The Principals
The First Family
Presidential Aides/Advisors/Assistants
Other White House Personnel
Department of Defense Employees
Monica Lewinsky's Friends/Family/Acquaintances
Monica Lewinsky's New York Employment Contacts
Secret Service
Lawyers and Judges
Media
Foreign
Dignitaries
Other
Factual Background
The Investigation
The Significance of the Evidence of Wrongdoing
The Scope of the Referral
1. Background of the Investigation.
2.
Current Status of the Investigation.
I. Nature of President Clinton's Relationship
with Monica Lewinsky
A. Introduction
B. Evidence
Establishing Nature of Relationship
1. Physical Evidence
2. Ms.
Lewinsky's Statements
3. Ms.
Lewinsky's Confidants
4.
Documents
5. Consistency and
Corroboration
C. Sexual Contacts
1. The President's Accounts
a. Jones Testimony
b.
Grand Jury Testimony
2. Ms. Lewinsky's Account
D. Emotional Attachment
E.
Conversations and Phone Messages
F.
Gifts
G. Messages
H. Secrecy
II. 1995: Initial Sexual Encounters
A. Overview of Monica Lewinsky's White House Employment
B. First Meetings with the President
C. November 15 Sexual Encounter
D. November 17 Sexual Encounter
E. December 31 Sexual Encounter
F. President's Account of 1995 Relationship
III. January-March 1996: Continued
Sexual Encounters
A. January 7 Sexual Encounter
B.
January 21 Sexual Encounter
C.
February 4 Sexual Encounter and Subsequent Phone Calls
D. President's Day (February 19) Break-up
E. Continuing Contacts
F. March 31 Sexual Encounter
IV. April 1996: Ms. Lewinsky's Transfer
to the Pentagon
A. Earlier Observations of Ms. Lewinsky in the West Wing
B. Decision to Transfer Ms. Lewinsky
C. Ms. Lewinsky's Notification of Her
Transfer
D. Conversations with
the President about Her Transfer
1. Easter Telephone Conversations and Sexual Encounter
2. April 12-13: Telephone Conversations
V. April-December 1996: No Private
Meetings
A. Pentagon Job
B. No Physical
Contact
C. Telephone
Conversations
D. Public
Encounters
E. Ms. Lewinsky's
Frustrations
VI. Early 1997: Resumption of Sexual
Encounters
A. Resumption of Meetings with the President
1. Role of Betty Currie
a. Arranging Meetings
b.
Intermediary for Gifts
c.
Secrecy
2. Observations by Secret Service Officers
B. Valentine's Day Advertisement
C.
February 24 Message
D. February
28 Sexual Encounter
E. March 29
Sexual Encounter
F. Continuing
Job Efforts
VII. May 1997: Termination of Sexual
Relationship
A. Questions about Ms. Lewinsky's Discretion
B. May 24: Break-up
VIII. June-October 1997: Continuing
Meetings and Calls
A. Continuing Job Efforts
B. July 3
Letter
C. July 4 Meeting
D. July 14-15 Discussions of Linda Tripp
E. July 16 Meeting with Marsha Scott
F. July 24 Meeting
G. Newsweek Article and Its
Aftermath
H. August 16 Meeting
I. Continuing Job Efforts
J. Black Dog Gifts
K. Lucy Mercer Letter and Involvement of
Chief of Staff
L. News of Job
Search Failure
IX. October-November 1997: United
Nations' Job Offer
A. October 10: Telephone Conversation
B.
October 11 Meeting
C. October
16-17: The "Wish List
D.
The President Creates Options
E.
The U.N. Interview and Job Offer
F.
The U.N. Job Offer Declined
X. November 1997: Growing Frustration
A. Interrogatories Answered
B. First
Vernon Jordan Meeting
C.
November 13: The Zedillo Visit
D.
November 14-December 4: Inability to See the President
XI. December 5-18, 1997: The Witness
List and Job Search
A. December 5: The Witness List
B.
December 5: Christmas Party at the White House
C. December 6: The Northwest Gate Incident
1. Initial Visit and Rejection
2.
Ms. Lewinsky Returns to the White House
3. "Whatever Just Happened Didn't
Happen"
D. The President Confers with His Lawyers
E. Second Jordan Meeting
F. Early Morning Phone Call
G. Job Interviews
XII. December 19, 1997 - January 4,
1998: The Subpoena
A. December 19: Ms. Lewinsky Is Subpoenaed
B. December 22: Meeting with Vernon Jordan
C. December 22: First Meeting
with Francis Carter
D. December
23: Clinton Denials to Paula Jones
E. December 28: Final Meeting with the
President
E. December 28:
Concealment of Gifts
D.
December 31: Breakfast with Vernon Jordan
E. January 4: The Final Gift
XIII. January 5-January 16, 1998: The
Affidavit
A. January 5: Francis Carter Meeting
B.
January 5: Call from the President
C. January 6: The Draft Affidavit
D. January 7: Ms. Lewinsky Signs Affidavit
E. January 8: The Perelman Call
F. January 9: "Mission Accomplished"
G. January 12: Pre-Trial Hearing in Jones
Case
H. January 13: References
from the White House
I. January
13: Final Jordan Meeting
J.
January 13-14: Lewinsky-Tripp Conversation and Talking Points
K. January 15: The Isikoff Call
L. January 15-16: Developments in the Jones
Law Suit
XIV. January 17, 1998-Present: The
Deposition and Afterward
A. January 17: The Deposition
B.
The President Meets with Ms. Currie
C. January 18-19: Attempts to Reach Ms.
Lewinsky
D. January 20-22:
Lewinsky Story Breaks
1. "Clinton Accused"
2.
Denials to Aides
3. Initial
Denials to the American Public
4. "We Just Have To Win"
Introduction
I. There is substantial and credible information that President
Clinton lied under oath as a defendant in Jones v. Clinton
regarding his sexual relationship with Monica Lewinsky.
(1) He denied that he had a "sexual relationship"
with
(2) He denied that he had
a "sexual affair" with Monica
(3) He denied that he had "sexual
relations" with Monica
(4) He denied that he engaged in or
caused contact with the
(5)
He denied that he made contact with Monica Lewinsky's
A. Evidence that President Clinton Lied Under Oath During the
Civil Case
1. President Clinton's Statements Under Oath About Monica
Lewinsky
2. Monica Lewinsky's
Testimony
(i) Wednesday, November 15, 1995
(ii) Friday, November 17, 1995
(iii) Sunday, December 31,
1995
(iv) Sunday,
January 7, 1996
(v)
Sunday, January 21, 1996
(vi) Sunday, February 4, 1996
(vii) Sunday, March 31, 1996
(viii) Sunday, April 7, 1996
(ix) Friday, February 28, 1997
(x) Saturday, March 29, 1997
(xi) Two Subsequent Meetings
3. Phone Sex
4. Physical
Evidence
5. Testimony of
Ms. Lewinsky's Friends, Family Members, and Counselors
(i) Catherine Allday Davis
(ii)
Neysa Erbland
(iii)
Natalie Rose Ungvari
(iv)
Ashley Raines
(v)
Andrew Bleiler
(vi) Dr. Irene
Kassorla
(vii) Linda
Tripp
(viii) Debra
Finerman
(ix) Dale
Young
(x) Kathleen
Estep
6. Summary
A. Background
B. The
President's Grand Jury Testimony
C. Summary
A. There is substantial and credible information that President
Clinton lied under oath when he testified that he could not
specifically recall instances in which he was alone with Monica
Lewinsky.
1. The President's Civil Deposition Testimony
2. Evidence That Contradicts the
President's Testimony
3.
The President's Grand Jury Testimony
4. Summary
B. There is substantial and credible information that the
President lied under oath in his civil deposition about gifts he
exchanged with Monica Lewinsky.
1. The President's Civil Deposition Testimony About His
Gifts to Monica Lewinsky
2.
Evidence that Contradicts the President's Civil Deposition
Testimony
3.
President's Civil Deposition Testimony About Gifts from
Monica Lewinsky to the President
4. Evidence that Contradicts the
President's Testimony
5. Grand Jury Testimony of the President and Ms. Currie
6. Summary
A. Conversations with Ms. Lewinsky Regarding the Possibility of
Her Testifying in the Jones Case
1. President Clinton's Testimony in His Deposition
2. Evidence that Contradicts the
President's Civil Deposition Testimony
(i) Ms. Lewinsky's Testimony
(ii) The President's Grand
Jury Testimony
3. Summary
B. There is substantial and credible information that President
Clinton lied under oath in his civil deposition when he denied
knowing that Ms. Lewinsky had received her subpoena at the time he
had last talked to her.
1. Evidence
2. Summary
(i) concealment of gifts that the President had given Ms.
Lewinsky and that were subpoenaed from Ms. Lewinsky in the Jones
case; and
ii) concealment of a
note sent by Ms. Lewinsky to the President on January 5, 1998.
A. Concealment of Gifts
1. Evidence Regarding Gifts
2. The
President's Grand Jury Testimony
3.
Summary of Gifts
B. January 5, 1998, Note to the President
1. Evidence Regarding the January 5, 1998 Note
2. President Clinton's Testimony
3. Summary on January 5, 1998, Note
VI. There is substantial and credible
information that
(i) President Clinton and Ms. Lewinsky had an understanding that
they would lie under oath in the Jones case about their relationship;
and
(ii) President Clinton endeavored
to obstruct justice by suggesting that Ms. Lewinsky file an
affidavit so that she would not be deposed, she would not contradict
his testimony, and he could attempt to avoid questions about Ms.
Lewinsky at his deposition.
A. Evidence Regarding Affidavit and Use of Affidavit
B. Summary of President's Grand Jury Testimony
C. Evidence Regarding Cover Stories
D. The President's Grand Jury Testimony on
Cover Stories
E. Summary
A. Evidence
B. Summary
A. President's Testimony in the Jones Case
B. Evidence That Contradicts the
President's Civil Deposition
C.
Summary
A. Evidence
1. Saturday, January 17, 1998, Deposition
2. Sunday, January 18, 1998, Meeting
with Ms. Currie
3.
Conversation Between the President and Ms. Currie on Tuesday,
January 20, 1998, or Wednesday, January 21, 1998.
B. The President's Grand Jury Testimony
C. Summary
A. The Testimony of Current and Former Aides
1. John Podesta
2. Erskine
Bowles
3. Sidney
Blumenthal
4. Harold Ickes
B. The President's Grand Jury Testimony
C. Summary
A. Beginning on January 21, 1998, the President misled the American
people and Congress regarding the truth of his relationship with Ms.
Lewinsky.
B. The First Lady, the
Cabinet, the President's staff, and the President's associates
relied on and publicly emphasized the President's denial.
C. The President repeatedly and
unlawfully invoked the Executive Privilege to conceal evidence of
his personal misconduct from the grand jury.
D. The President refused six invitations
to testify to the grand jury, thereby delaying expeditious
resolution of this matter, and then refused to answer relevant
questions before the grand jury when he testified in August 1998.
E. The President misled the
American people and the Congress in his public statement on August
17, 1998, when he stated that his answers at his civil deposition in
January had been "legally accurate."
F. Summary