Text Of Clinton Testimony (2)

This is part two of President Clinton's uncorrected testimony to the Ken Starr grand jury:

PRESIDENT CLINTON: I did. And at the time that she made the statement -- and indeed to the present day, because as far as I know, she was never deposed since the judge ruled she would not be permitted to testify in a case that the judge ruled had no merit; that is, this case we are talking about -- I believed at the time that she filled out this affidavit, if she believed that the definition of "sexual relationship" was "two people having intercourse," then this is accurate.

And I believe that is the definition that ordinary Americans would give it. If you said, "Jane and Harry had a sexual relationship" and you're not talking about people being gone into a lawsuit and being given definitions and then a great effort to trick them in some way, but you're just talking about people in ordinary conversation, I'll bet the grand jurors, if they were talking about two people they know and said, "They had a sexual relationship," they meant they were "sleeping" together; they meant they were "having intercourse" together. So I am not at all sure that this affidavit is not true and was not true in Ms. Lewinsky's mind at the time she swore it out.

OIC ATTORNEY: Did you talk with Ms. Lewinsky about what she meant to write in her affidavit?

PRESIDENT CLINTON: I didn't talk to her about how her definition -- I did not know what was in this affidavit before it was filled out, specifically. I did not know what words were used specifically before it was filled out or what meaning she gave to them. But I am just telling you that it's certainly true what she says here, that we didn't have -- there was no employment, no benefit in exchange; there was nothing having anything to do with sexual harassment.

And if she defined sexual relationship in the way I think most Americans do, meaning intercourse, then she told the truth. And that depends on what was in her mind. I don't know what was in her mind. You'll have to ask her that.

OIC ATTORNEY: But you indicated before that you were aware of what she intended by the term "sexual relationship."

PRESIDENT CLINTON: No, sir. I said I thought that this could be a truthful affidavit, and when I read it, since that's the way I would define it, since keep in mind she was not -- she was not bound by this sexual relations definition, which is highly unusual; I think anybody would admit that. When she used a different term, "sexual relationship," if she meant by that what most people mean by it, then that is not an untruthful statement.

OIC ATTORNEY: So your definition of sexual relationship is intercourse only; is that correct?

PRESIDENT CLINTON: No, not necessarily intercourse only, but it would include intercourse. I believe that the common understanding of the term, if you say two people are having a sexual relationship, most people believe that includes intercourse. So if that's wha Ms. Lewinsky thought, then this is a truthful affidavit. I don't know what was in her mind, but if that's what she thought, the affidavit is true.

OIC ATTORNEY: What else would sexual relationship include besides intercourse?

PRESIDENT CLINTON: Well, that -- I think -- let me answer what I said before. I think most people when they use that term include sexual relationship and whatever other sexual contact is involved in a particular relationship, but they think it includes intercourse as well. And I would have thought so. Before I got into this case and heard all I've heard and seen all I've seen, I would have thought that that's what nearly everybody thought it meant.

OIC ATTORNEY: Well, I ask, Mr. President, because your attorney, using the very document, Grand Jury Exhibit 4, WJC-4, represented to Judge Wright that his understanding of the meaning of that affidavit, which you've indicated you thought Ms. Lewinsky thought was just intercourse, he says to Judge Wright that it meant absolutely no sex of any kind, in any manner, shape or form.

PRESIDENT CLINTON: Well, let me say this. I didn't have any discussion, obviously, at this moment with Mr. Bennett. I'm not even sure I paid much attention to what he was saying. I was -- I was ready to get on with my testimony here, and they were having these constant discussions all through the deposition. But that statement, in the present tense, at least, is not inaccurate, if that's what Mr. Bennett meant.

That is, at the time the he said that and for some time before that, that would be a completely accurate statement.

Now, I don't believe that he was -- I don't know what he meant. You'd have to talk to him because I just wasn't involved in this, and I didn't pay much attention to what was being said. I was just waiting for him to get back to me. So I can't comment on or be held responsible for whatever he said about that, I don't think.

OIC ATTORNEY: Well, if you -- do you agree with me that if he mislead Judge Wright in some way that you would have corrected the record, and said, excuse me, Mr. Bennett, I think the judge is getting a misimpression by what you are saying?

PRESIDENT CLINTON: Mr. Bennett was representing me. I wasn't representing him. And I wasn't even paying much attention to this conversation, which is why, when you started asking me about this, I asked to see the deposition. I was focusing on my answers to the questions. And I've told you what I believe about this deposition, which I believe to be true.

And it's obvious, and I think by your questions you have betrayed that the Jones lawyers' strategy in this case had nothing to do with uncovering or proving sexual harassment.

By the time this discovery started, they knew they had a bad case on the law, and they knew what our evidence was. They knew they had a lousy case on the facts. And so their strategy, since they were being funded by my political opponents, was o have this dragnet of discovery. They wanted to cover everybody, and they convinced the judge, because she gave them strict orders not to leak, that they should be treated like other plaintiffs in other civil cases and how could they ever know whether there had been any sexual harassment, unless they first knew whether there had been any sex.

And so with that broad mandate limited by time and employment in the federal or state government, they proceeded to cross the country and try to turn up whatever they could; not because they thought it would help their case. By the time they did this discovery, they knew what this deal was in their case, and they knew what was going to happen. And Judge Wright subsequently threw it out. They --

OIC ATTORNEY: With all respect, Mister --

PRESIDENT CLINTON: Now, let me finish, Mr. Bennett [sic}. I mean, you brought this up. Excuse me, Mr. Bittman.

What they wanted to do, and what they did do, and what they had done by the time I showed up here was to find any negative information they could on me, whether it was true or not, get it in a deposition, and then leak it, even though it was illegal to do so. It happened repeatedly. The judge gave them orders. One of the reasons she was sitting in that deposition was because she was trying to make sure that it didn't get out of hand. But that was their strategy, and they did a good job of it, and they got away with it.

I've been subject to quite a lot of illegal leaking. And they had a very determined, deliberate strategy, because their real goal was to hurt me. When they knew they couldn't win the lawsuit, they thought, well, maybe we can pummel him. Maybe they thought I'd settle. Maybe they just thought they would get some political advantage out of it. But that's what was going on here.

Now, I'm trying to be honest with you and it hurts me. And I'm trying to tell you the truth about what happened between Ms. Lewinsky and me. But that does not change the fact that the real reason they were zeroing in on anybody was to try to get any person in there, no matter how uninvolved with Paula Jones, no matter how uninvolved with sexual harassment, so they could hurt me politically. That's what was going on, because by then -- by this time, this thing had been going on a long time. They knew what our evidence was, they knew what the law was in the Circuit in which we were bringing this case, and so they just thought they would take a wrecking ball to me and see if they could do some damage.

OIC ATTORNEY: Judge Wright had ruled that the attorneys in the Jones case were permitted to ask you certain questions --

PRESIDENT CLINTON: She certainly did, and they asked them, and I did my best to answer them. I'm just trying to tell you what my state of mind was.

OIC ATTORNEY: And it was your responsibility to answer those questions truthfully, Mr. President.

PRESIDENT CLINTON: It was. But it was not my responibility, in the face of their repeated illegal leaking, it was not my responsibility to volunteer a lot of information. There are many cases in this deposition where I gave -- and keep in mind, I prepared -- I treated them, frankly, with respect. I prepared very well for this deposition on the Jones matters; I prepared very well on that. I did not know that Linda Tripp had been involved in the preparation of this deposition or that --

OIC ATTORNEY: Do you know that now?

PRESIDENT CLINTON: No, I don't. I just know that what -- what I read in the papers about it. But I had no way of knowing that they would ask me all these detailed questions. I did the best I could to answer them.

OIC ATTORNEY: Did you prepare --

PRESIDENT CLINTON: But in this deposition, Mr. Bittman, I was doing my best to be truthful. I was not trying to be particularly helpful to them, and I didn't think I had an obligation to be particularly helpful to them to further -- when I knew that there was no evidence here of sexual harassment, and I knew what they wanted to do was to leak this, even though it was unlawful to do so. That's what I knew.

OIC ATTORNEY: Did you believe, Mr. President, that you had an obligation to make sure that the presiding federal judge was on board and had the correct facts? Did you believe that was your obligation?

PRESIDENT CLINTON: Sir, I was trying to answer my testimony; I was thinking about my testimony. I don't believe I ever even focused on what Mr. Bennett said in the exact words he did until I started reading this transcript carefully for this hearing. That moment, that whole argument just passed me by. I was a witness; I was trying to focus on what I said and how I said it. And believe me, I knew what the purpose of the deposition was. And sure enough, by the way, it did all leak, just like I knew it would.

OIC ATTORNEY: Let me ask you, Mr. President, you indicate in your statement that were alone with Ms. Lewinsky; is that right?

PRESIDENT CLINTON: Yes, sir.

OIC ATTORNEY: How many times were you alone with Ms. Lewinsky?

PRESIDENT CLINTON: Let me begin with the correct answer: I don't know for sure. But if you would like me to give an educated guess, I will do that, but I do not know for sure. And I will tell you what I think, based on what I remember, but I can't be held to a specific time because I don't have records of all of them.

OIC ATTORNEY: How many times do you think?

PRESIDENT CLINTON: Well, you have -- there are two different periods here. There's the period when she worked in the White House, until April of '96, and then there's the period when she came back to visit me, from February '97 until late December '97. Based on our records -- let's start with the records, where we have the best records and closest in time. Based on our records, between February and December, it appears to me that at least I could have seen her approximately nine times, althugh I do not believe I saw her quite that many times, at least it could have happened. There were -- we think there were nine or 10 times when she was in the White House, when I was in the Oval Office when I could have seen her. I do not believe I saw her that many times, but I could have.

Now, we have no records for the time when she was an employee at the White House because we have no records of that for any of the employees at the White House, unless there is some formally scheduled meeting that was on the -- on the calendar for the day.

I remember -- I'll tell you what I remember. I remember meeting her or having my first real conversation with her during the government shutdown in November of '95 when she -- the -- as I explained in my deposition, during the government shutdown, most federal employees were actually prohibited from coming to work, even in the White House. Most people in the White House couldn't come to work. The chief of staff could come to work, my national security adviser could come to work. That's it. Therefore, interns were assigned to all offices. And I believe it was her last week as an intern. Anyway, she worked in the Chief of Staff's Office.

One night she brought me some pizza. We had some remarks.

Now the next time I remember seeing her alone was on a couple of occasions when she was working in the Legislative Affairs Office as a full-time employee. I remember specifically -- I have a specific recollection of two times -- I don't remember when they were, but I remember twice when on a Sunday afternoon, she brought papers down to me, stayed, and we were alone.

And I am frankly quite sure -- although I have no specific memory, I am quite sure there were a couple of more times; probably two times more, three times more. That's what I would say; that's what I can remember. But I do not remember when they were or at what time of day they were or what the facts were, but I have a general memory that would say I certainly saw her more than twice during that period between January and April of 1996, when she worked there.

OIC ATTORNEY: So, if I can summarize your testimony, approximately five times you saw her before she left the White House and approximately nine times after she left the employment at the White House?

PRESIDENT CLINTON: There were several times in '97. I have told her that I've looked at my calendar. And I'll tell you what I think the outer limits are. I would think that would sound about right.

In that first four-month period, maybe there is one or two more, and maybe there is one less. I just don't know, I don't remember, I didn't keep records. But I am giving you what I specifically remember and then what I generally remember. I am doing the best to be helpful to you.

OIC ATTORNEY: Have you reviewed the records for December 28th, 1997, Mr. President?

PRESIDENT CLINTON: Yes, sir, I have.

OIC ATTORNEY: Do you claim that Ms. Lewinsky waat the White House and saw you on December 28th, 1997?

PRESIDENT CLINTON: Yes, sir, I do.

OIC ATTORNEY: And do you remember talking with Ms. Lewinsky about her subpoena that she had received for the Paula Jones case that day?

PRESIDENT CLINTON: I remember talking with Ms. Lewinsky about her testimony or about the prospect that she might have to give testimony. And she talked to me about that, and I remember that.

OIC ATTORNEY: And you also gave her Christmas gifts, is that not correct, Mr. President?

PRESIDENT CLINTON: That is correct. They were Christmas gifts, and they were going-away gifts. She was moving to New York and taking a new job, starting a new life, and I gave her some gifts.

OIC ATTORNEY: And you actually requested this meeting, is that not correct?

PRESIDENT CLINTON: I don't remember that, Mr. Bittman, but it's quite possible that I invited her to come by before she left town. But usually when we met, she requested the meetings.

And my recollection is in 1997, she asked to meet with me several times when I could not meet with her and did not do so. But it's quite possible that because she had given me a Christmas gift and because she was leaving, that I invited her to come by the White House and get a couple of gifts before she left town.
I don't remember who requested the meeting, though. I'm sorry, I don't.

OIC ATTORNEY: You were alone with her on December 28, 1997?

PRESIDENT CLINTON: Yes, sir, I was.

OIC ATTORNEY: The gifts that you gave her was a -- were a canvas bag from the Black Dog Restaurant at Martha's Vineyard; is that right?

PRESIDENT CLINTON: Well, that was just -- that was just something I had in the place to contain the gifts, but I believe that the gifts I gave her were -- I had put them in that bag. That's what I had there, and I knew she liked things from the Black Dog, so I gave her -- I think that's what I put the presents in. I remember what the presents were; I don't remember what the bag was I gave them in.

OIC ATTORNEY: Did you also give her a marble bear's head carving from Vancouver, Canada?

PRESIDENT CLINTON: I did do that. I remember that.

OIC ATTORNEY: You also gave her a Rockettes blanket? And that's the famous Rockettes from New York?

PRESIDENT CLINTON: I did do that. I had had that in my possession for a couple of years but had never used it, and she was going to New York, so I thought it would be a nice thing to give her.

OIC ATTORNEY: You gave her a box of cherry chocolates; is that right?

PRESIDENT CLINTON: I don't remember that, sir. I mean, there could have been. I just don't remember. I remember giving the bear and the throw. I don't remember what -- it seems to me like there was one other thing in that bag. I didn't remember the cherry chocolates.

OIC ATTORNEY: How about a pin of the New York skyline? Did you give her that?

PRESIDENT CLINTON: That could have been in there. seem to remember I gave her some kind of pin.

OIC ATTORNEY: What about a pair of joke sunglasses?

PRESIDENT CLINTON: I don't remember that. I'm not denying it. I just -- I'm telling you what I remember and what I don't.

OIC ATTORNEY: You had given Ms. Lewinsky gifts on other occasions; is that right, Mr. President?

PRESIDENT CLINTON: Yes, I had.

OIC ATTORNEY: This, though, was -- you gave her the most gifts that you had ever given her in a single day; is that right?

PRESIDENT CLINTON: That's probably true. It was sort of like a going-away present and a Christmas present as well. And she had given me a particularly nice book for Christmas, an antique book on presidents. She knew that I collected old books, and it was a very nice thing. And I just thought I ought to get up a few things and give them to her before she left.

OIC ATTORNEY: You mentioned that you discussed her subpoena in the Paula Jones case.
Tell us specifically, what did you discuss?

PRESIDENT CLINTON: No, sir, that's not what I said. I said my recollection is, I knew by then, of course, that she had gotten a subpoena and I knew that she was -- therefore was slated to testify. And she mentioned to me -- and I believe it was at this meeting, she mentioned -- I remember a conversation about the possibility of her testifying. I believe it must have occurred on the 28th. She mentioned to me that she did not want to testify. And so I -- so that's how it came up, not in the context of "I heard you have a subpoena. Let's talk about it." She raised the issue with me in the context of her desire to avoid testifying, which I certainly understood, not only because there were some embarrassing facts about our relationship that were inappropriate, but also because a whole lot of innocent people were being traumatized and dragged through the mud by these zealous lawyers with their dragnet strategy. And so I -- and since she didn't know Paula Jones and knew nothing about sexual harassment and certainly had no experience with that, I clearly understood why she didn't want to be a part of it.

OIC ATTORNEY: And you didn't want her to testify, did you? You didn't want her to disclose these embarrassing facts of this inappropriate, intimate relationship that you had; is that correct?

PRESIDENT CLINTON: Well, I did not want her to have to testify and go through that. And of course I had -- I didn't want her to do that. Of course not.

OIC ATTORNEY: Did you want those facts -- not only the fact that she would testify, but did you want the facts that she had about your embarrassing, inappropriate, intimate relationship to be disclosed?

PRESIDENT CLINTON: Not there, but not in any context. However, I never had any high confidence that they wouldn't be.

OIC ATTORNEY: Did anyone, as far as you knew, know about your embarrassing, inappropriate, intimate relations that you had with Miss Lewinsky?

PRESIDENT CLINTON: At hat time, I was unaware that she had told anyone else about it, but if -- if I had known that, I would -- it would not have surprised me.

OIC ATTORNEY: Had you told anyone?

PRESIDENT CLINTON: Absolutely not.

OIC ATTORNEY: Had you tried, in fact, not to let anyone else know about this relationship?

PRESIDENT CLINTON: Well, of course.

OIC ATTORNEY: What did you do?

PRESIDENT CLINTON: Well, I never said anything about it, for one thing, and I did what people do when they do the wrong thing. I tried to do it where nobody else was looking (at us ?).

OIC ATTORNEY: How many times did you do that?

PRESIDENT CLINTON: Well, if you go back to my statement, I remember there were a few times in '96 -- I can't say with any certainty -- and there was once in early '97. After she left the White House I do not believe I ever had any inappropriate contact with her in the rest of '96. There was one occasion in '97 when, regrettably, that we were together for a few minutes -- I think about 20 minutes -- and there was inappropriate contact. And after that, to the best of my memory and belief, it did not occur again.

OIC ATTORNEY: Did you tell her -- in the conversation about her being subpoenaed, she was upset about it and you acknowledged that? I'm sorry, you have to expel that from the record.

Yes or no, do you agree that she was upset about being subpoenaed?

PRESIDENT CLINTON: Oh, yes, sir, she was upset. She -- well, she -- we -- she didn't -- we didn't talk about the subpoena, but she was upset. She said, "I don't want to testify. I know nothing about this. I certainly know nothing about sexual harassment. Why do they want me to testify?" And I explained to her why they were doing this and why all these women were on these lists and -- people that they knew good and well had nothing to do with any sexual harassment.

I explained to her that it was a political lawsuit. They wanted to get whatever they could under oath that was damaging to me, and then they wanted to leak it in violation of the judge's orders and turn up their nose and say, "Well, you can't prove we did it." Now that was their strategy.

And they were very frustrated because everything they leaked so far was old news, so they desperately were trying to validate this massive amount of money they had spent by finding some new news.

OIC ATTORNEY: You were familiar --

PRESIDENT CLINTON: And she didn't want to be caught up in that, and I didn't blame her.

OIC ATTORNEY: You were familiar, weren't you, Mr. President, that she had received this subpoena regarding --

PRESIDENT CLINTON: Yes, sir, I was.

OIC ATTORNEY: And Mr. Jordan informed you of that, was that right?

PRESIDENT CLINTON: No, sir. I believe -- and I believe I testified to this in my deposition -- I think the first person who told me that she had been subpoenaed was Bruce Lindsey. I think the first -- and I was -- in this deposition its a little bit cloudy, but I was trying to remember who the first person who told me was, because the question was -- again as I remember it. Could we go to that in the deposition since you asked me that?

OIC ATTORNEY: Actually, I think your -- with all respect -- I think you may be confusing when Mr. Lindsey -- perhaps Mr. Lindsey did tell you that she was subpoenaed. I don't know. But in your deposition, you referred to Mr. Lindsey notifying you that she had been identified as a witness.

PRESIDENT CLINTON: Where is that, sir? I don't want to get -- I just want -- what page is that?

OIC ATTORNEY: Well, actually --

PRESIDENT CLINTON: No, it had to be, because I saw a witness list much earlier than that.

OIC ATTORNEY: Much earlier than December 28th?

PRESIDENT CLINTON: Oh, sure, and earlier than she -- I believe --

OIC ATTORNEY (?): It's page 69.

PRESIDENT CLINTON: I believe Monica Lewinsky's name was on a witness list earlier than she was subpoenaed.

OIC ATTORNEY: Yes.

PRESIDENT CLINTON: So I believe when I was answering this question; at least I thought I was answering when I found out -- yes, see this, on page 68, "Did anyone other than your attorneys ever tell you Monica Lewinsky had been served with a subpoena in this case?"? Then I said, "I don't think so."

Then I -- said, did you ever talk to Monica about the possibility she might be asked to testify in this case? Then I gave an answer that was non-responsive that really tried to finish the answer above. I said, "Bruce Lindsey -- I think Bruce Lindsey told me that she was. I think maybe that's the first person who told me that she was. I want to be as accurate as I can."

And that -- I believe that Bruce is the first person who told me that Monica had gotten a subpoena.

OIC ATTORNEY: Did you in fact have a conversation with Mr. Jordan on the evening of December 19, 1997 in which he talked to you about Monica being in Mr. Jordan's office, bringing a copy of the subpoena and being upset about being subpoenaed?

PRESIDENT CLINTON: I remember that Mr. Jordan was in the White House -- in on December and -- for an event of some kind; that he came up to the residence floor and told me that he had -- that Monica had gotten a subpoena and -- or that Monica was going to have to testify. And I think he told me he recommended a lawyer for her. I believe that's what happened. But it was a very brief conversation. He was there for some other reason.

OIC ATTORNEY: And Mr. Jordan testified that he had also spoken to you at around 5:00 p.m., and the White House phone logs reflect this, that he called you at around the time he met with Ms. Lewinsky and informed you then that she had been subpoenaed. Is that consistent with your memory? Also on the 19th.

PRESIDENT CLINTON: I had a lot of phone conversations with Vernon about this. I didn't keep records of them. I now have some records. My memory is not clear. My tesimony on that was not clear. I just knew that I had talked to Vernon at some time, but I thought that Bruce was the first person who told me.

OIC ATTORNEY: But Mr. Jordan had also told you, is that right?

PRESIDENT CLINTON: Yes, I know now I had a conversation with Mr. Jordan about it where he said something to me about that.

OIC ATTORNEY: And that was probably on the 19th, December 19th?

PRESIDENT CLINTON: Well, I know I saw him on the 19th, so I'm quite sure. And if he says he talked to me on the 19th, I believe he would have better records, and I certainly think he's a truthful person.

OIC ATTORNEY: Getting back to your meeting with Ms. Lewinsky on December 28th. You are aware that she's been subpoenaed. You are aware, are you not, Mr. President, that the subpoena called for the production of, among other things, all the gifts that you had given Ms. Lewinsky. You were aware of that on December 28th, weren't you?

PRESIDENT CLINTON: I'm not sure. And I understand this is an important question. I did have a conversation with Ms. Lewinsky at some time about gifts, the gifts I had given her.

I do not know whether it occurred on the 28th or whether it occurred earlier. I do not know whether it occurred in person or whether it occurred on the telephone. I have searched my memory for this because I know it's an important issue. Perhaps if you -- I can tell you what I remember about the conversation and you can see where I'm having trouble placing the date.

OIC ATTORNEY: Please.

PRESIDENT CLINTON: The reason I'm not sure it happened on the 28th is that my recollection is that Ms. Lewinsky said something to me like, "What if they ask me about the gifts you've given me?" That's the memory I have. That's why I would question whether it happened on the 28th, because she had a subpoena with her, request for production. And I told her that if they asked her for gifts, she'd have to give them whatever she had, that that's what the law was.

And let me also tell you, Mr. Bittman, if you go back and look at my testimony here, I actually asked the Jones lawyers for help on one occasion when they were asking me what gifts I had given her so they could -- I was never hung up about this gift issue. Maybe it's because I have a different experience, but, you know, the president -- I -- gets hundreds of gifts a year, maybe more. I have always given a lot of gifts to people, especially if they give me gifts, and this was no big deal to me. I mean, it's nice, I enjoy it. I gave dozens of personal gifts to people last Christmas. I give gifts to people the time. Friends of mines gives me gifts all the time -- give me ties, give me books, give me everything. So it was just not a big deal.

Continue To Part 3 of the president's testimony.