317. Lewinsky 8/6/98 GJ at 64.
318. Clinton 8/17/98 GJ at 130.
319. Lewinsky 8/26/98 Depo. at 40.
320. Lewinsky 8/6/98 GJ at 94-97.
321. Lewinsky 8/26/98 Depo. at 40-41.
322. Lewinsky 8/26/98 Depo. at 41.
323. Lewinsky 8/26/98 Depo. at 41.
324. Lewinsky 8/6/98 GJ at 20, 95-97; Lewinsky 7/30/98 Int. at 13.
325. Lewinsky 8/6/98 GJ at 95; Lewinsky 8/26/98 Depo. at 41-44; Lewinsky 7/27/98 Int. at 4-5; Lewinsky 7/30/98 Int. at 13.
326. Lewinsky 8/6/98 GJ at 92; Lewinsky 7/27/98 Int. at 4-5; Lewinsky 7/30/98 Int. at 13.
327. 1248-DC-00000008 (phone logs).
328. Lewinsky 8/6/98 GJ at 93, 97.
329. Lewinsky 8/6/98 GJ at 93. See also Lewinsky 8/26/98 Depo. at 43; Lewinsky 7/27/98 Int. at 5; Lewinsky 7/30/98 Int. at 13. Ms. Lewinsky testified that she did not see Mr. Ickes but recognized his voice. Lewinsky 8/6/98 GJ at 97.
330. Lewinsky 8/6/98 GJ at 93; Lewinsky 8/26/98 Depo. at 45; Lewinsky 7/27/98 Int. at 5; Lewinsky 7/30/98 Int. at 13.
331. Lewinsky 8/6/98 GJ at 94. See also Lewinsky 7/30/98 Int. at 11; Tripp 7/9/98 GJ at 30-36; 845-DC-00000012 - 13 (Tripp notes).
332. Muskett 7/21/98 GJ at 9-13.
333. Muskett 7/21/98 GJ at 22-24.
334. Muskett 7/21/98 GJ at 25-26, 83.
335. Muskett 7/21/98 GJ at 27-28, 91-93.
336. Muskett 7/21/98 GJ at 28, 31-33.
337. Muskett 7/21/98 GJ at 34-37.
338. Lewinsky 8/6/98 GJ at 36-37; Lewinsky 7/27/98 Int. at 2.
339. Muskett 7/21/98 GJ at 36-37, 39-40. Officer Muskett recalled that the plainclothes agent on duty at the time was Reginald Hightower. Muskett 7/21/98 GJ at 22. While not "100 percent sure" that this incident occurred, Agent Hightower testified that "it probably did happen." Hightower 7/28/98 GJ at 46-49.
340. Muskett 7/21/98 GJ at 42-46. Mr. Ickes testified that he cannot recall this incident but cannot rule it out. Ickes 8/5/98 GJ at 58-59.
341. Muskett 7/21/98 GJ at 47-52, 89.
342. 1506-DC-00000144 (phone logs).
343. Lewinsky 8/6/98 GJ at 64-65. See also Lewinsky 2/1/98 Statement at 1; Lewinsky 7/31/98 Int. at 6-7; Lewinsky 8/3/98 Int. at 5; Tripp 7/9/98 GJ at 72-73; 845-DC-00000014 (Tripp notes); T2 at 17.
344. Lewinsky 8/6/98 GJ at 65; Lewinsky 7/29/98 Int. at 3-4; Lewinsky 8/3/98 Int. at 5.
345. Lieberman 1/30/98 GJ at 62.
346. Lieberman 1/30/98 GJ at 62.
347. Bowles 4/2/98 GJ at 66-67.
348. Currie 5/7/98 GJ at 49-50.
349. Jordan 3/3/98 GJ at 64-65.
350. V006-DC-00002289 (email noting departures of White House
employees); Lewinsky 8/6/98 GJ at 65. According to the job
description for the position:
The incumbent of this Schedule C position will have access
to highly confidential, sensitive and frequently politically
controversial information and must be a person in whom the
[Assistant Secretary of Defense for Public Affairs] has
complete trust and confidence.
833-DC-00002880. Ms. Lewinsky held clearance for Sensitive
Compartmented Information. Lewinsky 8/24/98 Int. at 3.
According to a regulation:
Sensitive Compartmented Information is information that not
only is classified for national security reasons as Top
Secret, Secret, or Confidential, but also is subject to
special access and handling requirements because it involves
or derives from particularly sensitive intelligence sources
and methods.
28 C.F.R. § 17.18(a) (1998).
351. Lewinsky 7/29/98 Int. at 1.
352. Lewinsky 8/6/98 GJ at 66.
353. Tripp 7/9/98 GJ at 94-98.
354. Lewinsky 8/6/98 GJ at 28 & Ex. ML-7.
355. Tripp 7/14/98 GJ at 3-4, 11-12; 845-DC-00000019 (Tripp notes).
356. Lewinsky 7/29/98 Int. at 4-5.
357. Lewinsky 7/30/98 Int. at 14. See also Lewinsky 7/29/98
Int. at 4; Lewinsky 8/6/98 GJ at 27-28; Tripp 7/9/98 GJ at 118-19
(mistakenly indicating that this occurred July 15, 1996); 845-DC-00000018 (Tripp notes).
358. 1506-DC-00000275 (call log); 1506-DC-000000638.
359. Lewinsky 7/29/98 Int. at 4-5; Lewinsky 7/30/98 Int. at
14-15; 845-DC-00000016 - 17 (Tripp notes); 845-DC-00000020 - 22
(same); Tripp 7/9/98 GJ at 102-04, 115-16; Tripp 7/14/98 GJ at
11-12, 35-37.
360. 1506-DC-00000222 (5/21/96); 1506-DC-00000264 (7/5/96);
1506-DC-00000268 (7/6/96); 1506-DC-00000328 (10/22/96); 1506-DC-00000353 (12/2/96) (President's schedules).
361. Lewinsky 7/29/98 Int. at 3; Finerman 3/18/98 Depo. at
49-50; Tripp 7/9/98 GJ at 53, 61-62, 94. Along with talking with
the President, Ms. Lewinsky also contacted former White House
colleagues for help returning to work there. Lewinsky 8/3/98
Int. at 5.
362. T7 at 36.
363. T7 at 36-37.
364. Lewinsky 7/30/98 Int. at 14; Lewinsky 8/6/98 GJ at 21;
Erbland 2/12/98 GJ at 30; Tripp 7/14/98 GJ at 4-6; 845-DC-00000020 (Tripp notes).
365. Lewinsky 8/20/98 GJ at 25.
366. Lewinsky 7/29/98 Int. at 3, 16; Tripp 7/9/98 GJ at 99-100; 845-DC-00000015 (Tripp notes). The President was at the
Renaissance Hotel in Washington from 8:40 to 9:25 p.m. that day.
1506-DC-00000188 - 189 (President's schedules).
367. V006-DC-00000534 (radio address guest list); 1222-DC-00000045 (itinerary); V006-DC-00001841 - 1847 (photographs);
V006-DC-00003735 (photo requests); V006-DC-00001865 (videotape).
368. Lewinsky 8/20/98 GJ at 28-31; Lewinsky 7/29/98 Int. at
16; Lewinsky 8/24/98 Int. at 6-7; V006-DC-00000682 (President's
schedule for August 18); V006-DC-00003735 (photo request from Ms.
Lewinsky); MSL-DC-0000489 - 490 (event invitation); Tripp 7/9/98
GJ at 125-26; 845-DC-00000019 (Tripp notes).
369. Lewinsky 8/20/98 GJ at 28-31. See also Lewinsky 7/30/98
Int. at 17.
370. Lewinsky 7/31/98 Int. at 7. Ms. Lewinsky thought that
this might have been October 23 or 24. Id. The President was at
the Sheraton Washington Hotel from 6:55 to 8:05 p.m. on October
23. 1506-DC-00000334 - 335 (President's schedule).
371. Newsweek, 8/10/98, cover photo.
372. Lewinsky 8/11/98 Int. at 2.
373. Lewinsky 8/20/98 GJ at 26-27.
374. Lewinsky 7/29/98 Int. at 5.
375. V006-DC-00000007 (WAVES records); V006-DC-00001855 -
1856 (photos from the reception); V006-DC-00000391 (White House
event attendance records).
376. MSL-DC-00001052 (spelling and punctuation corrected).
See also Lewinsky 2/1/98 Statement at 1-2; Tripp 7/14/98 GJ at
32-34. Ms. Lewinsky did not send this letter. Lewinsky 8/4/98
Int. at 5.
377. Catherine Davis 3/17/98 GJ at 23-24, 27; Finerman
3/18/98 Depo. at 12; Kassorla 8/28/98 Int. at 4; Raines 1/29/98
GJ at 31-32; Tripp 7/2/98 GJ at 41-43.
378. Tripp 7/14/98 GJ at 39-40; 845-DC-00000022 (Tripp
notes).
379. 833-DC-00001974 (email to Ms. Tripp).
380. Currie 5/7/98 GJ at 63.
381. Currie 5/6/98 GJ at 97-98.
382. Currie 5/6/98 GJ 14-15.
383. Currie 5/6/98 GJ at 52-53, 94-96.
384. 827-DC-00000002, 827-DC-00000018 (Ms. Lewinsky's WAVES
records).
385. Currie 5/6/98 GJ at 57-58.
386. Currie 5/6/98 GJ at 84-85. In a later appearance before
the grand jury, Ms. Currie testified that she could no longer
recall any occasions when she came just to admit Ms. Lewinsky,
but she could not rule it out. Currie 7/22/98 GJ at 24.
387. Currie 1/27/98 GJ at 32-33. See also Currie 5/6/98 GJ
at 98; Currie 7/22/98 GJ at 25-26, 41. Ms. Currie subsequently
wavered on this point. Currie 7/22/98 GJ at 14 ("[t]he
President, for all intents and purposes, is never alone"); id. at
15-16 (testifying that President and Ms. Lewinsky, in study
together, were "not alone" so long as Ms. Currie was at her
desk); id. at 25 (agreeing that Ms. Lewinsky and President were
alone together); id. at 131 ("I was always there. And I
considered them not to be alone. . . . I always thought that my
presence there meant that they were not alone."). Cf. Clinton
8/17/98 GJ at 134 ("there were a lot of times when we were alone,
but I never really thought we were").
388. Pape 5/18/98 Int. at 3-4.
389. Chinery 6/11/98 Depo. at 33.
390. Chinery 6/11/98 Depo. at 44-45; Chinery 7/23/98 GJ at
49.
391. Chinery 7/23/98 GJ at 8; Chinery 6/11/98 Depo. at 13-17.
For other Secret Service corroboration of Ms. Currie's role, see
Chinery 7/23/98 GJ at 49-50; Chinery 6/11/98 Depo. at 33, 37, 44;
Garabito 7/30/98 GJ at 44-47; Shegogue 8/4/98 GJ at 11, 14-19,
24-27.
392. Lewinsky 8/20/98 GJ at 5. See also id. at 14; Lewinsky
8/19/98 Int. at 5.
393. Currie 5/6/98 GJ at 88-89. See also id. at 184; Currie
5/14/98 GJ at 78.
394. Currie 5/6/98 GJ at 88-89.
395. Currie 5/14/98 GJ at 72-74, 91; Currie 1/24/98 Int. at
3.
396. 837-DC-00000001; 837-DC-00000004; 837-DC-00000006; 837-DC-0000008; 837-DC-00000011; 837-DC-00000014; 837-DC-00000018.
397. Lewinsky 7/31/98 Int. at 13; Marcia Lewis 2/11/98 GJ at
28-30; T1 at 63-64.
398. Dragotta 8/13/98 GJ at 10-11; Janney 8/13/98 GJ at 7, 9-11, 14; Niedzwiecki 7/30/98 GJ at 12-13, 20-21; Pape 8/5/98 GJ at
24; Keith Williams 7/23/98 GJ at 14.
399. Currie 5/14/98 GJ at 72-73.
400. Currie 5/14/98 GJ at 73-74, 86-89; Currie 7/22/98 GJ at
51-52.
401. Currie 5/14/98 GJ at 88-89. See also id. at 91; Currie
7/22/98 GJ at 49-50 (testifying that she did not open sealed
cards from Ms. Lewinsky to President but "may have read" unsealed
ones).
402. Currie 5/6/98 GJ at 88-89. See also Currie 5/14/98 GJ
at 78.
403. "The President got everything anyone sent him." Currie
5/6/98 GJ at 129.
404. Currie 5/14/98 GJ at 143-45; Currie 1/24/98 Int. at 8.
405. Currie 5/6/98 GJ at 157-58.
406. Currie 5/6/98 GJ at 156; Currie 7/22/98 GJ at 42-43.
407. Currie 1/27/98 GJ at 63-64. See also Currie 5/6/98 GJ
at 164; Currie 7/22/98 GJ at 31-33. According to Ms. Lewinsky,
the President at one point told her similarly that "if the two
people who are involved [in a relationship] say it didn't happen
-- it didn't happen." Lewinsky 2/1/98 Statement at 10, ¶ 11.
408. Currie 5/14/98 GJ at 131-43. Ms. Currie testified: "I
think . . . what I was trying to do was allow the President to
have personal and private phone calls if he wanted to. And the
appearance of any impropriety, I didn't want to have it." Id. at
141.
409. Currie 7/22/98 GJ at 33-35.
410. Dragotta 8/13/98 GJ at 8-10; Pape 8/5/98 GJ at 17-18.
Asked if she had tried to persuade officers not to log in Ms.
Lewinsky's visits, Ms. Currie testified: "I hope I didn't. I
can't imagine -- and I can't imagine that it could be." Currie
7/22/98 GJ at 115. None of the Uniformed Division officers
interviewed by the OIC acknowledged having permitted Ms. Lewinsky
to enter the White House without proper clearance. However, as
noted elsewhere, there is clear evidence that Ms. Lewinsky was in
the White House on days for which no records show her entry or
exit.
411. V006-DC-00003712 (2/24/97 message). Records show seven
calls from Ms. Lewinsky's line to Ms. Currie's line on December
5, 1997, for example, and six calls the following day. 1216-DC-00000022.
412. Currie 5/6/98 GJ at 16-17, 20-21, 68-70, 73-74, 85-86;
Currie 5/7/98 GJ at 8. See also 1037-DC-00000341 (email).
413. Currie 5/6/98 GJ at 73-74, 85-86. Ms. Currie later said
that "I don't want the impression of sneaking, but it's just that
I brought her in without anyone seeing her." Id. at 156. Ms.
Lewinsky confirmed that Ms. Currie helped her avoid Mr. Goodin
and others. Lewinsky 8/20/98 GJ at 15; Lewinsky 7/27/98 Int. at
4; Lewinsky 8/3/98 Int. at 5; Lewinsky 8/24/98 Int. at 7.
414. Currie 5/6/98 GJ at 84-85.
415. Lewinsky 7/31/98 Int. at 4.
416. Lewinsky 8/5/98 Int. at 3.
417. Lewinsky 7/31/98 Int. at 5. Ms. Lewinsky told
confidants about Ms. Currie's role. Catherine Davis 3/17/98 GJ
at 17, 33, 37-38; Erbland 2/12/98 GJ at 43; Finerman 3/18/98
Depo. at 39-40; Raines 1/29/98 GJ at 49; Ungvari 3/19/98 GJ at
38-40; 1037-DC-00000337 - 338 (email from Ms. Lewinsky); 1037-DC-00000001 - 02 (card from Ms. Lewinsky).
418. Carbonetti 6/16/98 Int. at 2; Chinery 6/11/98 Depo. at
39-40; Janney 5/27/98 Int. at 2; LaDow 5/27/98 Int. at 3; Ludtke
6/5/98 Int. at 2; Pape 8/5/98 GJ at 23-24; Pape 5/18/98 Int. at
3-6.
419. Chinery 7/23/98 GJ at 50.
420. Pape 5/18/98 Int. at 5.
421. Washington Post, 2/14/97, "Love Notes" at 44 (824-DC-00000013 - 14). See also 1078-DC-00000002. A copy of the ad was
found in the box of gifts and other items that Ms. Lewinsky,
after being subpoenaed in the Jones case, gave Ms. Currie for
safekeeping. 824-DC-00000013 - 14; Lewinsky 8/20/98 GJ at 71-72.
Ms. Lewinsky told several people about the ad. Catherine Davis
3/17/98 GJ at 28; Finerman 3/18/98 Depo. at 22-23; Marcia Lewis
2/10/98 GJ at 59-61; Raines 1/29/98 GJ at 109. In email on
February 13, she said she planned to check her telephone messages
from London (where she would be on Valentine's Day) "in the hopes
that the creep will call and say 'Thank you for my love note. I
love you. Will you run away with me?' What do ya think the
likelihood of that happening is?" 833-DC-00001934. On February
19, she wrote in an email that the President had not left any
message for her on Valentine's Day. 833-DC-00009446.
422. 827-DC-00000018 (Epass records); Kessinger 2/24/98 Int.
at 2.
423. 833-DC-00001906 (email from Ms. Lewinsky to Ms. Tripp).
424. V006-DC-00003712.
425. V006-DC-00003720 (radio address attendance list).
426. 827-DC-00000018; V006-DC-00000008; V006-DC-00001796.
427. 1222-DC-00000234; 968-DC-00000073.
428. 968-DC-00003506.
429. Lewinsky 8/26/98 Depo. at 45-46, 48-49; Lewinsky 8/6/98
GJ at 30.
430. Lewinsky 8/6/98 GJ at 45-46.
431. Lewinsky 8/26/98 Depo. at 46.
432. Lewinsky 8/6/98 GJ at 30.
433. Lewinsky 8/6/98 GJ at 30-31, 46-47; Lewinsky 7/30/98
Int. at 15; Lewinsky 7/31/98 Int. at 5. Mr. Goodin and Ms.
Currie confirmed that Ms. Lewinsky stayed behind and talked with
the President after the radio address. Currie 1/27/98 GJ at 34;
Goodin 2/17/98 GJ at 52, 55. Mr. Goodin testified that he
approached the President and "basically offer[ed] to chase her
away because I didn't know if that was a good use of his time,"
but the President replied that "she's a friend of a political
supporter." Goodin 2/17/98 GJ at 56. Nancy Hernreich, who was
not present at the radio address, testified that Mr. Goodin told
her about Ms. Lewinsky's presence there on the following work
day. Hernreich 2/26/98 GJ at 5-9.
434. Currie 7/22/98 GJ at 130-31; Currie 1/27/98 GJ at 34-35;
Lewinsky 8/6/98 GJ at 31; Lewinsky 7/30/98 Int. at 15.
435. Currie 7/22/98 GJ at 131. Ms. Currie also maintained
that the President and Ms. Lewinsky were "[n]ever out of
eyesight." Id. at 135. The President, however, acknowledged
"inappropriate intimate contact" with Ms. Lewinsky on February 28
and testified that, to the best of his knowledge, Ms. Currie
never witnessed any such encounters between himself and Ms.
Lewinsky. Clinton 8/17/98 GJ at 10, 53-54.
436. Lewinsky 8/26/98 Depo. at 46-47.
437. Lewinsky 8/26/98 Depo. at 46-47.
438. Lewinsky 8/26/98 Depo. at 47; Lewinsky 8/6/98 GJ at 31.
Ms. Currie testified that the President later asked her, "Did
Monica show you the hat pin I gave her?" Currie 5/6/98 GJ at
142.
439. Lewinsky 8/6/98 GJ at 156. See also Lewinsky 8/20/98 GJ
at 72; Lewinsky 8/26/98 Depo. at 47; Currie 5/6/98 GJ at 101-102;
Catherine Davis 3/17/98 GJ 30-31; Erbland 2/12/98 GJ at 40-41;
Finerman 3/18/98 Depo. at 15-16; Marcia Lewis 2/10/98 GJ at 51-52; Raines 1/29/98 GJ at 53-55.
A draft of Ms. Lewinsky's thank-you note (to "Dear Mr. P")
was found in her apartment. It says in part:
All of my life, everyone has always said that I am a
difficult person for whom to shop, and yet, you managed to
choose two absolutely perfect presents! A little phrase
(with only eight letters) like "thank you" simply cannot
begin to express what I feel for what you have given me.
Art & poetry are gifts to my soul!
I just love the hat pin. It is vibrant, unique and a
beautiful piece of art. My only hope is that I have a hat
fit to adorn it (ahhh, I see another excuse to go shopping)!
I know that I am bound to receive compliments on it.
I have only read excerpts from "Leaves of Grass" before
-- never in its entirety or in such a beautifully bound
edition. Like Shakespeare, Whitman's writings are so
timeless. I find solace in works from the past that remain
profound and somehow always poignant. Whitman is so rich
that one must read him like one tastes a fine wine or good
cigar -- take it in, roll it in your mouth, and savor it!
I hope you know how very grateful I am for these gifts,
especially your gift of friendship. I will treasure them
all . . . always.
MSL-DC-00000621 - 622 (emphasis in original) (ellipsis in
original). Ms. Lewinsky said she sent a version of this letter
to the President and enclosed a necktie. Lewinsky 8/4/98 Int. at
5.
440. Lewinsky 8/24/98 Int. at 7; Finerman 3/18/98 Depo. at
22; Raines 1/29/98 GJ at 109.
441. Lewinsky 8/26/98 Depo. at 47-48. See also Lewinsky
8/6/98 GJ at 31, 38-39.
442. Lewinsky 8/26/98 Depo. at 47-48. See also Lewinsky
8/6/98 GJ at 31, 38-39.
443. Lewinsky 7/30/98 Int. at 15.
444. Lewinsky 8/26/98 Depo. at 48.
445. Lewinsky 8/6/98 GJ at 32, 39-40. Ms. Lewinsky testified
that she did not keep the soiled dress as a souvenir. She said
she does not ordinarily clean her clothes until she is ready to
wear them again. "I was going to clean it. I was going to wear
it again." Lewinsky 8/6/98 GJ at 41. She also testified that
she was not certain that the stains were semen. She had dined
out after the radio address, "[s]o it could be spinach dip or
something." Lewinsky 8/6/98 GJ at 40. See also Lewinsky 7/29/98
Int. at 17.
446. FBI Lab Reports, 8/6/98, 8/17/98.
447. Clinton 8/17/98 GJ at 55.
448. Clinton 8/17/98 GJ at 138.
449. Clinton 8/17/98 GJ at 136-37.
450. V006-DC-00000008 (WAVES records); V006-DC-00001792
(WAVES request). Phone records indicate that Ms. Lewinsky called
Ms. Currie for one minute at 8:37 a.m. that day. 1014-DC-00000022.
451. 968-DC-00000236 (presidential diary); V006-DC-00002130
(movement log); 968-DC-00003510 (phone log). Mrs. Clinton was in
Africa. 968-DC-00003843 (schedule).
452. Lewinsky 7/30/98 Int. at 16; Lewinsky 8/20/98 GJ at 67-69; Lewinsky 8/24/98 Int. at 7.
453. Lewinsky 8/26/98 Depo. at 49.
454. Lewinsky 8/26/98 Depo. at 50.
455. Lewinsky 8/26/98 Depo. at 50.
456. Lewinsky 8/26/98 Depo. at 51. See also Lewinsky 8/20/98
GJ at 68-69; Lewinsky 7/30/98 Int. at 16. Ms. Lewinsky testified
that their genitals only briefly touched: "[W]e sort of had
tried to do that, but because he's so tall and he couldn't bend
because of his knee, it didn't really work." Lewinsky 8/26/98
Depo. at 51.
457. Lewinsky 8/20/98 GJ at 68-69; Lewinsky 8/26/98 Depo. at
50; Lewinsky 7/30/98 Int. at 16.
458. Lewinsky 7/30/98 Int. at 16.
459. Clinton 8/17/98 GJ at 10.
460. Clinton 8/17/98 GJ at 54-55, 137-38.
461. Lewinsky 8/6/98 GJ at 66; Lewinsky 7/27/98 Int. at 5;
Lewinsky 7/31/98 Int. at 8; Lewinsky 2/1/98 Statement at 1-2;
MSL-DC-00001052; T1 at 38. Mr. Nash said he had never heard of
Ms. Lewinsky before January 1998. Nash 3/19/98 Int. at 1; Nash
9/2/98 Int. at 1.
462. Lewinsky 8/6/98 GJ at 67.
463. Lewinsky 8/6/98 GJ at 66-67; Lewinsky 7/27/98 Int. at 5;
Lewinsky 8/5/98 Int. at 2.
464. Lewinsky 8/6/98 GJ at 86-87.
465. Lewinsky 8/26/98 Depo. at 62.
466. Clinton 8/17/98 GJ at 113-14. Later the President said:
"I didn't order her to be hired at the White House. I could have
done so. I wouldn't do it."(467)
467. Clinton 8/17/98 GJ at 124.