4. “We Just Have To Win”
Amidst the flurry of press activity on January 21, 1998, the President’s former political consultant, Dick Morris, read the Post story and called the President.(1139) According to Mr. Morris, he told the President, “You poor son of a bitch. I’ve just read what’s going on.”(1140) The President responded, Mr. Morris recalled, “Oh, God. This is just awful. . . . I didn’t do what they said I did, but I did do something. I mean, with this girl, I didn’t do what they said, but I did . . . do something(1141). . . . And I may have done enough so that I don’t know if I can prove my innocence. . . . There may be gifts. I gave her gifts, . . . (a)nd there may be messages on her phone answering machine.”(1142) Mr. Morris assured the President, “(t)here’s a great capacity for forgiveness in this country and you should consider tapping into it.”(1143) The President said, “But what about the legal thing? You know, the legal thing? You know, Starr and perjury and all. . . . You know, ever since the election, I’ve tried to shut myself down. I’ve tried to shut my body down, sexually, I mean. . . . But sometimes I slipped up and with this girl I just slipped up.”(1144)
Mr. Morris suggested that he take a poll on the voters’ willingness to forgive confessed adultery.
The President agreed.(1145)
Mr. Morris telephoned the President later that evening with the poll results, which showed that the voters were “willing to forgive (the President) for adultery, but not for perjury or obstruction of justice(.)”(1146) When Mr. Morris explained that the poll results suggested that the President should not go public with a confession or explanation, he replied, “Well, we just have to win, then.”(1147)
The President had a follow-up conversation with Mr. Morris during the evening of January 22, 1998, when Mr. Morris was considering holding a press conference to “blast Monica Lewinsky `out of the water.’ “(1148) The President told Mr. Morris to “be careful”.
According to Mr. Morris, the President warned him not to “be too hard on (Ms. Lewinsky) because there’s some slight chance that she may not be cooperating with Starr and we don’t want to alienate her by anything we’re going to put out.”(1149)
Meanwhile, in California, the President’s good friend and Hollywood producer, Harry Thomason, had seen the President’s interview with Jim Lehrer on televison.(1150) Mr. Thomason, who had occasionally advised the President on matters relating to the media, traveled to Washington, D.C., and met with him the next day.(1151) Mr. Thomason told the President that “the press seemed to be saying that (the President’s comments were) weak” and that he, Mr. Thomason, “thought his response wasn’t as strong as it could have been.”(1152) Mr. Thomason recommended that the President “should explain it so there’s no doubt in anybody’s mind that nothing happened.”(1153) The President agreed: “You know, you’re right. I should be more forceful than that.”(1154)
In the ensuing days, the President, through his Cabinet, issued a number of firm denials. On January 23, 1998, the President started a Cabinet meeting by saying the allegations were untrue.(1155) Afterward, several Cabinet members appeared outside the White House. Madeline Albright, Secretary of State, said: “I believe that the allegations are completely untrue.” The others agreed. “I’ll second that, definitely,” Commerce Secretary William Daley said. Secretary of Education Richard Riley and Secretary of Health and Human Services Donna Shalala concurred.(1156)
The next day, Ann Lewis, White House Communications Director, publicly announced that “those of us who have wanted to go out and speak on behalf of the president” had been given the green light by the President’s legal team.(1157) She reported that the President answered the allegations “directly” by denying any improper relationship. She believed that, in issuing his public denials, the President was not “splitting hairs, defining what is a sexual relationship, talking about `is’ rather than was.(1158) You know, I always thought, perhaps I was naive, since I’ve come to Washington, when you said a sexual relationship, everybody knew what that meant.”
Ms. Lewis expressly said that the term includes “oral sex.” (1159)
* * *
On Monday, January 26, 1998, in remarks in the Roosevelt Room in the White House, President Clinton gave his last public statement for several months on the Lewinsky matter. At an event promoting after-school health care, the President denied the allegations in the strongest terms: “I want to say one thing to the American people. I want you to listen to me. I’m going to say this again: I did not have sexual relations with that woman, Miss Lewinsky. I never told anybody to lie, not a single time. Never. These allegations are false.”(1160)
1. Lewinsky 8/6/98 GJ at 31-32, 39-40; DB Photos 0004 (photo of dress).
2. FBI Lab Report, 8/3/98.
3. OIC letter to David Kendall, 7/31/98 (1st letter of day).
4. Kendall letter to OIC, 7/31/98; OIC letter to Kendall, 7/31/98 (2d letter of day); Kendall letter to OIC, 8/3/98; OIC letter to Kendall, 8/3/98.
5. FBI Observation Report (White House), 8/3/98.
6. FBI Lab Reports, 8/6/98 & 8/17/98. The FBI Laboratory performed polymerase chain reaction analysis (PCR) and restriction fragment length polymorphisim analysis (RFLP). RFLP, which requires a larger sample, is the more precise method. United States v. Hicks, 103 F.3d 837, 844-847 (9th Cir. 1996).
7. FBI Lab Report, 8/17/98, at 2.
8. Lewinsky 7/27/98 Int. During earlier negotiations with this Office, Ms. Lewinsky provided a 10-page handwritten proffer statement summarizing her dealings with the President and other matters under investigation. Lewinsky 2/1/98 Statement. Ms. Lewinsky later confirmed the accuracy of the statement in grand jury testimony. Lewinsky 8/20/98 GJ at 62-63. The negotiations in January and February 1998 (which produced the written proffer) did not result in a cooperation agreement because Ms. Lewinsky declined to submit to a face-to-face proffer interview, which the OIC deemed essential because of her perjurious Jones affidavit, her efforts to persuade Linda Tripp to commit perjury, her assertion in a recorded conversation that she had been brought up to regard lying as necessary, and her forgery of a letter while in college. In July 1998, Ms. Lewinsky agreed to submit to a face-to-face interview, and the parties were able to reach an agreement.
9. Ex. ML-7 to Lewinsky 8/6/98 GJ.
10. Lewinsky 8/26/98 Depo. at 5-6; Lewinsky 8/6/98 GJ at 27-28.
11. Lewinsky 8/26/98 Depo. at 69.
12. Lewinsky 8/6/98 GJ at 59-60, 87; Lewinsky 8/20/98 GJ at 82; Lewinsky 8//98 Int. at 8.
13. Ms. Tripp testified that she took notes on two occasions. Tripp 6/30/98 GJ at 141-42; Tripp 7/7/98 GJ at 153-54; Tripp 7/16/98 GJ at 112-13.
14. Kassorla 8/28/98 Int. at 2-3. Ms. Lewinsky (who voluntarily waived therapist-patient privilege) consulted Dr. Kassorla in person from 1992 to 1993 and by telephone thereafter. Id. at 1. Anticipating that the White House might fire Ms. Lewinsky in order to protect the President, Dr. Kassorla cautioned her patient that workplace romances are generally ill-advised. Id. at 2.
15. Kassorla 8/28/98 Int. at 2, 4. Ms. Lewinsky also consulted another counselor, Kathleen Estep, three times in November 1996. While diagnosing Ms. Lewinsky as suffering from depression and low self-esteem, Ms. Estep considered her self-aware, credible, insightful, introspective, relatively stable, and not delusional. Estep 8/23/98 Int. at 1-4.
16. Catherine Davis 3/17/98 GJ at 21-22.
17. Young 6/23/98 GJ at 40. See also Catherine Davis 3/17/98 GJ at 73; Erbland 2/12/98 GJ at 25 (“I never had any reason to think she would lie to me. I never knew of her to lie to me before and we talked about our boyfriends and, you know, sexual relationships throughout our friendship and I never knew her as a liar.”); Finerman 3/18/98 Depo. at 113-16 (characterizing Ms. Lewinsky as trustworthy and honest); Raines 1/29/98 GJ at 87 (“I have no reason to believe that (Ms. Lewinsky’s statements) were lies or made up.”); Tripp 7/29/98 GJ at 187 (“There were so many reasons why I believed her. She just had way too much detail. She had detail that none of us could really conceivably have if you had not been exposed in a situation that she claimed to be.”); Ungvari 3/19/98 GJ at 19 (“(s)he’s never lied to me before”); id. at 21, 61-62; Young 6/23/98 GJ at 38-40.
18. Ms. Lewinsky testified that she has “always been a date-oriented person.” Lewinsky 8/6/98 GJ at 28. See also Tripp 6/30/98 GJ at 141-42 (Ms. Lewinsky “had a photographic memory for the entire relationship”).
19. Clinton 1/17/98 Depo. at 78, 204. The transcript of this deposition testimony appears in Document Supp. A. For reasons of privacy, the OIC has redacted the names of three women from the transcript. The OIC will provide an unredacted transcript if the House of Representatives so requests.
20. Clinton 1/17/98 Depo. at 57.
21. Clinton 1/17/98 Depo. at 54.
22. Clinton 1/17/98 Depo. at 204. Beyond his denial of a sexual relationship with Ms. Lewinsky, the President testified that he could not recall many details of their encounters. He said he could not specifically remember whether he had ever been alone with Ms. Lewinsky, or any of their in-person conversations, or any notes or messages she had sent him, or an audiocassette she had sent him, or any specific gifts he had given her. Alone together: Clinton 1/17/98 Depo. at 52-53, 56-59. Conversations: Id. at 59. Cards and letters: Id. at 62. Audiocassette: Id. at 63-64. Gifts from the President to Ms. Lewinsky: Id. at 75. When asked about their last conversation, the President referred to a December encounter when, he said, Ms. Lewinsky had been visiting his secretary and he had “stuck (his) head out” to say hello. Id. at 68. He did not mention a private meeting with Ms. Lewinsky on December 28, 1997, or a telephone conversation with her on January 5, 1998. Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7; Clinton 8/17/98 GJ at 34-36, 126-28.
23. Clinton 8/17/98 GJ at 10, 79, 81.
24. Clinton 8/17/98 GJ at 10.
25. Clinton 8/17/98 GJ at 31, 10. See also id. at 38-39.
26. Clinton 8/17/98 GJ at 10, 92-93.
27. Clinton 8/17/98 GJ at 22.
28. Clinton 8/17/98 GJ at 10, 12, 93-96.
29. 849-DC-00000586. The definition mirrors a federal criminal statute, 18 U.S.C. 2246(3). The ellipsis in the quotation omits two paragraphs of the definition that Judge Wright ruled inapplicable. Clinton 1/17/98 Depo. at 21-22. The President testified that he considered the definition “rather strange,” and at one point he spoke of “people being drawn into a lawsuit and being given definitions, and then a great effort to trick them in some way.” Clinton 8/17/98 GJ at 19, 22. He acknowledged, however, that the definition “was the one the Judge decided on and I was bound by it.” Clinton 8/17/98 GJ at 19.
30. Clinton 8/17/98 GJ at 15, 93, 100, 102.
31. Clinton 8/17/98 GJ at 151.
32. Clinton 8/17/98 GJ at 168.
33. Clinton 8/17/98 GJ at 102-105, 167-68.
34. Clinton 8/17/98 GJ at 95-96, 100, 110, 139. The President did not always specify that the contact had to be direct. Id. at 15 (“(m)y understanding of the definition is it covers contact by the person being deposed with the enumerated areas, if the contact is done with an intent to arouse or gratify”); id. at 16 (definition covers “(a)ny contact with the areas there mentioned”).
35. Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7. These numbers include occasions when one or both of them had direct contact with the other’s genitals, but not occasions when they merely kissed. On the timing of some of their sexual encounters, Ms. Lewinsky’s testimony is at odds with the President’s. According to Ms. Lewinsky, she and the President had three sexual encounters in 1995 (the President said he recalled none) and two sexual encounters in 1997 (not one, as the President testified). Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7; Lewinsky 8/26/98 Depo. at 6; Clinton 8/17/98 GJ at 9-10. The President’s account omits the two 1995 encounters when Ms. Lewinsky was an intern (as well as one 1995 encounter when she worked on the White House staff), and it treats the 1997 encounter that produced the semen-stained dress as a single aberration.
36. Lewinsky 8/6/98 GJ at 34-36; Lewinsky 8/20/98 GJ at 17; Lewinsky 7/27/98 Int. at 2; Lewinsky 7/31/98 Int. at 4; Catherine Davis 3/17/98 GJ at 16; Erbland 2/12/98 GJ at 27-28, 43-44; Finerman 3/18/98 Depo. at 32; Kassorla 8/28/98 Int. at 2; Raines 1/29/98 GJ at 32-33; Tripp 7/2/98 GJ at 54, 101; Tripp 7/7/98 GJ at 171; Ungvari 3/19/98 GJ at 19, 25.
37. Lewinsky 8/6/98 GJ at 35; Lewinsky 7/27/98 Int. at 2.
38. Lewinsky 8/6/98 GJ at 12, 21; Lewinsky 2/1/98 Statement at 1. See also Andrew Bleiler 1/28/98 Int. at 3; Catherine Davis 3/17/98 GJ at 21; Kassorla 8/28/98 Int. at 2; Tripp 7/2/98 GJ at 100, 104-107; Ungvari 3/19/98 GJ at 23.
39. Lewinsky 8/6/98 GJ at 19; Catherine Davis 3/17/98 GJ at 20; Erbland 2/12/98 GJ at 29, 44; Ungvari 3/19/98 GJ at 20; Young 6/23/98 GJ at 37-38; but see Raines 1/29/98 GJ at 43 (testifying that she was “pretty sure” that Ms. Lewinsky spoke of reciprocal oral sex); Tripp GJ 7/2/98 at 101 (testifying that she understood that, on rare occasions, the President reciprocated).
40. Lewinsky 8/6/98 GJ at 38-39. See also Lewinsky 8/20/98 GJ at 24.
41. Lewinsky 8/6/98 GJ at 19-20, 38-39; Ungvari 3/19/98 GJ at 23-24.
42. Lewinsky 7/30/98 Int. at 5-13, 15-16; Lewinsky 8/6/98 GJ at 19-21; Lewinsky 8/20/98 GJ at 31-32, 40, 67-69; Lewinsky 8/26/98 Depo. at 20, 30-31, 50; Andrew Bleiler 1/28/98 Int. at 3; Catherine Davis 3/17/98 GJ at 20-21, 169; Erbland 2/12/98 GJ at 29, 43-45; Estep 8/23/98 Int. at 2; Kassorla 8/28/98 Int. at 2; Ungvari 3/19/98 GJ at 23-24.
43. Clinton 8/17/98 GJ at 10; Lewinsky 8/26/98 Depo. at 5. In Ms. Lewinsky’s recollection, the friendship started to develop following their sixth sexual encounter, when the President sat down and talked with her for about 45 minutes after she had complained that he was making no effort to get to know her. Lewinsky 8/26/98 Depo. at 23, 33-34.
44. Lewinsky 8/20/98 GJ at 59. See also id. at 52; Lewinsky 8/6/98 GJ at 168. After the President’s August 1998 speech acknowledging improper conduct with Ms. Lewinsky, she testified that she was no longer certain of her feelings because, in her view, he had depicted their relationship as “a service contract, that all I did was perform oral sex on him and that that’s all that this relationship was. And it was a lot more than that to me. . . .” Lewinsky 8/20/98 GJ at 54. See also id. at 53-56, 102-104.
45. MSL-55-DC-0178 (document retrieved from Ms. Lewinsky’s home computer); Catherine Davis 3/17/98 GJ at 147; Erbland 2/12/98 GJ at 92.
46. Lewinsky 8/20/98 GJ at 52; T1 at 101. See also Marcia Lewis 2/11/98 GJ at 7; Catherine Davis 3/17/98 GJ at 182.
47. Lewinsky 8/6/98 GJ at 18.
48. Lewinsky 7/27/98 Int. at 6; Currie 5/7/98 GJ at 60; Catherine Davis 3/17/98 GJ at 27; Raines 1/29/98 GJ at 53; Ungvari 3/19/98 GJ at 45; Young 6/23/98 GJ at 47; (49)
49. —
50. Lewinsky 7/27/98 Int. at 6.
51. Lewinsky 8/26/98 Depo. at 55-57; Lewinsky 7/27/98 Int. at 6.
52. Marcia Lewis 2/11/98 GJ at 7-8.
53. Erbland 2/12/98 GJ at 84. See also Lewinsky 8/26/98 Depo. at 56-57; Catherine Davis 3/17/98 GJ at 166-67. In late 1997, Ms. Lewinsky asked Vernon Jordan whether he believed that the Clintons would remain married. Lewinsky 2/1/98 Statement at 8; Jordan 3/3/98 GJ at 150.
54. Lewinsky 8/6/98 GJ at 17. See also Lewinsky 8/26/98 Depo. at 24; Lewinsky 8/24/98 Int. at 6; Tripp 7/7/98 GJ at 172.
55. Raines 1/29/98 GJ at 39. See also Catherine Davis 3/17/98 GJ at 18; Finerman 3/18/98 Depo. 47-49; Raines 1/29/98 GJ at 47-48; Tripp 7/14/98 GJ at 77, 79-81.
56. Lewinsky 8/6/98 GJ at 52-53.
57. Lewinsky 8/6/98 GJ at 52.
58. Lewinsky 8/6/98 GJ at 21-23; Lewinsky 7/27/98 Int. at 2. See also Catherine Davis 3/17/98 GJ at 36; Erbland 2/12/98 GJ at 38-39, 43; Finerman 3/18/98 Depo. at 26-29, 110, 116-17; Raines GJ at 51; Tripp 7/7/98 GJ at 62-63, 65-66; Ungvari 3/19/98 GJ at 81.
59. Lewinsky 8/6/98 GJ at 44; Lewinsky 8/24/98 Int. at 5; Currie 5/14/98 GJ at 131-32, 136, 141; Currie 7/22/98 GJ at 35, 77.
60. Lewinsky 8/20/98 GJ at 55.
61. Lewinsky 8/6/98 GJ at 23.
62. Lewinsky 8/6/98 GJ at 23-24; Lewinsky 7/27/98 Int. at 2. See also Catherine Davis 3/17/98 GJ at 36-37; Erbland 2/12/98 GJ at 38-39; Raines 1/29/98 GJ at 51; Ungvari 3/19/98 GJ at 81. Ms. Lewinsky gave the President a novel about phone sex, “Vox” by Nicholson Baker. Lewinsky 7/27/98 Int. at 13; 1361-DC-00000030 (White House list of books in private study, including “Vox”).
63. Lewinsky 7/30/98 Int. at 15.
64. Lewinsky 8/6/98 GJ at 23; Lewinsky 8/20/98 GJ at 6. The messages, on tapes that Ms. Lewinsky turned over to the OIC, are as follows: “Aw, shucks.” “Hey.” “Come on. It’s me.” “Sorry I missed you.” Lewinsky 8/6/98 GJ at 22-23; Lewinsky 7/29/98 Int. at 3, 5; Lewinsky 8/3/98 Int. at 6.
65. Lewinsky 8/6/98 GJ at 22-23; Catherine Davis 3/17/98 GJ at 28-29; Erbland 2/12/98 GJ at 49; Kassorla 8/28/98 Int. at 4; Raines 1/29/98 GJ at 89; Tripp 7/2/98 GJ at 89; Tripp 7/9/98 GJ at 95-97, 104-105; Ungvari 3/19/98 GJ at 31-33.
66. Lewinsky 8/6/98 GJ at 67-69.
67. Lewinsky 8/6/98 GJ at 74-75.
68. Lewinsky 8/6/98 GJ at 114.
69. Clinton 8/17/98 GJ at 10.
70. Clinton 8/17/98 GJ at 47, 51.
71. Clinton 8/17/98 GJ at 47, 124.
72. Lewinsky 8/6/98 GJ at 25-26.
73. Lewinsky 7/27/98 Int. at 12. See also MSL-55-DC-0184 – 186 (eight-line poem recovered from Ms. Lewinsky’s home computer that refers to President as “the Boss with whom we’re all smitten” and wishes him “Happy National Boss Day!”).
74. V006-DC-00000167; V006-DC-00000181 (gift record and donor information); V006-DC-0003646 (correspondence history).
75. V006-DC-00000157 – 158 (gift record and donor information).
76. Lewinsky 8/11/98 Int. at 2; V006-DC-00000178 (autographed photo).
77. Few of Ms. Lewinsky’s subsequent gifts were logged. Of the roughly 30 gifts (including several antiques) that, in her account, she gave the President, White House records show only the matted poem from interns, two or three neckties (records conflict), and a T-shirt. V006-DC-00000157; V006-DC-00000162; V006-DC-00000167; V006-DC-00000180; V006-DC-00000181; V006-DC-00003714; V006-DC-00003715.
78. MSL-55-DC-0177.
79. Lewinsky 8/26/98 Depo. at 5-6 & Ex. ML-7. In response to a January 20, 1998, subpoena seeking “any and all gifts . . . to or from Monica Lewinsky . . . including . . . any tie, mug, paperweight, book, or other article,” the President turned over a necktie, two antique books, a mug, and a silver standing holder for cigars or cigarettes. Subpoena V002; V002-DC-00000001; V002-DC-00000469. A subpoena dated July 17, 1998, identified specific gifts, including “Vox,” a novel about phone sex by Nicholson Baker that, according to Ms. Lewinsky, she gave the President in March 1997. Lewinsky 8/6/98 GJ at 183-84; Lewinsky 7/27/98 Int. at 13; Subpoena D1415. The President did not produce “Vox” in response to either subpoena, though his attorney represented that “the President has complied with (the) grand jury subpoenas.” David Kendall Letter to OIC, 8/31/98. “Vox,” however, does appear on an October 1997 list of books in the President’s private study, and Ms. Lewinsky saw it in the study on November 13, 1997. 1361-DC-00000030; Lewinsky 8/6/98 GJ at 183-84.
80. Lewinsky 8/26/98 Depo. at 5-6 & Ex. ML-7.
81. Lewinsky 8/20/98 GJ at 36. See also Lewinsky 8/6/98 GJ at 236; Catherine Davis 3/17/98 GJ at 153.
82. Lewinsky 8/6/98 GJ at 236; Lewinsky 8/20/98 GJ at 36; Lewinsky 8/3/98 Int. at 8; Lewinsky 8/11/98 Int. at 2-3. For example, one day after the President and Ms. Lewinsky talked by telephone on February 7, 1996, and one day after they talked on August 4, 1996, he wore a necktie she had given him. Lewinsky 8/5/98 Int. at 1; Lewinsky 8/11/98 Int. at 2-3.
83. Lewinsky 8/6/98 GJ at 236.
84. Clinton 8/17/98 GJ at 47. See also id. at 33-36, 43-46.
85. Lewinsky 8/6/98 GJ at 26.
86. Lewinsky 8/6/98 GJ at 189.
87. Lewinsky 8/6/98 GJ at 26-27.
88. Clinton 8/17/98 GJ at 48-49. In the Jones deposition, in contrast, the President was asked if he remembered anything written in Ms. Lewinsky’s notes or cards to him. He testified: “No. Sometimes, you know, just either small talk or happy birthday or sometimes, you know, a suggestion about how to get more young people involved in some project I was working on. Nothing remarkable. I don’t remember anything particular about it.” Clinton 1/17/98 Depo. at 62.
89. Lewinsky 2/1/98 Statement at 10. See also Lewinsky 8/20/98 GJ at 62-63; Lewinsky 8/6/98 GJ at 141-42, 178-79. Ms. Lewinsky once told Betty Currie: “As long as no one saw us–and no one did–then nothing happened.” Currie 1/27/98 GJ at 63-4.
90. Lewinsky 8/6/98 GJ at 78, 97-101; Lewinsky 7/27/98 Int. at 3.
91. Lewinsky 8/20/98 GJ at 22. See also Lewinsky 7/27/98 Int. at 9 (President assumed Ms. Lewinsky’s Jones affidavit would be a denial, since their pattern had been to conceal and deny).
92. Lewinsky 8/20/98 GJ at 4; Lewinsky 8/6/98 GJ at 166-67. See also Lewinsky 7/27/98 Int. at 9-10, 12.
93. Lewinsky 8/6/98 GJ at 234.
94. Clinton 8/17/98 GJ at 38.
95. Clinton 8/17/98 GJ at 38, 119. See also id. at 80, 119, 136, 153.
96. Clinton 8/17/98 GJ at 37.
97. Lewinsky 8/6/98 GJ at 53-54. See also Lewinsky 7/27/98 Int. at 2, 11; Lewinsky 8/19/98 Int. at 4; Lewinsky 2/1/98 Statement at 1.
98. Lewinsky 8/6/98 GJ at 53-54.
99. Lewinsky 8/6/98 GJ at 54.
100. Lewinsky 8/6/98 GJ at 54-55; Lewinsky 7/30/98 Int. at 10.
101. Lewinsky 8/6/98 GJ at 54-55.
102. Lewinsky 8/6/98 GJ at 18, 53-54.
103. Lewinsky 8/6/98 GJ at 18-19; Lewinsky 2/1/98 Statement at 1.
104. Lewinsky 8/20/98 GJ at 105; Lewinsky 2/1/98 Statement at 1.
105. Lewinsky 8/20/98 GJ at 22.
106. Lewinsky 2/1/98 Statement at 4; Lewinsky 8/6/98 GJ at 123, 233.
107. Clinton 1/17/98 Depo. at 50-51, 68.
108. Clinton 8/17/98 GJ at 118-19.
109. Clinton 8/17/98 GJ at 119. The President did not elaborate on his understanding of the words “ask()” or “lie” in that statement. In other exchanges, he indicated that he construes some words narrowly. Id. at 59 (accuracy of particular statement “depends on what the meaning of the word `is’ is”); id. at 107 (“I have not had sex with her as I defined it”); id. at 134 (“it depends on how you define alone”); id. (“there were a lot of times when we were alone, but I never really thought we were”).
110. Lewinsky 8/6/98 GJ at 47. Along with weekend visits, Ms. Lewinsky sometimes saw the President on holidays: New Year’s Eve, President’s Day, Easter Sunday, July 4. In November 1997, she grew irritated that the President did not arrange to see her on Veterans Day. Lewinsky 9/3/98 Int. at 2.
111. Lewinsky 8/6/98 GJ at 18. See also Lewinsky 8/20/98 GJ at 7, 22.
112. Lewinsky 8/6/98 GJ at 84-85; Lewinsky 8/20/98 GJ at 7. Ms. Lewinsky told friends about White House people she tried to avoid. Tripp 6/30/98 GJ at 159-60, 164; Tripp 7/14/98 GJ at 75; T1 at 32; 1037-DC-00000318 (email from Ms. Lewinsky).
113. Lewinsky 8/6/98 GJ at 34-35; Lewinsky 8/20/98 GJ at 16-17; Lewinsky 7/31/98 Int. at 4. The study is one of the most private rooms in the White House. Fox 2/17/98 GJ at 76. See also Chinery 7/23/98 GJ at 52; Currie 5/6/98 GJ at 67; Ferguson 7/17/87 GJ at 32, 38; Maes 4/8/98 GJ at 89-90; Podesta 6/23/98 GJ at 72.
114. Lewinsky 7/31/98 Int. at 4.
115. Lewinsky 8/4/98 Int. at 4.
116. Lewinsky 8/6/98 GJ at 36. See also Lewinsky 7/31/98 Int. at 4.
117. Lewinsky 8/6/98 GJ at 36-37; Lewinsky 7/27/98 Int. at 2. According to a Secret Service officer who entered the Oval Office when the President and Ms. Lewinsky were in or near the study, the door leading from the Oval Office to the hallway was slightly ajar. Muskett 7/21/98 GJ at 36-37, 39. In his Jones deposition, the President was asked if there are doors at both ends of the hallway. He responded: “(There) are, and they’re always open.” Clinton 1/17/98 Depo. at 59.
In early 1998, in the course of denying any sexual relationship with Ms. Lewinsky, the President repeatedly told Deputy Chief of Staff John Podesta that “the door was open.” Podesta 6/16/98 GJ at 88-89.
118. Lewinsky 8/6/98 GJ at 56. See also Lewinsky 7/31/98 Int. at 3.
