Grounds
  
There is Substantial and Credible Information that President Clinton Committed Acts that May Constitute Grounds for an Impeachment
Introduction
Pursuant to Section 595(c) of Title 28, the Office of Independent Counsel (OIC) hereby submits substantial and credible information that President Clinton obstructed justice during the Jones v. Clinton sexual harassment lawsuit by lying under oath and concealing evidence of his relationship with a young White House intern and federal employee, Monica Lewinsky. After a federal criminal investigation of the President's actions began in January 1998, the President lied under oath to the grand jury and obstructed justice during the grand jury investigation. There also is substantial and credible information that the President's actions with respect to Monica Lewinsky constitute an abuse of authority inconsistent with the President's constitutional duty to faithfully execute the laws.
I. There is substantial and credible information that President Clinton lied under oath as a defendant in Jones v. Clinton regarding his sexual relationship with Monica Lewinsky.
On May 6, 1994, former Arkansas state employee Paula Corbin Jones filed a federal civil rights lawsuit against President Clinton claiming that he had sexually harassed her on May 8, 1991, by requesting her to perform oral sex on him in a suite at the Excelsior Hotel in Little Rock.
II. There is substantial and credible information that President Clinton lied under oath to the grand jury about his sexual relationship with Monica Lewinsky.
In January 1998, upon application of the Attorney General, the Special Division of the United States Court of Appeals for the District of Columbia Circuit expanded the OIC's jurisdiction to investigate, among other matters, whether Monica Lewinsky and the President obstructed justice in the Jones case. The criminal investigation was triggered by specific and credible evidence that Monica Lewinsky denied her relationship with President Clinton in a false affidavit in the Jones case, that she had spoken to the President and Vernon Jordan about her testimony, and that she may have been influenced to lie by the President through the assistance of Vernon Jordan and others in finding her a job. After the President, in his January 17 deposition, denied any sexual relationship with Monica Lewinsky and otherwise minimized his overall relationship with her, the President's testimony became an additional subject of the OIC investigation.
III. There is substantial and credible information that President Clinton lied under oath during his civil deposition when he stated that he could not recall being alone with Monica Lewinsky and when he minimized the number of gifts they had exchanged.
The President testified to the grand jury and stated to the Nation on August 17 that his testimony in his civil deposition had been "legally accurate." Even apart from his answers about the sexual relationship, the President's deposition testimony was inaccurate on several other points.
IV. There is substantial and credible information that the President lied under oath during his civil deposition concerning conversations he had with Monica Lewinsky about her involvement in the Jones case.
President Clinton was asked during his civil deposition whether he had discussed with Ms. Lewinsky the possibility of her testifying in the Jones case. He also was asked whether he knew that she had been subpoenaed at the time he last had spoken to her.
V. There is substantial and credible information that President Clinton endeavored to obstruct justice by engaging in a pattern of activity to conceal evidence regarding his relationship with Monica Lewinsky from the judicial process in the Jones case. The pattern included:
From the beginning, President Clinton and Monica Lewinsky hoped and expected that their relationship would remain secret. They took active steps, when necessary, to conceal the relationship. The President testified that "I hoped that this relationship would never become public."(213)
VI. There is substantial and credible information that
Based on their conversations and their past practice, both the President and Ms. Lewinsky understood that they would lie under oath in the Jones case about their sexual relationship, as part of a scheme to obstruct justice in the Jones case.
VII. There is substantial and credible information that President Clinton endeavored to obstruct justice by helping Ms. Lewinsky obtain a job in New York at a time when she would have been a witness against him were she to tell the truth during the Jones case.
The President had an incentive to keep Ms. Lewinsky from jeopardizing the secrecy of the relationship. That incentive grew once the Supreme Court unanimously decided in May 1997 that the case and discovery process were to go forward.
VIII. There is substantial and credible information that the President lied under oath in describing his conversations with Vernon Jordan about Ms. Lewinsky.
President Clinton was asked during his civil deposition whether he had talked to Mr. Jordan about Ms. Lewinsky's involvement in the Jones case. The President stated that he knew Mr. Jordan had talked to Ms. Lewinsky about her move to New York, but stated that he did not recall whether Mr. Jordan had talked to Ms. Lewinsky about her involvement in the Jones case. The testimony was false. A lie under oath about these conversations was necessary to avoid inquiry into whether Ms. Lewinsky's job and her testimony were improperly related.
IX. There is substantial and credible information that President Clinton endeavored to obstruct justice by attempting to influence the testimony of Betty Currie.
In a meeting with Betty Currie on the day after his deposition and in a separate conversation a few days later, President Clinton made statements to her that he knew were false. The contents of the statements and the context in which they were made indicate that President Clinton was attempting to influence the testimony that Ms. Currie might have been required to give in the Jones case or in a grand jury investigation.
X. There is substantial and credible information that President Clinton endeavored to obstruct justice during the federal grand jury investigation. While refusing to testify for seven months, he simultaneously lied to potential grand jury witnesses knowing that they would relay the falsehoods to the grand jury.
The President's grand jury testimony followed seven months of investigation in which he had refused six invitations to testify before the grand jury. During this period, there was no indication that the President would admit any sexual relationship with Ms. Lewinsky. To the contrary, the President vehemently denied the allegations.
XI. There is substantial and credible information that President Clinton's actions since January 17, 1998, regarding his relationship with Monica Lewinsky have been inconsistent with the President's constitutional duty to faithfully execute the laws.
Before, during, and after his January 17, 1998, civil deposition, the President attempted to conceal the truth about his relationship with Ms. Lewinsky from the judicial process in the Jones case. Furthermore, the President has since lied under oath to the grand jury and facilitated the provision of false information to the grand jury by others.
Introduction >