Set forth below are answers to the questions that you have asked
me.
I would like to repeat, at the outset, something that I have
said before about my approach to these proceedings. I have asked my
attorneys to participate actively, but the fact that there is a
legal defense to the various allegations cannot obscure the hard
truth, as I have said repeatedly, that my conduct was wrong. It was
also wrong to mislead people about what happened, and I deeply
regret that.
For me, this long ago ceased to be primarily a legal or
political issue and became instead a painful personal one,
demanding atonement and daily work toward reconciliation and
restoration of trust with my family, my friends, my Administration
and the American people. I hope these answers will contribute to a
speedy and fair resolution of this matter.
1. Do you admit or deny that you are the chief law-enforcement
officer of the United States of America?
Response to Request No. 1:
The President is frequently referred to as the chief
law-enforcement officer, although nothing in the Constitution
specifically designates the President as such. Article II, Section
1 of the United States Constitution states that "(t)he executive
power shall be vested in a President of the United States of
America," and the law-enforcement function is a component of the
executive power.
2. Do you admit or deny that upon taking your oath of office
that you swore you would faithfully execute the office of President
of the United States, and would to the best of your ability,
preserve, protect and defend the Constitution of the United States?
Response to Request No. 2:
At my Inaugurations in 1993 and 1997, I took the following oath:
"I do solemnly swear that I will faithfully execute the Office of
President of the United States, and will to the best of my ability,
preserve, protect and defend the Constitution of the United
States."
3. Do you admit or deny that, pursuant to Article II, Section 2
of the Constitution, you have a duty to "take care that the laws
be faithfully executed?"
Response to Request No. 3:
Article II, Section 3 (not Section 2), of the Constitution
states that the President "shall take care that the Laws be
faithfully executed," and that is a Presidential obligation.
4. Do you admit or deny that you are a member of the bar and
officer of the court of a state of the United States, subject to
the rules of professional responsibility and ethics applicable to
the bar of that state?
Response to Request No. 4:
I have an active license to practice law (inactive for
continuing legal education purposes) issued by the Supreme Court of
Arkansas. The license, No. 73017, was issued in 1973.
5. Do you admit or deny that you took an oath in which you swore
or affirmed to tell the truth, the whole truth, and nothing but the
truth, in a deposition conducted as part of a judicial proceeding
in the case of Jones v. Clinton on January 17, 1998?
Response to Request No. 5:
I took an oath to tell the truth on January 17, 1998, before my
deposition in the Jones v. Clinton case. While I do not recall the
precise wording of that oath, as I previously stated in my grand
jury testimony on August 17, 1998, in taking the oath "I believed
then that I had to answer the questions truthfully."
6. Do you admit or deny that you took an oath in which you swore
or affirmed to tell the truth, the whole truth, and nothing but the
truth, before a grand jury empanelled as part of a judicial
proceeding by the United States District Court for the District of
Columbia Circuit on August 17, 1998?
Response to Request No. 6:
As the August 17, 1998, videotape reflects, I was asked "Do you
solemnly swear that the testimony you are about to give in this
matter will be the truth, the whole truth, and nothing but the
truth, so help you God?," and I answered, "I do."
7. Do you admit or deny that on or about October 7, 1997, you
received a letter composed by Monica Lewinsky in which she
expressed dissatisfaction with her search for a job in New York?
Response to Request No. 7:
At some point I learned of Ms. Lewinsky's decision to seek
suitable employment in New York. I do not recall receiving a letter
in which she expressed dissatisfaction about her New York job
search. I understand Ms. Lewinsky has stated that she sent a note
indicating her decision to seek employment in New York, but I do
not believe she has said the note expressed dissatisfaction about
her search for a job there. App. at 822-23 (grand jury testimony of
Ms. Lewinsky).
8. Do you admit or deny that you telephoned Monica Lewinsky
early in the morning on October 10, 1997, and offered to assist her
in finding a job in New York?
Response to Request No. 8:
I understand that Ms. Lewinsky testified that I called her on
the 9th of October, 1997. App. at 823 (grand jury testimony of Ms.
Lewinsky). I do not recall that particular telephone call.
9. Do you admit or deny that on or about October 11, 1997, you
met with Monica Lewinsky in or about the Oval Office dining room?
10. Do you admit or deny that on or about October 11, 1997,
Monica Lewinsky furnished to you, in or about the Oval Office
dining room, a list of jobs in New York in which she was
interested?
11. Do you admit or deny that on or about October 11, 1997, you
suggested to Monica Lewinsky that Vernon Jordan may be able to
assist her in her job search?
12. Do you admit or deny that on or about October 11, 1997,
after meeting with Monica Lewinsky and discussing her search for a
job in New York, you telephoned Vernon Jordan?
Response to Request Nos. 9. 10, 11 and 12:
At some point, Ms. Lewinsky either discussed with me or gave me
a list of the kinds of jobs she was interested in, although I do
not know whether it was on Saturday, October 11, 1997. Records
included in the O.I.C. Referral indicate that Ms. Lewinsky visited
the White House on October 11, 1997, and I may have seen her on
that day.
I do not believe I suggested to Ms. Lewinsky that Mr. Jordan
might be able to assist her in her job search, and I understand
that Ms. Lewinsky has stated that she asked me if Mr. Jordan could
assist her in finding a job in New York.
I speak to Mr. Jordan often, and I understand that records
included in the O.I.C. Referral indicate that he telephoned me
shortly after Ms. Lewinsky left the White House complex. I
understand that Mr. Jordan testified that he and I did not discuss
Ms. Lewinsky during that call.
13. Do you admit or deny that you discussed with Monica Lewinsky
prior to December 17, 1997, a plan in which she would pretend to
bring you papers with a work-related purpose, when in fact such
papers had no work-related purpose, in order to conceal your
relationship?
14. Do you admit or deny that you discussed with Monica Lewinsky
prior to December 17, 1997, that Betty Currie should be the one to
clear Ms. Lewinsky in to see you so that Ms. Lewinsky could say
that she was visiting with Ms. Currie instead of with you?
15. Do you admit or deny that you discussed with Monica Lewinsky
prior to December 17, 1997, that if either of you were questioned
about the existence of your relationship you would deny its
existence?
19. Do you admit or deny that on or about December 17, 1997, you
suggested to Monica Lewinsky that she could say to anyone inquiring
about her relationship with you that her visits to the Oval Office
were for the purpose of visiting with Betty Currie or to deliver
papers to you?
Response to Request Nos. 13, 14, 15, and 19:
I was asked essentially these same questions by O.I.C. lawyers.
I testified that Ms. Lewinsky and I "may have talked about what to
do in a nonlegal context at some point in the past, but I have no
specific memory of that conversation." That continues to be my
recollection today -- that is, any such conversation was not in
connection with her status as a witness in the Jones v. Clinton
case.
16. Do you admit or deny that on or about December 6, 1997, you
learned that Monica Lewinsky's name was on a witness list in the
case of Jones v. Clinton?
Response to Request No. 16:
As I stated in my August 17th grand jury testimony, I believe
that I found out that Ms. Lewinsky's name was on a witness list in
the Jones v. Clinton case late in the afternoon on the 6th of
December, 1997. App, at 535.
17. Do you admit or deny that on or about December 17, 1997, you
told Monica Lewinsky that her name was on the witness list in the
case of Jones v. Clinton?
18. Do you admit or deny that on or about December 17, 1997, you
suggested to Monica Lewinsky that the submission of an affidavit in
the case of Jones v. Clinton might suffice to prevent her from
having to testify personally in that case?
Response to Requests Nos. 17 and 18:
As I previously testified, I recall telephoning Ms. Lewinsky to
tell her Ms. Currie's brother had died, and that call was in the
middle of December. I do not recall other particulars of such a
call, including whether we discussed the fact that her name was on
the Jones v. Clinton witness list. As I stated in my August 17th
grand jury testimony in response to essentially the same questions,
it is quite possible that that happened. . . . I don't have any
memory of it, but I certainly wouldn't dispute that I might have
said that (she was on the witness list)."
I recall that Ms. Lewinsky asked me at some time in December
whether she might be able to get out of testifying in the Jones v.
Clinton case because she knew nothing about Ms. Jones or the case.
I told her I believed other witnesses had executed affidavits, and
there was a chance they would not have to testify. As I stated in
my August 17th grand jury testimony, "I felt strongly that... (Ms.
Lewinsky) could execute an affidavit that would be factually
truthful, that might get her out of having to testify." I never
asked or encouraged Ms. Lewinsky to lie in her affidavit, as Ms.
Lewinsky herself has confirmed.
19. For the Response to Request No. 19, see Response to Request
No. 13 et al., supra.
20. Do you admit or deny that you gave false and misleading
testimony under oath when you stated during your deposition in the
case of Jones v. Clinton on January 17, 1998, that you did not know
if Monica Lewinsky had been subpoenaed to testify in that case?
Response to Request No. 20:
It is evident from my testimony on pages 69 to 70 of the
deposition that I did know on January 17, 1998, that Ms. Lewinsky
had been subpoenaed in the Jones v. Clinton case. Ms. Jones'
lawyer's question, "Did you talk to Mr. Lindsey about what action,
if any, should be taken as a result of her being served with a
subpoena?", and my response, "No," j. at 70, reflected my
understanding that Ms. Lewinsky had been subpoenaed. That testimony
was not false and misleading.
21. Do you admit or deny that you gave false and misleading
testimony under oath when you stated before the grand jury on
August 17, 1998, that you did know prior to January 17, 1998, that
Monica Lewinsky had been subpoenaed to testify in the case of Jones
v. Clinton?
Response to Request No. 21:
As my testimony on January 17 reflected, and as I testified on
August 17, 1998, I knew prior to January 17, 1998, that Ms.
Lewinsky had been subpoenaed to testify in Jones v. Clinton. App.
at 487. That testimony was not false and misleading.
22. Do you admit or deny that on or about December 28, 1997, you
had a discussion with Monica Lewinsky at the White House regarding
her moving to New York?
Response to Request No. 22:
When I met with Ms. Lewinsky on December 28, 1997, I knew she
was planning to move to New York, and we discussed her move.
23. Do you admit or deny that on or about December 28, 1997, you
had a discussion with Monica Lewinsky at the White House in which
you suggested to her that she move to New York soon because by
moving to New York, the lawyers representing Paula Jones in the
case of Jones v. Clinton may not contact her?
Response to Request No. 23:
Ms. Lewinsky had decided to move to New York well before the end
of December 1997. By December 28, Ms. Lewinsky had been subpoenaed.
I did not suggest that she could avoid testifying in the Jones v.
Clinton case by moving to New York.
24. Do you admit or deny that on or about December 28, 1997, you
had a discussion with Monica Lewinsky at the White House regarding
gifts you had given to Ms. Lewinsky that were subpoenaed in the
case of Jones v. Clinton?
25. Do you admit or deny that on or about December 28, 1997, you
expressed concern to Monica Lewinsky about a hatpin you had given
to her as a gift which had been subpoenaed in the case of Jones v.
Clinton?
Response to Request Nos. 24 and 25:
As I told the grand jury, "Ms. Lewinsky said something to me
like, what if they ask me about the gifts you've given me," but I
do not know whether that conversation occurred on December 28,
1997, or earlier.
Whenever this conversation occurred, I testified, I told her
"that if they asked her for gifts, she'd have to give them
whatever she had. ..." I simply was not concerned about the fact
that I had given her gifts. Indeed, I gave her additional gifts on
December 28, 1997. I also told the grand jury that I do not recall
Ms. Lewinsky telling me that the subpoena specifically called for a
hat pin that I had given her.
26. Do you admit or deny that on or about December 28, 1997, you
discussed with Betty Currie gifts previously given by you to Monica
Lewinsky?
27. Do you admit or deny that on or about December 28, 1998, you
requested, instructed, suggested to or otherwise discussed with
Betty Currie that she take possession of gifts previously given to
Monica Lewinsky by you?
Response to Request Nos. 26 and 27:
I do not recall any conversation with Ms. Currie on or about
December 28, 1997, about gifts I had previously given to Ms.
Lewinsky. I never told Ms. Currie to take possession of gifts I had
given Ms. Lewinsky; I understand Ms. Currie has stated that Ms.
Lewinsky called Ms. Currie to ask her to hold a box.
28. Do you admit or deny that you had a telephone conversation
on January 6, 1998, with Vernon Jordan during which you discussed
Monica Lewinsky's affidavit, yet to be filed, in the case of Jones
v. Clinton?
Response to Request No. 28:
White House records included in the O.I.C. Referral reflect that
I spoke to Mr. Jordan on January 6, 1998. I do not recall whether
we discussed Ms. Lewinsky's affidavit during a telephone call on
that date.
29. Do you admit or deny that you had knowledge of the fact that
Monica Lewinsky executed for filing an affidavit in the case of
Jones v. Clinton on January 7, 1998?
30. Do you admit or deny that on or about January 7, 1998, you
had a discussion with Vernon Jordan in which he mentioned that
Monica Lewinsky executed for filing an affidavit in the case of
Jones v. Clinton?
Response to Request Nos. 29 and 30:
As I testified to the grand jury, "I believe that (Mr. Jordan)
did notify us when she signed her affidavit. While I do not recall
the timing, as I told the grand jury, I have no reason to doubt Mr.
Jordan's statement that he notified me about the affidavit around
January 7, 1998.
31. Do you admit or deny that on or about January 7, 1998, you
had a discussion with Vernon Jordan in which he mentioned that he
was assisting Monica Lewinsky in finding a job in New York?
Response to Request No. 31:
I told the grand jury that I was aware that Mr. Jordan was
assisting Ms. Lewinsky in her job search in connection with her
move to New York. I have no recollection as to whether Mr. Jordan
discussed it with me on or about January 7, 1998.
32. Do you admit or deny that you viewed a copy of the affidavit
executed by Monica Lewinsky on January 7, 1998, in the case of
Jones v. Clinton, prior to your deposition in that case?
33. Do you admit or deny that you had knowledge that your
counsel viewed a copy of the affidavit executed by Monica Lewinsky
on January 7, 1998, in the case of Jones v. Clinton, prior to your
deposition in that case?
Response to Request Nos. 32 and 33:
I do not believe I saw this affidavit before my deposition,
although I cannot be absolutely sure. The record indicates that my
counsel had seen the affidavit at some time prior to the
deposition.
34. Do you admit or deny that you had knowledge that any facts
or assertions contained in the affidavit executed by Monica
Lewinsky on January 7, 1998, in the case of Jones v. Clinton were
not true?
40. Do you admit or deny that during your deposition in the case
of Jones v. Clinton on January 17, 1998, you affirmed that the
facts or assertions stated in the affidavit executed by Monica
Lewinsky on January 7, 1998, were true?
Response to Request Nos. 34 and 40:
I was asked at my deposition in January about two paragraphs of
Ms. Lewinsky's affidavit. With respect to Paragraph 6, 1 explained
the extent to which I was able to attest to its accuracy.
With respect to Paragraph 8, I stated in my deposition that it
was true. In my August 17th grand jury testimony, I sought to
explain the basis for that deposition answer: "I believe at the
time that she filled out this affidavit, if she believed that the
definition of sexual relationship was two people having
intercourse, then this is accurate."
35. Do you admit or deny that you viewed a copy of the affidavit
executed by Monica Lewinsky on January 7, 1998, in the case of
Jones v. Clinton, at your deposition in that case on January 17,
1998?
36. Do you admit or deny that you had knowledge that your
counsel viewed a copy of the affidavit executed by Monica Lewinsky
on January 7, 1998, in the case of Jones v. Clinton, at your
deposition in that case on January 17, 1998?
Response to Request Nos. 35 and 36:
I know that Mr. Bennett saw Ms. Lewinsky's affidavit during the
deposition because he read portions of it aloud at the deposition.
I do not recall whether I saw a copy of Ms. Lewinsky's affidavit
during the deposition.
37. Do you admit or deny that on or about January 9, 1998, you
received a message from Vernon Jordan indicating that Monica
Lewinsky had received a job offer in New York?
Response to Request No. 37:
At some time, I learned that Ms. Lewinsky had received a job
offer in New York. However, I do not recall whether I first learned
it in a message from Mr. Jordan or whether I learned it on that
date.
38. Do you admit or deny that between January 9, 1998, and
January 15, 1998, you had a conversation with Erskine Bowles in the
Oval Office in which you stated that Monica Lewinsky received a job
offer and had listed John Hilley as a reference?
39. Do you admit or deny that you asked Erskine Bowles if he
would ask John Hilley to give Ms. Lewinsky a positive job
recommendation?
Response to Request Nos. 38 and 39:
As I testified to the grand jury, I recall at some point talking
to Mr. Bowles "about whether Monica Lewinsky could get a
recommendation that was not negative from the Legislative Affairs
Office," or that "was at least neutral," although I am not
certain of the date of the conversation. To suggest that I told Mr.
Bowles that Ms. Lewinsky had received a job offer and had listed
John Hilley as a reference is, as I testified, a "little bit"
inconsistent with my memory. It is possible, as I also indicated,
that she had identified Mr. Hilley as her supervisor on her resume
and in that respect had already listed him as a reference.
40. For the Response to Request No. 40, see Response to Request
No. 34, et al., supra.
41. As to each, do you admit or deny that you gave the following
gifts to Monica Lewinsky at any time in the past?
a. A lithograph
b. A hatpin
c. A large "Black Dog" canvas bag
d. A large "Rockettes" blanket
e. A pin of the New York skyline
f. A box of "cherry chocolates"
g. A pair of novelty sunglasses
h. A stuffed animal from the "Black Dog"
i. A marble bear's head
j. A London pin
k. A shamrock pin
l. An Annie Lennox compact disc
m. Davidoff cigars
Response to Request No. 41:
In my deposition in the Jones case, I testified that I
"certainly ... could have" given Ms. Lewinsky a hat pin and that
I gave her "something" from the Black Dog. In my grand jury
testimony, I indicated that in late December 1997, I gave Ms.
Lewinsky a Canadian marble bear's head carving, a Rockettes
blanket, some kind of pin, and a bag (perhaps from the Black Dog)
to hold these objects. I also stated that I might have given her
such gifts as a box of candy and sunglasses, although I did not
recall doing so, and I specifically testified that I had given Ms.
Lewinsky gifts on other occasions. I do not remember giving her the
other gifts listed in Question 41, although I might have. As I have
previously testified, I receive a very large number of gifts from
many different people, sometimes several at a time. I also give a
very large number of gifts. I gave Ms. Lewinsky gifts, some of
which I remember and some of which I do not.
42. Do you admit or deny that when asked on January 17, 1998, in
your deposition in the case of Jones v. Clinton if you had ever
given gifts to Monica Lewinsky, you stated that you did not recall,
even though you actually had knowledge of giving her gifts in
addition to gifts from the "Black Dog?"
Response to Request No. 42:
In my grand jury testimony, I was asked about this same
statement. I explained that my full response was "I don't recall.
Do you know what they were?" By that answer, I did not mean to
suggest that I did not recall giving gifts; rather, I meant that I
did not recall what the gifts were, and I asked for reminders.
43. Do you admit or deny that you gave false and misleading
testimony under oath in your deposition in the case of Jones v.
Clinton when you responded "once or twice" to the question "has
Monica Lewinsky ever given you any gifts?"
Response to Request No. 43:
My testimony was not false and misleading. As I have testified
previously, I give and receive numerous gifts. Before my January
17, 1998, deposition, I had not focused on the precise number of
gifts Ms. Lewinsky had given me. My deposition testimony made clear
that Ms. Lewinsky had given me gifts; at the deposition, I recalled
"a book or two" and a tie. At the time, those were the gifts I
recalled. In response to O.I.C. inquiries, after I had had a chance
to search my memory and refresh my recollection, I was able to be
more responsive. However, as my counsel have informed the O.I.C.,
in light of the very large number of gifts I receive, there might
still be gifts from Ms. Lewinsky that I have not identified.
44. Do you admit or deny that on January 17, 1998, at or about
5:38 P.M., after the conclusion of your deposition in the case of
Jones v. Clinton, you telephoned Vernon Jordan at his home?
Response to Request No. 44:
I speak to Mr. Jordan frequently, so I cannot remember specific
times and dates. According to White House records included in the
O.I.C. Referral, I telephoned Mr. Jordan's residence on January 17,
1998, at or about 5:38 p.m.
45. Do you admit or deny that on January 17, 1998, at or about
7:02 P.M., after the conclusion of your deposition in the case of
Jones v. Clinton, you telephoned Betty Currie at her home?
46. Do you admit or deny that on January 17, 1998, at or about
7:02 P.M., after the conclusion of your deposition in the case of
Jones v. Clinton, you telephoned Vernon Jordan at his office?
47. Do you admit or deny that on January 17, 1998, at or about
7:13 P.M., after the conclusion of your deposition in the case of
Jones v. Clinton, you telephoned Betty Currie at her home and asked
her to meet with you the next day, Sunday, January 18, 1998?
Response to Request Nos. 45. 46 and 47:
According to White House records included in the O.I.C.
Referral, I placed a telephone call to Ms. Currie at her residence
at 7:02 P.M. and spoke to her at or about 7:13 P.M. I recall that
when I spoke to her that evening, I asked if she could meet with me
the following day. According to White House records included in the
O.I.C. Referral, I telephoned Mr. Jordan's office on January 17,
1998, at or about 7:02 P.M.
48. Do you admit or deny that on January 18, 1998, at or about
6:11 A.M., you learned of the existence of tapes of conversations
between Monica Lewinsky and Linda Tripp recorded by Linda Tripp?
Response to Request No. 48:
I did not know on January 18, 1998 that tapes existed of
conversations between Ms. Lewinsky and Ms. Tripp recorded by Ms.
Tripp. At some point on Sunday, January 18, 1998, I knew about the
Drudge Report. I understand that, while the report talked about
tapes of phone conversations, it did not identify Ms. Lewinsky by
name and did not mention Ms. Tripp at all. The report did not state
who the parties to the conversations were or who taped the
conversations.
49. Do you admit or deny that on January 18, 1998, at or about
12:50 P.M., you telephoned Vernon Jordan at his home?
Response to Request No. 49:
According to White House records included in the O.I.C.
Referral, I telephoned Mr. Jordan's residence on January 18, 1998,
at or about 12:50 P.M.
50. Do you admit or deny that on January 18, 1998, at or about
1:11 P.M., you telephoned Betty Currie at her home?
Response to Request No. 50:
According to White House records included in the O.I.C.
Referral, I telephoned Ms. Currie's residence on January 18, 1998,
at or about 1:11 P.M.
51. Do you admit or deny that on January 18, 1998, at or about
2:55 p.m., you received a telephone call from Vernon Jordan?
Response to Request No. 51:
According to White House records included in the O.I.C.
Referral, Mr. Jordan telephoned me from his residence on January
18, 1998, at or about 2:55 p.m. App. at 2879.
52. Do you admit or deny that on January 18, 1998, at or about
5:00 p.m., you had a meeting with Betty Currie at which you made
statements similar to any of the following regarding your
relationship with Monica Lewinsky?
a. "You were always there when she was there, right? We were
never really alone."
b. "You could see and hear everything."
c. "Monica came on to me, and I never touched her right?"
d. "She wanted to have sex with me and I couldn't do that."
Response to Request No. 52:
When I met with Ms. Currie, I believe that I asked her certain
questions, in an effort to get as much information as quickly as I
could, and made certain statements, although I do not remember
exactly what I said. See App. at 508.
Some time later, I learned that the Office of Independent
Counsel was involved and that Ms. Currie was going to have to
testify before the grand jury.
After learning this, I stated in my grand jury testimony, I told
Ms. Currie, "Just relax, go in there and tell the truth." App. at
591.
53. Do you admit or deny that you had a conversation with Betty
Currie within several days of January 18, 1998, in which you made
statements similar to any of the following regarding your
relationship with Monica Lewinsky?
a. "You were always there when she was there, right? We were
never really alone."
b. "You could see and hear everything."
c. "Monica came on to me, and I never touched her right?"
d. "She wanted to have sex with me and I couldn't do that."
Response to Request No. 53:
I previously told the grand jury that, "I don't know that I"
had another conversation with Ms. Currie within several days of
January 18, 1998, in which I made statements similar to those
quoted above. "I remember having this (conversation) one time."
App. at 592. I further explained, "I do not remember how many
times I talked to Betty Currie or when. I don't. I can't possibly
remember that. I do remember, when I first heard about this story
breaking, trying to ascertain what the facts were, trying to
ascertain what Betty's perception was. I remember that I was highly
agitated, understandably. I think." App. at 593.
I understand that Ms. Currie has said a second conversation
occurred the next day that I was in the White House (when she was),
Supp. at 535-36, which would have been Tuesday, January 20, before
I knew about the grand jury investigation.
54. Do you admit or deny that on January 18, 1998, at or about
11:02 p.m., you telephoned Betty Currie at her home?
Response to Request No. 54:
According to White House records included in the O.I.C.
Referral, I called Ms. Currie's residence on January 18, 1998, at
or about 11:02 p.m. App. at 2881.
55. Do you admit or deny that on Monday, January 19, 1998, at or
about 8:50 a.m., you telephoned Betty Currie at her home?
Response to Request No. 55:
According to White House records included in the O.I.C.
Referral, I called Ms. Currie's residence on January 19, 1998, at
or about 8:50 a.m. App. at 3147.
56. Do you admit or deny that on Monday, January 19, 1998, at or
about 8:56 a.m., you telephoned Vernon Jordan at his home?
Response to Request No. 56:
According to White House records included in the O.I.C.
Referral, I called Mr. Jordan's residence on January 19, 1998, at
or about 8:56 a.m. App. at 2864.
57. Do you admit or deny that on Monday, January 19, 1998, at or
about 10:58 a.m., you telephoned Vernon Jordan at his office?
Response to Request No. 57:
According to White House records included in the O.I.C.
Referral, I called Mr. Jordan's office on January 19, 1998, at or
about 10:58 a.m. App. at 2883.
58. Do you admit or deny that on Monday, January 19, 1998, at or
about 1:45 p.m., you telephoned Betty Currie at her home?
Response to Request No. 58:
According to White House records included in the O.I.C.
Referral, I called Ms. Currie's residence on January 19, 1998, at
or about 1:45 p.m. App. at 2883.
59. Do you admit or deny that on Monday, January 19, 1998, at or
about 2:44 p.m., you met with individuals including Vernon Jordan,
Erskine Bowles, Bruce Lindsey, Cheryl Mills, Charles Ruff, and Rahm
Emanuel?
60. Do you admit or deny that on Monday, January 19, 1998, at or
about 2:44 p.m., at any meeting with Vernon Jordan, Erskine Bowles,
Bruce Lindsey, Cheryl Mills, Charles Ruff, Rahm Emanuel, and
others, you 17 discussed the existence of tapes of conversations
between Monica Lewinsky and Linda Tripp recorded by Linda Tripp, or
any other matter related to Monica Lewinsky?
Response to Request Nos. 59 and 60:
I do not believe such a meeting occurred. White House records
included in the O.I.C. Referral indicate that Mr. Jordan entered
the White House complex that day at 2:44 p.m. Supp. at 1995.
According to Mr. Jordan's testimony, he and I met alone in the Oval
Office for about 15 minutes. Supp. at 1763 (grand jury testimony of
Vernon Jordan).
I understand that Mr. Jordan testified that we discussed Ms.
Lewinsky at that meeting and also the Drudge Report, in addition to
other matters. Supp. at 1763. Please also see my Response to
Request No. 48, supra.
61. Do you admit or deny that on Monday, January 19, 1998, at or
about 5:56 p.m., you telephoned Vernon Jordan at his office?
Response to Request No. 61:
According to White House records included in the O.I.C.
Referral, I called Mr. Jordan's office on January 19, 1998, at or
about 5:56 p.m. App. at 2883.
62. Do you admit or deny that on January 21, 1998, the day the
Monica Lewinsky story appeared for the first time in the Washington
Post, you had a conversation with Sidney Blumenthal, in which you
stated that you rebuffed alleged advances &om Monica Lewinsky and
in which you made a statement similar to the following?: "Monica
Lewinsky came at me and made a sexual demand on me."
63. Do you admit or deny that on January 21, 1998, the day the
Monica Lewinsky story appeared for the first time in the Washington
Post, you had a conversation with Sidney Blumenthal, in which you
made a statement similar to the following in response to a question
about your conduct with Monica Lewinsky?: "I haven't done anything
wrong.
64. Do you admit or deny that on January 21, 1998, the day the
Monica Lewinsky story appeared for the first time in The Washington
Post, you had a conversation with Erskine Bowles, Sylvia Matthews
and John Podesta, in which you made a statement similar to the
following?: "I want you to know I did not have sexual
relationships with this woman Monica Lewinsky. I did not ask
anybody to lie. And when the facts come out, you'll understand."
65. Do you admit or deny than on or about January 23, 1998, you
had a conversation with John Podesta, in which you stated that you
had never had an affair with Monica Lewinsky?
66. Do you admit or deny that on or about January 23, 1998, you
had a conversation with John Podesta, in which you stated that you
were not alone with Monica Lewinsky in the Oval Office, and that
Betty Currie was either in your presence or outside your office
with the door open while you were visiting with Monica Lewinsky?
67.
Do you admit or deny that on or about January 26, 1998, you
had a conversation with Harold Ickes, in which you made statements
to the effect that you did not have an affair with Monica Lewinsky?
68. Do you admit or deny that on or about January 26, 1998, you
had a conversation with Harold Ickes, in which you made statements
to the effect that you had not asked anyone to change their story,
suborn perjury or obstruct justice if called to testify or
otherwise respond to a Request for information from the Office of
Independent Counsel or in any other legal proceeding?
Responses to Requests Nos. 62-68:
As I have previously acknowledged, I did not want my family,
friends, or colleagues to know the full nature of my relationship
with Ms. Lewinsky. In the days following the January 21, 1998,
Washington Post article, I misled people about this relationship. I
have repeatedly apologized for doing so.
69. Do you admit or deny that on or about January 21, 1998, you
and Richard (Dick) Morris discussed the possibility of
commissioning a poll to determine public opinion following The
Washington Post story regarding the Monica Lewinsky matter?
70. Do you admit or deny that you had a later conversation with
Richard (Dick) Morris in which he stated that the polling results
regarding the Monica Lewinsky matter suggested that the American
people would forgive you for adultery but not for perjury or
obstruction of justice?
71. Do you admit or deny that you responded to Richard (Dick)
Morris's explanation of these polling results by making a statement
similar to the following: "(w)ell, we just have to win, then"?
Response to Request Nos. 69, 70 and 71:
At some point after the O.I.C. investigation became public, Dick
Morris volunteered to conduct a poll on the charges reported in the
press. He later called back. What I recall is that he said the
public was most concerned about obstruction of justice or
subornation of perjury. I do not recall saying, "Well, we just
have to win then."
72. Do you admit or deny the past or present existence of or the
past or present direct or indirect employment of individuals, other
than counsel representing you, whose duties include making contact
with or gathering information about witnesses or potential
witnesses in any judicial proceeding related to any matter in which
you are or could be involved?
Response to Request No. 72:
I cannot respond to this inquiry because of the vagueness of its
terms ("indirect," "potential," "could be involved"). To the
extent it may be interpreted to apply to individuals assisting
counsel, please see my responses to Request Nos. 73-75. To the
extent the inquiry addresses specific individuals, as in Request
Nos. 73-75, I have responded and stand ready to respond to any
other specific inquiries.
73. Do you admit or deny having knowledge that Terry Lenzner was
contacted or employed to make contact with or gather information
about witnesses or potential witnesses in any judicial proceeding
related to any matter in which you are or could be involved?
Response to Request No. 73:
My counsel stated publicly on February 24, 1998, that Mr. Terry
Lenzner and his firm have been retained since April 1994 by two
private law firms that represent me. It is commonplace for legal
counsel to retain such firms to perform legal and appropriate tasks
to assist in the defense of clients. See also Response to No. 72.
74. Do you admit or deny having knowledge that Jack Palladino
was contacted or employed to make contact with or gather
information about witnesses or potential witnesses in any judicial
proceeding related to any matter in which you are or could be
involved?
My understanding is that during the 1992 Presidential campaign,
Mr. Jack Palladino was retained to assist legal counsel for me and
the campaign on a variety of matters arising during the campaign.
See Response to No. 72.
75. Do you admit or deny having knowledge that Betsy Wright was
contacted or employed to make contact with or gather information
about witnesses or potential witnesses in any judicial proceeding
related to any matter in which you are or could be involved?
Response to Request No. 75:
Ms. Betsey Wright was my longtime chief of staff when I was
Governor of Arkansas, and she remains a good friend and trusted
adviser. Because of her great knowledge of Arkansas, from time to
time my legal counsel and I have consulted with her on a wide range
of matters. See also Response to No. 72.
76. Do you admit or deny that you made false and misleading
public statements in response to questions asked on or about
January 21, 1998, in an interview with "Roll Call," when you
stated "Well, let me say, the relationship was not improper, and I
think that's important enough to say. But because the investigation
is going on and because I don't know what is out -- what's going to
be asked of me, I think I need to cooperate, answer the questions,
but I think it's important for me to make it clear what is not. And
then, at the appropriate time, I'll try to answer what is. But let
me answer -- it is not an improper relationship and I know what the
word means."?
Response to Request No. 76:
The tape of this interview reflects that in fact I said: "Well,
let me say the relationship's not improper and I think that's
important enough to say. . . ." With that revision, the quoted
words accurately reflect my remarks. As I stated in Response to
Request Nos. 62 to 68, in the days following the January 21, 1998,
disclosures, I misled people about this relationship, for which I
have apologized.
77. Do you admit or deny that you made false and misleading
public statements in response to questions asked on or about
January 21, 1998, in the Oval Office during a photo opportunity,
when you stated: "Now, there are a lot of other questions that
are, I think, very legitimate. You have a right to ask them; you
and the American people have a right to get answers. We are working
very hard to comply and get all the requests for information up
here, and we will give you as many answers as we can, as soon as we
can, at the appropriate time, consistent with our obligation to
also cooperate with the investigations. And that's not a dodge,
that's really (what) I've -- I've talked with (our) people. I want
to do that. I'd like for you to have more rather than less, sooner
rather than later. So we'll work through it as quickly as we can
and get all those questions out there to you."?
Response to Request No. 77:
I made this statement (as corrected), according to a transcript
of a January 22, 1998 photo opportunity in the Oval Office. This
statement was not false and misleading. It accurately represented
my thinking.
78. Do you admit or deny that you discussed with Harry
Thomasson, prior to making public statements in response to
questions asked by the press in January, 1998, relating to your
relationship with Monica Lewinsky, what such statements should be
or how they should be communicated?
Response to Request No. 78:
Mr. Thomasson was a guest at the White House in January 1998,
and I recall his encouraging me to state my denial forcefully.
79. Do you admit or deny that you made a false and misleading
public statement in response to a question asked on or about
January 26, 1998, when you stated "But 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, Ms.
Lewinsky"?
Response to Request No. 79:
I made this statement on January 26, 1998, although not in
response to any question. In referring to "sexual relations", I
was referring to sexual intercourse. As I stated in Response to
Request Nos. 62 to 68, in the days following the January 21, 1998,
disclosures, answers like this misled people about this
relationship, for which I have apologized.
80. Do you admit or deny that you made a false and misleading
public statement in response to a question asked on or about
January 26, 1998, when you stated "I never told anybody to lie,
not a single time. Never?"
Response to Request No. 80:
This statement was truthful: I did not tell Ms. Lewinsky to lie,
and I did not tell anybody to lie about my relationship with Ms.
Lewinsky. I understand that Ms. Lewinsky also has stated that I
never asked or encouraged her to lie.
81. Do you admit or deny that you directed or instructed Bruce
Lindsey, Sidney Blumenthal, Nancy Hernreich and Lanny Breuer to
invoke executive privilege before a grand jury empanelled as part
of a judicial proceeding by the United States District Court for
the District of Columbia Circuit in 1998?
Response to Request No. 81:
On the recommendation of Charles Ruff, Counsel to the President,
I authorized Mr. Ruff to assert the Presidential communications
privilege (which is one aspect of executive privilege) with respect
to questions that might be asked of witnesses called to testify
before the grand jury to the extent that those questions sought
disclosure of matters protected by that privilege. Thereafter, I
understand that the Presidential communications privilege was
asserted as to certain questions asked of Sidney Blumenthal and
Nancy Hernreich. Further, I understand that, as to Mr. Blumenthal
and Ms. Hernreich, all claims of official privilege were
subsequently withdrawn and they testified fully on several
occasions before the grand jury.
Mr. Lindsey and Mr. Breuer testified at length before the grand
jury about a wide range of matters, but declined, on the advice of
the White House counsel, to answer certain questions that sought
disclosure of discussions that they had with me and my senior
advisers concerning, among other things, their legal advice as to
the assertion of executive privilege. White House counsel advised
Mr. Lindsey and Mr. Breuer that these communications were protected
by the attorney-client privilege, as well as executive privilege.
Mr. Lindsey also asserted my personal attorney-client privilege as
to certain questions relating to his role as an intermediary
between me and my personal counsel in the Jones v. Clinton case, a
privilege that was upheld by the Federal appeals court in the
District of Columbia.
