The following excerpts from the report sent to Congress by Whitewater independent counsel Kenneth W. Starr have been supplied by the Associated Press and edited for taste by the Deseret News:
. . . The Office of the Independent Counsel . . . hereby submits substantial and credible information that President William Jefferson Clinton committed acts that may constitute grounds for an impeachment.. . . The information reveals that President Clinton:
- lied under oath at a civil deposition while he was a defendant in a sexual harassment lawsuit;
- lied under oath to a grand jury;
- attempted to influence the testimony of a potential witness who had direct knowledge of facts that would reveal the falsity of his deposition testimony;
- attempted to obstruct justice by facilitating a witness's plan to refuse to comply with a subpoena;
- attempted to obstruct justice by encouraging a witness to file an affidavit that the president knew would be false, and then by making use of that false affidavit at his own deposition;
- lied to potential grand jury witnesses, knowing that they would repeat those lies before the grand jury; and
- engaged in a pattern of conduct that was inconsistent with his constitutional duty to faithfully execute the laws.
On Jan. 12, 1998, this office received information that Monica Lewinsky was attempting to influence the testimony of one of the witnesses in the (Paula Corbin) Jones litigation, and that Ms. Lewinsky herself was prepared to provide false information under oath in that lawsuit . . .
. . . Perjury and acts that obstruct justice by any citizen - whether in a criminal case, a grand jury investigation, a congressional hearing, a civil trial, or civil discovery - are profoundly serious matters. When such acts are committed by the president of the United States, we believe those acts "may constitute grounds for an impeachment."
The Scope of the Referral
1. Background of the Investigation. . . . In January 1998, Linda Tripp, a witness in three ongoing OIC investigations, came forward with allegations that: Monica Lewinsky was planning to commit perjury in Jones v. Clinton, and she had asked Ms. Tripp to do the same. Ms. Tripp also stated that: Vernon Jordan had counseled Ms. Lewinsky and helped her obtain legal representation in the Jones case, and at the same time, Mr. Jordan was helping Ms. Lewinsky obtain employment in the private sector.
OIC investigators and prosecutors recognized parallels between Mr. Jordan's relationship with Ms. Lewinsky and his earlier relationship with a pivotal Whitewater-Madison figure, Webster L. Hubbell. Prior to January 1998, the OIC possessed evidence that Vernon Jordan - along with other high-level associates of the president and first lady - helped Mr. Hubbell obtain lucrative consulting contracts while he was a potential witness and/or subject in the OIC's ongoing investigation . . .
Specifically, in the wake of his April 1994 resignation from the Justice Department, Mr. Hubbell launched a private consulting practice in Washington, D.C. In the startup process, Mr. Hubbell received substantial aid from important public and private figures.
On the day prior to Mr. Hubbell announcing his resignation, White House Chief of Staff Thomas "Mack" McLarty attended a meeting at the White House with the President, First Lady, and others, where Mr. Hubbell's resignation was a topic of discussion.
. . . Mr. Jordan introduced Mr. Hubbell to senior executives at New York-based MacAndrews & Forbes Holding Co. Mr. Jordan is a director of Revlon, Inc., a company controlled by MacAndrews & Forbes . . . MacAndrews & Forbes retained Mr. Hubbell at a rate of $25,000 per quarter. Vernon Jordan informed President Clinton that he was helping Mr. Hubbell.
By late 1997, this office was investigating whether a relationship existed between consulting payments to Mr. Hubbell and his lack of cooperation (specifically, his incomplete testimony) with the OIC's investigation. . . .
Against this background, the OIC considered the January 1998 allegations that: Ms. Lewinsky was prepared to lie in order to benefit the President, and Vernon Jordan was assisting Ms. Lewinsky in the Jones litigation, while simultaneously helping her apply for a private-sector job with, among others, Revlon, Inc. . . .
2. Current Status of the Investigation.
When the OIC's jurisdiction was expanded to cover the Lewinsky matter in January 1998, several matters remained under active investigation by this Office. Evidence was being gathered and evaluated on, among other things, events related to the Rose Law Firm's representation of Madison Guaranty Savings & Loan Association; events related to the firings in the White House Travel Office; and events related to the use of FBI files. Since the current phase of the investigation began, additional events arising from the Lewinsky matter have also come under scrutiny, including possible perjury and obstruction of justice related to former White House volunteer Kathleen Willey, and the possible misuse of the personnel records of Pentagon employee Linda Tripp. . . .
Several volumes accompany the Referral. . . .
END OF INTRODUCTION
Physical evidence conclusively establishes that the president and Ms. Lewinsky had a sexual relationship.
According to Ms. Lewinsky, the president touched her (in a manner) which means that his conduct met the Jones definition of sexual relations even under his theory. . . .
. . . The sexual encounters generally occurred in or near the private study off the Oval Office - most often in the windowless hallway outside the study. During many of their sexual encounters, the president stood leaning against the doorway of the bathroom across from the study, which, he told Ms. Lewinsky, eased his sore back.
According to Ms. Lewinsky, she performed (a sex act) on the president on nine occasions. On all nine of those occasions, the president fondled and kissed her.
Ms. Lewinsky grew emotionally attached to President Clinton. She testified: "I never expected to fall in love with the president. I was surprised that I did." . . . At times, she believed that he loved her too. . . . she recalled his saying that the two of them were "emotive and full of fire," and she made him feel young . . .
According to Ms. Lewinsky's friend Neysa Erbland, President Clinton once confided in Ms. Lewinsky that he was uncertain whether he would remain married after he left the White House. . . . Ms. Lewinsky thought, according to Ms. Erbland, that "maybe she will be his wife."
. . . Along with face-to-face meetings, according to Ms. Lewinsky, she spoke on the telephone with the president approximately 50 times. . . . On 10 to 15 occasions, she and the president had phone sex.
Ms. Lewinsky and the President exchanged numerous gifts. By her estimate, she gave him about 30 items, and he gave her about 18. . . .
1. Mutual Understanding
. . . In her handwritten statement to this Office, Ms. Lewinsky wrote that "the president told Ms. L to deny a relationship, if ever asked about it.
2. Cover Stories
. . . When visiting the president while she worked at the White House, she generally planned to tell anyone who asked . . . that she was delivering papers to the president.
. . . In his grand jury testimony, the president . . . stated that "I never asked Ms. Lewinsky to lie."
3. Steps to Avoid Being Seen or Heard
. . . Fear of discovery constrained their sexual encounters in several respects, according to Ms. Lewinsky. . . . On one occasion, according to Ms. Lewinsky, the president put his hand over her mouth during a sexual encounter to keep her quiet. Concerned that they might be interrupted abruptly, according to Ms. Lewinsky, the two of them never fully undressed. . . .
II. 1995: Initial Sexual Encounters
. . . During the November 1995 government shutdown, the president invited her to his private study, where they kissed. Later that evening, they had a more intimate sexual encounter. They had another sexual encounter two days later, and a third one on New Year's Eve. . . .
Meetings with the President
The month after her White House internship began, Ms. Lewinsky and the president began what she characterized as "intense flirting." . . . Ms. Lewinsky told her aunt that the president "seemed attracted to her or interested in her or something," and told a visiting friend that "she was attracted to (President Clinton), she had a big crush on him, and I think she told me she at some point had gotten his attention, that there was some mutual eye contact and recognition, mutual acknowledgment."
In the autumn of 1995, an impasse over the budget forced the federal government to shut down for one week, from Tuesday, Nov. 14, to Monday, Nov. 20. . . .
During the shutdown, Ms. Lewinsky worked in Chief of Staff (Leon) Panetta's West Wing office, where she answered phones and ran errands. The president came to Mr. Panetta's office frequently because of the shutdown, and he sometimes talked with Ms. Lewinsky. She characterized these encounters as "continued flirtation." . . .
C. November 15 Sexual Encounter
Ms. Lewinsky testified that Wednesday, Nov. 15, 1995 - the second day of the government shutdown - marked the beginning of her sexual relationship with the president. . . .
According to Ms. Lewinsky, she and the president made eye contact when he came to the West Wing to see Mr. Panetta and Deputy Chief of Staff Harold Ickes, then again later at an informal birthday party. . . . At one point, Ms. Lewinsky and the president talked alone in the chief of staff's office.
En route to the restroom at about 8 p.m., she passed George Stephanopoulos' office. The president was inside alone, and he beckoned her to enter. She told him that she had a crush on him. He laughed, then asked if she would like to see his private office. . . . they went through the president's private dining room toward the study off the Oval Office. Ms. Lewinsky testified: "We talked briefly and sort of acknowledged that there had been a chemistry that was there before and that we were both attracted to each other and then he asked me if he could kiss me." Ms. Lewinsky said yes. In the windowless hallway adjacent to the study, they kissed. Before returning to her desk, Ms. Lewinsky wrote down her name and telephone number for the president.
At about 10 p.m., in Ms. Lewinsky's recollection, she was alone in the chief of staff's office and the president approached. He invited her to rendezvous again in Mr. Stephanopoulos' office in a few minutes, and she agreed. . . . They met in Mr. Stephanopoulos' office and went again to the area of the private study. . . .
According to Ms. Lewinsky, she and the president kissed. "I believe he took a phone call . . . and so we moved from the hallway into the back office. While the president continued talking on the phone (Ms. Lewinsky understood that the caller was a member of Congress or a senator), she performed (a sexual act) on him. He finished his call, and, a moment later, told Ms. Lewinsky to stop. In her recollection: "I told him that I wanted . . . to complete that. And he said . . . that he needed to wait until he trusted me more. And then I think he made a joke . . . that he hadn't had that in a long time." . . .
According to Ms. Lewinsky, she and the president had a second sexual encounter two days later . . . on Friday, Nov. 17. . . .
Ms. Lewinsky testified:
Ms. Lewinsky and the president went into the area of the private study, according to Ms. Lewinsky. There, either in the hallway or the bathroom, she and the president kissed. After a few minutes, in Ms. Lewinsky's recollection, she told him that she needed to get back to her desk. The president suggested that she bring him some slices of pizza. . . .
Ms. Lewinsky testified that she and the president had a sexual encounter during this visit. . . . At some point, Ms. Currie approached the door leading to the hallway, which was ajar, and said that the president had a telephone call. Ms. Lewinsky recalled that the caller was a member of Congress with a nickname. While the president was on the telephone, according to Ms. Lewinsky . . . she performed (a sex act on him again).
During this visit, according to Ms. Lewinsky, the president told her that he liked her smile and her energy. He also said: "I'm usually around on weekends, no one else is around, and you can come and see me." . . .
Testifying before the grand jury on Aug. 17, 1998, the president said that his first "real conversation" with Ms. Lewinsky occurred during the November 1995 furlough. He testified: "One night she brought me some pizza. We had some remarks."
E. December 31 Sexual Encounter
According to Ms. Lewinsky, she and the president had their third sexual encounter on New Year's Eve. . . .
Sometime between noon and 1 p.m., in Ms. Lewinsky's recollection, she was in the pantry area of the president's private dining room talking with a White House steward . . . Just then, the president came down the hallway from the Oval Office and saw Ms. Lewinsky. . . .
According to Ms. Lewinsky, they moved to the study. "And then . . . we were kissing and (she performed a sex act).
F. President's Account of 1995 Relationship
As noted, the president testified before the grand jury that on Nov. 17, 1995, Ms. Lewinsky delivered pizza and exchanged "some remarks" with him, but he never indicated that anything sexual occurred then or at any other point in 1995. Testifying under oath before the grand jury, the president said that he engaged in "conduct that was wrong" involving "inappropriate intimate contact" with Ms. Lewinsky "on certain occasions in early 1996 and once in early 1997." By implicitly denying any sexual contact in 1995, the president indicated that he and Ms. Lewinsky had no sexual involvement while she was an intern. In the president's testimony, his relationship with Ms. Lewinsky "began as a friendship," then later "came to include this conduct."
III. January-March 1996: Continued Sexual Encounters
President Clinton and Ms. Lewinsky had additional sexual encounters near the Oval Office in 1996. After their sixth sexual encounter, the president and Ms. Lewinsky had their first lengthy conversation. On President's Day, Feb. 19, the president terminated their sexual relationship, then revived it on March 31.
A. January 7 Sexual Encounter
According to Ms. Lewinsky, she and the president had another sexual encounter on Sunday, Jan. 7, 1996. . . .
According to Ms. Lewinsky, the president telephoned her early that afternoon. It was the first time he had called her at home. . . .
"We made an arrangement that . . . he would have the door to his office open, and I would pass by the office with some papers and then . . . he would sort of stop me and invite me in. So, that was exactly what happened. . . . and so we spoke for about 10 minutes in the (Oval) office. We sat on the sofas. Then we went into the back study and we were intimate in the bathroom."
Ms. Lewinsky testified that during this bathroom encounter, she and the president kissed . . . The president "was talking about (a sex act) on me," according to Ms. Lewinsky. But she stopped him . . . and he did not. Ms. Lewinsky did perform (a sex act) on him.
January 21 Sexual Encounter
. . . They continued talking as they went to the hallway by the study. Then, with Ms. Lewinsky in midsentence, "he just started kissing me.". . . According to Ms. Lewinsky, the president . . .exposed himself," and she performed (a sex act) . . .
On Sunday, February 4, according to Ms. Lewinsky, she and the president had their sixth sexual encounter and their first lengthy and personal conversation. . . . After their sexual encounter, the president and Ms. Lewinsky sat and talked in the Oval Office for about 45 minutes. . . .
After the break-up on February 19, 1996, according to Ms. Lewinsky, "there continued to sort of be this flirtation. . . . "
On Sunday, March 31, 1996, according to Ms. Lewinsky, she and the president resumed their sexual contact. . . .
. . . Deeming her frequent visits to the Oval Office area a "nuisance," one Secret Service officer complained to Evelyn Lieberman, the deputy chief of staff for operations. . . .
Ms. Lieberman testified that, because Ms. Lewinsky was so persistent in her efforts to be near the president, "I decided to get rid of her." . . .
Ms. Lewinsky was devastated. She felt that she was being transferred simply because of her relationship with the president. And she feared that with the loss of her White House job, "I was never going to see the president again. I mean, my relationship with him would be over."
Conversations with the president about her transfer
1. Easter Telephone Conversations and Sexual Encounter
On Easter Sunday, April 7, 1996, Ms. Lewinsky told the president of her dismissal and they had a sexual encounter. . . .
At the White House, according to Ms. Lewinsky, she told Secret Service Officer Muskett that she needed to deliver papers to the president. . . .
According to Ms. Lewinsky, the president . . . indicated that she could have any job she wanted after the election.
. . . The president and Ms. Lewinsky had a sexual encounter in the hallway, according to Ms. Lewinsky.
. . . During this encounter . . . the president indicated that Ms. Lewinsky should perform (a sex act) while he talked on the phone, and she obliged. The telephone conversation was about politics, and Ms. Lewinsky thought the caller might be Dick Morris. White House records confirm that the president had one telephone call during Ms. Lewinsky's visit: from "Mr. Richard Morris.". . .
A second interruption occurred a few minutes later . . .
"Harold Ickes has a very distinct voice . . . "
o minutes after Ms. Lewinsky left the White House, the president called the office of the person who had decided to transfer Ms. Lewinsky, Evelyn Lieberman.
. . . After Ms. Lewinsky began her Pentagon job on April 16, 1996, she had no further physical contact with the president for the remainder of the year. She and the president spoke by phone (and had phone sex). . . .
D. Public Encounters
. . . Ms. Lewinsky attended the president's 50th birthday party at Radio City Music Hall. . . . According to Ms. Lewinsky, when the president reached past her at the rope line to shake hands with another guest, she reached out and touched him . . . in a "playful" fashion. . . .
VI. Early 1997: Resumption of Sexual Encounters
In 1997, President Clinton and Ms. Lewinsky had further private meetings, which now were arranged by Betty Currie, the president's secretary. . . . On March 29, they had what proved to be their final sexual encounter.
D. February 28 Sexual Encounter
. . . Wearing a navy blue dress from the Gap, Ms. Lewinsky attended the radio address at the president's invitation (relayed by Ms. Currie). . . .
In the study, according to Ms. Lewinsky, the president "started to say something to me and I was pestering him to kiss me, because . . . it had been a long time since we had been alone." The president told her to wait a moment, as he had presents for her. . . .
Ms. Lewinsky testified that after the president gave her the gifts, they had a sexual encounter. . . .
In his grand jury testimony, the president . . . indicated that he and Ms. Lewinsky had had sexual contact on the day of the radio address. He testified:
"I was sick after it was over and I, I was pleased at that time that it had been nearly a year since any inappropriate contact had occurred with Ms. Lewinsky. I promised myself it wasn't going to happen again. The facts are complicated about what did happen and how it happened. But, nonetheless, I'm responsible for it." . . .
E. March 29 Sexual Encounter
According to Ms. Lewinsky, she had what proved to be her final sexual encounter with the president on Saturday, March 29, 1997. . . .
He told her that he suspected that a foreign embassy (he did not specify which one) was tapping his telephones, and he proposed cover stories. . . . If anyone ever asked about their phone sex, she should say that they knew their calls were being monitored all along, and the phone sex was just a put-on.
In his grand jury testimony, the president implicitly denied this encounter. He acknowledged "inappropriate intimate contact" with Ms. Lewinsky "on certain occasions in early 1996 and once in early 1997." . . .
B. May 24: Break-up
. . . According to Ms. Lewinsky, the president explained that they had to end their intimate relationship. Earlier in his marriage, he told her, he had had hundreds of affairs; but since turning 40, he had made a concerted effort to be faithful. He said he was attracted to Ms. Lewinsky, considered her a great person, and hoped they would remain friends. He pointed out that he could do a great deal for her. . . .
. . . Ms. Lewinsky also drafted a note to the president pleading for a brief meeting. . . . Referring to her inability to get in touch with him, she wrote: "Please do not do this to me. I feel disposable, used and insignificant."
. . . "Very frustrated" over her inability to get in touch with the president to discuss her job situation, Ms. Lewinsky wrote him a peevish letter. . . . Ms. Lewinsky also obliquely threatened to disclose their relationship. If she was not going to return to work at the White House, she wrote, then she would "need to explain to my parents exactly why that wasn't happening."
. . . On Friday, July 4, 1997, Ms. Lewinsky had what she characterized as a "very emotional" visit with the president.
. . . The president was "the most affectionate with me he'd ever been," Ms. Lewinsky testified. He stroked her arm, toyed with her hair, kissed her on the neck, praised her intellect and beauty. . . .
He remarked . . . that he wished he had more time for me. And so I said, well, maybe you will have more time in three years. . . . And he said, well, I don't know, I might be alone in three years. And then I said something about . . . us sort of being together. . . . And he . . . jokingly said, well, what are we going to do when I'm 75 . . . And . . . I told him that we'd deal with that." . . .
Ms. Lewinsky testified that "I left that day sort of emotionally stunned," for "I just knew he was in love with me."
. . . Ms. Lewinsky testified that she brought birthday gifts for the president (his birthday is Aug. 19):
. . . "I asked him . . . if we could share a birthday kiss in honor of our birthdays, because mine had been just a few weeks before. So, he said that that was OK and we could kind of bend the rules that day." . . .
. . . Ms. Lewinsky continued trying to discuss her situation with the president. On Friday, Sept. 12, 1997, she arrived at the White House without an appointment, called Ms. Currie, and had a long wait at the gate. When Ms. Currie came to meet her, Ms. Lewinsky was crying. Ms. Currie . . . had gotten (the president's) authorization to ask John Podesta, the deputy chief of staff, to help Ms. Lewinsky return to work at the White House.
L. News of Job Search Failure
On Oct. 6, 1997, according to Ms. Lewinsky, she was told that she would never work at the White House again. Ms. Tripp conveyed the news, which she indicated had come from a friend on the White House staff.
. . . For Ms. Lewinsky, who had previously considered moving to New York, this call was the "straw that broke the camel's back." She was enraged. . . .
IX. October-November 1997:
United Nations' Job Offer
Having learned that she would not be able to return to the White House, Ms. Lewinsky sought the president's help in finding a job in New York City. The president offered to place her at the United Nations. After initial enthusiasm, Ms. Lewinsky cooled on the idea of working at the U.N., and she prodded the president to get her a job in the private sector.
B. October 11 Meeting
. . . Ms. Lewinsky asked the president whether Vernon Jordan, a well-known Washington attorney who she knew was a close friend of the president and had many business contacts, might help her find a job. According to Ms. Lewinsky, the president was receptive to the idea. . . .
D. The President Creates Options
At some point around this time in the fall of 1997, Ms. Currie asked John Podesta . . . to help Ms. Lewinsky find a job in New York. Mr. Podesta testified that . . . he approached then-U.N. Ambassador William Richardson . . . and asked the Ambassador to consider a former White House intern for a position at the U.N. . . .
E. The U.N. Interview and Job Offer
On Friday morning, Oct. 31, Ambassador Richardson and two of his assistants, Mona Sutphen and Rebecca Cooper, interviewed Ms. Lewinsky at the Watergate.
. . . According to his assistant, Ambassador Richardson made the decision to hire Ms. Lewinsky.
. . . When the president was asked in the Jones deposition whether he knew that Ms. Lewinsky had received the offer of a job at the U.N., he testified: "I know that she interviewed for one. I don't know if she was offered one or not."
. . . By courier, she sent the president another note:
"I asked you three weeks ago to please be sensitive to what I am going through right now and to keep in contact with me, and yet I'm still left writing notes in vain. . . . "
She added: " . . . I need you right now not as president, but as a man. PLEASE be my friend."
. . . On the morning of Saturday, Dec. 6, Ms. Lewinsky went to the White House to deliver the letter and gifts to the president . . .
. . . Ms. Lewinsky testified that in the early-morning hours of Dec. 17, at roughly 2:00 or 2:30 a.m., she received a call from the president. . . .
The president told Ms. Lewinsky to contact Ms. Currie in the event she were subpoenaed. He also reviewed one of their established cover stories. He told Ms. Lewinsky that she "should say she visited the (White House) to see Ms. Currie and, on occasion when working at the (White House), she brought him letters when no one else was around." The president's advice "was . . . instantly familiar to (Ms. Lewinsky)." She testified that the president's use of this "misleading" story amounted to a continuation of their pre-existing pattern. . . .
In his grand jury appearance, the president . . . did not remember such a call. The president was also asked whether . . . he instructed her to say that she was coming to bring letters. The president answered: "I might well have said that."
. . . according to Mr. Jordan, Ms. Lewinsky asked him about the future of the Clintons' marriage. Because Ms. Lewinsky seemed "mesmerized" by President Clinton, he "asked her directly had there been any sexual relationship between (her) and the president." . . . Ms. Lewinsky said she had not had a sexual relationship with the president.
Ms. Lewinsky testified, however, that at this time she assumed that Mr. Jordan knew "with a wink and a nod that (she) was having a relationship with the president." She therefore interpreted Mr. Jordan's questions as "What are you going to say?" . . .
That evening, Mr. Jordan visited the president at the White House. . . .
Mr. Jordan asked . . . "Mr. President, have you had sexual relations with Monica Lewinsky?" The president told Mr. Jordan, "No, never." . . .
That morning, Ms. Lewinsky met with the president in the Oval Office. . . . she, the president and Ms. Currie played with Buddy, the president's dog, and chatted. Then, the president took her to the study and gave her several Christmas presents: a marble bear's head, a Rockettes blanket, a Black Dog stuffed animal, a small box of chocolates, a pair of joke sunglasses and a pin with a New York skyline on it.
Ms. Lewinsky testified that, during this visit, she and the president had a "passionate" and "physically intimate" kiss. . . .
In the afternoon of Dec. 28, a few hours after Ms. Lewinsky's White House visit, Ms. Currie drove to Ms. Lewinsky's Watergate apartment and collected a box containing the president's gifts. Ms. Currie then took the box home and hid it under her bed. . . .
According to Ms. Currie, Ms. Lewinsky said that she was uncomfortable retaining the gifts herself because "people were asking questions" about them. Ms. Currie said she drove to Ms. Lewinsky's residence after work, collected the box, brought it home, and put it under her bed. Written on the top of the box were the words "Please do not throw away!!!"
. . . the president testified that he never asked Ms. Currie to collect a box of gifts from Ms. Lewinsky. . . .
Ms. Lewinsky testified that in late December 1997 she realized that she needed to "come up with some sort of strategy as to what to do if Linda Tripp divulged what she knew. . . .
She told Mr. Jordan: "I used to trust Ms. Tripp, but I didn't trust her anymore." Ms. Lewinsky said that Ms. Tripp might have seen some notes in her apartment. Mr. Jordan asked: "Notes from the president to you?" Ms. Lewinsky responded: "No, notes from me to the president." According to Ms. Lewinsky, Mr. Jordan said: "Go home and make sure they're not there."
When Ms. Lewinsky returned home to her apartment that day, she discarded approximately 50 draft notes to the president. . . .
On Jan. 8, she interviewed for a job in New York City. After the interview went poorly, Mr. Jordan placed a phone call to the company's chairman on her behalf, and Ms. Lewinsky was given a second interview. The following week, after Ms. Lewinsky told Ms. Currie that she would need a reference from the White House, the President asked Chief of Staff Erskine Bowles to arrange one. . . .
She and Mr. Jordan discussed the draft by telephone. Ms. Lewinsky testified that having Mr. Jordan review the affidavit was like getting it "blessed" by the president. . . .
E. January 8: The Perelman Call
. . . Jan. 8, 1998, Ms. Lewinsky interviewed in New York with Jaymie Durnan, senior vice president and special assistant to the chairman at MacAndrews & Forbes Holdings Inc. Mr. Durnan . . . told her that he would pass on her resume to Revlon, an MFH company. . . .
F. January 9: "Mission Accomplished"
On . . . Jan. 9, 1998, Ms. Lewinsky interviewed with Allyn Seidman, senior vice president of MFH, and . . . Ms. Seidman called her back that day and "informally offered her a position, and she informally accepted."
. . . Mr. Jordan testified that he also told the president directly that, "Monica Lewinsky's going to work for Revlon,' and his response was, `Thank you very much.' "
G. January 12: Pre-Trial Hearing in Jones Case
On Jan. 12, 1998, . . . Ms. Jones' witness list named . . . Ms. Lewinsky. . . .
J. January 13-14: Lewinsky-Tripp Conversation and Talking Points
. . . On Jan. 14, Ms. Lewinsky gave Ms. Tripp a three-page document regarding "points to make in Ms. Tripp's affidavit." Ms. Lewinsky testified that she wrote the document herself. . . .
XIV. January 17, 1998-Present: The Deposition and Afterward
The president was asked a number of questions about Ms. Lewinsky during his Jan. 17, 1998, deposition in the Jones case. In sworn testimony, the president denied having a sexual affair or sexual relations with her. . . .
B. The President Meets with Ms. Currie
Soon after the deposition, the president called Ms. Currie and asked her to come to the White House the next day. . . .
At approximately 5:00 p.m. on Sunday, Jan. 18, 1998, Ms. Currie met with the president. . . . He told Ms. Currie that, during his deposition the previous day, he had been asked questions about Monica Lewinsky. Ms. Currie testified: "I think he said, `There are several things you may want to know.' " He proceeded to make a series of statements . . . :
"You were always there when she was there, right?"
"We were never really alone."
"Monica (Lewinsky) came on to me, and I never touched her, right?"
"You can see and hear everything, right?" . . .
Ms. Currie testified that she did, in fact, agree with the president . . . Before the grand jury, however, Ms. Currie acknowledged the possibility that Ms. Lewinsky could have visited the president when she was not at the White House. . . .
The president also made the following statement during their Jan. 18, 1998, meeting, according to Ms. Currie: "(Monica Lewinsky) wanted to have sex with me, but I told her I couldn't do that."
When the president was questioned about this meeting with Ms. Currie in the grand jury, he testified that he recalled the conversation, but he denied that he was "trying to get Betty Currie to say something that was untruthful." . ..
In his grand jury testimony, the president acknowledged that, "in fairness," Ms. Currie "may have felt some ambivalence about how to react" to his statements. . . .
Finally, when asked about his statement to Ms. Currie that "Monica came on to me and I never touched her," the president refused to answer.
D. January 20-22: Lewinsky Story Breaks
After the publication of an article alleging a sexual relationship with Ms. Lewin-sky, President Clinton conferred with his attorneys and issued a number of denials to his aides and to the American public.
1. "Clinton Accused"
On Wednesday, Jan. 21, 1998, the Washington Post published a story titled "Clinton Accused of Urging Aide to Lie; Starr Probes Whether President Told Woman to Deny Alleged Affair to Jones's Lawyers." The White House learned the essentials of the Post story on the night of Jan. 20, 1998.
President Clinton placed a number of phone calls that night and the following morning. From 12:08 a.m. to 12:39 a.m., he spoke with his personal attorney, Robert Bennett. . . . Immediately after his call to Mr. Bennett, President Clinton called Deputy White House Counsel Bruce Lindsey . . . the president called Ms. Currie at home. . . . Ms. Currie testified that the president was concerned that her name was mentioned in the Post article. . . .
A few hours later, at approximately 6:30 a.m., the president called Mr. Jordan in New York City to tell him, according to Mr. Jordan, that the Post story was untrue.
Responding to the Post story that day, the White House issued a statement, personally approved by the president, declaring that he was "outraged by these allegations" and that "he has never had an improper relationship with this woman." . . .
2. Denials to Aides
According to Mr. Lindsey, the remainder of the morning was spent in a series of meetings about the Lewinsky matter. . . . At these meetings, President Clinton denied the allegations to several of his top aides.
The president met with Chief of Staff Erskine Bowles, along with his two deputies, John Podesta and Sylvia Matthews. According to Mr. Bowles, the president told them, "I want you to know I did not have sexual relationships with this woman, Monica Lewinsky. I did not ask anybody to lie. And when the facts come out, you'll understand." The president made a similar denial that morning to Harold Ickes, his former deputy chief of staff. The president also discussed the matter with Ms. Currie for a second time. . . .
. . . The president was asked during his grand jury appearance whether he recalled denying a sexual relationship with Ms. Lewinsky to his senior aides and advisers, including Mr. Bowles, Mr. Podesta, Mr. Blumenthal, Mr. Ickes and Mr. Jordan. The president did not recall specific details but did remember the following:
"I met with certain people, and a few of them I said I didn't have sex with Monica Lewinsky, or I didn't have an affair with her or something like that. I had a very careful thing I said, and I tried not to say anything else . . . I remember that I issued a number of denials to people that I thought needed to hear them, but I tried to be careful and to be accurate." . . .
BEGINNING OF GROUNDS SECTION
. . . The Office of Independent Counsel hereby submits substantial and credible information . . . supporting the fol-lowing eleven possible grounds for impeachment:
1. President Clinton lied under oath in his civil case when he denied a sexual affair, a sexual relationship or sexual relations with Monica Lewinsky.
2. President Clinton lied under oath to the grand jury about his sexual relationship with Ms. Lewinsky.
3. In his civil deposition, to support his false statement about the sexual relationship, President Clinton also lied under oath about being alone with Ms. Lewinsky and about the many gifts exchanged between Ms. Lewinsky and him.
4. President Clinton lied under oath in his civil deposition about his discussions with Ms. Lewinsky concerning her involvement in the Jones case.
5. During the Jones case, the president obstructed justice and had an understanding with Ms. Lewinsky to jointly conceal the truth about their relationship. . . .
6. During the Jones case, the president obstructed justice and had an understanding with Ms. Lewinsky to jointly conceal the truth of their relationship from the judicial process. . . .
7. 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 harmful to him were she to tell the truth in the Jones case.
8. President Clinton lied under oath in his civil deposition about his discussions with Vernon Jordan concerning Ms. Lewin-sky's involvement in the Jones case.
9. The president improperly tampered with a potential witness by attempting to corruptly influence the testimony of his personal secretary, Betty Currie, in the days after his civil deposition.
10. President Clinton endeavored to obstruct justice during the grand jury investigation by refusing to testify for seven months and lying to senior White House aides with knowledge that they would relay the president's false statements to the grand jury. . . .
11. President Clinton abused his constitutional authority by lying to the public and the Congress in January 1998 about his relationship with Ms. Lewinsky; promising at that time to cooperate fully with the grand jury investigation; later refusing six invitations to testify voluntarily to the grand jury; invoking Executive Privilege; lying to the grand jury in August 1998; and lying again to the public and Congress on Aug. 17, 1998 - all as part of an effort to hinder, impede, and deflect possible inquiry by the Congress of the United States. . . .
The detailed testimony of Ms. Lewinsky . . . establish that Ms. Lewinsky and the president engaged in substantial sexual activity between Nov. 15, 1995, and Dec. 28, 1997.
The president, however, testified under oath in the civil case - both in his deposition and in a written answer to an in-ter-rogatory - that he did not have a "sexual relationship" or a "sexual affair" or "sexual relations" with Ms. Lewinsky. In addition, he denied engaging in activity covered by a more specific definition of "sexual relations" used at the deposition.
In his civil case, the president made five different false statements related to the sexual relationship. For four of the five statements, the president asserts a semantic defense: The president argues that the terms used in the Jones deposition to cover sexual activity did not cover the sexual activity in which he engaged with Ms. Lewinsky. For his other false statements, the president's response is factual - namely, he disputes Ms. Lewinsky's account that he ever touched her breasts or genitalia during sexual activity. . . .
. . . In sum, based on all of the evidence and considering the president's various responses, there is substantial and credible information that the president lied under oath in his civil deposition and his interrogatory answer in denying a sexual relationship, a sexual affair, or sexual relations with Ms. Lewinsky. . . .
. . . During the investigation, the OIC (Office of the Independent Counsel) gathered a substantial body of information that established that the president and Monica Lewinsky did, in fact, have a sexual relationship.
. . . The president was largely aware of that extensive body of evidence before he testified to the grand jury on Aug. 17, 1998. . . .
As a result, the president had three apparent choices . . . First, the president could adhere to his previous testimony in his civil case, as well as in his public statements, and deny any sexual relationship. But he knew . . . that the contrary evidence was overwhelming. . . . Second, the president could admit a sexual relationship, which would cause him also to simultaneously admit that he lied under oath in the Jones case. Third, the president could invoke his Fifth Amendment privilege against compelled self-incrimination.
Confronting those three options, the president attempted to avoid them altogether. The president admitted to an "inappropriate intimate" relationship, but he maintained that he had not committed perjury in the Jones case when he denied having a sexual relationship, sexual affair or sexual relations with her. . . .
During his grand jury testimony, the president was asked whether Monica Lewin-sky performed (a sex act) on him and, if so, whether he had committed perjury in his civil deposition. . . . The president refused to say whether he had (a specific sex act). Instead, the president said that the undefined terms "sexual affair," "sexual relationship" and "sexual relations" necessarily require sexual intercourse, that he had not engaged in intercourse with Ms. Lewinsky and that he therefore had not committed perjury . . .