Clinton Impeachment Trial: Monica Lewinsky’s Deposition

This is Monica Lewinsky’s deposition in the Senate impeachment trial of President Bill Clinton.

Lewinsky was deposed by the House Managers.

The video was shown to the Senate impeachment trial.

Monica Lewinsky’s Deposition.

In the Senate of the United States Sitting for the Trial of the Impeachment of William Jefferson Clinton, President of the United States



SENATOR DeWINE: If not, I will now swear the witness.

Ms. Lewinsky, will you raise your right hand, please?

Whereupon, MONICA S. LEWINSKY was called as a witness and, after having been first duly sworn by Senator DeWine, was examined and testified as follows:

SENATOR DeWINE: The House Managers may now begin your questioning.

MR. BRYANT: Thank you, Senator.

Good morning to all present.



Q. Ms. Lewinsky, welcome back to Washington, and wanted to just gather a few of our friends here to have this deposition now. We do have quite a number of people present, but we–in spite of the numbers, we do want you to feel as comfortable as possible because I think we–everyone present today has an interest in getting to the truth of this matter, and so as best as you can, we would appreciate your answers in a–in a truthful and a fashion that you can recall. I know it’s been a long time since some of these events have occurred.

But for the record, would you state your name once again, your full name?

A. Yes. Monica Samille Lewinsky.

Q. And you’re a–are you a resident of California?

A. I’m–I’m not sure exactly where I’m a resident now, but I–that’s where I’m living right now.

Q. Okay. You–did you grow up there in California?

A. Yes.

Q. I’m not going to go into all that, but I thought just a little bit of background here.

You went to college where?

A. Lewis and Clark, in Portland, Oregon.

Q. And you majored in–majored in?

A. Psychology.

Q. Tell me about your work history, briefly, from the time you left college until, let’s say, you started as an intern at the White House.

A. Uh, I wasn’t working from the time I–

Q. Okay. Did you–

A. I graduated college in May of ’95.

Q. Did you work part time there in–in Oregon with a–with a District Attorney–

A. Uh–

Q. –in his office somewhere?

A. During–I had an internship or a practicum when I was in school. I had two practicums, and one was at the public defender’s office and the other was at the Southeast Mental Health Network.

Q. And those were in Portland?

A. Yes.

Q. Okay. What–you received a bachelor of science in psychology?

A. Correct.

Q. Okay. As a part of your duties at the Southeast Health Network, what did you–what did you do in terms of working? Did you have direct contact with people there, patients?

A. Yes, I did. Um, they referred to them as clients there and I worked in what was called the Phoenix Club, which was a socialization area for the clients to–really to just hang out and, um, sort of work on their social skills. So I–

Q. Okay. After your work there, you obviously had occasion to come to work at the White House. How did–how did you come to decide you wanted to come to Washington, and in particular work at the White House?

A. There were a few different factors. My mom’s side of the family had moved to Washington during my senior year of college and I wanted–I wasn’t ready to go to graduate school yet. So I wanted to get out of Portland, and a friend of our family’s had a grandson who had had an internship at the White House and had thought it might be something I’d enjoy doing.

Q. Had you ever worked around–in politics and campaigns or been very active?

A. No.

Q. You had to go through the normal application process of submitting a written application, references, and so forth to–to the White House?

A. Yes.

Q. Did you do that while you were still in Oregon, or were you already in D.C.?

A. No. The application process was while I was a senior in college in Oregon.

Q. Had you ever been to Washington before?

A. Yes.

Q. Obviously, you were accepted, and you started work when?

A. July 10th, 1995.

Q. Where–where were you assigned?

A. The Chief–

Q. Physically, where were you located?

A. Oh, physically?

Q. Yes.

A. Room 93 of the Old Executive Office Building.

Q. Were you designated in any particular manner in terms of–were all interns the same, I guess would be my question?

A. Yes and no. We were all interns, but there were a select group of interns who had blue passes who worked in the White House proper, and most of us worked in the Old Executive Office Building with a pink intern pass.

Q. Now, can you explain to me the significance of a pink pass versus a blue pass?

A. Sure.

Q. Okay. Is it–is it access?

A. Yes.

Q. To what?

A. A blue pass gives you access to anywhere in the White House and a pink intern pass gives you access to the Old Executive Office Building.

Q. Did interns have blue passes?

A. Yes, some.

Q. Some did, and some had pink passes?

A. Correct.

Q. And you had the pink?

A. Correct.

Q. How long was your internship?

A. It was from July ’til the end of August, and then I stayed on for a little while until the 2nd.

Q. Are most interns for the summertime–you do part of the summer or the entire summer?

A. I believe there are interns all year-round at the White House.

Q. Now, you as an intern, you are unpaid.

A. Correct.

Q. And tell–tell me how you came to, uh, through your decisionmaking process, to seek a paid position and stay in Washington.

A. Uh, there were several factors. One is I came to enjoy being at the White House, and I found it to be interesting. I was studying to take the GREs, the entrance exam for graduate school, and needed to get a job. So I–since I had enjoyed my internship, my supervisor at the time, Tracy Beckett, helped me try and secure a position.

Q. Now, you mentioned the pink pass that you had. So you were able to–I don’t want to presume–you were able to get into the White House on occasion even with a pink pass?

A. The–do you mean the White House proper, or–

Q. Yes, the White House–

A. –the complex?

Q. Yes. Let me be clear. When I–I tend to say `White House’–I mean the actual building itself. And I know perhaps you think of the whole complex in terms of the whole–

A. I’m sorry. Just to be clear–

Q. Yes.

A. –do you mean the West Wing and the residence and–

Q. Right.

A. –the East Wing when you say the White House?

Q. Right. The White House where the President lives, and works, I guess, right.

A. I’m sorry. Can you repeat the question?

Q. Yes, yes. I mean that White House. As an intern, you had a pink pass that did allow you to have access to that White House where the President was on occasion?

A. No.

Q. Did not. Did you have–did you ever get in there as an intern?

A. Yes.

Q. And under–under what circumstances?

A. It–

Q. Did you have to be accompanied by someone, or–

A. Exactly; someone with a blue pass.

Q. So how did you–once you decided you wanted to stay in Washington and find a paying job, you sought out some help from friends there, people you knew, contacts, and you were–you did–you were successful?

A. Correct.

Q. And you were hired where–where in the White House?

A. In Legislative Affairs.

Q. Now, again, to educate me on this, in that group, in that section, department, you would have worked where, physically?

A. Physically, in the East Wing.

Q. Okay, and as an intern before, you worked in the Old Executive Office Building?

A. Correct.

Q. But you moved about and occasionally would go into the White House, if escorted?

A. Correct.

Q. It takes a while, but I’ll get there with you; I’ll catch up.

When did you actually–what was your first day on the job with the Legislative Affairs, uh, group?

A. Um, first day on the job was sometime after the furlough. I was hired right before the furlough, but the paperwork hadn’t gone through, so first day on the job was some point after the furlough. I don’t remember the exact date.

Q. So you remained, uh, on as an intern during the furlough–

A. Correct.

Q. –the Government shutdown period.

A. Correct.

Q. And that was in November of 1995, some date during that?

A. Yes.

Q. Okay. Um, tell me how you, um, began–I guess the–the–we’re going to talk about a relationship with the President. Uh, when you first, uh, I guess, saw him, I think there was some indication that you didn’t speak to him maybe the first few times you saw him, but you had some eye contact or sort of smiles or–

A. I–I believe I’ve testified to that in the grand jury pretty extensively.

Q. Uh-huh.

A. Is–is there something more specific?

Q. Well, again, I’m wanting to know times, you know, how soon that occurred and sort of what happened, you know, if you can–you know, there are going to be occasions where you–obviously, you testified extensively in the grand jury, so you’re going to obviously repeat things today. We’re doing the deposition for the Senators to view, we believe, so it’s–

MR. CACHERIS: May I note an objection. The Senators have the complete record, as you know, Mr. Bryant, and she is standing on her testimony that she has given on the occasions that Mr. Stein alluded to at the introduction of this deposition.

MR. BRYANT: Well, I appreciate that, but, uh, if this is going to be the case, we don’t even need the deposition, because we’re limited to the record and everything is in the record. So I think, uh, to be fair, we’re–we’re obviously going to have to talk about, uh, some things for 8 hours here, or else we can go home.

THE WITNESS: Sounds good to me.


MR. BRYANT: I think we probably all would like to do that.

SENATOR DeWINE: Counsel, are you objecting to the question?

MR. CACHERIS: Yes. I’m objecting to him asking specific questions that are already in the record that–he has said they are limited to the record, and so we accept his, his designation. We’re limited to the record.

SENATOR DeWINE: We’re going to go off the record for just a moment.

THE VIDEOGRAPHER: We’re going off the record at 9:37 a.m.


THE VIDEOGRAPHER: We are going back on the record at 9:45 a.m.

SENATOR DeWINE: We are now back on the record.

The objection is noted, but it’s overruled, and the witness is instructed to answer the question.

Senator Leahy?

SENATOR LEAHY: And I had noted during the break that obviously, the witness has 48 hours to correct her deposition, and would also note that when somebody has testified to some of these things 20 or more times that it is not unusual to have some nuances different, and that could also be reflected in time to correct her testimony.

And I had also noted when we were off the record Mr. Manager Bryant’s comment on January 26th, page S992 in the Congressional Record, in which he said: `If our motion is granted, I want to make this very, very clear. At no point will we ask any questions of Monica Lewinsky about her explicit sexual relationship with the President, either in deposition or, if we are permitted on the floor of the Senate, they will not be asked.’

And I should add also, to be fair to Mr. Bryant, another sentence in that: `That, of course, assumes that White House Counsel does not enter into that discussion, and we doubt that they would.’ Period, close quote.

SENATOR DeWINE: Let me just add something that I stated to counsel and to Ms. Lewinsky off the record, and I think I will briefly repeat it, and that is that counsel is entitled to an answer to the question, but Ms. Lewinsky certainly can reference previous testimony if she wishes to do that. But counsel is entitled to a new explanation of–of what occurred.

Counsel, you may–why don’t you re-ask the question, and we will proceed.

MR. BRYANT: May I, before I do that, ask a procedural question in terms of timekeeping?

SENATOR DeWINE: The time is not counted–any of the time that you have–once there is an objection, none of the time is counted until we rule on the objection and until you then have the opportunity to ask the question again. So the time will start now.

MR. BRYANT: Very good.


Q. Ms. Lewinsky, again, let me–I know this is difficult, but let me apologize that, uh, that it is going to be necessary that I ask you these questions because we’re limited to the record and if we–we can’t ask you any new questions outside that record, so I have to talk about what’s in the record. And I realize you’ve answered all these questions several times before, but it’s, uh–I’m sincere that we really wouldn’t need to take your deposition if we couldn’t ask you those kinds of questions. So it’s not motivated to cause you uncomfort or to make you sit here in Washington when you’d rather be in California. We’ll try to get through this as quickly as we can.

But we were talking about when you were first assigned there at the White House and those initial contacts, and I mean, again, when you were–you would see the President. I think you’ve mentioned you would–there was some mild flirting going on; you would smile or you would make eye contact. It was something of this nature?

A. Yes.

Q. And the first–was the first time you actually spoke to the President or he spoke to you, other than perhaps a hello in the hallway, was that on November the 15th, 1995?

A. Yes.

Q. And that was–that was the day, uh, of the first so-called salacious encounter, the same day?

A. Yes.

Q. Now, when the President gave a statement testifying before the grand jury, he–he described that relationship as what I considered sort of an evolving one. He says: `I regret that what began as a friendship came to include this conduct.’ And he goes on to take full responsibility for his actions. But that almost sounds as if this was an evolving–something from a friendship evolving over time to a sexual relationship. That was not the case, was it?

A. I–I can’t really comment on how he perceived it. My perception was different.

Q. Okay–

A. But I–I–I mean, I don’t feel comfortable saying that he didn’t, that he didn’t see it that way, or that’s wrong; that’s how he saw it. I–

Q. But you saw it a different way?

A. Yes.

Q. Now, on November the 15th, had you already accepted this job with Legislative Affairs?

A. Yes.

Q. And, uh, was–that was during the shutdown, so you had no job to go to because the Government was shut down.

A. No. I accepted it on the Friday before the furlough.

Q. And that–

A. But the paperwork hadn’t gone through.

Q. Okay. Did, uh–when you first met with the President on November the 15th, did he say anything to you that would indicate that he knew you were an intern?

A. No.

Q. Did he make a comment about your, your pink security badge?

A. Can I ask my counsel a question real quickly, please?

[Witness conferring with counsel.]

MR. CACHERIS: Okay, Mr Bryant.

THE WITNESS: Sorry. It was–that occurred in the second encounter of that evening.


Q. Okay. On November–

A. So, not the first encounter.

Q. On November the 15th, 1995?

A. Correct.

Q. What–do you recall what he said or what he did in regard to the intern pass?

A. He tugged on my pass and said: `This is going to be a problem.’

Q. And what did, uh–did he say anything else about what he meant by `problem’?

A. No.

Q. Tell me about your job at Legislative Affairs. Did that involve going into the White House itself?

A. Yes. My job was in the White House.

Q. You were in one wing, but did that involve going–did it give you access–

A. Yes.

Q. –pretty well throughout the White House?

A. Yes.

Q. What did you do primarily?

A. I worked under Jocelyn Jolly, who supervised the letters that came from the Hill; so the opening of those letters and reading them and vetting them and preparing responses for the President’s signature–responding.

Q. Now, you’ve indicated through counsel at the beginning that you are willing to affirm, otherwise adopt, your sworn testimony of August the 6th and August the 20th, I think, which would be grand jury, and the deposition of August the 26th, 1998.

A. Correct.

Q. So you’re saying that that information is accurate, and it is truthful?

A. Yes.

Q. Well, thank you. That–that will save us a little bit of time, but certainly we will ask you some of that information also.

At some point, you were transferred to the Pentagon, to the Department of Defense. When did that occur?

A. I found out I was being transferred on April 5th, 1996.

Q. Did you want to go–

A. No.

Q. –to the Department of Defense? Did you have a discussion with the President about this?

A. Yes.

Q. What was your reaction to being transferred?

A. I started to cry.

Q. Did you talk to anyone else at the White House other than the President about the transfer at that time?

A. Yes.

Q. And who–who was that?

A. I spoke with several people. I–I can’t–I know I–I spoke with, uh, Jocelyn about it. I spoke with people with whom I was friendly at the White House. I spoke to Betty, Nancy Hernreich, several people.

Q. Did you–did you find out why you were being transferred?

A. Uh, I was told why I was being transferred by Mr. Keating on Friday, the 5th of April.

Q. And that was why?

A. Uh, he said that the–the Office of Administration, I think it was, was not pleased with the way the correspondence was being handled, and they were, quote-unquote, `blowing up’ the Correspondence Office, and that I was being transferred and it had nothing to do with my work.

Q. Did you have any understanding that it might have been other reasons that you were being moved?

A. Not at that point.

Q. Did the–what did the President say about your transfer at that point?

A. He thought it had something to do with our relationship.

Q. What else did he say about–about your transfer, if anything? Did he give you any assurances that you might be back, or–

A. Yes.

Q. Back after what time period?

A. He promised me he’d bring me back after the election.

Q. So this was, again, in early 19–April of 1996, and he was up for reelection–

A. Yes.

Q. –in November of 1996.

A. Yes.

Q. Did you attach any significance to being transferred away before the election and then him assuring you he would bring you back after the election? Did you attach any significance to the election and your having to leave?

A. Emotional significance, yes.

Q. Your emotion? I’m–I’m not sure I follow you. You were–

A. Well, yes, I attached significance to it.

Q. And that was emotional–

A. But that was emotional.

Q. But the reason you both felt–again, I’m not trying to put words in your mouth, but you both felt you were leaving until after the election was because of your

relationship and perhaps people finding out?

A. No. I–I–first, I can only speak for myself. I mean, I, uh, my understanding initially was that it was, um, for work-related issues, but not my work, and I came to understand later that it was having to do with my relationship with the President.

Q. Okay. Did, uh, you have a conversation–and it may be the same one with the President on April the 12th–which determined that Ms. Lieberman maybe spearheaded your transfer because you were paying too much attention–you were all–you were both paying too much attention to each other and she was worried that it was close to election time? And I think you’ve testified to that, haven’t you?

A. Yes.

Q. Okay, good. You started, uh, with the Department of Defense at the Pentagon in mid-April, April the 17th, 1996?

A. Yes.

Q. What did you do there?

A. I was the confidential assistant to Mr. Bacon, who is the Assistant Secretary of Defense for Public Affairs.

Q. Did, uh–after the 1996 election, did you still want to go back to the White House?

A. Yes.

Q. You had not fallen in love with the job at the Pentagon that much?

A. No.

Q. Was that, in fact, a frustrating period of time?

A. Yes. No offense to Mr. Bacon, of course.

Q. I understand; I’m sure he would take none.

I would like–I don’t think it’s been mentioned, but you helped in preparing a chart which we have listed as one of our exhibits, ML Number 2, which I assume might have a different number for now, but it’s a chart of contacts–

A. Right.

Q. –that you had with the President. And do you have a copy of that chart? It–

[Witness conferring with counsel.]

MR. BRYANT: In the–yes, in the record, it’s at page 1251.

MR. BURTON: May we have an extra copy for counsel, please?


Q. Have you had occasion to review this document?

A. Yes.

Q. And very–very simply, I would like for you to, uh, if you can, to affirm that document as an accurate representation and a truthful representation of all the contacts that you had with the President from approximately August 9th, 1995 until January of 1998. It includes in-person contacts, telephone calls, gifts and notes exchanged, I think are the categories.

A. Yes. I believe there might have been one or two changes that were made and noted in the grand jury or my deposition, and I adopt those as well.

MR. BRYANT: Okay, good.

I am not going to at this point make her–the information she adopts and affirms exhibits to this deposition. I don’t want to clutter it any more unless someone wants to make this an exhibit in terms of your deposition testimony, your grand jury testimony, and now the charts that you have affirmed, so I just want you to specifically affirm it but not make it an exhibit, because it’s already a part of the record.

MR. CACHERIS: We defer to the White House.

MS. SELIGMAN: I just wanted to make clear on the record, then, what the app. or sub-cite is of anything we’re adopting so that we all know what particular pages it is.

MR. BRYANT: Okay. And that, again, was, I think, page 1251 of–right, of the record.

SENATOR LEAHY: I don’t–I don’t understand.

MS. MILLS: Can you cite the ending page?

SENATOR DeWINE: Counsel, is that where this appears?

MR. BRYANT: It appears in the record, uh–

SENATOR DeWINE: You need to designate also if you’re talking about the Senate record or–I think at this point we’ll go off the record.

THE VIDEOGRAPHER: We’re going off the record at 10:01 a.m.


THE VIDEOGRAPHER: We are going back on the record at 10:11 a.m.

SENATOR DeWINE: Let me–we’re now back on the record.

Let me advise counsel, the Managers, that they have used 25 minutes so far.

You may resume questioning, and if you could begin by identifying the exhibit for the record, please.

MR. BRYANT: Tom, let me also for clarification purposes–Tom, on the referral to the Senate record, you’re saying that the appendices are numbered 3, but the numbers are the same. The page numbers are the same.


MR. BRYANT: And the supplemental materials are your Volume IV, but, again, the pages are the same.

MR. GRIFFITH: That’s our understanding.

MR. BRYANT: Okay. For the record, then, using the Senate volumes, if this is an appendices, Volume III, and the chart that we just alluded to before the break is–appears at pages 116 through 126 of the Senate record, Volume III.


Q. Ms. Lewinsky, did you tell a number of people in varying details about your relationship with the President?

A. Yes.

Q. you tell us who did you tell?

A. Catherine Allday Davis, Neysa Deman Erbland, Natalie Ungvari, Ashley Raines, Linda Tripp, Dr. Kathy Estep, Dr. Irene Kassorla, Andy Bleiler, my mom, my aunt. Who else has been subpoenaed?

Q. Okay. Let me suggest Dale–did you mention Dale Young?

A. Dale Young. I’m sorry.

Q. Thank you.

Now, in the floor presentation, Mr. Craig, who was one of–is one of the counsel for the President, adopted an argument that had been raised in some of the previous hearings, uh, and he adopted this argument in the Senate that–that you have–have or had, I think, both past and present, the incentive to not tell the truth about how the President–this relationship with him because you wanted to avoid–and again, I use the quote from Mr. Craig’s argument–the demeaning nature of providing wholly un-reciprocated sex.

Did, uh–did you lie before the grand jury and to your friends about the nature of that relationship with the President–

A. No.

Q. –so as to avoid what Mr. Craig says? Okay, and I’ll break it down.

SENATOR DeWINE: Counsel, do you want to just–just rephrase the question?

MR. BRYANT: Okay. We’ll break it down into two questions.


Q. Did you not tell the truth before the grand jury as to how the President touched you because of what Mr. Craig alleges as the demeaning nature of the wholly un-reciprocated sex?

MR. CACHERIS: Well, that–may I register an objection, gentlemen? This witness is not here to comment on what some lawyer said on the floor of the Senate. He can ask her direct questions. She will answer them, but what Mr. Craig said or didn’t say would have happened after her grand jury testimony. So it’s totally inappropriate that he’s–

SENATOR DeWINE: Mr. Bryant, why don’t you–

MR. CACHERIS: –marrying those two concepts. We object.

SENATOR DeWINE: Mr. Bryant, why don’t you just rephrase the question?

MR. BRYANT: Well, we–we have had presented on behalf of the President a defense, an incentive, a reason why she would not tell the truth, and I think she should have the opportunity to respond to that–that allegation.

MR. CACHERIS: We–we don’t, uh–

SENATOR LEAHY: Ask her a direct question.

MR. CACHERIS: We welcome you asking her if her testimony was truthful, and she will tell you that it is truthful. We don’t have any problem with that. We don’t have any brief with what the White House did or didn’t do through their counsel. That’s their business. We don’t represent the White House.

MS. SELIGMAN: So, for the record, I’d like to object to the characterization of what Mr. Craig says, which obviously speaks for itself, but I certainly don’t want my silence to be construed as accepting the Manager’s characterization of it.

SENATOR DeWINE: Mr. Bryant, why don’t you–why don’t you ask the question?


SENATOR DeWINE: Go ahead and ask your question.


Q. In regard to your testimony at the grand jury about your–your relationship and the physical contact that you have said occurred in some of these, uh, visits with the President, it has been characterized in a way that would give you an excuse not to tell the truth. Did you tell the truth in the grand jury about what actually happened and how the President touched–the President touched you?

A. Yes.

Q. And did you likewise tell the truth to your friends in connection with the same matters?

A. Yes.

Q. Did your relationship with the President involve giving gifts, exchanging gifts?

A. Yes.

Q. And you mentioned earlier that in reference to this chart that it was, uh, subject to certain corrections you’ve made in later testimony. It was an accurate representation or an accurate compilation of the gifts that, uh, you gave the President and the President gave you. Is that correct?

A. Yes.

Q. Approximately how many gifts did you give the President?

A. I believe I’ve testified to that number. I don’t recall right now.

Q. About 30? Would that be–

A. If that’s what I testified to, then I accept that.

Q. That’s the number I have, and do you recall how many gifts approximately the President gave you?

A. It would be the same situation.

Q. Okay, and you’ve previously testified in your grand jury that he gave you about 18 gifts.

A. I accept that.

Q. Okay, good. What types of gifts did you give the President?

A. They varied. I think they’re listed on this chart, and I’ve testified to them.

Q. Okay, and–

MR. CACHERIS: Do you want her to read the list that’s on this chart?

MR. BRYANT: No. I was just, again, looking for just a–I think maybe a little broader category, but that’s–that’s okay. That’s an acceptable answer there.


Q. After leaving the White House and going to the Pentagon, did you continue to visit the President?

A. Yes.

Q. How would you–how would you be transported from the Pentagon over to the White House? How did you get there?

A. I drove or took a taxi.

Q. Do you have your own car?

A. No.

Q. Whose–whose car would you drive?

A. Either my mom’s or my brother’s.

Q. So you did have access to a vehicle?

A. Correct.

Q. Okay. How were these meetings arranged when you would want to go from the Pentagon to the White House? How did–how did these–how were they set up? Did you get an appointment?

[The witness conferring with counsel.]

SENATOR DeWINE: Counsel–if you have to ask counsel, you can stop and ask us–


SENATOR DeWINE: –to do that.


Q. How were these meetings arranged?

A. Through Ms. Currie.

Q. Would–would you call her and set the meeting up, or would she call you on behalf of the President and set the meeting up?

A. It varied.

Q. Both–both situations occurred?

A. Correct.

Q. Now, Ms. Currie is the President’s–that’s Betty Currie, we’re talking about, the President’s secretary?

A. Yes.

Q. Why was this done? Why was that procedure used?

A. It was my understanding that Ms. Currie took care of the President’s guests who were coming to see him, making those arrangements.

Q. Was, uh–was this–were these visits done sort of off the record, so to speak, so it wouldn’t necessarily be a record?

A. I believe so.

Q. In other words, you wouldn’t be shown on Betty Currie’s calendar or schedule book for the President?

A. I don’t know.

Q. Did–who suggested this type of arrangement for setting up meetings?

A. I believe the President did.

Q. During this time that you were at the Department of Defense at the Pentagon, uh, how–how was it working out about you being transferred back to the White House? How was the job situation coming?

A. Well, I waited until after the election and then spoke with the President about it on several occasions.

Q. And what would he say in response?

A. Various things; `I’m working on it,’ usually.

Q. In July, uh, particularly around the–the 3rd and 4th of July, there–there–you wrote the President a letter, I think.

A. Which year?

Q. July of ’90–it would have been ’97 that you wrote the President a letter expressing some frustrations about the job situation in terms of–is that, uh–can you tell us about that?

A. Yes. I had had a–well, I guess I was–I know I’ve testified about this, I mean, in the grand jury, but I was feeling at that point that I was getting the runaround on being brought back to the White House. So I sent a letter to the President that was probably the harshest I had sent.

Q. Did you get a response?

A. Sort of.

Q. Would you explain?

A. Um, Betty called me and told me to come to the White House the next morning, on July 4th, at 9:00 a.m.

Q. And what happened when you–I assume you went to the White House on July the 4th. What happened?

A. I know I–I–do you have a specific question? I know I testified, I mean, extensively about this whole day, that whole–

Q. Well, in regards to–let’s start with the job.

A. Well, I started crying. We were in the back office and, um–and when the subject matter came up, the President was upset with me and then I began to cry. So–

Q. Did he encourage you about you coming back? Did he make a promise or commitment to you that he would make sure you came back to work at the White House?

A. I don’t know that he reaffirmed his promise or commitment. I remember leaving that day thinking that, as usual, he was going to work on it and had a renewed sense of hope.

Q. Did he comment on your letter, the tone of your letter?

A. Yes.

Q. What did he say?

A. He was upset with me and told me it was illegal to threaten the President of the United States.

Q. Did you intend the letter to be interpreted that way?

A. No.

Q. Did you explain why you wrote the letter to him about reminding him that you were a good girl and you left the White House? Did you have that type of conversation?

A. Yes. That’s what made me start to cry.

Q. Did you, uh–did you ever explain to him that you didn’t intend to threaten him?

A. I believe so.

Q. What was the intent of the letter?

A. First, I felt the letter was going to him as a man and not as President of the United States. Um, second, I think I could see how he could interpret it as a threat, but my intention was to sort of remind him that I had been waiting patiently and what I considered was being a good girl, about having been transferred.

Q. And the threat we’re talking about here would not have been interpreted as a threat to do physical injury or bodily injury to him. It was to expose your relationship to the–to your parents–

A. Correct.

Q. –explain to them why you were not going back to the White House–

A. Correct.

Q. –after the election?

And certainly the President did not encourage you

to expose that relationship, did he?

A. I don’t believe he made any comment about it at that point.

Q. His only comment about the so-called threat was that it’s a—it’s–you can’t do that, it’s against the law to threaten the President?

A. Exactly.

Q. That meeting turned into–I guess you’ve testified that that meeting did turn into a more positive meeting toward the end. It was not all emotional and accusations being made?

A. Correct.

Q. At some point, uh–well, let me–let me back up and ask this. There was a subsequent meeting on July the 14th, and I believe the President had been out of town and this was the follow-up meeting to the July 4th meeting where you had originally discussed the possibility of a newspaper reporter or a magazine writer, I believe, writing a story about Ms. Willey?

A. Correct.

Q. And you, uh–did you have any instructions from the President, from either of these meetings, about doing something for the President, specifically about having Ms. Tripp call White House counsel–

A. I don’t know–

Q. –Mr. Lindsey?

A. –that I’d call them instructions.

Q. Okay. What did he tell you? I don’t want to mischaracterize.

A. He asked me if I would try to have Ms. Tripp contact Mr. Lindsey.

Q. Okay, and if you were to be successful in doing that, what were you supposed to do? Were you supposed to contact Ms. Currie, his secretary?

A. Yes.

Q. And what were you supposed to tell her?

A. In an innocuous way that I had been able to convey that to Ms. Tripp or get her to do that.

Q. Now, in–at some point in October of that year, 1997, did your job focus change?

A. Yes.

Q. And how was that? What were you doing?

A. Uh, it really changed on October 6th, 1997, as a result of a conversation with Linda Tripp.

Q. Uh, in that, as I understand, you sort of got secondhand information that you were probably never going back to work at the White House.

A. Correct.

Q. Did you understand what that meant? Did you accept that? And I guess why would you accept it at that point? Why would you give up on the White House?

MR. CACHERIS: Those are three questions, Mr. Bryant. Will you–would you break it down, please?

MR. BRYANT: Well, yeah, it’s true.


Q. Do you understand? I guess I’m trying to clarify.

A. Not really. I’m sorry.

Q. Why would you accept at that point in October that you were never going back to the White House?

A. I don’t really remember, I mean, what–what–what was going through my mind at that point as to–to answer that question. Is that–

Q. Okay.

A. I’m sorry.

Q. Certainly, if you don’t remember, that’s a–that’s a good answer.

A. Okay.

Q. So you don’t recall anything had really changed other than you had heard secondhand that you weren’t going to go back. You have no independent recollection of anything else other than what somebody told you that would have changed–

A. My recollection is–

Q. –changed your focus?

A. –that it was this–it was this conversation, what Linda Tripp told me from whom this information was coming, the way it was relayed to me that–that shifted everything that day.

Q. And you didn’t feel it was necessary to go back to the President and perhaps confront the President and say, `why am I not coming back, I want to come back?’

A. I mean, I had a discussion with the President, but I had made a decision from that based on that information, and I guess my–my experience of it coming up on a year from the election, having not been brought back, that it probably wasn’t going to happen.

Q. But you–you did call the President about that time and then–but the focus had been changed toward perhaps a job in another location.

A. Yes and no. I didn’t call him, but I, um–

Q. You called Betty–

A. –but we did have a discussion about that.

Q. You called Betty Currie, his secretary.

A. Yes.

Q. Okay, and then through her, he contacted you and you had a discussion?

A. Yes.

Q. And what did you tell him at that time about the job?

A. I believe I testified to that, so that my testimony is probably more accurate. The gist of it was, um, that I wanted to move to New York and that I was accepting I wasn’t going to be able to come back to the White House, and I asked for his help.

Q. Did you bring up Vernon Jordan’s name as perhaps somebody that could help you?

A. It’s possible it was in that conversation.

Q. What was the President’s comments back to you about your deciding to go to New York?

A. I don’t remember his exact comments. He was accepting of the concept.

Q. In regards to your–your, uh, decision to search for a job in New York, in your comments to the President, did he ever tell you that that was good, that perhaps the

Jones lawyers could not easily find you in New York?

A. I’m sorry. I don’t–I–I–

MR. CACHERIS: Excuse me again, Mr. Bryant. That’s a compound question. He could–she could answer it was good, and then she could answer maybe the Jones lawyer couldn’t get her, but I think you’d want an answer to each question.


Q. Okay. Let me ask it this way. There has been some reference to that fact throughout the proceedings, and I recall seeing something somewhere in your–your testimony that you said it or he said it. Do you recall anything being said about you going to Washington–to New York and that the effect of that might be that you would be more difficult to find?

A. I believe that might have been mentioned briefly on the 28th of December, but not as a reason to go to New York, but as a possible outcome of being there. Does that–does that make sense?

Q. It does.

A. Okay.

Q. What, uh–what would have been the context of that? And we’re jumping ahead to December the 28th, but what would have been the context of that particular conversation about the New York and being perhaps–the result being it might be difficult to find you, or more difficult? What was the context?

A. Um, I–I–if I remember correctly, it came sort of at the tail-end of a very short discussion we had about the Jones case.

Q. At this November the 11th meeting, did the President ask you to prepare a list, sort of a wish list for jobs?

A. I’m sorry. Which–

Q. I’m sorry. Did I say October? We’re back to the October the 11th meeting. Did the President ask you to prepare a wish list?

A. Okay. We haven’t gone to the October 11th meeting yet. I–I haven’t said anything about that meeting yet.

Q. Okay.

A. The phone call was on the 9th.

Q. Okay, and you subsequently had a meeting, then, with the President on the 11th?

A. Correct.

Q. Face–face-to-face meeting?

A. Correct.

Q. And at that meeting, did he suggest you give him a wish list or Betty Currie a wish list?

A. Yes.

Q. Again, I asked a compound question there.

Who did he suggest you give the wish list to?

MR. CACHERIS: We’re getting used to that.

MR. BRYANT: I’m getting good. I’m making my own objections now.


THE WITNESS: Um, we sustain those. No, I’m sorry.


MR. BRYANT: I can do that, too. I’ll be doing that in a minute. Overruled. Okay.

THE WITNESS: Um, I–I believe he–he said I should get him a list, and the implication was through Betty.


Q. And obviously you prepared a list of–

A. Correct.

Q. –the people you’d like to work for in New York City.

A. Correct.

Q. And you sent that list–

A. Yes.

Q. –to Betty Currie or to the President?

A. I sent it to Ms. Currie.

Q. And also during this time–and I’m probably going to speed this up a little bit, but, uh, you did interview for the job at the United Nations?

A. Yes.

Q. And, uh–and through a process of several months there, or weeks at least, you did–made an offer to take a job at the United Nations and eventually declined it. Is that correct?

A. Correct.

Q. Did you in early November have the occasion to meet with Vernon Jordan about the job situation?

A. Yes.

Q. And how did you learn about that meeting?

A. I believe I asked Ms. Currie to check on the status of–I guess of finding out if I could have this meeting, and then she let me–she let me know to call Mr. Jordan’s secretary?

Q. And you set up an appointment with Mr. Jordan, or did she, Ms. Currie, do that?

A. No. I set up an appointment. I think that was after a phone–well, I guess I don’t–I don’t know that, so sorry.

Q. But that appointment was November the 5th?

A. Yes.

Q. Prior to going to the meeting with Vernon Jordan, did you tell the President that you had a meeting with Mr. Jordan?

A. I don’t think so. I don’t remember.

Q. Did you carry any documents or any papers with you to the meeting with Mr. Jordan?

A. Yes.

Q. What were those?

A. My resume and a list of public relations firms in New York.

Q. Did Mr. Jordan ask you why you were there?

A. Yes.

Q. And what did you say?

A. I was hoping to move to New York and that he could assist me in securing a job there.

Q. Did he ask you why you wanted to leave Washington?

A. Yes.

Q. And what was your answer?

A. I gave him the vanilla story of, um, that I–I think I–I don’t remember exactly what I said. I–I believe I’ve testified to this. I think it was something about wanting to get out of Washington.

Q. The vanilla story. You mean sort of an innocuous set of reasons, not really the true reasons you wanted to leave?

A. Yes.

Q. And what were the true reasons you wanted to leave?

A. Because I couldn’t go back to the White House.

Q. Did–did you think Mr. Jordan accepted–did you think he would accept that vanilla story, or did you feel like he understood the real story?

A. No, I felt he accepted it.

Q. Did Mr. Jordan tell you during this meeting that he had already spoken with the President?

A. It was–I believe so.

Q. And that you had come highly recommended, I think?

A. Yes.

Q. Did he, Mr. Jordan, review your list of job preferences and suggest anything?

A. Yes.

Q. And what did he suggest?

A. He said the names of the–he looked at the list of public relations firms and I think sort of said, `oh, I’ve heard of them, I haven’t heard of these people, have you heard of so and so,’ that I hadn’t heard of.

Q. Your meeting lasted about 20 minutes?

A. If that’s what I’ve testified to, then I accept that.

Q. It is, or close to it. I know this is an approximation, but thereabouts. You weren’t there all day.

A. I had–well, I don’t–I don’t remember how long it was right now. I know I’ve testified to that. So if I said 20 minutes, then–

Q. Did you have a conversation with the President on–about a week later on November the 12th and by telephone?

A. Yes.

Q. And did you indicate there you had spoken with Mr. Jordan about a job?

A. Yes.

Q. After you met with Mr. Jordan, did you–did you have an impression that you would get, uh–get a job, get favorable results in your job search?

A. Yes.

Q. Did anything favorable happen to–in your job search from that November the 5th, 1997, meeting until Thanksgiving?

A. No, but I believe Mr. Jordan was out of town for a week or two.

Q. During the weeks after this November the 5th interview, did you try to contact Mr. Jordan?

A. Yes.

Q. How?

A. First, I sent him a thank-you note for the initial meeting, and I believe I placed some phone calls right before Thanksgiving–maybe a phone call. I don’t remember if it was more than one.

Q. What–what happened with respect to the job search, uh, through there, through Thanksgiving? Was there anything? I mean, I know he–you said he was out of down, but did anything, to your knowledge, occur? Could you see any results up to Thanksgiving?

A. From my meeting with Mr. Jordan?

Q. Yes.

A. No.

Q. Did you contact Betty Currie after you received no response from Mr. Jordan?

A. Yes.

Q. And did she page you? I think you were in Los Angeles at the time.

A. Correct.

Q. Okay. What–what did she tell you as a result of that telephone call?

A. She asked me to place a call to Mr. Jordan, which I did.

Q. And this would have been, again, around November the 26th, shortly–well, around Thanksgiving?

A. It was before Thanksgiving.

Q. And I assume you found Mr. Jordan.

A. Yes.

Q. And what did he tell you?

A. That he was working on it.

Q. Did he tell you to call him back?

A. Yes.

Q. Did you indeed call him back

A. I didn’t actually get ahold of him; he was out-of-town that day. I think it was December 5th.

Q. Did you try to meet with the President during this time?

A. Yes.

Q. How did you do that?

A. I was a pest. I sent a note to Ms. Currie and asked her to pass it along to the President, requesting that I meet with him.

Q. Were you successful in having a meeting as a result of those efforts?

A. I don’t know if it was a result of those efforts, but yes, I ended up having a meeting with the President.

Q. And when would that have been; what day?

A. On the 6th of December 1997.

Q. Again you are going through Betty Currie; is that, again, the standard procedure at that time?

A. Yes.

Q. Did you go–I think you spoke also perhaps to Betty Currie on December the 5th, the day before the meeting–

A. Yes.

Q. –and this was something about attending the President’s speech. Was that when that occurred–or the radio address, or something? Does that ring any bells?

A. No.

Q. Did–you did attend the Christmas party that day–

A. Yes.

Q. –and the White House. And you saw the President?

A. Yes.

Q. Just socially, speak to him, and that’s it?

A. Yes.

Q. Picture, handshaking, and that?

A. [Nodding head.]

Q. Okay. That’s a yes?

A. Yes. Sorry.

Q. Prior to December 6th, 1997, had you purchased a Christmas gift for the President?

A. Yes.

Q. Which was?

A. An antique standing cigar holder.

Q. And had you purchased any other additional gifts for him?

A. Yes.

Q. And what were those?

A. Uh, a Starbucks mug that said `Santa Monica’; a necktie that I got in London; a little box–I call it a `chochki’–from, uh–and an antique book on Theodore Roosevelt.

Q. Was it your intention to, to carry those Christmas presents to the President home that Saturday, December the 6th?

A. If I were to have a meeting with him, yes.

Q. Did you attempt to have a meeting?

A. Yes.

Q. Did you go through Betty Currie?

A. Yes. I sent her the letter to, to give to the President.

Q. And when you went to the White House that day, you also attempted to, to have the meeting through calling Betty Currie and telephoning her; I believe you had to go to–

A. Which day? I’m sorry.

Q. On the 6th.

A. No.

Q. The Saturday.

A. [No response.]

Q. No?

A. I–I attempted to give the presents to Betty, but I didn’t call and attempt to have a meeting there–well, I guess I called in the morning, so that’s not true–I’m sorry. Yes, I called Ms. Currie in the morning trying to see if I could see the President and apologize.

Q. And–were you–did you see the President, then, on the 6th?

A. Yes, I did.

Q. Tell us about that meeting–that was a long–was that, uh–did you have a telephone conversation with him that day also?

A. Yes.

Q. And that was the long telephone conversation?

A. It–it was.

Q. Okay. I think there has been some indication it

may have been 56 minutes, something approximating an hour-long conversation; does that sound right?

A. Right. That would–that might include some conversation time with Ms. Currie as well.

Q. Okay. Was he interrupted by Ms. Currie–could you tell–did he have to take a break from the telephone call to talk to Ms. Currie, or do you recall any, any–

A. I don’t recall that.

Q. –do you recall any breaks to talk to anybody else?

A. I don’t recall that. Doesn’t mean it didn’t happen; I just don’t remember it.

Q. What else did you–did you arrange in that telephone conversation, or did he invite you in that telephone conversation to come to the White House that day?

A. Yes, he did.

Q. What happened during, during that conversation in terms of–I understand that it was again an emotional day, some sort of a word fight; is that right?

A. Yes.

Q. Could you tell me–he was, uh–again, to perhaps save some time–he was angry about an earlier incident, and, uh, he felt like you were intruding on his lawyer time?

A. Uh, he was upset that I hadn’t accepted that he just couldn’t see me that day.

Q. And what was your response to that?

A. Probably not positive. Uh, that’s why it was a fight.

Q. Again, I want to be careful that I don’t put words in your mouth, but you were dealing with this relationship from an emotional standpoint of wanting to spend time with him–

A. Yes.

Q. –not as President, but as a man?

A. Correct.

Q. And this was at a point when you didn’t feel like you were spending enough time with him?

A. Correct.

Q. And he obviously felt he had to do other things, too, talk to lawyers and do those kinds of things–be the President–is that right?

A. Yes.

Q. Okay. Now, was some of this discussion that we term `the fight,’ was that over the telephone?

A. Yes. It was all over the telephone.

Q. So by the time you arrived and had the face-to-face meeting with him, that was over?

A. Correct.

Q. Was that during the time that you exchanged–exchanged some of the Christmas presents with him?

A. In–in the meeting?

Q. Yes.

A. Yes. I gave him my Christmas presents.

Q. Did you discuss the job search with him also at that time?

A. I believe I mentioned it.

Q. Did you tell him that, uh, your job search with

Mr. Jordan was not going well?

A. I don’t know if I used those words. I don’t, I don’t remember exactly–

Q. If your grand jury testimony said yes–I mean, words to that effect–that would–you could have used those words if they’re in your grand jury–

A. If my grand jury testimony says that–if that’s what I said in my grand jury testimony, then I accept that.

Q. I’m not trying to–I’m not trying to trick you.

A. Okay.

Q. Did he make any comment to you about what he might do to aid in your job search at that time, if you recall?

A. I think he–I think he said, oh, let me see about it, let me see what I can do–his usual.

Q. Did, uh, did the President say anything to you at that time about your name appearing on a witness list in the Paula Jones case?

A. No.

Q. Did you later learn that your name had appeared on such a list?

A. Yes.

Q. And did you later learn that that witness list had been faxed to the White House–to the President’s lawyers on December the 5th?

A. Much later, as in last year.

Q. Okay. Yes–that’s what I mean–later.

A. I, I mean–

Q. Yes.

A. –post this investigation.

Q. Okay. All right. Let’s go forward another week or so to December the 11th and a lunch that you had with Vernon Jordan, I believe, in his office.

A. Yes.

Q. How did–how was that meeting set up.

A. Through his secretary.

Q. Did you instigate that, or did he call through his secretary?

A. I don’t remember.

Q. What was the purpose of that meeting?

A. Uh, it was to discuss my job situation.

Q. And what, what–how was that discussed?

A. Uh, Mr. Jordan gave me a list of three names and suggested that I contact these people in a letter that I should cc him on, and that’s what I did.

Q. Did he ask you to copy him on the letters that you sent out?

A. Yes.

Q. During this meeting, did he make any comments about your status as a friend of the President?

A. Yes.

Q. What–what did he say?

A. In one of his remarks, he said something about me being a friend of the President.

Q. And did you respond?

A. Yes.

Q. How?

A. I said that I didn’t, uh–I think I–my grand jury

testimony, I know I talked about this, so it’s probably more accurate. My memory right now is I said something about, uh, seeing him more as, uh, a man than as a President, and I treated him accordingly.

Q. Did you express your frustration to Mr. Jordan with, uh, with the President?

A. I expressed that sometimes I had frustrations with him, yes.

Q. And what was his response to you about, uh–after you talked about the President?

A. Uh, he sort of jokingly said to me, You know what your problem is, and don’t deny it–you’re in love with him. But it was a sort of light-hearted nature.

Q. Did you–did you have a response to that?

A. I probably blushed or giggled or something.

Q. Do you still have feelings for the President?

A. I have mixed feelings.

Q. What, uh–maybe you could tell us a little bit more about what those mixed feelings are.

A. I think what you need to know is that my grand jury testimony is truthful irrespective of whatever those mixed feelings are in my testimony today.

Q. I know in your grand jury you mentioned some of your feelings that you felt after he spoke publicly about the relationship, but let me ask you more about the positive–you said there were mixed feelings. What about–do you still, uh, respect the President, still admire the President?

A. Yes.

Q. Do you still appreciate what he is doing for this country as the President?

A. Yes.

Q. Sometime back in December of 1997, in the morning of December the 17th, did you receive a call from the President?

A. Yes.

Q. What was the purpose of that call? What did you talk about?

A. It was threefold–first, to tell me that Ms. Currie’s brother had been killed in a car accident; second, to tell me that my name was on a witness list for the Paula Jones case; and thirdly, he mentioned the Christmas present he had for me.

Q. This telephone call was somewhere in the early morning hours of 2 o’clock to 2:30.

A. Correct.

Q. Did it surprise you that he called you so late?

A. No.

Q. Was this your first notice of your name being on the Paula Jones witness list?

A. Yes.

Q. I realize he, he commented about some other things, but I do want to focus on the witness list.

A. Okay.

Q. Did he say anything to you about how he felt concerning this witness list?

A. He said it broke his heart that, well, that my

name was on the witness list.

Can I take a break, please? I’m sorry.

SENATOR DeWINE: Sure, sure. We’ll take a 5-minute break at this point.

THE VIDEOGRAPHER: This marks the end of Videotape Number 1 in the deposition of Monica S. Lewinsky. We are going off the record at 10:56 a.m.


THE VIDEOGRAPHER: This marks the beginning of Videotape Number 2 in the deposition of Monica S. Lewinsky. The time is 11:10 a.m.

SENATOR DeWINE: We are now back on the record.

I will advise the House Managers that they have used one hour and 8 minutes.

Mr. Bryant, you may proceed.

MR. BRYANT: Thank you.


Q. Did–did we get your response? We were talking about the discussion you were having with the President over the telephone, early morning of the December 17th phone call, and he had, uh, mentioned that it broke his heart that you were on that list.

A. Correct.

Q. And I think you were about to comment on that further, and then you need a break.

A. No.

Q. No.

A. I just wanted to be able to focus–I know this is an important date, so I felt I need a few moments to be able to focus on it.

Q. And you’re comfortable now with that, with your–you are ready to talk about that?

A. Comfortable, I don’t know, but I’m ready to talk about.

Q. Well, I mean comfortable that you can focus on it.

A. Yes, sir.

Q. Good. Now, with this discussion of the fact that your name appeared as a witness, had you–had you been asleep that night when the phone rang?

A. Yes.

Q. So were you wide awake by this point? It’s the President calling you, so I guess you’re–you wake up.

A. I wouldn’t say wide awake.

Q. He expressed to you that your name–you know, again, you talked about some other things–but he told you your name was on the list.

A. Correct.

Q. What was your reaction to that?

A. I was scared.

Q. What other discussion did you have in regard to the fact that your name was on the list? You were scared; he was disappointed, or it broke his heart. What other discussion did you have?

A. Uh, I believe he said that, uh–and these are not necessarily direct quotes, but to the best of my memory, that he said something about that, uh, just because my name was on the list didn’t necessarily mean I’d be subpoenaed;

and at some point, I asked him what I should do if I received a subpoena. He said I should, uh, I should let Ms. Currie know. Uh–

Q. Did he say anything about an affidavit?

A. Yes.

Q. What did he say?

A. He said that, uh, that I could possibly file an affidavit if I–if I were subpoenaed, that I could possibly file an affidavit maybe to avoid being deposed.

Q. How did he tell you you would avoid being deposed by filing an affidavit?

A. I don’t think he did.

Q. You just accepted that statement?

A. [Nodding head.]

Q. Yes?

A. Yes, yes. Sorry.

Q. Are you, uh–strike that. Did he make any representation to you about what you could say in that affidavit or–

A. No.

Q. What did you understand you would be saying in that affidavit to avoid testifying?

A. Uh, I believe I’ve testified to this in the grand jury. To the best of my recollection, it was, uh–to my mind came–it was a range of things. I mean, it could either be, uh, something innocuous or could go as far as having to deny the relationship. Not being a lawyer nor having gone to law school, I thought it could be anything.

Q. Did he at that point suggest one version or the other version?

A. No. I didn’t even mention that, so there, there wasn’t a further discussion–there was no discussion of what would be in an affidavit.

Q. When you say, uh, it would be–it could have been something where the relationship was denied, what was your thinking at that point?

A. I–I–I think I don’t understand what you’re asking me. I’m sorry.

Q. Well, based on prior relations with the President, the concocted stories and those things like that, did this come to mind? Was there some discussion about that, or did it come to your mind about these stories–the cover stories?

A. Not in connection with the–not in connection with the affidavit.

Q. How would–was there any discussion of how you would accomplish preparing or filing an affidavit at that point?

A. No.

Q. Why–why didn’t you want to testify? Why would not you–why would you have wanted to avoid testifying?

A. First of all, I thought it was nobody’s business. Second of all, I didn’t want to have anything to do with Paula Jones or her case. And–I guess those two reasons.

Q. You–you have already mentioned that you were not a lawyer and you had not been to law school, those kinds of things. Did, uh, did you understand when you–the potential legal problems that you could have caused yourself by

allowing a false affidavit to be filed with the court, in a court proceeding?

A. During what time–I mean–I–can you be–I’m sorry–

Q. At this point, I may ask it again at later points, but the night of the telephone–

A. Are you–are you still referring to December 17th?

Q. The night of the phone call, he’s suggesting you could file an affidavit. Did you appreciate the implications of filing a false affidavit with the court?

A. I don’t think I necessarily thought at that point it would have to be false, so, no, probably not. I don’t–I don’t remember having any thoughts like that, so I imagine I would remember something like that, and I don’t, but–

Q. Did you know what an affidavit was?

A. Sort of.

Q. Of course, you’re talking at that time by telephone to the President, and he’s–and he is a lawyer, and he taught law school–I don’t know–did you know that? Did you know he was a lawyer?

A. I–I think I knew it, but it wasn’t something that was present in my, in my thoughts, as in he’s a lawyer, he’s telling me, you know, something.

Q. Did the, did the President ever tell you, caution you, that you had to tell the truth in an affidavit?

A. Not that I recall.

Q. It would have been against his interest in that lawsuit for you to have told the truth, would it not?

A. I’m not really comfortable–I mean, I can tell you what would have been in my best interest, but I–

Q. But you didn’t file the affidavit for your best interest, did you?

A. Uh, actually, I did.

Q. To avoid testifying.

A. Yes.

Q. But had you testified truthfully, you would have had no–certainly, no legal implications–it may have been embarrassing, but you would have not had any legal problems, would you?

A. That’s true.

Q. Did you discuss anything else that night in terms of–I would draw your attention to the cover stories. I have alluded to that earlier, but, uh, did you talk about cover story that night?

A. Yes, sir.

Q. And what was said?

A. Uh, I believe that, uh, the President said something–you can always say you were coming to see Betty or bringing me papers.

Q. I think you’ve testified that you’re sure he said that that night. You are sure he said that that night?

A. Yes.

Q. Now, was that in connection with the affidavit?

A. I don’t believe so, no.

Q. Why would he have told you you could always say that?

A. I don’t know.


[Page: S1219]


Mr. BURTON: Objection. You’re asking her to speculate on someone else’s testimony.

MR. BRYANT: Let me make a point here. I’ve been very patient in trying to get along, but as I alluded to earlier, and I said I am not going to hold a hard line to this, but I don’t think the President’s–the witness’ lawyers ought to be objecting to this testimony. If there’s an objection here, it should come from the White House side, nor should they be–

SENATOR DeWINE: Counsel, why don’t you rephrase the question?

MR. BRYANT: Do we have a clear ruling on whether they can object?

SENATOR DeWINE: We’ll go off the record for a moment.

THE VIDEOGRAPHER: We’re going off the record at 11:20 a.m.


THE VIDEOGRAPHER: We are going back on the record at 11:30 a.m.

SENATOR DeWINE: We are now back on the record.

It’s our opinion that counsel for Ms. Lewinsky do have the right to make objections. We would ask them to be as short and concise as humanly possible. So we will now proceed.

Mr. Bryant?

MR. BRYANT: Thank you, Senator.


Q. Let’s kind of bring this back together again, and I’ll try to ask sharper questions and avoid these objections.

We’re at that point that we’ve got a telephone conversation in the morning with you and the President, and he has among other things mentioned to you that your name is on the Jones witness list. He has also mentioned to you that perhaps you could file an affidavit to avoid possible testifying in that case. Is that right?

A. Correct.

Q. And he has also, I think, now at the point that we were in our questioning, referenced the cover story that you and he had had, that perhaps you could say that you were coming to my office to deliver papers or to see Betty Currie; is that right?

A. Correct. It was from the entire relationship, that story.

Q. Now, when he alluded to that cover story, was that instantly familiar to you?

A. Yes.

Q. You knew what he was talking about?

A. Yes.

Q. And why was this familiar to you?

A. Because it was part of the pattern of the relationship.

Q. Had you actually had to use elements of this cover story in the past?

A. I think so, yes.

Q. Did the President ever tell you what to say if

anyone asked you about telephone conversations that you had had with him?

A. Are we–are we still focused on December 17th?

Q. No, no.

A. Okay.

Q. It did not have to be that night. Did he ever?

A. If I could just–I–I’m pretty date-oriented, so if you could just be more specific with the date. If we’re staying on a date or leaving that date, it would just help me. I’m sorry.

Q. Well, my question was phrased did he ever do that, but–

A. Okay.

Q. Well, I–I’m sorry. I’m playing guessing games with you. Was there a conversation on March 29th of 1997 when the President told you he thought perhaps his telephone conversations were being tapped or taped–either way, or both–by a foreign embassy?

A. Yes.

Q. And was there some reference to some sort of cover story there in the event that his line was tapped?

A. Yes.

Q. And what was that?

A. That–I think, if I remember it correctly, it was that we–that he knew that we were sort of engaging in those types of conversations, uh, knowing that someone was listening, so that it was not for the purposes that it might have seemed.

Q. Did you find it a little strange that he would express concern about possible eavesdropping and still persist in these calls to you?

A. I don’t think phone calls of that nature occurred and happened right after, or soon after that discussion. I think it was quite a few months until that resumed.

Q. I think my question was more did you not find it a little strange that he felt that perhaps his phone was being tapped and conversations taped by a foreign embassy, and he–

A. I–I thought it was strange, but if–I mean, I wasn’t going to question what he was saying to me.

Q. But that he also continued to make the calls–you’re saying he didn’t make any calls after that?

A. No. My understanding was it was referencing a certain type of phone call, certain nature of phone call, uh, and those–

Q. Let me direct your attention back to a point I did not mention a couple–a few days before the December–early December telephone call, the lengthy telephone call from the President. We had talked about how that was a heated conversation.

A. Correct.

Q. At–did at some point during that telephone conversation–did the tone–did the President’s tone change to a more receptive, friendly conversation?

A. Yes.

Q. Do you know why that happened?

A. No, nor do I remember whose tone changed first. I

mean, we made up, so–

Q. Okay. Now let me go back again to the December 11th date–I’m sorry–the 17th. This is the conversation in the morning. What else–was there anything else you talked about in terms of–other than your name being on the list and the affidavit and the cover story?

A. Yes. I had–I had had my own thoughts on why and how he should settle the case, and I expressed those thoughts to him. And at some point, he mentioned that he still had this Christmas present for me and that maybe he would ask Mrs. Currie to come in that weekend, and I said not to because she was obviously going to be in mourning because of her brother.

Q. In–in that–in that relationship with the President, I think you have expressed in your testimony somewhere that you weren’t necessarily jealous of those types of people like Kathleen Willey or Paula Jones, and perhaps you didn’t even believe those stories occurred as–as they alleged.

A. That’s correct. I don’t–I don’t know, jealous or not jealous. I don’t think I’ve testified to my feelings of jealousy, but the latter half of the question is true.

Q. I–I saw it. I mean, it’s not a major point. I thought I saw that in your testimony, that particular word.

A. Okay. If I said that, then I–I don’t.

Q. Was it your belief that the Paula Jones case was not a valid lawsuit? Was that part of that discussion that night, or your strategy?

A. Uh, can I separate that–that into two questions?

Q. Any way, any way you want to.

A. Okay. I don’t believe it was a valid lawsuit, and I don’t think whether I believed it was a valid lawsuit or not was the topic of the conversation.

Q. Okay, that’s a fair answer.

You believe the President’s version of the Paula Jones incident?

A. Is that relevant to–

Q. I–I just asked you the question.

A. I don’t believe Paula Jones’ version of the story.

Q. Okay, good. That’s a fair answer.

You have testified previously that you tried to maintain secrecy regarding this relationship–and we’re talking about obviously with the President. Is that true?

A. Yes.

Q. And to preserve the secrecy and I guess advance this cover story, you would bring papers to the President and always use Betty Currie for the excuse for you to be WAVE’d in. Is that right?

A. Papers when I was working at the White House and Mrs. Currie after I left the White House. So Mrs. Currie wasn’t involved when I was working at the White House.

Q. Were these papers you carried in to the President–were they–were they business documents, or were they more personal papers from you to him?

A. They–they weren’t business documents.

Q. So, officially, you were not carrying in official papers?

A. Correct.

Q. You were carrying in personal papers that would not have entitled you ordinarily to go see the President?

A. Correct.

Q. When–in this procedure where Betty Currie was always the one that WAVE’d you in to the White House–and I–I don’t know if the people who may be watching this deposition, the Senators, understand that the WAVES process is just the–to give the guards the okay for you to come in. Is that a short synopsis?

A. I’m not really versed on–

Q. I’m not either. You know more than I do, probably, since you worked there, but–

A. Well, I know you had to go, you had to type in a thing in at WAVES, and now you have to give a Social Security, birth date, have to show ID.

Q. Is there a record kept of that?

A. I believe so.

Q. Was it always Betty Currie that WAVE’d you in to the–access to the White House? I’m talking about now after you left and went to work at the Pentagon.

A. No.

Q. Other people did that?

A. There were other reasons that I came to the White House at times.

Q. Did you ever ask the President if he would WAVE you in?

A. Yes.

Q. Did he ever do that?

A. No, not to my–not to my knowledge.

Q. Was there a reason? Did he express anything to you why he would or would not?

A. Yes. He said that, uh–I believe he said something about that there’s a specific list made of people that he requests to come in and–and there are people who have access to that list.

Q. So, obviously, he didn’t want your name being on that list?

A. Correct.

Q. Now, some of those people–

A. I think–well, that’s my understanding.

Q. Would some of those people be the people that worked outside his office, Ms. Lieberman and those–those folks?

A. I–I believe so, but I’m not really sure.

Q. Did you not want those people to know that you were inside the White House?

A. I didn’t.

Q. Why is that?

A. Because they didn’t like me.

Q. Would they have objected, do you think–if you know.

A. I don’t know.

Q. Did you work with Betty Currie on occasions to–to get in to see the President, perhaps bypass some of these people?

A. Yes.

Q. And that would be another way that you would conceal the meeting with the President, by using Betty Currie to get you in?

A. I–I think, yes, be cautious of it.

Q. Did–well, I think we’ve covered that, about some papers, and I think we’ve covered that after you left your job inside the White House with Legislative Affairs and went to the Pentagon, you developed a story, a cover story to the effect that you were going to see Betty, that’s how you would come in officially?

A. Correct.

Q. And during that time that you were at the Pentagon, you would more likely visit him on weekends or during the week? Which would–which would–

A. Weekends.

Q. Weekends. And why–why the weekends?

A. First, I think he had less work, and second of all, there were–I believe there were less people around.

Q. Now, whose idea was it for you to come on weekends?

A. I believe it was the President’s.

Q. When you–when the President was in his office, was your purpose to go there and see him? If he was in the office, you would go see him?

A. What–I’m sorry.

Q. No–that’s not clear. I’ll withdraw that question.

Was Ms. Currie, the President’s secretary–was she in the loop, so to speak, in keeping this relationship and how you got in and out of the White House, keeping that quiet?

A. I think I actually remember reading part of my grand jury testimony about this and that it was more specific in that she was in the loop about my friendship with the President, but I just want to not necessarily–there was a clarification, I believe, in that about knowledge of the complete relationship or not. So–

Q. She would help with the gifts and notes and things like that–the passing?

A. Yes.

Q. Would you agree that these cover stories that you’ve just testified to, if they were told to the attorneys for Paula Jones, that they would be misleading to them and not be the whole story, the whole truth?

A. They would–yes, I guess misleading. They were literally true, but they would be misleading, so incomplete.

Q. As I understand your testimony, too, the cover stories were reiterated to you by the President that night on the telephone–

A. Correct.

Q. –and after he told you you would be a witness–or your name was on the witness list, I should say?

A. Correct.

Q. And did you understand that since your name was on the witness list that there would be a possibility that you could be subpoenaed to testify in the Paula Jones case?

A. I think I understood that I could be subpoenaed, and there was a possibility of testifying. I don’t know if I necessarily thought it was a subpoena to testify, but–

Q. Were you in fact subpoenaed to testify?

A. Yes.

Q. And that was what–

A. December 19th, 1997.

Q. December 19th.

Now, you have testified in the grand jury. I think your closing comments was that no one ever asked you to lie, but yet in that very conversation of December the 17th, 1997 when the President told you that you were on the witness list, he also suggested that you could sign an affidavit and use misleading cover stories. Isn’t that correct?

A. Uh–well, I–I guess in my mind, I separate necessarily signing affidavit and using misleading cover stories. So, does–

Q. Well, those two–

A. Those three events occurred, but they don’t–they weren’t linked for me.

Q. But they were in the same conversation, were they not?

A. Yes, they were.

Q. Did you understand in the context of the conversation that you would deny the–the President and your relationship to the Jones lawyers?

A. Do you mean from what was said to me or–

Q. In the context of that–in the context of that conversation, December the 17th–

A. I–I don’t–I didn’t–

Q. Okay. Let me ask it. Did you understand in the context of the telephone conversation with the President that early morning of December the 17th–did you understand that you would deny your relationship with the President to the Jones lawyers through use of these cover stories?

A. From what I learned in that–oh, through those cover stories, I don’t know, but from what I learned in that conversation, I thought to myself I knew I would deny the relationship.

Q. And you would deny the relationship to the Jones lawyers?

A. Yes, correct.

Q. Good.

A. If–if that’s what it came to.

Q. And in fact you did deny the relationship to the Jones lawyers in the affidavit that you signed under penalty of perjury; is that right?

A. I denied a sexual relationship.

Q. The President did not in that conversation on December the 17th of 1997 or any other conversation, for that matter, instruct you to tell the truth; is that correct?

A. That’s correct.

Q. And prior to being on the witness list, you–you both spoke–

A. Well, I guess any conversation in relation to the Paula Jones case. I can’t say that any conversation from

the–the entire relationship that he didn’t ever say, you know, `Are you mad? Tell me the truth.’ So–

Q. And prior to being on the witness list, you both spoke about denying this relationship if asked?

A. Yes. That was discussed.

Q. He would say something to the effect that–or you would say that–you–you would deny anything if it ever came up, and he would nod or say that’s good, something to that effect; is that right?

A. Yes, I believe I testified to that.

Q. Let me shift gears just a minute and ask you about–and I’m going to be delicate about this because I’m conscious of people here in the room and my–my own personal concerns–but I want to refer you to the first so-called salacious occasion, and I’m not going to get into the details. I’m not–

A. Can–can we–can you call it something else?

Q. Okay.

A. I mean, this is–this is my relationship–

Q. What would you like to call it?

A. –so, I mean, is–

Q. This is the–or this was–

A. It was my first encounter with the President, so I don’t really see it as my first salacious–that’s not what this was.

Q. Well, that’s kind of been the word that’s been picked up all around. So–

A. Right.

Q. –let’s stay on this first–

A. Encounter, maybe?

Q. Encounter, okay.

A. Okay.

Q. So we all know what we’re talking about. You had several of these encounters, perhaps 10 or 11 of these encounters; is that right?

A. Yes.

Q. Okay. Now, with regard to the first one on November the 15th, 1995, you have testified to a set of facts where the President actually touched you in certain areas–is that right–and that’s–that’s where I want to go. That’s as far as I want to go with that question.

MR. CACHERIS: If that’s as far as it goes, we will not object–


MR. CACHERIS: –and if it goes any further, we will object.



Q. You have testified to that?

A. Yes.

Q. And I have the excerpts out, and I don’t–but they’ve been adopted and affirmed as true. So I’m not going to get–get you looking at–have you read those excerpts.

A. I appreciate that.

Q. Now, in the–in later testimony before the grand jury, you were given a definition, and in fact it was the same definition that was used in the Paula Jones lawsuit, of `sexual relations.’ Do you recall the–

A. So I’ve read.

Q. Yes.

A. I was not shown that definition.

Q. But you were asked a question that incorporated that definition.

A. Not prior to this whole–not prior to the Independent Counsel getting involved.

Q. But–no–it was the Independent Counsels themselves who asked you this question.

A. Right. Oh, so you’re–you’re saying in the grand jury, I was shown a definition of–

Q. Right.

A. Yes, that’s correct.

Q. And you admitted in that answer to that question that the conduct that you were involved in, the encounter of November the 15th, 1995, fit within that definition of `sexual relations’?

A. The second encounter of that evening did.

Q. Right.

And were there other similar encounters later on with the President, not that day, but other occasions that would have likewise fit into that definition of `sexual relations’ in the Paula Jones case?

A. Yes. And–yes.

Q. There was more than one occasion where that occurred?

A. Correct.

Q. So, if the President testifies that he did not–he was not guilty of having a sexual relationship under the Paula Jones definition even, then that testimony is not truthful, is it?

MR. CACHERIS: Objection. She should not be called upon to testify what was in the mind of another person. She’s testifying to the facts, and she has given the facts.

MR. BRYANT: I would ask that she answer the question.


SENATOR LEAHY: The objection is noted for the record.

SENATOR DeWINE: The objection is noted. She may answer the question.

THE WITNESS: I–I really–

SENATOR LEAHY: If she can.

THE WITNESS: –don’t feel comfortable characterizing whether what he said was truthful or not truthful. I know I’ve testified to what I believe is true.


Q. Well, truth is not a wandering standard.

A. Well–

Q. I would hope not. But you have testified, as I’ve told you, that what you and he did together on November the 15th, 1995 fit that definition of the Paula Jones, and you’ve indicated that there were other occasions that likewise–

A. Yes, sir.

Q. –that that occurred.

But now the President has indicated as a part of his specific defense–he has filed an answer with this Senate denying that this occurred, that he did these actions.

A. I know. I’m not trying to be difficult, but there is a portion of that definition that says, you know, with intent, and I don’t feel comfortable characterizing what someone else’s intent was.

I can tell you that I–my memory of this relationship and what I remember happened fell within that definition.

If you want to–I don’t know if there’s another way to phrase that, but I’m just not comfortable commenting on someone else’s intent or state of mind or what they thought.

Q. Let’s move forward to December the 19th, 1997, at that point you made reference to earlier.

A. I’m sorry. Can you repeat the date again? I’m sorry.

Q. Yes. December the 19th, 1997.

A. Okay, sorry.

Q. At that point where you testified that you received a subpoena in the Paula Jones case, and that was, of course, on December the 19th, 1997.

Do you recall the specific time of day and where you were when you were served with the subpoena?

A. I was actually handed the subpoena at the Metro entrance of the Pentagon–at the Pentagon, and the time–I think it was around 4:30–4–I–I–if I’ve testified to something different, then, I accept whatever I testified to, closer to the date. Sometime in the late afternoon.

Q. Did they call you, and you had to come out of your office and go outside–

A. Correct.

Q. –and do that?

Okay. And what did you do after you accepted service of the subpoena?

A. I started crying.

Q. Did he just give it to you and walk away, or did he give you any kind of explanation?

A. I think I made a stink. I think I was trying to hope that he would convey to the Paula Jones attorneys that I didn’t know why they were doing this, and this is ridiculous, and he said something or another, there is a check here for witness fee. And I said I don’t want their stinking money, and so–

Q. What did you do after, after you got through the emotional part?

A. I went to a pay phone, and I called Mr. Jordan.

Q. Any reason you went to a pay phone, and why did you call Mr. Jordan? Two questions, please.

A. First is because my office in the Pentagon was probably a room this size and has–let’s see, one, two, three, four–four other people in it, and there wasn’t much privacy. So that I think that’s obvious why I wouldn’t want to discuss it there.

And the second question was why Mr. Jordan–

Q. Why did you call Mr. Jordan; yes.

A. Because I couldn’t call Mrs. Currie because it was–I hadn’t expected to be subpoenaed that soon. So she was grieving with her brother’s passing away, and I didn’t know who else to turn to. So–

Q. And what–what occurred with that conversation with Mr. Jordan?

A. Well, I remember that–that he couldn’t understand me because I was crying. So he kept saying: `I don’t understand what you’re saying. I don’t understand what you’re saying.’

And I just was crying and crying and crying. And so all I remember him saying was: `Oh, just come here at 5 o’clock.’

So I did.

Q. You went to see Mr. Jordan, and you were inside his office after 5 o’clock, and you did–is that correct?

A. Yes.

Q. Were–were you interrupted, in the office?

A. Yes. He received a phone call.

Q. And you testified that you didn’t know who that was that called?

A. Correct.

Q. Did you excuse yourself?

A. Yes.

Q. What–after you came back in, what–what occurred? Did he tell you who he had been talking to?

A. No.

Q. Okay. What happened next?

A. I know I’ve testified about this–

Q. Yes.

A. –so I stand by that testimony, and my recollection right now is when I came back in the room, I think shortly after he had placed a phone call to–to Mr. Carter’s office, and told me to come to his office at 10:30 Monday morning.

Q. Did you know who Mr. Carter was?

A. No.

Q. Did Mr. Jordan tell you who he was?

A. No–I don’t remember.

Q. Did you understand he was going to be your attorney?

A. Yes.

Q. Did you express any concerns about the–the subpoena?

A. I think that happened before the phone call came.

Q. Okay, but did you express concerns about the subpoena?

A. Yes, yes.

Q. And what were those concerns?

A. In general, I think I was just concerned about being dragged into this, and I was concerned because the subpoena had called for a hatpin, that I turn over a hatpin, and that was an alarm to me.

Q. How–in what sense was it–in what sense was it an alarm to you?

A. The hatpin being on the subpoena was evidence to me that someone had given that information to the Paula Jones people.

Q. What did Mr. Jordan say about the subpoena?

A. That it was standard.

Q. Did he have any–did he have any comment about the specificity of the hatpin?

A. No.

Q. And did you–

A. He just kept telling me to calm down.

Q. Did you raise that concern with Mr. Jordan?

A. I don’t remember if–if I’ve testified to it, then yes. If–I don’t remember right now.

Q. Did–would you have remembered then if he made any comment or answer about the hatpin?

A. I mean, I think I would.

Q. And you don’t remember?

A. I–I remember him saying something that it was–you know, calm down, it’s a standard subpoena or vanilla subpoena, something like that.

Q. Did you ask Mr. Jordan to call the President and advise him of the subpoena?

A. I think so, yes. I asked him to inform the President. I don’t know if it was through telephone or not.

Q. And you did that because the President had asked you to make sure you let Betty know that?

A. Well, sure. With Betty not being in the office, I couldn’t–there wasn’t anyone else that I could call to get through to him.

Q. Did Mr. Jordan say to you when he might see the President next?

A. I believe he said he would see him that evening at a holiday reception.

Q. Did Mr. Jordan during that meeting make an inquiry about the nature of the relationship between you and the President?

A. Yes, he did.

Q. What was that inquiry?

A. I don’t remember the exact wording of the questions, but there were two questions, and I think they were something like did you have sex with the President or did he–and if–or did he ask for it or some–something like that.

Q. Did you–what did you suspect at that point with these questions from Mr. Jordan in terms of did he know or not know about this?

A. Well, I wasn’t really sure. I mean, two things. I think there is–I know I’ve testified to this, that there was another component to all of this being Linda Tripp and her–what she might have led me to believe or led me to think and how that might have characterized how I was perceiving the situation.

I–I sort of felt that I didn’t know if he was asking me as what are you going to say because I–I don’t know these answer to these questions, or he was asking me as I know the answer to these questions and what are you going to say. So, either way, for me, the answer was no and no.

Q. And that’s just what I wanted to ask you–you did answer no to both of those, but–

A. Yes.

Q. –as you explained–you didn’t mention this directly, but you mentioned in some of your earlier testimony about it, that this was kind of a wink and–you thought this might be a wink-and-nod conversation, where he really knew what was going on, but–

A. Well, I think that’s what I just said.

Q. –he was testing you to see what you would say?

A. –that I wasn’t–I–that was one of the–that was one of the things that went through my mind. I mean, it was not–I think that’s what I just testified to, didn’t I?

Q. You didn’t use the term `wink-and-nod,’ though.

A. Oh.

Q. Did you have any conversation with Mr. Jordan during that meeting about the specifics of an affidavit?

A. No.

Q. Do you know if the subject of an affidavit even came up?

A. I don’t think so.

Q. What happened next? Is that when he made the call to Mr. Carter, after this conversation?

A. No. He made the call to Mr: I think–well, I think he made the call to Mr. Carter, uh, shortly after I came back into the room, but I could be wrong.

Q. And then the meeting concluded after that–after the appointment was set up with Mr. Carter, the meeting concluded?

A. Yes.

SENATOR DeWINE: Mr. Bryant, we’re going to need to break sometime in the next 5 minutes. Is this a good time, or do you want to complete–

MR. BRYANT: This is a good time.

SENATOR DeWINE: Okay. We’ll take a 5-minute break.

THE VIDEOGRAPHER: We’re going off the record at 12:04 p.m.


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