lewinsky testified in the grand jury on August 6th of this year, you wore a necktie that she had given you? A No, sir, I don't believe I did. What necktie was it? Q The necktie you wore on August 6th, sir. A Well, I don't know that it was a necktie that Monica Lewinsky gave me. Can you describe it to me? Q Well, I don't want to take time at this point, but we will provide you with photographic evidence of that, Mr. President. A If you give me -- I don't believe that's accurate, Mr. Bennett. Q So, let me ask the question -- A But if you give it to me, and I look at it and I remember that she gave it to me, I'll be happy to produce it. I do not believe that's right. Q Well, if you remember that she gave it to you, why haven’t you produced it to the grand jury? A I don't remember that she gave it to me. That's why I asked you what the tie was. I have - Q Can you -- A -- no earthly idea. I believe that, that I did not wear a tie she gave me on August the 6th. Q Can you tell us why Bayani Nelvis wore a tie that Monica Lewinsky had given you on the day he appeared in the grand jury? A I don't know that he did. Q Have you given Bayani Nelvis any ties, sir? Oh, yes, a lot of ties. Q And so if he wore the tie that you gave him, that Monica Lewinsky had given you, that would not have been by design, is that what you are telling us? A Oh, absolutely not. Let me - Q You are not - A May I explain, Mr. Bennett? It won't - Q Yes.
A-- take long. Every year, since I've been President, I've gotten quite a large number of ties, as you might imagine. I get, I have a couple of friends, one in Chicago and one in Florida who give me a lot of ties, a lot of other people who send me ties all the time, or give them to me when I see them. So, I always have the growing number of ties in my closet. What I normally do, if someone gives me a tie as a gift, is I wear it a time or two. I may use it. But at the end of every year, and sometimes two times a year, sometimes more, I go through my tie closet and I think of all the things that I won’t wear a lot or that I might give away, and I give them mostly to the men who work there. I give them to people like Glen and Nelvis, who work in the kitchen, back in the White House, or the gentlemen who are my stewards or the butlers, or the people who run the elevators. And I give a lot of ties away a year. I'll bet I -- excluding Christmas, I bet I give 30, 40, maybe more ties away a year, and then, of course, at Christmas, a lot. So, there would be nothing unusual if, in fact, Nelvis had a tie that originally had come into my tie closet from Monica Lewinsky. It wouldn't be unusual. It wouldn't be by design. And there are several other people of whom that is also true. Q Mr. President, I'd like to move to a different area right now. I'd like to ask you some questions about Kathleen Willey. You met Kathleen Willey during your 1992 campaign, isn’t that so? A Yes, sir, I did. Q As a matter of fact, you first saw her at a rope line at the Richmond, Virginia airport on October 13, 1992, . is that not correct? A I don't believe that is correct. Q When did you first meet her, sir? A Well, let me ask you this. When was the debate in Richmond? Q I believe it wee October 13, 1992, sir. A Well, I believe that I had met her -- I believe I had met her before then, because Governor Wilder, I believe that was his last year as governor -- I think that's right, 92-93. I believe that I met her in connection with her involvement with Governor Wilder. And I have the impression -- it's kind of a vague memory, but I have the impression that I had met her once before, at least once before I came to that Richmond debate. Now, I'm not sure of that. Q Well, at least if you have met her before -- A But I am quite sure she was at the Richmond debate and I did meet her there. I'm quite sure of that. Q Mr. President, you've seen television footage of you standing on a rope line with Donald Beyer, Lt. Governor Donald Beyer - A I have. Q -- asking Mr. Beyer for the name of Kathleen Willey? You've seen that footage, haven't you? A I don't know that I've seen it, but I am aware that it exists. Q All right. And you can see him, you can read his lips. He’s saying the name Kathleen Willey in response to a question from you, isn't that so? A That's what I've heard. |
