999. Clinton 1/17/98 Depo. at 1 (849-DC-00000352 et seq.).

1000. Clinton 1/17/98 Depo. at 1-2.

1001. Clinton 1/17/98 Depo. at 10.

1002. Clinton 1/17/98 Depo. at 22-23; 849-DC-00000586 (Clinton Depo. Ex. 1).

1003. Clinton 1/17/98 Depo. at 54.

1004. Clinton 1/17/98 Depo. at 54. In addition, as previously indicated, Mr. Jordan believes he informed President Clinton on January 7 that Ms. Lewinsky had signed an affidavit denying that there had been a sexual relationship. Jordan 5/5/98 GJ at 223-25.

1005. Clinton 1/17/98 Depo. at 53-56.

1006. Clinton 1/17/98 Depo. at 50-51, 58-59.

1007. Clinton 1/17/98 Depo. at 52-53, 59.

1008. Clinton 1/17/98 Depo. at 59.

1009. Clinton 1/17/98 Depo. at 62-64.

1010. Clinton 1/17/98 Depo. at 75-77.

1011. Clinton 1/17/98 Depo. at 75-76.

1012. Clinton 1/17/98 Depo. at 75.

1013. Clinton 1/17/98 Depo. at 68.

1014. Clinton 1/17/98 Depo. at 68-71.

1015. Clinton 1/17/98 Depo. at 72, 79-83.

1016. Clinton 1/17/98 Depo. at 78.

1017. Clinton 1/17/98 Depo. at 212-13.

1018. Podesta 6/16/98 GJ at 62.

1019. Lindsey 2/19/98 GJ at 12-13. Mr. Lindsey refused to reveal the content of these conversations with the President, citing the presidential communication, deliberative process, and attorney-client privileges, both officially and privately, as well as the attorney work product doctrine. Id. at 13.

1020. Lindsey 2/19/98 GJ at 14-15.

1021. See Telephone Table 46, Call 4; Currie 1/27/98 GJ at 65-66; Currie 5/7/98 GJ at 79-85; Currie 7/22/98 GJ at 154. See also Currie 1/24/98 Int. at 5-6 ("CURRIE advised that sometime late that evening, she received a telephone call from CLINTON. CURRIE advised that CLINTON said he and CURRIE needed to talk. CURRIE advised it was too late to do anything that evening, so she and CLINTON agreed to meet at the White House at 5 p.m. the following day, Sunday, January 18, 1998."). Presidential call logs reflect that the President attempted to call Ms. Currie at 7:02 p.m. on January 17, 1998, and that he spoke to her for two minutes at 7:13 p.m. 1248-DC-00000307.

1022. Currie 5/7/98 GJ at 91. Also that evening, the President called Mr. Jordan, who testified that they did not discuss the afternoon deposition. See Telephone Table 46, Call 2; Jordan 5/28/98 GJ at 94-95.

1023. Currie 1/27/98 GJ at 70.

1024. Currie 1/27/98 GJ at 67.

1025. Currie 1/27/98 GJ at 76.

1026. Currie 1/27/98 GJ at 70, 76; 7/22/98 GJ at 6, 22. Presidential call logs reflect that the President called Ms. Currie before their meeting and spoke to her from 1:11 p.m. to 1:14 p.m. on January 18. 1248-DC-00000313.

1027. Currie 1/27/98 GJ at 70.

1028. Currie 1/27/98 GJ at 73 ("[M]y impression was that he was just making statements.").

1029. Currie 1/24/98 Int. at 6-7. The President repeated these statements to Ms. Currie a few days later. See infra.

1030. Currie 1/27/98 GJ at 71-74; 7/22/98 GJ at 6-7, 10-11, 79. See also Clinton 8/17/98 GJ at 55-57. According to Ms. Currie, the way the President phrased the inquiries made them sound like both questions and statements at the same time. Currie 1/24/98 Int. at 6.

1031. Currie 1/27/98 GJ at 74-75. Ms. Currie's testimony that the President wanted her to agree with his statements shifted somewhat between her first grand jury appearance and her last, which occurred five months later. On January 27, 1998, nine days after her conversation with the President, Ms. Currie testified that she understood from the President's questions that he wanted her to agree with him. Currie 1/27/98 GJ at 72-76. By July 22, 1998, however, Ms. Currie claimed that although the President stated "right?" at the end of the statements, Ms. Currie understood that she could agree or disagree with them. Currie 7/22/98 GJ at 23. Ms. Currie indicated during her first grand jury appearance that her memory about the events was "getting worse by the minute." Currie 1/27/98 GJ at 71. Later, Ms. Currie acknowledged that "closer to the event my recollection would be better." Currie 7/22/98 GJ at 182-183.

1032. Currie 1/27/98 GJ at 71, 75.

1033. Currie 7/22/98 GJ at 65-66. Indeed, she testified that, at some point after January 18, she heard that Ms. Lewinsky visited the Oval Office on Saturdays, one of her days off. Currie 7/22/98 GJ at 65-66.

1034. Currie 1/27/98 GJ at 32-33; 36-38.

1035. Currie 7/22/98 GJ at 12, 15-6; Currie 1/27/98 GJ at 76.

1036. Currie 7/22/98 GJ at 14. The President, apparently, had a similar understanding of "alone." Before the grand jury, the President explained that "when I said, we were never alone, right . . . I meant that she [Ms. Currie] was always in the Oval Office complex, in that complex, while Monica was there." Clinton 8/17/98 GJ at 132.

Elsewhere in her testimony, Ms. Currie appeared to have a different understanding of "alone." She testified that, on one occasion, because others observed Ms. Lewinsky in the Oval Office complex, Ms. Currie accompanied Ms. Lewinsky into the Oval Office, where the President was working. Ms. Currie explained that she waited in the dining room while Ms. Lewinsky and the President met in the study so "[t]hey would not be alone." Currie 7/22/98 GJ at 130. See also Clinton 8/17/98 GJ at 56 ("I asked her specifically . . . to remain in the dining room, Betty, while I met with Monica in my study."). Ms. Currie testified that she did not want people who had observed Ms. Lewinsky enter the Oval Office to think that she and the President were "alone." Currie 7/22/98 GJ at 132.

1037. Currie 7/22/98 GJ at 79. Ms. Currie testified: "The way the question was phrased to me at the time, I answered, 'Right.' It seemed to me that was the correct answer for me to give . . . the '[c]ome on to me,' I considered that more of a statement as opposed to a question." Id. at 80.

1038. Currie 1/27/98 GJ at 75.

1039. Currie 1/27/98 GJ at 83.

1040. Currie 1/27/98 GJ at 72-73; 7/22/98 GJ at 7, 10-11. Ms. Currie testified that the President made this statement in a way that did not invite her agreement. Rather, "I would call it a statement, sir." Currie 1/27/98 GJ at 73.

1041. Clinton 8/17/98 GJ at 57.

1042. Clinton 8/17/98 GJ at 132.

1043. Clinton 8/17/98 GJ at 55.

1044. Clinton 8/17/98 GJ at 141.

1045. Clinton 8/17/98 GJ at 55.

1046. Clinton 8/17/98 GJ at 135-36 ("As far as I know, she is unaware of what happened on the, on the occasions when I saw her in 1996 when something improper happened. And she was unaware of the one time that I recall in 1997 when something happened.").

1047. Clinton 8/17/98 GJ at 38.

1048. Clinton 8/17/98 GJ at 57-58, 132.

1049. Clinton 8/17/98 GJ at 133.

1050. Clinton 8/17/98 GJ at 133.

1051. Clinton 8/17/98 GJ at 135.

1052. Clinton 8/17/98 GJ at 139. The President referred to a statement he delivered in the beginning of his grand jury appearance: "[B]ecause of privacy considerations affecting my family, myself, and others, and in an effort to preserve the dignity of the office I hold, this is all I will say about the specifics of these particular matters." Clinton 8/17/98 GJ at 10.

1053. At 5:12 p.m., Ms. Currie paged Ms. Lewinsky, leaving the message: "Please call Kay at home." At 6:22 p.m., Ms. Currie paged Ms. Lewinsky: "Please call Kay at home." At 7:06 p.m., Ms. Currie paged Ms. Lewinsky: "Please call Kay at home." At 8:28 p.m., Ms. Currie paged Ms. Lewinsky: "Call Kay." 831-DC-00000008 (Ms. Lewinsky's pager records) (Ms. Lewinsky's pager recorded calls in Pacific time). See also Currie 5/7/98 GJ at 96-97; 7/22/98 GJ at 156, 158.

1054. Currie 5/7/98 GJ at 99-100.

1055. Telephone Calls, Table 47, Call 11. See also Currie 7/22/98 GJ at 161-62.

1056. See Telephone Calls, Table 48. At 7:02 a.m. she paged Ms. Lewinsky, leaving the message: "Please call Kay at home at 8:00 this morning." At 8:08 a.m., Ms. Currie paged Ms. Lewinsky again. After calling Ms. Lewinsky's home number at 8:29 a.m., Ms. Currie paged Ms. Lewinsky again at 8:33 a.m. Four minutes later, Ms. Currie paged yet again, leaving the message: "Please call Kay at home. It's a social call. Thank you." (Ms. Currie testified that these calls were, in fact, not of a social nature. Currie 7/22/98 GJ at 161). Receiving no response, Ms. Currie paged Ms. Lewinsky again at 8:41 a.m. She then placed a one-minute call to the President. Currie 5/7/98 GJ at 104-05; 7/22/98 GJ at 160-62.

1057. Currie 7/22/98 GJ at 162-63. This time, Ms. Currie left a more urgent message: "Please call Kay re: family emergency." 831-DC-00000009 (Ms. Lewinsky's pager records). See Telephone Calls, Table 48, Call 7.

1058. Currie 7/22/98 GJ at 157-59; 164-66.

1059. Jordan 6/9/98 GJ at 17. See also Telephone Calls, Table 48 (831-DC-00000009) (Ms. Lewinsky's pager records).

1060. Jordan 6/9/98 GJ at 38-39.

1061. Carter 6/18/98 GJ at 146.

1062. Jordan 6/9/98 GJ at 54-55.

1063. Schmidt, Baker, and Locy, "Clinton Accused of Urging Aide To Lie," Wash. Post, Jan. 21, 1998, at A1.

1064. Podesta 6/23/98 GJ at 12.

1065. See Telephone Calls, Table 50.

1066. Mr. Bennett was apparently referring to Ms. Lewinsky's affidavit.

1067. Clinton Accused at A1.

1068. Mr. Lindsey, on instructions from the President, see Lindsey 8/28/98 GJ at 23, has invoked the presidential communication privilege, the deliberative process privilege, the governmental attorney-client privilege, and President Clinton's personal attorney-client privilege with regard to conversations with the President and has thus refused to disclose what the President said to him on January 21. Lindsey 2/19/98 GJ at 42. Mr. Lindsey has testified, however, that based on the President's public statements and statements made to others in Lindsey's presence, the President misled him about the nature of his relationship with Ms. Lewinsky. Lindsey 8/28/98 GJ at 93-96, 101.

1069. Currie 5/7/98 GJ at 112-14.

1070. Lindsey 8/28/98 GJ at 90. Mr. Lindsey, citing privileges, refused to testify about the substance of this conversation.

1071. 1034-DC-00000111 (Mr. Jordan's calendar). See also Jordan 3/5/98 GJ at 79 (St. Regis Hotel), 160-61 (New York), 179 (the President's phone call); Jordan 6/9/98 GJ at 76.

1072. See Telephone Calls, Table 50, Call 6. See also Lindsey 8/28/98 GJ at 90. Mr. Lindsey asserted privileges over this conversation as well.

1073. White House Press Conference (Mike McCurry), Jan. 21, 1998.

1074. Lindsey 8/28/98 GJ at 11-12.

1075. Bowles 4/2/98 GJ at 84. See also Podesta 6/16/98 GJ at 85-86.

1076. Ickes 6/10/98 GJ at 73.

1077. Ms. Currie could not recall whether the President called her into the Oval Office to discuss Ms. Lewinsky on Tuesday, January 20, or Wednesday, January 21. Currie 1/27/98 GJ at 80-81.

1078. Currie 1/27/98 GJ at 80-81.

1079. Currie 1/27/98 GJ at 81.

1080. Currie 1/24/98 Int. at 8. The President did not specifically recall this second conversation with Ms. Currie, but did not dispute that it took place: "I do not remember how many times I talked to Betty Currie or when. I don't. I can't possibly remember that. I do remember when I first heard about this story breaking, trying to ascertain what the facts were, trying to ascertain what Betty's perception was." Clinton 8/17/98 GJ at 141-42.

1081. Blumenthal 2/26/98 GJ at 19.

1082. Blumenthal 6/4/98 GJ at 48-49. When later asked how he interpreted the President's statement, "I haven't done anything wrong," Mr. Blumenthal stated, "My understanding was that the accusations against him which appeared in the press that day were false, that he had not done anything wrong. . . . He had not had a sexual relationship with her, and had not sought to obstruct justice or suborn perjury." Blumenthal 6/25/98 GJ at 26.

1083. Blumenthal 6/4/98 GJ at 49. The President said, "I've gone down that road before, I've caused pain for a lot of people and I'm not going to do that again." Blumenthal 6/4/98 GJ at 49. Mr. Blumenthal "understood [this statement] to mean that he had had an adulterous relationship in the past, which is something he made very plain to the American people in his "60 Minutes" interview with the First Lady, which is how he introduced himself to the public . . . . And it's been very well known." Blumenthal 6/25/98 GJ at 32.

1084. Blumenthal 6/4/98 GJ at 49.

1085. Blumenthal 6/4/98 GJ at 50.

1086. Blumenthal 6/4/98 GJ at 49-50; Blumenthal 6/25/98 GJ at 15, 51.

1087. Podesta 6/16/98 GJ at 92.

1088. Podesta 6/16/98 GJ at 92. The President made another misleading statement about his relationship with Ms. Lewinsky to Mr. Podesta a few weeks later. According to Mr. Podesta, "[h]e said to me that after she [Ms. Lewinsky] left [the White House], that when she had come by, she came by to see Betty, and that he -- when she was there either Betty was with them -- either that she was with Betty when he saw her or that he saw her in the Oval Office with the door open and Betty was around -- and Betty was out at her desk." Podesta 6/16/98 GJ at 88.

1089. Clinton 8/17/98 GJ at 101-09.

1090. Clinton 8/17/98/ GJ at 101, 106. The President was asked specifically whether he denied telling Mr. Podesta that he did not have any kind of sex whatsoever, including oral sex, with Ms. Lewinsky. The President responded: "I'm not saying that anybody who had a contrary memory is wrong. I do not remember." Clinton 8/17/98 GJ at 105.

1091. In claiming that this statement was true, the President was apparently relying on the same tense-based distinction he made during the Jones deposition. See Clinton 8/17/98 GJ at 59-61 ("It depends on what the meaning of the word 'is' is. If the -- if he -- if 'is' means is and never has been, that is not -- that is one thing. If it means there is none, that was a completely true statement. . . . Now, if someone had asked me on that day, are you having any kind of sexual relations with Ms. Lewinsky, that is, asked me a question in the present tense, I would have said no. And it would have been completely true.")

1092. Clinton 8/17/98 GJ at 107.

1093. Clinton 8/17/98 GJ at 107.

1094. Broadcast on "All Things Considered" on National Public Radio, 5:07 p.m., Wednesday, January 21, 1998.

1095. "The News Hour with Jim Lehrer," PBS, interview with President Bill Clinton by Jim Lehrer, Wednesday, January 21, 1998. As evidenced by his grand jury testimony, the President is attentive to matters of verb tense. Clinton 8/17/98 GJ at 59.

1096. Televised Remarks by President Clinton at Photo Opportunity at the White House with Palestinian Authority Chairman Yasser Arafat, January 22, 1998, 10:22 a.m.

1097. Roll Call, Inc., January 22, 1998; transcript of press conference.

1098. "All Things Considered," January 21, 1998.

1099. "The News Hour," January 21, 1998.

1100. Televised Remarks By President Clinton at Photo Opportunity at the White House with Palestinian Authority Chairman Yasser Arafat, January 22, 1998, 10:22 a.m.

1101. Roll Call, Inc., January 22, 1998. President Clinton was extended invitations to appear before the grand jury and give his testimony on: January 28, 1998; February 4, 1998; February 9, 1998; February 21, 1998; March 2, 1998; and March 13, 1998. He declined all of these invitations. On July 16, 1998, the grand jury issued the President a subpoena. The President promptly moved for a postponement of two weeks in which to respond. At a hearing on the President's motion, Chief Judge Norma Holloway Johnson stated, "What we need to do is to move forward and move forward expeditiously. . . . [A]pparently the grand jury has determined that [they] need to hear from the [President]." In re Grand Jury Proceedings, Misc. No. 98-267, July 28, 1998, at pp. 27-28. Before Judge Johnson ruled, the President's attorneys negotiated the terms of the President's appearance.

1102. Morris 8/18/98 GJ at 6, 10, 12. Mr. Morris was questioned after the President's grand jury appearance on August 17, 1998; accordingly, the OIC never had an opportunity to question the President about this conversation.

1103. Morris 8/18/98 GJ at 14.

1104. Mr. Morris testified that he interpreted the "something" to be sexual in nature. Morris 8/18/98 GJ at 94.

1105. Morris 8/18/98 GJ at 14.

1106. Morris 8/18/98 GJ at 15.

1107. Morris 8/18/98 GJ at 15-16.

1108. Morris 8/18/98 GJ at 17.

1109. Morris 8/18/98 GJ at 28.

1110. Morris 8/18/98 GJ at 30.

1111. Morris 8/18/98 GJ at 34. Mr. Morris believed that Ms. Lewinsky's credibility was in question based on a claim by a USA Today reporter that there was an occasion when the President and Mr. Morris spoke on the telephone while they each were involved in a sexual encounter. The President was reportedly "having sex" with Ms. Lewinsky while Mr. Morris was allegedly involved with a prostitute at the Jefferson Hotel. Morris 8/18/98 GJ at 32, 34.

1112. Morris 8/18/98 GJ at 35.

1113. Thomason 8/11/98 GJ at 6.

1114. Although Mr. Thomason originally offered to stay with the President for a "couple of days," he stayed at the White House Residence for 34 days. Thomason 8/11/98 GJ at 6, 10. Mr. Thomason testified that while "not particularly an expert in media matters . . . my wife and I seem to have a feel of what the rest of America is thinking. . . ." Thomason 8/11/98 GJ at 24.

1115. Thomason 8/11/98 GJ at 15-16. Mr. Thomason said he "went on the assumption that [the allegations] were not true," but he never asked the President because he talked to his attorney, Robert Bennett (also the President's personal attorney), who advised him "to make sure you don't ask questions that will get you subpoenaed." Id. at 22, 27. Mr. Thomason also testified he did not ask the President whether the denial was true because "I wanted it to be true and I felt it not to be true." Id. at 32-33.

1116. Thomason 8/11/98 GJ at 15.

1117. Thomason 8/11/98 GJ at 27.

1118. Schmidt and Baker, "Ex-Intern Rejected Immunity Offer in Probe," Wash. Post, Jan. 24, 1998, at A1.

1119. Schmidt and Baker, "Ex-Intern Rejected Immunity Offer," at A1.

1120. Larry King Weekend, Jan. 24, 1998, Transcript No. 98012400V42.

1121. In fact, the President did draw a distinction between "is" and "was." See Clinton 8/17/98 GJ at 59.

1122. Larry King Weekend, Jan. 24, 1998, Transcript No. 98012400V42.

1123. Televised Remarks by President Clinton at the White House Education News Conference, Monday, January 26, 1998, 10:00 a.m. See Chi. Tribune, Jan. 27, 1998, at 1 ("A defiant President Clinton wagged his finger at the cameras and thumped the lectern Monday as he insisted he did not have sex with a young White House intern or ask her to deny it under oath.").