708. 849-DC-00000128.

709. 849-DC-00000121-37

710. See infra at Section XI.F. See also Lewinsky 8/6/98 GJ at 121-26.

711. Clinton 8/17/98 GJ at 84-85. In his Jones deposition, the President acknowledged that he may have heard of the witness list before he actually saw it. Clinton 1/17/98 Depo. at 70.

712. 833-DC-00003207 (Travel Voucher DOD).

713. Lewinsky 8/6/98 GJ at 107; Lewinsky 7/31/98 Int. at 1.

714. V006-DC-00000521 (guest list); VOO6-DC-00001859 (photograph of Ms. Lewinsky and the President at the reception).

715. Lewinsky 7/31/98 Int. at 1.

716. Lewinsky 7/31/98 Int. at 2; MSL-55-DC-0177. The wording of the letter resembles, in part, a message on a cassette found during the consensual search of Ms. Lewinsky's apartment: "Hi. [Sniffling, crying.] I was so sad seeing you last night. I was so angry with you that once again you had rejected me. . . . I wanted to feel the warmth of you and the smell of you and the touch of you. And it made me sad. And I -- you confuse me so much. I mean I [sigh]. I thought I -- I thought I fell in love with this person that -- that I really felt was such a good -- such a good person, such a good heart, someone who's had a life with a lot of experiences." See Document Supplement B, Tab 36.

717. MSL-55-DC-0177 (punctuation corrected).

718. MSL-55-DC-0177 (punctuation corrected).

719. MSL-DC-55-0177 (punctuation corrected).

720. MSL-55-DC-0177 (punctuation corrected).

721. Lewinsky 8/6/98 GJ at 108-09; Lewinsky 8/6/98 GJ at 27-29 & Exh. ML-7. The cigar holder, the tie, the mug, and the book have been produced to the OIC. V002-PHOTOS-0011 (holder, tie, and book); V002-PHOTOS-0005 (mug).

722. Lewinsky 8/6/98 GJ at 111-12.

723. Bryan Hall 5/21 98 Int. at 2; Bryan Hall 7/23/98 GJ at 10-11, 15-16; Niedzwiecki 7/30/98 GJ at 12-13; Lewinsky 8/6/98 GJ at 109-11.

724. Lewinsky 8/6/98 GJ at 110-11; Niedzwiecki 7/30/98 GJ at 13-14.

725. Byran Hall 7/23/98 GJ at 12-13; Niedzwiecki 7/30/98 GJ at 13, 15. Officer Hall recognized Ms. Lewinsky from a previous occasion, when she was greeted by, and delivered something to, Ms. Currie. Byran Hall 7/23/98 GJ at 6-10.

726. Tyler 7/28/98 GJ at 40; Chinery 7/23/98 GJ at 8.

727. Lewinsky 8/6/98 GJ at 111-12. Ms. Mondale recalled visiting the President that morning. Mondale 7/16/98 Int. at 1. See also 843-DC-00000004 (Epass records reflect that Ms. Mondale entered the White House at 9:33 a.m.).

728. Lewinsky 8/6/98 GJ at 111-12. See also Currie 7/22/98 GJ at 88-89. Ms. Lewinsky suspected that Ms. Mondale was romantically involved with the President. Lewinsky 8/6/98 GJ at 111-12.

729. Lewinsky 8/6/98 GJ at 112-13. Ms. Currie testified that Ms. Lewinsky angrily told her: "'You had lied to me, that the President is in the office, and he's meeting with someone.' And I said, 'Yeah, you're right.' She was not too happy about it, and words were exchanged." Currie 1/27/98 GJ at 37.

730. Keith Williams 7/23/98 GJ at 24. See also Chinery 7/23/98 GJ at 10; Purdie 7/23/98 GJ at 13.

731. Keith Williams 7/23/98 GJ at 12. Some testimony indicates that the President directly told Sergeant Williams about the Northwest Gate incident. Three officers testified that Sergeant Williams told them that the President had spoken to him and had indicated that he wanted the officer responsible for the disclosure of information fired. Niedzwiecki 7/30/98 GJ at 29, 37; Byran Hall 7/23/98 GJ at 25-26; Porter 8/13/98 GJ at 16-18. For example, Officer Niedzwiecki testified that soon after the incident, Sergeant Williams came to the Northwest Gate and said, "[t]he President wants somebody's job." Niedzwiecki 7/30/98 GJ at 29. Sergeant Williams testified, however, that the President did not speak to him directly about the incident. Keith Williams 7/23/98 GJ at 31-32. According to Sergeant Williams, when he met alone with Ms. Currie, he noticed that the door leading to the Oval Office was at first shut but then was cracked open. Keith Williams 7/23/98 GJ at 22, 30. Sergeant Williams testified that he heard what he assumed to be a male voice coming from within the Oval Office saying "[t]his person needs to be fired." Keith Williams 7/30/98 GJ at 10-11. Sergeant Williams told the officers at the gate that he spoke to the President only to get their attention. Keith Williams 7/30/98 GJ at 16-17. However, Sergeant Williams also told the supervisor who replaced him that afternoon that the President had spoken to him directly about the incident at the Northwest Gate. Deardoff 9/3/98 Depo. at 8-9.

732. Purdie 7/23/98 GJ at 13, 18-19. Captain Purdie testified that he thought that the remedy of firing was "out of proportion to the incident . . . [e]specially without doing an investigation or a fact-finding mission." Purdie 7/23/98 GJ at 19.

733. Lewinsky 8/6/98 GJ at 113.

734. Lewinsky 8/6/98 GJ at 113-14.

735. Lewinsky 8/6/98 GJ at 114.

736. Lewinsky 8/6/98 GJ at 114.

737. 827-DC-00000018. Secret Service logs reflect that the President was in the area of the Oval Office throughout this period. V006-DC-00002158.

738. Lewinsky 8/6/98 GJ at 115-16. Specifically, Ms. Lewinsky told the President "that I was supposed to get in touch with Mr. Jordan the previous week and that things didn't work out and that nothing had really happened yet." Id.

739. Lewinsky 8/6/98 GJ at 116. The President also told Ms. Lewinsky that he had already gotten a Christmas present for her and that he would give that to her during another visit. Lewinsky 8/1/98 Int. at 2.

740. Lewinsky 8/6/98 GJ at 115.

741. 1037-DC-00000011 (spelling corrected).

742. Keith Williams 7/23/98 GJ at 25. Ms. Currie confirmed that she told an officer, "Okay. Fine. This never happened." However, she testified that she said this so that no officer would get in trouble. Currie 7/22/98 GJ at 91-92.

When Ms. Currie left work that day, she stopped by a Secret Service post and told an officer that "she spoke to the President . . . and . . . they decided that the incident never happened, they weren't going to pursue . . . discipline actions against them, that they just wanted it to go away." Chinery 7/23/98 GJ at 22-23. Later that week, Ms. Currie told that officer to inform one of his supervisors "that everything was okay and just to keep quiet about it." Keith Williams 7/23/98 GJ at 27-28.

743. Purdie 7/23/98 GJ at 32; Purdie 7/17/98 GJ at 3.

744. Purdie 7/17/98 GJ at 6; Bryan Hall 7/23/98 GJ at 31-32; Chinery 7/23/98 GJ at 21.

745. Porter 8/13/98 GJ at 12.

746. Niedzwiecki 7/30/98 GJ at 30-31.

747. Niedzwiecki 7/30/98 GJ at 31, 44. See also Niedzwiecki 8/5/98 GJ at 4-6 (text of Niedzwiecki notes).

748. Purdie 7/23/98 GJ at 35.

749. Purdie 7/23/98 GJ at 34-36. While Deputy Chief O'Malley testified that Captain Purdie notified him of the incident, Deputy Chief O'Malley did not recall Captain Purdie discussing with him, at any time, a decision not to generate an incident report or a memorandum. Charles O'Malley 9/8/98 Depo. at 44, 47-48.

750. O'Malley 9/8/98 Depo. at 22, 40-41.

751. Clinton 8/17/98 GJ at 84-85, 87. Ms. Mondale stated that she met with the President alone in the Oval Office study that day. Mondale 7/16/98 Int. at 1.

752. Clinton 8/17/98 GJ at 86.

753. Clinton 8/17/98 GJ at 88-89.

754. Clinton 8/17/98 GJ at 89-90.

755. Clinton 8/17/98 GJ at 91-92.

756. Lewinsky 8/6/98 GJ at 151-52; Lewinsky 2/1/98 Statement at 6. On December 23, Paula Jones's attorneys issued a subpoena to the Secret Service.

757. Lindsey 3/12/98 GJ at 64-66; Lindsey 2/19/98 GJ at 9-10. WAVES records reflect that Robert Bennett entered the White House at 4:39 p.m. on Saturday, December 6. 1407-DC-00000005.

758. Lindsey 3/12/98 GJ at 65.

759. 964-DC-00000862 (Presidential mail notes)  .

760. Lindsey 3/12/98 GJ at 63-64. Mr. Lindsey refused to answer questions about his December 6 meeting with the President, claiming attorney-client privilege and Executive (presidential communications) Privilege. Id. at 66. The U.S. District Court for the District of Columbia rejected Mr. Lindsey's claim of privilege, In re Grand Jury Proceedings, 5 F. Supp.2d 21 (D.D.C. 1998), and the Court of Appeals denied Mr. Lindsey's appeal, In re Lindsey, 148 F.3d 1100 (D.C. Cir. 1998). A petition for Supreme Court review is pending.

761. WAVES records reflect that Mr. Jordan entered the White House at 5:21 p.m. on Sunday, December 7. 1178-DC-00000026.

762. Jordan 5/5/98 GJ at 83. He later testified that the conversation was "[a]bsolutely not" about Ms. Lewinsky. Jordan 5/5/98 GJ at 116.

763. V004-DC-00000171 (Akin, Gump visitor records) (recording visit of "Malensky"). Ms. Lewinsky recalled arranging the meeting on December 8 or 9. Lewinsky 8/1/98 Int. at 3. See also 833-DC-00017886 (reflecting Ms. Lewinsky's call to Mr. Jordan on December 8).

On December 8, Ms. Lewinsky sent Mr. Jordan a hat, a box of chocolates, and a note gently reminding him of his promise to help her find a job. Lewinsky 7/31/98 Int. at 15. She also sent the President a note and some peach candies. Lewinsky 8/1/98 Int. at 2; Lewinsky 8/1/98 Int. at 2; 837-DC-00000017; 837-DC-00000020 (courier receipts).

764. Jordan 3/3/98 GJ at 41-42.

765. V004-DC-00000148 (Akin, Gump phone records). See also Jordan 3/3/98 GJ at 54, 62-63, 70.

Mr. Halperin testified that Mr. Jordan had told him that Ms. Lewinsky "was a bright young woman who was energetic and enthusiastic and . . . encouraged me to meet with her." Halperin 4/23/98 GJ at 13. Similarly, Ms. Fairbairn stated that Mr. Jordan had told her that he "would like to send [her] a resume of a talented young lady and see if she matches up with any company openings." Fairbairn 1/29/98 Int. at 1. Mr. Georgescu, however, stated that Mr. Jordan "did not engage in a 'sales pitch' about [Ms.] Lewinsky." Georgescu 3/25/98 Int. at 2.

766. Lewinsky 8/6/98 GJ at 121. Ms. Lewinsky left the meeting with Mr. Jordan on December 8 with the impression that Mr. Jordan was going to get her a job. Lewinsky 8/1/98 Int. at 4.

767. Lewinsky 8/6/98 GJ at 119.

768. Lewinsky 8/6/98 GJ at 120.

769. Lewinsky 8/6/98 GJ at 120.

770. Lewinsky 8/6/98 GJ at 120. In her handwritten proffer, Ms. Lewinsky gave a very similar account of her second meeting with Mr. Jordan: "Ms. L. met again with Mr. Jordan in the beginning of December '97, at which time he provided Ms. L. with a list of three people to contact and suggested language to use in her letters to them. At some point, Mr. Jordan remarked something about Ms. L. being a friend of the Pres. of the United States. Ms. L. responded that she never really saw him as "the President"; she spoke to him like a normal man and even got angry with him like a normal man. Mr. Jordan asked what Ms. L. got angry about. Ms. L. replied that the Pres. doesn't see or call her enough. Mr. Jordan said Ms. L. should take her frustrations out on him -- not the President." Lewinsky 2/1/98 Statement at 3-4.

771. Lewinsky 8/6/98 GJ at 120.

772. Jordan 3/3/98 GJ at 154.

773. Jordan 3/3/98 GJ at 64-65.

774. Jordan 3/3/98 GJ at 65.

775. Jordan 3/3/98 GJ at 65.

776. 1414-DC-00001534 - 46 (Plaintiff's Second Request for Production of Documents and Things).

777. Lewinsky 8/6/98 GJ at 121-26.

778. Lewinsky 8/6/98 GJ at 126. Ms. Lewinsky testified that the call came as a surprise because Mrs. Clinton was in town. Id. at 122. See also 968-DC-00003479 (Mrs. Clinton's schedule reflects that she was in Washington, D.C. on December 17).

779. Lewinsky 8/6/98 GJ at 122-23.

780. Lewinsky 8/6/98 GJ at 123.

781. Lewinsky 2/1/98 Statement at 4.

782. Lewinsky 8/6/98 GJ at 123.

783. Lewinsky 2/1/98 Statement at 4.

784. Lewinsky 8/6/98 GJ at 123-24. Ms. Lewinsky testified that, "on [s]everal occasions," they had resolved to use this cover story to conceal their relationship. Id.

785. Lewinsky 8/6/98 GJ at 232.

786. Lewinsky 8/6/98 GJ at 126.

787. Lewinsky 8/6/98 GJ at 126.

788. Clinton 8/17/98 GJ at 116.

789. Clinton 8/17/98 GJ at 119. The President himself gave this explanation of Ms. Lewinsky's visits to the Oval Office at his Jones deposition. Clinton 1/17/98 Depo. at 50-51.

790. Clinton 8/17/98 GJ at 119-20.

791. Clinton 8/17/98 GJ at 119-20.

792. Clinton 8/17/98 GJ at 120.

793. Halperin 1/26/98 Int. at 2.

794. Berk 3/31/98 Int. at 1-2. In her proffer, Ms. Lewinsky stated that, during the week following her December 11 meeting with Mr. Jordan, she "had two interviews in NY in response to her letters." Lewinsky 2/1/98 Statement at 4.

795. Schick 1/29/98 Int. at 2.