Clinton's answers -- Part II

35-36. Do you admit or deny that you viewed a copy of the affidavit executed by Monica Lewinsky on Jan. 7, 1998, in the case of Jones v. Clinton at your deposition in that case on Jan. 17, 1998? Do you admit or deny that you had knowledge that your counsel viewed a copy of the affidavit at your deposition ... ?
I know that Mr. Bennett saw Ms. Lewinsky's affidavit during the deposition because he read portions of it out loud at the deposition. I do not recall whether I saw a copy of Ms. Lewinsky's affidavit during the deposition.
37. Do you admit or deny that on or about Jan. 9, 1998, you received a message from Vernon Jordan indicating that Monica Lewinsky had received a job offer in New York?
At some time, I learned that Ms. Lewinsky had received a job offer in New York. However, I do not recall whether I first learned it in a message from Mr. Jordan or whether I learned it on that date.
38-39. Do you admit or deny that between Jan. 9, 1998, and Jan. 15, 1998, you had a conversation with Erskine Bowles in the Oval Office in which you stated that Monica Lewinsky received a job offer and had listed John Hilley as a reference? Do you admit or deny that you asked Erskine Bowles if he would ask John Hilley to give Ms. Lewinsky a positive job recommendation?
As I testified to the grand jury, I recall at some point talking to Mr. Bowles "about whether Monica Lewinsky could get a recommendation that was not negative from the Legislative Affairs office," or that "was at least neutral," although I am not certain of the date of the conversation. To suggest that I told Mr. Bowles that Ms. Lewinsky had received a job offer and had listed John Hilley as a reference is, as I testified, a "little bit" inconsistent with my memory. It is possible, as I also indicated, that she had identified Mr. Hilley as her supervisor on her resume and in that respect had already listed him as a reference.
41. As to each, do you admit or deny that you gave the following gifts to Monica Lewinsky at any time in the past?
a. A lithograph
b. A hatpin
c. A large "Black Dog" canvas bag
d. A large "Rockettes" blanket
e. A pin of the New York skyline
f. A box of cherry chocolates
g. A pair of novelty sunglasses
h. A stuffed animal from the "Black Dog"
i. A marble bear's head
j. A London pin
k. A shamrock pin
l. An Annie Lennox compact disc
m. Davidoff cigars
In my deposition in the Jones case, I testified that I "certainly ... could have" given Ms. Lewinsky a hat pin and that I gave her "something" from the Black Dog. In my grand jury testimony, I indicated that in late December 1997, I gave Ms. Lewinsky a Canadian marble bear's head carving, a Rockettes blanket, some kind of pin, and a bag (perhaps from the Black Dog) to hold these objects. I also stated that I might have given her such gifts as a box of candy and sunglasses, although I did not recall doing so, and I specifically testified that I had given Ms. Lewinsky gifts on other occasions. I do not remember giving her the other gifts listed in Question 41, although I might have. As I have previously testified, I receive a very large number of gifts from many different people, sometimes several at a time. I also give a very large number of gifts. I gave Ms. Lewinsky gifts, some of which I remember and some of which I do not.42. Do you admit or deny that when asked on Jan. 17, 1998, in your deposition in the case of Jones v. Clinton if you had ever given gifts to Monica Lewinsky you stated that you did not recall, even though you actually had knowledge of giving her gifts in addition to gifts from the "Black Dog"?
In my grand jury testimony, I was asked about this same statement. I explained that my full response was "I don't recall. Do you know what they were?" By that answer I did not mean to suggest that I did not recall giving gifts; rather, I meant that I did not recall what the gifts were and I asked for reminders.
43. Do you admit or deny that you gave false and misleading testimony under oath in your deposition in the case of Jones v. Clinton when you responded "once or twice" to the question "Has Monica Lewinsky ever given you any gifts?"
My testimony was not false and misleading. As I have testified previously, I give and receive numerous gifts. Before my Jan. 17, 1998, deposition, I had not focused on the precise number of gifts Ms. Lewinsky had given me. My deposition testimony made clear that Ms. Lewinsky had given me gifts; at the deposition, I recalled "a book or two" and a tie. At the time, those were the gifts I recalled. In my response to OIC inquiries, after I had had a chance to search my memory and refresh my recollection, I was able to be more responsive. However, as my counsel have informed the OIC, in light of the very large number of gifts I received, there might still be gifts from Ms. Lewinsky that I have not identified.44. Do you admit or deny that on Jan. 17, 1998, at or about 5:38 p.m., after the conclusion of your deposition in the case of Jones v. Clinton you telephoned Vernon Jordan at his home?
I speak to Mr. Jordan frequently, so I cannot remember specific times and dates. According to White House records included in the OIC referral, I telephoned Mr. Jordan's residence on Jan. 17, 1998, at or about 5:38 p.m.
45-47. Do you admit or deny that on Jan. 17, 1998, at or about 7:02 p.m., after the conclusion of your deposition in the case of Jones v. Clinton, you telephoned Betty Currie at her home? Do you admit or deny that ... at or about 7:02 p.m., ... you telephoned Vernon Jordan at his office? Do you admit or deny that ... at or about 7:13 p.m., ... you telephoned Betty Currie at her home and asked her to meet with you the next day, Sunday, Jan. 18, 1998?
According to White House records included in the OIC Referral, I placed a telephone call to Ms. Currie at her residence at 7:02 p.m. and spoke to her at or about 7:13 p.m. I recall that when I spoke to her that evening, I asked if she could meet with me the following day. According to White house records included in the OIC Referral, I telephoned Mr. Jordan's office on Jan. 17, 1998, at or about 7:02 p.m. 48. Do you admit or deny that on Jan. 18, 1998, at or about 6:11 a.m., you learned of the existence of tapes of conversations between Monica Lewinsky and Linda Tripp recorded by Linda Tripp?
I did not know on Jan. 18, 1998, that tapes existed of conversations between Ms. Lewinsky and Ms. Tripp recorded by Ms. Tripp. At some point on Sunday, Jan. 18, 1998, I knew about the Drudge Report. I understand that while the report talked about tapes of phone conversations, it did not identify Ms. Lewinsky by name and did not mention Ms. Tripp at all. The report did not state who the parties to the conversations were or who taped the conversations.
49. Do you admit or deny that on Jan. 18, 1998, at or about 12:50 p.m., you telephoned Vernon Jordan at his home?
According to White House records included in the OIC Referral, I telephoned Mr. Jordan's residence on Jan. 18, 1998, at or about 12:50 p.m.50. Do you admit or deny that on Jan. 18, 1998, at or about 1:11 p.m., you telephoned Betty Currie at her home?
According to White House records included in the OIC Referral, I telephoned Ms. Currie's residence on Jan. 18, 1998, at or about 1:11 p.m.
51. Do you admit or deny that on Jan. 18, 1998, at or about 2:55 p.m., you received a telephone call from Vernon Jordan?
According to White House records included in the OIC Referral, Mr. Jordan telephoned me from his residence on Jan. 18, 1998, at or about 2:55 p.m.
52. Do you admit or deny that on Jan. 18, 1998, at or about 5:00 p.m., you had a meeting with Betty Currie at which you made statements similar to any of the following regarding your relationship with Monica Lewinsky?
a. "You were always there when she was there, right? We were never really alone."
b. "You could see and hear everything."
c. "Monica came on to me, and I never touched her, right?"
d. "She wanted to have sex with me and I couldn't do that."
When I met with Ms. Currie, I believe that I asked her certain question[s] in an effort to get as much information as quickly as I could and make certain statements although I do not remember exactly what I said.
Some time later, I learned that the Office of Independent Counsel was involved and that Ms. Currie was going to have to testify before the grand jury. After learning this, I stated in my grand jury testimony, I told Ms. Currie, "Just relax, go in there and tell the truth."
53. Do you admit or deny that you had a conversation with Betty Currie within several days of Jan. 18, 1998, in which you made statements similar to any of the following regarding your relationship with Monica Lewinsky?
a. "You were always there when she was there, right? We were never really alone."
b. "You could see and hear everything."
c. "Monica came on to me, and I never touched her, right?"
d. "She wanted to have sex with me and I couldn't do that."
I previously told the grand jury that "I don't know that I" had another conversation with Ms. Currie within several days of Jan. 18, 1998, in which I made statements similar to those quoted above. "I remember having this [conversation] one time." I further explained, "I do not remember how many times I talked to Betty Currie or when. I don't. I can't possibly remember that. I do remember, when I first heard about this story breaking, trying to ascertain what the facts were, trying to ascertain what Betty's perception was. I remember that I was highly agitated, understandably, I think."
I understand that Ms. Currie has said a second conversation occurred the next day that I was in the White House (when she was), which would have been Tuesday, Jan. 20, before I knew about the grand jury investigation.
54. Do you admit or deny that on Jan. 18, 1998, at or about 11:02 p.m., you telephoned Betty Currie at her home?
According to White House records included in the OIC Referral, I called Ms. Currie's residence on Jan. 18, 1998, at or about 11:02 p.m.
55. Do you admit or deny that on Monday, Jan. 19, 1998, at or about 8:50 a.m., you telephoned Betty Currie at her home?
According to White House records included in the OIC Referral, I called Ms. Currie's residence on Jan. 19, 1998, at or about 8:50 a.m.
56. Do you admit or deny that on Monday, Jan. 19, 1998, at or about 8:56 a.m., you telephoned Vernon Jordan at his home?
According to White House records included in the OIC Referral, I called Mr. Jordan's residence on Jan. 19, 1998, at or about 8:56 a.m.
57. Do you admit or deny that on Monday Jan. 19, 1998, at or about 10:55 a.m., you telephoned Vernon Jordan at his office?
According to White House records included in the OIC Referral, I called Mr. Jordan's office on Jan. 19, 1998, at or about 10:58 a.m.
58. Do you admit or deny that on Monday, Jan. 19, 1998, at or about 1:45 p.m., you telephoned Betty Currie at her home?
According to White House records included in the OIC Referral, I called Ms. Currie's residence on Jan. 19, 1998, at or about 1:45 p.m.
59-60. Do you admit or deny that on Monday, Jan. 19, 1998, at or about 2:44 p.m., you met with individuals including Vernon Jordan, Erskine Bowles, Bruce Lindsey, Cheryl Mills, Charles Ruff, and Rahm Emanuel? Do you admit or deny that ... you discussed [with them] the existence of tapes of conversations between Monica Lewinsky and Linda Tripp recorded by Linda Tripp, or any other matter relating to Monica Lewinsky?
I do not believe such a meeting occurred. White House records included in the OIC Referral indicate that Mr. Jordan entered the White House complex that day at 2:44 p.m. According to Mr. Jordan's testimony, he and I met alone in the Oval Office for about 15 minutes.
I understand that Mr. Jordan testified that we discussed Ms. Lewinsky at that meeting and also the Drudge Report, in addition to other matters.
61. Do you admit or deny that on Monday, Jan. 19, 1998, at or about 5:56 p.m., you telephoned Vernon Jordan at his office?
According to White House records included in the OIC Referral, I called Mr. Jordan's office on Jan. 19, 1998, at or about 5:56 p.m.
62-68. Do you admit or deny that on Jan. 2l, 1998, the day the Monica Lewinsky story appeared for the first time in The Washington Post, you had a conversation with Sidney Blumenthal in which you stated that you rebuffed alleged advances from Monica Lewinsky and in which you made a statement similar to the following? "Monica Lewinsky came at me and made a sexual demand on me." Do you admit or deny that ... you made a statement similar to the following in response to a question about your conduct with Ms. Lewinsky? "I haven't done anything wrong."
Do you admit or deny that on Jan. 21, 1998, ... you had a conversation with Erskine Bowles, Sylvia Matthews and John Podesta in which you made statements similar to the following? "I want you to know I did not have a sexual relationship with this woman, Monica Lewinsky. I did not ask anybody to lie. And when the facts come out, you'll understand."
Do you admit or deny that on or about Jan. 23, 1998, you had a conversation with John Podesta in which you stated that you had never had an affair with Monica Lewinsky? Do you admit or deny that ... you stated [to him] that you were not alone with Monica Lewinsky in the Oval Office, and that Betty Currie was either in your presence or outside your office with the door open while you were visiting with Monica Lewinsky?
Do you admit or deny that on or about Jan. 26, 1998, you had a conversation with Harold Ickes in which you made statements to the effect that you did not have an affair with Monica Lewinsky? Do you admit or deny that ... you made statements [to him] to the effect that you had not asked anyone to change their story, suborn perjury or obstruct justice if called to testify or otherwise respond to a request for information from the Office of Independent Counsel or in any other legal proceeding?
As I have previously acknowledged, I did not want my family, friends, or colleagues to know the full nature of my relationship with Ms. Lewinsky. In the days following the Jan. 21, 1998, Washington Post article, I misled people about this relationship. I have repeatedly apologized for doing so.
69-71. Do you admit or deny that on or about Jan. 21, 1998, you and Richard "Dick" Morris discussed the possibility of commissioning a poll to determine public opinion following [T]he Washington Post story regarding the Monica Lewinsky matter? Do you admit or deny that you had a later conversation with [him] in which he stated that the polling results regarding the Monica Lewinsky matter suggested that the American people would forgive you for adultery but not for perjury or obstruction of justice? Do you admit or deny that you responded to [him] ... by making a statement similar to the following: "[W]ell, we just have to win then"?
At some point after the OIC investigation became public, Dick Morris volunteered to conduct a poll on the charges reported in the press. He later called back. What I recall is that he said the public was most concerned about obstruction of justice or subornation of perjury. I do not recall saying, "Well, we just have to win then."72. Do you admit or deny the past or present existence of, or the past or present direct or indirect employment of individuals, other than counsel representing you, whose duties include making contact with or gathering information about witnesses or potential witnesses in any judicial proceeding related to any matter in which you are or could be involved?
I cannot respond to this inquiry because of the vagueness of its terms (e.g., "indirect," "potential," "could be involved"). To the extent it may be interpreted to apply to individuals assisting counsel, please see my responses to Request Nos. 73-76. To the extent the inquiry addresses specific individuals, as in Request Nos. 73-75, I have responded and stand ready to respond to any other specific inquiries.
73. Do you admit or deny having knowledge that Terry Lenzner was contacted or employed to make contact with or gather information about witnesses or potential witnesses in any judicial proceeding related to any matter in which you are or could be involved?
My counsel stated publicly on Feb. 24, 1998, that Mr. Terry Lenzner and his firm have been retained since April 1994 by two private law firms that represent me. It is commonplace for legal counsel to retain such firms to perform legal and appropriate tasks to assist in the defense of clients. See also Response to No. 72.74. Do you admit or deny having knowledge that Jack Palladino was contacted or employed to make contact with or gather information about witnesses or potential witnesses in any judicial proceeding related to any matter in which you are or could be involved?
My understanding is that during the 1992 Presidential Campaign, Mr. Jack Palladino was retained to assist legal counsel for me and the Campaign on a variety of matters arising during the Campaign. See also response to No. 72.
75. Do you admit or deny having knowledge that Betsy Wright was contacted or employed to make contact with or gather information about witnesses or potential witnesses in any judicial proceeding related to any matter in which you are or could be involved?
Ms. Betsey Wright was my long-time chief of staff when I was Governor of Arkansas, and she remains a good friend and trusted advisor. Because of her great knowledge of Arkansas, from time to time my legal counsel and I have consulted with her on a wide range of matters. See also response to No. 72.
76. Do you admit or deny that you made false and misleading public statements in response to questions asked on or about Jan. 21, 1998, in an interview with Roll Call, when you stated "Well, let me say, the relationship was not improper, and I think that's important enough to say. But because the investigation is going on, I don't know what is out -- what's going to be asked of me. I think I need to cooperate, answer the questions, but I think that it's important for me to make it clear what is not. And then, at the appropriate time, I'll answer to what is. But let me answer -- it is not an improper relationship and I know what the word means."
The tape of this interview reflects that in fact I said, "Well, let me say the relationship's not improper and I think that's important enough to say ..." With that revision, the quoted words accurately reflect my remarks. As I stated in Response to Request Nos. 62 to 68, in the days following the Jan. 21, 1998, disclosures, I misled people about this relationship, for which I have apologized.
77. Do you admit or deny that you made false and misleading public statements in response to questions asked on or about Jan. 21, 1998, in the Oval Office during a photo opportunity when you stated "Now there are lots of questions that I think are very legitimate. You have a right to ask them; you and the American people have a right to get answers. We are working very hard to comply and get all the requests for information up here and we will give you as many answers as we can as soon as we can at the appropriate time, consistent with our obligation to also cooperate with the investigations. And that's not a dodge. That's really what I've talked with our people. I want to do that. I'd like to have more rather than less, sooner rather than later. So we'll work through it as quickly as we can and get all those questions out there to you"?
I made this statement (as corrected), according to a transcript of a Jan. 22, 1998, photo opportunity in the Oval Office. This statement was not false and misleading. It accurately represented my thinking.
78. Do you admit or deny that you discussed with Harry Thomason, prior to making separate statements in response to questions asked by the press in January 1998, relating to your relationship with Monica Lewinsky, what such statements should be or how they should be communicated?
Mr. Thomason was a guest at the White House in January 1998, and I recall his encouraging me to state my denial forcefully.
79. Do you admit or deny that you made a false or misleading public statement in response to a question asked on or about Jan. 26, 1998, when you stated "But I want to say one thing to the American people. I want you to listen to me. I am going to say this again. I did not have sexual relations with that woman, Ms. Lewinsky"?
I made this statement on Jan. 26, 1998, although not in response to any question. In referring to "sexual relations," I was referring to sexual intercourse. As I stated in response to request Nos. 62 to 68, in the days following the Jan. 21, 1998, disclosures, answers like this misled people about this relationship, for which I have apologized.
80. Do you admit or deny that you made false and misleading public statements in response to a question asked on or about Jan. 26, 1998, when you stated " ... I never told anybody to lie, not a single time. Never"?
This statement was truthful: I did not tell Ms. Lewinsky to lie, and I did not tell anybody to lie about my relationship with Ms. Lewinsky. I understand that Ms. Lewinsky also has stated that I never asked or encouraged her to lie.
81. Do you admit or deny that you directed or instructed Bruce Lindsey, Sidney Blumenthal, Nancy Hernreich and Lanny Breuer to invoke executive privilege before a grand jury empaneled as part of a judicial proceeding by the United States District Court for the District of Columbia Circuit in 1998?
On the recommendation of Charles Ruff, Counsel to the President, I authorized Mr. Ruff to assert the presidential communications privilege (which is one aspect of executive privilege) with respect to questions that might be asked of witnesses called to testify before the grand jury to the extent that those questions sought disclosure of matters protected by that privilege. Thereafter, I understand that the presidential communications privilege was asserted as to certain questions asked of Sidney Blumenthal and Nancy Hernreich. Further, I understand that, as to Mr. Blumenthal and Ms. Hernreich, all claims of executive privilege were subsequently withdrawn and they testified on several occasions before the grand jury.
Mr. Lindsey and Mr. Breuer testified at length before the grand jury about a wide range of matters, but declined, on the advice of White House Counsel, to answer certain questions that sought disclosure of discussions that they had with me and my senior advisors concerning, among other things, their legal advice as to the assertion of executive privilege. White House Counsel advised Mr. Lindsey and Mr. Breuer that these communications were protected by the attorney-client privilege as well as executive privilege. Mr. Lindsey also asserted my personal attorney-client privilege as to certain questions relating to his role as an intermediary between me and my personal counsel in the Jones v. Clinton case, a privilege that was upheld by the federal appeals court in the District of Columbia.
-- William Jefferson Clinton

This article was published on Saturday, November 28, 1998

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