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Text Of Clinton Testimony

Following is the transcript of the President Clinton's testimony to the Ken Starr grand jury.

Mr. President, would you raise your right hand, please? Do you solemnly swear that the testimony you are about to give will be the truth, the whole truth, and nothing but the truth, so help you God?

PRESIDENT CLINTON: I do.

OIC ATTORNEY: Good afternoon, Mr. President.

PRESIDENT CLINTON: Good afternoon.

OIC ATTORNEY: Could you please state your full name for the record, sir?

PRESIDENT CLINTON: William Jefferson Clinton.

OIC ATTORNEY: My name is Sol Wisenberg. I'm a deputy independent counsel with the Office of Independent Counsel. And with me today are some other attorneys from the Office of Independent Counsel. At the courthouse are the ladies and gentlemen of the grand jury prepared to receive your testimony as you give it. Do you understand so?

PRESIDENT CLINTON: Yes, I do.

OIC ATTORNEY: This proceeding is subject to Rule 60 of the Federal Rules of Criminal Procedure. It's modified by Judge Johnson's order. You are appearing voluntarily today, as part of an agreement worked out between your attorney, the Office of the Independent Counsel, and with the approval of Judge Johnson. Is that correct, sir?

PRESIDENT CLINTON: That is correct.

MR. KENDALL: Mr. Weisenberg, excuse me. You refer to Judge Johnson's order. I'm not familiar with that order. Have we been served that, or not?

OIC ATTORNEY: No. My understanding is that that is an order that the judge is going to sign today. She didn't have the name of a -- (inaudible) -- a first person. Basically, my understanding is that it will cover all of the attorneys here today and the technical people -- (off mike). So that they will be authorized persons permitted to hear grand jury testimony that they otherwise wouldn't be authorized to hear.

MR. KENDALL: Thank you.

OIC ATTORNEY: The grand jury, Mr. President, has been impaneled by a United States District Court for the District of Columbia. Do you understand that, sir.

PRESIDENT CLINTON: I do.

OIC ATTORNEY: And among other things they are currently investigating under the authority of the Court of Appeals by application by the attorney general, whether Monica Lewinsky or others obstructed justice, intimidated witnesses, or committed other crimes related to the case of Jones versus Clinton. Do you understand that, sir?

PRESIDENT CLINTON: I do.

OIC ATTORNEY: And today, you will be receiving questions not only from attorneys on the OIC staff, but from some of the grand jury's, too. Do you understand?

PRESIDENT CLINTON: Yes, sir, I do.

OIC ATTORNEY: I'm going to talk briefly about your rights and responsibilities as a grand jury witness. Normally, grand jury witnesses, while not allowed to have attorneys in the grand jury room with them, can stop and consult with their attorneys. There are arrangements today. Your attorneys are here and presenfor consultation. And you can break and consult with them as necessary. But it won't count as our total (time ?). Do you understand that, sir?

PRESIDENT CLINTON: I do understand that.

OIC ATTORNEY: You have a privilege against self- incrimination. If a truthful answer to any question would tend to incriminate you, you can invoke the privilege, and that implication will not be used against you. Do you understand that?

PRESIDENT CLINTON: I do.

OIC ATTORNEY: And if you don't invoke it, however, any answer that you do give, can and will be used against you. Do you understand that?

PRESIDENT CLINTON: I do.

OIC ATTORNEY: Mr. President, do you understand that your testimony here today is under oath?

PRESIDENT CLINTON: I do.

OIC ATTORNEY: And do you understand that because you have sworn to tell the truth, the whole truth, and nothing but the truth, that if you were to lie or intentionally mislead the grand jury, you could be prosecuted for perjury and/or obstruction of justice?

PRESIDENT CLINTON: I believe that's correct.

OIC ATTORNEY: Is there anything that you -- I've stated to you regarding your rights and responsibilities that you would like to clarify that you don't understand?

PRESIDENT CLINTON: No, sir.

OIC ATTORNEY: Mr. President, I would like to read for you a portion of Federal Rules of Evidence 603, which discusses the important function the oath has in our judicial system. It says that the purpose of the oath is one, quote, "calculated to awaken the witness' conscience and press the witness' mind with the duty," end quote, to tell the truth.

Could you please tell the grand jury what that oath means to you for today's testimony?

PRESIDENT CLINTON: I have sworn an oath to the tell the grand jury the truth, and that's what I intended to do.

OIC ATTORNEY: Do you understand that it requires you to give the whole truth, that is, the complete answer to each question, sir?

PRESIDENT CLINTON: I will answer each question as accurately and fully as I can.

OIC ATTORNEY: Now, you took the same oath to tell the truth, the whole truth, and nothing but the truth, on January 17th, 1998, in a deposition in the Paula Jones litigation. Is that correct, sir?

PRESIDENT CLINTON: I did take an oath then.

OIC ATTORNEY: Did the oath you took on that occasion mean the same to you then, as it does to you today?

PRESIDENT CLINTON: I believed then that I had to answer the questions truthfully, that's correct.

OIC ATTORNEY: I'm sorry. I couldn't hear you, sir.

PRESIDENT CLINTON: I believe that I had to answer the questions truthfully, that's correct.

OIC ATTORNEY: And it meant the same to you then as it does today?

PRESIDENT CLINTON: Well, no one read me a definition, and we didn't go through this exercise then. I swore an oath to tell the truth, and I believed I was bound to be truthful, and I tried to be.

OIC ATTORNEY: At the Paula Jone deposition, you were represented by Mr. Robert Bennett, your counsel. Is that correct?

PRESIDENT CLINTON: That is correct.

OIC ATTORNEY: And he was authorized by you to be your representative during your -- (off mike). Is that correct?

PRESIDENT CLINTON: That is correct.

PRESIDENT CLINTON: I do.

OIC ATTORNEY: Now, today you'll be receiving questions not only from attorneys on the OIC staff but from some of the grand jurors, too. Do you understand?

PRESIDENT CLINTON: Yes, sir, I do.

OIC ATTORNEY: I'm going to talk briefly about your rights and responsibilities as a grand jury witness. Normally, grand jury witnesses, while not allowed to have attorneys in the grand jury room with them, can stop and consult with their attorneys. Through our arrangement today, your attorneys are here and present for consultation, and you can break to consult with them as necessary, but it won't count against our total time. Do you understand that, sir?

PRESIDENT CLINTON: I do understand that.

OIC ATTORNEY: You have a privilege against self-incrimination. If the truthful answer to any question would tend to incriminate you, you can invoke the privilege and that invocation will not be used against you. Do you understand that?

PRESIDENT CLINTON: I do.

OIC ATTORNEY: And if you don't invoke it, however, any answer that you do give can and will be used against you. Do you understand that, sir?

PRESIDENT CLINTON: I do.

OIC ATTORNEY: Mr. President, you understand that your testimony here today is under oath?

PRESIDENT CLINTON: I do.

OIC ATTORNEY: And do you understand that because you have sworn to tell the truth, the whole truth and nothing but the truth, that if you were to lie or intentionally mislead the grand jury, you could be prosecuted for perjury and/or obstruction of justice?

PRESIDENT CLINTON: I believe that's correct.

OIC ATTORNEY: Is there anything that you -- I've stated to you regarding your rights and responsibilities that you would me to clarify or that you don't understand?

PRESIDENT CLINTON: No, sir.

OIC ATTORNEY: Mr. President, I'd like to read for you a portion of Federal Rule of Evidence 603 which discusses the important function the oath has in our judicial system. It says that the purpose of the oath is one, quote, "calculated to awaken the witness's conscience and impress the witness's mind with the duty," end quote, to tell the truth. Could you please tell the grand jury what that oath means to you for today's testimony?

PRESIDENT CLINTON: I have sworn an oath to tell the grand jury the truth and that's what I intend to do.

OIC ATTORNEY: Do you understand it requires you to give the whole truth; that is, a complete answer to each question, sir?

PRESIDENT CLINTON: I will answer each question as accurately and fully as I can.

OIC ATTORNEY: Now, you took the same oath to tell the truth, the whole and truth and nothing but the ruth on January 17th, 1998, in a deposition in the Paula Jones litigation, is that correct, sir?

PRESIDENT CLINTON: I did take an oath then.

OIC ATTORNEY: Did the oath you took on that occasion mean the same to you then as it does today?

PRESIDENT CLINTON: I believed then that I had to answer the questions truthfully, that's correct.

OIC ATTORNEY: I'm sorry -- I didn't hear you, sir?

PRESIDENT CLINTON: I believed that I had to answer the questions truthfully, that's correct.

OIC ATTORNEY: And -- and it meant the same to then as it does today?

PRESIDENT CLINTON: Well, no one read me a definition, and we didn't go through this exercise then. I swore an oath to tell the truth, and I believed that I was bound to be truthful and I tried to be.

OIC ATTORNEY: All right. At the Paula Jones deposition, you were represented by Mr. Robert Bennett, your counsel, is that correct?

PRESIDENT CLINTON: That is correct.

OIC ATTORNEY: He was authorized by you to be your representative there, your attorney, is that correct?

PRESIDENT CLINTON: That is correct.

OIC ATTORNEY: Your counsel, Mr. Bennett, indicated that page five of the deposition, lines 10 through 12, I'm quoting, "The president intends to give full and complete answers as Miss Jones is entitled to have," end quote. My question to you is, do you agree with your counsel that a plaintiff in a sexual harassment case is, to use his words, "entitled to have" the truth?

PRESIDENT CLINTON: I believe that I was bound to give truthful answers. Yes, sir.

OIC ATTORNEY: But the question is, sir, do you agree with your counsel that a plaintiff in a sexual harassment case is entitled to have the truth?

PRESIDENT CLINTON: I believe when a witness is under oath in a civil case or otherwise under oath, the witness should do everything possible to answer the questions truthfully.

OIC ATTORNEY: I'm going to turn over questioning now to Mr. Bittman of our office, Mr. President.

OIC ATTORNEY: Good afternoon, Mr. President.

PRESIDENT CLINTON: Good afternoon, Mr. Bittman.

OIC ATTORNEY: My name is Robert Bittman; I'm an attorney with the Office of Independent Counsel. Mr. President, we are first going to turn to some of the details of your relationship with Monica Lewinsky that follow on your deposition that you provided in the Paula Jones case as was referenced, on January 17th, 1998.

(The) questions are uncomfortable, and I apologize for that in advance. I will try to be as brief and direct as possible.

Mr. President, were you physically intimate with Monica Lewinsky?

PRESIDENT CLINTON: Mr. Bittman, I think maybe I can save the -- you and the grand jurors a lot of time if I read a statement which I think will make it clear what the nature of my relationship with Miss Lewinsky was, how it related to the testimony I gave, what I was trying to do in that testimony, and I think it will perhaps make it possible for ou to ask even more relevant questions, from your point of view. And with your permission, I'd like to read that statement.

OIC ATTORNEY: Absolutely. Please, Mr. President.

PRESIDENT CLINTON: When I was alone with Miss Lewinsky on certain occasions in early 1996 and once in early 1997 I engaged in conduct that was wrong. These encounters did not consist of sexual intercourse. They did not constitute sexual relations as I understood that term to be defined at my January 17th, 1998 deposition.

OIC ATTORNEY: Your counsel, Mr. Bennett, indicated that -- page 5 of the deposition, lines 10 through 12, I'm quoting, "The President intends to give full and complete answers as Ms. Jones is entitled to have," end quote.

My question to you is, do you agree with your counsel that a plaintiff in a sexual harassment case is, to use his words, entitled to have the truth?

PRESIDENT CLINTON: I believe that I was bound to give truthful answers, yes, sir.

OIC ATTORNEY: But the question is, sir, do you agree with your counsel that a plaintiff in a sexual harassment case, is entitled to have the truth.

PRESIDENT CLINTON: I believe when a witness is under oath in a civil case, or otherwise under oath, that the witness should do everything possible to answer the questions truthfully.

OIC ATTORNEY: I'm going to turn over questioning now to Mr. Bittman from our office, Mr. President.

OIC ATTORNEY: Good afternoon, Mr. President.

PRESIDENT CLINTON: Good afternoon, Mr. Bittman.

OIC ATTORNEY: My name is Robert Bittman. I'm attorney with the Office of Independent Counsel. Mr. President, we are first going to turn to some of the details of your relationship with Monica Lewinsky, to follow up on your deposition that you provided in the Paula Jones case as -- (inaudible) -- referenced on January 17th, 1998.

The questions are uncomfortable, and I apologize for that in advance. I will try to be as brief and direct as possible.

Mr. President, were you physically intimate with Monica Lewinsky?

PRESIDENT CLINTON: Mr. Benton, I think maybe I can save the - - you and the grand jury a lot of time, if I read a statement which I think will make it clear what the nature of my relationship with Ms. Lewinsky was, and how it related to the testimony I gave, what I was trying to do in that testimony. And I think it will perhaps make it possible for you to ask even more relevant questions, from your point of view. And, with your permission, I'd like to read that statement.

MR. BITTMAN: Absolutely. Please, Mr. President.

PRESIDENT CLINTON: (Reading from statement.) "When I was alone with Ms. Lewinsky on certain occasions in early 1996, and once in early 1997, I engaged in conduct that was wrong. These encounters did not consist of sexual intercourse. They did not constitute sexual relations as I understood that term to be defined, at my January 17th, 1998 deposition, but they did involve inappropriate, inimate contact. These inappropriate encounters ended at my insistence in early 1997. I also had occasional telephone conversations with Miss Lewinsky that included inappropriate sexual banter.

I regret that what began as a friendship came to include this conduct, and I take full responsibility for my actions. While I will provide the grand jury whatever other information I can, because of privacy considerations affecting my family, myself, and others, and in an effort to preserve the dignity of the office I hold, this is all I will say about the specifics of these particular matters.

I will try to answer to the best of my ability other questions, including questions about m relationship with Miss Lewinsky, questions about my understanding of the term "sexual relations" as I understood it to be defined at my January 17th, 1998 deposition, and questions concerning alleged subornation of perjury, obstruction of justice, and intimidation of witnesses.

That, Mr. Bittman, is my statement.

OIC ATTORNEY: Thank you, Mr. President, and with that we would like to take a break.

PRESIDENT CLINTON: Would you like to have this?

OIC ATTORNEY: Yes, please. Matter of fact, why don't we have that marked as Grand Jury Exhibit WJC-1.

PRESIDENT CLINTON: So, we're going to take a break?

OIC ATTORNEY: Yeah, we'll take a break. Can we have the camera off, now, please?

(Break.)

MR. : Go ahead.

OIC ATTORNEY: Mr. President, your statement indicates that you -- your contacts with Miss Lewinsky did not involve a -- inappropriate, intimate contact.

MR. : Mr. Bittman --

PRESIDENT CLINTON: No, sir, it indicates that it DID involve inappropriate, intimate contact.

OIC ATTORNEY: They did involve inappropriate intimate contact.

PRESIDENT CLINTON: Yes, they did.

MR. : Mr. Bittman, the witness does not have a copy of the statement. (Pause.) Thank you.

OIC ATTORNEY: Was this contact with Ms. Lewinsky, Mr. President -- did it involve any sexual contact in any way, shape or form?

PRESIDENT CLINTON: Mr. Bittman, I said in the statement I would like to stay to the terms of the statement. I think it's clear what inappropriately intimate is. I have said what it did not include. It did not include sexual intercourse, and I do not believe it included conduct which falls within the definition I was given in the Jones deposition. And I would like to stay with that characterization.

OIC ATTORNEY: Let's, then, move to the definition that was provided to you during your deposition. We'll have that marked as Grand Jury Exhibit WJC-2. This is an exact copy, Mr. President, of the exhibit that was provided to you during that deposition. And I'm sure you remember from the deposition that paragraph one of the definition remained, and in fact Judge Wright ruled that that was to be the guiding definition, and that paragraphs two and three were stricken. Do you remember that, Mr. Presidnt?

PRESIDENT CLINTON: Yes. Specifically what I remembered is there were two different discussions, I think, of this. There was quite an extended one in the beginning, and everybody was entering into it, and then in the end the judge said that she would take -- (clearing his throat) -- excuse me -- the first definition and strike the rest of it. That's my memory.

OIC ATTORNEY: Did you -- well, at page 19 of your deposition in the case, the attorney who provided you with the definition asked you would you please take whatever time you need to read the definition. And later on in the deposition, you did, of course, refer to the definition several times. Were you during the deposition familiar with the definition?

PRESIDENT CLINTON: Yes, sir. My -- let me just ask a question. If you're going to ask me about my deposition, could I have a copy of it? Does anybody have a copy of it?

OIC ATTORNEY: I have a copy. We'll provide you with a copy.

MS. : And for the record, it is Grand Jury Exhibit WJC-3.

(The president is given a copy.)

PRESIDENT CLINTON: Now, you say that was on page 19, Mr. Bittman?

OIC ATTORNEY: Page 19, Mr. President, beginning at line 21. And I'll read it in full. This is from the Jones attorney.

Would you please take whatever time you need to read this definition, because when I use the term "sexual relations," this is what I mean today.

(Long pause here for reading of definition of "sexual relations.")

PRESIDENT CLINTON: Yes, sir. That starts on 19. And let me say that there is a -- just for the record, my recollection was accurate -- there was a long discussion here between the attorneys and the judge. It goes on till page 23. And in the end, the judge says, "I am talking only about part one and the definition"; and, "Do you understand that?" And I answered, "I do."

And the judge says "part one," and then the lawyer for Ms. Jones says, "He is only talking about part one." They asked me if I understand it. I say, "I do." And that was my understanding.

I might also note that, when I was given this and began to ask questions about it, I actually circled number one. This is my circle here. I remember doing that so I could focus only on those two lines, which is what I did.

OIC ATTORNEY: Did you understand the words in the first portion of the exhibit, Mr. President; that is, "For the purposes of this deposition, a person engages in" -- quote, unquote -- "sexual relations when the person knowingly engages in or causes"? Do you understand the words there in that phrase?

PRESIDENT CLINTON: Yes. I can tell you what my understanding of the definition is if you want me to do it.

OIC ATTORNEY: Sure.

PRESIDENT CLINTON: My understanding of this definition is that it covers contact by the person being deposed with the enumerated areas "if the contact is done with an intent to arouse or gratify." That's my understanding of the definition.
OIC ATTORNEY: What did you believe the definition to include and exclude? What kinds of activity?

PRESIDENT CLINTON: I felt the definition included any activity by the person being deposed where the person was the actor and came in contact with those parts of the bodies with the purpose of intent for gratification and excluded any other activity. For example, kissing's not covered by that, I don't think.

OIC ATTORNEY: Did you understand the definition to be limited to sexual activity?

PRESIDENT CLINTON: Yes, I understood the definition to be limited to physical contact with those areas of the body with the specific intent to arouse or gratify. That's what I understood it to be.

OIC ATTORNEY: What specific acts did the definition include as you understood the definition on January 17, 1998?

PRESIDENT CLINTON: Any contact with the areas there mentioned, sir. If you contacted the -- if you contacted those parts of the body with an intent to arouse or gratify, that is covered.

OIC ATTORNEY: What did you understand --

PRESIDENT CLINTON: The person being deposed. If the person being deposed contacted those parts of another person's body with an intent to arouse or gratify, that was covered.

OIC ATTORNEY: What did you understand the word "causes" in the first phrase? That is, "For the purposes of this deposition, a person engages in sexual relations when the person knowingly causes contact."

PRESIDENT CLINTON: I don't know what that means. It doesn't make any sense to me in this context because I think what I thought there was that since this was some sort of -- as remember, they said in the previous discussion, and I'm only remembering now, so if I make a mistake, you can correct me -- as I remember from the previous discussion, they said this was some kind of definition that had something to do with sexual harassment. So that implies as forcing to me, and I -- there was never any issue of forcing in the case involving -- well, any of these questions they were asking me. They made it clear in this discussion I just reviewed that what they were referring to was intentional sexual conduct, not some sort of forcible, abusive behavior.

So I basically -- I don't think I paid any attention to it because it appeared to me that that was something that had no reference to the facts that they admitted they were asking me about.

OIC ATTORNEY: So if I can be clear, Mr. President, is it your understanding back in January that the definition now marked as Grand Jury Exhibit 2 only included consensual sexual activity?

PRESIDENT CLINTON: Now my understanding -- let me go back and say -- my understanding, I'll tell you what it did include. My understanding was, when I was given it, was that what was covered in those first two lines was any direct contact by the person being deposed with those parts of another person's body if the contact was done "with an intent to arouse or gratify." That's whaI believed it meant. That's what I believed it meant then, and that's what I believe it means today.

OIC ATTORNEY: I am just trying to understand it. Mr. President, you indicated that -- put the definition in the context of a sexual harassment case.

PRESIDENT CLINTON: No, no. I think it was not in the context of sexual harassment. I just reread those four pages, which obviously the grand jury doesn't have. But there was some reference to the fact that this definition apparently -- had some connection to some definition in another context and that this was being used not in that context, not necessarily in the context of sexual harassment. So I would think that this "causes" would mean "to force someone to do something." That's what I read it. That's the only point I am trying to make.

Therefore, I did not believe that anyone had ever suggested that I had forced anyone to do anything -- and I did not do that -- and so that could not have had any bearing on any questions related to Ms. Lewinsky.

OIC ATTORNEY: I suppose since you have now read portions of the transcripts again, that you were reminded that you did not ask for any clarification of the terms -- is that correct -- of the definition?

PRESIDENT CLINTON: No, sir. When I read it, I thought it was rather strange with that definition, but it was the one the judge decided on. And I was bound by it, so I took it.

OIC ATTORNEY: During the deposition, you remembered that Ms. Lewinsky's name came up, and you were asked several questions about her. Do you remember that?

PRESIDENT CLINTON: Yes, sir, I do.

OIC ATTORNEY: During -- before those questions actually got started, your attorney Mr. Bennett objected to any questions about Ms. Lewinsky. And he represented to Judge Wright, who was presiding -- that was unusual, wasn't it, that a federal judge would come and actually -- in your experience -- that a federal judge would come and preside at a deposition?

MR. : Just a minute. Excuse me. Could you identify the transcript page from which Mr. Bennett objected to all testimony about Ms. Lewinsky before it got started?

OIC ATTORNEY: Objection. This quote that I am referring to is going to begin on page 54 of the deposition.

MR. : That is into the testimony, after the testimony about Ms. Lewinsky has begun, is it not?

OIC ATTORNEY: Mr. President, is it unusual for a federal judge to preside over a civil deposition?

PRESIDENT CLINTON: I think it is, but this was an unusual case. I believe I know why she did it.

OIC ATTORNEY: Your attorney, Mr. Bennett, objected to the questions about Ms. Lewinsky, didn't he?

PRESIDENT CLINTON: What page is that on, sir?

OIC ATTORNEY: Page 54, where he questions whether the attorneys for Ms. Jones had a good-faith basis to ask some of the questions that they were posing to you. His objections actually begin on page 53. Since, as the president pointed out, the grand juros correctly do not have a copy of the deposition, I will read the portion that I'm referring to, and this begins at line one on page 54.

"I question the good faith of counsel" -- the innuendo of the question -- "counsel is fully aware that Ms. Lewinsky has filed -- has an affidavit which they are in possession of saying that there is absolutely no sex of any kind in any manner, shape or form with President Clinton."

PRESIDENT CLINTON: Where is that?

OIC ATTORNEY: That is on page 54 Mr. President, beginning at line one, about midway through line one.

PRESIDENT CLINTON: Well, actually, in the present tense, that's an accurate statement. That was an accurate statement if -- I don't -- I think what Mr. Bennett was concerned about, if I -- maybe it would be helpful to you and to the grand jurors, quite apart from these comments, if I could tell you what his state of mind was, what my state of mind was, and why I think the judge was there in the first place. If you don't want me to do it, I won't, but I think it will help to explain a lot of this.

OIC ATTORNEY: Well, we are interested -- I know, from the questions that we've received from the grand jurors, they are interested in knowing what was going on in your mind when you were reading Grand Jury Exhibit 2, and what you understood that definition to include.

Our question goes to whether -- and you were familiar -- and what Mr. Bennett was referring to obviously was Ms. Lewinsky's affidavit. And we'll have that marked, Mr. President, as Grand Jury Exhibit WJC-4. And you remember that Ms. Lewinsky's affidavit said that she had had no sexual relationship with you. Do you remember that?

PRESIDENT CLINTON: I do.

OIC ATTORNEY: Do you remember in the deposition that Mr. Bennett asked you about that? This was towards the end of the deposition. And he asked you whether the statement that Ms. Lewinsky made in her affidavit was -- (after a pause) -- true.

PRESIDENT CLINTON: -- truthful.

OIC ATTORNEY: And you indicated that it was absolutely correct?

Continue To Part 2 of the president's testimony.

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