| Introduction |
| As required by Section 595(c) of Title 28 of the United States Code, the Office of the Independent Counsel ("OIC" or "Office") hereby submits substantial and credible information that President William Jefferson Clinton committed acts that may constitute grounds for an impeachment. |
| In May 1994, Paula Corbin Jones filed a lawsuit against William Jefferson Clinton in the United States District Court for the Eastern District of Arkansas. Ms. Jones alleged that while he was the Governor of Arkansas, President Clinton sexually harassed her during an incident in a Little Rock hotel room. President Clinton denied the allegations. He also challenged the ability of a private litigant to pursue a lawsuit against a sitting President. In May 1997, the Supreme Court unanimously rejected the President's legal argument. The Court concluded that Ms. Jones, "[l]ike every other citizen who properly invokes [the District Court's] jurisdiction . . . has a right to an orderly disposition of her claims," and that therefore Ms. Jones was entitled to pursue her claims while the President was in office. A few months later, the pretrial discovery process began. |
| On January 12, 1998, this Office received information that Monica Lewinsky was attempting to influence the testimony of one of the witnesses in the Jones litigation, and that Ms. Lewinsky herself was prepared to provide false information under oath in that lawsuit. The OIC was also informed that Ms. Lewinsky had spoken to the President and the President's close friend Vernon Jordan about being subpoenaed to testify in the Jones suit, and that Vernon Jordan and others were helping her find a job. The allegations with respect to Mr. Jordan and the job search were similar to ones already under review in the ongoing Whitewater investigation. |
| It is not the role of this Office to determine whether the President's actions warrant impeachment by the House and removal by the Senate; those judgments are, of course, constitutionally entrusted to the legislative branch. This Office is authorized, rather, to conduct criminal investigations and to seek criminal prosecutions for matters within its jurisdiction. In carrying out its investigation, however, this Office also has a statutory duty to disclose to Congress information that "may constitute grounds for an impeachment," a task that inevitably requires judgment about the seriousness of the acts revealed by the evidence. |
| 1. Background of the Investigation. The link between the OIC's jurisdiction -- as it existed at the end of 1997 -- and the matters set forth in this Referral is complex but direct. In January 1998, Linda Tripp, a witness in three ongoing OIC investigations, came forward with allegations that: (i) Monica Lewinsky was planning to commit perjury in Jones v. Clinton, and (ii) she had asked Ms. Tripp to do the same. Ms. Tripp also stated that: (i) Vernon Jordan had counseled Ms. Lewinsky and helped her obtain legal representation in the Jones case, and (ii) at the same time, Mr. Jordan was helping Ms. Lewinsky obtain employment in the private sector. |
| The Referral consists of several parts. Part One is a Narrative. It begins with an overview of the information relevant to this investigation, then sets forth that information in chronological sequence. A large part of the Narrative is devoted to a description of the President's relationship with Monica Lewinsky. The nature of the relationship was the subject of many of the President's false statements, and his desire to keep the relationship secret provides a motive for many of his actions that apparently were designed to obstruct justice. |