|
|
|
| 482. Currie 5/6/98 GJ at 31-33; Currie
5/7/98 GJ at 44, 68; Currie 5/14/98 GJ at 6-8, 148. Ms. Currie was uncertain when this
occurred. Currie 5/6/98 GJ at 31. 483. Currie 5/6/98 GJ at 45; Currie 5/14/98 GJ at 146. 484. Currie 5/14/98 GJ at 146. 485. Currie GJ 5/14/98 at 121; Currie GJ 5/6/98 at 13, 81. 486. Currie 5/7/98 GJ at 43-44. 487. Currie 5/7/98 GJ at 68. 488. Currie 5/7/98 GJ at 69. Contrary to Ms. Currie's testimony, Ms. Scott testified that the President never asked her to help Ms. Lewinsky, though they may have discussed it. In Ms. Scott's account, she met with Ms. Lewinsky as a favor to Ms. Currie. Scott 3/19/98 GJ at 20, 32, 37, 78-79, 84-85; Scott 3/26/98 GJ at 13, 15; Scott 3/31/98 GJ at 43-44. For his part, the President testified that he talked with Ms. Scott about bringing Ms. Lewinsky back to work at the White House, though he did not order her to hire Ms. Lewinsky. Clinton 8/17/98 GJ at 130. 489. Lewinsky 8/6/98 GJ at 67; Lewinsky 8/24/98 Int. at 7. Ms. Lewinsky also tried to get a White House job through other avenues. She applied for a position at the National Security Council and had interviews there on May 1 and June 11. Lewinsky 7/27/98 Int. at 5; Bailey 5/26/98 GJ at 23; Dimel 2/18/98 Int. at 1; Friedrich 7/17/98 Int. at 1; Stott 2/27/98 Int. at 2; V006-DC-00000008 (WAVES records); 827-DC-00000018 (Epass records); 833-DC-00001876 (Tripp email regarding a job announcement); V006-DC-00000221 - 224 (Dimel documents). She was not chosen for the job. V006-DC-00000223 - 224 (Dimel letter). She also pursued a job in the White House press office. Lewinsky 7/27/98 Int. at 5. At one point Ms. Lewinsky told the President that she had applied for these jobs, and he responded that he needed to know in advance if he was to help her. Lewinsky 7/27/98 Int. at 5. 490. 827-DC-00000018 (Epass records); V006-DC-00000008 (WAVES records); Scott GJ 3/19/98 at 17. 491. 1037-DC-00000265- 266 (spelling and punctuation corrected). See also Finerman 3/18/98 Depo. at 50-51 (recounting this meeting); Tripp 7/14/98 GJ at 89-91 (recounting this meeting). 492. Scott 3/19/98 GJ at 52. See also Scott 3/26/98 GJ at 16-17. 493. Scott 3/19/98 GJ at 74. 494. Scott 3/19/98 GJ at 87. 495. 833-DC-00001070. 496. Currie 5/7/98 GJ at 35; see id. at 39. 497. MSL-DC-00001176 - 1177. A revised version of the letter was also found in Ms. Lewinsky's apartment. MSL-DC-00001192. Consistent with a statement in the draft, Ms. Scott testified that "I don't hear about White House jobs." Scott 3/19/98 GJ at 90. Ms. Scott also testified that she recalled only a short thank-you note after her June 16 meeting with Ms. Lewinsky, though she did receive a "real pissy letter" from Ms. Lewinsky at some point, which she threw away. Scott 3/19/98 GJ at 77; Scott 3/26/98 GJ at 18. 498. MSL-DC-00001227 (emphasis in original). Ms. Lewinsky sent a version of the note. Lewinsky 8/4/98 Int. at 6. Records indicate that Ms. Lewinsky was in Madrid the following week and in Los Angeles later in the month. MSL-DC-00001221; 852-DC-00000035; 929-DC-00000056; 852-DC-00000037. 499. 1037-DC-00000103, 1037-DC-00000280, 1037-DC-00000296 (email from Catherine Davis to Ms. Lewinsky referring to "[y]our idea about working in another city or country") (multiple copies of same message). 500. Lewinsky 7/29/98 Int. at 8. 501. Lewinsky 8/6/98 GJ at 68, 87; Lewinsky 7/29/98 Int. at 7-8; Lewinsky 8/11/98 Int. at 6. 502. Lewinsky 8/6/98 GJ at 68, 87. See also Lewinsky 7/29/98 Int. at 7-8; Lewinsky 8/11/98 Int. at 6. 503. Lewinsky 8/6/98 GJ at 68-69, 87-89. See also Lewinsky 8/26/98 Depo. at 62-63. 504. Lewinsky 8/6/98 GJ at 68, 87; Lewinsky 7/29/98 Int. at 7-8; Lewinsky 8/11/98 Int. at 6. 505. Lewinsky 7/29/98 Int. at 8; Lewinsky 8/13/98 Int. at 1. Ms. Lewinsky said she thought of the United Nations because a former Pentagon colleague worked there and liked it. Lewinsky 8/13/98 Int. at 1. 506. Clinton 8/17/98 GJ at 124. 507. Lewinsky 8/6/98 GJ at 69. See also Lewinsky 7/29/98 Int. at 8. 508. Lewinsky 8/6/98 GJ at 69. See also Lewinsky 7/29/98 Int. at 7. 509. 827-DC-00000018. 510. V006-DC-00002140; V006-DC-00002214. 511. Lewinsky 8/6/98 GJ at 75. See also Lewinsky 7/29/98 Int. at 8; Lewinsky 8/4/98 Int. at 4. 512. Lewinsky 7/29/98 Int. at 8-9. 513. Lewinsky 8/26/98 Depo. at 54-55; Lewinsky 7/27/98 Int. at 3. 514. Lewinsky 8/26/98 Depo. at 55-56. 515. Lewinsky 8/26/98 Depo. at 56-57. See also Lewinsky 7/28/98 Int. at 6. 516. Lewinsky 8/26/98 Depo. at 56-57. See also Catherine Davis 3/17/98 GJ at 180; Tripp 7/7/98 GJ at 55-56; 845-DC-00000193 (Tripp notes). 517. Lewinsky 8/6/98 GJ at 72. See also Lewinsky 8/4/98 Int. at 4. 518. Lewinsky 8/6/98 GJ at 70-71; Tripp 7/14/98 GJ at 107-116. 519. Lewinsky GJ 8/6/98 at 72, 77; Lewinsky 302 7/29/98 at 7. According to Ms. Tripp, she had tried to alert Mr. Lindsey about the contact from Mr. Isikoff, but Mr. Lindsey, with whom she had worked at the White House, did not return her calls and pages. Ms. Tripp testified that she tried to reach him because "he was one of the protectors" of the President. Tripp 7/14/98 GJ at 111. Mr. Lindsey testified that he returned a page from Ms. Tripp, but not until July or August. Lindsey 2/18/98 GJ at 132-33. 520. Lewinsky 8/6/98 GJ at 71. 521. Lewinsky 8/6/98 GJ at 73-74; Lewinsky 7/29/98 Int. at 7. 522. Lewinsky 7/29/98 Int. at 7; Lewinsky 8/11/98 Int. at 5. 523. Lewinsky 8/6/98 GJ at 73; Lewinsky 7/29/98 Int. at 7. 524. 968-DC-00003546. 525. Lewinsky 8/6/98 GJ at 75. 526. 827-DC-00000018; see also Steven Pape 5/18/98 Depo. at 3. 527. V006-DC-00002142 (movement logs). 528. Lewinsky 8/6/98 GJ at 75-76; Lewinsky 7/29/98 Int. at 9. Ms. Currie did not recall Ms. Lewinsky's visit of July 14. Currie 7/22/98 GJ at 81. 529. Lewinsky 8/6/98 GJ at 76. 530. 1222-DC-00000251 (movement logs). 531. Lewinsky 8/6/98 GJ at 76. The President was referring to the Drudge Report, carried on the Internet, which had reported on July 4 (the day of Ms. Lewinsky's previous White House visit) that Michael Isikoff of Newsweek was "hot on the trail" of a story involving "a federal employee sexually propositioned by the President on federal property." Drudge Report 7/4/97. See also Washington Post, 8/11/97 at D1 (on Drudge Report's scoop of Newsweek). 532. Lewinsky 8/6/98 GJ at 76-77. 533. Lewinsky 8/6/98 GJ at 77. 534. Lewinsky 8/6/98 GJ at 77-78; Tripp 7/16/98 GJ at 12. 535. Lewinsky 8/6/98 GJ at 78; Lewinsky 7/27/98 Int. at 3; Lewinsky 7/29/98 Int. at 10; Tripp 7/14/98 GJ at 117-19; Tripp 7/16/98 GJ at 9. 536. Lewinsky 8/6/98 GJ at 78-79. 537. 968-DC-00003550. 538. Lewinsky 8/6/98 GJ at 79; Tripp 7/16/98 at 12. 539. Lewinsky 8/6/98 GJ at 79-80. 540. Lewinsky 7/29/98 Int. at 10-11. Subsequently, Ms. Tripp did call Mr. Lindsey. He urged her to contact Robert Bennett, but she never did so. Lindsey 3/12/98 GJ at 3, 13; Lindsey 2/18/98 GJ at 132-40; Tripp 7/16/98 GJ at 12-14, 54-67, 75-80; Lewinsky 7/29/98 Int. at 11; T29 at 16; 880-DC-0000002 - 8. 541. Scott 3/19/98 GJ at 64-72. 542. Lewinsky 7/31/98 Int. at 9. 543. Lewinsky 2/1/98 Statement at 2. 544. Scott 3/26/98 GJ at 18-21; Currie 5/7/98 GJ at 68. Ms. Lewinsky also conferred with her supervisor, Kenneth Bacon, about being detailed back to the White House. He gave his approval and sent a letter recommending her. Bailey 2/6/98 Int. at 3; Bacon 2/26/98 Int. at 2-3; 1012-DC-00000001; MSL-DC-00001230. 545. Scott 3/19/98 GJ at 78-79; Scott 3/26/98 GJ at 13-15; Scott 3/31/98 GJ at 43-44; Currie 5/7/98 GJ at 68. 546. 827-DC-00000018 (Epass records); V006-DC-00000008 (WAVES records); V006-DC-00001770 (WAVES request). 547. 1222-DC-00000254 (movement logs). 548. 968-DC-00003556 (phone logs). 549. Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7; Lewinsky 8/24/98 Int. at 6. 550. Newsweek, 8/11/97 at 30. 551. 845-DC-00000190 (letter); Tripp 7/16/98 GJ at 85-88. 552. T30 at 166. Ms. Tripp responded: "Oh, God. He thinks I screwed him in the article. I'm dead." Id. 553. V006-DC-00000008 (WAVES records). 554. V006-DC-00002146 (movement logs). Secret Service Officer Steven Pape testified about Ms. Lewinsky's August 16 visit. When Ms. Lewinsky entered the complex through the Southwest Gate, Officer Pape, who was familiar with Ms. Lewinsky's visits, predicted to another officer that the President would move to the Oval Office shortly. Officer Pape's prediction proved accurate: The President moved to the Oval Office, according to records, 18 minutes after Ms. Lewinsky entered the White House. Pape 8/5/98 GJ at 20-24; Myrick 8/13/98 GJ at 5-9; V006-DC-00002146 (movement logs); V006-DC-00002095 (movement logs); V006-DC-00002147 (movement logs). See also Shegogue 8/4/98 GJ at 10-11, 14-15, 17-20 (Secret Service officer recalling that Ms. Currie escorted Ms. Lewinsky into West Wing the day before President left for Martha's Vineyard). 555. 968-DC-00003558. 556. 968-DC-00002947. 557. Lewinsky 8/26/98 Depo. at 52. See also Lewinsky 8/20/98 GJ at 70. 558. Lewinsky 8/20/98 GJ at 70; Lewinsky 8/26/98 Depo. at 51-53. 559. Lewinsky 8/26/98 Depo. at 52. 560. DB-DC-00000022 (note dated 11/12/97). Ms. Lewinsky said that she sent this or a similar note to the President. Lewinsky 7/31/98 Int. at 2. See also 1037-DC-00000583 (email to Catherine Davis). 561. 1051-DC-00000003 (Pentagon phone records). 562. 1037-DC-00000086 - 87, 1037-DC-00000167, 1037-DC-00000255 - 256, 1037-DC-00000258 - 259 (email to Catherine Davis); 1318-DC-00000001 (card to Dale Young). 563. 1037-DC-00000086 - 87, 1037-DC-00000167, 1037-DC-00000255 - 256, 1037-DC-00000258 - 259 (email to Catherine Davis) (spelling and punctuation corrected). 564. Scott 3/26/98 GJ at 142. 565. Lewinsky 8/4/98 Int. at 5. 566. MSL-DC-00001052 (spelling and punctuation corrected). 567. Lewinsky 8/3/98 Int. at 6-7; Lewinsky 8/11/98 Int. at 5. See also 1037-DC-00000168 (email recounting episode). In mid or late September, according to Ms. Lewinsky, Ms. Currie told Ms. Lewinsky that she had spoken with Mr. Podesta. Lewinsky 7/31/98 Int. at 9; Lewinsky 8/13/98 Int. at 2; Lewinsky 2/1/98 Statement at 2. (Ms. Lewinsky thought that the President was having Ms. Currie do the "legwork" of getting her a job out of concern about appearances. Lewinsky 8/13/98 Int. at 3.) Mr. Podesta testified that he told Ms. Currie to have Ms. Lewinsky call him. Podesta 2/5/98 GJ at 35; Podesta 6/16/98 GJ at 12-19. Ms. Currie testified that she does not remember getting that response from Mr. Podesta, and, if she had gotten it, she would have passed it on to Ms. Lewinsky. Currie 5/14/98 GJ at 149-51. According to Ms. Lewinsky, Ms. Currie mentioned Mr. Podesta to her in September 1997, but never told her to call him. Lewinsky 8/24/98 Int. at 7. Subsequently, Ms. Currie asked Mr. Podesta to help Ms. Lewinsky get a New York job. Lewinsky 2/1/98 Statement at 2-3; Podesta 2/5/98 GJ at 40-43; Podesta 6/16/98 GJ at 13. 568. 1037-DC-00000038 - 040; 1037-DC-00000167 - 169 (email to Catherine Davis). 569. Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7. 570. 1037-DC-00000038, 1037-DC-00000040, 1037-DC-00000167 - 169. Ms. Lewinsky told several people about the gifts. Catherine Davis 3/17/98 (571) 571. Catherine Davis GJ 31-32, 109-111; Erbland GJ 39-42; Finerman depo 14-15; Marcia Lewis GJ 98; Raines GJ 53-55. - - - - - - -- - - 572. Lewinsky 7/29/98 Int. at 16; Lewinsky 8/4/98 Int. at 5. 573. MSL-DC-00001050. Beneath the text of the document, at the bottom of the page, Ms. Lewinsky added: "JUST A REMINDER TO THROW THIS AWAY AND NOT SEND IT BACK TO THE STAFF SECRETARY!" Id. The statement that Ms. Lewinsky and the President had not spent time together in six weeks evidently refers to her August 16 visit, before his vacation. 574. Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7. On September 30, the President signed, under penalty of perjury, interrogatory responses in the sexual harassment case, answering Ms. Jones's allegations against him. V002-DC-00000008 - 15. 575. Lewinsky 8/13/98 Int. at 1. In email, Ms. Lewinsky indicated that it was Ms. Currie who told her that the President was going to talk to the Chief of Staff. 1037-DC-00000168. 576. Bowles 4/2/98 GJ at 12, 65-73. 577. Bowles 4/2/98 GJ at 67-68. 578. Bowles 4/2/98 GJ at 70, 74-75. Mr. Bowles placed this incident in late summer or early fall of 1997. Bowles 4/2/98 GJ at 65-66. Mr. Podesta's account largely matches Mr. Bowles's, except that Mr. Podesta placed the incident in late spring or summer of 1997; he understood that Ms. Lewinsky wanted a job in the White House or an agency; and he recalled being told by Mr. Bowles that Ms. Lewinsky, according to the President, "thought that she hadn't been treated fairly" in being transferred to the Pentagon. Podesta 2/5/98 GJ at 21-22. 579. Lewinsky 8/6/98 GJ at 102. See also Lewinsky GJ 8/6/98 at 102; Lewinsky 7/29/98 Int. at 13; Lewinsky 7/31/98 Int. at 9; Tripp 7/28/98 GJ at 110-111, 125-26. Ms. Tripp's friend Kate Friedrich, however, has denied having made the remarks that Ms. Tripp attributed to her. Friedrich 7/17/98 Int. at 1. 580. Lewinsky 7/31/98 Int. at 10. 581. Lewinsky 8/13/98 Int. at 1. 582. MSL-55-DC-0178 (spelling and punctuation corrected). 583. Lewinsky 8/4/98 Int. at 2-3. 584. T1 at 28. 585. T1 at 24. 586. T1 at 61. 587. T1 at 25. 588. T13 at 19. 589. MSL-55-DC-00000001 (letter); 837-DC-00000001 (courier receipts); T1 at 97. 590. MSL-55-DC-00000001. 591. Lewinsky 8/6/98 GJ at 103; Lewinsky 7/31/98 Int. at 10. See also Lewinsky 7/29/98 Int. at 6; Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7. 592. T13 at 20. 593. T8 at 30. See also Lewinsky 7/31/98 Int. at 10. See also MSL-55-DC-0177 (draft letter from Ms. Lewinsky to the President referring to this remark); DB-DC-00000017 (another draft of same letter). 594. T8 at 30. 595. T8 at 30. 596. T8 at 33. 597. Lewinsky 7/31/98 Int. at 10; Lewinsky 7/27/98 Int. at 5. 598. Lewinsky 7/31/98 Int. at 10. 599. Lewinsky 7/31/98 Int. at 10. 600. Lewinsky 7/31/98 Int. at 11. 601. 827-DC-00000018 (Epass records). Ms. Lewinsky's aunt, Debra Finerman, wrote in a note that "Monica was called by Betty to come at 9:30 this a.m." MSL-DC-00000456 (document found in Ms. Lewinsky's apartment in the course of a consensual search on January 22, 1998). 602. 952-DC-00000060 (movement logs). 603. Lewinsky 8/6/98 GJ at 27-28 & Exh. ML-7. 604. Lewinsky 8/6/98 GJ at 104; Lewinsky 8/13/98 Int. at 2-3; T2 at 5. 605. Lewinsky 8/6/98 GJ at 104; Lewinsky 7/31/98 Int. at 11-12. Ms. Lewinsky was not certain whether it was during the October 11 visit or their October 10 phone conversation that she first asked the President to speak to Mr. Jordan on her behalf. Lewinsky 8/6/98 GJ at 104. 606. Lewinsky 8/6/98 GJ at 104; Lewinsky 7/31/98 Int. at 11-12. Ms. Lewinsky later said that the President assured her that he would call her and give "a report." T13 at 17-18. 607. T2 at 14. In the grand jury, Ms. Currie was shown a transcript of this recorded conversation and acknowledged that the meeting described by Ms. Lewinsky "probably happened." Currie 5/6/98 GJ at 187. 608. T2 at 14. Although it is unclear whether the President spoke with Mr. Bowles about a recommendation for Ms. Lewinsky in October, there is evidence he did so on January 13, 1998. See infra at Section XIII.H. 609. T2 at 10-11. 610. T2 at 11-12. 611. Lewinsky 7/31/98 Int. at 12. Ms. Lewinsky produced a draft of this document to the OIC on July 31, 1998. Lewinsky 7/31/98 Int. at 3. See also Lewinsky 8/13/98 Int. at 3. 612. DB-DC-00000027 (punctuation corrected) (emphasis in original). Ms. Lewinsky produced a draft of this document to the OIC on July 31, 1998. Lewinsky 7/31/98 GJ at 3. 613. DB-DC-00000027. Ms. Lewinsky also indicated that she would consider a job at one of the networks; she mentioned "Kaplan," and added that "CNN has a NY office." DB-DC-00000027. In a recorded conversation, Ms. Lewinsky said that she had told the President about her interest in television during their October 11 meeting. The President had responded, "The only one I know in a network is Kaplan, . . . but his job is in Atlanta." T2 at 6. See also Lewinsky 7/31/98 Int. at 11. CNN President Rick Kaplan is a friend of the President. 614. DB-DC-00000027. 615. T7 at 26. 616. T7 at 30. 617. T2 at 21-27. See also Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7; Lewinsky 8/11/98 Int. at 4. 618. T2 at 23. In her description, the card was "kind of cartoony" and said: "This is a test of the emergency insanity system." T2 at 21. See also Lewinsky 8/13/98 Int at 3. 619. T2 at 26-27. 620. T2 at 27-30. Ms. Lewinsky asked Ms. Currie to leave the packet under the President's desk.(621) 622. Phone records reflect that, on October 17, Ms. Lewinsky
placed two short calls to Ms. Currie from the Pentagon, one at 11:10 a.m. and the second
at 1:06 p.m. 833-DC-00017869 (Ms. Lewinsky's phone records). There are no records of calls
placed by Ms. Currie to Ms. Lewinsky from the White House. See Nagy 2/19/98 Int. at 4
("no record of local telephone calls coming from the White House"). Ms. Currie testified in the grand jury: "I don't remember a large package, only something with the Plum Book thing in it. And I just don't remember it being a large package." Currie 5/14/98 GJ at 52-53; see also Currie 5/14/98 GJ at 154. (The Plum Book is a government job search book, listing political appointee and Schedule C jobs. Currie 5/6/98 GJ at 154, 169.) Ms. Currie also recalled a list that Ms. Lewinsky had prepared about New York public relations firms. Currie 5/14/98 GJ at 56. 623. Lewinsky 8/13/98 Int. at 4; Lewinsky 8/26/98 Depo. at 61-63. 624. Podesta 2/5/98 GJ at 40-41. See also Lewinsky 7/31/98 Int. at 10. As previously discussed, Ms. Currie had earlier asked Mr. Podesta to help Ms. Lewinsky obtain a White House job.(625) 625. See supra at []. 626. Podesta 2/5/98 GJ at 40-45; Richardson 4/30/98 Depo. at 28. On Sunday, October 12, 1997, the President traveled to Latin America for one week. United States President, Weekly Compilations of Presidential Documents at 1608, 1609, 1653. On that trip, the President was accompanied by, among others, then-U.N. Ambassador William Richardson and the Deputy Chief of Staff, John Podesta. Richardson 4/30/98 Depo. at 28-29; Podesta 2/5/98 GJ at 44. Ambassador Richardson recalled that Mr. Podesta had first made the request prior to the trip to Latin America. Richardson 4/30/98 Depo. at 28. 627. Podesta 2/5/98 GJ at 45; Richardson 4/30/98 Depo. at 32. 628. Richardson 4/30/98 Depo. at 160-61; Clinton 1/17/98 Depo. at 73. 629. Richardson 4/30/98 Depo. at 26. 630. Watkins 5/27/98 Depo. at 11-12, 18. 631. Podesta 2/5/98 GJ at 46. 632. 828-DC-00000012 (faxed copy of Ms. Lewinsky's resume, produced by the U.N.); Currie 5/6/98 GJ at 174. 633. 828-DC-00000004 (U.N. phone records). 634. Lewinsky 8/13/98 Int. at 3. 635. Lewinsky 8/26/98 Depo. at 63-64. See also Lewinsky 8/26/98 Depo. at 63-64; Lewinsky 7/31/98 Int. at 12; Lewinsky 7/27/98 Int. at 5. 636. Lewinsky 7/27/98 Int. at 5. 637. Richardson 4/30/98 Depo. at 47-48; Watkins 5/27/98 Depo. at 27-29. Ms. Watkins further testified that she often placed calls from the Ambassador's line. Watkins 5/27/98 Depo. at 37-38. 638. Lewinsky 8/13/98 Int. at 3-4. 639. Lewinsky 8/13/98 Int. at 4. 640. Lewinsky 8/13/98 Int. at 4. See also Lewinsky 7/31/98 Int. at 12. 641. Lewinsky 8/26/98 Depo. at 64-65; Lewinsky 7/31/98 Int. at 13. 642. Lewinsky 8/26/98 Depo. at 65. Ms. Lewinsky wrote an email to her friend Catherine Allday Davis: "It was nice; the big creep called Thursday night to give me a pep talk because I was so afraid I'd sound like an idiot." 1037-DC-00000022 (spelling corrected).(643) 643. 1037-DC-000000022 (spelling corrected). 644. Lewinsky 7/31/98 Int. at 13. See also Lewinsky 8/26/98 Depo. at 65. 645. Clinton 1/17/98 Depo. at 74. 646. 828-DC-00000023 (Ambassador Richardson's diary reflecting 7:30 a.m. meeting with Monica Lewinsky). See also Ambassador Richardson 4/30/98 Depo. at 66-68; Sutphen 5/27/98 Depo. at 7; Cooper 1/27/98 Int. at 1-2; Lewinsky 7/31/98 Int. at 13-14. After meeting with Ms. Lewinsky, Ambassador Richardson spent the remainder of the day meeting individually with Senators and Members of Congress. 828-DC-00000023 (Ambassador Richardson's itinerary for October 31). 647. Richardson 4/30/98 Depo. at 68; Cooper 1/27/98 Int. at 1-2. 648. Richardson 4/30/98 Depo. at 39; Sutphen 5/27/98 Depo. at 15-16; Cooper 1/27/98 Int. at 2. 649. The draft was retrieved from Ms. Lewinsky's computer in the course of a consensual search on January 22, 1998. 650. MSL-55-DC-0179 (punctuation added)(italics in original). 651. MSL-55-DC-0179. 652. MSL-55-DC-0179. Ms. Lewinsky concluded the letter, "I was pleased the UN interview went well, but I'm afraid it will be like being at the Pentagon in NY. . . YUCK!" MSL-55-DC-0179 (ellipsis in original). 653. Lewinsky 8/13/98 Int. at 4-5; Lewinsky 7/31/98 Int. at 14; Lewinsky 7/27/98 Int. at 5. 654. 828-DC-00000003. 655. Lewinsky 8/26/98 Depo. at 67; Lewinsky 7/27/98 Int. at 5;
Lewinsky 7/31/98 Int. at 14; Lewinsky 8/13/98 Int. at 5. According to Ambassador Richardson, the position offered to Ms. Lewinsky was not newly created. He testified that he intended to expand an open position in the U.N.'s Washington office and move it to New York. Richardson 4/30/98 Depo. at 39-40. Although Ambassador Richardson did not recall whether this opening was publicized, he testified that it would be common for the office not to post Schedule C (political appointment) positions. Richardson 4/30/98 Depo. at 71-72. Peter Aronsohn, who filled the position Ms. Lewinsky was offered, characterized the job as a "new position." Aronsohn 8/27/98 Int. at 2. 656. Sutphen 5/27/98 Depo. at 26. 657. Richardson 4/30/98 Depo. at 90-91; Sutphen 5/27/98 Depo. at 21-23. 658. Lewinsky 8/26/98 Depo. at 65-66; Lewinsky 8/13/98 Int. at 4. 659. Currie 5/6/98 GJ at 174-75, 181; Currie 5/14/98 GJ at 65-66. 660. Clinton 1/17/98 Depo. at 73. 661. Sutphen 5/27/98 Depo. at 32-33; Lewinsky 8/13/98 Int. at 5. 662. Sutphen 5/27/98 Depo. at 33. See also Richardson 4/30/98 Depo. at 110-11 (recalling Ms. Lewinsky's request for additional time to consider the offer). 663. Lewinsky 7/27/98 Int. at 5; Sutphen 5/27/98 Depo. at 38; 1013-DC-00000095 (toll records for Debra Finerman). 664. 921-DC-00000101 - 118 (Second Set of Interrogatories from Plaintiff to Defendant Clinton). 665. V002-DC-00000016; V002-DC-00000020-21. 666. See supra at IX.B. See also Lewinsky 8/6/98 GJ at 104; Lewinsky 7/31/98 Int. at 11-12. 667. MSL-55-DC-0179. 668. Lewinsky 7/31/98 Int. at 14. 669. Lewinsky 7/31/98 Int. at 14. Phone records reflect that on November 4 at 3:54 p.m., Ms. Lewinsky placed a three-and-a-half-minute call to Mr. Jordan's office; at 4:09 p.m., Mr. Jordan placed a one-minute call to Ms. Currie; and at 4:38 p.m., Mr. Jordan placed a one-minute call to Ms. Currie. 833-DC-00017875 (Ms Lewinsky's phone records); V004-DC-00000134 (Akin, Gump phone records). 670. T2 at 11-12. See also Lewinsky 7/31/98 Int. at 11. 671. Jordan 5/5/98 GJ at 47 (Mr. Jordan testified that he believed the President had told Ms. Currie to "[c]all Vernon and ask Vernon to help her"). 672. Currie 5/6/98 GJ at 169-70, 176-78, 182-83, 198. 673. Clinton 1/17/98 Depo. at 81. 674. Clinton 1/17/98 Depo. at 82. 675. 1178-DC-00000011 (call logs). 676. Lewinsky 7/31/98 Int. at 14. 677. Lewinsky 7/31/98 Int. at 14-15. 678. Lewinsky 8/13/98 Int. at 3. 679. Lewinsky 8/6/98 GJ at 106; Lewinsky 7/31/98 Int. at 14-15; Lewinsky 7/27/98 Int. at 8, 10. Ms. Lewinsky later quoted the remark in email to a friend.(680) 680. 1037-DC-00000017 (email retrieved from Ms. Davis's computer). -- 681. 1037-DC-00000017 (email retrieved from Catherine Davis's computer). 682. Jordan 3/3/98 GJ at 13. 683. V004-DC-00000135 (Akin, Gump phone records). 684. Jordan 5/5/98 GJ at 54. 685. 1178-DC-00000026 (WAVES record). Ms. Lewinsky would learn of the meeting between the President and Mr. Jordan. In email to a friend dated November 6, Ms. Lewinsky wrote that Mr. Jordan had "[seen] the big creep yesterday afternoon." 1037-DC-00000017 (spelling corrected) (email to Catherine Davis). 686. Jordan 5/5/98 GJ at 34. 687. 833-DC-00000980 (letter retrieved from Ms. Lewinsky's Pentagon computer)(spelling corrected). 688. 1037-DC-00000017 (email retrieved from Catherine Davis's computer). Ms. Lewinsky wrote that she was "a little nervous to do the whole name of the BF. His first name is Vernon." Id. According to her aunt, Debra Finerman, Ms. Lewinsky used the code name "Gwen" when discussing Mr. Jordan because "he's an important person" and Ms. Lewinsky "always had the feeling somebody was listening in" on their phone conversations, they did not want an eavesdropper to know that Mr. Jordan was helping her find a job. Finerman 3/18/98 Depo. at 60. See also Lewinsky 8/5/98 Int. at 3; Lewinksy 8/3/98 Int. at 9. 689. Jordan 3/3/98 GJ at 50. 690. Jordan 5/5/98 GJ at 26-30, 34. 691. Epass records reflect that Ms. Lewinsky entered the White House at 6:20 p.m., admitted by Ms. Currie. 827-DC-00000018. Secret Service Movement logs show that the President entered the State Floor at 5:23 and moved to the Oval Office at 6:34. V006-DC-00002156. 692. 1037-DC-00000318 (email retrieved from Catherine Davis's computer). 693. Lewinsky 8/13/98 Int. at 5. 694. Lewinsky 8/13/98 Int. at 5. Many of Ms. Lewinsky's previous visits with the President had occurred on holidays. See, e.g., Lewinsky 7/30/98 Int. at 3, 13, 17 (describing visits on New Year's Eve, Presidents' Day, Easter Sunday, and July 4). 695. 837-DC-00000008(courier receipt). 696. DB-DC-00000022. Ms. Lewinsky produced a draft of this letter to the OIC on July 31, 1998. See also Lewinsky 7/31/98 Int. at 1 (confirming that she delivered a substantially similar note). 697. DB-DC-00000022. 698. Lewinsky 8/13/98 Int. at 5-6. On November 12, 1997, the President responded to Paula Jones's Third Set of Interrogatories. In response to an interrogatory that asked the President to provide information about all individuals who have discoverable and relevant information regarding the disputed facts at issue in the case, the President provided a list of names that did not include Ms. Lewinsky. 849-DC-0000090 - 97. 699. 1037-DC-00000318 (email retrieved from Catherine Davis's computer). 700. 1037-DC-00000318 (spelling corrected). Lewinsky 8/13/98 Int. at 6. On November 13, Ms. Hernreich was testifying before Congress. Walsh, "Democratic Donor Chung Invokes 5th Amendment; House Members Informally Interview Businessman Edward Walsh," Washington Post, November 15, 1997, at A6. 701. MSL-1249-DC-0140; Lewinsky 8/13/98 Int. at 6. 702. 1037-DC-00000318 (email retrieved from Catherine Davis's computer). 703. Lewinsky 8/13/98 Int. at 6; 1234-DC-00000050 (movement log); 986-DC-00003799 (Kearney Diary). 704. Lewinsky 8/13/98 Int. at 6. 705. Lewinsky 8/13/98 Int. at 6; 1037-DC-00000318 (email to Catherine Davis). 706. In a note to the President the next week, Ms. Lewinsky would write of the gifts: "I forgot to tell you: . . . The Gingko Blowjoba or whatever it is called and the Zinc lozenges were from me." MSL-55-DC-0140 (spelling and grammar corrected). 707. Lewinsky 8/6/98 GJ at 183-85; Lewinsky 8/2/98 Int. at 4. Ms. Lewinsky also saw a clipping of the Valentine's Day ad she had placed in the Washington Post on the President's desk. Lewinsky 8/6/98 GJ at 183-84. In a document composed soon after this visit, Ms. Lewinsky wrote: "When I was hiding out in your office for a half-hour, I noticed you had the new Sarah McLachlan CD. I have it, too, and it's wonderful. Whenever I listen to song #5 I think of you. That song and Billie Holiday's version of 'I'll be Seeing You' are guaranteed to put me to tears when it comes to you!" MSL-1249-DC-0140-41 (deleted file from Ms. Lewinsky's home computer) (spelling and grammar corrected). 708. 1037-DC-00000318 (email to Catherine Davis). 709. Lewinsky 8/13/98 Int. at 6. 710. OIC 8/27/98 Memo. 711. 968-DC-00000187 (presidential schedule); 968-DC-00000303 (Kearney Diary). Ms. Currie initially testified that she could not recall Ms. Lewinsky's November 13 visit. Currie 5/6/98 GJ at 12, 15. After viewing documentary evidence, she recalled that this was the only time she surreptitiously escorted Ms. Lewinsky into the White House. Id. at 85. 712. Lewinsky 8/11/98 Int. at 1; Lewinsky 7/31/98 Int. at 1-2;
837-DC-00000011 (courier receipt); MSL-1249-DC-0140-41 (document recovered from Ms.
Lewinsky's home computer). On November 17, 1997, the President responded to Paula Jones's First Set of Requests for Production of Documents and Things. One request sought documents sent to President Clinton by any woman (other than Mrs. Clinton) with whom President Clinton had sexual relations. V002-DC-00000056 - 92. President Clinton objected to this request as one designed "solely to harass, embarrass, and humiliate the President and the Office he occupies." V002-DC-00000075. Nonetheless, the President answered that he did not have any documents responsive to that request. 713. Lewinsky 8/6/98 GJ at 105. 714. Lewinsky 8/6/98 GJ at 105. Phone and pager records corroborate these contacts. 1205-DC-00000016; V004-DC-00000143; 831-DC-00000011. (Note that Ms. Lewinsky's pager records reflect Pacific Time; throughout this referral, time has been adjusted to Eastern Standard Time.) 715. MSL-1249-DC-0140 (spelling and punctuation corrected). 716. MSL-1249-DC-0139 (spelling and punctuation corrected). 717. 849-DC-00000128. 718. 849-DC-00000121-37 719. See infra at Section XI.F. See also Lewinsky 8/6/98 GJ at 121-26. 720. Clinton 8/17/98 GJ at 84-85. In his Jones deposition, the President acknowledged that he may have heard of the witness list before he actually saw it. Clinton 1/17/98 Depo. at 70. 721. 833-DC-00003207 (Travel Voucher DOD). 722. Lewinsky 8/6/98 GJ at 107; Lewinsky 7/31/98 Int. at 1. 723. V006-DC-00000521 (guest list); VOO6-DC-00001859 (photograph of Ms. Lewinsky and the President at the reception). 724. Lewinsky 7/31/98 Int. at 1. 725. Lewinsky 7/31/98 Int. at 2; MSL-55-DC-0177. The wording of the letter resembles, in part, a message on a cassette found during the consensual search of Ms. Lewinsky's apartment: "Hi. [Sniffling, crying.] I was so sad seeing you last night. I was so angry with you that once again you had rejected me. . . . I wanted to feel the warmth of you and the smell of you and the touch of you. And it made me sad. And I -- you confuse me so much. I mean I [sigh]. I thought I -- I thought I fell in love with this person that -- that I really felt was such a good -- such a good person, such a good heart, someone who's had a life with a lot of experiences.(726) 726. Search.001 transcript at 2. [get cite for tape itself] 727. MSL-55-DC-0177 (punctuation corrected). 728. MSL-55-DC-0177 (punctuation corrected). 729. MSL-DC-55-0177 (punctuation corrected). 730. MSL-55-DC-0177 (punctuation corrected). 731. Lewinsky 8/6/98 GJ at 108-09; Lewinsky 8/6/98 GJ at 27-29 & Exh. ML-7. The cigar holder, the tie, the mug, and the book have been produced to the OIC. V002-PHOTOS-0011 (holder, tie, and book); V002-PHOTOS-0005 (mug). 732. Lewinsky 8/6/98 GJ at 111-12. 733. Bryan Hall 5/21 98 Int. at 2; Bryan Hall 7/23/98 GJ at 10-11, 15-16; Niedzwiecki 7/30/98 GJ at 12-13; Lewinsky 8/6/98 GJ at 109-11. 734. Lewinsky 8/6/98 GJ at 110-11; Niedzwiecki 7/30/98 GJ at 13-14. 735. Byran Hall 7/23/98 GJ at 12-13; Niedzwiecki 7/30/98 GJ at 13, 15. Officer Hall recognized Ms. Lewinsky from a previous occasion, when she was greeted by, and delivered something to, Ms. Currie. Byran Hall 7/23/98 GJ at 6-10. 736. Tyler 7/28/98 GJ at 40; Chinery 7/23/98 GJ at 8. 737. Lewinsky 8/6/98 GJ at 111-12. Ms. Mondale recalled visiting the President that morning. Mondale 7/16/98 Int. at 1. See also 843-DC-00000004 (Epass records reflect that Ms. Mondale entered the White House at 9:33 a.m.). 738. Lewinsky 8/6/98 GJ at 111-12. See also Currie 7/22/98 GJ at 88-89. Ms. Lewinsky suspected that Ms. Mondale was romantically involved with the President. (739) 739. In a conversation on November 11, Ms. Lewinsky speculated that Ms. Mondale was and the President were starting a "relationship." Ms. Lewinsky noted with bitterness: "Maybe she's not sleeping with him yet. Anyway, there's the excitement. It's the President." LT16 at 91. - 740. Lewinsky 8/6/98 GJ at 112-13. Ms. Currie testified that Ms. Lewinsky angrily told her: "'You had lied to me, that the President is in the office, and he's meeting with someone.' And I said, 'Yeah, you're right.' She was not too happy about it, and words were exchanged." Currie 1/27/98 GJ at 37. 741. Keith Williams 7/23/98 GJ at 24. See also Chinery 7/23/98 GJ at 10; Purdie 7/23/98 GJ at 13. 742. Keith Williams 7/23/98 GJ at 12. Some testimony indicates that the President directly told Sergeant Williams about the Northwest Gate incident. Three officers testified that Sergeant Williams told them that the President had spoken to him and had indicated that he wanted the officer responsible for the disclosure of information fired. Niedzwiecki 7/30/98 GJ at 29, 37; Byran Hall 7/23/98 GJ at 25-26; Porter 8/13/98 GJ at 16-18. For example, Officer Niedzwiecki testified that soon after the incident, Sergeant Williams came to the Northwest Gate and said, "[t]he President wants somebody's job." Niedzwiecki 7/30/98 GJ at 29. Sergeant Williams testified, however, that the President did not speak to him directly about the incident. Keith Williams 7/23/98 GJ at 31-32. According to Sergeant Williams, when he met alone with Ms. Currie, he noticed that the door leading to the Oval Office was at first shut but then was cracked open. Keith Williams 7/23/98 GJ at 22, 30. Sergeant Williams testified that he heard what he assumed to be a male voice coming from within the Oval Office saying "[t]his person needs to be fired." Keith Williams 7/30/98 GJ at 10-11. Sergeant Williams told the officers at the gate that he spoke to the President only to get their attention. Keith Williams 7/30/98 GJ at 16-17. However, Sergeant Williams also told the supervisor who replaced him that afternoon that the President had spoken to him directly about the incident at the Northwest Gate. Deardoff 9/3/98 Depo. at 8-9. 743. Purdie 7/23/98 GJ at 13, 18-19. Captain Purdie testified that he thought that the remedy of firing was "out of proportion to the incident . . . [e]specially without doing an investigation or a fact-finding mission."(744) 744. Purdie 7/23/98 GJ at 19. 745. Lewinsky 8/6/98 GJ at 113. 746. Lewinsky 8/6/98 GJ at 113-14. 747. Lewinsky 8/6/98 GJ at 114. 748. Lewinsky 8/6/98 GJ at 114. 749. 827-DC-00000018. Secret Service logs reflect that the President was in the area of the Oval Office throughout this period. V006-DC-00002158. 750. Lewinsky 8/6/98 GJ at 115-16. Specifically, Ms. Lewinsky told the President "that I was supposed to get in touch with Mr. Jordan the previous week and that things didn't work out and that nothing had really happened yet." Id. 751. Lewinsky 8/6/98 GJ at 116. The President also told Ms. Lewinsky that he had already gotten a Christmas present for her and that he would give that to her during another visit. Lewinsky 8/1/98 Int. at 2. 752. Lewinsky 8/6/98 GJ at 115. 753. 1037-DC-00000011 (spelling corrected). 754. Keith Williams 7/23/98 GJ at 25. Ms. Currie confirmed that
she told an officer, "Okay. Fine. This never happened." However, she testified
that she said this so that no officer would get in trouble. Currie 7/22/98 GJ at 91-92. When Ms. Currie left work that day, she stopped by a Secret Service post and told an officer that "she spoke to the President . . . and . . . they decided that the incident never happened, they weren't going to pursue . . . discipline actions against them, that they just wanted it to go away." Chinery 7/23/98 GJ at 22-23. Later that week, Ms. Currie told that officer to inform one of his supervisors "that everything was okay and just to keep quiet about it." Keith Williams 7/23/98 GJ at 27-28. 755. Purdie 7/23/98 GJ at 32; Purdie 7/17/98 GJ at 3. 756. Purdie 7/17/98 GJ at 6; Bryan Hall 7/23/98 GJ at 31-32; Chinery 7/23/98 GJ at 21. 757. Porter 8/13/98 GJ at 12. 758. Niedzwiecki 7/30/98 GJ at 30-31. 759. Niedzwiecki 7/30/98 GJ at 31, 44. See also Niedzwiecki 8/5/98 GJ at 4-6 (text of Niedzwiecki notes). 760. Purdie 7/23/98 GJ at 35. 761. Purdie 7/23/98 GJ at 34-36. While Deputy Chief O'Malley testified that Captain Purdie notified him of the incident, Deputy Chief O'Malley did not recall Captain Purdie discussing with him, at any time, a decision not to generate an incident report or a memorandum. Charles O'Malley 9/8/98 Depo. at 44, 47-48. 762. O'Malley 9/8/98 Depo. at 22, 40-41. 763. Clinton 8/17/98 GJ at 84-85, 87. Ms. Mondale stated that she met with the President alone in the Oval Office study that day. Mondale 7/16/98 Int. at 1. 764. Clinton 8/17/98 GJ at 86. 765. Clinton 8/17/98 GJ at 88-89. 766. Clinton 8/17/98 GJ at 89-90. 767. Clinton 8/17/98 GJ at 91-92. 768. Lewinsky 8/6/98 GJ at 151-52; Lewinsky 2/1/98 Statement at 6. On December 23, Paula Jones's attorneys issued a subpoena to the Secret Service. 769. Lindsey 3/12/98 GJ at 64-66; Lindsey 2/19/98 GJ at 9-10. WAVES records reflect that Robert Bennett entered the White House at 4:39 p.m. on Saturday, December 6. 1407-DC-00000005. 770. Lindsey 3/12/98 GJ at 65. 771. 964-DC-00000862 (Presidential mail notes). 772. Lindsey 3/12/98 GJ at 63-64. Mr. Lindsey refused to answer questions about his December 6 meeting with the President, claiming attorney-client privilege and Executive (presidential communications) Privilege.(773) 773. Lindsey 3/12/98 GJ at 66. The U.S. District Court for the District of Columbia Circuit rejected Mr. Lindsey's claim of privilege, In re Grand Jury Proceedings, 5 F. Supp.2d 21 (D.D.C. 1998), and the Court of Appeals denied Mr. Lindsey's appeal, In re Lindsey, __ F.3d __, 1998 WL 418780 (D.C. Cir. 1998). A petition for Supreme Court review is currently pending. __ U.S.L.W. __ (U.S. Aug. 21, 1998) (No. 98-316). 774. WAVES records reflect that Mr. Jordan entered the White House at 5:21 p.m. on Sunday, December 7. 1178-DC-00000026. 775. Jordan 5/5/98 GJ at 83. He later testified that the conversation was "[a]bsolutely not" about Ms. Lewinsky. Jordan 5/5/98 GJ at 116. 776. V004-DC-00000171 (Akin, Gump visitor records) (recording
visit of "Malensky"). Ms. Lewinsky recalled arranging the meeting on December 8
or 9. Lewinsky 8/1/98 Int. at 3. See also 833-DC-00017886 (reflecting Ms. Lewinsky's call
to Mr. Jordan on December 8). On December 8, Ms. Lewinsky sent Mr. Jordan a hat, a box of chocolates, and a note gently reminding him of his promise to help her find a job. Lewinsky 7/31/98 Int. at 15. She also sent the President a note and some peach candies. Lewinsky 8/1/98 Int. at 2; Lewinsky 8/1/98 Int. at 2; 837-DC-00000017; 837-DC-00000020 (courier receipts). 777. Jordan 3/3/98 GJ at 41-42. 778. V004-DC-00000148 (Akin, Gump phone records). See also Jordan
3/3/98 GJ at 54, 62-63, 70. Mr. Halperin testified that Mr. Jordan had told him that Ms. Lewinsky "was a bright young woman who was energetic and enthusiastic and . . . encouraged me to meet with her." Halperin 4/23/98 GJ at 13. Similarly, Ms. Fairbairn stated that Mr. Jordan had told her that he "would like to send [her] a resume of a talented young lady and see if she matches up with any company openings." Fairbairn 1/29/98 Int. at 1. Mr. Georgescu, however, stated that Mr. Jordan "did not engage in a 'sales pitch' about [Ms.] Lewinsky." Georgescu 3/25/98 Int. at 2. 779. Lewinsky 8/6/98 GJ at 121. Ms. Lewinsky left the meeting with Mr. Jordan on December 8 with the impression that Mr. Jordan was going to get her a job. Lewinsky 8/1/98 Int. at 4. 780. Lewinsky 8/6/98 GJ at 119. 781. Lewinsky 8/6/98 GJ at 120. 782. Lewinsky 8/6/98 GJ at 120. 783. Lewinsky 8/6/98 GJ at 120. In her handwritten proffer, Ms. Lewinsky gave a very similar account of her second meeting with Mr. Jordan: "Ms. L. met again with Mr. Jordan in the beginning of December '97, at which time he provided Ms. L. with a list of three people to contact and suggested language to use in her letters to them. At some point, Mr. Jordan remarked something about Ms. L. being a friend of the Pres. of the United States. Ms. L. responded that she never really saw him as "the President"; she spoke to him like a normal man and even got angry with him like a normal man. Mr. Jordan asked what Ms. L. got angry about. Ms. L. replied that the Pres. doesn't see or call her enough. Mr. Jordan said Ms. L. should take her frustrations out on him -- not the President.(784) 784. Lewinsky Proffer at 3-4. - 785. Lewinsky 8/6/98 GJ at 120. 786. Jordan 3/3/98 GJ at 154. 787. Jordan 3/3/98 GJ at 64-65. 788. Jordan 3/3/98 GJ at 65. 789. Jordan 3/3/98 GJ at 65. 790. 1414-DC-00001534 - 46 (Plaintiff's Second Request for Production of Documents and Things). 791. Lewinsky 8/6/98 GJ at 121-26. 792. Lewinsky 8/6/98 GJ at 126. Ms. Lewinsky testified that the call came as a surprise because Mrs. Clinton was in town. Id. at 122. See also 968-DC-00003479 (Mrs. Clinton's schedule reflects that she was in Washington, D.C. on December 17). 793. Lewinsky 8/6/98 GJ at 122-23. 794. Lewinsky 8/6/98 GJ at 123. 795. Lewinsky 2/1/98 Statement at 4. 796. Lewinsky 8/6/98 GJ at 123. 797. Lewinsky 2/1/98 Statement at 4. 798. Lewinsky 8/6/98 GJ at 123-24. Ms. Lewinsky testified that, "on [s]everal occasions," they had resolved to use this cover story to conceal their relationship. Id. 799. Lewinsky 8/6/98 GJ at 232. 800. Lewinsky 8/6/98 GJ at 126. 801. Lewinsky 8/6/98 GJ at 126. 802. Clinton 8/17/98 GJ at 116. 803. Clinton 8/17/98 GJ at 119. The President himself gave this explanation of Ms. Lewinsky's visits to the Oval Office at his Jones deposition. Clinton 1/17/98 Depo. at 50-51. 804. Clinton 8/17/98 GJ at 119-20. 805. Clinton 8/17/98 GJ at 119-20. 806. Clinton 8/17/98 GJ at 120. 807. Halperin 1/26/98 Int. at 2. 808. Berk 3/31/98 Int. at 1-2. In her proffer, Ms. Lewinsky stated that, during the week following her December 11 meeting with Mr. Jordan, she "had two interviews in NY in response to her letters." Lewinsky 2/1/98 Statement at 4. 809. Schick 1/29/98 Int. at 2. 810. Lewinsky 8/6/98 GJ at 128; Harte 4/17/98 Int. at 1. 811. 902-DC-000000135 - 138 (Lewinsky subpoena). 812. 902-DC-000000137. 813. Lewinsky 8/6/98 GJ at 128-29; Lewinsky 7/27/98 Int. at 6; 8/1/98 Int. at 6-7. In the late-night December 17 call, the President told Ms. Lewinsky that, if she were subpoenaed, she should call Ms. Currie. Ms. Lewinsky did not do so on December 19 because Ms. Currie's brother had recently died and Ms. Lewinsky did not want to bother her. Lewinsky 8/6/98 GJ at 126. 814. Jordan 3/3/98 GJ at 92-93. Mr. Jordan said that he did not contemplate representing Ms. Lewinsky himself because "I represent companies. I don't represent individuals." Jordan 3/3/98 GJ at 101. 815. V004-DC-00000172 (Akin, Gump visitor logs). 816. V004-DC-00000151 (Akin, Gump telephone records, indicating the call ended at 5:05 p.m.); 1178-DC-00000014 (Presidential call logs, reflecting the call ended at 5:08 p.m.). Presidential call logs are recorded by hand, and thus are likely to be less accurate. The President may have been returning a call that Mr. Jordan had placed at 3:51 p.m. 817. Lewinsky 8/6/98 GJ at 131; V004-DC-00000151 (Akin, Gump telephone records). Mr. Jordan asked whether he could bring a potential client to Mr. Carter's office on Monday morning.(818) 818. Jordan 5/5/98 GJ at 154-55. See also Carter 6/18/98 GJ at 10. Although Mr. Jordan was adamant that Ms. Lewinsky was not in his office when he spoke with the President, he was uncertain whether Ms. Lewinsky was in the office when the 5:06 p.m. call was placed to Mr. Carter. Jordan 5/5/98 GJ at 154. - - |