133. Lewinsky 8/6/98 GJ at 8; Lewinsky 8/20/98 GJ at 8; Bobowick 2/12/98 Int. at 1; Currie 1/27/98 GJ at 23-24; Panetta 1/28/98 GJ at 121-23; Palmieri 2/24/98 GJ at 12; V006-DC-00000020 (White House employee data form).
134. Lewinsky 8/3/98 Int. at 2.
135. Lewinsky 8/3/98 Int. at 2; 828-DC-00000012 (resume); V006-DC-00000225 (employment approval for the Legislative Affairs Office); V006-DC-00000198 (1995 White House intern directory); V006-DC-00002287 (record of Ms. Lewinsky's transfer).
136. Lewinsky 8/26/98 Depo. at 60.
137. Lewinsky 8/6/98 GJ at 10.
138. Lewinsky 8/6/98 GJ at 9; Lewinsky 7/27/98 Int. at 2; Lewinsky 8/3/98 Int. at 1; V006-DC-00001826 (photo showing President and Ms. Lewinsky).
139. Lewinsky 8/26/98 Depo. at 16-17 & Ex. ML-7.
140. Finerman 3/18/98 Depo. at 10-11; Ungvari 3/19/98 GJ at
15-17.
141. Facts on File 852, 868 (1995).
142. Washington Post, 11/20/95 at A19; Los Angeles Times,
11/14/95 at A15; USA Today, 11/17/95 at 4A.
143. Lewinsky 8/6/98 GJ at 10-11; Byrne 6/25/98 Depo. at 18;
Byrne 7/30/98 GJ at 36; Palmieri 2/24/98 GJ at 16-19; Panetta
1/28/98 GJ at 122.
144. Goodin 2/17/98 GJ at 48-50; Griffin 5/11/98 Int. at 1;
Lewinsky 8/6/98 GJ at 10-11; Palmieri 2/24/98 GJ at 20-22; Raines
1/29/98 GJ at 35-36; V006-DC-00003737 - 3744 (White House photos
showing President and Ms. Lewinsky during furlough).
145. Lewinsky 8/6/98 GJ at 11.
146. Lewinsky 8/3/98 Int. at 2; Barry Toiv 3/11/98 Int. at 1
(job title).
147. Lewinsky 8/6/98 GJ at 10; Lewinsky 7/27/98 Int. at 1-2.
She told others that her physical relationship with the President
began during the November 1995 shutdown. Raines 1/29/98 GJ at
38; Tripp 7/2/98 GJ at 38-39. To one friend, Ms. Lewinsky
specified that the relationship began on November 15, 1995.
Tripp 6/30/98 GJ at 138; Tripp 7/2/98 GJ at 38-39, 80-82.
148. 827-DC-00000008. According to records, it was one of
only two times during Ms. Lewinsky's tenure at the White House
that she exited after midnight. 827-DC-00000003 - 16. (The
other post-midnight exit was not during the furlough; it was the
night of December 6-7, 1995.) As the omission of Ms. Lewinsky's
November 15 afternoon exit time illustrates, White House Epass
and WAVES records do not reflect all entries and exits of staff
and visitors. Secret Service Representatives Barry Smith et al.
3/16/98 Int. at 3-5. See also Appendix, Tab I.
149. 1222-DC-00000156, 1222-DC-00000083 - 85 (movement logs).
Times are approximate, as different logs of the President's
movements sometimes vary by a few minutes. With occasional
exceptions, these logs do not distinguish the President's private
study from the Oval Office.
150. Lewinsky 7/27/98 Int. at 2; Lewinsky 8/24/98 Int. at 5.
151. Lewinsky 7/30/98 Int. at 5; Lewinsky 8/11/98 Int. at 7;
Erbland 2/12/98 GJ at 24-25.
152. Lewinsky 8/6/98 GJ at 11; Lewinsky 7/27/98 Int. at 2;
Lewinsky 7/30/98 Int. at 5.
153. Lewinsky 8/6/98 GJ at 11; Lewinsky 7/27/98 Int. at 2;
Lewinsky 7/30/98 Int. at 5.
154. Lewinsky 8/6/98 GJ at 11; Lewinsky 8/26/98 Depo. at 7.
Ms. Lewinsky later told confidants that the relationship began
with kissing. Catherine Davis 3/17/98 GJ at 19; Finerman 3/18/98
Depo. at 31-35; Tripp 7/7/98 GJ at 151-52.
155. Lewinsky 7/30/98 Int. at 5.
156. Lewinsky 8/26/98 Depo. at 7.
157. Lewinsky 8/6/98 GJ at 12; Lewinsky 7/30/98 Int. at 5.
158. Lewinsky 8/26/98 Depo. at 7.
159. Lewinsky 8/26/98 Depo. at 7; Lewinsky 8/6/98 GJ at 12,
13.
160. Lewinsky 8/26/98 Depo. at 8; Lewinsky 7/30/98 Int. at 5.
161. Lewinsky 8/26/98 Depo. at 7-8.
162. Lewinsky 8/26/98 Depo. at 8. See also id. at 21.
Earlier in the evening, Ms. Lewinsky had removed her underwear.
Lewinsky Int. 9/3/98 at 1.
163. Lewinsky 8/6/98 GJ at 12-14; Lewinsky 8/26/98 Depo. at
9-10; Lewinsky 7/30/98 Int. at 6.
164. Lewinsky 8/26/98 Depo. at 10.
165. Lewinsky 8/26/98 Depo. at 11.
166. Lewinsky 9/3/98 Int. at 3; Lewinsky 8/24/98 Int. at 5;
Lewinsky 7/30/98 Int. at 6.
167. Lewinsky 8/6/98 GJ at 11-12; Lewinsky 8/26/98 Depo. at
7.
168. 1362-DC-00000549 (movement logs).
169. Lewinsky 7/30/98 Int. at 6.
170. 1472-DC-00000006 - 08. Starting 11 minutes later, the
President talked with other Members of Congress. Id.
171. 827-DC-00000008 (Epass records).
172. 1222-DC-00000085 (movement logs).
173. Lewinsky 8/6/98 GJ at 14. See also Lewinsky 7/30/98
Int. at 6-7.
174. Lewinsky 8/6/98 GJ at 14-15; Lewinsky 7/30/98 Int. at 7.
175. Lewinsky 8/6/98 GJ at 15-16.
176. In Ms. Currie's recollection, Ms. Lewinsky and the
President were alone together for about 30 seconds. Currie
1/27/98 GJ at 33-34; Currie 5/14/98 GJ at 36-38. Ms. Hernreich
testified that when delivering food during the government
shutdown, Ms. Lewinsky was alone with the President for two to
four minutes. Hernreich 2/26/98 GJ at 36-37. See also Hernreich
2/25/98 GJ at 12-17. Other witnesses also remembered Ms.
Lewinsky's pizza delivery during the furlough. Keating 2/25/98
GJ at 31-32; Palmieri 2/24/98 GJ at 20, 53, 62. The President
and Ms. Lewinsky (as well as others) appear in eight White House
photographs taken on November 17; in three of them, the President
is eating pizza. V006-DC-00003737 - 3744.
177. Lewinsky 8/6/98 GJ at 16; Lewinsky 8/26/98 GJ at 11-15;
Lewinsky 7/30/98 Int. at 7.
178. Lewinsky 8/26/98 Depo. at 12-13; Lewinsky 7/30/98 Int.
at 7.
179. Lewinsky 8/26/98 Depo. at 12; Lewinsky 7/30/98 Int. at
7.
180. Lewinsky 7/30/98 Int. at 7.
181. Lewinsky 8/26/98 Depo. at 13-14.
182. Lewinsky 8/26/98 Depo. at 13-14; Lewinsky 7/30/98 Int.
at 7. One friend understood that Ms. Lewinsky and the President
kissed when she brought pizza, and that Ms. Lewinsky performed
oral sex on him in a later encounter. Ungvari 3/19/98 GJ at 18-19, 20, 23. One of Ms. Lewinsky's counselors understood that the
relationship with the President began at a pizza party. Estep
8/23/98 Int. at 2.
183. Lewinsky 7/30/98 Int. at 7. See also Lewinsky 8/26/98
Depo. at 15.
184. 1472-DC-00000015 (phone logs). Ms. Lewinsky said that
this probably was the name she heard on that date. Lewinsky
8/11/98 Int. at 5. She testified that she could not recall
whether the President was on the telephone the whole time that
she performed oral sex. Lewinsky 8/26/98 Depo. at 14.
185. Clinton 1/17/98 Depo. at 58.
186. Clinton 8/17/98 GJ at 31-32.
187. 827-DC-00000011 (Epass records).
188. 1222-DC-00000179 (movement logs). The President had one
telephone call during this period, from 12:53 to 12:58 p.m.
1506-DC-00000029 (phone logs).
189. Lewinsky 8/26/98 Depo. at 15-16; Lewinsky 7/27/98 Int.
at 3-4; Lewinsky 7/30/98 Int. at 8.
190. Lewinsky 8/26/98 Depo. at 16.
191. Lewinsky 8/26/98 Depo. at 16; Lewinsky 7/27/98 Int. at
3-4; Lewinsky 7/30/98 Int. at 8.
192. Lewinsky 8/26/98 Depo. at 16.
193. Lewinsky 8/26/98 Depo. at 16-17. See also Lewinsky
7/30/98 Int. at 8.
194. Lewinsky 7/27/98 Int. at 3-4; Lewinsky 7/30/98 Int. at
8.
195. Lewinsky 8/26/98 Depo. at 17. See also Finerman 3/18/98
Depo. at 30-32, 35.
196. Lewinsky 7/30/98 Int. at 3.
197. 1222-DC-00000325 (Secret Service duty logs).
198. Clinton 8/17/98 GJ at 31-32.
199. Clinton 8/17/98 GJ at 9-10.
200. Ms. Lewinsky understood that the President may have
thought there was something improper in having a sexual
relationship with an intern. Lewinsky 8/24/98 Int. at 5.
201. Clinton 8/17/98 GJ at 10.
202. As noted above, White House entry and exit records are
incomplete.
203. 1222-DC-00000183 (movement logs).
204. Lewinsky 8/26/98 Depo. at 18. See also Lewinsky 7/30/98
Int. at 2, 8.
205. Lewinsky 8/26/98 Depo. at 18.
206. Lewinsky 8/26/98 Depo. at 19.
207. Lewinsky 8/26/98 Depo. at 19.
208. Lewinsky 8/26/98 Depo. at 19.
209. Lewinsky 8/26/98 Depo. at 19.
210. Lewinsky 8/26/98 Depo. at 20. They engaged in oral-anal
contact as well. Id.
211. Lewinsky 8/26/98 Depo. at 38.
212. 1222-DC-00000325, 1362-DC-00001171 (Secret Service duty
logs).
213. Fox 2/17/98 GJ at 33. Although Mr. Fox believed that
the incident occurred in late 1995, the totality of the evidence
suggests that it was on this date, January 7, 1996.
214. Fox 2/17/98 GJ at 31.
215. Fox 2/17/98 GJ at 60-61, 66-67.
216. Fox 2/17/98 GJ at 33.
217. Fox 2/17/98 GJ at 19-20, 42, 49-50.
218. Fox 2/17/98 GJ at 34-35. Officer Fox testified that the
President and Ms. Lewinsky were alone. Fox 2/17/98 GJ 36-37.
His sworn testimony on this point differs from the public
statements of his attorney, who told reporters that Officer Fox
did not know whether the two were alone. Chicago Tribune,
2/17/98 at 1C.
219. 827-DC-00000013 (Epass records).
220. 1222-DC-00000189 (movement logs). While Ms. Lewinsky
was in the White House, the President had a single phone call, at
3:47 p.m. for one minute. 1506-DC-00000050 (phone logs).
221. Lewinsky 7/30/98 Int. at 9; Lewinsky 8/24/98 Int. at 6.
222. Lewinsky 8/26/98 Depo. at 22-23.
223. Lewinsky 8/26/98 Depo. at 23.
224. Lewinsky 8/26/98 Depo. at 23.
225. Lewinsky 8/26/98 Depo. at 23-24. See also Lewinsky
7/30/98 Int. at 10.
226. Lewinsky 8/26/98 Depo. at 24-25.
227. Lewinsky 8/26/98 Depo. at 25.
228. Lewinsky 8/26/98 Depo. at 26.
229. Lewinsky 8/26/98 Depo. at 26. This interruption may
have been occasioned by the President's one-minute phone call at
3:47 p.m. 1506-DC-00000050 (phone logs).
230. Lewinsky 8/26/98 Depo. at 26-27. Ms. Lewinsky stated
that the Blairs from Arkansas were visiting the President.
Lewinsky 7/30/98 Int. at 10. This is confirmed by a Secret
Service itinerary for January 21, 1996, where Diane Blair is
listed as a houseguest. 1222-DC-00000024 (presidential
itinerary).
231. Lewinsky 8/26/98 Depo. at 27-28; Lewinsky 7/30/98 Int.
at 10; Tripp 7/7/98 GJ at 124-26, 139-143; Tripp 7/9/98 GJ at 4-5; 845-DC-00000004 (Tripp notes).
232. 1222-DC-00000196 (movement logs).
233. 1506-DC-00000068 (phone logs).
234. Lewinsky 8/26/98 Depo. at 28-29; Lewinsky 8/24/98 Int.
at 6.
235. Lewinsky 8/26/98 Depo. at 29-30.
236. Lewinsky 8/26/98 Depo. at 30-31.
237. Lewinsky 8/26/98 Depo. at 31-32. They engaged in oral-anal contact as well. Id. at 30-31.
238. Lewinsky 8/26/98 Depo. at 33.
239. Lewinsky 8/26/98 Depo. at 33-34.
240. Lewinsky 8/26/98 Depo. at 33.
241. Lewinsky 8/26/98 Depo. at 33-34; Lewinsky 8/24/98 Int.
at 6; Tripp 7/7/98 GJ at 169-71; 845-DC-00000006 (Tripp notes).
242. 1222-DC-00000197, 1222-DC-00000102 (movement logs).
243. 1506-DC-00000102 (phone logs).
244. Lewinsky 7/30/98 Int. at 11; Lewinsky 8/24/98 Int. at 6.
245. Lewinsky 7/30/98 Int. at 3, 11-12.
246. Lewinsky 7/30/98 Int. at 3, 11.
247. Lewinsky 8/6/98 GJ at 24; Lewinsky 7/29/98 Int. at 3.
248. Lewinsky 7/30/98 Int. at 11. Ms. Lewinsky later
recounted the episode to several others. Erbland 2/12/98 GJ at
46-47; Finerman 3/18/98 Depo. at 47; Tripp 7/7/98 GJ at 175-76;
Ungvari 3/19/98 GJ at 80.
249. Lewinsky 8/24/98 Int. at 6. See also Lewinsky 7/30/98
Int. at 11.
250. Garabito 7/30/98 GJ at 16-17, 23-24. According to a
colleague, Agent Garabito is over six feet tall, slender, and
Hispanic. OIC Memo of Interview with Special Agent Thomas M.
Powers, 9/7/98.
251. Garabito 7/30/98 GJ at 25, 30-31.
252. Garabito 7/30/98 GJ at 32. Agent Garabito later
recounted the incident to Larry L. Cockell, the head of the
Presidential Protective Division of the Secret Service. The OIC
learned of the episode from Agent Cockell's testimony. Cockell
7/23/98 GJ at 25-26.
253. 1472-DC-00000017 (call logs).
254. 1506-DC-00000017 (call logs).
255. Forbes, 9/22/97 at 2.
256. Lewinsky 8/6/98 GJ at 90.
257. Lewinsky 8/6/98 GJ at 91. See also Lewinsky 8/26/98
Depo. at 34; Tripp 7/7/98 GJ at 179-80. Ms. Lewinsky offered to
return to the White House to see him, but the President said he
needed to stay in the Residence because his daughter was ill.
Lewinsky 7/30/98 Int. at 12; Lewinsky 8/24/98 Int. at 6.
258. Ungvari 3/19/98 GJ at 29-31; Lewinsky 8/3/98 Int. at 3;
Ungvari 3/18/98 Int. at 4; Verna 6/11/98 Depo. at 10; 845-DC-00000009 (Tripp notes).
259. Ungvari 3/19/98 GJ at 30.
260. Lewinsky 8/11/98 Int. at 2.
261. Lewinsky 8/20/98 GJ at 19; Lewinsky 7/30/98 Int. at 12;
845-DC-00000010 - 11 (Tripp notes).
262. Lewinsky 8/26/98 Depo. at 34-35.
263. 1222-DC-00000112 (movement logs). The President and 32
guests saw Executive Decision that evening. 1506-DC-00000558
(White House daily diary).
264. 968-DC-00003459 (Hillary Clinton calendar).
265. Lewinsky 7/29/98 Int. at 3; Lewinsky 7/30/98 Int. at 12-13.
266. 827-DC-00000016 (Epass records).
267. 1222-DC-00000216 - 217; 1222-DC-00000112 - 113 (movement
logs).
268. 1506-DC-00000139 (phone logs).
269. 968-DC-00003459 (Hillary Clinton calendar). Mrs.
Clinton returned that evening. 1506-DC-00000559 (White House
diary); 1222-DC-00000041 (Secret Service itinerary).
270. Lewinsky 8/26/98 Depo. at 35-36.
271. Lewinsky 8/26/98 Depo. at 36; Lewinsky 7/30/98 Int. at
12.
272. Lewinsky 8/26/98 Depo. at 38-39.
273. Lewinsky 8/26/98 Depo. at 37.
274. Lewinsky 7/30/98 Int. at 12-13; Lewinsky 8/26/98 Depo.
at 37-38. In the grand jury, the President declined to answer
whether Ms. Lewinsky would be lying if she said he had used a
cigar as a sexual aid with her. Clinton 8/17/98 GJ at 110-11.
275. Lewinsky 7/30/98 Int. at 13.
276. Fox 2/17/98 GJ at 42-43.
277. Ludtke 6/5/98 Int. at 1-2.
278. Muskett 7/21/98 GJ at 124. Others also noted that Ms.
Lewinsky spent time around the West Wing. Byrne 3/13/98 Depo. at
22-25; Byrne 6/25/98 Depo. at 23, 39-44, 55-62, 104-113; Byrne
7/30/98 GJ at 8, 39-40; Hannie 4/6/98 Int. at 2-3; Keating
2/25/98 GJ at 52.
279. Lewinsky 8/20/98 GJ at 12.
280. Bordley 8/13/98 GJ at 9-16.
281. Bordley 8/13/98 GJ at 20-23, 29.
282. Bordley 8/13/98 GJ at 25-29.
283. Ferguson 7/17/98 GJ at 14-17, 27-28; Ferguson 7/23/98 GJ
at 14-17, 20.
284. Ferguson 7/17/98 GJ at 27.
285. Ferguson 7/17/98 GJ at 27-28; Ferguson 7/23/98 GJ at 20-21.
286. Ferguson 7/17/98 GJ at 29, 31.
287. Ferguson 7/17/98 GJ at 29. In addition, Officer Lewis
Fox and Agent Nelson Garabito testified about admitting Ms.
Lewinsky to the Oval Office on one occasion each, as recounted
above. Fox 2/17/98 GJ at 32-37; Garabito 7/30/98 GJ at 16-32.
Officer Fox also saw Ms. Lewinsky exit the Oval Office on another
occasion, but he did not know how long she had been inside. Fox
2/17/98 GJ at 43-46. Officer Gary Byrne also testified about
having seen Ms. Lewinsky in the Oval Office with the President,
though some details of his account varied in different tellings.
Byrne 7/30/98 GJ at 7-32; Byrne 7/17/98 GJ at 4-10.
288. Byrne 3/13/98 Depo. at 27-28, 46-47, 51-55; Byrne
6/25/98 Depo. at 31.
289. Lewinsky 8/20/98 GJ at 10-11; Lewinsky 7/31/98 Int. at
6.
290. Lieberman 1/30/98 GJ at 36-37. Ms. Lieberman testified
that she continued to disapprove of Ms. Lewinsky. When she saw
Ms. Lewinsky back in the White House after she no longer worked
there, Ms. Lieberman asked Ms. Currie, "What is she doing here?"
She also may have said to Ms. Currie, who told Ms. Lewinsky that
she could watch a presidential helicopter departure, "What are
you -- nuts?" or otherwise "expressed my displeasure."(291)
291. Lieberman GJ 1/30/98 at 50-52.
-
292. Lewinsky 8/20/98 GJ at 8.
293. Lieberman 1/30/98 GJ at 41.
294. Panetta 1/28/98 GJ at 139-42.
295. Lieberman 1/30/98 GJ at 45. See also Panetta 1/28/98 GJ
at 143 (describing precautions taken "to protect the President's
office and protect his integrity," including preventing President
from meeting alone with female acquaintances in circumstances
that "could be misinterpreted").
296. Lewis 2/11/98 GJ at 37-40. See also T3 at 15; Lewinsky
7/31/98 Int. at 7. Ms. Lieberman testified that the conversation
occurred in September 1997. Lieberman 1/30/98 GJ at 66. In her
recollection, the exchange began with Ms. Lewis coming up to her
and saying, "You ruined [Ms. Lewinsky's] life on the basis of
something that she never did." According to Ms. Lieberman, she
made no response, and Ms. Lewis walked away. Later Ms. Lewis
returned and said that she understood what Ms. Lieberman had done
and why. Lieberman 1/30/98 GJ at 64-66.
297. Abramson 2/20/98 Int. at 3; Band 2/25/98 Int. at 2-3;
Currie 5/6/98 GJ at 40-41; Ganong 2/12/98 Int. at 2; Keating
2/25/98 GJ at 73; Panetta 1/28/98 GJ at 139-42.
298. 1089-DC-00000970 (memo from Mr. Hilley to Ms.
Lieberman); Hilley 5/19/98 GJ at 34-35, 47-50. Mr. Hilley
testified that "extracurricular activities" -- which applied to
Ms. Lewinsky and one of her colleagues who was also transferred
-- did not refer to anything sexual in nature. Hilley 5/19/98 GJ
at 49-50. See also Byrne 6/25/98 Depo. at 22-25, 27-28, 38, 43,
54-55; Currie 5/14/98 GJ at 19-35; Fox 2/17/98 GJ at 46-48; Maes
5/7/98 GJ at 34-42.
299. Duncan 2/18/98 GJ at 24.
300. V006-DC-00001347.
301. Duncan 2/18/98 GJ at 13-14.
302. Duncan 2/18/98 GJ at 23, 41.
303. Duncan 2/18/98 GJ at 8, 23-24.
304. Lewinsky 8/6/98 GJ at 61. The President was traveling
to Oklahoma City on that day. V006-DC-00000694 (President's
schedule); 968-DC-00000841 (same).
305. Keating 2/25/98 GJ at 76. The Pentagon position had a
higher salary than Ms. Lewinsky's White House job. Lewinsky
8/3/98 Int. at 5. Ms. Lewinsky's supervisor, Jocelyn Jolley, was
also transferred that day. Keating 2/25/98 GJ at 76-79; Lewinsky
8/6/98 GJ at 171. Unlike Ms. Lewinsky, Ms. Jolley was given a
demotion: a temporary job at the General Services
Administration. Jolley 2/24/98 GJ at 36-39; Keating 2/25/98 GJ
at 79.
306. Keating 2/25/98 GJ at 78-79; Lewinsky 8/3/98 Int. at 3;
Capps 3/23/98 Int. at 2; Fox 2/17/98 GJ at 47; Lynn 8/5/98 GJ at
14-16; Verna 7/21/98 GJ at 21-23.
307. Lewinsky 8/6/98 GJ at 171. See also Lewinsky 8/3/98
Int. at 3. Ms. Lewinsky testified that Mr. Keating led her to
believe that she could probably return to work at the White House
after the election. Lewinsky 8/3/98 Int. at 4. Mr. Keating
testified that he told her that if she performed well at the
Pentagon, "she may be able to get a job back in the White House.
But not now." Keating 2/25/98 GJ at 79.
308. Lewinsky 8/26/98 Depo. at 60.
309. Lewinsky 8/6/98 GJ at 62.
310. 827-DC-00000016 (Epass records).
311. 1222-DC-00000219 (movement log).
312. Lewinsky 8/6/98 GJ at 62. See also Lewinsky 8/26/98
Depo. at 39; Lewinsky 7/27/98 Int. at 4; Tripp 7/9/98 GJ at 29-30.
313. In Ms. Lewinsky's recollection, Officer Muskett first
said he needed to get Evelyn Lieberman's authorization before
admitting Ms. Lewinsky to the Oval Office, but Ms. Lewinsky
talked him out of it. Lewinsky 8/6/98 GJ at 91; Lewinsky 8/20/98
GJ at 42; Lewinsky 8/26/98 Depo. at 39-40; Lewinsky 7/27/98 Int.
at 4; Lewinsky 7/30/98 Int. at 13; Lewinsky 7/31/98 Int. at 6.
314. Lewinsky 7/27/98 Int. at 4.
315. Lewinsky 8/6/98 GJ at 63. See also Lewinsky 8/26/98
Depo. at 40; Lewinsky 7/30/98 Int. at 13; Erbland 2/12/98 GJ at
37; Tripp 7/9/98 GJ at 31; 833-DC-00001070 (document recovered
from Ms. Lewinsky's computer referring to President's promise to
arrange for her return); MSL-DC-00001052 (another recovered
computer file, saying in part: "You promised you would bring me
back after the election with a snap of [your] fingers.");
Lewinsky Statement 2/1/98 at 1 ("he promised to bring her back to
the WH after the election"); Tripp 7/9/98 GJ at 31, 37-38, 42.
316. In a recorded conversation, Ms. Lewinsky recounted part
of this discussion:
[H]e said, "I promise you," you know, something like, "if I
win in November, I'll have you back like that. You can do
anything you want. You can be anything you want." And then
I made a joke and I said, "Well, can I be Assistant to the
President for Blow Jobs?" He said, "I'd like that."
T7 at 34-35.