For convenience, the pertinent testimony has
been highlighted in red and may be jumped to directly by clicking
here now.
Q. Now, do you know a woman named Monica Lewinsky?
A. I do.
Q. How do you know her?
A. She worked in the White House for a while, first as an intern, and then
in, as the, in the legislative affairs office.
Q. She began – excuse me.
A. So that's how I know her.
Q. Excuse me for interrupting you, sir. Did she begin to work as an intern
in the White House in the summer of 1995?
A. I don't know when she started working at the White House.
Q. Do you recall when you met her for the first time?
A. It would be sometime, I'd think, in later 1995.
Q. She began to work in the White House office of legislative affairs
around December of 1995, correct?
A. I have no idea.
Q. Do you know how she obtained that job?
A. No.
Q. Did you ever talk to anyone about finding a job for Monica Lewinsky?
A. When she got the job in the legislative affairs office? No.
Q. Before she got that job.
A. No.
Q. Did you ever talk to anyone about the possibility of her obtaining a
job
in the White House?
A. She, she came there as an intern, and as several of them have, she
applied for some job there apparently and got the job. I was not involved
in her moving from being an intern to being a full-time employee. I had
no
involvement in that whatever.
Q. And you never talked to anyone about that?
A. No, I did not.
Q. In April of 1996 she was offered and she accepted a job as assistant
to the assistant secretary for public affair at the U.S. Department of
Defense; is that correct?
A. I don't know when she went over there.
Q. Is it correct that she did accept that job at some point?
A. I don's know what her specific job was. I know that she moved over
to the Department of Defense.
Q. And worked at the Pentagon, correct?
A. Well, she worked for the Department of Defense. I think that's where
all their officer are in Washington.
Q.
Is it true that when she worked at the White House she met with you
several times?
A. I don't know about several times. There was a period when the, when
the Republican Congress shut the government down that the whole White
House was being run by interns, and she was assigned to work back in
the chief of staff's office, and we were all working there, and so I saw
her
on two or three occasions then, and then when she worked at the White
House, I think there was one or two other times when she brought some
documents to me.
Q. Well, you also saw here at a number of social functions at the White
House, didn't you?
A. Could you be specific? I'm not sure. I mean when we had, when we
had like big staff things for, if I had a, like in the summertime, if I
had a
birthday party and the whole White House staff came, then she must have
been there. If we had a Christmas party and the whole White House staff
was invited, she must have been there. I don't remember any specific
social occasions at the White House, but people who work there when
they're invited to these things normally come. It's a – they work long
hours, it's hard work, and it's one of the nice things about being able
to
work there, so I assume she was there, but I don't have any specific
recollection of any social events.
Next Crucial Testimony
JUDGE WRIGHT: I want to interrupt because I want a break. I also
wanted to ask about the luncheon break. We're not, we're not too far
from 12. I personally don't care when we take it, but has Skadden
lawyers arranged for lunch to be brought up to us?
MR. BENNETT: I've arranged for lunch, Your Honor. We can have it
– I don't know if it's there right now. We were thinking 12:30, but
whatever –
JUDGE WRIGHT: That's great. That's perfect.
MR. BENNETT: And we have a room set aside for you and your law
clerk where you can eat privately, and we have a separate room for their
side of the table, and our side.
JUDGE WRIGHT: All right, let's take a 10-minute break.
Short recess)
Q.
Mr. President, before the break, we were talking about Monica
Lewinsky. At any time were you and Monica Lewinsky alone together in
the Oval Office?
A. I don't recall, but as I said, when she worked at the legislative affairs
office, they always had somebody there on the weekends. I typically
worked some on the weekends. Sometimes they'd bring me things on the
weekends. She – it seems to me she brought things to me once or twice
on the weekends. In that case, whatever time she would be in there, drop
it off, exchange a few words and go, she was there. I don't have any
specific recollections of what the issues were, what was going on, but
when the Congress is there, we're working all the time, and typically I
would do some work on one of the days of the weekends in the
afternoon.
Q. So I understand, your testimony is that it was possible, then, that
you
were alone with her, but you have no specific recollection of that ever
happening?
A. Yes, that's correct. It's possible that she, in, while she was working
there, brought something to me and that at the time she brought it to me,
she was the only person there. That's possible.
Next Crucial Testimony
Q. Did it ever happen that you and she went down the hallway from the
Oval Office to the private kitchen?
MR. BENNETT: Your Honor, excuse me, Mr. President, I need some
guidance from the Court at this point. I'm going to object to the innuendo.
I'm afraid, as I say, that this will leak. I don't question the predicates
here.
I question the good faith of counsel, the innuendo in the question. Counsel
is fully aware that Ms. Jane Doe 6 has filed, has an affidavit which they
are
in possession of saying that there is absolutely no sex of any kind in
any
manner, shape or form, with President Clinton, and yet listening to the
innuendo in the questions –
JUDGE WRIGHT: No, just a minute, let me make my ruling. I do not
know whether counsel is basing this question an any affidavit, but I will
direct Mr. Bennett not to comment on other evidence that might be
pertinent and could be arguably coaching the witness at this juncture.
Now, I, Mr. Fisher is an officer of this court, and I have to assume that
he
has a good faith basis for asking the question. If in fact he has no good
faith basis for asking this question, he could later be sanctioned. If
you
would like, I will be happy to review in camera any good faith basis he
might have.
MR. BENNETT: Well, Your Honor, with all due respect, I would like
to know the proffer. I'm not coaching the witness. In preparation of the
witness for this deposition, the witness is fully aware of Ms. Jane Doe
6's
affidavit, so I have not told him a single thing he doesn't know, but I
think
when he asks questions like this where he's sitting on an affidavit from
the
witness, he should at least have a good faith proffer.
JUDGE WRIGHT: Now, I agree with you that he needs to have a good
faith basis for asking the question.
MR. BENNETT: May we ask what it is, Your Honor?
JUDGE WRIGHT: And I'm assuming that he does, and I will be willing
to review this in camera if he does not want to reveal it to counsel.
MR. BENNETT: Fine.
MR. FISHER: I would welcome an opportunity to explain to the Court
what our good faith basis is in an in camera hearing.
JUDGE WRIGHT: All right.
MR. FISHER: I would prefer that we not take the time to do that now,
but I can tell the Court I am very confident there is substantial basis.
JUDGE WRIGHT: All right, I'm going to permit the question. He's an
officer of the Court, and as you know, Mr. Bennett, this Court has ruled
on prior occasions that a good faith basis can exist notwithstanding the
testimony of the witness, of the deponent, and the other party.
MR. BENNETT: Yes, Your Honor, but you understand, and I'm not
arguing with you what my concern is, Your Honor, I wouldn't have any
trouble with that if I knew that this deposition would be kept under seal.
But when he mentions names, when he knows, or at least, you know,
hearsay, hearsay, hearsay about something, they check it out, they get
an
affidavit from the woman, they ask these questions, and the Washington
Times will have her name on the front page tomorrow or the day after.
JUDGE WRIGHT: As you know, I'm extremely sympathetic with your
position, however this is a discovery deposition.
MR. BENNETT: I understand. That's all right, Your Honor. I'm sorry.
JUDGE WRIGHT: Go ahead.
MR. FISHER: Thank you, Your Honor.
THE WITNESS: What was your question again, sir?
MR. FISHER: I've forgotten, Mr. President, I'm sorry.
JUDGE WRIGHT: Something about Ms. Jane Doe 6 in the hallway.
Q. Do you recall ever walking with Jane Doe 6 Lewinsky down the
hallway from the Oval Office to your private kitchen there in the White
House?
A. Well, let me try to describe the facts first, because you keep talking
about this private kitchen. The private kitchen is staffed by two naval
aides. They have total, unrestricted access to my dining room, to that
hallway, to coming into the Oval Office. The people who are in the outer
office of the Oval Office can also enter at any time.
I was, after I went through a presidential campaign in which the far right
tried to convince the American people I had committed murder, run drugs,
slept in my mother's bed with four prostitutes, and done numerous other
things, I had a high level of paranoia.
There are no curtains on the Oval Office, there are no curtains on my
private office, there are no curtains or blinds that can close the windows
in
my private dining room. The naval aides come and go at will. There is a
peephole on the office that George Stephanopoulos first and then Rahm
Emanuel occupied that looks back down that corridor. I have done
everything I could to avoid the kind of questions you are asking me here
today, so to talk about this kitchen as if it is a private kitchen, it's
a little
cubbyhole, and these guys keep the door open. They come and go at will.
Now that's the factual background here.
Now, to go back to your question, my recollection is that, that at some
point during the government shutdown, when Ms. Lewinsky was still an
intern but was working the chief staff's office because all the employees
had to go home, that she was back there with a pizza that she brought to
me and to others. I do not believe she was there alone, however. I don't
think she was. And my recollection is that on a couple of occasions after
that she was there but my secretary Betty Currie was there with her. She
and Betty are friends. That's my, that's my recollection. And I have no
other recollection of that.
.
MR. FISHER: While I appreciate all of that information, for the record
I'm going to object. It's nonresponsive as to the entire answer up to the
point where the deponent said, "Now back to your question."
Q. At any time were you and Monica Lewinsky alone in the hallway
between the Oval Office and this kitchen area?
A. I don't believe so, unless we were walking back to the back dining
room with the pizzas. I just, I don't remember. I don't believe we were
alone in the hallway, no.
Q. Are there doors at both ends of the hallway?
A. They are, and they're always open.
Q. At any time have you and Monica Lewinsky ever been alone together
in any room in the White House?
A. I think I testified to that earlier. I think that there is a, it is
– I have no
specific recollection, but it seems to me that she was on duty on a couple
of occasions working for the legislative affairs office and brought me
some
things to sign, something on the weekend. That's – I have a general
memory of that.
Q. Do you remember anything that was said in any of those meetings?
A. No. You know, we just have conversation, I don't remember.
Next Crucial Testimony
Q. How long has Betty Currie been your secretary?
A. Since I've been president.
Q. Did she also work with you in Arkansas?
A. Not when I was governor. She worked in the transition. She worked
for Warren Christopher in the transition, and then she came to work for
me.
Q. How is her work schedule arranged? Does she have a certain shift that
she works. or do you ask her to work certain hours the following day?
Please explain how her schedule is determined.
A. She works, she comes to work early in the morning and normally stays
there until I leave at night. She works very long hours, and then when
I
come in on the weekend, or on Saturday, if I work on Saturday, she's
there, and normally if I'm, if I'm working on Sunday and I'm having a
schedule of meetings, either she or Nancy Hernreich will be there. One
of
them is always there on the weekend. Sometimes if I come over just with
paperwork and work for a couple of hours, she's not there, but otherwise
she's always there when I'm there.
Q. Are there any other individuals who are specifically assigned to be
your
secretary?
A. No, just Betty. Betty and Nancy Hernreich basically runs the outer
office for me. They are my two major assistants, and of course, and there
are a couple of other people who work with them, Janice Kearney who
keeps my, in effect, diary now of what's going on, who's been – she's
been doing that maybe a. . .
Pages 61 to 64 missing
A. I don't know.
Q. Have you ever met
with Monica Lewinsky in the White House
between the hours of midnight and six a.m.?
A. I certainly don't think so.
Q. Have you ever met –
A. Now, let me just say, when she was working there, during, there may
have been a time when we were all – we were up working late. There are
lots of, on any given night, when the Congress is in session, there are
always several people around until late in the night, but I don't have
any
memory of that. I just can't say that there could have been a time when
that occurred, I just – but I don't remember it.
Q. Certainly if it happened, nothing remarkable would have occurred?
A. No, nothing remarkable. I don't remember it.
Next Crucial Testimony
Q. It would be extraordinary, wouldn't it, for Betty Currie to be in the
White House between midnight and six a.m., wouldn't it?
A. I don't know what the facts were. I mean I don't know. She's an
extraordinary woman.
Q. Does that happen all the time, sir, or rarely?
A. Well, I don't know, because normally I'm not there between midnight
and six, so I wouldn't know how many times she's there. Those are
questions you'd have to ask her. I just can't say.
Q. Has it ever happened that a White House record was created that
showed the Monica Lewinsky was meeting with Betty Currie when in fact
Monica Lewinsky was meeting with you?
MR. BENNETT: No, Your Honor, I'm going to certainly
let the
president answer that, but I object to the form of the question because
it
assumes facts not in evidence, and I again question their good faith in
this
line of questioning.
JUDGE WRIGHT: I overrule the objection. I will permit it. The nature
of many of the responses has been he doesn't recall or he doesn't know,
and so he has not outright denied it. This is discovery and I'll permit
the
question. Go ahead.
A. Would you repeat the question?
Q. Yes sir. Has it ever happened that a White House record was created
that reflected that Betty Currie was meeting with Monica Lewinsky when
in fact you were meeting with Monica Lewinsky?
A. Not to my knowledge.
Next Crucial Testimony
Q. Are there records created of your meetings with people in the White
House?
A. I believe we have a record of the people that, that see me. We have
–
I think there's a record of everybody that comes in and out of the White
House. Of course the people who work there and have permission to be
there can come in and out and move in and out of the offices, and I don't
know if there are records of all those meetings or not. For example there
are several of my staff people I see many times a day, and I have no idea
whether there's a record of every time I see those people.
Q. All right, sir, and I appreciate that, but just to be precise I'm not
asking
about records of everyone coming into the White House, but I'm asking
specifically about records of meetings with you.
A. The answer to that is I don't know. I mean I, Rahm Emanuel comes
through that back door into the kitchen and the hallway you talked about
three or four times a day, unannounced, unscheduled, sometimes at night,
sometimes in the daytime. I have no idea if there's a record of every time
he comes to see me. I have no idea if there's a record of every time John
Podesta comes down the hall and sticks his head in and talks to me about
something. I simply don't know. I don't know the answer to your question.
Q. You suspect, don't you, that there are at least some meetings that you
have for which there's no written record made, correct?
A. I don't know the answer to that. They keep a pretty good record of
everything I do, I think.
Q. When was the last time you spoke with Monica Lewinsky?
A. I'm trying to remember. Probably sometime before Christmas. She
came by to see Betty sometime before Christmas. And she was there
talking to her, and I stuck my head out, said hello to her.
Q. Stuck your head out of the Oval Office?
A. Uh-huh, Betty said she was coming by and talked to her, and I said
hello to her.
Q. Was that shortly before Christmas or –
A. I'm sorry, I don't remember. Been sometime in December, I think, and
I believe – that may not be the last time. I think she came to one of the,
one of the Christmas parties.
Q. Did she tell you she had been served with a subpoena in this case?
A. No. I don't know if she had been. Next Crucial Testimony
Q. Did anyone other than your attorneys ever tell you that Monica
Lewinsky had been served with a subpoena in this case?
A. I don't think so.
Q. Did you ever talk with Monica Lewinsky about the possibility that she
might be asked to testify in this case?
A. Bruce Lindsey, I think Bruce Lindsey told me that she was, I think
maybe that's the first person told me she was. I want to be as accurate
as
I can.
MR. BENNETT: Keep your voice up Mr. President.
THE WITNESS: Okay.
A. But he may not have. I don't have a specific memory, but I talked with
him about the case on more than one occasion, so he might have said that.
Q. Did he tell you that on the phone or in person?
A. I don't know. I talk to him and see him several times a day, so I don't
know. I would have no way of remembering that.
Q. Did you talk to Mr. Lindsey about what action, if any, should be taken
as a result of her being served with a subpoena?
A. No.
Q.
I believe I was starting to ask you a question a moment ago and we
got sidetracked. Have you ever talked to Monica Lewinsky about the
possibility that she might be asked to testify in this lawsuit?
A. I'm not sure, and let me tell you why I'm not sure. It seems to me the,
the, the – I want to be as accurate as I can here. Seems to me the last
time she was there to see Betty before Christmas we were joking about
how you-all, with the help of the Rutherford Institute, were going to call
every woman I'd ever talked to, and I said, you know –
MR. BENNETT: We can't hear you, Mr. President.
A. And I said that you-all might call every woman I ever talked to and
ask
them that, and so I said you would qualify, or something like that. I don't,
I
don't think we ever had more of a conversation than that about it, but
I
might have mentioned something to her about it, because when I saw how
long the witness list was, or I heard about it, before I saw, but actually
by
the time I saw it her name was in it, but I think that was after all this
had
happened. I might have said something like that, so I don't want to say
for
sure I didn't, because I might have said something like that.
Q. Was anyone else present when you said something like that?
A. Betty, Betty was present, for sure. Somebody else might have been
there, too, but I said that to a lot of people. I mean that was just
something I said.
Q. What, if anything, did Monica Lewinsky say in response?
A. Nothing that I can remember. Whatever she said, I don't remember.
A. Nothing that I can remember. Whatever she said, I don't remember.
Probably just some predictable thing.
Q. Recently you took a trip that included a visit to Bosnia, correct?
A. That's correct.
Q. While you were on that trip, did you talk to Monica Lewinsky?
A. I don't believe she was on that trip.
Q. Did you talk to her on the telephone?
A. No.
Q. While you were on that trip, did you ask anyone to talk to her?
A. I don't believe so, no. Can you be more specific? I don't have any
idea. I don't think so, no.
Q. While you were on that trip, did you ask anyone to meet with her?
A. Not to my knowledge. Next Crucial Testimony
Q. Excluding conversations that you may have had with Mr. Bennett or
any of your attorneys in this case, within the past two weeks has anyone
reported to you that they had had a conversation with Monica Lewinsky
concerning this lawsuit?
A. I don't believe so. I'm sorry, I just don't believe so.
Q. You know a man named Vernon Jordan?
A. I know him well.
Q. You've known him for a long time.
A. A long time.
Q.
Has it ever been reported to you that he met with Monica Lewinsky
and talked about this case?
A. I knew that he met with her. I think Betty suggested that he meet with
her. Anyway, he met with her. I, I thought that he talked to her about
something else. I didn't know that – I thought he had given her some
advice about her move to New York. Seems like that's what Betty said.
Next Crucial Testimony
Q. So Betty, Betty Currie suggested that Vernon Jordan meet with
Monica Lewinsky?
A. I don't know that.
Q. I thought you just said that. I'm sorry.
A. No, I think, I think, I think Betty told me that Vernon talked to her,
but
I, but my impression was that Vernon was talking to her about her moving
to New York. I think that's what Betty said to me.
Q. What do you know about her moving to New York?
A. Just that.
Q. Is she going to move to New York?
A. I don't know. She may have already moved to New York. I don't
know. My understanding was that her mother moved to New York and
that she was going to move to New York and that she was looking for
some advice about what she should do when she got there.
Q. Is it your understanding that she was offered a job at the U.N.?
A. I know that she interviewed for one. I don't know if she was offered
one or not.
Q. Have You ever talked to Bill Richardson about Monica Lewinsky? Next Crucial Testimony
A. No.
Q. What's his title?
A. He's the ambassador to the U.N.
JUDGE WRIGHT: I'm sorry, I didn't hear that.
THE WITNESS: He's the ambassador to the U.N.
Q.
Have you ever asked anyone to talk to Bill Richardson about Monica
Lewinsky?
A. I believe that, I believe that Monica, what I know about that is I
believe Monica asked Betty Currie to ask someone to talk to him, and
she, and she talked to him and went to an interview with him. That's what
I believe happened.
Q. And the source of that information is who?
A. Betty. I think that's what Betty – I think Betty did that. I think Monica
talked to Betty about moving to New York, and I, my recollection is that
that was the chain of events.
Q. Did you say or do anything whatsoever to create a possibility of
Monica Lewinsky getting a job at the U.N.?
A. To my knowledge, no, although I must say I wouldn't have thought
there was anything wrong with it. You know, she was a – she had worked
in the White House, she had worked in the Defense Department, and she
was moving to New York. She was a friend of Betty. I certainly wouldn't
have been opposed to it, based on anything I knew, anyway.
Q. Well, have you ever given any gifts to Monica Lewinsky?
A. I don't recall. Do you know what they were?
Q. A hat pin?
A. I don't, I don't remember. But I certainly, I could have.
Q. A book about Walt Whitman?
A. I give – let me just say, I give people a lot of gifts, and when people
are around I give a lot of things I have at the White House away, so I
could have given her a gift, but I don't remember a specific gift.
Q. Do you remember giving her a gold brooch?
A. No.
Q. Do you remember giving her an item that had been purchased from
The Black Dog store at Martha's Vineyard?
A. I do remember that, because when I went on vacation, Betty said that,
asked me if I was going to bring some stuff back from The Black Dog,
and she said Monica loved, liked that stuff and would like to have a piece
of it, and I did a lot of Christmas shopping from The Black Dog, and I
bought a lot of things for a lot of people, and I gave Betty a couple of
the
pieces, and she gave I think something to Monica and something to some
of the other girls who worked in the office. I remember that because Betty
mentioned it to me.
Q. What in particular was given to Monica?
A. I don't remember. I got a whole bag full of things that I bought at
The
Black Dog. I went there, they gave me some things, and I went and
purchased a lot at their store, and when I came back I gave a, a big block
of it to Betty, and I don't know what she did with it all or who got what.
Q. But while you were in the store you did pick out something for
Monica, correct?
A. While I was in the store – first of all, The Black Dog sent me a
selection of things. Then I went to the store and I bought some other
things, t-shirts, sweatshirts, shirts. Then when I got back home, I took
out
a thing or two that I wanted to keep, and I took out a thing or two I
wanted to give to some other people, and I gave the rest of it to Betty
and
she distributed it. That's what I remember doing.
Q. Has Monica Lewinsky ever given you any gifts?
A. Once or twice. I think she's given me a book or two.
Q. Did she give you a silver cigar box?
A. No.
Q. Did she give you a tie?
A. Yes, she had given me a tie before. I believe that's right. Now, as
I
said, let me remind you, normally, when I get these ties, I get ties, you
know, together, and they're given to me later, but I believe that she has
given me a tie.
Q. Well, Mr. President, it's my understanding that Monica Lewinsky has
made statements to people, and I'd like for you – Next
Crucial Testimony
MR. BRISTOW: Object, object to the form of the question. Counsel
shouldn't testify, and when you start out like that, it's obviously counsel
testifying. I don't think that's proper.
MR. BENNETT: Let me add to that, Your Honor wouldn't permit me
to make reference to this affidavit, and I respect your ruling.
JUDGE WRIGHT: Let me, let me just make my ruling. It is not
appropriate for counsel to make comments about, about these things. I
don't know whether he was trying to do this to establish a good faith basis
for the next question or not, but it is inappropriate for counsel to comment,
so I will sustain the objection.
MR. FISHER: I understand.
Q. Did you have an extramarital sexual affair with Monica Lewinsky?
A. No.
Q. If she told someone that she had a sexual affair with you beginning
in
November of 1995, would that be a lie?
A. It's certainly not the truth. It would not be the truth.
Q. I think I used the term "sexual affair." And so the record is completely
clear, have you ever had sexual relations with Monica Lewinsky, as that
term is defined in Deposition Exhibit 1, as modified by the Court.
MR. BENNETT: I object because I don't know that he can remember.
JUDGE WRIGHT: Well, it's real short. He can – I will permit the
question and you may show the witness definition number one.
A. I have never had sexual relations with Monica Lewinsky. I've never
had an affair with her. Next Crucial Testimony
Q. Have you ever had a conversation with Vernon Jordan in which
Monica Lewinsky was mentioned?
A. I have. He told me that he called – he mentioned in passing to me that
he had talked to her, and she had come to him for advice about moving to
New York.
Q. She had come to him for advice?
A. Uh-huh. She'd come to him for advice about moving to New York.
She had called him and asked if she could come see him, and Betty I think
had maybe said something to him about talking to her, and he had given
her some advice about moving to New York. That's all I know about that.
Q. Where were you when you had this conversation with Vernon Jordan.
A. I don't have any idea. I talk to Vernon Jordan a lot.
Q. Do you recall whether it was on the phone or in person?
A. No.
Q. What did he say that she had said to him in response?
A. He just said she seemed like a bright, energetic young woman and she
had certain interests, and he made some suggestions to her and suggested
where she ought to go for interviews. That's all I know about that.
Q. Did you express any approval or disapproval of anything Mr. Jordan
had done?
MR. BENNETT: I object. I don't know what that means, Your Honor.
That's awfully vague and ambiguous. Could you be more specific?
MR. FISHER: Sure.
Q. At the time that you talked to Vernon Jordan about his conversation
with Monica Lewinsky concerning her possible move to New York, did
you express any approval or disapproval?
A. I don't remember. I think he was just reporting on the meeting to me.
There'd be no reason that I would have disapproved it. She was a young
woman who'd worked in the White House and had gone to work in the
Defense Department and was moving to New York. I would not have
though there was anything wrong with that, with us trying to help her.
Q.
Is it your testimony that you had nothing whatsoever to do with causing
that conversation to take place between Monica Lewinsky and Vernon
Jordan?
MR. BENNETT: I object. That, that misstates the testimony.
MR. FISHER: I'm asking what his testimony is.
MR. BENNETT: Anything to do, I think he's testified, Your Honor. If
he want to ask more questions, that's all right, but – JUDGE WRIGHT:
I will – you might rephrase the question and ask whether he ever intended
to facilitate the conversation or took any action to help Ms. Lewinsky
gain
access to Vernon Jordan for this purpose, or for any purpose. You might
ask that. The president has testified on this matter that he doesn't think
it
would be improper if he had, so go ahead, you can ask.
Q. Did you do anything, sir, to prompt this conversation to take place
between Vernon Jordan and Monica Lewinsky?
A. I can tell you what my memory is. My memory is that Vernon said
something to me about her coming in, Betty had called and asked if he
would see her and he said she would, he said he would, and then she
called him and then he said something to me about it. I'm sure if he said
something to me about it I said something positive about it. I wouldn't
have said anything negative about it. I didn't have any negative knowledge.
I mean there would be no reason for me to be negative about it. Vernon
liked to help people. He was always trying to help people.
Q. My question, though, is focused on the time before the conversation
occurred, and the question is whether you did anything to cause the
conversation to occur.
A. I think in the mean – I'm not sure how you mean the question. I think
the way you mean the question, the answer to that is no, I've already
testified. What my memory of this is, if you're asking did I set the meetingup,
I do not believe that I did. I believe that Betty did that, and she may
have mentioned, asked me if I thought it was all right if she did it, and
if
she did ask me I would have said yes, and so if that happened, then I did
something to cause the conversation to occur. If that's what you mean,
yes. I didn't think there was anything wrong with it. It seemed like a
natural think to do to me. But I don't believe that I actually was the
precipitating force. I think that she and Betty were close, and I think
Betty
did it. That's my memory of it. Next Crucial
Testimony
Q. Have you ever had a conversation with Vernon Jordan in which Paula
Jones was mentioned?
A. I'm sure I have. I don't remember what it would have been, but I'm
sure I have. I mean after all this time, I'm sure I have.
MR. BRISTOW: Your Honor, I just think we should note for the
record that it is now almost 12:30, and to my knowledge this is the first
moment in the deposition that the word "Paula Jones" has been mentioned.
JUDGE WRIGHT: Are you suggesting we take a break?
MR. BRISTOW: I think it's a good time for a break, but I'm also
thinking of the fact that we do have some time constraints and – but
anyway, I just thought it was an appropriate thing to note.
MR. BENNETT: Your Honor, I hope the sandwiches are there, but I'm
happy to break now, but I'd like to get some guidance from the Court on
something. If at the completion of, as he has apparently just completed
Miss Lewinsky.
MR. FISHER: No, I haven't, but go ahead.
MR. BENNETT: Oh, I'm sorry, well, I'll wait until you finish with Miss
Lewinsky.
MR. FISHER: I have just a couple of other things.
MR. BENNETT: I can ask my generic question. Hypothetically, Your
Honor, if I have affidavits of women that he's questioning the president
about and Your Honor does not want me to emphasize or even mention it
for fear of the witness, when they are, when he is finished at the end
of the
day, may I read to the president certain relevant portions of those
affidavits that we have an ask the president if that's, as far as he knows,
a
true and accurate statement?
JUDGE WRIGHT: You may, because this is that type of deposition.
MR. BENNETT: Thank you.
JUDGE WRIGHT: And I realize that you want to make your record
because you're fearful about what might take place.
MR. BENNETT: Thank you, Your Honor, thank you, Your Honor.
JUDGE WRIGHT: Would you like to finish these questions now before
we break?
MR. FISHER: I have just a couple more on this particular subject.
JUDGE WRIGHT: All right, all right, let's proceed then.
Q. Mr. President, have you ever paid any money to Monica Lewinsky?
A. No, sir.
Q. Have you ever caused money to be paid to her?
A. Absolutely not.
Q. Have you ever paid off any debt that she owed to some other person?
A. No, sir.
Q. Have you ever caused a debt that she owed to some other person to
be repaid?
A. No, sir. Final Crucial Exchange
MR. FISHER: That's all I have on that subject.
JUDGE WRIGHT: All right, how much time – I'm suggesting we have
lunch for, within the next half-hour and then come back here in half an
hour.
MR. BENNETT:Would you like to break now –
THE
WITNESS: Mr. Fisher, is there something , let me just – you asked
that with such conviction and I answered with such conviction, is there
something you want to ask me about this? I don't, I don't even know what
you're talking about, I don't think.
MR. FISHER: Sir, I think this will come to light shortly, and you'll
understand. Return to Top of Page
MR. BENNETT: Your Honor, we've had an awful lot of innuendo, and
I object to it, and if they have it, let's get to it.
JUDGE WRIGHT: Well, I'm not – we're going to have a break for
lunch for a half an hour. I will use this time for Counsel for Ms. Jones
to
provide me with anything in camera that they might like to with respect
to
a good faith basis for some of the questions to which Counsel have
objected. Again, this is discovery, we're not applying the Rules of
Evidence. There must be a good faith basis for the questions, and I have
not seen any of the deposition, I mean, excuse me, any of the affidavits
to
which you're referring. I had not even heard of some of these individuals
until Monday when we met to discuss the – and I hate this word – the
parameters of the deposition, and so if you would please provide me with
an in camera document or document or documents, or you can just tell me
in camera off the record what your good faith basis is, then I can rule.
MR. CAMPBELL: Will we do that in your room Judge, here?
JUDGE WRIGHT: You can do that in my room, yeah, it doesn't matter.
MR. BENNETT: Your Honor, that's fine with me. I have no objection
to that, but since Your Honor has ruled that I will be permitted to do
that,
I don't feel that's necessary, and withdraw my request that they do that.
What I was worried about is that a record would be finished and we'd just
have a lot on innuendo, so I think as long as I'm permitted to do that,
then
I think it would be –
JUDGE WRIGHT: You may. And keep in mind, also, I don't know just
for what purpose this deposition will be used. It's certainly a discovery
deposition, that's the initial purpose. It's clear that because the Defendant
is the president, and because this Court has actually enormous discretion
with respect to the conduct of this case with respect to the Defendant,
it
would be possible that this might even be used for evidentiary purposes
if
Mr. Clinton can't be present to testify, and that is another reason I will
permit Mr. Bennett to rehabilitate the witness or put anything else on
the
record that you might think would be appropriate.
MR. BENNETT: That being the case, Your Honor, I would ask that
they not meet with you privately. I would never have the ability to question
or challenge that. I thought that was a possible solution to a problem
where I knew nothing and you might have the opportunity to rule
something out, but since you've given me the leeway, it would then be my
view that since you are the trial judge that there not be ex parte
discussions on evidence, and it was my suggestion, and I, and I admit to
that, but given what you just said, I think this is a better way to handle
it.
JUDGE WRIGHT: I'd like to give Counsel the benefit of the doubt, and
even though I do have very grave concerns about the leak of information
under seal in this matter, I can't tie it directly to any Counsel of Ms.
Jones,
and I have to, I don't believe any of the Counsel here are responsible
for
these leaks, and if I had reason to believe so, I would take appropriate
action.
MR. BENNETT: I would suggest that on Monday you might have more
of a factual basis since, since the Rader firm is apparently doing the
circuit
here in Washington.
MR. CAMPBELL: Your Honor, we object to that side-bar.
JUDGE WRIGHT: Again, we have to assume that all Counsel are
playing by the rules set by the Court and until that time, until it's brought
to
my attention, otherwise I'll just have to rest on that assumption. Let's
take
a break.
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