RETURN to Clinton/Starr Texts
Lewinsky Deposition, Part 1
OFFICE OF THE INDEPENDENT COUNSEL
DEPOSITION OF Wednesday, August 26, 1998
MONICA S. LEWINSKY : Washington, D. C.
Deposition of
MONICA S. LEWINSKY
before the Independent Counsel, held in the Conference Room of the
Office of the Independent Counsel, Suite 490-North, 1001
Pennsylvania Avenue, N. W., Washington, D. C. 20004, beginning
at 12:35 p.m., when were present:
For the Independent Counsel:
KARIN IMMERGUT, ESQUIRE
Associate Independent Counsel
MARY ANNE WIRTH, ESQUIRE
Associate Independent Counsel
Court Reporter: Elizabeth A. Eastman
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PROCEEDINGS
MS. IMMERGUT. We are on the record. Ms. Lewinsky, could you please state and spell your full name for the record?
MS. LEWINSKY: Monica Samille Lewinsky, M-O-N-I-C-A S-A-M-I-L-L-E, L-E-W-I-N-S-K-Y.
MS. IMMERGUT: For the record. I am Karin Immergut from the Office of Independent Counsel. Seated with me is Mary Anne Wirth, also from the Office of the Independent Counsel.
WHEREUPON,
MONICA S. LEWINSKY
having been called for examination by the Office of the Independent counsel, and having been first duly sworn by the notary, was examined and testified as follows:
EXAMINATION BY COUNSEL FOR THE INDEPENDENT COUNSEL BY MS. IMMERGUT:
QUESTION: Before we begin the deposition, I do want to advise you of certain rights that you have in connection with this deposition. You have already, I know, testified twice before the grand jury, and essentially the same rights do apply.
First, you have a right to have an attorney present outside of the room. Do you have an attorney present?
A Yes, I do.
QUESTION: Who is that attorney?
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A Plato Cacheris.
QUESTION: You have the right to consult with Mr. Cacheris any time during the testimony, and I simply ask that you just request a break when you need to consult with him. Do you understand that you have that right?
A Yes, I do.
QUESTION: You also generally as a witness in a deposition, or before a grand jury, have a Fifth Amendment right not to incriminate yourself. Obviously, that now is modified pursuant to the agreement that you have with the Office of the Independent Counsel.
Do you understand that?
A Yes.
QUESTION: Nave you seen the agreement that you have, giving you immunity for your cooperation in this case?
A Yes, I have.
QUESTION: That also is a grand jury exhibit in this case, is it not?
A Yes, it is.
QUESTION: Do you have any questions about what your rights are not to incriminate yourself as part of that agreement?
A No, I don't.
QUESTION: In addition, as always, you are required to tell the truth during this procedure and are subject to the penalties of perjury if you do not tell the complete truth.
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Do you understand that?
A Yes, I do.
QUESTION: Any other questions that you have before we proceed?
A No.
QUESTION: First I just want to ask you a general question. know you have testified in two other proceedings about various aspects of your relationship with the President. Can you characterize whether or not your relationship was one that started with sex and then evolved into a friendship, or the other way around?
A It started with a physical attraction, which led to a sexual relationship, and then the emotional and friendship aspects of that relationship developed after the beginning of our sexual relationship.
QUESTION: I would like to place before you whet I will mark as Deposition exhibit No. 1.
(Deposition Exhibit No. 1 was
marked for identification.)
BY MS. IMMERGUT:
QUESTION: This is also a chart that was previously marked as Grand Jury Exhibit ML #7. You can see the Xerox copy of that sticker on this exhibit, and I will place that before you, and ask if you recognize what that exhibit is?
A Yes, I do.
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QUESTION: What do you recognize it to be?
A A chart that I helped develop with the Office of Independent Counsel to describe and enumerate the - - my relationship with the President, the contacts between the President and myself.
QUESTION: As you've testified before, did you provide the information that is on this chart?
A Yes, I did.
QUESTION: And is it accurate to the best of your recollection of the events?
A Yes, it is.
QUESTION: What I would like to do is go through the events that are written in bold, which deal with the private encounters you had with the President that involved, for the most part, some sort of physical intimacy that we have listed as physical intimacy, including oral sex. I did want to get into some more detail about each incident.
Basically, with respect to each incident, I would like you to describe the circumstances leading up to the actual visit, who initiated it, how it was set up, and then I would like to ask you some details about the sexual encounters themselves that occurred during each of those
visits . .
So; why don't we start with the very first one,
which is the second encounter that you had on November 15th,
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1995 that you've already testified some about. If you can, could you just tell us how that visit was set up, and then what occurred during the visit?
A The President came back to Mr. Panetta's office and I was the only person in the office at the time, and believe it was maybe around, I think. 10 p.m. or so, and asked me, or told me that if I wanted to meet him back in Mr. Stephanopoulos' office in about 5-10 minutes, that I could. And I told him I was interested to do that.
QUESTION: At that time, did you understand what it was he wanted to meet with you about?
A I had an idea. I, I, I had assumed that since we bad been intimate in our previous encounter that evening, that we would again be intimate.
QUESTION: And just to clarify for the record, the intimacy that you had earlier that night was just kissing, is that correct?
A Yes.
QUESTION: So, did you, in fact, go meet with the President?
A Yes, I did.
QUESTION: And could you describe where you went to meet him?
A I met him back in Mr. Stephanopoulos' office and he invited me into the back study again, and we were in the hallway. And we were -- I don't remember exactly how it started. But I know that we were talking a bit and kissing.
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I remember -- I know that he - - I believe I unbuttoned my jacket end he touched my, my breasts with my bra on, and then either -- I don't remember if I unhooked my bra or he lifted my bra up, but he -- this is embarrassing.
QUESTION: Then touched your breasts with his hands?
A Yes, he did.
QUESTION: Did he touch your breasts with his mouth?
A Yes, he did.
QUESTION: Did he touch your genital area at all that day?
A Yes. We moved -- I believe he took a phone call in his office, and so we moved from the hallway into the back office, and the lights were of f. And at that point, he, he put his bend down my pants end stimulated me manually in the genital area.
QUESTION: And did he bring you to orgasm?
A Yes, he did.
QUESTION: Back to the touching of your breasts for a minute, was that then through clothing or actually directly onto your skin?
A Me touched my breasts through clothing, being my bra, and then also without my bra on.
QUESTION: On that occasion, did you perform oral sex on the President?
A Yes.
QUESTION: Who actually initiated your performing oral sex?
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A I did.
QUESTION: Was the President wearing pants?
A Yes, he was.
QUESTION: Who unzipped his pants?
A I believe I went to go unbutton his pants and I had trouble. So, he did that. So, but --
QUESTION: So, you started it?
A If I remember correctly.
QUESTION: And he helped complete opening his pants?
A yes.
QUESTION: Did the President at that time do anything to stop you from doing that?
A No. I think he asked me if I was sure I wanted to do that.
QUESTION: Did you have any other discussion with him while the sexual encounter was occurring, about the sex or what you were doing?
A No. Actually, I don't think he asked me if I were sure I wanted to do that, because he was on the telephone. So -- I'm sorry.
Could you repeat what you just asked me?
QUESTION: Did the President have any discussion with you about sex, or you with him, while the sexual encounter was occurring?
A Not at this time. He was on the telephone for the
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second half when we were in the office.
QUESTION: So, he was on the telephone while you were performing oral sex?
A He was on the telephone while he was - -
QUESTION: Touching you?
A Touching me, and was also on the telephone when I was performing oral sex.
QUESTION: For any part of this sexual encounter, was he then of f the telephone?
A Yes, I believe towards the end of my performing oral sex.
QUESTION: Did he say anything about the oral sex or anything about the sex at all when he got off the phone, that you can remember?
A He stopped me before he came, and I told him that I wanted to, to complete that. And he said that, that he needed to wait until he trusted me more. And then I think he
Q _____________
A Yes.
Q Did he ejaculate in your presence that time at all?
A No.
Q How did you depart from the office, or how did you
end that visit?
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A I believe we spoke for awhile and I know at some point in that conversation I - - oh, that might have been Friday. Hmm. I really don't remember how it ended.
QUESTION: Can you estimate at all how long the sexual part of your encounter with him lasted?
A Maybe 20 minutes?
Q How long - -
A I'm not a very good estimator of times. .
Q How long did the entire encounter last, if you can
recall?
A The second one of that evening?
Q Yes.
A Maybe half an hour or 40 minutes?
Q So, the entire encounter did not involve simply the
sexual part of it?
A No, it didn't.
QUESTION: Did you have talking beforehand or was most of the talking afterwards?
A It was before and after.
QUESTION: If I can direct your attention again back to Deposition Exhibit No. 1, the chart, the next date where you do have two encounters with the President is November 17th, 1995. Although you've described it somewhat for the grand jury, if you could now just describe in detail -- again, I'll direct your attention to that second contact where there was
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physical intimacy, including oral sex listed -- how that contact came about and what occurred during the contact?
A Yes. I had brought the President pizza, as he had asked. And when I brought it into him at the Oval Office, then he took me into the, to the back office and said that I could leave through that way. I believe we were talking for a little bit and he then, he got a phone call and he took the phone call in his bathroom.
Oh, it might have been before the phone call that
-- I don't, I don't remember who, who unbuttoned my jacket or anything like that, But we were kissing and he was fondling my breasts with his hands and with his mouth.
QUESTION: Was that through clothing or not through clothing?
A It was both.
QUESTION: Okay. So, was there a point that your bra is removed?
A Yes.
QUESTION: But you don't remember who actually removed it?
A No. I think, I think he -- rather than necessarily removing my bra, sometimes he would just expose my breasts.
QUESTION: By lifting the bra over your breasts?
A Yes, or sometimes lifting my breasts out of the bra. Oh, God.
QUESTION: So, on that occasion though, you do recall that he touched you not just through your bra, but also directly on
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the skin?
A Yes.
Q
A
Q
A
QUESTION: Was there any discussion about sex while you were in this encounter with him?
A I don't remember the specifics of it, but I know there was another discussion, I think, about him not letting me make him come, and then I had to get back to -- I'm sorry.
Could you repeat the question?
QUESTION: Was there any discussion during the November 17th encounter about sex during the encounter?
A I don't know exactly what you mean. I mean, do you mean either about --
QUESTION: Talking - -
A I mean, saying things, or --
QUESTION: Well, either about what he wanted or what you wanted, or anything like that, in terms of sex?
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A No. I mean, I think that there were always things being said, but not necessarily in a conversational form. Does that make sense?
QUESTION: Okay. And when you say there were always things being said, do you mean kind of chatting while you were having sex, or things that felt good? I don't mean that. mean -A Okay.
QUESTION: -- trying either implicitly giving you direction about what he wanted, or why he wouldn't ejaculate, anything like that?
A I believe that why he wouldn't ejaculate was, was discussed again.
QUESTION: Okay. You mentioned that the President unzipped his pants. Did you understand that to be a signal of what he wanted in terms of sex?
A Yes.
QUESTION: Did he ever say anything while that was happening about what he wanted or no?
A No. He was on the telephone.
QUESTION: Okay. And that was on the second time also?
A Yes.
QUESTION: Was he on the telephone the whole time that you performed oral sex on him on the l7th of November?
A I donut remember.
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QUESTION: Do you remember how you finished that meeting up with him that day, how you left?
A Yes. I know I needed to get back to my office, and he -- I think I told him that he should come down and have pizza with us, he should bring his pizza down, and that everyone was down there. And at some point I believe in that meeting he told me that, or he reiterated because he might have said it on the 15th as well, that I could come see him on the weekends when, when there weren't a lot of people around .
QUESTION: With respect again to the ejaculation, that he wouldn't actually ejaculate during oral sex, were you aware, or did he ejaculate anywhere in your presence on that occasion?
A No.
QUESTION: The next date listed on the chart is December 31st, 1995, a Sunday. Could you describe how that meeting was set up and what occurred when you got to the meeting?
A Yes. I had been having a conversation with Hal and had just told him that I smoked my first cigar the night before in honor of my brother's birthday. And Nel asked me if I wanted -- or offered that he could get me one of the President's cigars from his sort of stash of cigars. I said, that would be great.
And we went through the Roosevelt Room to the
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entrance into the back study which - - the door that leads into the dining room. And just as we approached the door, the door swung open and the President was standing right there, and he had something he was going to take to Mr. Panetta. So, he asked, he asked Nel to take this -- I think it was a picture actually -- a picture down to Mr. Panetta, and he invited me in,
So, I went into the office and he asked me what I was doing there. And -- well, first he told me he had been looking for me. And then he told me -- he asked me what I was doing there, and I told him that Nel was going to get me a cigar. So, he said that he would give me a cigar. So, he did give me a cigar.
And then we were talking for a little bit and I had
-- do you want me to just be --
QUESTION: If you could do a narrative, that's fine. A Well, he had -- I had thought that he had forgotten
my name before, because I had seen him in the hall a few times and he kept calling me "Kiddo", So, so, I sort of reiterated my - - I said my name again to him. You know, I said, you know, it's Monica Lewinsky, President Kiddo, you know. And he said, I know your name.
And he told me that he had tried to call me and that -- he said, but you're not in the book; I even spelled your last name right. So, it was, it was really funny. It
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was cute.
And then we were, we were kissing and he lifted my sweater and exposed my breasts and was fondling them with his hands end with his mouth. And then I believe I was fondling him over his pants in his genital area, and I think again I tried to unbutton his pants and I couldn't. So, he did it.
QUESTION: And again, just to be clear, when you mentioned he raised your sweater and fondled your breasts, were your breasts outside of your bra at that time?
A Yes.
Q
A
Q
A
Q
A
QUESTION: Did you have any discussion with him again about why he wasn't ejaculating, anything like that?
A Yes, I think so. It might have been at that time
-- the two excuses he always used were, one, that he didn't know me well enough or he didn't trust me yet. So that it sort of seemed to be some bizarre issue for him.
QUESTION: On that occasion, did he ever ejaculate in your.
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presence, even though not - - at any time later?
A After he told me to stop and then, and then wished me Happy New Year and kissed me goodbye, he went into the
QUESTION: Okay. Do you know how long that sexual encounter, or the sexual aspect of that encounter lasted, not including the other discussion with him?
A Maybe 10 minutes. Not, not very long. We would always spend quite a bit of time kissing. So.
QUESTION: And kissing and talking end just --
A Uh-huh.
QUESTION: - - being affectionate?
A Yes.
QUESTION: The next one is on page 2, and that would be January 7th of '96. Could you describe how that meeting was set up and what happened when you got there?
A Yes. The President called me -- this is the first time he called me at home -- that afternoon, and it was the first day of the blizzard. And I asked him what he was doing and he said he was going to be going into the office soon . said, oh, do you want some company. And he said, oh, that would be great. So, he said he was going into the office in about 45 minutes, and I told him that I should probably be in my office around that time, and he said he would call me in
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my office. I gave him my office number.
Then once I was in my office, he called me end we made en arrangement that I would pass - - he would have the door to his office open, and I would pass by the office with' some papers and then he would, he would sort of stop me and invite me in. So, that was exactly what happened.
I passed by and that was actually when I saw Lew Fox who was on duty outside the Oval Office, and stopped end . spoke with Lew for a few minutes, end then the President came out and said, oh, hey, Monica, you know, what are you doing here, come on in, sort of.
And so we spoke for about 10 minutes in the office. We sat on the sofas. Then we went into the back study and we were intimate in the bathroom.
QUESTION: And when you say you were intimate in the bathroom, what did you do?
A We kissed and he, he fondled my breasts and exposed
- - or I think pulled them out of my bra and fondled them with his hands and with his mouth, and --
QUESTION: Did he touch your genitals on that occasion?
A No. He wanted to and was talking about performing oral sex on me,
Q
A
QUESTION: Okay. On that date, did you gratify him in some
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way other than performing oral sex?
A Yes,
Q
A
Q
A
Q
A
Q
-A
Q
A
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A
QUESTION: Did you have any discussion about sex during the encounter that you had with him?
A No,
QUESTION: How long was your encounter with him?
A Hmm. Maybe about half an hour? I, I'm -- it's really hard for me to estimate the time.
QUESTION: And that would be the sexual aspect of it though that - -
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A Correct.
QUESTION: -- we're talking about. Did he ejaculate at any point in your presence after you performed oral sex on him?
A That day?
QUESTION: Yes.
A Ho,
MS. IMMERGUT: Did you have a question?
BY MS. WIRTH:
QUESTION: I have a question, actually going back to November 15th, if you don't mind.
A Okay.
QUESTION: When you were talking about the President having contact with your genitals, you said, I think, that he put his hands in your pants. When he touched your genitals, was that through your underwear or directly?
A I didn't have my underwear on at that point.
Q Okay. So, it was directly then?
A Yes.
Q Okay.
BY MS. IMMERGUT:
Q The next encounter listed is January 21st of '96,
also on page 2 of the exhibit. Could you describe how that encounter occurred and what happened during the encounter?
A Yes. I was -- actually, I'm looking at this right now and I think it might have been a Saturday -- no, it was a
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Sunday. I'm sorry. Never mind. I think it might have been a Saturday, but it, it says here Sunday. I just noticed that .
I was - - I had been in my office doing work. and I was leaving, leaving for the day. And as I was walking through the Residence hall to go through the West Wing to the Old Executive Office Building, I heard his voice behind me. And either he called my name or I just heard his voice and turned around, and he had just come off of the elevator and, I guess, was going back to his office.
So, we were, we were -- we stopped, and we spoke as we continued to walk through the outdoor corridor by the Rose Garden. And when we got to the point where he turns left to then go into the Oval Office, he told me that I could go out this way with him, that I could leave through the, that I could leave through the Oval Office. So, we walked down the pathway together and then went into the Oval Office from there .
QUESTION: And could you describe your encounter once you got into the Oval Office?
A Yes. We had, we had already had phone sex for the first time the week prior, and I was feeling a little bit insecure about whether he had liked it or didn't like it, and I just -- I felt in general that I didn't know -- from having spoken to him on the phone, you know, prior to having phone
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sex and from having had these encounters with him, I didn't know if this was sort of developing into some kind of a longer term relationship then what I thought it initially might have been, that maybe he had some regular girlfriend who was furloughed or something during the furlough.
And at that point, I, you know, I said to him, you know, I asked him why he doesn't ask me any questions about myself, and doesn't he, you know, is this just about sex, you know, because if it is, then I just want to know that; or do you have some interest in trying to get to know me as a person. And so he kind of laughed at the manner in which I was asking him and talking to him.
And we, we went into the back study and he was. he was waiting for a friend of his to come to the office, and he was talking about that he has a lot of -- that he doesn't get a lot of time to himself end he really cherishes the private times that he has with his friends, and he cherishes the time that he had with me, which seemed a little bit odd to me at that time.
But he, he was upset that day about the first soldier in Bosnia had been -- I believe it was that day --that it was the first soldier in Bosnia had been killed just recently, and he was very upset and moved. And so I was trying to comfort him.
QUESTION: When you say you thought it was odd that he said he
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cherished the time with you, why was that, why did you think it was odd at that point?
A Because I didn't feel, I didn't feel like he really knew me. We had spent time talking, but it didn't seem --and, you know, he had asked some questions and I offered a lot of information about myself, But he didn't seem to ask probing questions, when you're trying to get to know someone. So, it seemed a little bit odd to me that he would sort of cherish this time, when he, you know, when I felt like he didn't really even know me yet.
QUESTION: And at that point, sex was sort of the more dominant part of the relationship?
A Yes.
QUESTION: Rather than as it became - -
A There was always a lot of joking that went on between us. And so we, you know, I mean, it was fun. When we were together, it was fun. We would laugh and it would --we were very compatible sexually. And I've always felt that he was sort of my sexual soulmate. and that I just felt very connected to him when it came to those kinds of things.
QUESTION: So, on the January 21st date --
A Right.
QUESTION: -- how did it turn into your conversation end then go into actually having a sexual encounter?
A I was in the middle of saying something and he just
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started kissing me. And, so, it was funny. It was, it was very funny.
QUESTION: And what room were you physically in at that time? A We were in the hallway. And we were kissing and - -
oh. I had -- because I was leaving, I was having a bad hair day, and this was actually the first time that I had the infamous beret on. And so I just said something to him about feeling stupid. Here I was standing here in this dumb hat, and he said that it wasn't a dumb hat, that I looked cute and he liked it.
And so then he was kissing me, or we were kissing each other, I guess, and I think again he, he fondled my breasts with his hands and his mouth.
QUESTION: Through clothing or not through clothing?
A I think it was always through clothing, and then eventually it, it would be direct contact. So, it wouldn't just be this immediate jump to being, you know, to contact. It was -- there was sort of foreplay to the foreplay, if that makes sense.
QUESTION: Do you remember whether he removed any of your clothing on that occasion?
A I think he -- I remember him lifting my top. So --and he, he sort of exposing my breasts.
QUESTION: Did he stimulate your genitals on that occasion?
A No.
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QUESTION: Did you perform oral sex on him or any kind of sex on him?
A Yes, I did.
QUESTION: Could you describe how that came about?
A Yes. He unzipped his pants and sort of exposed himself and that -- end then I performed oral sex.
QUESTION: Let me ask, on all of these occasions when you've described just the pants unzipping and exposing, is it fair to say that he still kept his pants on?
A Yes,
Q It was just the zipper that --
A Yes.
Q - - was undone?
A Right. And actually at one point during this
encounter, I think someone came into the, to the Oval Office and he, you know, zipped up real quickly and went out and came back in, and I -- this is probably too much information. I just -- sorry.
QUESTION: And what happened?
A I just remember laughing because he had walked out there and he was visibly aroused, and I just thought it was funny. I mean, it wouldn't, it wouldn't necessarily be visible to anyone who just walked in because they wouldn't be looking at that, but it was just funny to me, So,
And then his - - then someone - - I think at that
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point someone came in to let him know that his friend had arrived. And so he asked me which way I wanted to leave, and I said I was going to go, I was going to leave through Betty's office. And we went into -- we went from the back study through the Oval into Betty's office area, and he took me into Nancy Hernreich's office and kissed me goodbye,
And then I went to go leave from, from Betty's office, from the door into the hallway, to the West Wing hallway, but it was locked. So, I went back in to tell him. He was still in Nancy's office, I went back into Nancy's office to tell him the door was locked, and he was manually stimulating himself .
QUESTION: Did he cause himself to ejaculate at that point, or did you see that?
A No.
Q But that was in Nancy Hernreich's office?
A Yes.
Q And what did you do when you saw that?
A I smiled,
Q Okay.
A And I think we kissed again.
Q On that occasion, you mentioned that he did not
touch your genitals at all. Was there any discussion about that?
A No.
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QUESTION: Then did you leave from Nancy Hernreich's office eventually?
A I think I left through the - - I left through the door in Betty's office that goes out into the Rose Garden.
QUESTION: On this particular entry on January 21st, it lists that the entire encounter was approximately 30 to 40 minutes. Do you recall what portion of that would have been the sexual encounter part of it, versus just talking?
A Maybe 15 minutes?
Q You just can't really estimate?
A Exactly.
Q Let's go now to February 4th of 1996, the next bold
date where there was a private encounter. Could you describe how that encounter came about and what happened?
A Yes, I was in my office on Sunday and the President called me in the office and - - from the Residence, and told me that he was going to be going into the office later, And I think I asked him if I could come see him. And he said that would be fine, and then that he -- oh, I think he was, he said he was going to go into the office in an hour and a half or so,
So, then he called me - - it was actually maybe two or three hours later, because I remember I thought he forgot, maybe he had forgotten to call me and that - - so. And when he called from the Residence to say he was on his way, I told
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him that -- I asked him if we could sort of bump into the hallway, bump into each other in the hallway on purpose this time, because when it happened accidentally, that seemed to work really well and I felt more comfortable doing that. So, that's what we did. We both said, okay, I'm going to leave now .
And indeed we bumped into each other in the hall
and went through the Rose Garden into the Oval Office, And I
think we went right into the back office. The -- when we got
there .
QUESTION: When you say the back office, you mean the study?
A Yes. And -- let's see,
You know, I need to take a break.
QUESTION: Okay. Let's take a break.
(Whereupon, the deposition was recessed from 1:10 p.m. until 1:15 p.m.)
BY MS. IMMERGUT:
Q Ms. Lewinsky, you are still under oath.
A Yes.
Q We are still on February 4th, 1996. You've
described going into the office and starting to kiss the President. What happened then?
A We were in the back office and we were kissing, and I was -- I had a dress on that buttoned all the way, all the way up and down.
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QUESTION: To the neck?
A Correct. It was long and down to the, to my ankles, or whatever. And he unbuttoned my dress and he unhooked my bra, and sort of took the dress off of my shoulders and took the bra off of my, off of my -- I'm not explaining this right. So that he moved the bra so that my bra was kind of hanging on one shoulder and so was off. And he just was, he was looking at me and touching me and telling me how beautiful I was.
Q And did he touch your breasts with his hands?
A Yes.
Q Did he also touch them with his mouth?
A Yes.
Q And at that point, that is directly on your skin,
is that right?
A Yes.
Q Did he touch your genitals?
A Yes, he did.
Q Did he bring you to orgasm on that date?
A Yes, he did.
Q
A
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A
Q
A
QUESTION: And again, just with respect to bringing you to an orgasm, did he touch you directly on your skin on your genitals, or was it through underwear?
A First it was through underwear and then it was directly touching my genitals,
QUESTION: Did he take your underwear off, or did you take your underwear off?
A Hmm.
QUESTION: Or did they stay on?
A I think that -- I believe that he touched me first with my underwear on, and then placed his bend under my underwear. And I think at some point I, I removed them.
QUESTION: Okay. Did you also perform oral sex on him at that
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time?
A Yes, I did.
QUESTION: How did it come about? Was that something that you decided to do, or did the President either, through his actions or words, indicate to you that he wanted that?
A I don't really remember. I mean, it was a mutual
-- I think in all of these instances, it wasn't, you know --I know sometimes it's sort of hard to answer these questions as more directed, But it was - - I mean, it was the course of being intimate, I mean, it was the course of having this kind of a relationship, that you - - sometimes he initiated it, sometimes I initiated it. It wasn't, you know, it wasn't
-- it didn't necessarily go through my mind, okay, now it's time to perform oral sex.
I mean, it was, it was the passion of the moment, That was, I mean, just sort of in the course of things that happened, you know. I always felt that we sort of just, we both really went to a, to a whole other place together sexually.
QUESTION: Is it fair to say you were both trying to please each other by doing different things?
A Yes. Yes.
QUESTION: Is it also fair to say that you were not the sole aggressor in this sexual --
A That's very fair to say.
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QUESTION: - - encounter?
A I was not.
QUESTION: Again, I'm just asking you every time in case you remember, do you remember how long the sexual aspect of that encounter lasted?
A I really, I really don't.
QUESTION: Okay. I just note, to direct your attention that the time that you provided us previously is approximately one and a half hours for the whole visit.
A Right, We spent a long time in the Oval Office talking after, maybe 45 minutes to an hour just talking.
QUESTION: And that - -
A I think he was maybe heeding my, my advice from. from the 21st, about trying to get to know me, and so he did.
QUESTION: And is it fair to say that's sort of when the friendship really starts to develop, around that time period?
A It does, That certainly helped. I think he, he was just very sweet, and he -- when I got up to leave, he kissed my arm and told me he'd call me, end then I said, yeah, well, what's my phone number. And so he recited both my home number end my office number off the top of his head. So, I told him, you know, that he got an A.
And he called me in my office later that afternoon to tell me how much he enjoyed talking to me. So -- and then again called Wednesday night to tell me again how much he had
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enjoyed talking to me,
So. it - - I think that certainly was a turning point in the relationship, where it kind of went from a --obviously there's, there's some personal and intimate aspects of a sexual relationship that develop just in talking or laughing or getting to the point where you, where you kiss someone on every encounter, But for me, I think that spending the time talking to him was certainly when I, when I got to know him as a person and started to realize that he wasn't necessarily the person I thought he was at that point,
QUESTION: Let's move on to the next date, which is March 31st, 1996, the next encounter where there is physically intimate contact. Why don't you tell us how that date was set up and what happened?
A I had spoken -- well, just to back up real quickly. The President had ended things on the, I think it was the 19th of February. But then he had called me later - - I think it was late February or early March at some point - -indicating to me he wanted to sort of see me again: possibly for some intimate moments.
And it wasn't until the 31st of March that we really were together again physically. But he had called, I think two times, two times prior during that work week, leading up to the 31st. And it was on the Friday night which is, looking at the chart, which was the 29th, that I, I asked
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him if I could see him on Sunday. And he said, he'd, you know, he'd see what he could do.
And then on Sunday, he called me in my office and
-- let's see. I believe -- oh. I believe that I brought him papers that day. That I think I asked him to tell the guard outside that he was expecting some papers, expecting someone from Leg Affairs, And then when I got to the door, I told them that I was supposed to bring papers to the President,
Q And that was part of a ruse to - -
A Yes.
Q --get into see him?
A Exactly.
Q Just to back up for a second, you mentioned that
you had had some phone calls with him between February 19th, '96 when he tried to cut off the relationship --
A Yes.
Q - - or the sexual part of the relationship - -
A Correct.
Q -- and the 31st, in which he had suggested that he
wanted to perhaps renew the intimacy. What led you to believe that?
A I saw him on my way out one evening. It was late. And he was on his way home from, I think it was the Israeli Embassy and Evelyn Lieberman was with him. So, I certainly made a point of not having any eye contact or anything with
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him, And he called me later that evening and said he had, he had -- after he left and went upstairs, he went back to his office and had called me in my office, hoping that I could come have a visit with him, but I had already gone home.
And so then I offered, I said, well, I could come back. And he said, no, I'm upstairs already. So,
QUESTION: Back now to March 31st --
A Yes.
QUESTION: -- of '96. So, what happens then? How actually is that then finally set up?
A He had called me in my office and then I brought papers there, or fake papers.
QUESTION: Do you then go into the Oval Office?
A Yes, I do.
QUESTION: And what happens?
A We went into the back study and we were in the, the hallway area, And it had sort of become actually a ritual sort of at this point, that we always kind of started out our meetings, that he was leaning against the closed door of the bathroom and I would rub his back, because he has a bad back, So, I used to always rub his back, and sometimes he'd rub my back. But I usually concentrated on his lower back because it was always bothering him.
And, you know, and then I'd usually move around and sort of just lovingly touch his chest and --
Lewinsky Deposition, Part 2