Warning: The following report contains sexually explicit language.
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A. Not Secret Service, but I liked or I preferred to sort of meet
up with him and then we'd walk in together. And I preferred to go in
through the Rose Garden because then I wasn't going - I wasn't risking the
possibility of running into someone in the hall right outside the Oval
Office. ...
... I think you've testified earlier that most of the sexual contact that
you had with the president tended to occur in the hallway, rather than in
the study, although sometimes it was in the study itself.
Did that have anything to do with whether or not it would be easier
to see you in the study as opposed to the hallway?
A. I think so, but I don't specifically - I don't specifically
remember discussing that with the president, but there were circumstances
that that sort of was obvious to me.
Q. And would that include the fact that windows in the study tended
to be uncurtained?
A. Just that, windows. Yes. ...
Q. (PROSECUTOR): In that regard, you also mentioned that you would
move from the oval area or that sometimes you'd start in the Oval Office
and then you'd move towards the hallway. Did the president ever initiate
that move?
A. I think we both did. I mean, it just depended on the day. It
wasn't -
Q: Was it understood that you wouldn't actually have a sexual
encounter in the Oval office?
A. I'm sure it was understood. I - I - I wouldn't have done that. I
mean - so - I'm sure he wouldn't have done that.
Q. (PROSECUTOR): Are there windows all around the Oval Office?
A. There are windows all around and it just I know this may sound
silly, but it wouldn't be appropriate. You know.
Q. What about any discussions with the president about not
acknowledging one another at parties or photographs, for example?
A. He called me in my office the day of Pat Griffin's going away
party and had asked me if I was going to go. I said yes and he said, "Well,
maybe we can get together after that."
And I told him I didn't think that was a good idea, that people
were going to be watching. I was paranoid anyway and - so I said, "I think
it's a good idea if we just sort of ignore each other at the party and
don't really say anything." And that's what we did.
Q. And what about with respect to a photograph that was taken at
the party and whether -
A. I mean, we didn't discuss this. I didn't know there was going to
be a picture taken. ...
Q. So in that case, that would be a concealment effort, but not one that
the president and you had collaborated on.
A. No.
Q. All right. What about an occasion when the president suggested
that the two (of) you might attend a movie and sort of bump into each other
outside the movie? Tell us about that discussion.
A. He told me he was going to watch a movie with some friends of
his and that if I wanted to I could bump into him in the hall outside and
then he'd invite me into the movie. ...
And he said yes and I don't remember who he said was going to be
there, but I said I didn't think that was a good idea.
Q. And why would you have to make prior arrangements for you to
bump into each other rather than having sort of a - you know, walk down the
hall together to the movie?
A. Well, I -
Q. I know it's kind of obvious.
A. For obvious reasons, I guess, because it wouldn't be
appropriate. It - people would - people would wonder what was going on.
Q. Right. Right. Okay. What about the fact that you made - that you
sent gifts and notes through Betty rather than directly to the president?
Was that something that was done in order to make it less obvious
that the notes were actually to the president? ...
A. You can't - I mean, you can't send a courier thing to the
president, you know, a courier to President Clinton, so -
Q. JUROR: Ms. Lewinsky, did you ever discuss with the president
whether you should delete documents from your hard drive, either at the
office or at home?
A. No.
... Q. JUROR: Did you ever discuss with the president whether you
should deny the relationship if you were asked about it?
A. I think I always offered that.
Q. JUROR. In discussions with the president?
A. In discussions - I told him I would always - I would always deny
it, I would always protect him.
Q. JUROR. And what did he say when you said that? What kind of
response did you receive? ...
A. ... I - in my head, I'm seeing him smile and I'm hearing him
saying "That's good," or - something affirmative. You know. Not - not
"Don't deny it." ...
Q. (PROSECUTOR): Ms. Lewinsky, with respect to the weekend visits,
did the president ever initiate that idea ...?
A. Yes. The - I don't remember if it was the Wednesday or the
Friday when the relationship first started, he said to me at some point,
you know, "You can come see me on the weekends. I'm usually around on the
weekends." So -
Q. And did you understand what that meant?
A. Yes. To me, it meant there aren't as many people around on the
weekends. ...
JUROR. ... When you first made the determination that you were
moving to New York and you wanted to explore the possibilities of a job in
private industry, can you recall how you first got the recommendation about
Vernon Jordan's assistance in this endeavor?
A. I can't. I know that it was - what I don't remember was if it
was my idea or Linda's idea. And I know that that came up in discussions
with her, I believe, before I discussed it with the president. I know that
I suggested to the president or I - I didn't suggest, I asked the president
if Mr. Jordan might be able to assist me. ...
JUROR. ... Did you and the president ... ever talk about sort of,
you know, that you weren't really having sex? ...
A. Yes.
JUROR: Was there ever sort of an understanding that, well, oral sex
isn't really sex? Or did you talk about that?
A. We didn't talk about it. ...
... JUROR: After you left the White House, it seems as if you attended a
number of public functions where you came in contact with him. Was that by
chance? Was that something you wanted to do? Was it a way to see him? Was
it something that he suggested? ...
A. Sure. No. Those were all ways for me to get a chance to see him.
I'm an insecure person and so I think - and I was insecure about the
relationship at times and thought that he would come to forget me easily
and if I hadn't heard from him - especially after I left the White House,
it was - it was very difficult for me and I always liked to see him and it
- and usually when I'd see him, it would kind of prompt him to call me. So
I made an effort. I would go early and stand in the front so I could see
him, blah, blah, blah.
Q. PROSECUTOR: Let me ask a follow-up question to that because I
think it may have been in about October of "96 when you had a telephone
conversation with him just prior to you going to Billy Shaddock to get a
photograph.
A. Right.
Q. During the conversation before, did you and the president have
any discussion about your dropping by and seeing him at a public departure?
A. Yes.
Q. All right. Would you tell us about that?
A. Let's see. I spoke with him - I think it was October 22nd, and
then I saw him at an event October 23rd and he called that night and I had
mentioned to him on - I think it was a Tuesday, the first phone
conversation, that I was going to be at the White House on Thursday.
And when he called me Wednesday night, he said - I was upset with
him and so then he said, you know, "Don't be mad. Don't be mad." You know.
"Are you coming tomorrow?"
And I said yes.
So he said, "Well, why don't you stop by Betty's office, stop by to
see Betty and then maybe you can come see me for a few minutes before I
leave." So -
Q. Okay. All right. The reason I was asking that as a follow-up is
that's sort of a prearranged semi-public occasion for the two of you to see
each other.
A. Right. I don't - I don't know necessarily that I was going to go
to the departure.
Q. I see.
A. But that was maybe kind of a cover story.
Q. I understand.
A. Or I'm not - I know he had a departure and I know that I was
going to see him for a few minutes before the departure because I thought -
I remember thinking that I might get to kiss him, so - ...
JUROR: Did you get to see him that day?
A. No, I didn't.
JUROR: Okay. Could you tell us a little about that?
A. Sure. I - the short of it is that I didn't end up seeing him
because Evelyn Lieberman was hanging around and left with him that day.
JUROR: She was someplace where she didn't belong.
... A. ... He had this big 50th birthday party at Radio City Music Hall and
there was a cocktail reception and at the - when he came to do the rope
line and he - after he greeted me and talked to me, he was talking to a
whole bunch of people in and around my area and I had - can I stand up and
show you?
MR. EMMICK: Sure. Sure.
A. Okay. If this is the rope line and here are all the people and
the president's standing here, as he started to talk to other people, I had
my back to him and I just kind of put - put my hand behind me and touched
him.
MS. IMMERGUT. Touched him in the crotch area?
A. Yes.
... A JUROR. Did anybody see you?
... A. No.
A JUROR. But there were people around.
A. There were, but it was - he was talking - everybody was enamored
with him. .. He was always very close to me when - whenever he'd do these
rope lines and would sort of make a point of talking to me ... while other
people were there and he'd usually hold my hand - you know, sort of shaking
hands and just - would continue to just touch me somewhere. I mean, not
intimately, not ...
MR. EMMICK. Right. Just to set the scene, are there a lot of people
kind of bunched together at the time?
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