Sue Hartigan <[EMAIL PROTECTED]> writes:
Q. Well, you would not check off someone's name approving the
appointment if you had some reason to question the trustworthiness of
the
individual, would you?
A. No.
Q. And to your own knowledge, did Kathleen Willey have a reputation
while working in the White House with respect to her character for
truthfulness?
A. No. I only know, the only thing that, the only conversation I ever
had
with her that amounted to anything was this conversation which lasted
about 10 minutes, maybe a little more, and I didn't doubt that she was
telling the truth about what she was talking about, but I didn't know
her
well enough to draw a final conclusion about whether she was generally
truthful or not.
Q. Was that the first conversation that you ever had with her?
A. I think it was the first � I mean I had talked to her in passing, you
know. She was, as I said, she was in Virginia when I was there in the
campaign, and I'd had conversations with her, but that's the first time
I'd
ever actually sat and talked with her, to the best of my knowledge. She
was around when we did the presidential debate in Richmond. She was
around that, you know, working in that, and I would talk to her, and she
was always very friendly and very nice, but that conversation, I
remember
this conversation very vividly because she was so agitated and she
seemed
to be in very difficult straits.
Q. But you don't remember any earlier conversation other than just
casual
conversation?
A. Yeah, I'm sure I had casual conversation with her. I knew who she
was and she was always there when we were there in Virginia.
Regarding Monica S. Lewinsky
Q. Now, do you know a woman named Monica Lewinsky?
A. I do.
Q. How do you know her?
A. She worked in the White House for a while, first as an intern, and
then
in, as the, in the legislative affairs office. . . . So that's how I
know her.
Q. . . . Did she begin to work as an intern in the White House in the
summer of 1995?
A. I don't know when she started working at the White House.
Q. Do you recall when you met her for the first time?
A. It would be sometime, I'd think, in later 1995. . . .
Q. Did you ever talk to anyone about the possibility of her obtaining a
job
in the White House?
A. She, she came there as an intern, and as several of them have, she
applied for some job there apparently and got the job. I was not
involved
in her moving from being an intern to being a full-time employee. I had
no
involvement in that whatever. . . .
Q. Is it true that when she worked at the White House she met with you
several times?
A. I don't know about several times. There was a period when the, when
the Republican Congress shut the government down that the whole White
House was being run by interns, and she was assigned to work back in
the chief of staff's office, and we were all working there, and so I saw
her
on two or three occasions then, and then when she worked at the White
House, I think there was one or two other times when she brought some
documents to me. . . .
Q. Mr. President. . . . At any time were you and Monica Lewinsky alone
together in the Oval Office?
A. I don't recall, but as I said, when she worked at the legislative
affairs
office, they always had somebody there on the weekends. I typically
worked some on the weekends. Sometimes they'd bring me things on the
weekends. She � it seems to me she brought things to me once or twice
on the weekends. In that case, whatever time she would be in there, drop
it off, exchange a few words and go, she was there. . . .
Q. Did it ever happen that you and she went down the hallway from the
Oval Office to the private kitchen. . . .
A. Well, let me try to describe the facts first, because you keep
talking
about this private kitchen. The private kitchen is staffed by two naval
aides. They have total, unrestricted access to my dining room, to that
hallway, to coming into the Oval Office. The people who are in the outer
office of the Oval Office can also enter at any time.
I was, after I went through a presidential campaign in which the far
right
tried to convince the American people I had committed murder, run drugs,
slept in my mother's bed with four prostitutes, and done numerous other
things, I had a high level of paranoia.
There are no curtains on the Oval Office, there are no curtains on my
private office, there are no curtains or blinds that can close the
windows in
my private dining room. The naval aides come and go at will. There is a
peephole on the office that George Stephanopoulos first and then Rahm
Emanuel occupied that looks back down that corridor. I have done
everything I could to avoid the kind of questions you are asking me here
today, so to talk about this kitchen as if it is a private kitchen, it's
a
little
cubbyhole, and these guys keep the door open. They come and go at will.
Now that's the factual background here.
Now, to go back to your question, my recollection is that, that at some
point during the government shutdown, when Ms. Lewinsky was still an
intern but was working the chief staff's office because all the
employees
had to go home, that she was back there with a pizza that she brought to
me and to others. I do not believe she was there alone, however. I don't
think she was. And my recollection is that on a couple of occasions
after
that she was there but my secretary Betty Currie was there with her. . .
.
Q. Have you ever met with Monica Lewinsky in the White House
between the hours of midnight and six a.m.?
A. I certainly don't think so. . . . Now, let me just say, when she was
working there, during, there may have been a time when we were all � we
were up working late. There are lots of, on any given night, when the
Congress is in session, there are always several people around until
late in
the night, but I don't have any memory of that. I just can't say that
there
could have been a time when that occurred, I just � but I don't remember
it.
Q. Certainly if it happened, nothing remarkable would have occurred?
A. No, nothing remarkable. I don't remember it.
Q. It would be extraordinary, wouldn't it, for Betty Currie to be in the
White House between midnight and six a.m., wouldn't it?
A. I don't know what the facts were. I mean I don't know. She's an
extraordinary woman.
Q. Does that happen all the time, sir, or rarely?
A. Well, I don't know, because normally I'm not there between midnight
and six, so I wouldn't know how many times she's there. Those are
questions you'd have to ask her. I just can't say.
Q. Has it ever happened that a White House record was created that
showed the Monica Lewinsky was meeting with Betty Currie when in fact
Monica Lewinsky was meeting with you. . . .
A. Not to my knowledge.
Q. Are there records created of your meetings with people in the White
House?
A. I believe we have a record of the people that, that see me. We have �
I think there's a record of everybody that comes in and out of the White
House. . . .
Q. When was the last time you spoke with Monica Lewinsky?
A. I'm trying to remember. Probably sometime before Christmas. She
came by to see Betty sometime before Christmas. And she was there
talking to her, and I stuck my head out, said hello to her.
Q. Stuck your head out of the Oval Office?
A. Uh-huh, Betty said she was coming by and talked to her, and I said
hello to her.
Q. Was that shortly before Christmas or �
A. I'm sorry, I don't remember. Been sometime in December, I think, and
I believe � that may not be the last time. I think she came to one of
the,
one of the Christmas parties.
Q. Did she tell you she had been served with a subpoena in this case?
A. No. I don't know if she had been.
Q. Did anyone other than your attorneys ever tell you that Monica
Lewinsky had been served with a subpoena in this case?
A. I don't think so.
Q. Did you ever talk with Monica Lewinsky about the possibility that she
might be asked to testify in this case?
A. Bruce Lindsey, I think Bruce Lindsey told me that she was, I think
maybe that's the first person told me she was. I want to be as accurate
as
I can.
[Robert Bennett, the president's attorney]: Keep your voice up Mr.
President.
Q. Did you talk to Mr. Lindsey about what action, if any, should be
taken
as a result of her being served with a subpoena?
A. No. . . .
Q. Have you ever talked to Monica Lewinsky about the possibility that
she might be asked to testify in this lawsuit?
A. I'm not sure, and let me tell you why I'm not sure. It seems to me
the,
the, the � I want to be as accurate as I can here. Seems to me the last
time she was there to see Betty before Christmas we were joking about
how you-all, with the help of the Rutherford Institute, were going to
call
every woman I'd ever talked to, and I said, you know �
Bennett: We can't hear you, Mr. President.
A. And I said that you-all might call every woman I ever talked to and
ask
them that, and so I said you would qualify, or something like that. I
don't, I
don't think we ever had more of a conversation than that about it, but I
might have mentioned something to her about it, because when I saw how
long the witness list was, or I heard about it, before I saw, but
actually by
the time I saw it her name was in it, but I think that was after all
this had
happened. I might have said something like that, so I don't want to say
for
sure I didn't, because I might have said something like that. . . .
Q. What, if anything, did Monica Lewinsky say in response?
A. Nothing that I can remember. Whatever she said, I don't remember.
Probably just some predictable thing. . . .
Q. Excluding conversations that you may have had with Mr. Bennett or
any of your attorneys in this case, within the past two weeks has anyone
reported to you that they had had a conversation with Monica Lewinsky
concerning this lawsuit?
A. I don't believe so. I'm sorry, I just don't believe so.
Q. You know a man named Vernon Jordan?
A. I know him well.
Q. You've known him for a long time.
A. A long time.
Q. Has it ever been reported to you that he met with Monica Lewinsky
and talked about this case?
A. I knew that he met with her. I think Betty suggested that he meet
with
her. Anyway, he met with her. I, I thought that he talked to her about
something else. I didn't know that � I thought he had given her some
advice about her move to New York. Seems like that's what Betty said. .
. .
Q. What do you know about her moving to New York?
A. Just that.
Q. Is she going to move to New York?
A. I don't know. She may have already moved to New York. I don't
know. My understanding was that her mother moved to New York and
that she was going to move to New York and that she was looking for
some advice about what she should do when she got there.
Q. Is it your understanding that she was offered a job at the U.N.?
A. I know that she interviewed for one. I don't know if she was offered
one or not.
Q. Have You ever talked to [U.N. Ambassador] Bill Richardson about
Monica Lewinsky?
A. No. . . .
Q. Have you ever asked anyone to talk to Bill Richardson about Monica
Lewinsky?
A. I believe that, I believe that Monica, what I know about that is I
believe Monica asked Betty Currie to ask someone to talk to him, and
she, and she talked to him and went to an interview with him. That's
what
I believe happened. . . .
Q. Well, have you ever given any gifts to Monica Lewinsky?
A. I don't recall. Do you know what they were?
Q. A hat pin?
A. I don't, I don't remember. But I certainly, I could have.
Q. A book about Walt Whitman?
A. I give � let me just say, I give people a lot of gifts, and when
people
are around I give a lot of things I have at the White House away, so I
could have given her a gift, but I don't remember a specific gift.
Q. Do you remember giving her a gold brooch?
A. No.
Q. Do you remember giving her an item that had been purchased from
The Black Dog store at Martha's Vineyard?
A. I do remember that, because when I went on vacation, Betty said that,
asked me if I was going to bring some stuff back from The Black Dog,
and she said Monica loved, liked that stuff and would like to have a
piece
of it, and I did a lot of Christmas shopping from The Black Dog, and I
bought a lot of things for a lot of people, and I gave Betty a couple of
the
pieces, and she gave I think something to Monica and something to some
of the other girls who worked in the office. I remember that because
Betty
mentioned it to me. . . .
Q. Has Monica Lewinsky ever given you any gifts?
A. Once or twice. I think she's given me a book or two.
Q. Did she give you a silver cigar box?
A. No.
Q. Did she give you a tie?
A. Yes, she had given me a tie before. I believe that's right. . . .
Q. Did you have an extramarital sexual affair with Monica Lewinsky?
A. No.
Q. If she told someone that she had a sexual affair with you beginning
in
November of 1995, would that be a lie?
A. It's certainly not the truth. It would not be the truth.
Q. I think I used the term "sexual affair." And so the record is
completely
clear, have you ever had sexual relations with Monica Lewinsky, as that
term is defined in Deposition Exhibit 1, as modified by the Court. . . .
A. I have never had sexual relations with Monica Lewinsky. I've never
had an affair with her.
Q. Have you ever had a conversation with Vernon Jordan in which
Monica Lewinsky was mentioned?
A. I have. He told me that he called � he mentioned in passing to me
that
he had talked to her, and she had come to him for advice about moving to
New York. . . .
Q. What did he say that she had said to him in response?
A. He just said she seemed like a bright, energetic young woman and she
had certain interests, and he made some suggestions to her and suggested
where she ought to go for interviews. That's all I know about that. . .
.
Q. Did you do anything, sir, to prompt this conversation to take place
between Vernon Jordan and Monica Lewinsky?
A. I can tell you what my memory is. My memory is that Vernon said
something to me about her coming in, Betty had called and asked if he
would see her and he said she would, he said he would, and then she
called him and then he said something to me about it. I'm sure if he
said
something to me about it I said something positive about it. I wouldn't
have said anything negative about it. I didn't have any negative
knowledge.
I mean there would be no reason for me to be negative about it. Vernon
liked to help people. He was always trying to help people.
Q. My question, though, is focused on the time before the conversation
occurred, and the question is whether you did anything to cause the
conversation to occur.
A. I think in the mean � I'm not sure how you mean the question. I think
the way you mean the question, the answer to that is no, I've already
testified. . . .
Q. Have you ever had a conversation with Vernon Jordan in which Paula
Jones was mentioned?
A. I'm sure I have. I don't remember what it would have been, but I'm
sure I have. I mean after all this time, I'm sure I have.
[Bill Bristow, attorney for Clinton co-defendant Danny Ferguson]:
Your Honor, I just think we should note for the record that it is now
almost 12:30, and to my knowledge this is the first moment in the
deposition that the word "Paula Jones" has been mentioned. . . .
Q. Mr. President, have you ever paid any money to Monica Lewinsky?
A. No, sir.
Q. Have you ever caused money to be paid to her?
A. Absolutely not.
Q. Have you ever paid off any debt that she owed to some other person?
A. No, sir.
Q. Have you ever caused a debt that she owed to some other person to
be repaid?
A. No, sir. . . .
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