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|
|
| 250. Garabito 7/30/98 GJ at 16-17,
23-24. According to a colleague, Agent Garabito is over six feet tall, slender, and
Hispanic. OIC Memo of Interview with Special Agent Thomas M. Powers, 9/7/98. 251. Garabito 7/30/98 GJ at 25, 30-31. 252. Garabito 7/30/98 GJ at 32. Agent Garabito later recounted the incident to Larry L. Cockell, the head of the Presidential Protective Division of the Secret Service. The OIC learned of the episode from Agent Cockell's testimony. Cockell 7/23/98 GJ at 25-26. 253. 1472-DC-00000017 (call logs). 254. 1506-DC-00000017 (call logs). 255. Forbes, 9/22/97 at 2. 256. Lewinsky 8/6/98 GJ at 90. 257. Lewinsky 8/6/98 GJ at 91. See also Lewinsky 8/26/98 Depo. at 34; Tripp 7/7/98 GJ at 179-80. Ms. Lewinsky offered to return to the White House to see him, but the President said he needed to stay in the Residence because his daughter was ill. Lewinsky 7/30/98 Int. at 12; Lewinsky 8/24/98 Int. at 6. 258. Ungvari 3/19/98 GJ at 29-31; Lewinsky 8/3/98 Int. at 3; Ungvari 3/18/98 Int. at 4; Verna 6/11/98 Depo. at 10; 845-DC-00000009 (Tripp notes). 259. Ungvari 3/19/98 GJ at 30. 260. Lewinsky 8/11/98 Int. at 2. 261. Lewinsky 8/20/98 GJ at 19; Lewinsky 7/30/98 Int. at 12; 845-DC-00000010 - 11 (Tripp notes). 262. Lewinsky 8/26/98 Depo. at 34-35. 263. 1222-DC-00000112 (movement logs). The President and 32 guests saw Executive Decision that evening. 1506-DC-00000558 (White House daily diary). 264. 968-DC-00003459 (Hillary Clinton calendar). 265. Lewinsky 7/29/98 Int. at 3; Lewinsky 7/30/98 Int. at 12-13. 266. 827-DC-00000016 (Epass records). 267. 1222-DC-00000216 - 217; 1222-DC-00000112 - 113 (movement logs). 268. 1506-DC-00000139 (phone logs). 269. 968-DC-00003459 (Hillary Clinton calendar). Mrs. Clinton returned that evening. 1506-DC-00000559 (White House diary); 1222-DC-00000041 (Secret Service itinerary). 270. Lewinsky 8/26/98 Depo. at 35-36. 271. Lewinsky 8/26/98 Depo. at 36; Lewinsky 7/30/98 Int. at 12. 272. Lewinsky 8/26/98 Depo. at 38-39. 273. Lewinsky 8/26/98 Depo. at 37. 274. Lewinsky 7/30/98 Int. at 12-13; Lewinsky 8/26/98 Depo. at 37-38. In the grand jury, the President declined to answer whether Ms. Lewinsky would be lying if she said he had used a cigar as a sexual aid with her. Clinton 8/17/98 GJ at 110-11. 275. Lewinsky 7/30/98 Int. at 13. 276. Fox 2/17/98 GJ at 42-43. 277. Ludtke 6/5/98 Int. at 1-2. 278. Muskett 7/21/98 GJ at 124. Others also noted that Ms. Lewinsky spent time around the West Wing. Byrne 3/13/98 Depo. at 22-25; Byrne 6/25/98 Depo. at 23, 39-44, 55-62, 104-113; Byrne 7/30/98 GJ at 8, 39-40; Hannie 4/6/98 Int. at 2-3; Keating 2/25/98 GJ at 52. 279. Lewinsky 8/20/98 GJ at 12. 280. Bordley 8/13/98 GJ at 9-16. 281. Bordley 8/13/98 GJ at 20-23, 29. 282. Bordley 8/13/98 GJ at 25-29. 283. Ferguson 7/17/98 GJ at 14-17, 27-28; Ferguson 7/23/98 GJ at 14-17, 20. 284. Ferguson 7/17/98 GJ at 27. 285. Ferguson 7/17/98 GJ at 27-28; Ferguson 7/23/98 GJ at 20-21. 286. Ferguson 7/17/98 GJ at 29, 31. 287. Ferguson 7/17/98 GJ at 29. In addition, Officer Lewis Fox and Agent Nelson Garabito testified about admitting Ms. Lewinsky to the Oval Office on one occasion each, as recounted above. Fox 2/17/98 GJ at 32-37; Garabito 7/30/98 GJ at 16-32. Officer Fox also saw Ms. Lewinsky exit the Oval Office on another occasion, but he did not know how long she had been inside. Fox 2/17/98 GJ at 43-46. Officer Gary Byrne also testified about having seen Ms. Lewinsky in the Oval Office with the President, though some details of his account varied in different tellings. Byrne 7/30/98 GJ at 7-32; Byrne 7/17/98 GJ at 4-10. 288. Byrne 3/13/98 Depo. at 27-28, 46-47, 51-55; Byrne 6/25/98 Depo. at 31. 289. Lewinsky 8/20/98 GJ at 10-11; Lewinsky 7/31/98 Int. at 6. 290. Lieberman 1/30/98 GJ at 36-37. Ms. Lieberman testified that she continued to disapprove of Ms. Lewinsky. When she saw Ms. Lewinsky back in the White House after she no longer worked there, Ms. Lieberman asked Ms. Currie, "What is she doing here?" She also may have said to Ms. Currie, who told Ms. Lewinsky that she could watch a presidential helicopter departure, "What are you -- nuts?" or otherwise "expressed my displeasure."(291) 291. Lieberman GJ 1/30/98 at 50-52. - 292. Lewinsky 8/20/98 GJ at 8. 293. Lieberman 1/30/98 GJ at 41. 294. Panetta 1/28/98 GJ at 139-42. 295. Lieberman 1/30/98 GJ at 45. See also Panetta 1/28/98 GJ at 143 (describing precautions taken "to protect the President's office and protect his integrity," including preventing President from meeting alone with female acquaintances in circumstances that "could be misinterpreted"). 296. Lewis 2/11/98 GJ at 37-40. See also T3 at 15; Lewinsky 7/31/98 Int. at 7. Ms. Lieberman testified that the conversation occurred in September 1997. Lieberman 1/30/98 GJ at 66. In her recollection, the exchange began with Ms. Lewis coming up to her and saying, "You ruined [Ms. Lewinsky's] life on the basis of something that she never did." According to Ms. Lieberman, she made no response, and Ms. Lewis walked away. Later Ms. Lewis returned and said that she understood what Ms. Lieberman had done and why. Lieberman 1/30/98 GJ at 64-66. 297. Abramson 2/20/98 Int. at 3; Band 2/25/98 Int. at 2-3; Currie 5/6/98 GJ at 40-41; Ganong 2/12/98 Int. at 2; Keating 2/25/98 GJ at 73; Panetta 1/28/98 GJ at 139-42. 298. 1089-DC-00000970 (memo from Mr. Hilley to Ms. Lieberman); Hilley 5/19/98 GJ at 34-35, 47-50. Mr. Hilley testified that "extracurricular activities" -- which applied to Ms. Lewinsky and one of her colleagues who was also transferred -- did not refer to anything sexual in nature. Hilley 5/19/98 GJ at 49-50. See also Byrne 6/25/98 Depo. at 22-25, 27-28, 38, 43, 54-55; Currie 5/14/98 GJ at 19-35; Fox 2/17/98 GJ at 46-48; Maes 5/7/98 GJ at 34-42. 299. Duncan 2/18/98 GJ at 24. 300. V006-DC-00001347. 301. Duncan 2/18/98 GJ at 13-14. 302. Duncan 2/18/98 GJ at 23, 41. 303. Duncan 2/18/98 GJ at 8, 23-24. 304. Lewinsky 8/6/98 GJ at 61. The President was traveling to Oklahoma City on that day. V006-DC-00000694 (President's schedule); 968-DC-00000841 (same). 305. Keating 2/25/98 GJ at 76. The Pentagon position had a higher salary than Ms. Lewinsky's White House job. Lewinsky 8/3/98 Int. at 5. Ms. Lewinsky's supervisor, Jocelyn Jolley, was also transferred that day. Keating 2/25/98 GJ at 76-79; Lewinsky 8/6/98 GJ at 171. Unlike Ms. Lewinsky, Ms. Jolley was given a demotion: a temporary job at the General Services Administration. Jolley 2/24/98 GJ at 36-39; Keating 2/25/98 GJ at 79. 306. Keating 2/25/98 GJ at 78-79; Lewinsky 8/3/98 Int. at 3; Capps 3/23/98 Int. at 2; Fox 2/17/98 GJ at 47; Lynn 8/5/98 GJ at 14-16; Verna 7/21/98 GJ at 21-23. 307. Lewinsky 8/6/98 GJ at 171. See also Lewinsky 8/3/98 Int. at 3. Ms. Lewinsky testified that Mr. Keating led her to believe that she could probably return to work at the White House after the election. Lewinsky 8/3/98 Int. at 4. Mr. Keating testified that he told her that if she performed well at the Pentagon, "she may be able to get a job back in the White House. But not now." Keating 2/25/98 GJ at 79. 308. Lewinsky 8/26/98 Depo. at 60. 309. Lewinsky 8/6/98 GJ at 62. 310. 827-DC-00000016 (Epass records). 311. 1222-DC-00000219 (movement log). 312. Lewinsky 8/6/98 GJ at 62. See also Lewinsky 8/26/98 Depo. at 39; Lewinsky 7/27/98 Int. at 4; Tripp 7/9/98 GJ at 29-30. 313. In Ms. Lewinsky's recollection, Officer Muskett first said he needed to get Evelyn Lieberman's authorization before admitting Ms. Lewinsky to the Oval Office, but Ms. Lewinsky talked him out of it. Lewinsky 8/6/98 GJ at 91; Lewinsky 8/20/98 GJ at 42; Lewinsky 8/26/98 Depo. at 39-40; Lewinsky 7/27/98 Int. at 4; Lewinsky 7/30/98 Int. at 13; Lewinsky 7/31/98 Int. at 6. 314. Lewinsky 7/27/98 Int. at 4. 315. Lewinsky 8/6/98 GJ at 63. See also Lewinsky 8/26/98 Depo. at 40; Lewinsky 7/30/98 Int. at 13; Erbland 2/12/98 GJ at 37; Tripp 7/9/98 GJ at 31; 833-DC-00001070 (document recovered from Ms. Lewinsky's computer referring to President's promise to arrange for her return); MSL-DC-00001052 (another recovered computer file, saying in part: "You promised you would bring me back after the election with a snap of [your] fingers."); Lewinsky Statement 2/1/98 at 1 ("he promised to bring her back to the WH after the election"); Tripp 7/9/98 GJ at 31, 37-38, 42. 316. In a recorded conversation, Ms. Lewinsky recounted part of
this discussion: [H]e said, "I promise you," you know, something like, "if I win in
November, I'll have you back like that. You can do anything you want. You can be anything
you want." And then I made a joke and I said, "Well, can I be Assistant to the
President for Blow Jobs?" He said, "I'd like that." T7 at 34-35. 317. Lewinsky 8/6/98 GJ at 64. 318. Clinton 8/17/98 GJ at 130. 319. Lewinsky 8/26/98 Depo. at 40. 320. Lewinsky 8/6/98 GJ at 94-97. 321. Lewinsky 8/26/98 Depo. at 40-41. 322. Lewinsky 8/26/98 Depo. at 41. 323. Lewinsky 8/26/98 Depo. at 41. 324. Lewinsky 8/6/98 GJ at 20, 95-97; Lewinsky 7/30/98 Int. at 13. 325. Lewinsky 8/6/98 GJ at 95; Lewinsky 8/26/98 Depo. at 41-44; Lewinsky 7/27/98 Int. at 4-5; Lewinsky 7/30/98 Int. at 13. 326. Lewinsky 8/6/98 GJ at 92; Lewinsky 7/27/98 Int. at 4-5; Lewinsky 7/30/98 Int. at 13. 327. 1248-DC-00000008 (phone logs). 328. Lewinsky 8/6/98 GJ at 93, 97. 329. Lewinsky 8/6/98 GJ at 93. See also Lewinsky 8/26/98 Depo. at 43; Lewinsky 7/27/98 Int. at 5; Lewinsky 7/30/98 Int. at 13. Ms. Lewinsky testified that she did not see Mr. Ickes but recognized his voice. Lewinsky 8/6/98 GJ at 97. 330. Lewinsky 8/6/98 GJ at 93; Lewinsky 8/26/98 Depo. at 45; Lewinsky 7/27/98 Int. at 5; Lewinsky 7/30/98 Int. at 13. 331. Lewinsky 8/6/98 GJ at 94. See also Lewinsky 7/30/98 Int. at 11; Tripp 7/9/98 GJ at 30-36; 845-DC-00000012 - 13 (Tripp notes). 332. Muskett 7/21/98 GJ at 9-13. 333. Muskett 7/21/98 GJ at 22-24. 334. Muskett 7/21/98 GJ at 25-26, 83. 335. Muskett 7/21/98 GJ at 27-28, 91-93. 336. Muskett 7/21/98 GJ at 28, 31-33. 337. Muskett 7/21/98 GJ at 34-37. 338. Lewinsky 8/6/98 GJ at 36-37; Lewinsky 7/27/98 Int. at 2. 339. Muskett 7/21/98 GJ at 36-37, 39-40. Officer Muskett recalled that the plainclothes agent on duty at the time was Reginald Hightower. Muskett 7/21/98 GJ at 22. While not "100 percent sure" that this incident occurred, Agent Hightower testified that "it probably did happen." Hightower 7/28/98 GJ at 46-49. 340. Muskett 7/21/98 GJ at 42-46. Mr. Ickes testified that he cannot recall this incident but cannot rule it out. Ickes 8/5/98 GJ at 58-59. 341. Muskett 7/21/98 GJ at 47-52, 89. 342. 1506-DC-00000144 (phone logs). 343. Lewinsky 8/6/98 GJ at 64-65. See also Lewinsky 2/1/98 Statement at 1; Lewinsky 7/31/98 Int. at 6-7; Lewinsky 8/3/98 Int. at 5; Tripp 7/9/98 GJ at 72-73; 845-DC-00000014 (Tripp notes); T2 at 17. 344. Lewinsky 8/6/98 GJ at 65; Lewinsky 7/29/98 Int. at 3-4; Lewinsky 8/3/98 Int. at 5. 345. Lieberman 1/30/98 GJ at 62. 346. Lieberman 1/30/98 GJ at 62. 347. Bowles 4/2/98 GJ at 66-67. 348. Currie 5/7/98 GJ at 49-50. 349. Jordan 3/3/98 GJ at 64-65. 350. V006-DC-00002289 (email noting departures of White House
employees); Lewinsky 8/6/98 GJ at 65. According to the job description for the position: 351. Lewinsky 7/29/98 Int. at 1. 352. Lewinsky 8/6/98 GJ at 66. 353. Tripp 7/9/98 GJ at 94-98. 354. Lewinsky 8/6/98 GJ at 28 & Ex. ML-7. 355. Tripp 7/14/98 GJ at 3-4, 11-12; 845-DC-00000019 (Tripp notes). 356. Lewinsky 7/29/98 Int. at 4-5. 357. Lewinsky 7/30/98 Int. at 14. See also Lewinsky 7/29/98 Int. at 4; Lewinsky 8/6/98 GJ at 27-28; Tripp 7/9/98 GJ at 118-19 (mistakenly indicating that this occurred July 15, 1996); 845-DC-00000018 (Tripp notes). 358. 1506-DC-00000275 (call log); 1506-DC-000000638. 359. Lewinsky 7/29/98 Int. at 4-5; Lewinsky 7/30/98 Int. at 14-15; 845-DC-00000016 - 17 (Tripp notes); 845-DC-00000020 - 22 (same); Tripp 7/9/98 GJ at 102-04, 115-16; Tripp 7/14/98 GJ at 11-12, 35-37. 360. 1506-DC-00000222 (5/21/96); 1506-DC-00000264 (7/5/96); 1506-DC-00000268 (7/6/96); 1506-DC-00000328 (10/22/96); 1506-DC-00000353 (12/2/96) (President's schedules). 361. Lewinsky 7/29/98 Int. at 3; Finerman 3/18/98 Depo. at 49-50; Tripp 7/9/98 GJ at 53, 61-62, 94. Along with talking with the President, Ms. Lewinsky also contacted former White House colleagues for help returning to work there. Lewinsky 8/3/98 Int. at 5. 362. T7 at 36. 363. T7 at 36-37. 364. Lewinsky 7/30/98 Int. at 14; Lewinsky 8/6/98 GJ at 21; Erbland 2/12/98 GJ at 30; Tripp 7/14/98 GJ at 4-6; 845-DC-00000020 (Tripp notes). 365. Lewinsky 8/20/98 GJ at 25. 366. Lewinsky 7/29/98 Int. at 3, 16; Tripp 7/9/98 GJ at 99-100; 845-DC-00000015 (Tripp notes). The President was at the Renaissance Hotel in Washington from 8:40 to 9:25 p.m. that day. 1506-DC-00000188 - 189 (President's schedules). 367. V006-DC-00000534 (radio address guest list); 1222-DC-00000045 (itinerary); V006-DC-00001841 - 1847 (photographs); V006-DC-00003735 (photo requests); V006-DC-00001865 (videotape). 368. Lewinsky 8/20/98 GJ at 28-31; Lewinsky 7/29/98 Int. at 16; Lewinsky 8/24/98 Int. at 6-7; V006-DC-00000682 (President's schedule for August 18); V006-DC-00003735 (photo request from Ms. Lewinsky); MSL-DC-0000489 - 490 (event invitation); Tripp 7/9/98 GJ at 125-26; 845-DC-00000019 (Tripp notes). 369. Lewinsky 8/20/98 GJ at 28-31. See also Lewinsky 7/30/98 Int. at 17. 370. Lewinsky 7/31/98 Int. at 7. Ms. Lewinsky thought that this might have been October 23 or 24. Id. The President was at the Sheraton Washington Hotel from 6:55 to 8:05 p.m. on October 23. 1506-DC-00000334 - 335 (President's schedule). 371. Newsweek, 8/10/98, cover photo. 372. Lewinsky 8/11/98 Int. at 2. 373. Lewinsky 8/20/98 GJ at 26-27. 374. Lewinsky 7/29/98 Int. at 5. 375. V006-DC-00000007 (WAVES records); V006-DC-00001855 - 1856 (photos from the reception); V006-DC-00000391 (White House event attendance records). 376. MSL-DC-00001052 (spelling and punctuation corrected). See also Lewinsky 2/1/98 Statement at 1-2; Tripp 7/14/98 GJ at 32-34. Ms. Lewinsky did not send this letter. Lewinsky 8/4/98 Int. at 5. 377. Catherine Davis 3/17/98 GJ at 23-24, 27; Finerman 3/18/98 Depo. at 12; Kassorla 8/28/98 Int. at 4; Raines 1/29/98 GJ at 31-32; Tripp 7/2/98 GJ at 41-43. 378. Tripp 7/14/98 GJ at 39-40; 845-DC-00000022 (Tripp notes). 379. 833-DC-00001974 (email to Ms. Tripp). 380. Currie 5/7/98 GJ at 63. 381. Currie 5/6/98 GJ at 97-98. 382. Currie 5/6/98 GJ 14-15. 383. Currie 5/6/98 GJ at 52-53, 94-96. 384. 827-DC-00000002, 827-DC-00000018 (Ms. Lewinsky's WAVES records). 385. Currie 5/6/98 GJ at 57-58. 386. Currie 5/6/98 GJ at 84-85. In a later appearance before the grand jury, Ms. Currie testified that she could no longer recall any occasions when she came just to admit Ms. Lewinsky, but she could not rule it out. Currie 7/22/98 GJ at 24. 387. Currie 1/27/98 GJ at 32-33. See also Currie 5/6/98 GJ at 98; Currie 7/22/98 GJ at 25-26, 41. Ms. Currie subsequently wavered on this point. Currie 7/22/98 GJ at 14 ("[t]he President, for all intents and purposes, is never alone"); id. at 15-16 (testifying that President and Ms. Lewinsky, in study together, were "not alone" so long as Ms. Currie was at her desk); id. at 25 (agreeing that Ms. Lewinsky and President were alone together); id. at 131 ("I was always there. And I considered them not to be alone. . . . I always thought that my presence there meant that they were not alone."). Cf. Clinton 8/17/98 GJ at 134 ("there were a lot of times when we were alone, but I never really thought we were"). 388. Pape 5/18/98 Int. at 3-4. 389. Chinery 6/11/98 Depo. at 33. 390. Chinery 6/11/98 Depo. at 44-45; Chinery 7/23/98 GJ at 49. 391. Chinery 7/23/98 GJ at 8; Chinery 6/11/98 Depo. at 13-17. For other Secret Service corroboration of Ms. Currie's role, see Chinery 7/23/98 GJ at 49-50; Chinery 6/11/98 Depo. at 33, 37, 44; Garabito 7/30/98 GJ at 44-47; Shegogue 8/4/98 GJ at 11, 14-19, 24-27. 392. Lewinsky 8/20/98 GJ at 5. See also id. at 14; Lewinsky 8/19/98 Int. at 5. 393. Currie 5/6/98 GJ at 88-89. See also id. at 184; Currie 5/14/98 GJ at 78. 394. Currie 5/6/98 GJ at 88-89. 395. Currie 5/14/98 GJ at 72-74, 91; Currie 1/24/98 Int. at 3. 396. 837-DC-00000001; 837-DC-00000004; 837-DC-00000006; 837-DC-0000008; 837-DC-00000011; 837-DC-00000014; 837-DC-00000018. 397. Lewinsky 7/31/98 Int. at 13; Marcia Lewis 2/11/98 GJ at 28-30; T1 at 63-64. 398. Dragotta 8/13/98 GJ at 10-11; Janney 8/13/98 GJ at 7, 9-11, 14; Niedzwiecki 7/30/98 GJ at 12-13, 20-21; Pape 8/5/98 GJ at 24; Keith Williams 7/23/98 GJ at 14. 399. Currie 5/14/98 GJ at 72-73. 400. Currie 5/14/98 GJ at 73-74, 86-89; Currie 7/22/98 GJ at 51-52. 401. Currie 5/14/98 GJ at 88-89. See also id. at 91; Currie 7/22/98 GJ at 49-50 (testifying that she did not open sealed cards from Ms. Lewinsky to President but "may have read" unsealed ones). 402. Currie 5/6/98 GJ at 88-89. See also Currie 5/14/98 GJ at 78. 403. "The President got everything anyone sent him." Currie 5/6/98 GJ at 129. 404. Currie 5/14/98 GJ at 143-45; Currie 1/24/98 Int. at 8. 405. Currie 5/6/98 GJ at 157-58. 406. Currie 5/6/98 GJ at 156; Currie 7/22/98 GJ at 42-43. 407. Currie 1/27/98 GJ at 63-64. See also Currie 5/6/98 GJ at 164; Currie 7/22/98 GJ at 31-33. According to Ms. Lewinsky, the President at one point told her similarly that "if the two people who are involved [in a relationship] say it didn't happen -- it didn't happen." Lewinsky 2/1/98 Statement at 10, ¶ 11. 408. Currie 5/14/98 GJ at 131-43. Ms. Currie testified: "I think . . . what I was trying to do was allow the President to have personal and private phone calls if he wanted to. And the appearance of any impropriety, I didn't want to have it." Id. at 141. 409. Currie 7/22/98 GJ at 33-35. 410. Dragotta 8/13/98 GJ at 8-10; Pape 8/5/98 GJ at 17-18. Asked if she had tried to persuade officers not to log in Ms. Lewinsky's visits, Ms. Currie testified: "I hope I didn't. I can't imagine -- and I can't imagine that it could be." Currie 7/22/98 GJ at 115. None of the Uniformed Division officers interviewed by the OIC acknowledged having permitted Ms. Lewinsky to enter the White House without proper clearance. However, as noted elsewhere, there is clear evidence that Ms. Lewinsky was in the White House on days for which no records show her entry or exit. 411. V006-DC-00003712 (2/24/97 message). Records show seven calls from Ms. Lewinsky's line to Ms. Currie's line on December 5, 1997, for example, and six calls the following day. 1216-DC-00000022. 412. Currie 5/6/98 GJ at 16-17, 20-21, 68-70, 73-74, 85-86; Currie 5/7/98 GJ at 8. See also 1037-DC-00000341 (email). 413. Currie 5/6/98 GJ at 73-74, 85-86. Ms. Currie later said that "I don't want the impression of sneaking, but it's just that I brought her in without anyone seeing her." Id. at 156. Ms. Lewinsky confirmed that Ms. Currie helped her avoid Mr. Goodin and others. Lewinsky 8/20/98 GJ at 15; Lewinsky 7/27/98 Int. at 4; Lewinsky 8/3/98 Int. at 5; Lewinsky 8/24/98 Int. at 7. 414. Currie 5/6/98 GJ at 84-85. 415. Lewinsky 7/31/98 Int. at 4. 416. Lewinsky 8/5/98 Int. at 3. 417. Lewinsky 7/31/98 Int. at 5. Ms. Lewinsky told confidants about Ms. Currie's role. Catherine Davis 3/17/98 GJ at 17, 33, 37-38; Erbland 2/12/98 GJ at 43; Finerman 3/18/98 Depo. at 39-40; Raines 1/29/98 GJ at 49; Ungvari 3/19/98 GJ at 38-40; 1037-DC-00000337 - 338 (email from Ms. Lewinsky); 1037-DC-00000001 - 02 (card from Ms. Lewinsky). 418. Carbonetti 6/16/98 Int. at 2; Chinery 6/11/98 Depo. at 39-40; Janney 5/27/98 Int. at 2; LaDow 5/27/98 Int. at 3; Ludtke 6/5/98 Int. at 2; Pape 8/5/98 GJ at 23-24; Pape 5/18/98 Int. at 3-6. 419. Chinery 7/23/98 GJ at 50. 420. Pape 5/18/98 Int. at 5. 421. Washington Post, 2/14/97, "Love Notes" at 44 (824-DC-00000013 - 14). See also 1078-DC-00000002. A copy of the ad was found in the box of gifts and other items that Ms. Lewinsky, after being subpoenaed in the Jones case, gave Ms. Currie for safekeeping. 824-DC-00000013 - 14; Lewinsky 8/20/98 GJ at 71-72. Ms. Lewinsky told several people about the ad. Catherine Davis 3/17/98 GJ at 28; Finerman 3/18/98 Depo. at 22-23; Marcia Lewis 2/10/98 GJ at 59-61; Raines 1/29/98 GJ at 109. In email on February 13, she said she planned to check her telephone messages from London (where she would be on Valentine's Day) "in the hopes that the creep will call and say 'Thank you for my love note. I love you. Will you run away with me?' What do ya think the likelihood of that happening is?" 833-DC-00001934. On February 19, she wrote in an email that the President had not left any message for her on Valentine's Day. 833-DC-00009446. 422. 827-DC-00000018 (Epass records); Kessinger 2/24/98 Int. at 2. 423. 833-DC-00001906 (email from Ms. Lewinsky to Ms. Tripp). 424. V006-DC-00003712. 425. V006-DC-00003720 (radio address attendance list). 426. 827-DC-00000018; V006-DC-00000008; V006-DC-00001796. 427. 1222-DC-00000234; 968-DC-00000073. 428. 968-DC-00003506. 429. Lewinsky 8/26/98 Depo. at 45-46, 48-49; Lewinsky 8/6/98 GJ at 30. 430. Lewinsky 8/6/98 GJ at 45-46. 431. Lewinsky 8/26/98 Depo. at 46. 432. Lewinsky 8/6/98 GJ at 30. 433. Lewinsky 8/6/98 GJ at 30-31, 46-47; Lewinsky 7/30/98 Int. at 15; Lewinsky 7/31/98 Int. at 5. Mr. Goodin and Ms. Currie confirmed that Ms. Lewinsky stayed behind and talked with the President after the radio address. Currie 1/27/98 GJ at 34; Goodin 2/17/98 GJ at 52, 55. Mr. Goodin testified that he approached the President and "basically offer[ed] to chase her away because I didn't know if that was a good use of his time," but the President replied that "she's a friend of a political supporter." Goodin 2/17/98 GJ at 56. Nancy Hernreich, who was not present at the radio address, testified that Mr. Goodin told her about Ms. Lewinsky's presence there on the following work day. Hernreich 2/26/98 GJ at 5-9. 434. Currie 7/22/98 GJ at 130-31; Currie 1/27/98 GJ at 34-35; Lewinsky 8/6/98 GJ at 31; Lewinsky 7/30/98 Int. at 15. 435. Currie 7/22/98 GJ at 131. Ms. Currie also maintained that the President and Ms. Lewinsky were "[n]ever out of eyesight." Id. at 135. The President, however, acknowledged "inappropriate intimate contact" with Ms. Lewinsky on February 28 and testified that, to the best of his knowledge, Ms. Currie never witnessed any such encounters between himself and Ms. Lewinsky. Clinton 8/17/98 GJ at 10, 53-54. 436. Lewinsky 8/26/98 Depo. at 46-47. 437. Lewinsky 8/26/98 Depo. at 46-47. 438. Lewinsky 8/26/98 Depo. at 47; Lewinsky 8/6/98 GJ at 31. Ms. Currie testified that the President later asked her, "Did Monica show you the hat pin I gave her?" Currie 5/6/98 GJ at 142. 439. Lewinsky 8/6/98 GJ at 156. See also Lewinsky 8/20/98 GJ at
72; Lewinsky 8/26/98 Depo. at 47; Currie 5/6/98 GJ at 101-102; Catherine Davis 3/17/98 GJ
30-31; Erbland 2/12/98 GJ at 40-41; Finerman 3/18/98 Depo. at 15-16; Marcia Lewis 2/10/98
GJ at 51-52; Raines 1/29/98 GJ at 53-55. 440. Lewinsky 8/24/98 Int. at 7; Finerman 3/18/98 Depo. at 22; Raines 1/29/98 GJ at 109. 441. Lewinsky 8/26/98 Depo. at 47-48. See also Lewinsky 8/6/98 GJ at 31, 38-39. 442. Lewinsky 8/26/98 Depo. at 47-48. See also Lewinsky 8/6/98 GJ at 31, 38-39. 443. Lewinsky 7/30/98 Int. at 15. 444. Lewinsky 8/26/98 Depo. at 48. 445. Lewinsky 8/6/98 GJ at 32, 39-40. Ms. Lewinsky testified that she did not keep the soiled dress as a souvenir. She said she does not ordinarily clean her clothes until she is ready to wear them again. "I was going to clean it. I was going to wear it again." Lewinsky 8/6/98 GJ at 41. She also testified that she was not certain that the stains were semen. She had dined out after the radio address, "[s]o it could be spinach dip or something." Lewinsky 8/6/98 GJ at 40. See also Lewinsky 7/29/98 Int. at 17. 446. FBI Lab Reports, 8/6/98, 8/17/98. 447. Clinton 8/17/98 GJ at 55. 448. Clinton 8/17/98 GJ at 138. 449. Clinton 8/17/98 GJ at 136-37. 450. V006-DC-00000008 (WAVES records); V006-DC-00001792 (WAVES request). Phone records indicate that Ms. Lewinsky called Ms. Currie for one minute at 8:37 a.m. that day. 1014-DC-00000022. 451. 968-DC-00000236 (presidential diary); V006-DC-00002130 (movement log); 968-DC-00003510 (phone log). Mrs. Clinton was in Africa. 968-DC-00003843 (schedule). 452. Lewinsky 7/30/98 Int. at 16; Lewinsky 8/20/98 GJ at 67-69; Lewinsky 8/24/98 Int. at 7. 453. Lewinsky 8/26/98 Depo. at 49. 454. Lewinsky 8/26/98 Depo. at 50. 455. Lewinsky 8/26/98 Depo. at 50. 456. Lewinsky 8/26/98 Depo. at 51. See also Lewinsky 8/20/98 GJ at 68-69; Lewinsky 7/30/98 Int. at 16. Ms. Lewinsky testified that their genitals only briefly touched: "[W]e sort of had tried to do that, but because he's so tall and he couldn't bend because of his knee, it didn't really work." Lewinsky 8/26/98 Depo. at 51. 457. Lewinsky 8/20/98 GJ at 68-69; Lewinsky 8/26/98 Depo. at 50; Lewinsky 7/30/98 Int. at 16. 458. Lewinsky 7/30/98 Int. at 16. 459. Clinton 8/17/98 GJ at 10. 460. Clinton 8/17/98 GJ at 54-55, 137-38. 461. Lewinsky 8/6/98 GJ at 66; Lewinsky 7/27/98 Int. at 5; Lewinsky 7/31/98 Int. at 8; Lewinsky 2/1/98 Statement at 1-2; MSL-DC-00001052; T1 at 38. Mr. Nash said he had never heard of Ms. Lewinsky before January 1998. Nash 3/19/98 Int. at 1; Nash 9/2/98 Int. at 1. 462. Lewinsky 8/6/98 GJ at 67. 463. Lewinsky 8/6/98 GJ at 66-67; Lewinsky 7/27/98 Int. at 5; Lewinsky 8/5/98 Int. at 2. 464. Lewinsky 8/6/98 GJ at 86-87. 465. Lewinsky 8/26/98 Depo. at 62. 466. Clinton 8/17/98 GJ at 113-14. Later the President said: "I didn't order her to be hired at the White House. I could have done so. I wouldn't do it."(467) 467. Clinton 8/17/98 GJ at 124. 468. Lewinsky 8/6/98 GJ at 97-99; Lewinsky 7/27/98 Int. at 3. 469. Lewinsky 8/6/98 GJ at 87; Lewinsky 7/27/98 Int. at 3. 470. Lewinsky 8/6/98 GJ at 98-99; Lewinsky 7/27/98 Int. at 3. See also Lewinsky 9/3/98 Int. at 1. 471. Kaye 5/21/98 GJ at 103-108. Ms. Finerman testified that she did have a conversation along these lines with Mr. Kaye. Finerman 3/18/98 Depo. at 52-57. Mr. Kaye testified that he could not recall having discussed Ms. Lewinsky with Ms. Scott. Kaye 5/21/98 GJ at 44. Ms. Scott testified that she could not recall talking to Mr. Kaye about Ms. Lewinsky in this period, or talking to him about phone calls between Ms. Lewinsky and the President at any time. Scott 3/31/98 GJ at 53. 472. 827-DC-00000018 (Epass records). 473. 1222-DC-00000242. 474. 968-DC-00003533. 475. Lewinsky 8/4/98 Int. at 2-3. 476. Lewinsky 8/6/98 GJ at 24-25, 101. 477. Lewinsky 8/4/98 Int. at 2; Lewinsky 7/31/98 Int. at 16. 478. Lewinsky 8/4/98 Int. at 2-3. 479. Lewinsky 8/4/98 Int. at 3. Ms. Lewinsky later told confidants
about the May 24 break-up. Catherine Davis 3/17/98 GJ at 133-35; Erbland 2/12/98 GJ at
46-47; Kassorla 8/28/98 Int. at 4; Raines 1/29/98 GJ at 58-59; Tripp 7/14/98 GJ at 78-84;
Ungvari 3/19/98 GJ at 80. Dr. Kassorla, Ms. Lewinsky's therapist, told Ms. Lewinsky that
the President's statement sounded rehearsed and insincere. Kassorla 8/28/98 Int. at 4. 480. Lewinsky 8/6/98 GJ at 25. See also Lewinsky 7/27/98 Int. at 3 (birthday kiss 8/16/97; Christmas kiss 12/28/97); id. at 7 (President told her that Christmas kiss was permissible). Ms. Lewinsky tried to initiate genital contact with the President on August 16, 1997, but he rebuffed her. Lewinsky 8/20/98 GJ at 70. 481. Clinton v. Jones, 117 S. Ct. 1636 (1997). |