• Transcript of Aug. 20 grand jury appearance

    This is a transcript of Monica S. Lewinsky's testimony to the grand jury on Aug. 6 as transcribed by the Federal Document Clearing House from printed and scanned documents supplied by the House Judiciary Committee. This is not an official transcript.

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    TESTIFIES TO GRAND JURY

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    GRAND JURY TESTIMONY OF MONICA S. LEWINSKY -- DAY ONE

    AUGUST 6, 1998

    PROCEEDINGS

    Whereupon,

    MONICA S. LEWINSKY

    was called as a witness and, after having been first duly sworn by the Foreperson of the Grand Jury, was examined and testified as follows:

    EXAMINATION

    BY MR. EMMICK:

    Q. Good morning.

    A. Good morning.

    Q. Ms. Lewinsky, this is the grand jury appearance that you'll be make or at least the first of the grand jury appearances, if there will be any more. What we routinely do with witnesses before the grand jury is that we begin the appearance by discussing your rights and your obligations and so that's what we'll do right now.

    A. Okay.

    Q. What I'd like to say first is that you have a Fifth Amendment right. That Fifth Amendment right is the right to refuse to answer any questions that may tend to incriminate you. Do you understand that right?

    A. Yes, I do.

    Q. Now, ordinarily, you could refuse to answer questions that would tend to incriminate you. As I understand it, here you have entered into an agreement with the government that provides you with immunity, in exchange for which you will be cooperating with the government. Is that right?

    A. Correct.

    MR. EMMICK: What I would like to do is show you a copy of what has been marked as Exhibit ML-2.

    (Grand Jury Exhibit No. ML-2 was marked for identification.)

    BY MR. EMMICK:

    Q. Do you recognize this?

    A. Yes, I do.

    A. On the third page of that document, there is a signature line that says Monica Lewinsky. Is that your signature?

    A. Yes, it is.

    Q. All right. You also have a right to counsel. What that means is that although your attorney cannot be in the grand jury room here with you, your attorney can be outside the grand jury room and available to answer whatever questions you might have. Do you understand that right?

    A. Yes, I do.

    Q. Do you have an attorney?

    A. Yes, I do.

    Q. Who would that be?

    A. Several.

    Q. All right.

    A. Jake Stein, Plato Cacheris -- do you want me to name all of them who are here or just the lead?

    Q. All right. Those are the lead counsel?

    A. Those are the lead counsel.

    Q. All right. And are they outside?

    A. Yes, they are.

    Q. You understand that if you need to speak with them, all you need to say is "I'd like to speak with my attorneys about something for just a minute"?

    A. Yes.

    Q. All right. In addition to those two rights that you have, you also have an obligation and that obligation is to tell the truth. That obligation is imposed on you because you have taken an oath and that is the oath to tell the truth. Do you understand that?

    A. Yes, I do.

    Q. Do you understand that if you were to intentionally say something that's false, in common parlance, if you were to lie, that would constitute perjury and perjury is a felony and it's punishable by up to five years in prison? Do you understand that?

    A. Yes.

    Q. DO you understand as well that because of the agreement that you have signed if you were to lie, if you were to intentionally lie, that would mean that the agreement that you have that gives you immunity could be voided and you could be prosecuted? Do you understand that?

    A. Mm-hmm.

    Q. All right. And that in simple parlance, what that means, is that you can retain immunity, but only if you do not lie. Do you understand that?

    A. Yes.

    Q. Okay. What I'd like to do is simply discuss with you briefly or clarify with you the fact that we have had interviews with you since the time when you signed this agreement. Is that right?

    A. Yes.

    Q. All right. We've had interviews with you, I believe, every day since the signing of the agreement.

    A. Correct.

    Q. Several hours a day?

    A. Yes.

    Q. Is that right? All right. I also wanted to ask you a question having to do with your mental state right now. How are you feeling?

    A. Nervous.

    Q. Okay. I wanted also to ask you, are you taking any medication at this time?

    A. Yes, I am.

    Q. What I'd like to ask about that is simply is that having any effect on your ability to recall or to communicate that in some way will hinder your ability to answer questions?

    A. I don't believe so, but it affects my short-term memory just a little bit.

    Q. Okay. That's fine. Understand, if you will, that your role today is simply to answer questions that we pose to you.

    We have spoken with you for a number of hours, a number of days, and we're going to be asking you to talk about essentially three years of conduct. We are not going to be asking you to recount every detail of the last three years of your life and we are not going to be asking you to recount everything that you've told us over the last ten days or so. You'll just be answering questions and we understand that you have other details that you could provide on other occasions.

    A. Yes.

    MR. EMMICK: All right. What I'd like to do next is to let you know what our approach is going to be today.

    What we're going to do is we're going to start off talking about your internship at the white House and then we're going to ask you questions having to do with your relationship with the President.

    Because we think that that will proceed more comfortably if those questions are asked by Ms. Immergut, I'm going to turn the questioning over to her and at some point, then, we'll collaborate in asking further follow-up questions. So without further ado --

    BY Ms. IMMERGUT:

    Q. Ms. Lewinsky, when did you s tart working at the White House?

    A. My internship began July of 1995.

    Q. And when you say "internship," could you just very briefly describe what it is you were doing and where you were working?

    A. Sure. I was interning for Mr. Panetta, who was Chief of Staff at that time, and I worked in his correspondence office preparing his correspondence, drafting some of the language.

    Q. Was there ever a time -- or I guess -- after beginning your internship, how long did you serve as an intern in the White House?

    A. About four, four and a half months. Four and a half months.

    Q. And was there ever a time that you then assumed a staff position that was not an intern position?

    A. Yes.

    Q. And when would that have been?

    A In November of 1995.

    Q When did you first notice the President of the United States?

    A Our first encounter, I guess non-verbal encounter, was August 9, 1995.

    Q And could you describe what that encounter was?

    A Yes. It was a departure ceremony on the South Lawn and, as he was going by on the rope line shaking hands, we made eye contact and it was more intense eye contact than I had experienced before with him.

    Q Okay. And did you have any further such contact sort of later, after that initial time?

    A Yes. The next day the President -- I guess the staff had a birthday party for the President on the South Lawn and the interns were invited to that later in the day. And at that party, there was sort of a more intense flirtation that went on at a distance.

    Q Okay. Did you feel that he was flirting with you as well? Or how would you describe the behavior that you both exhibited?

    A It was intense eye contact and when he went by the rope line to shake hands, it was -- I mean, he -- he's a charismatic person and so -- just when he shook my hand and -- there was an intense connection.

    Q Okay. And could you sort of just summarize the early relationship that you had with the President before any first sexual contact?

    A I think it was intense flirting.

    Q Okay. Did you have conversations with him?

    A Brief conservation that I think in passing -- if I saw him or -- at a departure ceremony, "Have a nice trip." I introduced myself at one point.

    Q Okay. And how did you manage to run into him or even see him? Was that a common occurrence or how would that be accomplished?

    A Before the relationship began, it was mainly at departure ceremonies, I think there were a few, and then on one occasion my best friend was in town and she was getting a tour of the West Wing and I was waiting for her in the basement lobby and met him that way. There were several other people there.

    A Yes.

    Q And when did that occur?

    A On November 15, 1995.

    Q Okay. And although as I've told you, I'm not going to go into a lot of specific dates, this one that I wanted you to explain sort of how it came about.

    A It was during the furlough. I was up in Mr. Panetta's West Wing office answering phones. The President came down several times during the day.

    There was the continued flirtation and around 8:00 in the evening or so I was in the hallway going to the restroom, passing Mr. Stephanopoulos's office and then from there invited me back into his study.

    Q Okay. And what happened there?

    A We talked briefly and sort of acknowledged that there had been a chemistry that was there before and that we were both attracted to each other and then he asked me if he could kiss me.

    Q And what did you say?

    A Yes.

    Q And did you kiss on that occasion?

    A Yes.

    Q And where in the -- you mentioned you went back to the study area.

    A Mm-hmm.

    Q Where exactly did the kiss occur?

    A Right outside his bathroom, in the hallway, inside --adjacent to the study, to the office.

    Q Okay. And how did you end that -- was there anything more than a romantic kiss on that sort of first encounter?

    A No.

    Q Okay. Did you have any later encounter with him on that same date?

    A Yes, I did.

    Q Okay. Could you describe how that occurred?

    A The President came down to Mr. Panetta's office, I think it might have been around 10 p.m., and he told me that if I wanted to meet him back in Mr. Stephanopoulos' office in five minutes, that would be fine. And I agreed. And I met him back there. We went back to his office again, in the back study area.

    Q Okay. And what happened in the back study area?

    A We talked and we were more physically intimate.

    Q Okay. And on that occasion, did you perform oral sex on the President?

    A Yes.

    Q With respect to physical intimacy, other than oral sex, was there other physical intimacy performed?

    A Yes. Everything up until oral sex.

    MS. IMMERGUT: Okay. And just for the grand jury purposes, I have marked as an exhibit ML-6 and I'll just read it to the grand jury and place it before you.

    (Grand Jury Exhibit No. ML-6 was marked for identification.)

    MS. IMMERGUT: It states "Definition of Sexual Relations. For the purposes of the grand jury session, a person engages in 'sexual relations' when the person knowingly engages or causes contact with the genitalia, anus, groin, breast, inner thigh, or buttocks of any person with an intent to arouse or gratify the sexual desire of any person. Contact means intentional touching, either directly or through clothing."

    BY MS. IMMERGUT:

    Q Ms. Lewinksy, do you understand that definition?

    A Yes, I do.

    MS. IMMERGUT: And I do have copies to pass out to the grand jury.

    BY MS. IMMERGUT: When you described that you had other physical intimacy during your contact with the President on November 15, 1995, did that include sexual relations within the definition of that I've just read to you?

    A Yes, it does.

    Q In that -- again, that second contact with him on November 15, 1995, where exactly did the sexual contact that you've described occur?

    A In the same hallway, by the back study, and then also in his office.

    Q Okay. And the back office, would that be the study area?

    A Yes.

    Q Okay. Did you have further sexual encounters with him after that first time on the 15th?

    A Yes.

    Q When was the next time?

    A On the 17th of November.

    Q And could you explain how that contact occurred?

    A We were again working late because it was during the furlough and Jennifer Palmieri and I, who was Mr. Panetta's assistant, had ordered pizza along with Ms. Currie and Ms. Hernreich.

    And when the pizza came, I went down to let him know that the pizza was there and it was at that point when I walked into Ms. Currie's office that the President was standing there with some other people discussing something.

    And they all came back down to the office and Mr. -- I think it was Mr. Toiv, somebody accidentally knocked pizza on my jacket, so I went to go use the restroom to wash it off and as I was coming out of the restroom, the President was standing in Ms. Currie's doorway and said, "You can come out this way."

    So we went back into his back study area, actually, I think, in the bathroom or in the hallway right near the bathroom, and we were intimate.

    Q Okay. And at that point, what sort of intimacy was it?

    A I believe it was just kissing at that point.

    Q Okay. And how did that encounter end?

    A I said I needed to pack and he said, "Well, why don't you bring me some pizza?" So I asked him if he wanted vegetable or meat.

    Q Okay. And, actually, where did the kissing occur that time?

    A It was -- I think it was in the bathroom or it was right outside the bathroom, in the hallway adjacent to the bathroom.

    Q Okay. So did you go back and get him some pizza?

    A Yes, I did.

    BY MR. WISENBERG:

    Q Pardon me. Sorry to interrupt. That's the bathroom adjacent to the hallway that leads from the Oval Office to the dining room. Is that correct?

    MR. WISENBERG: Sorry for interrupting.

    BY MS. IMMERGUT:

    Q Did you go back and get pizza?

    A Yes, I did.

    Q And did you ever return to the President with the pizza?

    A Yes, I did.

    Q Could you describe what happened when you returned?

    A Yes. I went back to Ms. Currie's office and told her the President had asked me to bring him some pizza.

    She opened the door and said, "Sir, the girl's here with the pizza." He told me to come in. Ms. Currie went back into her office and then we went back into the back study area again.

    Q Okay. And what happened in the back study area?

    A We were in the -- well, we talked and then we were physically intimate again.

    Q Okay. And was there oral sex performed on that occasion?

    A Yes.

    Q Okay. And that would be you performing oral sex on him?

    A Mm-hmm.

    Q Okay. And again -- and I have to sort of tell you, you can't answer "Mm-hmm" --

    A Oh, sorry.

    Q Just yes or no, just for the record. With respect to the physical intimacy again, does that fall -- when you say "physical intimacy," do you mean sexual relations within the definition?

    A Yes, I do.

    Q Now, without going into sort of a lot of details of specific dates, I wanted to ask you some general questions about the relationship and to make clear, although we've already -- Mr. Emmick already asked you whether or not you've met with us on several occasions, is it fair to say you've given us many, many details about each of the specific dates involved in the relationship?

    A Yes.

    Q Did the relationship with the President develop into or also have a non-sexual component to it?

    A Yes, it did.

    Q Could you describe sort of that aspect of the relationship for the grand jury?

    A We enjoyed talking to each other and being with each other. We were very affectionate.

    Q What sorts of things would you talk about?

    A We would tell jokes. We would talk about our childhoods. Talk about current events. I was always giving him my stupid ideas about what I thought should be done in the administration or different views on things. I think back on it and he always made me smile when I was with him. It was a lot of -- he was sunshine.

    Q And did he make you feel like he enjoyed your being there and talking to you about things?

    A Yes.

    Q Were there times that you visited him in the Oval Office where there was no sexual contact at all?

    A Yes.

    Q Was there sort of affectionate contact during some of those times?

    A Very. Yes.

    Q Okay. And how would you describe sort of affectionate, but non-sexual contact?

    A A lot of hugging, holding hands sometimes. He always used to push the hair out of my face.

    Q Okay. Could you describe generally how those meetings were set up or how those encounters were actually set up as a general matter?

    A After the first few incidents that sort of happened during the furlough, they were set up -- when I was working in Legislative Affairs, usually the President would call my office on a weekend.

    He had told me earlier on that he was usually around on weekends and that it was okay to come see him on the weekends. So he would call and we would arrange either to bump into each other in the hall or that I would bring papers to the office.

    Do you want me to do after?

    Q Okay. Then what happened after?

    A Once I left the White House, Ms. Currie arranged the visits.

    Q Okay. And how would she arrange those, typically?

    A I don't understand. I'm sorry.

    Q When you say Ms. Currie would arrange them, how would it come about that they would be set up?

    A Usually either through my talking to the President prior to and then him talking to Ms. Currie or me bugging Ms. Currie to ask the President.

    Q Okay. All right. Did the relationship after the events you've described of November 15th and 17th, did it continue also to have a sexual component?

    A Yes, it did.

    Q After the two incidents that you've described, did you have further sexual contact with him?

    A Yes.

    Q And I'm going to ask you just some general questions about that. The grand jurors heard that there's a chart and we'll sort of go through a chart afterwards in less detail. Approximately how many times do you recall performing oral sex on the President?

    A I think about nine.

    Q Did he ever perform oral sex on you?

    A No. We had discussed it and there were times when it almost happened, but mother nature was in the way.

    Q Okay. How many times did he ejaculate when you performed oral sex?

    A In my presence?

    Q In your presence.

    A Twice.

    Q Okay. And do you recall the dates of those times?

    A Mm-hmm. February 28, 1997 and March -- I think it's the 29th, 1997.

    Q Did you engage, other than oral sex, in other physical intimacy that would fall within the definition of sexual relations that we've read to you?

    A Yes.

    Q Were you alone with the President when you had these sexual encounters with him?

    A Yes.

    Q It seems like an obvious question, but I have to ask it. Did the President ever have telephone calls while you were actually engaging with oral sex with him?

    A Twice.

    Q And when those telephone calls occurred, did he ever talk on the phone while you were performing oral sex?

    A Yes.

    Q Do you have any recollection about when those occurred?

    A I believe one was November 15, 1995, in my second visit with him, and I know April 7, 1996.

    Q Okay. Did you ever have sexual intercourse with the President?

    A No.

    Q Was there ever a time when your genitals actually touched each other?

    A Grazed each other, yes.

    Q And do you remember when that occurred?

    A Yes. February 28, 1997. Oh, no. I'm sorry. March 29th, not February 28th. Sorry.

    Q Okay. And could you explain why you didn't have sexual intercourse with him?

    A He didn't want to. The president said that he -- that at his age, that there was too much of a consequence in doing that and that when I got to be his age I would understand. But I wasn't happy with that.

    Q Okay. I want to move away from that now.

    A Okay.

    Q And ask you whether or not you've ever spoken to the President on the telephone.

    A Yes.

    Q And can you estimate approximately how many times beginning of your relationship with him that you've him on the phone?

    A Over 50, probably.

    Q And has he initiated any of those calls?

    A Yes.

    Q Do you have any sort of idea how many times he's called you?

    A Most of those phone calls were calls that he placed to me directly.

    Q Okay. Did he ever leave any messages for you at your home?

    A Yes.

    Q And you remember about how many times he left messages?

    A I think about four.

    Q Did you save any of those messages?

    A Yes, I did.

    Q And have you provided any cassette tape of those messages to the OIC?

    A Yes, I have.

    Q Do you remember any particular messages that he left you?

    A I remember them all.

    Q Okay. Why don't you just tell the grand jury what they say.

    A They're pretty innocuous. Sometimes -- or one time, it was, you know, "Sorry I missed you." One time, it was just "Hello." And then one time he called really late at night when I was not at home and it was whispered kind of loudly, you know, "Come on. It's me." Something like that. It was always nice to hear his voice.

    Q Okay. Did he ever tell you how he felt about leaving messages on your home machine?

    A Yes.

    Q What did he tell you about that?

    A I believe it was the beginning of 1996, at some point, he just remarked that he didn't like to do that, he just -- 1 think felt it was a little unsafe.

    Q Okay. Did he ever call you late at night?

    A Yes.

    Q Can you tell us a little bit about that? Did that happen on many occasions?

    A Yes. He's a night owl, so it would be customary for him to call sometimes 2:00 in the morning, 2:30 in the morning.

    Q Okay. What sorts of things did you discuss with him generally of a non-sexual nature on your telephone calls with him?

    A Similar to what we discussed in person, just how we were doing. A lot of discussions about my job, when I was trying to come back to the White House and then once I decided to move to New York. We told jokes. We talked about everything under the sun.

    Q Okay. Was there ever a time that you began to engage in phone sex on the telephone? Mm-hmm. Yes. And do you remember when that started to occur? In the beginning of 1996. Okay. Did he participate in that? Yes. Okay. And about how many times did you have phone sex with him, if you know?

    A Oh, maybe 10, 15 sure. I'm not really -- I'm not really

    Q Okay. We can look at the chart after to refresh your recollection, but that sounds sort of ballpark?

    A I think so.

    Q More than 10, about? In your view?

    A Yes, I think so.

    Q Did the President ever tell you that he wanted to end the sexual relationship with you?

    A Yes.

    Q And did he tell you that more than once?

    A Yes.

    Q Could you tell us when he told you that?

    A February -- it was Presidents Day of 1996. I think that's February 19th. And also on May 24, 1996 -- no, 1997. I'm sorry.

    Q And just for the grand jury's information, on the chart that we're going to show them in a little bit, how do you list -- do you have a term that you refer to the May 24, 1997 meeting with him?

    A D-day.

    Q And what does that stand for?

    A Dump day.

    Q And on those two occasions, what did he tell you about wanting to end the relationship? Just generally.

    A Both were, I think, motivated sort of by guilt and just not wanting to -- more I think on the 24th of May in '97, just really wanting to do the right thing in God's eyes and do the right thing for his family and he just -- he didn't feel right about it.

    Q Did you engage in sexual contact with him after those times?

    A Yes. Kissing.

    Q Okay. After the -- well, after the February 19, 1996 time?

    A Yes. Yes.

    Q And what about after the May 24, 1997 time?

    A Just kissing.

    Q Did your relationship involve giving gifts to each other?

    A Mm-hmm. Yes. I'm sorry.

    Q And did you give any gifts to him?

    A Yes.

    Q Do you have any sort of ballpark figure of how many gifts you've given to him since you've known him?

    A About 30.

    Q And what about him to you? Do you have any estimate of how many gifts he gave you?

    A I think about 18.

    Q Did you ever write him any notes or letters or cards?

    A Yes.

    Q And what sort of cards or letters or notes would you write to him?

    A It varied on the occasion. It could be a funny card that I saw or a Halloween card. If I was angry, it could be an angry letter. If I was missing him, it was a missing him letter.

    Q Okay. So were some of them -- is it fair to say some of them were romantic in nature?

    A Yes.

    Q And when they were angry, what would you be angry about in your letters or cards?

    A Either job-related issues or him not paying enough attention to me.

    Q Okay. Did he write you any letters or notes?

    A No.

    Q Did he ever say why he wasn't writing you any letters or notes?

    A No.

    BY MS. IMMERGUT:

    Q I'd now like to show you what I had previously marked as Exhibit 7, I believe. Perhaps somebody has the other original version.

    (Grand Jury Exhibit No. ML-7 was marked for identification.)

    Q I'm going to place this before you and ask if you recognize that chart.

    A Yes, I do.

    Q And have you seen that chart before?

    A Yes, I have.

    Q Did you assist the Office of Independent Counsel in preparing that chart?

    A Yes.

    Q Did you provide all of the information that's listed on that chart?

    A Yes.

    Q Could you describe for the grand jury just generally what is described by that chart?

    A I think it's a chronology that marks some of the highlights of my relationship with the president. It definitely includes the visits that I had with him and most of the gifts that we exchanged. It reflects most of the phone calls that I remember.

    Q And to the best of your knowledge, is the chart I accurate?

    A Yes.

    Q Have you noticed anything that you would add or delete from the chart since you've reviewed it?

    A Yes. On page...

    Q Do the grand jurors have the chart?

    EMMICK: They do. Yes.

    A On page 5, the last entry in the chart, on 10/23, I attended a Democratic fundraiser that you guys have all probably seen on T.V. lately.

    Q Okay. Anything else that you've noticed?

    A No.

    Q Okay. Otherwise, would you say that the chart is a pretty accurate rendition or description of your memory of all of the events?

    A Yes.

    Q How is it that you remember all the events in such detail over really sort of what is a few years?

    A I've always been a date-oriented person and I had a --probably a habit of circling dates in my Filofax when I either talked to the President or saw him.

    Q And did you provide those Filofax sheets to the Office of Independent Counsel?

    A Yes.

    Q And did that assist you in remembering the dates?

    A Yes, it did.

    Q And were these encounters important to you?

    A Very.

    Q And, again, on that chart there are various categories. In the visit category -- or descriptions in the visit category area that are described as physical intimacy. And with respect to all of those, do they fall within the definition of sexual relations that I've presented as Exhibit 6 to the grand jury?

    A Yes.

    Q So anywhere physical intimacy is listed on the chart, it falls within that definition. Is that correct?

    A Right. I think the only thing that might be missing is kissing.

    Q Okay. And kissing is separately described on the chart, is it not?

    A No, not necessarily.

    Q Okay.

    A I mean, because the physical intimacy -- wherever there's physical intimacy, there was always -- there was always kissing.

    Q Okay. But where there's physical intimacy, there I was also then more than kissing.

    A Correct.

    Q Okay. So physical intimacy is never on the chart to describe only kissing.

    A Correct.

    Q Okay. There's one particular date also that I wanted to cover with you which is February 28, 1997.

    A Okay.

    Q Because at that time, as the chart demonstrates, you haven't really seen the President since April of the year before. Could you describe what the circumstances were leading up to your visit with him on February 28, 1997?

    A The president had told me in December that he had a Christmas present for me and I ended up not getting it until the end of February. Ms. Currie called me at work during that week to -- or I guess it was that day, I'm sorry, that Friday, to invite me to a radio address that evening.

    I went to the radio address and when I went to take my picture with the president, he said to go see Betty because he had something to give me after. So I waited a little while for him and then Betty and the President and I went into the back office.

    Q Okay. Anti why did Betty come in the back office with you?

    A I later found out that -- I believe it was Stephen Goodin who said to Ms. Currie and the president that the president couldn't be alone with me, so Ms. Currie came back into the back office with us.

    Q And then what?

    A And then left.

    Q Okay. She left? And do you know where she went?

    A I came to learn later, I believe she was in the pantry. In the back pantry.

    Q Okay. And how did you learn that later?

    A I think that Mr. Nelvis told me. Or Ms. Currie told me.

    Q Okay. What happened when she went to the back pantry? Did you remain with the president?

    A Yes, I did.

    Q And could you describe what you and the president did?

    A Mm-hmm. He gave me my hat pin and the book "Leaves of Grass" and I was pestering him to kiss me and so we moved -- that was in the back study and then we moved over to the back hallway by the bathroom and we were physically intimate.

    Q Okay. And did you perform oral sex on that occasion?

    A Yes.

    Q And how did you -- do you remember what dress you were wearing on that occasion?

    A Yes.

    Q What dress was it?

    A The navy blue dress from The Gap.

    Q And after that incident, did you ever tell Linda Tripp that there might be the president's semen on that dress?

    A Yes, I did.

    Q And why did you tell her that? Or did you believe that that could be true?

    A I thought it was possible.

    Q Were you positive it was true?

    A No.

    Q Back to the incident with the president, how did you leave it with him on that occasion? Sort of once you finished the visit, what happened?

    A Betty came back into the back study and then I think Ms. Currie walked me out.

    Q Okay. How much about your relationship with the president did you tell Linda Tripp?

    A A lot. Most everything.

    Q Okay. And did you tell her about the sexual encounters that you had with him?

    A Yes.

    Q Did you also tell her about the emotional encounters and the gifts?

    A Yes.

    Q Were you truthful about the relationship when you told Linda Tripp about it?

    A Most of the time, but sometimes -- there were occasions when I wasn't truthful.

    Q Were you truthful about the sexual parts of the relationship with her?

    A Yes.

    Q And what about the emotional component, when you would tell her -- and why don't I say before December of 1997, were you truthful about the emotional components of the relationship?

    A Yes.

    Q I'm actually done with my questioning on that. Do you want to break now or continue to different subjects?

    A A five-minute break? could I --

    FOREPERSON: We can take a ten-minute break.

    IMMERGUT: Okay. A ten-minute break.

    EMMICK: A ten-minute break.

    IMMERGUT: Would that be all right?

    WITNESS: Okay.

    EMMICK: That's fine.

    (WITNESS EXCUSED. WITNESS RECALLED.)

    IMMERGUT: Madam Foreperson, are there any unauthorized persons present?

    FOREPERSON: No, there are none.

    IMMERGUT: Do we have a quorum?

    FOREPERSON: Yes, we do. Ms. Lewinsky, I would like to remind you that you are still under oath.

    WITNESS: Thank you.

    BY MS. IMMERGUT:

    Q Ms. Lewinsky, the grand jurors had a few follow-up questions --

    A Sure.

    Q -- for you that I wanted to ask you before we move on to other topics. You mentioned that on the occasions where you had sexual contact with that were described, sexual contact with the President, that it occurred in the hallway, as you described, or sometimes in the back study.

    A Mm-hmm.

    Q Why did --

    JUROR: Pardon me.

    BY MS. IMMERGUT:

    Q Oh, excuse me. Why did you choose the hallway?

    A Because I believe it was -- it was really more the president choosing the hallway, I think, and it was -- there weren't any windows there. It was the most secluded of all the places in the back office. Well, that's not true. The bathroom is the most secluded, I guess, because you can close the door.

    Q And did you sometimes have sexual encounters in the bathroom?

    A Mm-hmm.

    Q And then next to the bathroom, would you say that the hallway is...

    A Right.

    Q ... off the study is the next most...

    A He has a bad back and so I think a lot of times we ended up just sort of standing there because he could close the door to the bathroom and lean up against the bathroom and then he was -- I guess it made his back feel better and also made him a little shorter. So...

    Q Did the president ever tell you he was concerned about being seen?

    A I'm sure that came up in conversation.

    BY MR. EMMICK:

    Q Did he ever indicate to you looking outside that he might be concerned, for example?

    A Yes, yes.

    BY MS. IMMERGUT:

    Q Can you describe that?

    A Sure. I think the one that comes to mind was actually December 28th of last year when I was getting my Christmas kiss. And he was kissing me in the doorway between the back study, or the office, and the hallway, and I sort of opened my eyes and he was looking out the window with his eyes wide open while he was kissing me and then I got mad because it wasn't very romantic. And then so then he said, "Well, I was just looking to see to make sure no one was out there"

    Q Can you generalize about the locations where you had your sexual encounters with the president?

    A I'd say they mainly took place in that hallway, but there were occasions on which we were intimate in the office and then also in the bathroom.

    Q Okay. And when you say the office, do you mean the back study?

    A Right.

    Q So not the Oval Office?

    A No, no, we were never physically intimate in the Oval Office.

    Q Okay. Did you notice whether doors were closed when you were physically intimate with him in the back study or hallway?

    A No, he always -- well, I'm not sure about the door going in the dining room but I know that the door leading from the back hallway to the -- into the Oval Office was always kept ajar so that he could hear if someone was coming.

    BY MR. WISENBERG:

    Q How ajar? How much ajar?

    A Maybe this much (indicating).

    BY MR. EMMICK:

    Q You're indicating six to eight inches, something like that?

    A I'm not very good with that.

    Q A foot or less, something like that?

    A A foot or less. I guess that's -- I would assume that's --

    Q Enough so that one could hear more easily what was going on in the next room?

    A Mm-hmm. Right, or if someone came in to holler for him.

    BY MS. IMMERGUT:

    Q Now directing your attention back to February 28th, -- 1997, the day that you wore the blue cocktail dress --

    A It's not a cocktail dress.

    Q Okay, I'm sorry.

    A No, that's Okay. I'm a little defensive about this subject. I'm sorry.

    Q How would you describe the dress?

    A It's a dress from the Gap. It's a work dress. It's a casual dress.

    Q With respect to that dress...

    A Right, I'm sorry.

    Q ... you mentioned that you believe that there could be semen on it. Could you describe what you did with the President that led you to believe that?

    A We were in the bathroom and -- can I close my eyes so I don't have to...

    Q Well, you have to speak up. That's the only...

    A Okay. We were in the bathroom and I was performing oral sex. I'm sorry, this is embarrassing. And usually he doesn't want to -- he didn't want to come to completion.

    Q Ejaculate?

    A Yes. And this has sort of been a subject that we had talked about many times before and he was always saying it had issues to do with trust and not knowing me well enough at first and then not feeling right about things, and not that he said this but I took away from that to sort of mean - that maybe in his mind if he didn't come then maybe it wasn't -- he didn't need to feel guilty about that, that maybe with it not coming to completion that that was easier for him to rationalize.

    And it was on this occasion that since we hadn't been alone together since April 7th of '96 that after we had engaged in oral sex for a while and he stopped me as he normally did, I said to him, you know -- this is so embarrassing, I'm sorry. I said to him, you know, I really -- I want to make you come. I mean, this is...

    Q Okay. Why don't you just describe the position that you were in once he had tried to stop you. What did you do that led you to believe there might get semen on your dress?

    A I told him that I really cared about him and he told me that he didn't want to get addicted to me and he didn't want me to get addicted to him, and we embraced at that point and that's -- I mean, it was -- it's just a little tiny spot down here, and a little tiny spot up here and --

    Q Okay. And to get -- when you're pointing down here, you mean sort of your right lower hip area?

    A Well, one of my -- I don't know if it was my right or my left, but lower hip area.

    Q Okay. And the chest area would be the second place that you thought you might have gotten some?

    A Mm-hmm.

    Q And is that from when you -- when you did actually continue to perform oral sex on him later?

    A I believe so.

    Q Did you ever see something that you thought was semen on the dress that led you to conclude that?

    A The next time I went to wear the dress.

    Q So at the time you didn't notice anything on the dress?

    A I don't believe so.

    Q Okay. What happened then the next time you wore the dress that led you to conclude that?

    A Well, I also -- can I say here? I also -- I think I wore the dress out to dinner that night, so which is why I'm not sure that that's what it is.

    Q Okay.

    A So it could be spinach dip or something. I don't know. I'm sorry, could you repeat the question?

    Q Sure. When was the -- when was it that you at least began to believe that maybe there was semen on the dress?

    A I really don't remember when it was the next time I went to wear the dress, but I gained weight so I couldn't wear the dress and it didn't fit. And I'm not a very organized person. I don't clean my clothes until I'm going to wear them again.

    Q Did you notice there was something on the dress?

    A Yes. And at that point I noticed it and I kind of thought, oh, this is dirty, it needs to get cleaned. And then I remembered that I had worn it the last time I saw the president, and I believe it was at that point that I thought to myself, oh, no. And it was --it...

    Q So at that point, you weren't positive what it was. And why did you tell Linda that you thought there was semen on the dress?

    A I think it just sort of came up in conversation somehow and then -- as kind of this funny, gross thing. And then the next time she was at my house I still couldn't fit into the dress and believe that I said to her, oh, look, you want to see this? You know, this is what I was talking about.

    And but I just want to say because I know everybody here reads the newspapers and listens to TV that I didn't keep this dress as a souvenir. I was going to wear it on Thanksgiving and my cousins, who I always try to look skinny for because they are all skinny -- and I know it sounds stupid. And when I told Linda I was thinking about wearing the dress, she discouraged me. She brought me one of her jackets from her thinner closet. And so it wasn't a souvenir. I was going to clean it. I was going to wear it again.

    Q Different topic. Where was Nel when you were -- or do you have any idea where Nel was when you were in the hallway or the study with the president?

    A On which --

    Q On any of the occasions. I mean, would Nel be around generally?

    A There were some occasions that -- very few occasions, I think, that Nel was there -- was at the White House. And I don't know where he would have necessarily -- I think he was in the pantry on the 28th of February.

    Q Do you know where he was on any of the other occasions? And, again, where you had sexual contact with the president.

    A I don't think so.

    Q Did you ever use hand towels in the bathroom to wipe your lipstick?

    A Hand towels, no.

    Q What about tissues?

    A I believe I used a tissue sometimes to wipe off my lipstick.

    WISENBERG: Karen, can I ask something really quick?

    IMMERGUT: Sure.

    BY MR. WISENBERG:

    Q How about, do you think Nel would have been around on renaissance -- right before the departure for renaissance weekend?

    A New Year's Eve '95?

    Q Yeah.

    A Yes, he was.

    Q Also, did you ever show -- did -- I don't -- it's my bad. Did you ever show the dress to Linda Tripp?

    A Yes.

    Q You mentioned that the president called you on a number of occasions. Some of those occasions included phone sex. Did he indicate where he was when he was placing those calls?

    A Not always, but sometimes.

    Q And where did he say he was when he did say where he was?

    A At home.

    Q Meaning the White House residence?

    A Yes.

    Q Where else might he have placed calls from?

    A There were, I think, two times that he placed calls from the campaign term, from Florida I think.

    Q Do you know whether he sometimes placed calls from the Oval Office or other places?

    A Yes, yes.

    Q How do you know that?

    A Sometimes he would mention it and say he was in the office. I know one time I said -- I knew he was in the office and I asked him if he was in the back or could he go in the back.

    Q Did he not only call you, what, at your home but also call you at your office?

    A When I was working at the White House, yes.

    Q But not while you were working at the Pentagon?

    A He never directly called me when I was working at the Pentagon.

    Q When you say didn't directly call, what do you mean?

    A I mean he -- there were, I think, maybe two occasions when I was working at the Pentagon when Betty placed a call for him, and when that didn't occur he picked up the phone and dialed the phone number himself.

    Q When he placed calls to you when you were at Leg Affairs, or Legislative Affairs, excuse me, was there anything that indicated on your caller ID?

    A Yes. When he called from the Oval Office, the phones have a caller ID up at the top, and when he calls from the Oval Office it says POTUS and when he calls from the residence it has an asterisk.

    Q And did you ever discuss with him the fact that you had POTUS on your ID?

    A Yeah.

    Q Tell us about that.

    A I think one time when he called and I picked up the phone I said something that indicated to him that I knew who it was. And he said, "Well, how did you know it was me?" And I told him, "Well, don't you know that it lights up POTUS when you call from the Oval Office?" And he said, "No, I didn't know that." So I thought that was funny.

    Q When you --

    A And he made an effort one time to call me from the residence on a line and called and said, "Did it show up a phone number instead of -- So it had. He seemed proud of himself.

    Q All right. You had mentioned earlier that on, I think it was February 28th, Steve Goodin spoke with Betty and the President about being -- about him being alone with you.

    A Mm-hmm.

    Q Could you give us a little more detail about what you saw and what you later learned and where you later learned it so that we can figure out what you know from personal knowledge?

    A Okay. What I saw was Steve Goodin and Ms. Currie going into the Oval Office. I think --

    Q Where are you at this time?

    A Oh, I'm sorry. I was in Ms. Currie's office and I was waiting with Ms. Currie. And I believe Stephen was there at some point and he might have gone into the Oval Office first and then called Ms. Currie in a few minutes after or maybe the president called her in after. And they spoke sort of...

    A JUROR: (COUGHING)

    WITNESS: Do you want some water? Oh, okay so --

    BY MR. EMMICK:

    Q Was there anyone else in the Oval Office, as far as you know?

    A It's possible I think I might have seen Rahm Emanuel in there at some point, but I'm not really sure that he was included in this conversation.

    Q So they go into the Oval Office and what do you next see or hear?

    A I believe Betty came out to get me. I was really nervous because I hadn't been alone with the president since the elections so I was focused -- I was kind of internal, focused on being nervous.

    Q Betty came out to get you and what did the two of you do?

    A The three of us went into the back office.

    Q You had mentioned earlier that you later came to learn that there was a discussion between them, between them, about you and the president and whether you should be alone.

    Tell us when you learned that approximately and what you learned.

    A I think I learned it, I believe, maybe shortly after -- not on that day, maybe within the next few weeks, guess -- that Stephen had said to the president or maybe had said to Betty, you know, she can't be alone with him. So, and I don't recall if I learned that from Ms. Currie or from Nel.

    BY MR. WISENBERG:

    Q But it -- was it when, based on what you were told, it was a conversation between -- it was a conversation in which Goodin, MS. Currie and the president were there?

    A Correct.

    BY MR. EMMICK:

    Q Let's focus a little bit about the Presidential aides. You mentioned Steve Goodin. Where are the aides at the time you are having your encounters, if we can call that, with the president?

    A Most of the time they weren't -- they weren't there. They weren't at the White House.

    Q And how was that arranged?

    A When I was working in Legislative Affairs, I don't think --I don't know if it was ever verbally spoken but it was understood between the president and myself that most of the -- most people weren't in on the weekends so there was -- it would be safer to do that then. And then after I left the White House, that was sort of always a concern that Betty and I had just because she knew and I knew that a lot of people there didn't like me.

    Q So is it fair to say then that the Presidential aides, whether they be Steve Goodin or Andrew Friendly or whoever it might be, were not around at the time?

    A Correct. They may have been but --

    Q Mm-hmm. I wonder if you could expand a little bit on the nature of your relationship with Betty and then the nature of your relationship with Nel, and specifically what we mean to ask is to what extent were these relationships genuine relationships and to what extent were they, in part, based on an interest in cultivating their friendship because of your relationship with the president?

    A I think that they -- both of them started out probably at the latter of what you said, as maybe a function of making my relationship with the President easier, or for me, I guess, getting information, but that they both came to have a very genuine component to them. I still care very deeply about Betty.

    Q When you talk about getting information, could you expand on what you mean by that?

    A I think sometimes if it was from Ms. Currie finding out what the president's schedule was, when he might be around, what might be a good time to come to talk to him to let him know something.

    With Nel, Nel and I developed a started during the furlough and I thought that he was a really nice guy and didn't get treated correctly or properly, I guess. And the kind of information, he sort of just would give me information about the president. I mean, I don't think that was the only -- that wasn't the only component of the friendship, but that was a component of it.

    Q You have discussed how Betty helped arrange for you to come visit the president, especially in 1997, I think it would be fair to say.

    A Yes.

    Q When those arrangements were made, who initiated the arrangements? How did they start off? Did you ask? Did the President ask? Did Betty ask?

    A I'd say most of the time it was probably me asking -- either asking the President directly or asking him through Betty or through sending a note of some sort. And there were occasions that he initiated, so it would come through Betty.

    Q All right. Let me ask you the following question. You have described the ways that Betty helped let you in --

    A Mm-hmm.

    Q -- facilitate the relationship, if you will. Do you think Betty Currie knew about your relationship with the president?

    A I don't know. It's possible she could have gleaned that from witnessing that the -- you know, that the President was having a relationship that caused -- with a 25 year-old woman or, at the time, younger -- you know, that made me 50 emotional. But I really can't answer that question.

    Q She saw you under circumstances where she realized you and the President had an emotional tie.

    A I believe so. I'm not really -- I'm not really comfortable sort of answering questions about what -- you know, what Betty knew because --

    Q Well, then let me focus more on what Betty was in a position to see.

    A Okay.

    Q Was Betty in a position to see that you and the president visited frequently and had a strong emotional attachment?

    A I believe so, yes.

    Q Did you ever expressly tell Betty about the relationship?

    A What aspect of the relationship?

    Q Well, let me separate it out for you.

    A Okay.

    Q Did you ever expressly tell Betty about the emotional aspect of the relationship?

    A I believe I characterized that to her.

    Q Did you ever expressly tell Betty about the sexual the relationship?

    A No, I don't believe so.

    Q Let me ask the question, why not?

    A Because it's not appropriate. I mean, I think -- I don't think people necessarily talk about these things. I mean, there is a difference between a relationship that you have with someone who is sort of involved in a situation, and then the kind of relationship you have with a friend whom you talk to. I think with -- a little bit with Betty's age and it wasn't clear to me that the -- you know, the President didn't tell her so, if he didn't tell her, why should I tell her.

    Q Let me ask similar questions about Nel. Do you think Nel knew?

    A Nel knew --

    Q About the emotional aspect of the relationship?

    A Yes, I think so.

    Q Is that based on what you told him or what you think he must have seen, or both?

    A I think probably based more on what I told him.

    Q Do you think Nel knew about the sexual aspect of the relationship?

    A We never directly discussed it, so I don't know if -- I don't know how to answer that.

    Q Did he ever say things to you that made you think that he must know about the sexual aspect of the relationship?

    A Not that I remember.

    Q You mentioned earlier, perhaps an obvious thing, that you were alone with the president on the times that you had sexual contact with the president.

    A Yes.

    Q Were there also when you were alone with the president that you did not have sexual contact with the president?

    A Mm-hmm, yes.

    Q Can you give us sort of a general description about how those encounters occurred and where they occurred?

    A Okay. There were numerous that ranged from the beginning of our relationship till the end of our relationship.

    Q Were some of them brief? Were some of them substantial in length?

    A Mm-hmm, yes.

    Q Where within the White House would those have occurred?

    A One occurred in the Oval Office and then the others occurred -- oh, that's not true. Two occurred in the Oval Office and the others were in the back study area.

    I should also just -- maybe I could just add right now that every -- that every time I had a visit with the President when I was working there -- not after, but when 1 was working there -- we usually would -- we'd start in the back and we'd talk and that was where we were physically intimate, and we'd usually end up, kind of the pillow talk of it, I guess, was sitting in the Oval Office talking. So there's --

    BY MR. WISENBERG:

    Q And, again, when you say when you started in the back, that could either be the hallway or the back?

    A Correct, yes.

    BY MR. EMMICK:

    Q I would like to ask you some questions about any steps you took to try to keep your relationship with the President secret.

    A A lot.

    Q All right. Well, why don't we just ask the question open-endedly and we'll follow up.

    A Okay. I'm sure, as everyone can imagine, that this is a kind of relationship that you keep quiet, and we both wanted to be careful being in the White House. Whenever I would visit him during -- when -- during my tenure at the White House, we always -- unless it was sort of a chance meeting on a weekend and then we ended up back in the office, we would usually plan that I would either bring papers, or one time we had actually accidentally bumped into each other in the hall and went from that way, so then we planned to do that again because that seemed to work well. But we always -- there was always some sort of a cover.

    Q When you say that you planned to bring papers, did you ever discuss with the president the fact that you would try to use that as a cover?

    A Yes.

    Q Okay. What did the two of you say in those conversations?

    A I don't remember exactly. I mean, in general, it might have been something like me saying, well, maybe once I got there kind of saying, "Oh, gee, here are your letters," wink, wink, wink, and him saying, "Okay, that's good," or --

    Q And as part of this concealment, if you will, did you carry around papers when you went to the visit the President while you worked at Legislative Affairs?

    A Yes, I did.

    Q Did you ever actually bring him papers to sign as part of business?

    A No.

    Q Did you actually bring him papers at all?

    A Yes.

    Q All right. And tell us a little about that.

    A It varied. Sometimes it was just actual-copies of letters. One time I wrote a really stupid poem. Sometimes I put gifts in the folder which I brought.

    Q And even on those occasions, was there a legitimate business purpose to that?

    A No.

    Q Did you have any discussions with the President about what you would say about your frequent visits with him after you had left Legislative Affairs?

    A Yes.

    Q Yes. What was that about?

    A I think we -- we discussed backwards route of it was that Betty that -- you know, the always needed to be the one to clear me in so that, you know, I could always say I was coming to see Betty.

    Q And is there some truth in the notion that you were coming to see Betty?

    A Coming to see Betty, I don't know. Did I -- I saw Betty on every time that I was there.

    Q What was your purpose though in going --

    A My purpose was -- most of the time my purpose was to see the president, but there were some times when I did just go see Betty but the president wasn't in the office.

    Q When the president was in the office, was your purpose in going there to see the president?

    A Yes.

    Q What about the writing of things down on paper? Was there any discussion between you and the president about the risks of writing things down and whether you should write things down?

    A Yes.

    Q All right. Tell us about that.

    A There were on some occasions when I sent him cards or notes that I wrote things that he deemed too personal to put on paper just in case something ever happened, if it got lost getting there or someone else opened it. So there were several times when he remarked to me, you know, you shouldn't put that on paper.

    Q We'll have occasion to get into some details about that in a bit. I don't know how to ask this question more delicately, so I'll just ask you. Did you take any steps to try to be careful with how loud you might be in sexual matters?

    A Yes.

    Q All right. Can you tell us, as discreetly as you can and as -- about that?

    A I think we were both aware of the volume and sometimes I'd use my hand -- I bit my hand -- so that I wouldn't make any noise.

    Q All right, that's fine. Let me ask another question. Did you try to take -- are you okay?

    A Yeah, this is just embarrassing.

    Q Did you try to take different routes in and out of the Oval Office area as part of your way of concealing the relationship?

    A Yes, I did.

    Q Could you tell us about that?

    A I made an effort on my own to go out a different door than the door that I came in so that if there was a guard that was on duty in the front of the Oval Office he might see me going in but a different guard would see me leave, so no one would know exactly how long I had been in there.

    Q Did you try to do that most of the time, all of the time?

    A I'd say 90 percent of the time. I mean, I can't really recall a time that I didn't do that, but it's possible. That was the pattern.

    Q Were there some people that you tried to specifically avoid when you were visiting with the president?

    A Yes.

    Q All right. Who were they, please?

    A Pretty much everybody but Betty.

    Q Okay. What about, for example, Nancy Hernreich?

    A Yes.

    Q All right. And how would you take steps to avoid Nancy Hernreich?

    A Generally, coming in on the weekend. This is after I left?

    Q Yes.

    A Okay. After I left the White House it was coming in on the weekend or sometimes we -- I tried to see him but I don't think it actually ever occurred on Tuesday nights because Ms. Hernreich has yoga, I think -- I believe.

    BY MR. WISENBERG:

    Q Who told you that she had yoga?

    A Ms. Currie.

    BY MR. EMMICK:

    Q Any discussion with the president about trying to make sure that there are fewer people around when you were to visit?

    A When I worked in Legislative Affairs, I think that was sort of the understanding that the weekend was the -- there weren't a lot of people around. And there were times - when I think that the president might have said, oh, there are too many people here because there was some big issue or some big event happening maybe.

    Q Were there any occasions when you tried to make . arrangements to see the President but for some reason or another Betty was not in a position to let you in?

    A Sure, I think so.

    Q Any occasions when you had actually planned to visit and then for some reason or another she wasn't there, that you remember?

    A No, not that I remember.

    Q What about throwing away notes that you had written to the president? Was there any discussion of throwing out the notes or any notations that you would write on the notes to remind him to throw them out?

    A Yes, I think that I may have had a discussion with the president about him throwing things away, I think, or making sure that they're not there. I know one specific occasion in one of the notes that I sent him I made a joke that really was reminding him not to --to make sure he threw the -- make sure he threw it away.

    Q I've asked you a number of questions having to do with how you tried to keep the relationship secret. Let me ask, did you tell some people about the relationship?

    A Unfortunately, yes.

    Q All right. Could you tell us some of the people that you've told about the relationship?

    A Linda Tripp, Catherine Davis, Neysa Erbland, Dale Young, Ashley Raines, and my mom and my aunt. Everybody knew a different amount of -- had a different amount of information.

    Q Natalie Ungvari?

    A Oh, Natalie Ungvari, yes.

    Q Did you tell any of your -- any counselors or therapists of any kind about your relationship?

    A Yes, I did.

    Q All right. Would you tell us who they would be?

    A Dr. Irene Kassorla, and I believe it's Dr. Kathy Estep.

    Q When you talked about your relationship with the president with these people, did you lie about your relationship?

    A No. I may have not told them every detail, but I don't believe I ever lied. Oh, about the -- oh, wait, do you mean the doctors or was that in general?

    Q I meant in general.

    A Well, there were -- about my relationships -- I'm sorry, could you be more specific?

    Q Sure. You listed a number of people that you had told about your relationship with the president.

    A Right.

    Q I'm just trying to figure out if you told the truth to those people when you described the relationship.

    A Yes. There were some occasions when I wasn't . . truthful about certain things, but not having to do with, I think, the general relationship. Does that make sense?

    Q Expand on that just a little. I'm just not sure.

    A Well, I think with Linda Tripp, I mean there were times that I was not truthful with her. I mean, I didn't know if that's what you were encompassing by saying relationship or not.

    Q Let's put Linda Tripp aside for a bit because I think I know what you have in mind.

    A Right.

    Q Put Linda Tripp aside for a bit. Were you truthful with the others about your description of the relationship?

    A Yes.

    Q And since you mentioned Linda Tripp, were there occasions toward the end of, I guess it would be December or January, when you said some things to Linda Tripp that were not true?

    A Yes.

    Q All right. We'll have a chance to get to that in a bit.

    A Okay.

    Q What I would like to turn to next is the -- is April of 1996 and your transfer from the White House to the Department of Defense. When were you first told about the fact that you were being terminated from Legislative Affairs?

    A On the 5th -- 1 think it was the 5th of April, Friday.

    Q Did you later have a telephone conversation with the president about your being terminated?

    A Yes, I did.

    Q When was that?

    A On the 7th, on Easter.

    Q Easter Sunday, April 7th of 1996?

    A Correct.

    Q Would you tell us first what your reaction was when you were told that you were going to be terminated from Legislative Affairs?

    A My initial reaction was that I was never going to see the president again. I mean, my relationship with him would be over.

    Q You did not want to go to the Pentagon?

    A No.

    Q When you spoke with the president on April 7th, did you call him or did he call you?

    A He called me.

    Q Would you tell us how that telephone conversation -proceeded and then we'll talk about the meeting.

    A Okay. I had asked him how -- if he was doing okay with Ron Brown's death, and then after we talked about that for a little bit I told him that my last day was Monday. And he was -- he seemed really upset and sort of asked me to tell him what had happened. So I did and I was crying and I asked him if I could come see him, and he said that that was fine.

    Q Did you go over to the White House?

    A Yes, I did.

    Q About what time of day, if you remember?

    A I think it was around 6:00 p.m.

    Q Who let you in?

    A I had a pass at the time.

    Q How long did you visit with the president that day?

    A Maybe a half an hour. I'm not very good with the time estimates.

    Q You've already had occasion to talk a little bit about the sexual aspect of your encounter with the president at that time and the phone call that you -- that came in in the midst. I'm not going to ask you about that. What I am going to ask you about instead was your discussions with the president about the termination and about what the future would hold for you.

    A He told me that he thought that my being transferred had something to do with him and that he was upset. He said, "Why do they have to take you away from me? I trust you." And then he told me --he looked at me and he said, "I promise you if I win in November I'll bring you back like that."

    Q How were things left at the end of that meeting?

    A I sort of ran out.

    Q Right. I guess what I mean by that -- I'm sorry, I didn't mean to be that specific.

    A Okay.

    Q At the end of the meeting, were you going to go to the Pentagon?

    A Well, he was going to see what he could do.

    Q I see. All right.

    A He said he'd try to see. He said he was going to ask -- try to find out what had happened. And I told him that I was going to be meeting with Ms. Hernreich the next day and he sort of said, "Let me see what I can do."

    Q Did you later have a telephone call with the president where you discussed what he had learned?

    A Yes.

    Q When was that?

    A The following Friday.

    Q That would have been then April 12th?

    A Yes, I think so.

    Q Did he call you or did you call him?

    A He called me.

    Q Where were you?

    A I was at home.

    Q How long was the telephone conversation?

    A Maybe about 20 minutes.

    Q Tell us what the two of you talked about.

    A He told me that he had asked Nancy and Marsha Scott to find out why I had been transferred, and that what he had come to learn was that Evelyn Lieberman had sort of spearheaded the transfer, and that she thought he was paying too much attention to me and I was paying too much attention to him and that she didn't necessarily care what happened after the election but everyone needed to be careful before the election.

    Q Did he offer any of his views about what you should do with respect to this Pentagon job?

    A He told me that I should try it out and if I didn't like it that he would get me a job on the campaign.

    Q What was your reaction to that?

    A I think I was disappointed. I didn't want to go to the Pentagon and I didn't really see what the difference on the campaign was going to be -- why I couldn't work -- if I could work at the campaign why I couldn't work at the White House. So --

    Q Did you start working at the Pentagon?

    A Yes.

    Q What position did you hold when you worked at the Pentagon?

    A Confidential Assistant to Ken Bacon, who is the Pentagon spokesman.

    Q Let's talk generally, if you will, about what sort of contact you had with the president during the rest of 1996. Did you see him in person?

    Q Just a bit more detail so that we can get a sense 786 --

    A Yes, I did.

    Q Okay. Did you see him in person very often?

    A No. I wasn't alone with him so when I saw him it was in some sort of event or group setting.

    Q Did you continue to have telephone contact with him?

    A Yes.

    Q And those telephone contacts are set out in the chart that we've put together --

    A Mm-hmm.

    Q -- with your assistance?

    A I guess. Yes. I'm sorry.

    Q Let's then just turn to the first part of 1997. The election is over. Did you talk with the president about getting you back to the White House?

    A Yes.

    Q All right. Would you tell us about-that?

    A I believe the first time I might have mentioned it to him was in January of '97 in a phone conversation, and he told me that he would talk to Bob Nash, who is the head of White House or presidential Personnel, I think it is, about bringing me back. In the next phone call he said he had spoken to Bob Nash and then -- do you want me to go as far as...

    Q Just a bit more detail so we can get a sense of what efforts you thought were being taken and whether you came to be disappointed with those efforts.

    A Very disappointed. He -- my understanding at first was that the ball had sort of been passed to Bob Nash to bring me -- to find a position for me to come back to the White House. I then came to learn maybe in March or so that the ball had been passed from Bob Nash to Marsha Scott. And then Marsha Scott was supposed to help me find a position at the White House, which didn't work out, then she was going to detail me to her office in the White House and then she later rescinded that offer. Keep going?

    Q Were you frustrated with all that?

    A Very frustrated.

    Q And did you communicate your frustration to the president?

    A Yes, I did.

    Q Tell us about how you communicated your frustration to the president.

    A There were various occasions, different things that happened. Sometimes it was in our phone conversations, sometimes it was in a letter, sometimes it was in person.

    Q Let me direct your attention to July 3rd of 1997. Did you cause some sort of a communication to be made to the president on that day?

    A Yes.

    Q Tell us about that.

    A I had been trying to get in touch with him maybe since the latter part of June to discuss some of my meetings with Marsha Scott that had not gone as I had hoped they would and -- excuse me -- the president wasn't responding to me and wasn't returning my calls and wasn't responding to my notes. And I got very upset so I sat down that morning actually and scribbled out a long letter to him that talked about my frustrations and that he had promised to bring me back; if he wasn't going to bring me back that I -- you know, then could be help me find a job -- at that point I said in New York at the United Nations, and that I sort of dangled in front of him to remind him that if I wasn't coming back to the White House I was going to need to explain to my parents exactly why that wasn't happening.

    Q And what was your purpose in sending a letter of that kind to the president?

    A I think it was sort of had a few purposes, in that towards the end of the letter I softened up again and was back to my mushy self, but the purpose was -- one of the purposes, I think, was to kind of remind him that I had left the White House like a good girl in April of '96. A lot of other people might have made a really big stink and said that they weren't going to lose their job and they didn't want to do that and would have talked about what kind of relationship they had with the president so they didn't lose their job, and that I had been patient and had waited and that all of this had gone on. So I was frustrated.

    Q Did you -- how did you get this letter to the president?

    A I gave it to Ms. Currie.

    Q Did you meet with the president on the 3rd of July?

    A Mm-hmm. Yes, I'm sorry.

    Q Did you meet with the president on the 4th of July?

    A Yes, I did.

    Q Would you tell us how that was arranged?

    A I spoke with Ms. Currie later that afternoon on the 3rd and she told me to come to the White House at 9 o'clock the next morning.

    Q You showed up at the White House?

    A (Nodding)

    Q What I would like to do with respect to this meeting is just ask you to give a very general description of the meeting, whether it was emotional.

    A It was very emotional.

    Q I don't want to focus on the emotional aspect of that meeting. What I want to do is focus on the end of the meeting.

    A Okay.

    Q And whether or not you said anything to the president about Kathleen Willey.

    A Yes, I did.

    Q Can you tell us what happened in that conversation?

    A Can I jump back a little to how I got the information or do you want me to just stick to what I told him?

    Q Sure, why don't you. Okay, jump back to how you got the information and then we'll plug it in.

    A Just so everyone understands. I believe it was in February or March of that year when I was friends with Linda, she had frantically come to me telling me that this reporter whom I had never heard of before that day, Michael Isikoff, had shown up in her office to question her about Kathleen Willey, who was this woman that you all know now but who was this woman who had -- that Linda had worked with in the White House and that I guess this woman had told Michael Isikoff that the president had sexually harassed her and that Linda would corroborate that fact. And Linda was -- she had said to me that she was nervous and she responded that no -- I think she had sort of tried to lead Michael Isikoff away from the fact that it had been sexual harassment but, at the same time, had sort of confirmed to Michael Isikoff that something might have happened there.

    I'm sorry, I'm going too long.

    Q It's all right.

    A Throughout the next couple months I had encouraged Linda to get in touch with someone at the White House to let them know that this was out here. Being a political appointee, I thought that was something that should be done.

    Q Who at the White House did you encourage her to contact?

    A Well, she said she would feel comfortable either getting in contact with Nancy Hernreich or Bruce Lindsey from her experiences at the White House. And I don't really remember how it came to be Bruce Lindsey but that -- I don't remember who encouraged what. She contacted Bruce, or she told me she contacted Bruce Lindsey and that Mr. Lindsey did not return her phone call or answer her page.

    Q So jumping forward to July --

    A Right.

    Q -- what were you trying to convey to the president and what did you say to him?

    A Just let me add that I think right -- at some point before July 4th, soon before July 4th, Michael Isikoff had again contacted Linda and so the story was sort of bubbling this was going on and that this woman was going to be another Paula Jones and he didn't really need that. So --

    Q This is another grand juror who has just walked in

    A Okay.

    Q So that you know.

    A Thanks. So I wanted to inform the president about what he should sort of be aware of. And at the end of our meeting -- it had been a really emotional meeting -- I told him that I wanted to talk to him about something serious and that while I didn't want to be the one to talk about this with him, I thought it was important he know.

    And I told him that a woman whom I was friendly with at the Pentagon had been approached by Michael Isikoff and sort of informed her that Kathleen Willey was claiming -- I know I didn't use the term sexually harassed because I would have felt uncomfortable saying that to the president, so I think I said something or another that indicated what Kathleen Willey was claiming, and that this woman had known Kathleen Willey when she worked at the White House and she -- I think I may have indicated that she had -- did not corroborate Kathleen Willey's story.

    Q Did you identify Ms. Tripp by name?

    A No, I did not.

    Q Did the president ask who it was you were referring to?

    A No, he did not.

    Q Continue. I think you were --

    A At that point -- I don't know if it was at that point in the conversation, then the president informed me that Kathleen Willey had actually called Nancy Hernreich during the week earlier and had said -- excuse me, sorry -- and had said that this reporter was chasing after her trying to find out her relationship with the president. And so to me, what that meant was that when -- I thought that meant that when Kathleen found out Linda wasn't going to corroborate her story that she was trying to cover her tracks with the White House so that they wouldn't then find out or think that she was trying to encourage Michael Isikoff. So I thought everything was over with and I later told that to Linda.

    Q Why did you want to say anything to the president at all about that? What did you think the president might do to respond?

    A I thought he -- I thought maybe, you know, my understanding from Linda was that Kathleen had been trying to get a job, and I could certainly understand the frustrations of being told someone is going to help you get a job and then you don't. And I thought at that point -- I didn't know too many details about what was going on. I don't think she was in the Paula Jones case and I thought, well, gee, maybe if you know someone who needs -- who would want to hire her you can make this go away for -- that's how I thought of it. Then I thought maybe there was something he could do to fix it or someone else could do to fix it, or just be aware of it.

    Q He might get her a job, for example?

    A He might. I mean, I think that was one of the things that crossed my mind.

    Q At that time, did the president ask you whether you had disclosed anything about your relationship to anyone else?

    A Not at that time.

    Q Did he at some other time?

    A Yes, he did.

    Q When was that?

    A I think there might have been several times throughout the relationship, but he specifically asked me about Linda Tripp on July 14th.

    Q All right. Then we'll get to that in just a moment.

    A Okay.

    Q At the beginning of the meeting with the president on July 4th, you had sent him a letter in which you said that you were considering telling your parents. Did he ever say anything to you about, you know, you shouldn't be threatening the president, or something like that?

    A Yes. Our meeting started out with a fight, so he sat down and we sat down and he lectured me and, you know, "First of all, it's illegal to threaten the President of the United States and, second of all --" I mean, it was just -- and then I started crying so --

    Q All right, fine. After the meeting on July 4th concluded, did you leave the country?

    A Yes.

    Q All right. Where did you go?

    A I think a few days after that. I went to Madrid.

    Q When did you return, as best you can remember?

    A On the 14th of July.

    Q All right. Then let's turn our attention to the 14th of July. You got back from overseas. Did you get a call from Betty?

    A Yes, I did.

    Q Tell us about that.

    A She called around -- I think it might have been around 7:30 -- I was already in bed because of jet lag and everything -- and told me that she thought the president either wanted to talk to me or see me later, and that I believe he was going out golfing at the time, and that she'd call me back later to let me know what was going to happen. And she did. She called back maybe around 8:30 or so, 8:30, 9 o'clock, and asked me to come over to the White House. So I did.

    Q When you got to the White House, did you see the president?

    A Yes, I did.

    Q Could you tell us how that meeting went?

    A It was an unusual meeting, I mean, first because we -- he met me in Betty's office and we went into Nancy Hernreich's office, which is adjacent to Ms. Currie's office, and sat on the sofa and talked. It was very distant and very cold. And he asked me if the --I don't remember the sequence of things necessarily, but at one point he asked me if the woman that I had mentioned on July 4th was Linda Tripp. And I hesitated and then answered yes, and he talked about that there was some issue with -- this had to do with Kathleen Willey and that, as he called it, that there was something on the sludge report, that there had been some information.

    And what his main concern seemed to be was that Kathleen Willey had called Nancy again that week and was upset because Michael Isikoff had told her that he knew she had called the White House saying he was pursuing her and her story. Is that clear?

    A JUROR: No.

    A Okay. Kathleen had called Nancy, and the president had told me that Kathleen had called Nancy. This was on July 4th. And then that following week when I was in Madrid, I believe -- I know I was in Madrid, I think it was that following week -- Kathleen called Nancy again. And Kathleen was upset because Michael Isikoff had told Kathleen that he knew that she had called Nancy the previous week.

    Does that make a little more sense?

    A JUROR: Yes, thank you.

    A So what the president's concern was that the only people who knew that Kathleen had called Nancy originally were Nancy, Bruce Lindsey, the president and myself, and Kathleen. So he was concerned and had asked me if I had told Linda the information he had shared with me, and I had said yes, I did because I thought that meant it was over, that Kathleen was trying to backtrack.

    So that alarmed me because, obviously, someone had told Michael Isikoff. And he was concerned about Linda, and I reassured him. He asked me if I trusted her, and I said yes. And he -- we had talked about -- oh, I had -- I'm sorry, I'm sorry. On July 4th I had mentioned that -- to the president that this woman had tried to contact Bruce Lindsey and that Bruce Lindsey didn't return her phone call.

    So on July 14th, the president asked me if I thought Linda would call Bruce Lindsey again, and I told him that she is a really proud woman and that she was really offended that he didn't call her back and it was -- so I didn't think she would. And he asked me if I would just try to see if she would call, and so I said I would try.

    BY MR. EMMICK:

    Q Did he ask you whether you had told anything to Linda about your relationship with the president?

    A Yes, he did.

    Q All right. Tell us about that.

    A He asked me just that, and I said no.

    Q Where was this conversation taking place with the president?

    A In Nancy Hernreich's office.

    Q Did there come a time when he left to take a conference call?

    A Yes, he did.

    Q All right. Did you know who the conference call was with?

    A That's a little murky for me. I believe it might have been with his attorneys, but I don't remember how I know that. So it's possible it was with his attorneys.

    BY MR. WISENBERG:

    Q How would you know it? I mean, how would you know it?

    A I don't know. That's just what sounds -- that's what came to my mind when I was recalling the event. And I don't recall how I knew that so I don't know if maybe that's just how I'm recalling it or that I knew it and I don't remember who told me.

    Q Was there anybody there to tell you he was talking to his attorneys other than him that day?

    A It could have been Betty. I sat with Betty when -- in her office when he was on the conference call in the Oval Office or in the back. I don't know where he was, actually.

    BY MR. EMMICK:

    Q Other than the president asking you to get a hold of Linda and have Linda call Bruce Lindsey, how were things left at the end of the meeting?

    A He asked me to let Betty know the following day without getting into details with her, even mentioning names with her, if I had, you know, kind of mission accomplished sort of thing with Linda.

    Q And did you?

    A Yes, I got in touch with Betty the next day and I told her that I needed to talk to the president having to do with what he had asked me.

    Q And did you follow up with that?

    A Yes, he called me that evening.

    Q Okay. And what did the two of you talk about?

    A We discussed the -- I guess that I had tried to talk to Linda and that she didn't seem very receptive to trying to get in touch with Bruce Lindsey again, but that I would continue to try. And I think I just gave him some more -- I think I gave him maybe the background information about what I knew when Linda worked there and gave him, I think, a fuller version of whatever it was I knew about this situation.

    EMMICK: I'm prepared to move on. Is this an appropriate time for another break?

    FOREPERSON: Most appropriate.

    EMMICK: Okay. Good timing.

    WITNESS: Me, too. Too much water.

    IMMERGUT: Ten minutes?

    EMMICK: Let's just take ten minutes.

    FOREPERSON: Ten minutes, please.

    (WITNESS EXCUSED. WITNESS RECALLED.)

    WITNESS: So where are we?

    EMMICK: In fact, I'll even walk up and show you where we are, but first we have to clarify that there are no unauthorized persons present and we have a quorum.

    FOREPERSON: That's correct. And I need to remind you that you're still under oath.

    WITNESS: Thanks.

    BY MR. EMMICK:

    Q Just to make some reference here, we are here at the end of July, but there are some questions. I'm going to circle back to April 7th.

    A Okay.

    Q We're going to ask. some more detail on April 7th and we're going to talk a little bit about a call that you had from the President in -- I think it is April of '97 about some conversations that --

    A Okay.

    Q A call in that time period.

    A Okay.

    Q There were also some -- let's call them sort of a laundry list of follow-up questions.

    A Okay.

    Q So we'll focus there and a little bit on the 14th and a little bit on that phone call.

    A I thought I -- I also might just say that if, as happened before, if I'm saying something and I'm - not clear, I'm not understanding, just let me know, because I do that a lot.

    BY MR. EMMICK:

    Q All right. Let's start off with some questions. -. First, let's focus on July 14th because the President wanted you to have Linda contact Lindsey. Why wouldn't Lindsey just contact Linda? Was there any discussion of that? -Why did it have to go one way rather than the other way?

    A I don't believe there was a discussion about it. I have my own thoughts on it, but there wasn't a discussion about it.

    Q What were your own thoughts on it?

    A That it would just -- I -- I think I sort of thought that it would probably be more proper -- not in a chain of command, necessarily, but -- it just seemed more appropriate for Linda to call Bruce Lindsey.

    Q Did it look -- do you think it would have looked inappropriate for Lindsey to contact Tripp?

    A I think it would have been awkward because I think -- how would -- you know, how would Bruce Lindsey have known to call -- you know, to call Linda at that point? If -- you know, the President thought at that point that -- you know, that Linda didn't know anything, so if Linda didn't know anything, then how -- wouldn't it be odd for Bruce Lindsey to just call her back out of the blue?

    Q Okay.

    A I mean, that was sort of how I thought of it.

    Q But in either event, there wasn't any actual discussion about the strategy behind who would have to call . . whom?

    A Not that I remember. No.

    BY MR. WISENBERG:

    Q Well, did you say to him anything like, "Hey, she tried to call him before."

    A Right.

    Q "She isn't going to anything like that?

    A Yes. I think I had a3 call him this time." I mean, mentioned that before. I mean, that might have been -- you know, I think was sort of -- he was saying, "Well, just try to see."

    Q Let me approach the question in just a little bit different way. When you talked to Linda and tried to convince Linda to talk to Bruce Lindsey, what did you say to her to try to convince her to talk to what I mean? her? Do you understand what I mean?

    A Right. Well, I didn't tell Linda that -- and this was unusual, I didn't tell Linda that I had seen the President on the 14th of July because I was somewhat wary of her, having learned that someone had told Michael Isikoff, and I knew it wasn't me, so sort of assuming that Linda had talked to Michael Isikoff and not really knowing where she was coming from on this, so I just kept encouraging her to call Bruce Lindsey again, that this was heating up more and you really should call Bruce Lindsey.

    Q All right. Let me go to another question. You made a reference earlier to the fact that you felt that Nel hadn't been treated well or hadn't been treated respectfully. Could you tell us what you meant by that?

    A People in the White House -- I mean, Nel is stationed in the pantry, which is right -- I mean, which is even a part of the Oval Office area and he's always there and he takes very good care of the President and people just walk right past him, they don't say hi to him, a lot of people don't acknowledge him.

    And they just -- you know, they kind of come to him when they need something, but aren't -- and I just -- I don't think people should be treated like that. I mean, I think anybody who -- and especially everyone who is working at the White House and who works --I've always categorized people as people who are there to serve the President and people who are there to serve themselves through the President and I think Nel has a lot of loyalty to the President.

    Q Would it be fair to say that it's no so much that they were affirmatively mistreating him, but they were treating him as a non-person almost? Or is that --

    A I think that's a mistreatment.

    Q Yes. That's a mistreatment. Okay. That's a fair characterization.

    A In my opinion.

    Q We had talked earlier about certain people that you wanted to avoid in order to help keep the relationship secret and you talked about Nancy Hernreich as being one of those people. Can you tell us what other people you wanted to sort of avoid in that same vein?

    A Stephen Goodin. Let's see. I guess it's different from when I was at the White House to after. When I was there, Evelyn Lieberman, Harold Ickes, anybody who knew who I was, certainly. And after I left, I think it was mainly anybody who knew me from before. So --

    Q All right.

    A Does that -- does that answer it?

    Q If that's the answer, then that's the best we can do.

    A Okay.

    Q We talked earlier about February 28th and about Steve Goodin going into the Oval Office with Betty and what you learned about that conversation they had.

    A Mm-hmm.

    Q The question is this: why would Steve Goodin, who is after all just a presidential aide, why would he be in a position to be able to tell the President, "You can't be with Monica Lewinsky alone"?

    A I don't know. And that was a question that I -- that I posed -- 1 don't think I posed it as a question, but I sort of made a comment, you know, who is -- and then -- I don't remember if it was to Betty or to Nel, you know, why he would always sort of -- what's the word I'm looking for? would -- you know, how inappropriate that was.

    Q Right.

    A And maybe Stephen made the comment to Betty. Maybe just Betty. I -- I -- I -- you know, I wasn't in the room, so I don't know what the course of the conversation was. Maybe Stephen said it to Betty and Betty told the President that Stephen had said that to Betty. So I'm not sure, but I thought it was inappropriate, too.

    Q Any other follow-up on that?

    A JUROR: I think a point be is that did he feel that he had the authority do so because someone else was encouraging him to monitor that sort of activity, such as Evelyn Lieberman, for example?

    A That's a good thought. I don't know. I don't have any knowledge of that. I never thought of that.

    BY MR. EMMICK:

    Q You mentioned that during 1997 especially you frequently complained to the President that although he said he could bring you back (snapping finger) like that, it wasn't happening. How did the President respond when you complained about these things?

    A You know, I mean, it was the -- "Bob Nash is handling it," "Marsha's going to handle it" and "We just sort of need to be careful." You know, and, "Oh, I'll -- " he would always sort of --what's the word I'm looking for? Kind of validate what I was feeling by telling me something that I don't necessarily know is true. "Oh, I'll talk to her," "I'll -- you know, I'll see blah, blah, blah," and it was just "I'll do," "I'll do," "I'll do." And didn't, didn't, didn't.

    Q All right. You mentioned that in that July 3rd letter that you sent to the President through Betty you made a reference to the fact that you might have to explain things to your parents. What did you mean by that?

    A If I was going to pick up and move from Washington -- first of all, I had told my -- well, my mom knew, you know, that I was having some sort of a relationship with the President. My dad had no idea. And I had told my dad that was I -- you know, I was told I could probably come back to the White House after the election, as Tim Keating had told me. And the President. So I had sort of told him that course and I would -- have needed to explain to them why I was going to pick up and move to New York without -- what the point would be.

    Q Were you meaning to threaten the President that you were going to tell, for example, your father about the sexual relationship with the President?

    A Yes and no. I don't think I -- I know that I never would have done that. I think it was more -- the way I felt was, you know, you should remember that I sort of -- I've been a good girl up until now.

    I mean, I kind of have -- that I think I tended to -- I know that I thought he tended to forget what I had gone through already and that -- and so that this wasn't an issue of, well, you know, "We can do this in a little while, this is maybe changing your job while you're in the White House," you know, if I had wanted to maybe do something different, it was a lot more significant. And I felt that he was giving me the runaround a bit, too.

    Q Is it fair to say that it was in part an implied threat?

    A Yes, but I think -- but I think if you want to look at it that way, it was a threat to him as a man and not a threat to him as president. Does that -- I mean --

    Q What do you mean?

    A Well, I think when I hear you say, you know, "Was that an implied threat" that that letter being sent to any man who is having an illicit relationship with someone would be a threat, and so it was irrelevant, the fact that he was president.

    Q I see.

    A So just because we had talked earlier about it and then that was what had upset me, when the President said, "It's illegal to threaten the President of the United States."

    Q Right.

    A And I just thought, you know, "I don't deal with you like the President, I deal with you as a person."

    EMMICK: All right.

    WISENBERG: Can I ask something about that?

    EMMICK: Yes.

    BY MR. WISENBERG:

    Q But you had said your mother by that time knew there was some of kind of a relationship.

    A Right. He didn't know that, though.

    Q But you hadn't told -- he didn't know that.

    A I never told him that. No.

    BY MR. EMMICK:

    Q A question about lipstick and tissues.

    A Okay.

    Q You mentioned that a couple of times you used tissues to wipe lipstick off. Do you remember where you threw those tissues away and did it occur to you that somebody might see those tissues later and therefore might think of it as somehow evidencing the relationship?

    A No, really the only -- the one time that

    I specifically remember doing that was on January 7th of '96. And -- no, I don't think that -- I mean, I had light lipstick on so I don't -- I think if it had been a darker colored lipstick that maybe I would have been concerned, I might have thought about that, but that didn't cross my mind. I don't think people go through the trash.

    Q Right.

    A I hope not.

    Q Do you recall where you through that tissue away on that occasion?

    A It was in the bathroom. I think there's a wastebasket right next to the sink.

    Q All right. A question going back to the '96 period, because you had mentioned that on February 19th of '96 the President told you essentially we should break up, we shouldn't have any more of a sexual relationship, yet five or six weeks later, there was a continuation of the sexual relationship. How does that happen? How does it get broken off and then rekindled?

    A Well, there continued to sort of be this flirtation that was -- when we'd see each other. And then one night, I -- don't -- I think it was maybe in the end of -- the end of February or maybe some time in March when he had -- I had seen him in the hall when I was leaving to go from work, and this was the night he was coming back from the Israeli embassy from something, and we didn't make any contact or anything because he was with Evelyn Lieberman. And I went home.

    About 45 minutes later, he called me and had told he had gone back to his office and had called my office because he wanted me to come over and visit with him, but I was home now, you know, and then he had gone back upstairs.

    So that had sort of implied to me that he was interested in starting up again and then when I saw him on the 31st of March -- when he kissed me, that pretty much --

    Q Just, basically, people got back together.

    A Yeah. There was never a discussion of, "Okay, now we're going to resume our relationship again." I didn't want to -- why bring up the memory of the guilt? So --

    Q Okay. Then what I'd like to do next is turn our attention back to April 7th, which is the Easter Sunday, and we're going to ask some more detailed questions about that period. First, when you got to the White House, did you see a Secret Service agent and did the two of you talk?

    A Yes.

    Q All right. Tell us who it was and what the two of you said to one another.

    A It was John Muskett, I believe. And I had brought some papers with me from home and so I believe I said something, "Oh, the President asked me to bring these to him." And John Muskett said, "Oh, I'd better check with Evelyn Lieberman." And I don't remember exactly what the rest of the exchange was, but I talked him out of doing that and then I just went in.

    Q Were you nervous when he said, "I've got to talk to Evelyn Lieberman"?

    A Oh, yeah. Yes. Also, it alarmed me that she was there. I didn't really expect her to be there on a Sunday evening.

    Q You mentioned that a telephone call came in while you were with the President. Did you later come to believe you knew who that call was from?

    A I made a speculation about who that call was from. I have no knowledge nor had no knowledge about who was on the phone call.

    Q Let's take this a step at a time, then.

    A Okay.

    Q First, what do you remember about the content of the call and then what was the reason that you drew conclusion you did later?

    A The content was political in nature-and I whatever drew, you -- know, the possibility that it was Dick Morris just based on -- that it was campaign stuff. And I think that how it even came up that it could possibly be Dick Morris was in a joking way with Linda on the phone.

    So I don't believe that I ever -- I don't think I would have ever categorically stated that it was Dick Morris on the phone, because I didn't know that.

    Q All right. About how long after April 7th did you draw the conclusion or develop the suspicion perhaps that it was Dick Morris?

    A I don't remember.

    Q Okay. All right. At some point, did you hear a voice that you believed to be Harold Ickes' voice?

    A Yes.

    Q Okay. Tell us how that happened.

    A The President and I were in -- I believe it was the back study or the study and -- or we might have been in the hallway, I don't really remember, but I -- Harold Ickes has a very distinct voice and so he -- I heard him holler "Mr. President," and the President looked at me and I looked at him and he jetted out into the Oval Office and I panicked and didn't know that -- I thought that maybe because Harold was so close with the President that they might just wander leave. So I went out the back way.

    Q When you say you went out the back way --

    A Through the dining room.

    Q Where did you go?

    A I went through the dining room exit, to the left, past the Chief of Staff's office, to the right, down the stairs.

    Q Were you in a hurry?

    A Yes.

    Q All right. At some point afterwards, did you get a call from the President?

    A Yes.

    Q All right. And what happened in that phone call?

    A He asked me why I left, so I told him that I didn't know if he was going to be coming back and so he -- he was a little upset with me that I left.

    Q All right. Before we move off that particular call, are there any follow-up questions that you have? Yes?

    WISENBERG: Yes. Yes. And I'll try to be delicate. I'm not known for delicacy.

    A I can see that everyone seems to agree with that.

    BY MR. WISENBERG:

    Q First of all, Ms. Lewinsky, when you went out the dining room, did you go out through Nel's pantry door or through the main dining room door?

    A I would have gone out the dining room door.

    Q Okay. I want to make sure that I get the sequence right, because this is partly based on stuff we discussed Monday in New York and you correct me if I get anything wrong.

    A Okay.

    Q We'll do it that way. As I understand it, there is a --you're back with the President that day and let me ask first if you recall, the more intimate sexual moments that day, were they in the hallway or the back study?

    A Both.

    Q Okay. Now, as I understand it, you're with the President. It's an intimate moment. A call comes in.

    A Correct.

    Q All right. And the President leaves.

    A Mm-hmm.

    Q You put your top back on. Your top had been off and you put your top back on.

    A Mm-hmm.

    Q And at some point he comes back. Is that correct?

    A Mm-hmm.

    Q Okay. And what I'm trying to do is distinguish between the Ickes event and the call, if there is a distinction in your mind. In other words...

    A Yes.

    Q The call is something different, as far as you know, from the Ickes event.

    A Correct.

    Q Okay. The President comes back and it's at some point later that you hear the voice of Harold Ickes.

    A I'm sorry --

    Q The President comes back from the phone call that he takes --

    A No. The -- someone came in to tell the President he had a phone call, so someone came in, hollered something, not Mr. Ickes.

    Q Okay.

    A The President went out, came back in and I think then they sent the phone call in.

    Q All right. He took that in --

    A He took the phone call in the back study.

    Q Okay.

    A Then we were -- and I think we had been in the hallway -- I know we had been in the hallway prior to that.

    Q Okay.

    A And he came back in and then the phone rang and he took the phone call in the back study.

    Q Okay.

    A Then it was much later in that same-day that he heard the "Mr. President" voice.

    Q Of Ickes.

    A Right. And I'm going to -- I think that we were in the back study at that point because that's why he jetted so quickly, not wanting Harold, I think, to walk back there. That was --

    Q Okay. Now, the voice you heard saying to the President that he had a call --

    A Mm-hmm.

    Q You never saw the President attached to that voice.

    A No. And it wasn't a voice that was familiar to me.

    Q Okay. And you never saw Ickes. Is that correct? When you later heard his voice, you didn't see him. You're just familiar with his voice.

    A Correct.

    Q As far as you know, did Ickes see you when you headed out the back way?

    A He couldn't have.

    Q Okay. Why do you say that?

    A Because he was in the office.

    Q Okay. And you said that Ickes was much later. I mean, much later within the whole time you were there with the President that day?

    A Right. Correct.

    Q Okay. I mean, not like several hours later.

    A No. No.

    Q Okay.

    A Just much later within my visit.

    Q Okay. Thank you.

    BY MR. EMMICK:

    Q What I'd like to do is turn our attention to a call that you got from the President some time, I believe, in April, but correct me if I'm wrong, where he asked you something about whether you had told your mother...

    A Yes.

    Q ... about the relationship. Let's first talk about -- can you place this in time as best you can?

    A It was April. And this came about because -- I guess Marsha Scott, I think, had relayed some information to the President about her conversations, I think possibly with Walter Kaye, who is a friend of my family's, and that from that conversation, I think Marsha either directly said to the President or the President wondered from something Marsha said, if I had told my mom -- well, it must have been the President assuming from something that Marsha said.

    The President asked me if I had told my mom or had my mom told --and where that went was had my mom told Walter Kaye. And I said no.

    Q What you're describing, is it all based President said in this phone call?

    A I don't understand.

    Q Yes. You said that at some point it was based on the fact that Walter had spoken to Marsha Scott and I'm trying to figure out if you're learning that from a different source or if it's all from the President.

    A No, I was learning that from the phone call with the President.

    Q All right. How long was the phone call?

    A You know, I'm thinking just now, I don't know if that was in April. It could have been in May.

    EMMICK: Okay.

    A JUROR: Of 1997?

    A Yes. Sorry. Okay. I don't know if the month time is important or not.

    BY MR. EMMICK:

    Q In April or May, you have this discussion.

    A Right.

    Q The President asks you if you've told your mother about the relationship.

    A Right.

    Q What do you respond?

    A "No. Of course not."

    Q Okay.

    WISENBERG: Mike?

    EMMICK: Yes?

    WISENBERG: Can I butt in?

    EMMICK: Yes.

    BY MR. WISENBERG:

    Q Do you know independently what, if any, conversation there was -- that is, whether -- did you later learn that Walter had said something to Marsha or that somebody had said something to Walter?

    A In a way, that's too broad of a question because I think Walter Kaye kind of comes in and out -- if you look at this whole few years, he comes in and out of this in a few ways, so -- did I learn independently that Walter had had a discussion with Marsha? No. Is that what you were asking me?

    Q Well, that's one. How about with anybody else? I guess did you hear anything that struck you as this is kind of consistent with what the President had told me in that conversation or this fits together now? Walter had a conversation with somebody and could have actually talked to Marsha Scott and then that got relayed to the President.

    A I don't think I'm following you 100 percent. I'm sorry.

    Q Okay. Well, I'm not always very articulate. I'll just --

    A It --

    Q Do you recall -- let me be more specific. Are you - aware of your aunt ever having made a comment to Walter Kaye?

    A I'm aware of Walter Kaye having made a comment to my aunt.

    Q Okay. And what was that?

    A He remarked something to my aunt that he had heard from people that the reason I had left the White House or had been moved from the White House was because I had had this relationship with the President.

    A No. And it wasn't a voice that was familiar to me.

    Q Okay. And you never saw Ickes. Is that correct? When you later heard his voice, you didn't see him. You're just familiar with his voice.

    A Correct.

    Q As far as you know, did Ickes see you when you headed out the back way?

    A He couldn't have.

    Q Okay. Why do you say that?

    A Because he was in the office.

    Q Okay. And you said that Ickes was much later. I mean, much later within the whole time you were there with the President that day?

    A Right. Correct.

    Q Okay. I mean, not like several hours later.

    A No. No.

    Q Okay.

    A Just much later within my visit.

    Q Okay. Thank you.

    BY MR. EMMICK:

    Q What I'd like to do is turn our attention to a call that you got from the President some time, I believe, in April, but correct me if I'm wrong, where he asked you something about whether you had told your mother...

    A Yes.

    Q ... about the relationship. Let's first talk about -- can you place this in time as best you can?

    A It was April. And this came about because -- I guess Marsha Scott, I think, had relayed some information to the President about her conversations, I think possibly with Walter Kaye, who is a friend of my family's, and that from that conversation, I think Marsha either directly said to the President or the President wondered from something Marsha said, if I had told my mom -- well, it must have been the President assuming from something that Marsha said.

    The President asked me if I had told my mom or had my mom told --and where that went was had my mom told Walter Kaye. And I said no.

    Q What you're describing, is it all based President said in this phone call?

    A I don't understand.

    Q Yes. You said that at some point it was based on the fact that Walter had spoken to Marsha Scott and I'm trying to figure out if you're learning that from a different source or if it's all from the President.

    A No, I was learning that from the phone call with the President.

    Q All right. How long was the phone call?

    A You know, I'm thinking just now, I don't know if that was in April. It could have been in May.

    EMMICK: Okay.

    A JUROR: Of 1997?

    A Yes. Sorry. Okay. I don't know if the month time is important or not.

    BY MR. EMMICK:

    Q In April or May, you have this discussion.

    A Right.

    Q The President asks you if you've told your mother about the relationship.

    A Right.

    Q What do you respond?

    A "No. Of course not."

    Q Okay.

    WISENBERG: Mike?

    EMMICK: Yes?

    WISENBERG: Can I butt in?

    EMMICK: Yes.

    BY MR. WISENBERG:

    Q Do you know independently what, if any, conversation there was -- that is, whether -- did you later learn that Walter had said something to Marsha or that somebody had said something to Walter?

    A In a way, that's too broad of a question because I think Walter Kaye kind of comes in and out -- if you look at this whole few years, he comes in and out of this in a few ways, so -- did I learn independently that Walter had had a discussion with Marsha? No. Is that what you were asking me?

    Q Well, that's one. How about with anybody else? I guess did you hear anything that struck you as this is kind of consistent with what the President had told me in that conversation or this fits together now? Walter had a conversation with somebody and could have actually talked to Marsha Scott and then that got relayed to the President.

    A I don't think I'm following you 100 percent. I'm sorry.

    Q Okay. Well, I'm not always very articulate. I'll just --

    A It --

    Q Do you recall -- let me be more specific. Are you - aware of your aunt ever having made a comment to Walter Kaye?

    A I'm aware of Walter Kaye having made a comment to my aunt.

    Q Okay. And what was that?

    A He remarked something to my aunt that he had heard from people that the reason I had left the White House or had been moved from the White House was because I had had this relationship with the President.

    Q Do you know what your aunt responded to Walter Kaye?

    A My understanding was she got up and walked out. She was having lunch with him.

    BY MR. EMMICK:

    Q After you had this telephone call with the President where he asked you whether you had told your mom, was the next time that you saw the President May 24th, I think, which you refer to as dump day?

    A Yes. Either way, it would have been, whether it was in April or May.

    Q Right. Because you didn't see him in April --

    A Right.

    Q -- and you only saw him once in May.

    A Right. Correct.

    Q All right. And you had -- that's fine. All right. What I'd like to turn our attention to next is as we're - working down our outline here, we're finished up with the July 3rd, 4th and 4th period. I take it that you remained frustrated with the President's efforts to try to get you back to the White House.

    A Mm-hmm. I mean, it always -- and I did make this clear to him, that it was always more important to me to have him in my life than to -- than to get the job, but-the job was something that was important to me.

    Q Did there come a time in about October when you gave up, more or less, on your efforts to get back to the White House and you turned your attention more to New York City?

    A Yes.

    Q All right. Tell us how that happened.

    A Linda Tripp called me at work on October 6th and told me that her friend Kate in the NSC had heard from -- had heard rumors about me and that I would never work in the White House again and, if I did, I wouldn't have a blue pass and that her advice to me was "get out of town." So that meant to me that I wasn't going to be coming back to the White House and I was very upset by that.

    Also, she, Linda, told me that Kate had said, "You know, they create jobs at the White House, you know, six days a week." And that Stephen Goodin's girlfriend had just gotten a job, so with these examples of how there had been all these other people receiving jobs that I could have done and I didn't get it.

    Q Did you communicate your additional frustration and disappointment to the President?

    A Yes, I did.

    Q Tell us how and when.

    A I believe I sent him a short note telling him that I really needed to talk to him in person having to do with this subject matter and he and I had an argument in a conversation on the 9th of October.

    Q And was that a telephone conversation?

    A Yes, it was.

    Q Did he call you or did you call him?

    A He called me.

    Q About what time, if you can remember?

    A I think it was around 2:30, 3:00 in the morning.

    Q Was it a long phone call?

    A Yes. Yes. 2:00, 2:30 maybe.

    Q Is it fair to characterize involving an argument?

    A Yes. And then we made up.

    Q And then you made up.

    A It was half argument, half making up.

    Q Did the name Vernon Jordan come up in the course of that discussion?

    A It's possible.

    Q What do you have in mind about the first time that Vernon Jordan's name would have come up in conversations with the President?

    A It was either in that phone call or on 11th.

    Q And tell us whether it was in the what was said phone call or about Vernon on the 11th.

    A I don't remember. I know that I had discussed with Linda and either I had had the thought or she had suggested that Vernon Jordan would be a good person who is a close friend of the President and who has a lot of contacts in New York, so that that might be someone who might be able to help me secure a position in New York, if I didn't want to go to the UN.

    Q And what was the President's response?

    A "I think that was a good idea."

    Q At some point, did you send the President something like a list of jobs or interests that you might have in New York?

    A Yes. He asked me to prepare that on the 11th of October.

    Q At some point, did you have an initial meeting with Vernon Jordan?

    A Yes, I did.

    Q Can you tell us when that was, as best you can recall?

    A The beginning of November of last year.

    Q How was that meeting arranged?

    A Through conversations with the President and with Betty.

    Q Without getting into a lot of detail about what happened there during the first meeting with Vernon Jordan, what did you think were your job prospects after that? Did it look like things were going to happen?

    A Yes.

    Q All right. And what happened with respect to the job situation from that meeting with Vernon Jordan until, say, Thanksgiving?

    A Nothing, really.

    Q Okay. Then let's turn our attention to the month of December. We'll have to relate back a little bit to November in order to complete things, but on December 5th, did you return to Washington from overseas?

    A I did. You know -- the question you just asked me before about until Thanksgiving, I did have a conversation with him before Thanksgiving, I think it was the day before.

    Q Okay.

    A so --

    Q Then why don't you complete that, then.

    A Okay. I had spoken to Betty about -- about not being --being able to get in touch with Mr. Jordan because he was in and out of town and then wasn't necessarily returning my call. He's a busy man. And so Betty arranged for me to speak with him again and I spoke with him when I was in Los Angeles before -- right before Thanksgiving.

    Q Okay. Let's just go back, if we might, to that early November meeting with Mr. Jordan.

    A Okay.

    Q Did he say anything indicating to you that he had spoken with the President recently about you?

    A Yes. I believe he mentioned he'd had a conversation with the President.

    Q And what did he say about that or what did he say that indicated he may have spoken with the President?

    A I believe he mentioned that in the course of the conversation and as I was leaving, he remarked to me that I came highly recommended.

    Q Okay. Let's turn our attention to December 5th, then.

    A Okay.

    Q Having in mind that you had had a meeting with Vernon Jordan and a discussion and were trying to get a hold of him, when you got back from overseas, sort of what was the status of the Vernon Jordan job effort?

    A When I had spoken with Mr. Jordan right before Thanksgiving, he had asked me to call him the next week, either, I think, Thursday or Friday. And because I was out of town, I called him on Friday when I got back, and it was my understanding from his secretary he had gone out of town that day, so we had missed each other.

    Q All right. Did you try to arrange a meeting with President Clinton?

    A Yes.

    Q Tell us what you did to try to arrange a meeting with President Clinton.

    A I sent a note to Betty much earlier in the week that I asked her to pass along to him which in that letter requested of him that I could come have a visit that Saturday.

    Q Did you follow up that note with a call to Ms. Currie?

    A Yes.

    Q When was that call, if you remember?

    A December 5th.

    Q Okay. And what happened during the call?

    A Well, there were several calls, actually. And so at first, it was -- the first few, she still hadn't given him the note.

    So then finally she gave him the note, just, I think, right after the radio address or right before his radio address, and then she told me that he was meeting with his lawyers all day Saturday, but that she was coming in in the morning to give a tour and she would check and see with him then, you know, if maybe I could come by, but that the prospects didn't look good.

    Q Was she focused on Saturday because you had asked whether Saturday would be a good time?

    A Mm-hmm. Yes. I'm sorry. Maybe he was going out of town on Sunday. I'm not sure why I would have focused on Saturday versus Sunday.

    Q In any event, what she said was he was busy with meetings with lawyers, something like that?

    A Yes.

    Q All right. Did you go to a Christmas party that night?

    A Yes, I did.

    Q Did you see the President?

    A Yes, I did.

    Q Let's turn our attention to December 6th.

    A Okay.

    Q Are you doing okay?

    A Yes.

    Q All right. December 6th. Let me ask as a background question, had you previously purchased for the President a Christmas present?

    A Yes.

    Q All right. What was that Christmas present?

    A It was a sterling silver antique standing cigar holder.

    Q You had been unable to arrange an actual visit with the President to give him that present in person. What did you do instead?

    A I had some other gifts for him as well that I had gotten on my trips and --

    Q Tell us what those other gifts were, if you remember.

    A A tie. A mug from Starbucks in Santa Monica. A little box that's called hugs and kisses and it's Xs and Os inside, it's really -- it's just a cute little chatchki. An antique book from the flea market in New York that was on Theodore Roosevelt. And -- I think that's it.

    Q Okay. What did you try to do on the 6th in order to give those gifts to the President?

    A Well, I had wanted to give them to him, if I was going to have a planned visit with him, and then through the -- just some course of events, I got upset and I decided that I was really tired of everything that was going on and I just -- it was clear to me that he was ignoring me and I just didn't want to deal with this anymore.

    So I decided -- I had purchased these presents for him and I'm very -- I spend a lot of time and am very particular about the presents I give to people, so I didn't want to give them to someone else and I wanted him to have them, so I packaged them up with a note that I was going to drop off to Betty.

    Q And where did you go?

    A I went to the southwest gate.

    Q What happened at the southwest gate?

    A I paged Betty or I think I might have called her. I know I called her and she wasn't at her desk, so I paged her to let her know I was there. And then Marsha Scott drove up, so I ran away to the northwest gate because I didn't want Marsha to see me. Continue from there?

    Q Yes. Did you have any trouble getting in at the northwest gate? What happened?

    A Well, I wasn't trying to get in. I -- so --

    Q What were you trying to do?

    A I was trying to wait for Betty. So I called Betty from the northwest gate and she wasn't at her desk and then I saw someone go into the -- it was under construction at the time, so it was a different little hut than normal, and I saw someone who went in who I thought was John Podesta, so I thought I would -- since I knew that Betty had talked to John Podesta about me, I thought I would ask him, you know, maybe I would ask her -- I would give the gifts -- I would feel comfortable probably giving the gifts to John Podesta to give to Betty, just knowing that he knew I had a relationship with her.

    So when I went in to ask this person who I thought was John Podesta -- it turned out to be Lanny -- I think Lanny Davis, and so then one of the guards said, "Oh, are you here to see Betty Currie?" And I said, "No. I'm not here to see her, I'm trying to get her. She doesn't know I'm coming."

    And then they told me she was giving a tour and that Eleanor --do you want me to go into this detail?

    Q Sure.

    A Okay. That Eleanor Mondale had come recently and that she was giving a tour to Eleanor Mondale. Then I sort of -- wanting to know if the President was in the office, asked the guards, "Oh, well, is the President in the office? Because if he is, she's probably too busy to come out and get these gifts."

    And they said, "Yes, he was."

    Q What was you reaction to that?

    A Not good.

    Q Okay.

    A Very upset. Hysterical.

    Q Where did you go and what did you do?

    A I turned around and walked out and I was livid. I had --well -- are the grand jurors aware of the rumors about Eleanor Mondale that had been out? I mean, because it doesn't make sense if --

    BY MS. IMMERGUT:

    Q Well, why don't you say why you were upset.

    (REDACTED MATERIAL)

    BY MR. WISEWBERG:

    Q A question. Pardon me for interrupting. I just wanted to -- you said you were upset. Did you show your upsetness to any of the guards?

    A No.

    Q Thank you.

    BY MR. EMMICK:

    Q Did you contact Betty?

    A Yes, I did.

    Q Where did you contact her from?

    A I called her from the pay phone at the Corcoran Gallery.

    Q Did you have a fight with her?

    A I think so.

    Q Okay. You say you think so --

    A I'm trying to remember if I -- if I actually got her on the phone, which I think I did. I'm pretty sure I did.

    Q All right. Did you eventually come to talk to the President on the telephone?

    A Through a much more circuitous route, yes, I did.

    Q All right. And where were you at that time?

    A I was at home.

    Q All right. And about what time of day was it?

    A Maybe around noon or so.

    Q How did the two of you come to be speaking on the phone? Who placed the calls?

    A Well, I believe maybe I had called Betty or maybe Betty called me, one of the two, but she put him on the phone.

    Q All right. And what happened in the conversation with the President?

    A Well, we had a fight. And he was very angry with me.

    Q Why was he angry with you?

    A Because I had gotten so upset and I had made a stink to Betty and I had -- you know -- I -- what I came to learn, I think, is that as a result of me being upset with Betty and mentioning that I knew Eleanor Mondale was there, Betty called the guards at the northwest gate and so it had just caused a whole big commotion. And he was just angry at me and he told me it was none of my business what -- you know, what he was doing and that -- you know, that -- that he had never been treated as poorly by anyone else as I treated him and that he spent more time with me than anyone else in the world, aside from his family, friends and staff, which I don't know exactly which category that put me in, but --

    Q Okay. Was it a long phone call with the President?

    A Maybe half an hour, 45 minutes.

    Q Eventually, were arrangements made for you to visit him at the White House?

    A Mm-hmm.

    Q Are you doing okay?

    A Yeah, yes.

    Q Were you surprised that he would let you come to the White House?

    A Yeah, I was -- yes, I was a little bit surprised.

    Q Why?

    A Because none of the other times that we had really fought on the phone did it end up resulting in a visit that day.

    Q All right. What about the fact that he was supposedly meeting with his lawyers all day? Did he say anything about that?

    A He had in the fight. When we were fighting, he said -- you know, he was angry because he said, "I have one day to meet with my lawyers and, you know, I've got you messing things up and being upset and blah, blah, blah." So --

    Q Did you go and did you meet with the President?

    A Yes, I did.

    Q Did Betty wave you in?

    A Yes.

    Q Can you describe for us in general terms how that meeting went? Did you give him the gifts, for example?

    A I did. It was -- it was a really nice visit.

    Q Okay. What do you mean by a "nice visit"?

    A It was just sweet. He liked his Christmas presents and we were very affectionate and it just -- it was just nice to be with him.

    Q Did you discuss the job search?

    A I believe so.

    Q At the time, how did you think the job search was going? . .

    A Not very well. With respect to Mr. Jordan.

    Q Right. And did you communicate that to the President?

    A Yes.

    Q Can you give us a little more detail? What would you have said to one another?

    A I think I said that I -- that I was supposed to get in touch with Mr. Jordan the previous week and that things didn't work out and that nothing had really happened yet.

    Q Did the President say what he was going to do?

    A I think he said he would -- you know, this was sort of typical of him, to sort of say, "Oh, I'll talk to him. I'll get on it."

    Q Okay. Did he say anything to you about whether he had a Christmas present for you?

    A Yes, he did.

    Q What did he say?

    A He told me that on the phone, actually.

    Q All right. What did he say about that?

    A Well, I said to him, "Well, how do you have a Christmas present? I haven't read that you've gone Christmas shopping yet." And he said that he had bought it in Vancouver.

    Q Okay. Did he say at any time on the 6th anything about a witness list or your being on a witness list?

    A No.

    Q How were things left when you left him on the 6th?

    A That he would bring me -- oh, our meeting ended up -- or was cut short by the fact that he had to have a meeting with Mr. Bowles, so he told me that he'd give me my Christmas present another time and that he wouldn't jerk me around and abandon me.

    You know, that -- because I think I remarked to him, "Well, at the rate we go, I won't get it 'til Christmas of '98." So --

    EMMICK: I have no more questions about this date and I look at the time and it looks like it's 12:30.

    FOREPERSON: Sol, I think, went to check on something.

    EMMICK: Oh, all right.

    FOREPERSON: Did you check on something for lunch?

    WISENBERG: I have checked. It is here. It's been here.

    EMMICK: Okay. All right. Well, if this would be a good time to take a break for lunch --

    FOREPERSON: It's fine with me.

    EMMICK: Okay. Let's take an hour-long break for lunch.

    FOREPERSON: Hour-long.

    EMMICK: Okay.

    WITNESS: Okay.

    FOREPERSON: Okay.

    EMMICK: Thank you.

    (Whereupon, at 12:34 p.m., a luncheon recess was taken)

    AFTERNOON SESSION:

    Whereupon, MONICA S. LEWINSKY was recalled as a witness and, after having been previously duly sworn by the Foreperson of the Grand Jury, was examined and testified further as follows:

    WITNESS: Time for a nap?

    EMMICK: Madam Foreperson, do we have a quorum?

    FOREPERSON: Yes, we do.

    EMMICK: Are there any unauthorized persons

    FOREPERSON: There are none. Monica, I'd like to remind you that you are still under oath.

    WITNESS: Okay. Thanks.

    BY MR. EMMICK:

    Q Ms. Lewinsky, we just got through speaking about the December 6th meeting that you had with the President. What I'd like to do is turn our attention next to the date of December 11th.

    A Mm-hmm.

    Q Did you have a meeting with Vernon Jordan on that day?

    A Yes, I did.

    Q Would you tell us when that meeting was?

    A Around lunchtime.

    Q And how was that meeting arranged?

    A By his secretary.

    Q What was the purpose of the meeting?

    A For him to -- I learned after we had the meeting, for him to give me some contact names and some suggestion of what to do with these contact names.

    Q When you say --

    A For a job.

    Q When you say "contact names," these are names of potential employers?

    A Yes.

    Q What else did the two of you talk about?

    A We talked about my -- the fact that my mom's fiance at the time knew Mr. Jordan. We talked about the President. What else did we talk about? I think that's it.

    Q All right. Did he at some point make a comment to you about your being a friend of the President?

    A Yes, he did.

    Q Would you tell us how the conversation transpired from that point?

    A I don't remember how we got to this point, but at some point, Mr. Jordan said something to me, "Well, you're a friend of the President of the United States."

    And I remarked that I didn't -- I didn't really look at him as the President, that I saw him more as a man and reacted to him more as a man and got angry at him like a man and just a regular person.

    And Mr. Jordan asked me what I got angry at the President about, so I told him when he doesn't call me enough or see me enough.

    We were sort of bantering back and forth about that and then he told me that I shouldn't get angry at the President because he's got a lot of -- it sounds so stupid -- obviously, he has a lot of other more important things and difficult things to deal with than someone getting upset with him. And he suggested that if I was upset that I should call and take my frustrations out on Mr. Jordan instead of the President.

    I mean, I think I should just say that it was all -- this was all sort of in a light tone.

    Q Is this a meeting during which the subject of your possibly being in love cropped up?

    A Oh, yes. So after we had the conversation I was just talking about with Mr. Jordan, he said to me, "Well, you know what your problem is?"

    And I said, "What?

    He said, "Don't deny it." And he said, "You're in love, that's what your problem is."

    A So I think I just -- probably blushed or giggled, something like that.

    Q How did the meeting end? What were you going to do and what was he going to do?

    A I was planning to send the letters that he had suggested I write to the list of people and he suggested that I cc him and keep in touch with him, keep him apprised of what was happening with my job search.

    Q And did you send out those letters?

    A Yes, I did.

    Q And make arrangements for some interviews?

    A Yes, I did.

    Q What I want to do next, then, is direct your attention to a few days later, several days later, a week later, I guess. Did you come to have a telephone conversation with the President on December 17th?

    A Yes.

    Q Would you tell us how that telephone call was -- how that conversation took place?

    A Okay. The phone rang unexpectedly at about maybe 2:00 or 2:30 and --

    BY MS. IMMERGUT:

    Q In the morning?

    A Right. In the morning. And it was the President and he called and said he had two things to tell me and then he had to call me right back. So he called me right back.

    BY MR. EMMICK:

    Q Did he explain why he had to call and then call back?

    A I don't know. He just was very brief with me and then he said, "I'll call you right back." And he hung up and called back about a minute later.

    Q Before you get to the actual things that he says next, you mentioned that you unexpectedly got the call. Why were you surprised by the call?

    A Normally, the President wouldn't call me when Mrs. Clinton was in town, so -- and I usually was aware when she was out of town, so I that I would sort of be expecting or hoping that he would call. And the call came as a surprise to me.

    Q He called you back?

    A Right.

    Q Then what happened?

    A And he told me that he had two things to tell me. The first was that Betty's brother had been killed in a car accident and that -- so I reacted ti that and we talked about that being -- that this was the same brother who had been beaten up just a few months ago and she had lost her sister and her mom was ill. We talked about Betty for a little bit.

    And then he told me he had some more bad news, that he had seen the witness list for the Paula Jones case and my name was on it.

    Q Did you get an impression from him about when he had found out your name was on the witness list?

    A Yes. I mean, the impression I got based on the entire conversation was that he found out recently.

    Q When he told you that, what did he say about having seen your name on the witness list?

    A He told me it broke his heart.

    Q Tell us how the conversation went from there.

    A I was -- I'm sure, as you can imagine, I was upset and shocked. He told me that it didn't necessarily mean that I would be subpoenaed, but that that was a possibility, and if I were to be subpoenaed, that I should contact Betty and let Betty know that I had received the subpoena.

    I believe that I probably asked him, you know, what should I do in the course of that and he suggested, he said, "Well, maybe you can sign an affidavit."

    At some point in the conversation, and I don't know if it was before or after the subject of the affidavit came up, he sort of said, "You know, you can always say you were coming to see Betty or that you were bringing me letters." Which I understood was really a reminder of things that we had discussed before.

    Q So when you say things you had discussed, sort of ruses that you had developed.

    A Right. I mean, this was -- this was something that -- that was instantly familiar to me.

    Q Right.

    A And I knew exactly what he meant.

    Q Had you talked with him earlier about these false explanations about what you were doing visiting him on several occasions?

    A Several occasions throughout the entire relationship. Yes. It was the pattern of the relationship, to sort of conceal it.

    Q When he said that you might sign an affidavit, what did you understand it to mean at that time?

    A I thought that signing an affidavit could range from anywhere -- the point of it would be to deter or to prevent me from being deposed and so that that could range from anywhere between maybe just somehow mentioning, you know, innocuous things or going as far as maybe having to deny any kind of a relationship.

    Q At some point, did you talk with him about possibly settling the Paula Jones case?

    A Yes. I had -- I had had a thought and then had a conversation with Linda about this and just a way that he could settle the case and I suggested it to him.

    Q And what was that way? Not in a lot of detail, but --

    A The gist of it is, I thought that first Mrs. Clinton should do something publicly, maybe on a TV show or something, and talk about how difficult the case had been for her and on her daughter and that he would settle it and it would go away. And then the President should unannounced and unexpectedly go into the briefing room, make a brief statement that he -- in an effort to put this behind him, you know, against his attorneys' advice, he was going to pay Ms. Jones whatever it was, however much she wanted, and so that this case would be overwith.

    Q Did the two of you talk about how much the settlement amount would be or might be?

    A Yes. I believe at some point I had mentioned that I had recently read the -- I think she had lowered her -- the amount that she wanted to $500,000 or something lower and he said, "I thought it was a million or two million dollars."

    And I thought that was very strange, that he wouldn't know she had -- you know, that her lawyers -- or his lawyers had not told him that she had lowered her request for money. Or I don't know how you say that legally, whatever it is that she did.

    Q Right. Demand, probably.

    A The demand was lower.

    Q Right.

    A We also talked in this conversation about he mentioned that -- he said he'd try and see if Betty could come in on the weekend to give me my Christmas presents and I told him that was out of the question, to -- you know, let Betty be.

    Q Because her brother had just been killed, right?

    A Right.

    Q All right. About how long was the entire phone call? Or I guess technically it would be the second phone call.

    A Maybe a half an hour. Maybe I could just say since you asked me earlier that it was him suggesting that I would contact Betty if I were subpoenaed that led me to believe he didn't think I would be subpoenaed that soon because he knew Betty was going to be out, you know, he assumed obviously that Betty would be out for the week or two weeks with the unexpected loss of her brother.

    Q Right.

    A So that was what led me to believe he had just found out.

    Q After the call was ended, did you call anyone else?

    A Yes. About a half an hour later, I called Linda.

    Q What did the two of you talk about?

    A My conversation with the President.

    Q Right. It seems self-evident, but --

    A I know. I'm sorry.

    Q That's all right. What did you tell Linda?

    A Well, if I could just jump back --

    Q Yes.

    A I mean, I had -- Linda had told me some time in -- I think the second week of December that she had been subpoenaed in the Paula Jones case and that she intended to rat on me, so up until this point, I had been trying to convince her not to tell, that it's not anybody's business.

    So when I -- part of my telling her that the President had called; that I, too, may be pulled into this case was just sort of --maybe assure her that if that happened, there would be someone else denying it, it wouldn't be just Linda out there alone saying "I don't know anything about any kind of relationship between the President and Monica."

    Q Kind of a unified front or something like that?

    A Exactly.

    Q All right. How was the conversation left with Linda?

    A I think that we'd talk about it the next day.

    Q Did you get subpoenaed?

    A Yes, I did.

    Q When did you get subpoenaed?

    A On Friday, the 19th of December.

    Q Can you tell us about when you believe you were subpoenaed?

    A I believe it was around 3:00, 4:00 in the afternoon. I think closer to 3:00, 3:30.

    Q Okay. Where were you served?

    A At the Pentagon.

    Q Could you tell us how it happened? Did someone call you?

    A Yes. I received a call in my office from the gentleman who was to deliver the subpoena to me. He informed me he had a subpoena for me. I made a stink to him, asking him why I was being subpoenaed and I had no idea what was going on.

    When he gave me the subpoena, he suggested I call Ms. Jones' attorneys, which I made a comment to him that that's not something I would do.

    Q When you actually did get served, what was your real reaction inside?

    A I burst into tears. It was -- it was very scary. I mean, it just -- sort of my worst nightmare, or I had thought until that point, was being subpoenaed in this case. So I was pretty upset.

    Q You couldn't call Betty because Betty was --

    A Right.

    Q -- in mourning herself. Who did you call?

    A I called Mr. Jordan.

    Q From what phone did you call Mr. Jordan?

    A From a pay phone.

    Q Close to where you were served, the nearest pay phone around?

    A No, I think it was the pay phone which is down the hall from my office, which is kind of halfway between where I was served and my office.

    Q And why did you use a pay phone?

    A Because I was crying and I -- I mean, I -- my office, the way my office is set up is my desk was in the same room with four or five other people, so I couldn't very well have any kind of a private discussion.

    Q What did you tell Mr. Jordan?

    A Well, I don't remember what I told him. I was crying and he didn't seem to understand me, so he just -- he just told me to come to his office around 5:OO.

    BY MS. IMMERGUT:

    Q Did you tell him you'd been subpoenaed?

    A I probably did. I just -- I mean, I don't -- I don't remember, I just remember being on the phone crying and him saying, "I can't understand you. I can't understand you."

    Q You got off the phone. What did you do next? Did you finally go to Vernon Jordan's office?

    A Yes. I tried to compose myself and I went into the office. I told Mr. -- I believe I told Mr. Bacon or some other people in the office that I had an emergency and I needed to leave. I went home, sort of put myself together, and went to Mr. Jordan's office.

    Q When you got to Mr. Jordan's office, did you have to wait outside for a bit?

    A Yes.

    Q In like a reception area?

    A I waited in the lobby, like I always did.

    Q About how long did you wait in the lobby?

    A I don't really remember.

    Q At some point, I take it, you did actually meet with Mr. Jordan?

    A Yes.

    Q How did the conversation with Mr. Jordan progress?

    A First, I came in and I explained to him clearly that I had been subpoenaed and that I was upset and shortly after, I think maybe I said I didn't know what I was supposed to do, I didn't have an attorney, I think I was rambling.

    Shortly after I had arrived at Mr. Jordan's office, he received a phone call and I stepped out of the office.

    Q Did he ask you to step out of the office?

    A I think I may have offered. That was sort of par for the course. And I waited for him while he was on the phone outside his office and when I came back in, he placed a call to -- I don't know if it was right after I came back in, but at some point, when I came back in, he placed a call to Mr. Frank Carter.

    Q Now, when you stepped out, he took one call and then you stepped back in, did he tell you who he'd been on the phone with?

    A No.

    Q All right. He places a call to Frank Carter. Do you know whether he talked to Frank Carter in person or do you know whether he just left a message or do you recall?

    A I don't really recall.

    Q When --

    A Oh, he said something about -- well, I know he referred to Mr. Carter as Mr. Carter, so I don't know if he was talking -- I don't really remember if he was talking to Mr. Carter or he was talking to someone else, but it scared me because I thought for Mr. Jordan to be referring to someone else as Mr. something, that -- I sort of thought he must be a big deal.

    Q All right. When you went to the meeting with Mr. Jordan, did you bring the subpoena with you?

    A Yes, I did.

    Q Did you show it to Mr. Jordan?

    A I believe so.

    Q What most troubled you about the language of the subpoena and what the subpoena had called for you to produce?

    A The thing that alarmed me was that it asked for a hat pin.

    Q Okay. And why did that alarm you?

    A Because I thought that was a very specific gift and in this list of gifts, everything else seemed to be somewhat generic and then it had hat pin, which screamed out at me because that was the first gift that the President had given me and it had some significance.

    Q When you showed Mr. Jordan the subpoena, did he make any remark about any of the things that were called for?

    A Yes. When I mentioned to him, I think, about the hat pin, he said, "Oh, don't worry about it. This is a vanilla subpoena, this is a standard subpoena," something like that. Generic subpoena, maybe.

    Q Did you know what he meant, a vanilla or standard subpoena that asks for hat pins?

    A Well, what I understood that to mean was that -- that what he was trying to say is there was nothing out of the ordinary about this subpoena.

    Q I see. I guess what I'm trying to get at is do you think he was trying to imply that all subpoenas ask for that or that all subpoenas in the Paula Jones case asked for that or all subpoenas --what was he -- from your point of view, what was he trying to convey?

    A I think what he -- I think what he was trying to convey was stop worrying, that this is not something out of the -- you know, out of the realm of possibility of what might be in a subpoena.

    Q All right. Were you reassured by that?

    A A little. I -- I sort of felt that he wasn't -- I mean, he didn't really understand what I was saying.

    Q All right. Did you have any discussion with him about letting the President know that you'd been subpoenaed?

    A Yes. I asked Mr. Jordan to inform the President.

    Q How did you ask? How often? How vigorously?

    A I -- I mean, I asked him to -- to please make sure that he told the President. He said he was going to see the President that night, so --

    Q All right. Did the subject of a possible sexual relationship between you and the President come up in the conversation?

    A Yes, it did.

    Q Tell us how it came up.

    A Mr. Jordan said to me that there -- "There are two important questions" or "There are two important -- " I think, "Two important questions that are related to the case: Did you have sex with the President, you know, or did he ask?" And I said no to both of those.

    Q What did you interpret him to be asking when he asked you those questions?

    A Well, I thought he -- I guess -- can I step back for a minute?

    Q Sure.

    A Up until a point that we'll get to, which is December 31st, I sort of -- mainly, I think, from my discussions with Linda, I was under the impression that -- that Mr. Jordan kind of knew with a wink and a nod that I was having a relationship with the President, that it was never -- he and I never discussed it, but I thought it might be possible.

    I'm, you know, a young woman, sort of coming to see him, the President's mentioned me. But I also was sort of under this influence of Linda saying to me, "Of course he knows. Of course he knows. Of course he knows."

    So when he asked me those questions, I thought he was asking me, saying essentially "What are you going to say?" not necessarily asking me directly what -- you know, "What are the answers to these questions?" More "What are you going to reply in regard to the case?"

    Q Now, was your interpretation of his questions based entirely on your assumption about what he knew? Or was it based in part on how he asked the questions?

    A I think it was based more in part on my assumptions of what he knew.

    Q Was there anything unusual or suggestive about how he asked the questions?

    A No.

    Q And how did you answer the questions?

    A No and no.

    Q Okay. Did you try to make it clear to him at all that there was more to the story than just no and no?

    A Not at that point.

    Q At that time, did you make arrangements to meet with the attorney who you would get, Mr. Frank Carter?

    A Yes. After Mr. Jordan made the arrangements with Mr. Carter, he told me to be at his office at -- I think 11:OO or 10:30 on Monday.

    Q All right. How did the meeting with Mr. Jordan end? Was there any reference to a hug?

    A Oh, yes. I'm sorry.

    Q That's okay.

    A When I was leaving, I asked him if he would give the President a hug for me. I bugged him again about making sure he told the President. And so he said, "I don't hug men." I said, "Well, okay."

    Q All right.

    A But --

    Q All right. Did you call Linda Tripp afterwards?

    A Yes, I did.

    Q What was the purpose of your call?

    A In a -- to let her know that I had been subpoenaed.

    Q Tell us how that conversation went.

    A It probably would be impossible for anyone who didn't --who has listened to that tape to follow. I was beyond paranoid.

    I had no idea how I had gotten onto the witness list and then, of course, been subpoenaed and I was thinking at that point that maybe my phone was tapped or someone had read my e-mails or something. But in thinking that my phone might be tapped, I sort of tried to explain to this to Linda that I had been subpoenaed in a veiled fashion.

    Q How did you do that? What do you mean?

    A I used different cover stories. I think like it was a movie or it was a book, trying to discuss things. I think I said something -- "I received the flowers," trying to intimate that I had received the subpoena. So --

    Q Eventually, did you drop the sort of disguised way of talking and just talk about the subpoena, or do you recall?

    A I don't believe I did. I don't really remember, though.

    Q How were things left with Linda?

    A She was having a party the next day, so we made plans that -- or I suggested that I come early and we could discuss this and that I would help her set up for her dumb party. I'm sorry.

    Q Her dumb party? All right. Well, we'll skip the dumb party for now.

    A I'm sorry.

    MR. EMMICK: That's all right.

    MR. WISENBERG: I have a quick question.

    MR. EMMICK: Okay. A dumb party question?

    MR. WISENBERG: Not about the dumb party.

    MR. EMMICK: All right.

    BY MR. WISENBERG:

    Q When you were doing the flowers bit, the book bit, how was she -- you're trying to speak in code to her, how was she responding?

    A I don't really remember. I just sort of remember her not understanding and me being frustrated. "Hello? Understand. We just talked about this."

    A JUROR: Excuse me. May I ask a question?

    MR. EMMICK: Sure. Absolutely. Yes.

    A JUROR: Did you ever find out how the Paula Jones lawyers knew about the hat pin, et cetera?

    THE WITNESS: I -- from what I've read in the press, yes.

    A JUROR: But just from any other source? Did you ever suspect maybe Linda or --

    THE WITNESS: I had -- I came to start to suspect her, but not in any way that -- that it really has turned out to be. Not to that degree.

    A JUROR: Thank you.

    BY MR. EMMICK:

    Q Let's turn our attention, then, to December 22nd, which is the day that you met with Frank Carter and I think you had said that you were going to meet with Vernon earlier.

    A Mm-hmm.

    Q Tell us about that. The Vernon part.

    A Okay. With all the details?

    Q Well, first, when were you supposed to meet with Vernon and then did you place another call to him?

    A Right. I -- I -- I asked -- I called on the morning of the 22nd to see if I could come to see Mr. Jordan earlier. And I was -- I was a little concerned. I thought maybe he didn't really understand or -- fully understand what it was that was happening here with me being subpoenaed and what this really meant. So I came to see Mr. Jordan earlier and I also wanted to find out if he had in fact told the President that I had been subpoenaed.

    Q Right.

    A Which I found out he did. So I -- so I told Mr. Jordan that -- I said I was concerned that maybe -- that someone had listened in on phone calls and Mr. Jordan said, "Well, you know, so what? The President's allowed to call people."

    And I said, "Well, we've had phone sex."

    And so Mr. Jordan said, "Well, what's phone sex?"

    And so I said, "Well, you know what phone sex is."

    And he said, "No, I don't. I'm just an old man. I don't know what phone sex is."

    And it was kind of this -- discussion that way.

    Q Did you discuss the hat pin?

    A We didn't discuss the hat pin, but I brought -- I had put together sort of an assortment of things that I was planning to hand over to Mr. Carter as being in response to the subpoena, sort of things that I would -- considered -- gifts, being the Christmas cards that I had received from the White House, I had a copy of the President's book, "Hope and History," which he had signed to me which had a very innocuous sort of inscription. And I think brought some innocuous pictures with me. So I showed those to Mr. Jordan.

    Q What did you say about those items?

    A I know that -- I think I was a little more specific in my proffer about what -- I mean, what I remember saying now was that --you know, that I sort of showed him that this is what I was going to respond to for the subpoena.

    Q Well, did you bring everything that could have responded to the subpoena that day?

    A No. No.

    Q Did you try to convey to Mr. Jordan the fact that it wasn't everything?

    A I think I might have.

    Q And do you remember how you would have conveyed it? Would it have been very expressly or would it have been more impliedly?

    A More impliedly.

    BY MS. IMMERGUT:

    Q Did you tell Mr. Jordan that the President had indeed given you a hat pin?

    A I did, but I had told him that on Friday and that was what prompted the sort of "this is a vanilla response."

    MR. EMMICK: Let me show you the written proffer --

    THE WITNESS: Okay.

    MR. EMMICK: -- and see if that helps you recall or if you know whether or not when you wrote it it's accurate.

    What we're looking at is the top of page 6 -- everyone else has a copy.

    THE WITNESS: Okay. There's some spelling mistakes.

    MORE

    MR. EMMICK: Why don't I just read out loud. This paragraph starts, "On the day Mr. Jordan drove Ms. Lewinsky to Mr. Carter's office, she showed Mr. Jordan the items she was producing in response to the subpoena. Ms. Lewinsky believes she made it clear this was not everything she had that could respond to the subpoena, but she thought it was enough to satisfy. Mr. Jordan made no comment about whether or not what Ms. Lewinsky brought was right or wrong.

    Mr. Jordan drove Ms. Lewinsky to Mr. Carter's office, introduced them and then left.

    BY Mr. EMMICK:

    Q Now, having read that to you, does that refresh your recollection about what was said to him?

    A I think I would have implied it.

    Q Yes.

    A That this wasn't everything. I -- I don't really remember if I specifically said -- and from reading this, it doesn't make me think I necessarily specifically said, "This isn't everything, but it's enough to satisfy," but I could have said that.

    Q At the time you wrote this, were you trying to be completely truthful and accurate?

    A I was trying to be completely -- yes, I was completely truthful and accurate. I'm just also while I'm reading this now, it doesn't necessarily indicate to me that -- that what I'm saying here is sort of a direct quote of what I said.

    Q Do you remember what Mr. Jordan's reaction was? There it's written that he didn't indicate whether he thought it was right or wrong, but more generally, how did he react when you tried to convey to him that this may not be everything?'

    A There were often times when I was with Mr. Jordan that he would have no reaction at all. He would kind of do this "Mmmph" thing.

    Q I'm not sure how the court reporter is going to get that. Is that a grunt?

    A And so -- I remember feeling in general with Mr. Jordan and this subject matter, just not knowing. Do you understand what I'm trying to say? Is this clear? And not really ever getting much of a reaction from him.

    Q Did you take from his lack of reaction that he did understand or was it still ambiguous in your mind?

    A I think sometimes I thought he understood and sometimes I thought it was ambiguous.

    Q Okay. Did the subject of phone sex come up again in your conversation with Mr. Jordan?

    A Aside from what I mentioned before?

    Q Yes. Did you explain to him what phone sex was at some point?

    A I think it -- at -- I don't think I said it. He might have said -- know, is it -- uh -- this is embarrassing. Hmm. I think he -- it's hard. I think he -- uh -- might have given some suggestion as to what he thought phone sex was and I agreed. Is that --

    Q That's fine.

    A -- fair?

    Q That's fine.

    A By this time, had you expected the President to call you?

    A Mm-hmm. Yes.

    MR. EMMICK: I'm sorry?

    A JUROR: Before you go on, can you ask her what does that mean?

    MR. EMMICK: What does phone sex --

    A JUROR: No, what did he say?

    MR. EMMICK: I think the grand juror is asking for more detail.

    THE WITNESS: If I remember correctly, I believe that he said --or maybe I said something like -- you know, "He's taking care of business on one end and I'm taking care of business on another." Does that --

    BY MR. WISENBERG:

    Q Do you remember which one of you said it?

    A When I'm saying that now, I think I said it, because that sounds more familiar to me. Does that answer your question?

    A JUROR: (Nods affirmatively.)

    BY MR. EMMICK:

    Q Did you expect the President to call you?

    A Yes, I did.

    Q Is that why you were bugging or asking Vernon so much about whether he had told the President?

    A I don't know. Maybe.

    Q All right.

    A I think I just wanted to make sure the President knew.

    BY MS. IMMERGUT:

    Q That you had been subpoenaed.

    A Right. Because I was supposed to call -- you know, in the event that I was subpoenaed, I was supposed to have called Betty and -- so --

    BY MR. EMMICK:

    Q I'm going to ask a question that will suggest what assumptions you were making about what Vernon knew or didn't. Why would you feel comfortable talking with Vernon Jordan about phone sex?

    A I wasn't comfortable talking to Vernon Jordan about phone sex.

    Q Okay.

    MR. EMMICK: Okay.

    MR. WISENBERG: Questions?

    MR. EMMICK: Yes?

    BY MR. WISENBERG:

    Q Did you say on the 22nd that you showed to Vernon Jordan the gifts you bringing to Frank Carter?

    A Yes.

    Q Okay. Was a hat pin among the things you showed to Vernon Jordan?

    A No.

    Q But you had indicated to him on the 19th that the President had given you a hat pin.

    A Yes.

    MR. WISENBERG: Thank you.

    BY MR. EMMICK:

    Q At some point, you went to Frank Carters's.

    A Mm-hmm. Yes.

    Q Tell us what happened when you got to Frank Carter's.

    A We arrived at Mr. Carter's office and Mr. Jordan and I sat down on the sofa. Mr. Carter came out. Mr. Jordan introduced us and left.

    Q In your discussions with Mr. Carter, what was the major point that you were trying to make? What was the big thing you were trying to convey to Mr. Carter?

    A That there was absolutely no reason why I should have been subpoenaed in this case.

    Q Okay. And --

    A And that I certainly did not have a relationship with the President.

    Q You said that to him.

    A I don't think I said those words, but that was what I was trying to convey, and certainly when asked those questions, that's what I answered.

    Q Did you discuss with him how you could get out of the deposition?

    A Yes.

    Q Tell us what you talked about. Maybe that would be the easier way to go.

    A Okay. I told Mr. Carter I really didn't want to be dragged into this, I didn't -- I thought Paula Jones' claim was bunk and I didn't want to be associated with the case. believe I suggested maybe that I could -- maybe I asked him if I could sign an affidavit or is that something to do.

    He said that the first step -- to hold off on that and that the first step is he would try to talk to the attorneys for Paula Jones and find out what it is, why they're subpoenaing me and where it is that they're going with this and that maybe one option might be is he could arrange for them to interview me, just kind of do a brief interview, versus a deposition.

    Q Did you discuss with him the subpoena insofar as it requested items? Did you, for example, go through and talk about what items were called for?

    A Yes, we did. Yes. And I said no to everything until we got to the gifts, and then I sort of turned over what it was that I had brought with me that I thought responded to the gifts. And that was it.

    Q Was there any mention made by either of you of Bob Bennett?

    A Yes.

    Q Tell us what was said.

    A I requested of Mr. Carter that he get in touch with Mr. Bennett and just to be in touch with him and to let him know that I had been subpoenaed in this case and I didn't know why.

    Q Why did you request that Mr. Carter contact Mr. Bennett?

    A Because I thought in the -- how do I explain this? Sort of in the story or role, the story that I was giving to Mr. Carter and being a low level political appointee and, in general, even if I hadn't been a low level political appointee, I thought it was probably appropriate to align myself with the President's side, being that that's whose side I was on and there was no question in my mind.

    Q Is another way of saying that you were trying to send a message to the President or to Mr. Bennett?

    A Not to the President. He knew. I mean, the President knew, you know? So --

    Q So it was more a message to Mr. Bennett?

    A I just -- to me, that seemed -- I mean, I think -- you have to look at this from the point of view that I was a political appointee. And so --

    Q What does that imply for you?

    A For me, that means that the reason you're in this job is you work for this administration and that you're politically aligned with this administration and everything you do is in the best interests of the administration and, ultimately, the President. And that's where your goal and your focus should be.

    Q How were things left? What was he going to do and what were you going to next?

    A Mr. Carter was going to get in touch with attorneys for Paula Jones and get in touch with Mr. Bennett. And he was going to send me a retainer letter. And we'd be in touch.

    Q Let me then ask you the following. You had earlier indicated that the President said that he had a Christmas present for you.

    A Mm-hmm. Yes.

    Q Did you ever make contact with Betty Currie in order to make arrangements to pick up the present?

    A Yes.

    Q Tell us about that.

    A I called Betty after Christmas to see how she was doing and find out how her holiday was and to ask her -- or to let her know that the President had mentioned to me he had a Christmas present for me and, you know, to touch base with me to see if he -- what he wanted to do, if he wanted to get together.

    So she called me back and told me to come to the White House at 8:30 in the morning on Sunday, the 28th of December.

    Q Did you?

    A Yes, I did.

    Q All right. Betty waved you in?

    A Yes.

    Q At about what time was it, if you can remember?

    A 8:30.

    Q When you got there, what happened?

    A I think the President was already there. He was just coming to the Oval Office and Betty and the President and I were in the Oval Office and this was the first time I got to meet Buddy. So we played with Buddy in the office and he was running around the carpet. And I had brought a small Christmas present for Buddy. And so the three of us were just talking and goofing off. And then the President and I went into the back study and he gave me my Christmas presents.

    Q How long were you in the back study with the President?

    A Maybe about 45 minutes to an hour.

    Q What was the Christmas present or presents that he got for you?

    A Everything was packaged in a big Black Dog -- or big canvass bag from the Black Dog store in Martha's Vineyard. And he got me a marble bear's head carving, sort of -- you know, a little sculpture, I guess, maybe.

    Q Was that the item from Vancouver?

    A Yes. Then he got me a big Rockettes blanket from Christmas of '95 or '96, I think. He got me a Black Dog stuffed animal that had a little Black Dog T-shirt on it. He got me a small little box of chocolates, cherry chocolates, and then he got me some sunglasses that were a joke because I had -- I had teased him for a long time about the different sunglasses that he was wearing in public. And so then I bought him a normal pair of sunglasses, and so we had just sort of had -- this was a long running joke with us, so he bought me these really funny looking sunglasses and we both were putting them on and joking around goofing off.

    So -- I'm trying to think what else. Can I look at the list?

    MR. EMMICK: Sure. Feel free.

    THE WITNESS: Oh. He got me a pin that had the most of my Christmas presents were sort of New York themed, so he got me a pin that had the New York skyline on it. I think that's it. Well, it's a lot, so -- not just that's it.

    BY MR. EMMICK:

    Q Now, you had mentioned earlier that you were concerned about the fact that the subpoena covered this hat pin.

    A Mm-hmm.

    Q Did you discuss that concern with President Clinton?

    A Yes. We -- we really spent maybe about five -- no more than ten minutes talking about the Paula Jones case on this day and --do you want me to talk about the hat pin or that period of time?

    Q The whole period of time, I suppose.

    A I brought up the subject of the case because I was concerned about how I had been brought into the case and been put on the witness list. So I asked him how he thought I got put on the witness list and he told me he thought that maybe it was that woman from the summer with Kathleen Willey, which I knew to be Linda Tripp, or maybe -- he said maybe some of the uniformed -- maybe the uniformed officers.

    We talked about that. I mentioned that I had been concerned about the hat pin being on the subpoena and he said that that had sort of concerned him also and asked me if I had told anyone that he had given me this hat pin and I said no.

    Q That was false.

    A Correct. Yes. When in fact I had told people about the hat pin.

    Q Right.

    A Let's see. And then at some point I said to him, "Well, you know, should I -- maybe I should put the gifts away outside my house somewhere or give them to someone, maybe Betty." And he sort of said -- I think he responded, "I don't know" or "Let me think about that." And left that topic.

    Q When you said "the gifts, what did you mean by "the gifts"?

    A I meant all the gifts that he had given me.

    Q All right. Do you think that you're the one who came up with Betty's name?

    A I'm not 100 percent sure, but when I received the call from Betty, I wasn't surprised that it was Betty calling, so that's what leads me to believe that I might have suggested it.

    Q Okay. Did you discuss with the president the fact that you were planning to sign an affidavit?

    A I might have mentioned it, but I don't think -- we really didn't spend very much time on this subject.

    Q All right. So you walked in without many gifts, you were going to walk out with a bag of gifts.

    A Hm-hmm.

    Q Did it strike you as unusual that when you had a subpoena calling for you to produce gifts the President is giving you a bag of gifts.

    A At the time, it didn't strike me as unusual.

    Q Okay. And why is that?

    A I never thought about it. I mean, I was -- I was -- I had struggled for a long time before the 28th -- or I should just say -- I guess a few days before the 28th, that if I was going to see the president, if I should tell him or not that Linda knew. And I decided not to.

    And so I -- I thought this might be the last time I saw him before I went to new York and I wanted it to be a really nice visit, so I was -- I --- having decided not to tell him about Linda, I kind of didn't even want to go too far there in getting mired down in the discussion of the case.

    Q All right. When you left the White House, did anything unusual happen with respect to your E-pass?

    A Yes. Well, I had a visitor's pass.

    Q Visitor's E-pas, I guess.

    A Is that what --

    Q A visitor's pass?

    A Visitor's -- I don't know. I know it is a visitor's pass. Betty escorted me out and I realized that I left the pass in the office, so Betty told me that she would call down to the guard station and let them know that I was fine and I had just left the pass somewhere.

    Q Do you remember what gate you used when you left the White House?

    A I believe it was the southwest gate.

    Q Did you hear from Betty later that day?

    A Yes, I did.

    Q Were you surprised to hear from her?

    A No. I mean, I wasn't surprised that I was hearing from Betty. I think I was a little surprised to sort of get the nature of this phone call when the President could have just said right then and there, "Well, yeah, I think, you know, why don't you give them to Betty, that's a good idea." But I wasn't terribly surprised. No.

    Q What did she say?

    A She said, "I understand you have something to give me." Or, "The President said you have something to give me." Along those lines.

    Q How long after you had left the White House did Betty call you?

    A Several hours.

    Q When she said something along the lines of "I understand you have something for me," or "The President says you have something for me," what did you understand her to mean?

    A The gifts.

    Q Okay.

    A Kind of -- what I was reminded of then a little bit was jumping all the way back to the July 14th incident where I was supposed to call Betty the next day but not really get into details with her, that this was maybe along those same lines.

    Q That actually anticipates my next question.

    A Oh.

    Q Did you feel any need to explain to her what was going to happen?

    A No.

    Q What arrangements did you make for transfer of the something?

    A I think we discussed some things and Betty mentioned she was on the way to the hospital to visit her mom and she'd swing by and, you know, pick up whatever it was I was supposed to give her.

    Q Now, at the time you had that conversation, were you already packing up the gifts at all?

    A No.

    Q When was she going to come by, then? That day?

    A Yes.

    Q What did you do after the phone call ended?

    A I put all the gifts that he had given me on my bed and I got a big box from The Gap and went through each item and decided if I needed to give it to them or not.

    Q Can you explain what you mean by that?

    A It sort of was a difficult -- I -- I wasn't sure if I was going to get this box back, so I didn't want to give everything in the event that I didn't get the box back for some reason. And I kept out some innocuous things and I kept out- the -- really the most --the most sentimental gift he had given me was the book, the "Leaves of Grass" book, so -- and it was just -- it's beautiful and it meant a lot to me, so I kept that out.

    Q What other -- it sounds to me like you had one category of more sentimental gifts that you kept out of the box.

    A Mm-hmm.

    Q And kept for yourself. What other items were in that category, other than the "Leaves of Grass"?

    A Not necessarily sentimental ones, but just -- I think I kept out the marble bear head, the bag, the canvas bag, the blanket, the sunglasses, the chocolates. And I think that's it. Oh, wait. And I might have kept out some of the Martha's Vineyard stuff that I had gotten in the fall.

    Q Those were items that you've recently turned over to our office.

    A Yes.

    Q Which items did you put into the box? If you remember.

    A The hat pin, the pin that I had received that day for Christmas, a pin that he had given me for my birthday, a picture that he had signed for me for my birthday that I had framed, a picture he had signed for me of him wearing the first tie I gave him.

    Q Any other Black Dog items?

    A I think there was a Black Dog hat that I put in there. And I'm not -- I'm not really sure what else was in there. Oh, I also put the copies that I had left of the Valentine's Day ad that I had put in the paper for him.

    Q The Romeo and Juliet quote?

    A Mm-hmm.

    Q All right. Did Betty come by?

    A Yes, she did. I met her outside.

    Q How did you know when she was going to come by? Was there a prearranged time she was going to come by or did she call you from --

    A I think she called me on her way out.

    Q You met her outside, you had the box with you?

    A Mm-hmm. I had taped it up and I wrote "Please do not throw away" on it.

    Q Were you concerned that she might throw it away?

    A Mm-hmm. Yes. Sorry.

    Q Okay. Let me just ask you some questions. Did you ever discuss with her the contents of the box?

    A I don't believe so.

    Q Did she ever ask about the contents of the box?

    A No.

    Q Did she ever say anything indicating that she knew from a prior discussion the contents of the box?

    A Not -- no, not that I remember.

    Q Sounds like it was a short conversation.

    A We talked about her mom a bit and Christmas. I think maybe I had elaborated on what I got for Christmas from him.

    Q Now, you could have just thrown these items out, rather than putting them in a box. Why didn't you- just throw them out?

    A Because I -- they meant a lot to me.

    Q Okay. You could have given the items to someone else, a friend of yours, Ashley Raines, or to your mother or just hidden them somewhere. Why didn't you do that?

    A I think -- I've come to sort of see this now. I don't know that I necessarily saw it then, but I feel now a little bit that me turning over some of these things was a little bit of an assurance to the President or reassurance that, you know, that everything was okay.

    Q In your mind, then, were you giving these items not just to Betty, but really to the President as well, in a manner of speaking?

    A I think that was even more directly what I thought it was. Not that they were going to be in his possession, but that he would understand whatever it was I gave to Betty and that that might make him feel a little bit better.

    Q Did Betty say where she was going to put the box of gifts?

    A I think she said she was going to keep them in a closet. Or, you know, she'd keep the box in a closet.

    Q Right.

    A You asked me -- never mind.

    Q The gifts. Right. I understood. I understood. All right. What I'd like to do now is ask a few questions

    MR. WISENBERG: Mike?

    EMMICK: Yes?

    WISENBERG: Before you leave that topic, I have a few on that. Do you mind?

    MR. EMMICK: No. Not at all.

    BY MR. WISENBERG:

    Q You've said here today, Ms. Lewinsky, and I think you told us earlier in some of your sessions with us, that you were -- the non-innocuous items were going to go to Frank Carter and --

    MR. EMMICK: You mean the innocuous items.

    WISENBERG: What did I say?

    EMMICK: The not innocuous items.

    WISENBERG: Boy. Thank you. I stand corrected.

    BY MR. WISENBERG:

    Q The innocuous items were going to go to Frank Carter, the non-innocuous items were not, but that one of the reasons, one of the criterion for stuff that didn't even go in the Betty Currie box that you would keep would be sentimental value.

    A Mm-hmm.

    Q Is that -- have I described that accurately?

    A Sort of.

    Q Okay. How not sort of?

    A I didn't really give any gifts to Mr. Carter. Nothing that I turned over to Mr. Carter was a gift from the President. And I think the way you described the dividing of the actual gifts was sort of innocuous, you know, not innocuous -- sentimental value, I think that was more accurate.

    Q Well, as between the gifts you put in the box and the gifts you kept?

    A Mm-hmm.

    Q All right. How would you describe today the difference between the two? I just want to make sure I understand, between the ones you kept and the ones you put in the Betty box.

    A You know, I don't have a perfect memory of what the criteria was at the time. I know I kept the book out because that was the most sentimental thing to me. And I believe that the things I put-in the box - were -- also in the box was a dress he gave me from Martha's Vineyard, so the things that went into the box were, I think, more along the lines of some of the things that really complied with the subpoena, that were maybe specifically named, although I think books might have been specifically named in the subpoena, but I kept the "Leaves of Grass."

    Q They complied with the subpoena, but they're going to Betty Currie.

    A Correct.

    Q Now, my question is, and I've asked you this before, but I want to ask you in front of the grand jury, since you were basically trying to keep some sentimental things but you told us that the hat pin was sentimental to you, why is the hat pin going into the Betty box?

    A Because the hat pin was the alarm of the subpoena, so -- I -- I -- to me, it seemed logical that putting the hat pin in the box -- I mean, it was what had been named in the subpoena.

    MR. EMMICK: All right. Should we take a break?

    THE FOREPERSON: Yes, we should.

    THE WITNESS: Oh, thank goodness.

    MR. EMMICK: Okay. All right. Ten minutes.

    THE WITNESS: Okay.

    THE FOREPERSON: Ten minutes.

    (Witness excused. Witness recalled;)

    MR. EMMICK: All right. Do we have a quorum?

    THE FOREPERSON: Yes, we do.

    MR. EMMICK: Any unauthorized persons present?

    THE FOREPERSON: None at all.

    THE WITNESS: Let me guess. You're going to remind me I'm still under oath.

    THE FOREPERSON: There you go.

    THE WITNESS: Fast learner.

    Q Ms. Lewinsky, this is what we're going to do. We're going to go over some questions that we'd like to ask and then we're going to turn our attention to the December 31st meeting, the breakfast meeting with Vernon Jordan.

    A Okay.

    Q Let's go to questions first. One question is Betty comes by and gets this box of gifts. Is there any other way Betty would have known to call and pick up this box of gifts except for the President asking her to?

    A The only thing I can think of is if he had asked someone else to ask Betty.

    Q Do you have any reason to think that happened?

    A No, but, I mean, I wasn't there, so I don't know -- I don't know what he said, how -- maybe he left her a note. I mean, I don't know. So --

    Q Another way of asking it is did you-tell someone else about this and they might have asked Betty?

    A No.

    BY MR. WISENBERG:

    Q Did you think it as a coincidence that she called you?

    A No.

    BY MR. EMMICK:

    Q Let me ask you a couple of questions about the December 20th dumb party.

    A Okay.

    Q Okay? First, why is it a dumb party.

    A Oh. Really? You want me to answer that?

    Q Yes.

    A Well, because it was Linda Tripp's party and -- well, that should be enough, but just that I got there and I got stuck having to do all this stuff and I had really wanted to talk to her about the predicament we were in and -- I now look back on it and just -- she had spent all this money on food and a month before she had had no money for the bus and was trying to sell her clothes and somehow she had $500 to spend on food and had money to spend on presents underneath her tree and it was just dumb.

    Q Let's focus on the discussions you had with Linda at the dumb party or before the dumb party about the situation.

    A I really didn't sort of get into, I think, a full discussion with her until after -- well, until I was leaving and I asked her to walk me out to my car.

    Q Let's talk first then about the efforts you made to talk with her about the subpoena in the house. Did you try to?

    A Probably. It was -- I got there maybe -- the -- I think the party was supposed to start around 7:30 and I got there at 5:00 and she had made no food, had done nothing. (sic) mean, she just had this fridge stuffed with food. So I was trying to help prepare all this stuff. There was a lot more work to do than I thought there would be and then her daughter had this obsession with vacuuming that night, so there were just a lot of people and I don't really remember trying to get a chance.

    I may have tried to or sort of said "I need to talk to you," kind of a thing, but I don't recall having any discussions with her before the party.

    Q Okay. And then you mentioned that you were able to talk to her a little bit outside, I think you said?

    A Mm-hmm.

    Q Tell us about that.

    A The main -- the main feeling I had at that point, once I had received my subpoena was that -- that now she didn't need to worry about denying that she knew anything about this relationship, because I was going to deny it under oath as well.

    And so sort of just -- I figured that conversation would kind of just be mapping out what our next steps would be. But it ended up being much shorter and I -- she looked at the subpoena -- excuse me --sorry -- and I think she -- she kept talking about how weird, "Isn't the hat pin strange? Isn't it strange that they're asking about the hat pin?"

    And we talked about that. And I think that -- I -- I was -- I was -- I don't think that I was left with the feeling that she was going to continue on this path of insisting she would rat on me. So -- is that clear? I'm sorry -- no? Okay. When I left that night, I felt a little more -- I think I felt a little more reassured that she and I would be saying the same thing in the Paula Jones case. Is that -- okay. But I wasn't 100 percent sure and I think that we left it that we'd have some more discussions about this.

    Q Okay. One of the things we wanted to get back to was the whole situation on the 28th where there's a subpoena that calls for you to turn over gifts and the President is giving you gifts.

    A Mm-hmm.

    Q What do you think the President is thinking when he is giving you gifts when there's a subpoena covering the gifts? I mean, does he think in any way, shape or form that you're going to be turning these gifts over?

    A You know, I can't answer what he was thinking, but to me, it was -- there was never a question in my mind and I -- from everything he said to me, I never questioned him, that we were ever going to do anything but keep this private, so that meant deny it and that meant do -- take whatever appropriate steps needed to be taken, you know, for that to happen, meaning that if I had turned over every gift he had given me -- first of all, the point of the affidavit and the point of everything was to try to avoid a deposition, so where I'd have to sort of -- you know, I wouldn't have to lie as much as I would necessarily in an affidavit, how I saw it.

    So by turning over all these gifts, it would at least prompt them to want to question me about what kind of friendship I had with the President and they would want to speculate and they'd leak it and my name would be trashed and he would be in trouble. So --

    Q So your impression, then, was in the same way that the two of you were going to deny the relationship, you would also deny or conceal the gifts that were personal that passed between you.

    A And the phone call -- I mean, I think that it was everything. I think it was kind of -- at least for me, I don't know what he did, for me, this had to be thought through. You know, I had to anticipate everything that might happen and make sure -- you know --

    Q You did what was necessary.

    A Exactly.

    BY MS. IMMERGUT:

    Q Although, Ms. Lewinsky, I think what is sort of -- it seems a little odd and, I guess, really the grand jurors wanted your impression of it, was on the same day that you're discussing basically getting the gifts to Betty to conceal hem, he's giving you a new set of gifts.

    A You know, I have come recently to look at that as sort of a strange situation, I think, in the course of the past few weeks, but at the time, I was -- you know, I was in love with him, I was elated to get these presents and -- at the same time that I was so scared about the Paula Jones thing, I was happy to be with him and -- I -- I didn't think about that.

    He had -- he had hesitated very briefly right before I left that day in kind of packaging -- he packaged all my stuff back up and I just sort of -- you know, remember him kind of hesitating and thinking to myself -- I don't think he said anything that indicated this to me, but I thought to myself, "I wonder if he's thinking he shouldn't give these to me to take out." But he did.

    Q And he had already told you he had some gifts for you for Christmas.

    A Correct.

    BY MR. EMMICK:

    Q You mentioned earlier when I asked who was on the list in your mind of people who should be avoided like Nancy Hernreich or Steve Goodin, you mentioned Mr. Ickes.

    A Mm-hmm.

    Q That name came up. Why was Mr. Ickes on the avoid list?

    A He -- well, he -- he's just strange. And he -- I'm sorry. He would -- you know, you could be the only person in the hall and you would pass Mr. Ickes in the hall and he would just glare at you. You know.

    And I'd say, "Hello," you know, as you would imagine you're supposed to do and he'd just glare at you and walk past you. And I thought that was strange. Call me weird.

    Q Okay. And that's the reason that you mentioned him on the list of people to avoid?

    A And I think just -- his name is sort of in my mind for having to do with things that we're discussing today and what's been in the press of it, but it really was most every senior person in the White House, I mean, except for Betty who knew who I was that would concern me.

    Q Right.

    A I mean, I had -- you know, I had had a lot of interaction with these people during the furlough, so --

    Q Let me ask you a question about Tim Keating. Did Tim Keating tell you or imply to you that you could come back after the election?

    A He told me that I could probably come back after the election.

    Q Okay. Do you remember when he said that to you?

    A Yes. On --

    Q Go ahead.

    A I'm sorry. On the day that he informed me of the transfer.

    Q So that would have been the 5th of April? Does that sound right? Friday, the 5th of April?

    A Correct. It was Good Friday, I remember.

    Q Did he say anything about any problem of an appearance of impropriety during that conversation with you? Something like doesn't matter after the election, anything like that?

    A No. No. No.

    Q That subject didn't come up at all?

    A Not with Mr. Keating.

    Q You mentioned that when -- oh, I'm sorry. Go ahead. Sure.

    A JUROR: I'm sorry. What would have prompted him to make a comment like that, that you could come back after the election?

    THE WITNESS: I was crying and I just kept telling him, I -- you know, I didn't really want to leave and why did I have to leave and wasn't there -- you know, weren't there other openings rather than me having to go to the Pentagon because he had --

    Do you want me to get into a little bit about what was said there?

    MR. EMMICK: If it will help answer the question, sure.

    A JUROR: Yes. Please.

    THE WITNESS: Okay. There had been problems with my supervisor, Jocelyn Jolley, and so when I was called in to Tim's office, I had thought he was -- he had just spoken with Jocelyn and I thought he was going to tell me they had fired Jocelyn and instead he told me that they were -- that for reasons having to do with some of the workload not -- things with the letters from the Office of Management and Budget, that they had to blow up -- quote-unquote, blow up the correspondence office and they were eliminating my position.

    My transfer had nothing to do with my work, I shouldn't see this as a negative thing. He told me I was too sexy to be working in the East Wing and that this job at the Pentagon where I'd be writing press releases was a sexier job.

    And I was crying and --

    BY MR. EMMICK:

    Q What do you think he meant by "too sexy"?

    A I think he meant that -- he -- I think he was trying to --you know, trying to conceal the fact that -- you know, that I now know, the real reason I was being transferred. And so I think he was trying to not maybe anger me. And thought that somehow by -- maybe he thought I'd think that was a complement (sic).

    A JUROR: Did you think he was patronizing you?

    THE WITNESS: A little bit. Yeah. That's a good way to put it. I -- I just -- I just remember thinking that was -- I was never going to see the President again and that all of a sudden that this -- you know, the end of his -- this relationship.

    And I kept -- I've always sort of -- I'm the kind of person that always thinks that I can fix everything and so it was kind of this --feeling of wait, this train's going too fast and I can't stop it and that it had already passed and -- and -- so when Tim said that, I think he sort of said that -- I don't think he meant to say that. I think that was probably more than he was supposed to say.

    A JUROR: Thank you.

    BY MR. EMMICK:

    Q Going back again to the 17th of December when the President called you and let you know about the witness list, you said he used the phrase, "It broke my heart to see you on the witness list." What was your reaction when he said that?

    A I believed him. I think I also --

    Q You thought he was being sincere?

    A JUROR: Can I ask another follow-up question?

    MR. EMMICK: Sure.

    A JUROR: Because you had nothing to do with formulating this witness list, why do you think it breaks his heart, that your name was on there? Because you're innocent of having formulated this list. Do you have -- or in your opinion, what is it that hurt him?

    THE WITNESS: I think it was the idea that -- that -- this was going to -- that this was going to be a bad thing for me. I mean, if you imagine what's happened now hadn't happened and let's just say the Paula Jones thing had gone ahead and I had somehow been dragged into that, just being associate (sic) with it and it being difficult and maybe he -- maybe it was going to seriously alter any kind of friendship or relationship that we had, you know?

    BY MR. EMMICK:

    Q I want to ask a question about computer e-mails or files. Did you arrange for the deletion of files or e-mails that might have related to you and the President?

    A Did I arrange?

    Q Or did you delete them. Sorry.

    A Yes, I did.

    Q Okay. Did you ask Linda Tripp if she would delete e-mails relating to the President?

    A Yes.

    Q Did you speak with someone at the Department of Defense in order to learn something about those deletions or to make sure that they would be more longstanding?

    A Not about deletions.

    Q Okay. Well, what was it that you spoke with him about?

    A I asked him -- I asked Floyd, I think it is, if -- if --sort of how easily someone could break into the computers. And I couldn't imagine how I had come to this witness -- come to be on this witness list, so one of the things I thought was maybe someone had broken into my computer and was reading my e-mails. And he told me that that was really difficult.

    And then I asked him about -- then with the thought in mind of getting rid of the e-mails, I asked him what the sort of saving procedure was with the e-mails. I know at the White House, they back them up and put them in the archive forever and he told me that at the Pentagon, they sort of stay on the server for four weeks and then they're dumped into e-mail heaven or something.

    Q All right. Did you ever ask Catherine Allday Davis to delete e-mails that you had sent relating to the President?

    A No.

    Q At any time, did you create anything like a spreadsheet that contained on it information relating to your relationship with the President?

    A Yes.

    Q Okay. Tell us about that.

    A Linda and I had been talking and she had been talking about she's really good at coming up with patterns of things or -- I think that was the word she used. And so she was wanting to see -- you know, I think in an effort to aid her in trying to figure out what the pattern of my relationship with the President was, I made a stupid spreadsheet on Microsoft Excel that just had the -- the numbered days of the month and the months and determined on what day was there a phone call or did I see him or see him at an event or something like that. So --

    Q Is that something that you ultimately printed out and showed to her?

    A Yes.

    Q I take it that was on the DOD computer?

    A Yes.

    Q Were the entries that you made, would they have revealed that you were talking about Clinton?

    A No.

    Q Okay. Did you ever have an extra copy of that -- let's call it a spreadsheet?

    A No.

    Q Did you save the file of the spreadsheet?

    A No. I don't believe so.

    Q All right. Going back also to the night of the 17th, December 17th, just so that we can get clear on the date of that, it was at 2:30 in the morning. Is it literally on the 17th or is it --

    A Nineteen -- eighteen -- it is literally the morning, 2:30 in the morning of the 17th. So, yes.

    Q Okay. Good. When the President gave you the Vancouver bear on the 28th, did he say anything about what it means?

    A Mm-hmm.

    Q What did he say?

    A I think he -- I believe he said that the bear is the --maybe Indian symbol for strength, just -- you know, and to be strong like a bear.

    Q And did you interpret that as be strong in your decision to continue to conceal the relationship?

    A No.

    MR. EMMICK: All right. Any follow-up on that?

    MS. WIRTH: Can I ask one question?

    MR. EMMICK: Sure.

    BY MS. WIRTH:

    Q Did he say something like "This is when you need to be strong," or "This is for when you need to be..strong"? Beyond saying that it was a symbol of strength?

    A I think he -- he held it and he said, you know, "You can hold onto this when you need to be strong."

    MS. WIRTH: Thank you.

    BY MR. EMMICK:

    Q What I'd like to do is ask you about a passage from the proffer and I'm looking at page 5.

    A Okay.

    Q And you'll see at the bottom, and I'll read the passage, this is relating to the meeting on the 19th, just after you've gotten the subpoena, meeting with Vernon Jordan, and what the passage says is "Possibly later in that meeting, but more probably the next meeting," I assume that's a reference to the 22nd?

    A Correct.

    Q "Ms. Lewinsky tried to make it clear to Mr. Jordan that she in fact did have a physically intimate relationship with the President." And then let's go to the next page. It says, "Ms. Lewinsky made it clear she intended to deny the sexual relationship with the President."

    So I guess what I want to talk about is the portion of the passage on page 5.

    A Mm-hmm.

    Q Tell us how you tried to make it clear to Mr. Jordan that you had a physically intimate relationship with the President.

    A I think by mentioning the phone sex.

    Q I see. All right. Any other way that you tried to make it clear to him?

    A Not that I remember.

    Q All right. And then is it your recollection now that it was on the 22nd that you were trying to make this clear to Mr. Jordan?

    A Yes.

    Q As opposed to the 19th?

    A Yes.

    MR. EMMICK: Any other follow-up on that?

    BY MS. IMMERGUT:

    Q Ms. Lewinsky, how did you make it clear to him that you intended to deny the relationship with the President on the 23rd? Excuse me. The 22nd.

    A This is, I think, as I mentioned to you guys before, this is -- I don't have a memory of this. I know when I wrote this I was telling the truth, so I'm sure I did do this, but I don't remember.

    MR. WISENBERG: Ms. Lewinsky --

    Mike, do you mind if I ask some questions?

    MR. EMMICK: Go right ahead.

    BY MR. WISENBERG:

    Q I think, you can correct me if I'm wrong, you've done it previously today, so I'm sure you will again if I am, you told us when we first met with you in the proffer meeting that you couldn't specifically remember that item. Is that correct?

    A Yes.

    Q And I think you said you couldn't specifically remember any more of the item that Mike just read to you on the bottom of the previous page about the physically intimate relationship.

    A Right.

    Q But that you had no doubt that it's true. Is that correct?

    A I was being truthful in my proffer. Yes.

    Q And the proffer, written proffer, is accurate. Is that correct?

    A Yes.

    Q But -- and I think you also said you feel some -- I don't know if this is the reason you don't remember it, but you have expressed to us that you feel some guilt about Vernon Jordan. Is that correct?

    A Mm-hmm.

    Q That's a yes?

    A Yes.

    Q Okay. Can you tell us why that is?

    A He was the only person who did what he said he was going to do for me and -- in getting me the job. And when I met with Linda on the 13th, when she was wearing a wire, and even in subsequent or previous conversations and subsequent conversations, I attributed things to Mr. Jordan that weren't true because I knew that it had leverage with Linda and that a lot of those things that I said got him into a lot of trouble and I just -- he's a good person and --

    Q Is one example of -- and then I'll leave this topic, is one example of one of the things you told Linda that isn't true, "I told Vernon Jordan no job, no affidavit?" Something along those lines?

    A Yes. Because Linda made me promise her that on the 9th.

    Q Okay. Of January?

    A Of January.

    MR. WISENBERG: Okay.

    THE FOREPERSON: Do you need a minute?

    THE WITNESS: I'm okay. Thanks.

    A JUROR: I'm a little confused. When you said that you said certain things because you know Linda had the mike, right?

    THE WITNESS: Oh, I didn't know Linda had the mike. I now know that she was wearing a wire.

    A JUROR: Okay. But so why would you say these things about Mr. Jordan that were not true? What was the reason?

    THE WITNESS: Because -- I had -- from some of my conversation with Linda, I started to think that she was a little bit jealous that Mr. Jordan was helping me get a job in New York and that I was leaving the Pentagon and that -- she had remarked one time that -- that, you know, Mr. Jordan who is the most powerful, you know, man in this city got me my attorney and she -- she thinks that she only had -- you know, this dinky attorney or something like that.

    And I was -- I was so desperate for her to -- I was -- for her to not reveal anything about this relationship that I used anything and anybody that I could think of as leverage with her. I -- her, the President, my mom, everybody. I mean, not her, but Mr. Jordan, the President, my mom. Anybody that I thought would have any kind of influence on her, I used.

    Does that answer your question?

    A JUROR: Well, it doesn't. I guess-what I'm trying to figure out, okay, is what was that going to accomplish? Was that going to make her -- what?

    THE WITNESS: Well, specifically, with the statement about I won't sign the affidavit until I get the job, is that I had a conversation with Linda, which we'll probably get to --

    MR. EMMICK: I hope.

    THE WITNESS: Oh. On January 9th and in that conversation, she had told me she had changed her mind, she was going to be vague on the truth about Kathleen Willey and then she told me -- at that point, I had told her I hadn't signed an affidavit when I had and I told I didn't have a job yet and I knew I was probably going to be getting a job that day.

    And she said, "Monica, promise me you won't sign the affidavit until you get the job. Tell Vernon you won't sign the affidavit until you get the job because if you sign the affidavit before you get the job, they're never going to give you the job."

    And I didn't want her to think that I had gone ahead and done anything without her and that I was leaving her in the dark. I wanted her to feel that -- sort of Linda and myself against everyone else because I felt like I needed to hold her hand through this in order to try to get her to do what I wanted, essentially.

    BY MR. EMMICK:

    Q We can get into that in more detail when we talk about the 13th.

    A Okay.

    Q Why don't we do the following. I wanted to ask some --rather than just jumping into the 31st which is a Vernon Jordan meeting, why don't we ask some questions about which of your gifts to the President you have ever seen in the White House itself, either in the dining room or the study or the Oval Office generally.

    A Does that include gifts that I gave him that I've seen him wear?

    Q All right. Well, let's just start with the things that you've seen in the area itself.

    A Okay. Okay. I -- can I go through -- just go through the list?

    Q Sure.

    A That would probably be easier. On page 6, I've seen the two little books.

    Q Two little books?

    A The "Oy Vey" book, which is jokes and the little golf book.

    Q Do you remember when you saw those books?

    A Yes. On -- I think it was November 13th.

    Q Zadilla day?

    A Zadilla day.

    Q All right.

    A I saw a copy of the Washington Post ad that I had in a book on his desk.

    Q You gave him a smallish copy of the --

    A I gave him an actual copy that I cut out from one of the papers and I glued it into a little cardboard thing.

    Q And where did you see it on his desk.

    A It was inside a book.

    Q And the book was on the desk in the study?

    A Yes.

    MS. WIRTH: Mike, could I ask a question?

    BY MS. WIRTH:

    Q Did you see the ad in a particular book?

    A Yes.

    Q Which one?

    A "VOX."

    Q Okay. And was that on the desk in the study?

    A Yes.

    Q And was "Oy Vey" on the desk in the study?

    A Yes.

    Q What about the little golf book?

    A I think it was. I -- I -- I'm not 100 percent sure it was a golf book, I'm 99.9 percent sure.

    Q And about how many books does the President have on his desk in the study?

    A He has maybe about 15 or 20 little books that are on his desk and he has more books over there and more books on the bookshelf.

    MS. WIRTH: Thank you.

    BY MR. EMMICK:

    Q How about the opener?

    A Right. The -- right. The wooden frog letter opener that I gave him. I'm just trying to go through this way, so --

    Q All right. Go ahead.

    A I saw the -- well, I lent him the book "Disease and Misrepresentation."

    Q And did you see it in the Oval Office somewhere?

    A No, I saw it in the back study.

    Q The back study? And that would have been on page 8, I believe?

    A Right. And then the letter opener that I was mentioning a moment ago was on page 9. I saw the antique paperweight.

    Q Okay. Where is it that you saw the opener?

    A It was on top of -- I think it's a cigar box on his desk in the back office. I saw the antique --

    BY MS. IMMERGUT:

    Q When did you see that, Monica?

    A Zadilla day. I saw the antique paperweight on his -- he has a collection of antique political memorabilia in the dining room on top of sort of a chest sort of thing, and I saw that there on -- I think on December 6th or December 28th.

    BY MR. EMMICK:

    Q Okay. Do you remember which?

    A No. I saw the standing cigar holder, I think, it was on his Oval Office desk. Or it might have been in the back. I think it was on the Oval Office desk. On the 28th of December. And that's it.

    Q All right. Let's turn our attention to the 31st of December. You had indicated earlier that at some point you started to get more and more concerned about Linda Tripp and whether she was going to rat on you, I think was the way you put it. What did you do with respect to Vernon Jordan in that concern?

    A Since Linda had stopped returning my calls around the 24th of December, by the end of December, I realized I'd kind of better come up with some sort of strategy as to how -- if Linda Tripp comes out and says all these things where this is coming from and try to prepare the President.

    And since I couldn't find it within myself to bring it up to him directly, I called Mr. Jordan and told him that I needed to talk to him, I had some concerns about something.

    Q When did you call him?

    A I think it was the 30th of December.

    Q Did you speak with him directly?

    A I think I might have spoken with his -- with his secretary.

    Q Do you remember her name?

    A Gail. There was another one, too, but I've forgot her name. And I met Mr. Jordan for breakfast on -- no, not Sunday but December 31st, the morning of the 31st, at the Park Hyatt Hotel.

    And in the course of the conversation I told him that I had had this friend, Linda Tripp, who was sort of involved in the Paula Jones case with, I think, the Kathleen Willey stuff. I don't know if I went into that much detail, but I did tell him her name.

    And I said that she was my friend, that I didn't really trust her -- 1 used to trust her, but I didn't trust her any more and I was a little bit concerned because she had spent the night at my home a few times and I thought -- I told Mr. Jordan, I said, well, maybe she's heard some -- you know -- I mean, maybe she saw some notes lying around.

    And Mr. Jordan said, "Notes from the President to you?" And I said, "No, notes from me to the President." and he said, "Go home and make sure they're not there."

    Q What did you understand him to mean when he said, "Go home and make sure they're not there"?

    A I thought that meant that -- to go home and search around and if there are any copies of notes or anything that I sent or drafts, to throw them away.

    Q Did you have any further discussions with Mr. Jordan about Mr. Clinton and the Clinton's (sic) marital status?

    A Yes. After breakfast, in the car, I asked Mr. Jordan if he thought the President would always be married to the First Lady and he said, "Yes, as he should be." And gave me a quote from the Bible. And a few -- maybe a minute or so later, he said, "Well, maybe you two will have an affair when he's out of office."

    And at that point, I was shocked because I thought Mr. Jordan had known that we had already had this affair and I think I alluded to this earlier today when I saying until the 31st I didn't know, and I said, "Well, we already had an affair. We just -- you know, we didn't have sex or did everything but sex," or something like that. And he just kind of went -- one of those "Mmmph." You know --

    Q A grunt?

    A And didn't really respond to me. So I took that as my cue to drop the subject. But -- so --

    MR. EMMICK: All right.

    BY MR. WISENBERG:

    Q What did you eat for breakfast at the Hyatt?

    A I had an -- I had an egg white omelet.

    BY MR. EMMICK:

    Q What did he have?

    A I think he had cereal with yogurt.

    BY MR. WISENBERG:

    Q Do you remember who paid?

    A Mr. Jordan. He's a gentleman.

    Q Do you remember how he paid?

    A No.

    Q Has anyone from the Office of Independent Counsel or the FBI shown you any paperwork of any kind with reference to that breakfast?

    A No.

    MR. WISENBERG: Thank you.

    BY MR. EMMICK:

    Q Let's turn back to the topic of gifts. Okay. Did you give a gift to the President in early January.

    A Yes, I did. Well, I guess -- I gave it to Ms. Currie for the President.

    Q What was the gift?

    A It was an antique book on the various presidents with sketchings. A history book.

    Q Where did you buy the book?

    A At an antique bookstore in Georgetown.

    Q Was there anything along with the book?

    A A note.

    Q Okay. What kind of a note?

    A An embarrassing mushy note.

    Q Okay. Did you attach the note to the book in some way?

    A I don't really -- I might have put it inside the book or I may have put it outside. I wrapped the book.

    Q And how did you try to get this book to the President?

    A I called Betty over the weekend and asked her if I could drop it off so I didn't have to waste money on a courier.

    Q And when you say "the weekend," are you talking about that first weekend in January?

    A Yes.

    Q Do you remember if it was Saturday, the 3rd, or Sunday, the 4th?

    A I believe it was Sunday the 4th.

    Q You called Betty and what again did you say to Betty?

    A I don't -- I think I said something -- you know, - "I have something for him, could I drop it off to you so I don't have to waste money on a courier."

    Q Okay. And what did you do?

    A So she said that was fine. So I went over to her home and --

    Q Had you been to her home before?

    A Yes.

    Q Had you ever dropped anything off at her home for the President before?

    A No.

    Q What did you do when you got her home?

    A Well, she was sitting on the porch, so we sat on the porch and I gave her the package and we talked for a little while.

    Q Did you talk at all about the gift that was for the President?

    A We might have. I might have mentioned it. Probably did. I'm not --

    Q Was there any discussion about the fact that the President was himself under subpoena and was going to be deposed in a couple of weeks?

    A No.

    Q Were you concerned about giving him a book, a gift, under those circumstances?

    A No.

    Q Okay. Did you ever talk to the President and learn whether he got the book and the note?

    A Yes, I did.

    Q All right. When did you talk with him and learn about that?

    A On the 5th of January. I think it was the 5th of January. You know -- can I just --

    Q Sure. Take a look.

    A Yes. It was the 5th of January.

    Q And that would have been Monday?

    A Correct.

    Q Why don't we try to proceed through Monday because Monday started with a meeting with you and Frank Carter and then there was the phone call afterwards, so let's go first to the meeting with Frank Carter.

    A Okay.

    Q Feel free.

    A I met with Mr. Carter to go over in more detail where we stood at that point with the Paula Jones case and he went over -- he went over what was going to happen if an affidavit wasn't going to satisfy the Paula Jones attorneys and I did have to get deposed and what the room looks like, what -- you know -- everything that happens in a deposition and he threw out a bunch of different questions.

    You know, they'll probably ask you who your first-grade teacher was and they'll ask you -- you know, some things and then some of the questions that concerned me were questions like "How did you get your job at the Pentagon?" And how did -- you know, and he said, "They'll ask things like did you find out about the opening on a bulletin board or did someone tell you about it? Who recommended you for the job? How did everything get facilitated for the transfer?"

    And that alarmed me because I didn't really know how to necessarily answer that. I didn't express that to Mr. Carter, but --

    Q Well, when you say you didn't know how to answer it, what do you mean, you didn't know how to answer it?

    A Well, I was concerned that if I said in -- you know, if possibly that was going to come up in the affidavit which hadn't bee written yet or in a deposition, if I had said -- mentioned certain people that had been involved in helping me secure the position over at the Pentagon or forcing me to go there, really, that because these people didn't like me, if they were ever questioned by the Paula Jones attorneys, that they might say something contrary to what I said just because -- to get me in trouble because they didn't like me.

    So I was concerned that -- I wanted to -- I wanted to have some sort of feeling of protection, that -- you know, that I wouldn't be screwed over by these people.

    Q Were you concerned that they were going to say nasty things about you or were you concerned that they were going to say things that might ultimately lead to the revealing of the relationship in some way?

    A No, I was just concerned that they would purposefully say something different from whatever I said just because they had the opportunity to screw me. I mean -- not -- never mind.

    Q Okay.

    A To cause trouble for me. How's that?

    Q Did you discuss with Mr. Carter the affidavit that you were considering?

    A Yes.

    Q What did you talk about?

    A I think he -- he said he would work on a draft and he'd get a draft of the affidavit to me.

    Q Okay. At the time, did you want anyone else to review that affidavit before you ultimately signed it?

    A At first, I didn't think about it, but then I did. I decided I wanted Mr. Jordan to look at it.

    Q All right. Why did you want Mr. Jordan to look it?

    A I think I felt that -- that he being the President's best friend and having a -- a clearer understanding of my relationship with the President than Mr. Carter did, that I just would feel that it sort of had been blessed.

    MR. EMMICK: Okay.

    BY MS. IMMERGUT:

    Q And would that be blessed by the President as well?

    A Yes, I that's what I -- I mean, I -- I think I felt that -excuse me. That, you know, if Mr. Jordan thought something was okay, that I'm sure the President would think it was fine.

    MS. IMMERGUT: Okay.

    BY MR. EMMICK:

    Q Did you discuss the subpoena and the items that might be responsive to the subpoena anymore? I think you had talked about it earlier.

    A You know, there's been a little bit of confusion for me when I gave Mr. Carter those items, so it's possible.

    Q All right. You mentioned that Mr. Carter asked you some hard questions about like how you got your job. Did you want to talk with anybody about that afterwards?

    A Yes. I placed a call to Ms. Currie and asked her to let the President know I needed to speak to him and it was important.

    Q Did you say anything to Ms. Currie about signing something?

    A I think I might have sort of said, just, you know, hoping that she might pass that along, I think.

    BY MS. IMMERGUT:

    Q Do you remember saying that you wanted to or needed to speak to the President before you signed something?

    A I think so.

    BY MR. EMMICK:

    Q All right. Did you explain to her what you meant when you said that?

    A No.

    Q Okay.

    A I'm pretty sure I did say that to Ms. Currie.

    Q Did you finally get in contact or did you at some time shortly thereafter get in contact with Mr. Clinton?

    A Yes.

    Q How did that happen?

    A Ms. Currie called me back a few hours later and then she put the President on.

    Q Before we talk about what the President and you talked about, as background, I guess, were you upset or in a mood that day from a photograph you had seen?

    A Oh, you really want to embarrass me, don't you?

    Q Well, I just want to get the mood right.

    A I had been peeved by the photo and the footage that was in the media from the President and First Lady being romantic on their holiday vacation. So I felt a little bit like -- I -- I was just annoyed. I was jealous and it just seemed sort of something he had never -- an aspect of their relationship that he had never really revealed to me and it made me feel bad.

    So I was -- I don't know if anyone here has ever done this, where you -- you're annoyed with someone so you kind of want to pick a fight with them and you want to be a little bit hostile so that -- you know, you just rub them the wrong way.

    Q Okay.

    A So that's how I was feeling.

    Q That's how you exhibited the annoyance or anger or whatever.

    A Mm-hmm.

    Q Okay. Tell us about your conversation with the President.

    A Because of those feelings, I was a little bit curt with him and so I told him that I had had this meeting with Mr. Carter and that I was concerned, you know, from the questions he asked me that if, you know, if I at some point had to kind of -- under oath, answer these questions and in the course of answering a question I mentioned people at the White House who didn't like me, that somehow I would end up getting -- they'd get me in trouble.

    And so he -- so when I told him the questions about my job at the Pentagon, he said, "Well, you could always say that the people in Legislative Affairs got it for you or helped you get it."

    And there was a lot of truth to that. I mean, it was a generality, but that was -- I said, "Well, that's a good idea. Okay."

    Q Was there any discussion of the book?

    A Yes. I had asked him if he had gotten the book that I sent with Betty and he said he did, he really liked it, and then -- I had written him this -- this note that I had sort of -- wrote -- I think it was Saturday night when I got home from the movies and I had seen the Titanic that weekend and it just was -- just brought up a lot of feelings and thoughts for me that I put on -- that I put on paper.

    And so I sort of said something about, "Oh, well, I shouldn't have written some of those things in the note." Because I was angry about seeing the picture with them romantic, it made me feel really stupid for having sent this letter.

    And he said, "Yeah, you shouldn't have written some of those things." Kind of along the ways he had said before, about not writing particular things on paper, you know, putting things to paper. So --

    Q About how long was your telephone call with the President?

    A Maybe 15 minutes.

    MR. EMMICK: Anything else on that?

    THE WITNESS: I see you trying not to laugh.

    MR. EMMICK: What about break-wise? Where are we? Is this a good time for a break or do we want to keep going?

    THE FOREPERSON: Yes. Yes.

    MR. EMMICK: All right.

    THE FOREPERSON: I would say only five minutes.

    MR. EMMICK: All right. Five minutes it is.

    THE FOREPERSON: A five-minute break. I'm sorry, guys. Okay.

    (Witness excused. Witness recalled.)

    MR. EMMICK: Madam Foreperson, do we have a quorum?

    THE FOREPERSON: Yes, we do.

    MR. EMMICK: Are there any unauthorized persons present?

    THE FOREPERSON: There are none.

    Monica, it's my responsibility --

    THE WITNESS: I know.

    THE FOREPERSON: -- to remind you you're still under oath.

    THE WITNESS: Okay. Thank you.

    BY MR. EMMICK:

    Q We just finished talking about January 5th. Why don't we turn to January 6th. On January 6th, did you pick up a copy of the draft affidavit from Frank Carter?

    A Yes, I did.

    Q You had mentioned earlier that you wanted Vernon Jordan to look at it. Did you contact him?

    A Yes, I did.

    Q Did you speak with him personally or did you speak with someone on his staff?

    A I don't really remember.

    Q And did you try to get a copy of the draft affidavit to Mr. Jordan?

    A Yes. I dropped off a Xerox copy in his office.

    Q In his office?

    A In the lobby of his -- of Akin Gump.

    Q Did you make any arrangements to contact him in order to talk about the draft affidavit?

    A I believe -- I think I remember Gail saying he was in a meeting and something about 4:OO, that he was going to be out and he would call me at 4:00.

    Q Did you talk with him on the affidavit?

    A Yes, I did.

    Q All right. Tell us what the two of you talked about.

    A I had had some concerns from looking at the draft affidavit and addressed those concerns with him and he agreed.

    Q What were the nature of the concerns, if you remember?

    A I think that the general concern was that Mr. Carter had inserted some information about me having possibly been alone with the President for a few minutes, bring him a letter in Legislative Affairs.

    Q Would it help you if I showed you a copy of the draft with some of your handwriting on it?

    A Oh. Yes.

    MR. EMMICK: I'm placing before the witness what is marked as Grand Jury Exhibit ML-3.

    (Grand Jury Exhibit No. ML-3 was

    marked for identification.)

    BY MR. EMMICK:

    Q Can you tell us what this is?

    A Sure. Do the grand jurors have a copy of this?

    Q They do.

    A Okay. This is a draft of my affidavit that Mr. Carter drew up based on his conversations with me.

    Q And the handwriting on it? Whose is that?

    A That's my handwriting.

    Q There's also some underlining and some scratch-outs.

    A Mh-hmm.

    Q Did you do all of that?

    A Yes.

    Q Can you remember looking at that now what the two of you talked about?

    A I think that -- I think that it was -- I think the two main things were this last sentence in paragraph 6 and the -- the concern was, for me at least, was not wanting to give the Paula Jones attorneys any thought about why they might need to want to talk to me. So if I had mentioned that I had been in there alone, it would kind of make them thing, oh, well, what happened and did he proposition or blah, blah, blah.

    And then the second thing was in the -- towards the end of paragraph 8 on page 2, the idea of with crowds of other people, I think to me was too far from the fake truth?

    Q Okay.

    A Does that -- is that clear? Sort of -- that that seemed to be too out of the realm of possibility, so --

    Q Too implausible?

    A Exactly. Thank you. So I believe that, you know, that this statement, "There were other people present on all of these occasions," was something that I discussed with Mr. Jordan.

    Q Did he agree with the suggestions or thoughts that you had on those two passages?

    A Yes, I believe so.

    Q Was there any discussion with Mr. Jordan about the portion of paragraph 8 saying that there was no sexual relationship?

    A No.

    Q At any time, did Mr. Jordan say that he didn't want to speak to you about the affidavit?

    A No.

    Q How long was your conversation with Mr. Jordan?

    A I don't remember. Not long. We may have also talked about job stuff, too. But --

    Q All right, then. Let's turn our attention to the next day, which is the 7th. That's the day when you finalized and signed the affidavit. Is that right?

    A Yes.

    Q And you notarized it under penalty of perjury.

    A Yes.

    MR. EMMICK: I believe you have -- this is the final version and it is Grand Jury Exhibit ML-4.

    (Grand Jury Exhibit No. ML-4 was

    marked for identification.)

    BY MR. EMMICK:

    Q I'm placing that before you.

    A Okay.

    Q And it says ""Affidavit of Jane Doe No. 6" at the top and it has your signature, right?

    A Mm-hmm.

    Q When you spoke with Frank Carter that morning in order to finalize the affidavit, do you remember what changes were made?

    A When I spoke with him before I arrived at his office or in his office?

    Q Either time.

    A I believe that I sort of dictated to him the changes -- I think that's possible or I gave them to him in person, I don't really remember. Mr. Carter had prepared three different versions of the affidavit for the significant portion related to this case, I guess, they were all denying sexual relations, all three of them. And we discussed various things about it and eventually decided on this affidavit.

    Q All right. Let me ask you a straightforward question. Paragraph 8 at the start says, "I have never had a sexual relationship with the President." Is that true?

    A No.

    Q All right. The next logical follow-up is, and maybe it's self-evident, but why were you willing to say something that was false under penalty of perjury?

    A I don't think that it's anybody's business.

    Q Okay. Let me turn the page for you. At the end of paragraph 8, the statement, "The occasions that I saw the President after I left my employment at the White House in April 1996 were official receptions, formal functions or events related to the U.S. Department of Defense, where I was working at the time. There were other people present on those occasions." That's not correct either, is it?

    A No, it's misleading.

    Q Okay. In what respect?

    A For me, at the time, I said -- well, it doesn't say the only occasions, but it's misleading in that one reading it would assume that the only occasions on which I saw the President were those listed.

    Q Right.

    A But I did some justifying in signing the affidavit, so --

    Q Justifying -- does the word "rationalizing" apply as well?

    A Rationalize, yes.

    Q All right. All right. On the 7th, after you signed the affidavit, did you keep a copy of the affidavit?

    A Yes, I did.

    Q Where did you go later on the 7th?

    A To New York.

    Q Did you take a copy of the affidavit with you?

    A Yes.

    Q Why?

    A If I remember correctly, I was in a rush and I kind of wanted to have it, if I wanted to look it over again or --

    Q Why were you going to New York?

    A A job interview.

    Q Did you have a job interview?

    A Yes, I did.

    Q Was that the next day?

    A Yes.

    Q All right. Let's turn our attention to the job interview on the morning of the 8th. Now, was that with McAndrews & Forbes?

    A Yes. This is my -- I had -- I mean, just to remind everyone, I had had some job interviews on the 18th of December up in New York at McAndrews & Forbes and Burson-Marsteller. I also took a test on the 30th, I think, of December at Burson-Marsteller and this is now another interview at McAndrews & Forbes on the 8th.

    Q Do you remember who you interviewed with that morning?

    A Jamie Dernan.

    Q How did the interview go?

    A Very poorly.

    Q Okay. Tell us why it went poorly. What do you mean?

    A I think it started off on the wrong foot because I was in a waiting room downstairs and I had thought they would let me know when he was available and I'd go to his office and instead he just walked in unannounced and the interview started, so I was -- I didn't have my wits together at the moment. And I was -- I just was sort of flustered from that moment on. I think everyone can relate to having a bad interview. Maybe.

    Q How long was the interview?

    A Maybe 20 minutes.

    Q Was that the only interview that morning?

    A Yes.

    Q What was your reaction afterwards?

    A I was upset. I felt horrible. I might have even cried. I was embarrassed. I thought that I had sort of embarrassed Mr. Jordan, I think, in such a bad interview.

    Q After having a bad interview like that, did you expect an offer?

    A No, I didn't think so. My first interview with McAndrews & Forbes had been really, really good, so I wasn't sure exactly what was going to happen, but I didn't think it was --

    Q Not a good sign.

    A Correct.

    Q What did you do after you had that bad interview?

    A At some point, I called Mr. Jordan to just let him know that it had gone poorly.

    Q Do you remember whether you placed on call or several calls to try to get a hold of him?

    A I'm sure I placed several. It was -- he's difficult to get a hold of.

    Q Did you eventually talk to him on the 8th?

    A Yes, I did.

    Q What did you tell him?

    A I told him that it hadn't worked out and that I was asking his advice on whether I should contact Burson-Marsteller or not and that I was concerned that the McAndrews & Forbes hadn't gone well.

    Q At the time you were talking to him, were you still upset about the interview?

    A I don't really remember. I'm sure I was. It was kind of a depressing thing all day.

    Q And did he say what he was going to do because the interview had not gone well?

    A Yes.

    Q What did he say?

    A He said he'd call the chairman. I thought he was kidding.

    Q Okay. And did he call you back some time shortly thereafter?

    A Yes, he did.

    Q About how long after he called -- excuse me. About how long after he said he was going to call the chairman did he call you back? If you remember.

    A I don't remember. I don't think it was very long after, but --

    Q What did he say when he called back?

    A That not to worry -- you know, I don't remember the exact words that he used. The gist of the conversation was that, you know, the were going to call me and everything was going to be okay.

    Q Did he say that he had gotten a hold of the chairman or did he mention that at all or --

    A I don't remember.

    Q Did Revlon or McAndrews & Forbes personnel get a hold of you later after Mr. Jordan called?

    A Yes. They called to set up an interview for me with someone directly at Revlon for the next day.

    Q Do you remember about when it was that you were called later on the 8th?

    A I think it was some time early evening.

    Q Early evening?

    A Or evening.

    Q Were you surprised by the call?

    A From having heard from Mr. Jordan, not 100 percent.

    Q All right. They set up an interview for the next day?

    A yes.

    Q Did you have an interview the next day?

    A Yes.

    Q Who did you interview with?

    A Ellen Seidman.

    Q And what was the tone of that interview?

    A It went very well. It was --

    Q Better than with Jamie Dernan?

    A Yes.

    Q All right.

    A It was a very good interview.

    Q Did you interview with others at Revlon as well?

    A Yes.

    Q Do you remember about how many interviews there were?

    A Two others, aside from Ms. Seidman's.

    Q And you mentioned that the interviews went well. After the interviews, did you give a call to Vernon to let him know how things were going?

    A I think so.

    Q Later that day, did you have another call from Revlon?

    A From Revlon?

    Q Mm-hmm.

    A Yes, I did.

    Q Tell us about that.

    A They sort of informally offered me a position and I informally accepted it.

    Q Do you remember who it was you were speaking with at the time?

    A I believe it was Ellen Seidman.

    Q Okay. You made a reference earlier in this grand jury appearance to a conversation you had with Linda Tripp on the 9th.

    A Yes.

    Q We're now on the 9th and I can tell you would like to talk about this conversation. Tell us about your conversation with Linda Tripp on the 9th. Let's start with when it happened.

    A Well, I was returning Linda's call from earlier in the week and I think I made a couple of attempts to get a hold of her at her office and when I did get in touch with her, I told her I was on a pay phone because I was concerned about the phones.

    And I just -- I -- I didn't -- I was very distrustful of her at this point, especially when I first got on the phone with her. I didn't really know why we were going to be in touch at this point, from what had happened the few weeks before.

    So she started out the conversation, I think, asking me, you know, what was going on with my job stuff and everything and I told her I didn't have a job yet and that I hadn't heard from Betty, the President, or Mr. Jordan since December and I didn't know what was going on and so we were discussing that. And that was not true, obviously.

    And then she told me that she had gone up to New York over Christmas to be with -- I think Norma Asness is her name, and that while she was in New York during the holidays she was shopping with Ms. Asness and this other woman on Madison Avenue buying shoes and that this woman had told Linda she was really savvy and Linda should move to New York and get a PR job in New York. Which I thought was a little strange, since I was in the process of moving to New York for a PR job.

    That was just one of the indications that made me think she was a little bit jealous of the help I was getting, that I was talking about earlier.

    So when we started to discuss the case, she told me that -- that because of this experience she had had in New York, she decided that maybe it would be best for her to be really vague on the truth about Kathleen Willey. You know, she really didn't know anything, she didn't really remember much, and that -- you know, led me to -- and I believe she may have even said directly that she wasn't going to tell about me or that I was -- you know, my understanding of that was that she wasn't even going to mention me and that I was safe.

    Q Did this come as a surprise to you?

    A Yes, it did.

    Q In what way?

    A Because she had -- I mean, she had stopped returning my phone calls, we had left everything in a very bad note a few weeks prior to that. So --

    In the course of this conversation, when we talked about my job, she said, "Well, Monica -- " Oh. Oh. She asked me what I was going to do in the case and I told her that I was planning on signing an affidavit. Even though I had already signed the affidavit, I didn't want Linda to think that I would have gone ahead and done such a bold thing without her approval.

    So she made -- that's when, as I mentioned earlier, she made me promise her that I wouldn't sign the affidavit until I got the job. She also went into this whole long story about her friend --

    Am I getting into too much detail?

    MR. EMMICK: Close.

    JURORS: No. No.

    MR. EMMICK: Okay.

    THE WITNESS: Okay. All right. She told me about her -- this friend, I don't remember her name, but she's this -- she's an Indian woman who Linda goes to the gym with and that this Indian woman had gone to a psychic and the psychic had essentially said that one of her friends was in imminent danger having to do with the words she would speak.

    So that that led Linda to believe, you know, along with this event in New York that she should -- you know, she's kind of going to go the good route -- well, what I considered the good route in the Paula Jones case. And it was really based on this conversation that I had with her and this sort of change that I agreed to meet with Linda on the 13th of January.

    BY MR. EMMICK:

    Q Then let's go to the 13th of January. Let me first cover some of the job-related items. On the 13th, did you get a formal offer from Revlon?

    A Yes, I did.

    Q And did you accept that offer?

    A Yes, I did.

    Q How was the matter left about references or recommendations?

    A Well, she -- I can't remember her name, something with a J, I think. The woman in human resources with whom I was dealing about the job offer said, you know, I needed to send her some references, so this had been in -- oh. So I called Betty to ask her to remind the President or to check out for me what Mr. Hilley would say to -- I'm not saying this clearly. I'm sorry.

    Q That's all right.

    A One of the people that I needed to get a reference from was John Hilley, who was the head of Legislative Affairs and had been my boss when I was there the latter half of my tenure at the White House. I was concerned that if I put him down as a reference, he might not say flattering things about me.

    So I asked -- I had mentioned this to the President on October 11th and he said he'd, you know, make sure everything was okay, so I wanted to -- so I checked with Betty to ask her to kind of find out what was happening, what the status of that was. So --

    Q Did you get a message later from Betty on that subject?

    A Yes, I did.

    Q Okay. What was that message?

    A She had me page her and then later I came to find out from her that afternoon that it had been -- I think Mr. Podesta took care of it and that everything would be fine with Mr. Hilley.

    Q Now, when the two of you were paging each other on this day, the name Kay was used rather than either Betty or Monica. Where did that name come from?

    A This has sort of become a kind of strange area for me. I had not -- and I do not specifically remember discussing with Betty the fact that I had been subpoenaed in the Paula Jones case and anything surrounding that, but sort of I now know from -- from sort of things that I've been reminded of or shown that I must have. And one of them that indicates that to me is this notion that she -- I -- she and I had started -- I suggested that we use sort of the code name Kay in her paging me and in me paging her. And --

    Q And where does the name Kay come from?

    A Because Betty and I, our first encounter and our first connection was through Walter Kaye.

    Q Now, had you and Betty had earlier conversations about the fact that her message indicator, I guess it would be her beeper or her pager?

    A Her pager.

    Q Her pager.

    A Her text message pager.

    Q Her text message pager on some occasion might have indicated Monica?

    A Yes. There had been -- I think there had been at least one time when Betty's pager had been sitting on her desk when she was in with the President or had stepped away and someone else had picked up her pager when it went off and there was a message from me.

    And so from -- you know, Betty kind of covered it, I think, by saying -- or she did actually have another friend named Monica or something or another, but it was -- you know -- Rebecca Cameron was the person who picked up the pager and so it was sort of a -- not a good thing to happen.

    Q Why use any fake names, Kay or any other name? What's the reason you've got to use fake names at this time?

    A I was beyond paranoid. I mean, I -- and obviously in denial. I think the -- I could not understand how I had been dragged into the Paula Jones case and so I was very wary of everything.

    Q What did Betty say, if you can remember, when you suggested that you refer to one another as Kay?

    A Okay.

    Q Okay. Did she ask why or --

    A I don't remember having this conversation with her.

    Q All right. Were you also using names to refer to others? For example, the name Mary?

    A Yes.

    Q Who did Mary refer to?

    A Linda.

    Q And why were you using the name Mary to refer to Linda?

    A Because that's what she chose.

    Q And why were you using any name other than Linda to refer to Linda?

    A Because Linda and Betty were the two people who paged me that were involved -- you know, somehow fell into this circle of the Paula Jones story. Is that -- it's not clear. I'm sorry. Okay.

    Q When you were speaking with Linda about the President, did you sometimes refer to the President as "her" rather than "him"?

    A Linda? No. I don't believe so.

    BY MS. IMMERGUT:

    Q So that was Betty?

    A Yes.

    BY MR. EMMICK:

    Q Okay. And why did you use "her" to refer to the President?

    A I believe that that was only in pages to her and it was just -- you know, I knew that the WAVES -- from having worked at the White House, I knew that people had access to the WAVES pages, let alone that someone types them, so it just was another measure of caution that I used throughout.

    Q All right.

    A I don't think I ever referred to the President on Betty's pages.

    Q When we were talking earlier about your clarifying whether John Hilley would give you a recommendation, you indicated that you had a page from Betty. Does it refresh your recollection about what the page said if I were to read the following?

    We have a page indicating that it says, "Will know something soon, Kay." Does that remind you about any pages that you got from Betty?

    A Yes, I think I mentioned earlier that she paged me and then I talked to her later that day and found out about John Hilley.

    Q All right. did you -- at some point, did you send to Revlon a letter giving them the two recommendations, one of which was John Hilley?

    A Yes.

    Q Do you remember when that was?

    A I believe I faxed it on the 14th of January.

    Q So that would be the next day.

    A Correct.

    BY MR. WISENBERG:

    Q Pardon me. Were they recommendations or references? Just as a technical matter, in other words, were they names or were they actual letters of recommendation?

    A Oh. They were references, then.

    BY MR. EMMICK:

    Q All right. Let's go back to the 13th for just a moment because you met with Linda Tripp that day, I think you said, on the 9th you had --

    A I also met with Mr. Jordan.

    Q Okay. All right. Okay. Well, let's go back to Mr. Jordan, then.

    A Well, I -- I mean, I was just thinking about the day. I'm sorry.

    Q No, that's fine. That's fine.

    A Just I stopped in to see him for five minutes, to Thank him for getting me the job, and I gave him a tie and a pocket square.

    MR. EMMICK: Okay.

    BY MS. IMMERGUT:

    Q Did you ever provide Mr. Jordan with a signed copy of the affidavit?

    A I did not provide him with a copy. No.

    Q Do you know whether or not he ever received a copy?

    A I believe I showed him a copy. I don't know that he received a copy.

    BY MR. EMMICK:

    Q On this same meeting on the 13th?

    A I -- I -- you know, I have to say I know I brought the copy with me to show him and I may have said, you know, "Do you want to see it?" And I think he may have not even --I think he may have said, you know, "I don't need to see it." Or -- I --

    BY MS. IMMERGUT:

    Q So you don't specifically recall handing it over tohim or even showing it to him specifically.

    A No.

    Q But you brought it for him to --

    A I did bring it.

    MS. IMMERGUT: Correct.

    BY MR. EMMICK:

    Q All right. So that's the Vernon Jordan part of the 13th.

    A Right.

    Q What about the meeting with Linda Tripp?

    A It was long. I was -- I was very nervous. I was wary of her. I actually thought she might have a tape recorder with her and had looked in her bag when she had gone up to the restroom. I told her a whole bunch of lies that day.

    Q What were you trying to accomplish in meeting with her?

    A I was trying to -- I was trying to make Linda continue to feel comfortable that she and I were sort of on the -- that we were on the same side, we were on the right side.

    We -- and that -- when I had agreed to meet with her, I thought we were going to go over kind of her strategy for what she was going to do in the case and then once we got together, she kind of started wavering about what she wanted to do and then -- so I just was using everything I knew to try to convince he that -- that this is the right thing to do.

    Q I think you mentioned earlier that you told her lies.

    A Yes.

    Q What lies do you have in mind?

    A I mean, I think -- throughout that month of December, after I knew she was subpoenaed, there were various things that I think I said that were untrue, but I specifically remember from this meeting the thing that I had -- what I said to Linda was, "Oh, you know, I told -- I told Mr. Jordan that I wasn't going to sign the affidavit until I got the job." Obviously, which wasn't true.

    I told her I didn't yet have a job. That wasn't true. I told her I hadn't signed the affidavit. That wasn't true. I told her that some time over the holidays I had freaked out and my mom took me to Georgetown Hospital and they put me on Paxil. That wasn't true.

    I think I told her that -- you know, at various times the President and Mr. Jordan had told me I had to lie. That wasn't true. That's just a small example. Probably some more things about my mom. Linda had an obsession with my mom, so she was a good leverage.

    Q Let's turn our attention back to the 14th, then. On the 14th, the next day?

    A Okay.

    Q Right.

    A Okay.

    Q There's three pieces of paper that have come to be referred to as the talking points.

    A Yes.

    MR. EMMICK: I think we have them marked as Grand Jury Exhibit ML-5.

    (Grand Jury Exhibit No. ML-5 was marked for

    identification.)

    BY MR. EMMICK:

    Q I'll place them in front of you.

    A Okay.

    Q And they are three pages. I wonder if you tell us how those came to be written and on what computer and the like.

    A Okay. First of all, they're out of order.

    Q Okay.

    A So the last page was actually the first page.

    Q All right. Well, let's clarify. What is now the first page says "Points to make in affidavit." And the second page says, "The first few paragraphs" at the top. And the third page says, "You're not sure you've been clear." The third page should be the first page?

    A Yes.

    Q All right. Let's go to first the mechanics of how these got generated.

    A Mm-hmm.

    Q Were those printed from your printer?

    A Yes.

    Q Were they typed on your computer?

    A Yes.

    Q Was anyone present with you when they were typed?

    A No.

    Q When were they typed?

    A On the 14th.

    Q Did you talk with anyone in an effort to get assistance editing or writing or getting approval for what is in the talking points?

    A No.

    Q How did the -- where did you get the ideas that are reflected in the talking points?

    A They were based on conversations I've had with Linda from the moment Kathleen Willey and Michael Isikoff ever entered into the picture until the conversations I had with her in the morning of the 14th on the phone.

    Q Tell me what you mean by that.

    A At various times, especially early on, around March or so when -- when Kathleen Willey first came up, Linda talked about how -- you know, that -- that -- what Kathleen was saying to Michael Isikoff was not true. And so, you know, we had had -- I remember having this discussion with her where we were saying, well, if -- you know, if she's lying to Michael Isikoff, how do you know she didn't lie to you?

    Linda said, "Yeah, that's a good point. Maybe she did." You know?

    And I said, "Yeah, sure. She could have, you know, smeared her own lipstick and untucked her own blouse."

    And Linda said, "Yeah, it's true."

    That was very early on and throughout my discussions with Linda, especially when she was saying -- saying things about how to be vague on the Kathleen Willey issue in the Paula Jones case, we had these sorts of discussions.

    Q What did you do with the talking points? How did you relay them to Linda Tripp?

    A I took a copy of them to her.

    Q And how were the arrangements made to give her that copy?

    A She had told me she was going to go see her attorney, Kirby, that afternoon and was going to talk to him about signing an affidavit, which is why this was all generated. And so I offered to drive her there so that we could just talk on the way because we -- we had some time to talk that morning, but not as much as I wanted.

    Q Who was driving? You were driving?

    A Yes.

    Q And Linda has the talking points in her hands?

    A I handed them to her in the parking lot of the Pentagon.

    Q Did she read them?

    A Yes, she did.

    Q What was she saying or doing as she was reading them?

    A She was going through it and she was sort of reading and going, "Yeah. Mm-hmm. Uh-huh. Well, that's true. Oh, good point."

    I think she may have said, "Oh, these are --this is really --that's true." You know. "Did you write this?" Sort of a thing.

    Q Okay. What did you think would happen after you dropped the talking points off to Linda and then you dropped Linda off? How were things left, I guess is another way to ask that question.

    A I believe that it was in the car ride home that she said -- made some comment to me about -- that, well, she -- she feels okay -- and this might have been on the 13th when she said this, she feels okay about, you know, kind of not telling the truth or being vague on the truth when she talks to me, but then when she doesn't talk to me, she -- her mind starts to wander to different things, so I just remember feeling -- oh, like I had to hold her hand through everything and I constantly had to talk to her. So I may have said, "I'll call you tonight" or something like that.

    Q Have you ever talked to Bruce Lindsey?

    A No. I may have said hello them in the hall, but I --but -- just in passing.

    Q Did you ever talk with the President about the talking points?

    A No.

    Q Did you ever talk with anyone at Bob Bennett's firm about the talking points?

    A No.

    Q Did you ever talk with anyone associated with the White House in any way about the talking points?

    A No. And that would include Mr. Jordan.

    Q Okay. Let's turn our attention, then, to the next day, which is January 15th. Did Betty call you that day about a call she had received from Mike Isikoff?

    A Yes.

    Q Okay. Tell us about that telephone call.

    A I had learned earlier from my attorney that the Paula Jones people had -- had -- well, I guess my attorney had asked me something about if I had ever received any courier packages from the White House and I hadn't, but I told him I did -- I did send things to Betty and he said, oh, well, he had heard -- I think through -- maybe through Bennett's people -- Mr. Bennett's firm, the attorneys, I'm sorry, I don't mean to be so informal, that there was some issue with these courier -- with a courier service.

    So, I called the courier service and was unable to find out that the records could be subpoenaed and then I spoke with Betty later that day and she told me that -- that Michael Isikoff had called her or had called for her intern and Betty had answered the phone and in the course of that he asked her about the courier, my sending things to her through a courier.

    And that she sort of said she didn't really remember or know what he was talking about and that he'd get back to her. Or she'd get back to him. I'm sorry.

    Q And then she called you and related this to you?

    A Yes. Yes.

    Q What was your reaction to that?

    A I was very shocked and very -- feeling very strange, that somehow this was closing in more and I -- I didn't know how they could have gotten this information about the courier because there was -- the first person that I thought of that knew about the courier was Linda and the only other person I thought of was this gentleman in my office who was a Clinton hater, Mark Huffman. So, I thought that maybe -- I thought, well, maybe he had been the one who had sort of turned me, trying to cause trouble.

    Q All right. What did you and Betty talk about doing in response to the Iskikoff calls?

    A The president was out of town that day and so I think she said she was going to try to get in touch with the President and I believe that Betty and I may have discussed that, you know, they were -- the courier packages were always sent to her and that some of the things were for her, you know.

    Q Did Vernon Jordan come up?

    A Yes. I know later -- and I don't know if maybe she mentioned to me earlier in the day that she wanted to try to get in touch with Mr. Jordan, but I do know that -- that later in the evening Betty called me and asked me if I could give her a ride to Mr. Jordan's office because Bob, her husband, had the car that day and it was raining. So --

    Q So you drove her to Vernon Jordan's.

    A Yes.

    Q Describe what happened when you drop her off.

    A Well, actually, I parked the car and I decided to wait for her downstairs in the restaurant. I think it's The Front Page. And she went up to Mr. Jordan's office and was there maybe 15, 20 minutes. I'm not very good with time.

    Q Why didn't she just take a taxi there? It's a three, four dollar taxi ride up there.

    A I don't know.

    Q Okay. How long did you wait?

    THE WITNESS: You know, I need to use the restroom.

    MR. EMMICK: Okay.

    THE WITNESS: I'm sorry.

    MR. EMMICK: The witness needs a break.

    THE FOREPERSON: Yes.

    MR. EMMICK: Okay. Thank you.

    THE WITNESS: Two minutes.

    MR. EMMICK: That's all right.

    (Witness excused. Witness recalled.)

    MR. WISENBERG: Let the record reflect the witness has reentered the grand jury room.

    Madam Foreperson, do we have a quorum?

    THE FOREPERSON: Yes.

    MR. WISENBERG: Any unauthorized persons present?

    THE FOREPERSON: None.

    MR. WISENBERG: Anything you want to say?

    THE FOREPERSON: Monica Lewinsky, I just wanted to let you know that you are still under oath.

    THE WITNESS: Really?

    THE FOREPERSON: Mm-hmm. Yes, mean.

    BY MR. WISENBERG:

    Q I have, I hope, just one or two questions about your proffer.

    A Okay.

    Q Your written proffer. Can you grab a hold of that?

    A Sure.

    Q And what are we calling that? That is ML-1.

    A Okay.

    (Grand Jury Exhibit No. ML-1 was marked

    for identification.)

    BY MR. WISENBERG:

    Q If you'll take a look at page 4, paragraph 4, that has to do with the President's call to you.

    A Yes?

    Q At two a.m. on the 17th of December telling you, among other things, that you're on the witness list, correct?

    A Correct.

    Q Going to the middle portion, starting with "When asked." "When asked what to do if she was subpoenaed, the President suggested she could sign an affidavit and try to satisfy their inquiry and not be deposed."

    A Mm-hmm.

    Q The next sentence says, "In general, Ms. L. should say she visited the White House to see Ms. Currie and, on occasion, when working at the White House, she brought him letters when no one else was around."

    Have you read that correctly? Have I read that sentence correctly?

    A Yes.

    Q Okay. And I think you have earlier described that as a -- maybe not in these exact words, but you saw it as a continuation on his part of the pre-established pattern of things he had said in the past. Is that correct?

    A Yes.

    Q All right. And would you agree with me that that is --that if you said that to the Jones people or to anybody else that that is misleading in a sense because it doesn't tell the whole story of what you were doing when you visited the President.

    A Yes.

    Q Take a look at -- then I would like you to take a look at page 10, I think it's page 10, it's paragraph 10, whatever page it is.

    A Okay.

    Q Mine's cut off. It's the last -- I think it's the last page.

    Q I'll read it. "Ms. L. had a physically intimate relationship with the President. Neither the President nor Mr. Jordan or anyone on their behalf asked or encouraged Ms. L. to lie." I would like you for us to reconcile if you can that statement in your proffer with statements like the ones in paragraph 4 where you talk about specific things the President said or did that were kind of continuations of this pattern.

    A Sure. Gosh. I think to me that if -- if the President had not said the Betty and letters cover, let's just say, if we refer to that, which I'm talking about in paragraph 4, page 4, I would have known to use that.

    So to me, encouraging or asking me to lie would have --you know, if the President had said, "Now, listen. You better not say anything about this relationship, you better not tell them the truth, you better not --"

    For me, the best way to explain how I feel what happened was, you know, no one asked or encouraged me to lie, but no one discouraged me either.

    Q Okay. so you said what you would have done if the President hadn't said that, but he did say that, what you mentioned in paragraph 4, correct?

    A Right.

    Q And I guess -- and you had a conversation with him about what to do gifts that you both knew were under subpoena, then you get the call from Betty. Those things happened. When we discussed this on Monday in the proffer session, I think you said something to the effect of or that in paragraph 10 you were being pretty literal. Is that accurate? When you say that no one encouraged you -- told you or encouraged you to lie?

    A Yes and no. I mean, I think I also said that Monday that it wasn't as if the President called me and said, "You know, Monica, you're on the witness list, this is going to be really hard for us, we're going to have to tell the truth and be humiliated in front of the entire world about what we've done," which I would have fought him on probably. That was different.

    And by him not calling me and saying that, you know, I knew what that meant. So I -- I don't see any -- I don't see any disconnect between paragraph 10 and paragraph 4 on the page. Does that answer your question?

    BY MS. IMMERGUT:

    Q Did you understand all along that he would deny the relationship also?

    A Mm-hmm. Yes.

    Q And when you say you understood what it meant when he didn't say, "Oh, you know, you must tell the truth," what did you understand that to mean?

    A That -- that -- as we had on every other occasion and every other instance of this relationship, we would deny it.

    MR. WISENBERG: That's all I have on that. And probably not anything else. Maybe.

    MS. IMMERGUT: I had a couple of quick questions.

    THE WITNESS: Sure.

    BY MS. IMMERGUT:

    Q Back for just a moment to January 15th with the visit when you took Betty to Vernon Jordan after she had been called by Michael Isikoff.

    A Mm-hmm.

    Q Did you ever tell Ms. Currie that you had been called by Michael Isikoff?

    A No.

    Q Had you ever been called by Michael Isikoff before January 15th?

    A No. I'm trying to remember now -- I know that I had seen the Newsweek thing light up on my caller ID, but I don't remember if that was around that time or if that was later, once the scandal started.

    Q Do you recall any calls from Michael Isikoff that you would have told Betty about, calling about gifts from the President?

    A No. Absolutely not.

    Q You mentioned, obviously, that you've given the President several gifts. Have you given him any ties.

    A Yes.

    Q How many ties have you given him, just approximately?

    A Six.

    Q Have you had any conversations with the President about wearing your ties?

    A Almost all of our conversations included something about my ties.

    Q Could you just briefly describe what things that you've said to him and he to you about wearing the ties?

    A I used to bug him about wearing one of my ties because then I knew I was close to his heart.

    Q And did he ever say anything about -- after he had one of your ties or to alert you when he had worn any of your ties?

    A Yes, there were several occasions.

    Q And what kind of thing would he say to you?

    A "Did you see I wore your tie the other day?"

    Q So was he aware based on things you had told him that you would be looking out for when he would wear ties on various occasions?

    A Yes.

    MS. IMMERGUT: I'd like to show you now what's marked as Grand Jury Exhibits ML-8, 9 and 10.

    (Grand Jury Exhibits No. ML-8, ML-9 and

    ML-10 were marked for identification.)

    MS. IMMERGUT: And, unfortunately, I don't have copies yet for the grand jury because we got them at the last --

    MR. WISENBERG: I'll pass them around afterwards.

    MS. IMMERGUT: Okay. And I'll spread them out for you here.

    THE WITNESS: Okay.

    BY MS. IMMERGUT:

    Q Directing your attention first to ML-8, it's a photograph of the President, obviously. Do you recognize the tie that he's wearing in that photograph?

    A Yes, I do.

    Q Had you actually seen that on television on June 24, 1998?

    A Yes, I did.

    Q Do you recall what that's in relation to or what event is being depicted on that photograph?

    A He was leaving for China.

    Q And now directing your attention to Exhibit 9, do you know what that's a photograph of?

    A I don't know where it's from, but it's the President wearing my tie.

    Q And this one states it's Monday, July 6, 1998. Do you remember watching any of the media on that date?

    A Yes, I do.

    Q And do you remember seeing him wearing your tie on that date?

    A Yes, I do.

    Q Do you remember what event was taking place on that date that he was wearing your tie?

    A I don't, but I just saw it says "Medicare costs," so --

    Q Okay. And then finally, ML-10. Do you recognize what that's a photograph of?

    A Yes.

    Q And what is that?

    A The President wearing the same tie.

    Q And do you know what date that is?

    A Date? It was a few days after, he wore the tie when he came back from China, so it's July 9th.

    Q Okay. And what -- I guess -- did you reach any conclusions from the fact that he was wearing your tie on those days?

    A I -- -- I think -- the first time he wore the tie, I thought maybe it was a coincidence, but I didn't really think so. And then when he wore it when he came back from China on the 6th, I thought maybe it was a reminder of July 4th, because that had been the first workday after July 4th and we had had a really intense, emotional meeting July 4th of '97. And then when he wore it a few days later, I thought he's trying to say something. I mean, the President doesn't wear the same tie twice in one week, so -- I didn't know what it meant, but it was some sort of a reminder to me.

    MS. IMMERGUT: Okay. Nothing further on that.

    BY MR. WISENBERG:

    Q This is well after the scandal broke, is that correct?

    A Yes.

    BY MS. IMMERGUT:

    Q This is this summer, right?

    A Correct.

    BY MR. WISENBERG:

    Q You've told us something about seeing a picture of Nelvis, Bayani Nelvis, I think coming to the grand jury.

    A Yes.

    Q Can you tell us -- and you noticed something about some neck wear her was wearing?

    A I think it was on Nel's maybe third appearance or his last appearance. He was wearing the first tie that I ever gave to the President.

    Q Did you know that the President had ever given that tie to Mr. Nelvis?

    A no.

    Q And what is -- can you recall the last time the President had ever worn that tie?

    A No. I didn't see him every day, so -- I mean, I know he -- I know some of the times he wore that tie, but I don't know the last time he wore the tie.

    Q Okay. Is there any question in your mind that the President knew that both these ties, the one that we're putting around pictures of and the one that Nel wore to the grand jury, were ties you have given him?

    A Not in my mind, but I can't -- I can't answer that.

    MR. WISENBERG: Okay.

    MR. EMMICK: There's a question? Yes.

    A JUROR: Did you know the President after a while gave his ties to the people who worked for him? Did you know that?

    THE WITNESS: Yes, I did know that.

    MR. WISENBERG: Pardon me just a minute.

    (Pause.)

    MR. WISENBERG: I'm going to ask the witness to be excused very briefly and we'll possibly call you back in a couple of minutes.

    (The witness was excused.)

    (Whereupon, at 4:45 p.m., the taking of testimony in the presence of a full quorum of the Grand Jury was concluded.)