Q. My name is Robert Bittman. I'm an attorney with the Office of Independent Counsel. ... Mr. President, were you physically intimate with Monica Lewinsky?

A. 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 Ms. Lewinsky was. And with your permission, I'd like to read that statement.

Q. Absolutely. Please, Mr. President.

A. 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 [in the Paula Jones sexual harassment case].

But they did involve inappropriate, intimate contact. These inappropriate encounters ended at my insistence in early 1997. I also had occasional telephone conversations with Ms. 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 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 my relationship with Ms. Lewinsky, questions about my understanding of the term of 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.

Q. Mr. President, your statement [in his deposition in the Jones case] indicates that your contacts with Ms. Lewinsky did not involve any inappropriate intimate contact ...

A. No, sir, it indicates that it did ... (inaudible) ... inappropriate intimate contact.

Q. OK, it did involve inappropriate intimate contact.

A. Yes, sir, it did. ...

Q. Do you remember in the deposition that Mr. [Robert S.] Bennett [Clinton's lawyer] asked you about that? ... [H]e asked you whether the statement that Ms. Lewinsky made in her affidavit [denying any sexual relationship with the president] was true. And you indicated that it was absolutely correct.

A. I did. And at the time that she made the statement . . . 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 most ordinary Americans would give it.

If you said Jane and Harry had a sexual relationship and they're not talking about people being drawn into a lawsuit and being given a definition and then a great effort to trick them in some way but you're just talking about people in an ordinary conversation, I 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'm not at all sure that this affidavit is not true and was not true in Ms. Lewinsky's mind at the time she swore (inaudible) it out. ...

Q. So your definition of sexual relationship is intercourse only, is that correct?

A. No, not necessarily intercourse only, but it would include intercourse. I believe 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 what Ms. Lewinsky thought, then this is a truthful affidavit ...

Q. Well, if you do you agree with me that he [Bennett] misled [U.S. District Judge Susan Webber] 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're saying?"

A. 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. . . . By the time this discovery started, they knew they had a base 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 to have this dragnet of discovery.

They wanted to cover everybody. ... And so with that broad mandate, limited by time and employment in the federal, 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 the deal was in that case. And they knew what was going to happen. Judge Wright subsequently threw it out.

What they...

Q. But...

A. Now let me finish, Mr. Bennett. You've got I mean, you brought this up.

Excuse me, Mr. Bittman. What they wanted to do and what they did do and what they have 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.

... And so they just thought that they would take a wrecking ball to me and see if they could do some damage. ...

Q. Was it your responsibility to answer those questions truthfully, Mr. President?

A. It was. But it was not my responsibility, in the face of their repeated illegal leaking, it was not my responsibility to volunteer a lot of information.

Q. Do you know that now?

A. No, I don't. I just know . . . 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. ...

Q. Let me ask you, Mr. President, you indicate in your statement that you were alone with Ms. Lewinsky. Is that right?

A. Yes, sir.

Q. How many times were you alone with Ms. Lewinsky?

A. 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...

Q. How many times, do you think?

A. ... I remember specifically ...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 ... that 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.

...

On Monica Lewinsky being subpoenaed in the Paula Corbin Jones lawsuit:

Q. Do you believe that Ms. Lewinsky was at the White House and saw you on December 28th, '97?

A. Yes, sir, I do.

Q. And do you remember talking with Ms. Lewinsky about her subpoena to appear in the Paula Jones case on that day?

A. I remember talking with Ms. Lewinsky about her testimony or about the prospect that she might have to give testimony. And she she talked to me about that. I remember that.

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

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

Q. [Y]ou gave her the most gifts that you had ever given her in a single day. Is that right?

A. Yes, that's probably true. . . . I just thought I ought to get up a few things and give them to her before she left.

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

A. No, sir, that's 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 . . . that she did not want to testify. And so so that's how it came up not in the context of, "I heard you have a subpoena. Let's talk about it." . . .

Q. And you didn't want her to testify, did you? You want her to disclose these embarrassing facts of this inappropriate, intimate relationship that you had? Is that correct?

A. 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.

Q. Did you want those facts not only the fact that you had testified, but did you want the facts that she had about your embarrassing, inappropriate, intimate relationship to be disclosed?

A. Not there. But not in any context. However, I I never had any high confidence that they wouldn't be.

Q. Did anyone, as far as you knew, know about your embarrassing, inappropriate, intimate relationship that you had with Ms. Lewinsky?

A. At that 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.

Q. Had you told anyone?

A. Absolutely not.

Q. And you tried, in fact, not to let anyone else know about this relationship?

A. Well, of course.

Q. What did you do?

A. 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 when nobody else was looking. ...

Q. ... Do you agree that she was upset about being subpoenaed?

A. 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...

Q. 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?

A. 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'd given her. ... My recollection is that Ms. Lewinsky said something to me like, "What if they ask me about the gifts you've given me?"... 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. ...

Q. And your testimony is that Ms. Lewinsky was concerned about her turning over any gifts that you had given her, and that your recommendation to her was, "Absolutely, Monica, you have to produce everything that I have given you?" Is that your testimony?

A. My testimony is what I have said . ... I said, well, if you get a request to produce those, you have to give them whatever you have. ... I certainly never encouraged her not to comply lawfully with the subpoena.

Q. Mr. President, if ... as you have earlier testified, you didn't want anyone to know about this relationship you had with Ms. Lewinsky, why would you feel comfortable giving her gifts in the middle of discovery in the Paula Jones case?

A. Well, sir, for one thing, there was no existing improper relationship at that time. I had, for nearly a year, done my best to be a friend to Ms. Lewinsky, to be a counselor to her, to give her good advice and to help her. ...

Q. What about notes and letters? Cards, letters and notes to Ms. Lewinsky? After this relationship, this intimate, inappropriate, intimate relationship between you and Ms. Lewinsky ended, she continued to send you numerous intimate notes and cards. Is that right?

A. Well, they were some of them were somewhat intimate. . . . But she had clearly accepted the fact that there could be no

contact between us that was in any way inappropriate.

Now, she sent cards sometimes that were just funny, even a little bit off color, but they were funny. She liked to send me cards ...

Q. She professed her love to you in these cards after the end of the relationship, didn't she?

A. Well...

Q. She said she loved you.

A. Sir, the truth is that ... I believe that she had accepted, understood my decision to stop this inappropriate contact. She knew from the very beginning of our relationship that I was apprehensive about it. ... But most of these messages were not what you would call over the top. They weren't things that, if you read them, you would say, "Oh my goodness, these people are having some sort of sexual affair."

Q. Mr. President, my question

...

4 A. But some of them were quite affectionate. ...

Q. My question was, did she or did she not profess her love to you in these cards and letters that she sent to you after the relationship ended?

A. Most of them were signed "Love," you know, "Love, Monica." I don't know that I would consider I don't believe that in most of these cards and letters she professed her love, but she might well have.

I but you know, love can mean different things, too, Mr. Bittman. I have there are lot of women with whom I have never had any inappropriate conduct, who were friends of mine, who will say from time to time, "I love you." And I know that they don't mean anything wrong by that. ...

Q. When you testified in the Paula Jones case this was only 2 1/2 weeks after you had given her these six gifts you were asked ... "Well, have you ever given any gifts to Monica Lewinsky?" And you answered, "I don't recall."...

A. I think what I meant there is, I don't recall what they were, not that I don't recall whether I had given them. ... They didn't ask me about the Christmas gifts. And I don't know why I didn't think to say anything about them. . . . I had no interest in not answering the questions about these gifts. I do not believe that gifts ... are incriminating, nor do I think they are wrong. I think it was a good thing to do. I'm not I'm still not sorry I gave Monica Lewinsky gifts. ...

On the involvement of Betty Currie, the president's secretary:

Q. Let me ask you about the meeting you had with Betty Currie at the White House on Sunday, January 18, this year, the day after your deposition. First of all, you didn't Mrs. Currie, your secretary of six or seven years, you never allowed her, did you, to watch whatever whatever intimate activity you did with Ms. Lewinsky, did you? ...

A. Well, yes. I I've never I mean, it's almost humorous, sir. I'd have to be an exhibitionist not to have tried to exclude everyone else.

Q. So if Ms. Currie testified that you approached her on the 18th when you spoke with her and you said, "You were always there when she was there." She wasn't, was she? That is, Mrs. Currie.

A. She was always there in the White House. . . . I wanted to establish that Betty was there at all other times in the in the complex - and I wanted to know what Betty's memory was about what she heard, what she could hear. . . .And I was trying to figure it out. And I was trying to figure it out in a hurry because I knew something was up...

Q. Ms. Currie testified that these were not really questions to her, that they were more like statements. Is that not the truth?

A. Well, I can't testify as to what her perception was. I can tell you this. I was trying to get information in a hurry. I was downloading what I remembered. I think Ms. Currie would also testify that I explicitly told her . . . that she might have to be called as witness, that she should go in there and tell the truth, tell what she knew and be perfectly truthful.

So I was not trying to get Betty Currie to say something that was untruthful. I was trying to get as much information as quickly as I could.

Q. What information were you trying to get from her when you said, "I was never alone with her, right?"

A. I don't remember exactly what I did say with her. That's what you say I said.

Q. If Ms. Currie testified to that that she says you told her, "I was never alone with her, right?"

A. Well, I was never alone with her....

Q. Did you not say that, Mr. President?

A. Mr. Bittman, just a minute. "I was never alone with her, right?" might be a question. And what I might have meant by that is, "In the Oval Office complex."

Q. But you knew the answer...

A. Could we've been going for more than an hour, would you mind if we take a break? I need to go to the restroom. ...

Q. Mr. President, I want to go into a new subject area. ... the statement of your attorney, Mr. Bennett, at the Paula Jones deposition counsel is fully aware that Ms. Lewinsky ...[filed] an affidavit saying that there was absolutely no sex of any kind in any manner, shape or form with President clinton. That statement was made by your attorney in front of Judge Susan Webber Wright.

A. That's correct.

Q. Your that statement is a completely false statement. Whether or not Mr. Bennett knew of your relationship with Ms. Lewinsky, the statement that there was no sex of any kind in any manner, shape or form with President clinton was an utterly false statement. Is that correct?

A. It depends upon what the meaning of the word "is" means. If "is" means "is and never has been," that's one thing. If it means "there is none," that was a completely true statement.

But as I have testified I'd like to testify again this is somewhat unusual for a client to be asked about his lawyer's statements instead of the other way around. I was not paying a great deal of attention to this exchange. I was focusing on my own testimony. ...

Q. I just want to make sure I understand you correctly. Do you mean today that because you were not engaging in sexual activity with Ms. Lewinsky during the deposition that the statement Mr. Bennett made [inaudible]?

A. No, sir. I mean that at the time of the deposition, we had been that was well beyond any point of improper contact between me and Ms. Lewinsky. So that anyone generally speaking, in the present tense, saying that was not an improper relationship would be telling the truth if that person said there was not, in the present tense the present tense encompassing many months. That's what I meant by that not that I was I wasn't trying to give you a cute answer to that...

President Clinton accuses Jones' lawyers of trying to 'trick' him.

Q. Mr. President, 3 1/2 weeks before, Mr. [Vernon] Jordan had made a special trip to the White House to tell you Ms. Lewinsky had been subpoenaed; she was distraught; she had a fixation over you. And you couldn't remember that 3 1/2 weeks later?

A. Mr. Wisenberg, if they had access to all this information from their conversations with Linda Tripp, if that was the basis of it, they were free to ask me more questions. They may have been trying to trick me.

Now, they knew more about the details of my relationship with Monica Lewinsky. ... They knew a lot more than I did. And 'D instead of trying to trick me, what they should have done is to ask me specific questions....

This is the third or fourth time that you seem to be complaining that I did not do all their work for them. ... Now, they had been up all night with Linda Tripp, who had betrayed her friend Monica Lewinsky, stabbed her in the back, and given them all this information.

They could have helped more. If they wanted to ask me follow-up questions, they could. They didn't. I'm sorry. I did the best I could.

On the President's memory

Q. If Vernon Jordan has told us that you have an extraordinary memory, one of the greatest memories he has ever seen in a politician, would that be something you would care to dispute?

A. No. I do have a good memory. At least I have had a good memory in my life.

Q. You understand that if you answered, "I don't think so," to the question "Has anyone other than your attorneys told you that Monica Lewinsky has been served with a subpoena in this case?" and if you answered, "I don't think so," but you really knew Vernon Jordan had been telling you all about it, you understand that that would be a false statement, presumably perjurious.

A. Mr. Wisenberg, I have testified about this three times. Now, I will do it the fourth time. I am not going to answer your trick questions. . . . It's also if I could say one thing about my memory I have been blessed and advantaged in my life with a good memory. I have been shocked and so have members of my family and friends of mine at how many things that I have forgotten in the last six years I think because of the pressure and the pace and the volume of events in a president's life, compounded by the pressure of your four-year inquiry, and all the other things that have happened. ...

Q. Well, you're not telling our grand jurors that you think the case was a political case for a setup, Mr. President, that that would give you the right to commit perjury....

A. No, sir. No, sir. In the face of their the Jones' lawyers the people that were questioning me, in the face of their illegal leaks, their constant unrelenting illegal leaks, in a lawsuit that I knew and that by the time that this deposition and this discovery started, they knew was a bogus suit on the law and a bogus suit on the facts ...

Q. The question ...

A. In the face of that, I knew that in the face of their illegal activity, I still had to behave lawfully. But I wanted to be legal without being particularly helpful. I thought that was what I was trying to do.

And this is the you're the first person to ever suggest to me that I should have been doing their lawyers' work for them when they were perfectly free to ask follow-up questions. ... It now appears to me they didn't because they were afraid I would give them a truthful answer, and that there had been some communication between you and Ms. Tripp and them. And they were trying to set me up and trick me.

And now you seem to be complaining that they didn't do a good enough job. I did my best, sir, at this time. I did not know what I now know about this. A lot of other things were going on in my life.

Did I want this to come out? No. Was I embarrassed about it? Yes. Did I ask her to lie about it? No. Did I believe there could be a truthful affidavit? Absolutely.

Now that's all I know to say about this. I will continue to answer your questions as best I can. ...

Q. You didn't think you had a free shot to say, "I don't know" or "I don't recall," but when you really did know and you did recall, and it was just up to them, even if you weren't telling the truth, to do a follow-up and to catch you?

A. No, sir, I'm not saying that. . . . I've been pretty tough, so let me say something sympathetic. All of you are intelligent people. You've worked hard on this. You've worked for a long time. You've gotten all the facts. You've seen a lot of evidence that I haven't seen. And it's an embarrassing and personally painful thing, the truth about my relationship with Ms. Lewinsky. So the natural assumption is that while all this was going on, I must have been focused on nothing but this, therefore, I must remember everything about it. ... All I can tell you is I was concerned about it. . . . But there were a lot of other things going on, and I don't necessarily remember it all. And I don't know if I can convince you of that.

But I tried to be honest with you about my mindset about this deposition, and I'm just trying to explain that I don't have the memory that you assume that I should about some of these things.

On a visit by Monica Lewinsky to the White House

Q. I want to talk to you for a bit, Mr. President, about the incident that happened at the northwest gate of the White House on December 5th. Sorry, December 6th, 1997. ... [T]he Paula Jones case was pending, correct?

A. Yes, sir ...

Q. The witness list came out on December 5th of 1997 with Monica Lewinsky's name on it. Mr. President, when did you find out that Monica's name was on that witness list?

A. I believe that I found out late in the afternoon on the 6th. That's what I believe ...

Q. Now, on the morning of the 6th, Monica Lewinsky came to the northwest gate and found out that you were being visited by Eleanor Mondale at the time and had an extremely angry reaction. You know that, sir, don't you?

A. I have I have I know that Monica Lewinsky came to the gate on the 6th, and apparently directly called in and wanted to see me and couldn't, and was angry about it. I know that.

Q. And she expressed that anger to Betty Currie over the telephone, isn't that correct, sir?

A. That Betty told me that ...

Q. And Mrs. Currie and yourself were very irate that Ms. Lewinsky had overheard that you were in the Oval Office with a visitor on that day isn't that correct, that you and Mrs. Currie were very irate about that?

A. Well, I don't remember all that. What I remember is that she was very Monica was very upset. She got upset from time to time. And and I was, you know I couldn't see her. I had I was doing, as I remember I had some other work to do that morning, and she had just sort of showed up and wanted to be let in and wanted to come in at a certain time. . . . And we couldn't see her. Now, I did arrange to see her later that day. And I was upset about her conduct . . . I thought her conduct was inappropriate that day.

Q. I want to go back, and I want to take them one at a time. No. 1, did you find out at some point during that day that Monica had overheard from somebody in the Secret Service that you were meeting with Ms. Mondale and that Monica got very irate about that?

A. I knew that at some point . . . I knew that. I don't know that I knew how she knew that on that day. I don't remember that.

Q. Pardon me. That leads into my second question, which is: Weren't you irate at the Secret Service precisely because they had revealed this information to Ms. Lewinsky . . . that somebody should be fired over this, on that very day?

A. I don't remember whether it happened on that very day. But let me tell you that the uniformed Secret Service . . . no one should be telling anybody, not anybody not a member of my staff who the president is meeting with. That's an inappropriate thing to do ...

Q. It would be an inappropriate thing, sir. And that leads into my next question: Is that why did Mrs. Currie, on your instructions, later that day tell many of the Secret Service officers involved that it never happened, to forget about it?

A. That what never happened?

Q. The incident that you were so irate about earlier. The incident of somebody disclosing to Mrs. to Ms. Lewinsky that Ms. Mondale was in the Oval Office with you.

A. I don't know the answer to that. I think maybe you know I don't know. I know that . .

Q. You don't recall that you later gave orders to the effect that we're going to pretend this never happened ...

A. No, sir.

Q. ... Or something like that?

A. No, sir. I don't recall that ...

Q. And you have no knowledge of the fact that Secret Service officers were told later in the day something to the effect of, "This never happened, this event never happened," you have no knowledge of that?

A. Sir, I'm not sure anybody ever told that to me. I mean, I thought you were asking ... your previous question was different than what you're asking now. What I remember was being upset that this matter would be discussed by anybody. ... Now the question you seem to be asking me now I just want to be sure I'm getting the right question is whether I gave instructions in effect to pretend that Monica Lewinsky was never at the gate.

Q. To the effect of ...

A. And if that is the question you're asking me, I don't believe I ever did that, sir. I certainly have no memory of doing that.

Q. Or anything to that effect?

A. I don't know what that means.

Q. Is that your testimony?

A. What does that mean, "anything to that effect"?

Q. Well, Mr. President, you've told us that you were not going to try to help the Jones' attorneys, and I think it's clear from your testimony that you were pretty literal at times. So that's why I'm saying I don't necessarily know the exact words. The question was, do you have any knowledge of the fact ...

A. No, but I...

Q. ... of the fact that later in the day, on Saturday, the 6th of December 1997, Secret Service people were then were told something to this effect, "This event never happened. Let's just pretend this event did not happen." Do you have knowledge of it or not?

A. No, sir. And I didn't instruct the Secret Service in that regard. I have no memory of saying anything to anybody in the Secret Service that would have triggered that kind of instruction.

Q. ...[W]hile you were standing in the doorway between the Oval Office and Betty Currie's office, did you tell Captain Purdy ... (inaudible)... of the uniform division, "I hope I can count on your discretion in this matter," at the end of the day when you all were talking about that earlier incident? Did you tell him that or anything like that, sir?

A. I don't remember anything I said to him in that regard. I have no recollection of that whatever.

The grand jurors ask questions

Q. Mr. President, these next series of questions are from the grand jurors. And let me you tell you that the grand jurors want you to be more specific about the inappropriate conduct. The first question was one of the grand jurors has said that you referred to what you did with Ms. Lewinsky as "inappropriate contact." What do you mean by that?

A. I mean just what I said. ... This has been tough enough already on me and on my family, although I take responsibility for it. I have no one to blame but myself.

What I meant was, and what they can infer that I meant was, that I did things that were when I was alone with her that were inappropriate and wrong, but that they did not include any activity that I that was within the definition of sexual relations that I was given by Judge Wright in the deposition ...

Q. Well, I have a question regarding your definition. And my question is, is oral sex performed on you within that definition as you understood it?

A. As I understood it, it was not, no.

Q. The grand jurors would like to know upon what basis what legal basis - you're declining to answer more specific questions about this. I've mentioned to you that obviously you have privileges privileges against self-incrimination. There's no general right not to answer questions. And so one of the questions from the grand jurors is [on] what basis what legal basis - are you declining to answer these questions?

A. I'm not trying to evade my legal obligations or my willingness to help the grand jury achieve their legal obligation. As I understand it, you want to examine whether you believe I told the truth in my deposition, whether I asked Ms. Lewinsky not to tell the truth, and whether I did anything else, with evidence or in any other way, that amounted to an obstruction of justice or a subornation of perjury.

And I'm prepared to answer all questions that I that the grand jury needs to draw that conclusion.... And I believe that you can achieve that without requiring me to say and do things that I don't think are necessary, and that I think, frankly, go too far in trying to criminalize my private life.

Q. ... If the person being deposed kissed the breasts of another person, would that be in the definition of sexual relations as you understood it when you were under oath in the Jones case?

A. Yes, that would constitute contact. I think that would, if it were direct contact, I believe it would. I maybe I should read it again, just to make sure.

This basically says if there was any direct contact with an intent to arouse or gratify, if that was the intent of the contact, then that would fall within the definition. That's correct.

Q. So touching in your view, then and now the person being deposed touching or kissing the breast of another person - would fall within the definition?

A. That's correct, sir.

Q. And you testified that you didn't have sexual relations with Monica Lewinsky in the Jones deposition, under that definition, correct?

A. That's correct, sir.

Q. If the person being deposed touched the genitalia of another person, would that be ... under your understanding, then and now, sexual relations?

A. Yes, sir.

Q. Yes, it would?

A. Yes, it would if you had a direct contact ...

Q. So you didn't do any of those three things with Monica Lewinsky?

A. You are free to infer that my testimony is that I did not have sexual relations as I understood this term to be defined.

Q. Including touching her breast, kissing her breast or touching her genitalia?

A. That's correct.

Q. Would you agree with me that the insertion of an object into the genitalia of another person with the desire to gratify sexually would fit within the definition you used in the Jones case as sexual relations?

A. There is nothing here about that, is there? I don't know that I ever thought about that one way or the other.

Q. ... As you understood the definition then and as you understood it now, would it include sticking an object into the genitalia of another person in order to arouse or gratify the sexual desire of any person? Would it constitute, in other words, contact with the genitalia? If an object ...

A. I don't know the answer to that. [He reviews the definition of sexual contact.] So if I were asked I've not been asked this question before, but I guess that's the way I would read it.

Q. If it that it would not be covered, that activity would not be covered?

A. That's right. . . . But as I said, I've not been asked this before. I'm just doing the best I can here.

Q. If you're wrong . . . did you engage in sexual relations, under the definition, with Monica Lewinsky?

A. Mr. Wisenberg, I have said all along that I would say what I thought it meant, and you could infer that I didn't. This is an unusual question, but it's a slippery slope . . . All I can tell you is whatever I thought was covered and I thought about this carefully. And let me just point out, this was uncomfortable for me ...

Q. Oral sex, in your view, is not covered, correct?

A. If performed on the deponent.

Q. Is not covered, correct?

A. That's my reading of this ...

Q. Do you recall denying any sexual relationship with Monica Lewinsky to the following people Harry Thomason, Erskine Bowles, Harold Ickes, Mr. Podesta, Mr. Blumenthal, Mr. Jordan, Ms. Betty Currie? ... Do you recall denying any sexual relationship with Monica Lewinsky to those individuals?

A. I recall telling a number of those people that I didn't have either I didn't have an affair with Monica Lewinsky or I didn't have sex with her. And I believe, sir, that you will have to ask them what they thought. But I was using those terms in the normal way people use them.

You will have to ask them what they thought I was saying.

Q. If they testify that you denied a sexual relations or relationship with Monica Lewinsky, or if they told us that you denied that, do you have any reason to doubt [that]?

A. No. The let me say this: It's no secret to anybody that I hoped that this relationship would never become public ....

Q. Did you...

A. I really...

Q. ... deny it to them or not, Mr. President?

A. Let me finish. So what I did not want to mislead my friends, but I wanted to find language where I could say that. I also, frankly, did not want to turn any of them into witnesses, because and sure enough, they all became witnesses. ...

Q. You told us now that you were being careful, but that it might have been misleading, is that correct?

A. It might have been. Since we have seen this four-year, $40 million investigation come down to parsing the definition of sex, I think it might have been. I don't think at the time that I thought that's what this was going to be about...

So I what I was trying to do was to give them something they could that would be true, even if misleading, in the context of this deposition, and keep them out of trouble, and let's deal and deal with the what I thought was the almost ludicrous suggestion that I had urged someone to lie or tried to suborn perjury in other ways.

Q. I want to go over some questions again. I don't think you're going to answer them (off-mike), and so I don't need a lengthy response, just a yes or a no. And I understand the basis upon which you are not answering them, but I need to ask them for the record.

If Monica Lewinsky says that while you were in the Oval Office area you touched her breasts, would she be lying?

A. Let me say something about all this.

Q. All I really need for you, Mr. President ...

A. I know. But ...

Q. ... [W]e only have four hours, and your answers have been extremely lengthy.

A. I know well it's I know that. ... But go ahead and ask your questions.

Q. The question is, if Monica Lewinsky says that while you were in the Oval Office area you touched her breast, would she be lying?

A. That is not my recollection. My recollection is that I did not have sexual relations with Ms. Lewinsky. And I'm staying on my )) former statement about that.

Q. If she said ...

A. My statement is that I did not have sexual relations as defined by that.

Q. If she says that you kissed her breast, would she be lying?

A. I'm going to revert to my former statement.

Q. OK. If Monica Lewinsky says that while you were in the Oval Office area you touched her genitalia, would she be lying? That calls for a yes, no, or reverting to your former statement.

A. I will revert to my statement on that.

Q. If Monica Lewinsky says that you used a cigar as a sexual aid with her in the Oval Office area, would she be lying? Yes, no, or won't answer?

A. I will revert to my former statement.

Q. If Monica Lewinsky says that you had phone sex with her, would she be lying?

A. Well, that is at least, in general terms, I think, is covered by my statement...

Monica Lewinsky's request for a job recommendation.

Q. Did you on or about January 13, 1998, Mr. President, ask Erskine Bowles to ask John Hilley if he would give a recommendation for Monica Lewinsky?

A. ... I recall talking to Erskine Bowles about that. And my recollection is, sir, that Ms. Lewinsky was moving to New York, wanted to get a job in the private sector, was confident she would get a good recommendation from the Defense Department and was concerned that, because she had been moved from the Legislative Affairs Office, transferred to the Defense Department, that her ability to get a job might be undermined by a bad recommendation from the Legislative Affairs Office.

So I asked Erskine if we could get her a recommendation that just was at least neutral so that, if she had a good recommendation from the Defense Department, it wouldn't prevent her from getting a job in the private sector...

... You know, she tried for months and months to get a job back in the White House, not so much in the West Wing, but somewhere in the White House complex, including the Old Executive Office Building. And she talked to Marsha Scott, among others. She very much wanted to come back.

And she interviewed for some jobs but never got one. And she was, from time to time, upset about it. ... She wasn't going to get a job in the White House. So she wanted to get a job in the private sector, and she said that, "I hope that I won't get a letter out of the Legislative Affairs Office that will prevent my getting a job in the private sector." And that's what I talked to Erskine about. Now, that's my entire memory of this.

Gifts under the bed

Q. And so you have no knowledge that or you had no knowledge at the time that - Betty Currie went and picked up, your secretary went and picked up from Monica Lewinsky items that were called for by the Jones subpoena - and hid them under her bed? You had no knowledge that anything remotely like that was going to happen?

A. I did not. I did not know she had those items, I believe, until that was made public.

Q. And you agree with me that that would be a very wrong thing to do, to hide evidence in a civil case or any case? Isn't that true?

A. Yes. I don't know that Ms. Currie knew that that's what she had at all. But ...

Q. I'm not saying she did. I'm just saying ...

A. [If] Monica Lewinsky did that after they had been

subpoenaed, and she knew what she was doing, she should not have done that. And I ...

Q. And if you...

A. And indeed, I myself told her, if they ask you for gifts, you have to give them what you have. And I don't understand if, in fact, she was worried about this, why she was so worried about it. It was no big deal.

Q. I want to talk about a December 17th phone conversation you had with Monica Lewinsky at approximately 2A.m. Do you recall making that conversation and telling her initially about the death of Betty's brother, but then telling her that she was on the witness list, and that it broke your heart that she was on the witness list?

A. No, sir, I don't. But it would it it would it is quite possible that that happened ... Now, I remember I called her to tell her Betty's brother had died. I remember that. And I know it was in the middle of December, and I believe it was before Monica had been subpoenaed ...

"Mysterious area of human life"

A. [After allegations of sexual harassment], Judge [Clarence] Thomas was able to go on and serve on the Supreme Court. What I learned from that, I can tell you that I was a citizen out there just listening. And when I heard both of them testify, what I believed after it was over, I believed that they both thought they were telling the truth. This is you're dealing with, in some ways, the most mysterious area of human life. I'm doing the best I can to give you honest answers ... And, you know, those people both testified under oath. So, if there'd been a special prosecutor, they could, one of them could have gone after Anita Hill, another could have gone after Clarence Thomas. I thank God there was no such thing then, because I don't believe that it was a proper thing.

Q. One of -

A. And I think they both thought they were telling the truth. So, maybe Ms. Lewinsky believes she's telling the truth, and I'm glad she got her mother and herself out of trouble. I'm glad you gave her that sweeping immunity. I'm glad for the whole thing. I, I, I it breaks my heart that she was ever involved in this.

Q. ... I want to go back to late December and early January, late December of '97 and early January of '98. During this time, Mr. President, you are being sued for sexual harassment by a woman who claims, among other things, that others got benefits that she didn't because she didn't have oral sex with you. While this is happening, your powerful friend, Vernon Jordan, is helping to get Monica Lewinsky a job and a lawyer... Don't you see a problem with this?

A. No. Would you like to know why?

Q. Isn't that why I would. But isn't that why Vernon Jordan asked you on December 19th whether or not you had sexual relationships with Monica Lewinsky ... because he knew it would be so highly improper to be helping her with a lawyer and a job if, in fact, she had had a relationship with you?

A. I don't know. I don't believe that at all. I don't believe that at all, particularly since, even if you look at the facts here in their light most unfavorable to me, no one has suggested that there was any sexual harassment on my part. And I don't think it was wrong to be helping her. Look -

Q. A subpoenaed witness in a case against you?

A. Absolutely. Look, for one thing, I had already proved in two ways that I was not trying to influence her testimony. I didn't order her to be hired at the White House. I could have done so. I wouldn't do it. She tried for months to get in. She was angry.

Secondly, after I -

Q. Wasn't she kept -

A. After I terminated the improper contact with her, she wanted to come in more than she did. She got angry when she didn't get in sometimes. I knew that that might make her more likely to speak, and I still did it because I had to limit the contact.

And thirdly, let me say ... I formed an opinion early in 1996, once I got into this unfortunate and wrong conduct, that when I stopped it, which I knew I'd have to do and which I should have done a long time before I did, that she would talk about it. Not because Monica Lewinsky is a bad person. She's basically a good girl. She's a good young woman with a good heart and a good mind. I think she is burdened by some unfortunate conditions of her, her upbringing. But she's basically a good person.

But I knew that the minute there was no longer any contact, she would talk about this. She would have to. She couldn't help it. It was, it was a part of her psyche. So, I had put myself at risk, sir. I was not trying to buy her silence or get Vernon Jordan to buy her silence ... She had not been involved with me for a long time in any improper way, several months, and I wanted to help her get on with her life. It's just as simple as that.

Q. OK Let me draw your attention to early January of this year, after Christmas, before your deposition. Do you remember talking to Betty Currie about Monica, who had just called her and said that she, Monica, needed to talk to you before she signed something?

A. I'm not sure that I do remember that. But, go ahead.

Q. This is in early January. And then Betty Currie relayed this to you that Monica called, it's very important, she needs to talk to you before she signs something. And then you do, indeed, talk to Monica that day on the telephone.

A. I did talk to her that day? ... I may have talked to her, but I don't remember the specific conversation.

Q. [S]he had just given you a gift actually in early January, a book on the presidents of the United States. And you discussed this with her and she said that you said you liked it a lot.

A. I did like it a lot ... My impression, my belief, was that she gave me that book for Christmas ...

Q. Let me see if I can jog your memory further. Monica talked to you in that phone conversation that told you that she had just met with her attorney that Mr. Jordan arranged with her, and the attorney said that if she is deposed that they were going to ask her how she got her job at the Pentagon. And Monica then asked you, what do you think I should say, how did I answer that question, how did I get the job at the Pentagon. Did you talk to Monica about that, about possibilities

A. I don't believe no. I don't remember her asking me that ... I don't know exactly how she got her job at the Pentagon. I know Evelyn Lieberman wanted to transfer her out of the job she had, and somebody must have arranged that. But I didn't arrange it.

Q. Now, that's actually not my question. My question is whether you remember talking to Monica about her being concerned that, I may have to answer some questions about how and why I was transferred to the Pentagon out of the White House, fearing that this would -

A. No, I don't remember that at all.

Q. - lead to questions, or answers that would reveal your relationship?

A. Oh, no, sir. I don't remember that. Maybe somebody maybe she did. But I only remember well, I don't remember that. That's all I can tell you. I don't remember that.

Q. Are you saying, Mr. President, that you did not then say to Ms. Lewinsky that you could always say that people in Legislative Affairs got you the job, or helped you get it?

A. I have no recollection of that whatever.

Q. Are you saying you didn't say it?

A. No, sir. I'm telling you, I want to say I don't recall I don't have any memory of this as I sit here today. And I can tell you this, I never asked her to lie. I never did ...

Q. Did you ever tell Ms. Lewinsky, or promise to her that you would do your best to get her back into the White House after the 1996 presidential elections?

A. What I told Ms. Lewinsky was that I would, I would do what I could to see, if she had a good record at the Pentagon, and she assured me she was doing a good job and working hard, that I would do my best to see that the fact that she had been sent away from the Legislative Affairs section did not keep her from getting a job in the White House, and that is, in fact, what I tried to do. I had a conversation with Ms. Scott about it, and I tried to do that. But I did not tell her I would order someone to hire her, and I never did, and I wouldn't do that. It wouldn't be right.

The stained dress

Q. Mr. President, if there is a semen stain belonging to you on a dress of Ms. Lewinsky's, how would you explain that?

A. Well, Mr. Bittman, I, I don't first of all, when you asked me for a blood test, I gave you one promptly. You came over here and got it. That's we met that night and talked. So, that's a question you already know the answer to ...

Q. Is it possible or impossible that your semen is on a dress belonging to Ms. Lewinsky?

A. I have nothing to add to my statement about it, sir. You know whether you know what the facts are. There's no point in a hypothetical.

Q. Don't you know what the facts are also, Mr. President?

A.I have nothing to add to my statement, sir.

Clinton addresses questions from the grand jury

Q. Well, the grand jury would like to know, Mr. President, why it is that you think that oral sex performed on you does not fall within the definition of sexual relations as used in this deposition.

A. Because that is if the deponent is the person who has oral sex performed on him, then the contact is with not with anything on that list, but with the lips of another person. It seems to be self-evident that that's what it is. And I thought it was curious.

Let me remind you, sir, I read this carefully. And I thought about it. I thought about what "contact" meant. I thought about what "intent to arouse or gratify" meant.

And I had to admit under this definition that I'd actually had sexual relations with Gennifer Flowers. Now, I would rather have taken a whipping than done that, after all the trouble I'd been through with Gennifer Flowers, and the money I knew that she made for the story she told about this alleged 12-year affair, which we had done a great deal to disprove. So, I didn't like any of this. but I had done my best to deal with it and the that's what I thought. And I think that's what most people would think, reading that.

Q. Would you have been prepared, if asked by the Jones lawyers, would you have been prepared to answer a question directly asked about oral sex performed on you by Monica Lewinsky?

A. If the judge had required me to answer it, of course, I would have answered it. And I would have answered it truthfully, if I -

Q. By the way, do you believe that the -

A. - had been required.

Q. Jones litigants had the same understanding of sexual relations that you claim you have?

A. I don't know what their understanding was, sir ... I think their position ... was, we're going to cast the widest net we can and get as much embarrassing stuff as we can, and then dump it out there and see if we can make him bleed. I think that's what they were trying to do.

Q. Don't you think, sir, that they could have done more damage to you politically ... if they had understood the definition in the same way you did and asked the question directly?

A. I don't know, sir ... Their whole strategy was, well, our lawsuit's not good, but maybe we can hurt him with the discovery. And you know, they did some. But it didn't amount to much. And did I want, if I could, to avoid talking about Monica Lewinsky? Yes, I'd give anything in the world not to be here talking about it. I'd be giving I'd give anything in the world not to have to admit what I've had to admit today ...

The necktie

Q. Can you explain why, on the very day that Monica Lewinsky testified in the grand jury on August 6th of this year, you wore a necktie that she had given you?

A. No sir, I don't believe I did. What necktie was it?

Q. The necktie you wore on August 6th, sir.

A. Well, I don't know that it was a necktie that Monica Lewinsky gave me. Can you describe it to me?

Q. Well, I don't want to take time at this point, but we will provide you with photographic evidence of that, Mr. President.

A. If you give me I don't believe that's accurate, Mr. Bennett ...

Q. Well, if you remember that she gave it to you, why haven't you produced it to the grand jury?

A. I don't remember that she gave it to me. That's why I asked you what the tie was. I have

Q. Can you

A. no earthly idea. I believe that, that I did not wear a tie she gave me on August the 6th.

Q. Can you tell us why Bayani Nelvis wore a tie that Monica Lewinsky had given you on the day he appeared in the grand jury?

A. I don't know that he did.

Q. Have you given Bayani Nelvis any ties, sir?

A. Oh, yes, a lot of ties.

Q. And so if he wore the tie that you gave him, that Monica Lewinsky had given you, that would not have been by design, is that what you're telling us?

A. Oh, absolutely not. Let me -

Q. You are not

A. May I explain, Mr. Bennett? I won't -

Q. Yes.

A. - take long. Every year, since I've been president, I've gotten quite a large number of ties, as you might imagine. I get, I have a couple of friends, one in Chicago and one in Florida, who give me a lot of ties, a lot of other people who send me ties all the time, or give them to me when I see them.

So, I always have a growing number of ties in my closet. What I normally do, if someone gives me a tie as a gift, is I wear it a time or two. I may use it. But at the end of every year, and sometimes two times a year, sometimes more, I go through my closet and I think of all the things that I won't wear a lot or that I might give away. I give them mostly to the men who work there.

On Kathleen Willey

Q. Mr. President, I'd like to move to a different area right now. I'd like to ask you some questions about Kathleen Willey. You met Kathleen Willey during your 1992 campaign, isn't that so?

A. Yes, sir, I did.

Q. As a matter of fact, you first saw her at a rope line at the Richmond, Va., airport on October 13, 1992, is that not correct?

A. I don't believe that is correct.

Q. Mr. President, you've seen television footage of you standing on a rope line with Donald Beyer, Lt. Gov. Donald Beyer ... asking Mr. Beyer for the name of Kathleen Willey?...

A. I don't know that I've seen it, but I am aware that it exists.

Q. All right. And you can see him, you can read his lips. He's saying the name of Kathleen Willey in response to a question from you, isn't that so?

A. That's what I've heard.

Q. And, as a matter of fact, you sent Nancy Hernreich, who was present on that day, to go get her telephone number, didn't you, sir?

A. I don't believe so.

Q. ... All right. Do you recall, having received her telephone number, called her that night?

A. No, sir, I don't.

Q. Do you recall inviting her to meet with you at your hotel that night?

A. No, sir, I do not.

Q. Do you recall where you stayed in Richmond, Va., during the debates you've told us about?

A. Well, I stayed at some hotel there, I believe.

Q. Actually, did you stay at the Williamsburg Inn, not in Richmond?

A. Yeah, that's right ...

Q. Do you know of any reason Kathleen Willey's telephone number would appear on your toll records from your room in Williamsburg?

A. No, there

Q.If you didn't call her?

A. No, I'm not denying that I called her, sir. You asked me a specific question. I won't deny that I called her. I don't know whether I did or not.

Q. As a matter of fact, you called her twice that day, didn't you, sir?

A. I don't recall. I may well have done it, and I don't know why I did it.

Q. Well, does it refresh your recollection that you called her and invited her to come to your room that night, sir?

A. I don't believe I did that, sir.

Q. If Kathleen Willey has said that, she's mistaken or lying, is that correct, Mr. President?

A. I do not believe I did that. That's correct.

Q. But what is your best recollection of that conversation, those conversations?

A. On that day, no, she did not. She was troubled.

Q. On some other day?

A. I wouldn't call it a sexual advance. She was always very friendly. But I never took it seriously.

On executive privilege

Q. Mr. President, at various times in this investigation, officials have invoked executive privilege in response to questions that have been posed to them by the grand jury and in the grand jury. One of the grand jurors has posed the question: Did you personally authorize the invocation of executive privilege

A. If the answer is authorized, I think the answer to that would be yes. But I would like the grand jury to know something.

In the cases where we raised the lawyer-client privilege, or executive privilege, or where the Secret Service raised their privilege - and when I say I had nothing to do with that, I did not authorize it, approve it or anything else - that was something that [they] asked to be free to make their decision on by themselves.

The grand jury's question.

Q. Mr. President among the many remaining questions of the grand jurors is one that they would like answered directly without relation to, without regard to inferences, which is the following: Did Monica Lewinsky perform oral sex on you? They would like a direct answer to that, yes or no?

A. Well, that's not the first time that question's been asked. But since I believe, and I think any person, reasonable person, would believe that that is not covered in the definition of sexual relations I was given, I'm not going to answer, except to refer to my statement.

I had intimate contact with her that was inappropriate. I do not believe any of the contacts I had with her violated the definition I was given. Therefore, I believe I did not do anything but testify truthfully on these matters.

Q. We have a couple of photos of the tie that you wore.

A. Would you please give them to me?

Q. Yes.

A. Now, this is August 6th, is that correct?

Q. 1998, the day that Monica Lewinsky appeared at the grand jury. And my question to you on that is, were you sending some hTC kind of a signal to her by wearing -

A. No, sir.

Q. - one of the ties let me finish, if you don't mind, sir.

A. Sure, I'm sorry. My apology.

Q. Were you sending some kind of a signal to her by wearing a tie she had given you on the day that she appeared in front of the grand jury?

A. No, sir. I don't believe she gave me this tie. And if I was sending a signal, I'm about to send a terrible signal, and maybe you ought to invite her to talk again ....

The president's final statement

A. Mr. Bennett, I haven't said this all day long, but I would like to say it now. Most of my time and energy in the last five and a half years have been devoted to my job. Now, during that five and a half years, I have also had to contend with things no previous president has ever had to contend with: a lawsuit that was dismissed for lack of legal merit, but that cost me a fortune and was designed to embarrass me; this independent counsel inquiry, which has gone on a very long time and cost a great deal of money, and about which serious questions have been raised; and a number of other things.

And, during this whole time, I have tried as best I could to keep my mind on the job the American people gave me ....

Q. Mr. President, the grand jury, I am notified, still has unanswered questions of you, and we appeal to you again to make yourself available to answer those questions ...

A. You know, Mr. Bennett, I wish I could do it. I wish the grand jurors had been allowed to come here today as we invited them to do. I wanted them down here. ... I wanted them to be able to ask these questions directly. But we made an agreement that was different, and I think I will go ahead and stick with the terms of it ...

Q. Just for the record, the invitation to the grand jury was contingent upon us not videotaping, and we had to videotape because we have an absent grand juror.

Clinton lawyer David Kendall: Is that the only reason, Mr. Wisenberg, you have to videotape?

Clinton: Well, yes. Do you want to answer that?

Mr. Bittman: Thank you, Mr. President.

Pub Date: 9/22/98