1057 

OK-302 (Rev. 8-19-941 

- 1 - 

OFFICE OF THE INDEPEhdE?;T COUNSEL 

Date of uanscnpoon 2/6/96 _X_~ 

NEYSA ERBLANI3, ) 

-, was served with United States District Court, 

District of Columbia Grand Jury Subpoena, dated February 1, 1998. 

lnvesrigaaon on 

2/298 at SHERMAN OAKS, CA File I 29D-OIC-LR-35063 

by v Da&d&ted z/6/98 

- 

1059 

OIC-302 (Rev. 8-19-94) 

- 1 - 

OFFICE OF THE INDEPENDENT COUNSEL 

Date of traxcription 2/6/98 

NEYSA ERBLAND, 

-, having been advised of the identy of the interviewing 

agents and the nature of the investigation declined to furnish 

any information concerning the investigtion without consulting 

with her attorney. 

NEYSA ERBLAND was served with United States District 

Court, District of Columbia Grand Jury Subpoena dated February 1, 

1998. 

NEYSA ERBLAND is described as: 

(telephonically) 

Investigation on 2/2/98 at Sherman Oaks, Ca. File # 29D-OIC-LR-35063 

Date dictated 2/6/98 
1060 
1061 

Neysa Erbland, 2/l 2198 

&and Jury 

Page 1 to Page 107 

CONDENSE! TRANSCRIPT AND CONCORDANCE 

PREPARED BY: 

OFFICE OF THE INDEPENDENT COUNSEL 

1001 Pennsylvania Avenue, N.W. 

Suite 490-North 

Washington, DC 20004 

Phone: 202-514-8688 

FAX: 202-514-8802 
Page 1 

1062 

Nevsa Erbland. 2112198 

- 

Page 4 

xuut11 . . 

ill UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBlA 

[2! . . . . . . . . . . . . . . . . x 

13: 

rt!ln . re: 

i Z j GRAND JURY PROCEEDINGS : 

;:I . . . . . . . . . . . . . . . Lx 

1::; 

Grand Jury Room No. 4 

United States District Court 

[ill for the District of Columbia 

I121 3rd 8 Constiiution. N.W. 

1133 Washington, D.C. 2 !oool 

[14! Z 1998 

I:zithe 

The%%%t$%~Y%/? ERBIAND was taken in - 

rescnca of a full quorum of Grand Jury 97.2. impaneled 

[17]on !z eptemberl9.19! 

1181 

I191 

97. commencing at 1 f43 p.m., before: - 

MARY ANNE WlRTH 

SOLOMON WlSENBERG 

i2Oj S t-FPHEN BINHAK 

I211 

I221 

[231 

[241 

1251 

_. _ . _ . . . _ 

Associate Independent Counsel 

Oft& of lnde~ndent Counsel 

1001 Peens?syfimra Avenue, Northwest 

Suite 4 

Washi ngton. D.C. 20004 

rli 

Page 2 

PROCEEDINGS 

i2jWhereupon 

NEYSA ERBtAND 

i:iwas called as a witness and after having been duly sworn by 

rslthe Foreperson of the Grand Jurv. was examined and testified 

,_,-- icias follaws~ . .._._. 

[71 EXAMINATION 

18: BY MR. WlSENBERG: 

r:ijplease? 

Q Would you state and spell your name for the record, 

IllI A 

Q 

Neysa Erbland. Ne-y-s-a E-r-b-t-a-nd. 

Ms. Erbland. my name is Sol Wrsenberg and Im ’ an 

i::iattomey with the office of Independent Counsel. To my right 

[141ls My Anne Worth, also an attome 

: 15 1 her ng t IS Steve Brnhak, also an 

with our office, and to 

a I omey with our office. 

116:These are the grand jurors and this is the grand jury court 

i I 7 j reporter. 

Page 3 

[ . 1. ! A Okay. 

[?: Q Thrs is a United States grand jury empaneled by 6 

13 1 United States drstnd jud e here conducting an investigation 

r 4 I of possible violations of B ederal criminal jaws involvino 

- 

I 5 I possible perjury, obstruction of ustice ‘ and subomati& of 

i;;gaj;ry rn ,‘“’ da;: Jones v. Clinton. Do you understand 

I;! Q Now Im ’ going to talk a lii bit about your 

[ IO i nghts and responsibilities. 

Ill1 You may refuse to answer any question if a truthful 

r 12 1 answer to that question would tend to incrrminate you. 

r 13 1 you understand that? 

Do 

A YeS. 

Q Thats ’ the privilege against self-incrimination. 

I201 A Yes. 

I211 Q You do not have a right to have an attorney in the 

t221grand jury room tih you, but the grand jury will permit you 

[23]a reasonable opportunrty to step outside the grand jury room 

[24 )to consult wrth a counsel if you have brought counsel with 

[25lyOU. 

111 A Okay. 

(21 Q And you have brought counsel with you. 

I31 A 

[41 Q 

I have brought counsel. 

And can you tell us who that is? 

(51 A Ralph Caccia. 

[61 Q All right. And do you know how you spell that? 

[I ‘ A C-a-d-q-r-a. 

Q 

~~~collea ues, the 

Okay. We are bound that is my&f, my 

[lo 1 boun c? by an Oat 

rand jurors the co&t reporter are 

1111 recognized exca 

of sacrec$. That means with certain wall 

t 12 1 allowed to talk a I! 

tions, which Ill ’ get into, we are not 

out what you testify to here today. 

t 13 I Do you unprsta;;, that? 

(141 

Q We cant ’

~:~~cant ’ go blab about it to R 

o out and blab about it to the press, we 

r 17 1 understand that7 

e outside world. Do you 

iiei A Yes. 

Q 

i:i;who are attached to our investigation. We can tell them 

Now, some of the exceptions are we have FBI agents 

[tllabout what goes on in a grand jury mom. Do you understand 

rzzlthat? 

1231 A Yes. 

Q The 

I::iso they cant ’ go bla ii. burg on the courthouse steps. Do you 

however, atso are bound by an oath of secrecy 

t 11 understand that? 

Page 5 

I121 A ’ Yes. 

Q 

~::~jury.secrecy or our office could if a a& allowed us to do 

In pertain circumstances you could breach grand 

r 15 ~sq, d we had a court order to do so. 

t16~wrth Independent Counsels. 

One example would be 

[171 Under some circumstances. Independent Counsels 

[lslara allowed when the make their final re rt to Con ress, 

t Iswith the authority andy~nission of a fedi% judge. !o 

rzo]reveal certain thongs a put what happened in he grand jury, 

(211 not necessaniy everything. but certarn things. Do you 

t 22 1 understand that? 

1231 A Yes. 

Q 

~::1secrecy. ’ Do you understand that? 

All right. You am not bound by an oath of 

I11 A I do. 

Page 6 

El. 

;:yt 

[51 

Q 

_ :76!it. Do you understand that? 

You are free to talk to anybody in the world about 

. 

[El A Okay. Yes. 

0 You dont ’ have to, its ’ up to you, but youre ’

r unhallowed toA D”ly;“,“. understand? 

I111 

you understand that 

A Ido. 

Q You are not a target. Do you understand that? 

1251 A Yes. 

-. . 

OlCStarr Page 1 to Page 6 
1063 

am 

Page 7 

Neysa EMand, 2112198 

Ill Q 

121 A 

Tt;, are not a subject. Do you understand that? 

131 Q A witness is just somebody who comes in and whc c.as 

[ 4 1 testimony or evidence that a grand jury is interested in that 

I 51 IS relevant to what the grand jury rs dotng. 

[ 6 ] understand that? 

Do you 

171 A Yes. 

(81 Q You are a witness. Do you understand that? 

I91 A Yes. 

Q 

i:yithey will never be a ta 

Do you understand we cannot promise anybody ttra: 

et? 

I121 A I unders 9 ‘ and. 

Do you understand that? 

Q lt% an ongoin 

/::&e may find down the road. hi 

investigation, we have no idea what 

e are not allowed to make that 

(15 1 promise to,anyesy. You understand? 

[I61 

[I71 Q You are here pursuant to subpoena. is that co&ct? 

Page 10 

Xy*x(Zl 

1:: Q 

A 

Okay. And following that, any further education? 

Well I went to three different - four different 

~:~schools. but I dont ’ have a degree until June. 

[41 Q Okay. Can you tell us what schools ou went to? 

iz;Northrid 

A I went to San Francisco State Cal S&e 

r7lUnivers I& in Los Angles. 

e NYU and I am currently enrolled at Antioch 

Q 

I ii New York? 

Okay. And NYU is the time you spent three years in 

(101 A Correct. 

Ill1 0 You lived in Manhattan at that time? 

!I21 A Mm-hmm. Yes. 

I131 Q All right. Are you currently employed? 

I141 A No. 

Cl51 Q 

I161 

Okay. Have you recently been employed? 

A No. 

(171 Q Do you know Monica Lewinsky? 

(181 A Yes. 

i$ihen 

Q Okay. Can you tell the grand jury how you know 

[211 A 

I221 Q 

Shes ’ a good friend of mine from high school. 

Okav. Is that when you first met her? 

risj A Correct 

Q The subpoena asked for documents, various 

[:i;documents and various items. Is that correct? 

1211 A Thats ’ correct. 

Q 

I:<ithe subpoena? 

Did you bring any documents or items pursuant to 

(241 A I did not. 

[25j Q So you dont ’ have any? 

Wi A 

1241 

(251 

Yes.* 

Okay. Do you remember what year that was? 

It was 87. ‘

Page 8 Page 11 

[II 0 Okay. Was she in your class? 

I21 A . 

I:;school? 

Q 

She was in my class. 

Okay. Did you meet her freshman year in high 

(11 A I dont. ’

121 Q Okay. You know YOU cant ’ lii in front of us. 

r71corred7 ,_,--.. --_. 

[41 A Correct. 

Q Thats ’ perjury if you lie about anything material 

izi in front of p gFzri;ry. Do you understand that? 

171 . , 

0 if j ask any uestion that you cannot understand 

I ii because its ’ too wordy, too 9 

~101rne to repeat it_ 

ong, not clear, feel free to ask 

Ill1 A 

Q %I% thats ’ about tt. Do you understand your 

I::inghts and~spp;;~bilities as Ive ’ read them to you? 

I141 

[I51 . Q Do you have any questions about that before we 

r161beqin the substanttve Dart of the auestionina? 

(17’ - 

r1s; 

A I do not. 

MR. WlSENBERG: 

I 15 J oing to turn the questioning 

:zo I P o step outside for a moment 

[2?i THE WITNESS: Okay. 

i221 BY MS. WIRTH: 

l23! Q Ms. Erbland. can you tell us your full name. 

I 2 4 1 please? 

i25i A Neysa Erbland. 

Page 9 

Q Oka 

A Im ’ 1 5. 

And how old are you? 

!4! 

_ pi 

17; Q Okay. And where do you lie now? 

(81 A I live in Sherman Oaks,. 

191 Q Okay. Also in Califomra. for the record? 

1101 A Correct. 

[ill 0 And how long have you lived there? 

[121 A Three weeks. 

1131 Q Okay. And are you a Melon California resident? 

II41 A Yes, I am. Although I lived P or three years in New 

, il51YtXk _ _ , - 

(161 0 When you went to school? 

(171 A 

[181 Q 

Yes. I went to school for a year in New York. 

( 19 1 marital status? 

Okay. Well ’ get to that in a moment What is your 

i201 A I am married. 

I211 Q Okay. And can you tell us your educational 

[22 1 background, statirng wth hi h school? 

1231 

1241 

Aa lFv;a!t a hig a school diploma. 

I251 A From Beverly Hills High. 

[51 A Yes. 

[61 Q Oka . 

r 7 1 your relationship w ir 

And can ou describe for the grand jury what 

h her was II e In hgh school? .t 

[El A Well, the first three years of high school, we 

I 5 I werent ’ very close friends and then she had moved schools to 

I 1 o I Be1 Air Prep School and then for one semester I did that as 

111 Iwell and thats ’ where we became very close friends. 

1121 0 

I 13 1 school? 

Okay. And that was your senior year in high 

II41 A 

t 151sernester of m 

That was my senior year. I went for the first 

[ 16 ] going back t0 L 

senior to Bel Air Prep and then I ended up 

Q 

verly to graduate. 

I'71 

[I81 A 

Okay. And did she remain at Bel Air Prep? 

She remained at Bel Air Prep. 

[I91 Q Is that where she graduated from? 

(201 A Yes. 

Ill 

Page 12 

Q SDend time together? 

[21 A Yes. 

I31 Q Was she among your closest friends? 

[41 A Yes. 

;;lthat aoe? Q Was she what you would consider a best friend at 

. -. 

111 wm A Yes. 

181 Q Tell us what happened next? Did you go immediately 

I 9 1 to San Francisco State? 

1101 A Yes. I went rtght after I graduated. Just that 

111 ~fall. we went - mv bovfriend at the time and I went to San 

i 12 j Francisco State. - ~’ 

have 

A Yes. 

Q Well ’ call her Monica, if thats ’ okay wtth you. 

A Thats ’ fine. 

l201. Q Okay. Describe the nature of your contact with 

r2llher. 

1221 A lf I remember correctly, we never - I might have 

t23jseen her a few times when I came home, but I dont ’ thrnk she 

I24)ever cana to see us She was in school at Santa Monica 

r2s1Cokge at the time. But we spoke on the phone. 

-. . 

. 

Page 7 to Page 12 OlCShrr 
1064 

as4 Neysa Erbland, 2/12l98 

. 

Page 13 

.- Q How often? About. 

.-. 

-. A 

> Q 

I would say eve two weeks maybe. 

Okay. And wha r 

i iistay at San Francisco State? 

happened then. How long did you 

A 

: l: and started 

I stayed there one year and then I moved back horna 

i -. anmediate 

going 

:.: 

.c. 8 

to Cal State Northridge, I think 

after that. 

From home? 

._. 

- A From home. 

i-’‘ 0 

i !I for a minute. 

Can you tell the grand jury - well, jet me back 

When you came back home and you went to 

: :: : Cal State, where was Monica? Was she still 

A 

oing to school? 

,-:. 

,--_ 

::4: Q 

She was still at Santa Monica ?Wege. 

I’ L’ 

.--_ A 

And where is that in relation to where you were? 

Where I was in school? 

1161 Q Mm-hmm. 

- ,.-. 

<- A Close. In driving distance. 20 minutes, 

i:S: Q 

1:5-t&&J 

Okay. Did you see her then during that period of 

.;.r 

I*-. A Yes. 

I;:: Q 

12:: relationshi 

Okay. And can you tell the grand jury what your 

1 

with her was like then? 

I was married at the time to somebody else, I think 

iii&e didnt ’ see each other as much as we had, say, in high 

~~~:school, but we remained friends. 

Page 14 

,. . 

.-_ Q I-. A 

Okay. Then what happened? 

Then I 

:::after that and she wen 9 

ot divorced and I moved to New York soon 

at that time to Lewii and Clark in 

iii Portland. 

,:. 

.-. 0 

IT: A Actual1 she went to ewes and Clark before I went 

Okay. ;nd, - Im ’ soy? 

:-:to New York because 

Q 

vrsrted her there once. 

:c. 

i S iYork for about three years. 

And I think~ou told us ear&r you were in New 

1::‘ A Yes. 

1::: Q 

f--ihme7 

Did you keep up your relationship wkh her at that 

,__. - 

1:3: 

1:4: ’ 

A Yes 

Q With Monica? 

1::. A Mm-hmm. 

r. _- 

, .c Q And what was the nature of vour contact with her 

iI-during ‘ that period? 

I:?’ A 

r. 2‘ 

,.- Q 

We spoke often, I think at least once a week. 

A 

On the phone? 

i2Z. On the hone. 

::: .came here to see her, t? 

And when she moved to D.C.. I never 

ut she came to me in New York. 

,--. 

:::-D.C.? 

Q Okay. When you say *here,” you mean Washington, 

A I do. 

Q Okay. And during the time that you were in 

Page 15 

: : New ‘ York did ou travel to California sometimes - 

I-. t-_ A ‘ tes. 

. -* 

,-_ and see her? 

!+: 2 fo see her in California? 

:5: 

: E. home? 

Q Not to see her. but did you see her when you came 

I-‘ A If memo 

:e:D.C. because she went x0 

serves. when we were visiting, she was in 

m PorUand to D.C. 

13: Q 

A And rwas in New York. 

And ou were still liiing in New York at that time. 

1::: 

Ii:: 

Ii?: 

4 $3~. And so your visits would be in DC. 

113: 0 No? InNew York? 

114: A Our visits woutd be in New York. 

[IS’ Q 

ric:you? 

In New York? She would come up to New York to se 

I:: ‘ A 

[I E :was comin 

Yes. Or I think Christmas. if I came home and she 

[ 1 zr.each other 9 

home to see her father, then maybe we would see! 

here. 

12:: Q 

rz:-well. 

SO you occasionally saw each other in California as 

ix: A Yes. 

Q 

i::$ime that you were in California would you see her In person? 

About how many times a year during that period of 

rzs:Hyou know. 

I 

8 

Page 16 

Ill A From when until when? 

Q During the three years you were n Naw York. A&G 

iii on the average how often did you see her? 

~$mes 

A jn California. I wouldnt ’ say more than three 

[6! Q 

A 

Okay. And in New York? 

171 In New York, I saw her twice. 

181 0 

[91 A 

Okay. But you stilf maintained very close contact? 

But we stills oke. Yes. 

I101 Q R 

rlllphane? 

And you spo e to her weekly, pratty much, on the 

[I21 A Mm-hmm. 

I131 Q All right. During your relationshzp with her 

t 14 lthroughout the years from hrgh, school through coi e and 

r151tho penod of trme when shes in D.C. and youre ’ KI % ew 

[161Y.ork When you talked to her on the telephone, dd she 

t 17 ldrscuss personal, private matters with you dunrg those 

.--. I1 8 1 conversatiins? 

1191 A Yes. 

(201 Q . Did she discuss romantic relationships, if any, 

121 I that she wr in+r33,ed n? 

1221 

1231 Q Okay. Have you met her family? 

I241 A Yes. 

1251 Q Okay. Does that go back to hih school? 

Page 17 

ill A Yes. 

121 

131 

2 (33,~. And shes ’ met yours? 

I41 Q Oka 

tswhen you left New v 

. You told us earlier that there came a tima 

[ 6 I rtght? 

ark and came back to California. is that 

What year was that? 

171 A That was about two and a half an a o, I think. 

181 

191 I., 

AQ & ~~~u~d that would be I& or 987 ‘

Q 

;:;;did you do? 

Okay. And when you came bar& to California, what 

1121 A ’ Well, I had otten married to my present husband. 

I131 r! .~~, Q InNewYo 7 

i ::I home 

A 

and 

We had come home gotten marriad at my parents 

then we were both still liiing in New York, but soon 

t 16) after that, fd ’ say within a few months, we ended 

t 17 J back to Califomra. And I worked for a little while 

moving 

[lslfirst came back and then - 

%ienl 

(191 Q 

A 

And went to school again? 

~:!~rnonths~ Three months. 

No. that wasnt ’ until recently, just the past two 

i221 Q Okay. What are you studying, by the way? 

I231 A Creative writing. 

Q Okay. NOW, during the period that you lived back 

i::;in California, the most recant two and a half years, did you 

Page 18 

I I I continue your contact with Monica? 

I21 A 

t:;tektphane 

Q 

Yes, I did. 

And tell the rand jury the type of contact, 

in person how o 91 en and so on. 

151 ‘A Wes’ 

161She went to the Pen IF 

e on the phone, we trted to s ak - when 

gon, we didnt ’ get to speak on 

(7 1 that often because she traveled a tot. 

I? e phone 

But as much as we 

rsicould, talk on the phone. She came into town to sea her dad 

rsla few times. 

tlnlthree times 

I saw her most every time she came in, maybe 

s--1------ --..--. 

Ill1 Q Did you ever see her on the East Gxrst? Did you 

I .~~. 12 lever come here to vistt here? 

I131 A I never cama here. 

0 

~:!.~we*lt get to that later, when she was traveling, how often 

Okay. And aside from the tii at the Pentagon, 

fl6lWaS your phone contact with her? 

A 

~ii~vveeks at a time. 

Well, it varied. Sometimes shed ’ be gone for three 

1191 0 

-1201 _ A 

But aside from the Pentagon, aside from - 

1211stJlr! 

Oh, aside from - when she was at the White House 

1221 Q Mm&mm. 

1231 A Wespokeonceaweekoratkasttwiceamo~. 

IG{often? 

Q Okay. Andduringthe timeat thePentagon, how * 

OfCStaW 

I 

. 

Pagel3toPegel8 _ 
1065 

Neysa Erbland, 2112198 XWY 

Page 19 

[II 

(21 

I31 

(41 

A At least once a month. 

Q Okay. But it varied, sometimes more often? 

A Yes. 

Q All right. BY the way, when was the last time YOU 

[51saw her? 

- _ 

I61 A 

Q 

It was Thanksgiving time. 

171 

[El A 

This past Thanksgrving? 

This past Thanksgiving. 

[91 Q And where was that? 

1101 A In Los An eles. 

1111 Q Okay. D’ I3 

i12j 

YOU visit with her at that time? 

A Yes.- - 

i131 0 Oka 

A The 7 ast time I spoke to her was January 16th. 

And when was the last time you spoke to her? 

il41 

!I51 Q Ofl998? 

1161 A Yes. 

!171 Q All right. Now, ou mentioned a moment ago that at 

I ls~some point Monica worked at tzl e White House, correct? - 

il9i A Yes. 

:201 Q So you knew that she had a job in the White House? 

I211 A Yes. 

Q 

ii:hhite House? 

Did you know that she had an internship inthe 

I241 A Yes. 

I251 0 Do you know roughly when that was? 

Page 20 

Ill 

I21 

Aa p;Jh;Ee. started there? 

.~, 

[31 

[(I 

151 

A It was about 95. ‘

0 Okay. Do you remember what time of the year? 

.-. A I would sav middle of the vear. I think. 

0 

itishe talk to 

Okay. And do you know how she got that job? Did 

$ 

ou about that? 

/ 

I81 

! Iiielse? 

~~~~%k!%t%?k%hlte House or somebody 

1111 A I dont ’ know who she knew. It was ust ‘ like a 

112 1 connection, somebody who could help her get a JO 4 . I dont ’

I 13 I know if it was somebodv In the White House or somebodv who 

i 14 jjust had pull or somethin 

. 

::51 Q And did s f 

:161aettina that iob? 

e tell you what her reaction was to 

i:,j- " A’ She was very excited. 

:I61 Q And did she tell you anything about that job, what 

: : 9 1 it was like to work there? 

:20! A She used to tell me about the White House and that 

:: I 1 she wanted me to come because you could get the great tour 

;2? Iwhen you worked there. And that rt was just exciting. She 

:231was brg on the White House. 

i241 Q And did she tell you anything about the type of 

: 3 5 1 work that she did? 

Page 21 

A 

ii jof. Schlepptng 

Yes, I think it was just like messen erin kind 

[3lforth, getting co R 

apers around bnnging documen 

ee. Grunt work. 

i? ba %and 

141 0 Did she tell ou who she worked for? 

_ f51 A Yes, I but I J ont ’ know. 

0 Oka And did she ever talk about who her friends 

ifiwere there tn thedA 

rte House or in Washington enerally? 

: 

She did. She mentioned a few of he women at the 

ii 1 office that she spoke to. 

9 : 

I think she had one other friend 

; io 1 that she had met outside the White House. 

::11 0 Do you remember any names? 

!:?I 

il31 

A I dont. ’ / 

Q Oka Do 

i ;:; lasted in the White blouse! 

ou remember how long the internship 1 

A Well, I dont ’ remember. There was a shift I know, 

t 16 1 when she started getting paid. I dont ’ know when that was, 

j 

r:?lwhen it actually became a paying ob. ‘

I181 Q Okay. So eventua 1 ly she got a permanent paying job / 

; lglin the White House. 

rzoj A Right. 

0 

i::iof work she was doin 

Do you remember in what area she worked, what & 

i231 A No. 2 ot exactly. 

when she got that permanent job? I 

i241 Q Okay. You were talking to her during this period? i 

(251 A Yes. 

1 

Page 22 

r.. 

.-. Q This is relatively still once a week an average or 

[ 2 : hwce a month at least? 

r3: A Yes. 

14: 0 Okay. So she didnt ’ tell you much about what - 

rs!dd she ever mention that she worked in the office of 

r6:Legislative Affairs? Is that somethrng that she mentioned? 

A 

Ii i like just kind of - 

She may have. I mean, we generally talked more 

19: Q Social stuff? 

rioi A Social stuff. 

[l?: 0 

A 

Did she talk to you about her family much? 

I::;withhermomatthetime.soA little bit. Just - you know, she was living 

114: 0 In DC.? 

A In D.C. So - you know I like her mom so I would 

iizioften ask her about her mom and what she was doingand ’ how 

il7jshe was doing. 

1181 Q What is her relationship with her mother like? 

I191 A Close. 

[20! I;; yererrte$J~~ %%iu~~%E KE%!kL$% “yho%tot$eanv ”u 

~&-~d,-&her% the White Ho&s or outside in ’ 

[231Washington? 

[241 A Yes. 

1251 Q Agail 

But, again - 

n no names come to mind? Have you ever heard 

Page 23 

[lIthe name Ashle 7 

[21 A do. Thenwas one 

13lscmething like that, but - 

- Iwant to say Christine or 

[41 

AQ %% wen so man 

Iiiknow, even when she would talk a lo 

names always flying around, you 

r71and then she went here or this 

ut - you know, officials 

r B J House today. I know so little a 

;i%i?%?r%% head. ‘

grscy cam43 rnto the White 

ut. ou know, polrtics and 

y u rn Washington tha names just kind of went 

Q bkay. Can you describe what her reaction was 

r 12 Iduring this tirnd when she got her permanent ob? ‘ How was she 

rl3lfeelrng about working in the White House at t 

Ll41 A She was very happy. 

I! at time? 

1151 Q Okav. And vou never came to D.C. to see her? 

i16j ier cam& 

1171 % 'OE 

rlslyou during either th 

y. Now did she ever discuss the President with 

e period of time that she was working as 

ri91an intern or as a permanent r employee? 

(201 A Yes. 

she tell you? 

.lat the 

mber w K 

were having an affair. 

enshe first mentioned that? 

ippened. I 

[211 Q And what did 

1221 

1231 

; sdo” tozJ~mmtt 

(241 A We x , she menttoned it after it had hz 

tzslthink it was a few months after it had started that she 

Page 24 

t 1 @ally told me. So if she started in 95, ‘ I would say 

rzwrthrn srx months, she probab told me. 

I31 Q ire 

I41 A 

Do you remem r how the subject first came up? 

Yes. We were - I dont ’ know how the topic 

I 51statted, but she had started to say, you know, that he was so 

r61ade and that, you know, and I would say, “Ooh.” You know 

ct17$?atly?” And she said, “No. You know, well, when you se& 

t B 1 hm In person, rts ’ drfferent. Hes ’ much better looking in 

rslperson than he rs when you see him on T.V.” 

I101 

I111 

And; you know, and I would say, Oh,,my ‘ God. Could 

[I21 iti President 

imagrne rf@ou know: ;,ended up havrl an affarr wrth 

And she said yes that wou be weld and 

[13lcrazy.” And I said. Well 

[141?Jo. 

u have to tell me.” She said, 

Well, I wouldn! be a le to tell you. That would be 

rls~fust too much of a brg deal. 

tlr+sver happened.’ 

I couldnt ’ tell anybody if that 

1171 And rt went back and forth like that for a few 

rlslminutes and finally she said, “Oka . hs ’ happened.” 

[191 Q 

1201 A 

And what did she te\ 

She said that lt start d 

ou about what had happened? 

that they had been kind of 

iii jpkirg eyes at each other and kind ofjust flirty a file 

r221M .__, ~. ,.-. vou know. ..- ;.. and ---- she -.-- would __ --.- see him rn the halls or 

r23;some@1g kke that. And one afternoon, I 

(24 jdropprng something off or something like at and he must 

[zslhave sard something to her, you know, that she looked good in 

I * i. 

. OlCStan Page 19 to Page 24 
1066 

asA Neysa Et-bland, 2112198 XuA4C) 

Page 25 

; 1; her suit or something to that effect; and she - she lifted 

(21~ her skirt and showed him her underwear. And I guess it 

131s & rted from there. 

(41 0 Did she ever tell ou where that hap ned 

[5]~hysically in the White House? br if it was in the &e 

[6] OUSe? 

A When things ha 

ti i there was an office. a private eR” 

ned It was in - she toM me that 

o ce,. &hind or next to the 

;s;Oval Office and that that was his pnvate office and thats ’

r1o;where thin s would happen when they ha pened. 

I111 a Okay. And do you remem L 

r12;that pointalf y?u remember. 

r what you said to her at 

[131 Oh, my God. No way. Are you kidding? 

:141 

I151 

AQ y”,“,,you believe her? 

(161 Q 

A 

Can you tell the grand jury wh you believed-her? 

I never had any reason to thin 4she would Ire to 

i:i;rne. I never knew of her to lie to me before and we talked - 

!19;about our boyfriends and, you know, sexual relationships 

:zo]throughout our friendship and I never knew her as a trar. 

:211 0 Were 

r22lthe President she ha J 

ou aware that prior to her relatronship with 

;25;married person? 

a previous relationship with another 

I241 A Yes. 

1251 Q And who was that? 

Page 26 

111 A And Bleiler. 

(21 Q 

A 

AndYdid she talk to you about that as well? 

I31 Yes, quite a bii. 

I41 Q 

[s;was going on? 

Did she talk to you about that at the time that it 

161 - -A Yes. 

Q When she first brought the subject of her 

iiirelationship with the President up wrth you dunn 

[ g]wnversation. was it during that conversation tha 1 she 

that 

[ 1 o 1 described to you how it began? 

Ill1 A I believe so. 

r:21 Q And did she tell you anything else about the nature 

l i3]of her relationship with him during that conversation? 

[I41 A Just whatever other sexual things that they had 

:?sldone together. 

Li61 Q Okay. What did she tell you? 

::?I A She - in her words or - 

::s1 0 

A 

iizithat she had had all of her clothes off 

: 2 I 1 his shirt off and that she had given him oral sex and 

: 22; kissed and fondled each other and that the 

; 23 1 That was ktnd of a little bit of a letdown for Ii 

didnt ’ have sex. 

er. 

Q Do ou remember anything else during that 

if : jconversation that s K e told you? 

Page 27 

:11 A No. 

Q Oka 

!: i with her, did the su IT rect of her relationship with the 

Now when you had subsequent conversation: 

; 4 ; President rntiyez.to come up? 

i51 

161 Q And, again, for the record, this is during the 

[ 7 ; period thatAsheTeT an Intern? 

I81 

I91 Q In the White House? 

I101 A And it kind of blends into when she was getting - 

Ill] Q 

il2l A 

A permanent job? 

0 

- a paying job. Yes. 

i :: 1 told you in 

Okay. Do you remember anything further that she 

subsequent conversations about her relationship 

j : 5 ; with the President? 

il61 A 

;:~lgeneral? . 

About the sexual relationship or just anything in 

iI Q 

: : 9; remember. 

Whatever you can remember, the best you can 

A 

/fP;would see him as often as she could. 

Just that she liked him and liked seeing him and 

iI21 0 

A 

Did she tell you where? 

ii: i always in the side office. 

It was always in that - to my knowledge, it was 

:251 Q Okay. To your knowledge, never anywhere else? 

Page 28 

A No. 

Q Did she tell you when? Time of day, day of the 

ou know tf I called her on 

saw himon ’ Monday.’ 

Q 

~~~ab-out how she managed to 

Did you ever have a?y conversations wtth her 

[ 9; President? Was that sort o 

pet a prrvate vrsrt wdh the 

[lolyou? 

a subject that came up between 

A Well, when she was still working there, I think, 

IE;ust ‘ as an intern or as a whatever, as a paid worker, 

1131 i hat she just kind of had access to most parts of the White 

~14~House. 

Q Okay. Did you ever ask her how is tt this happens 

[:ziand no one catches you. no one sees you? 

A I may have. I think -just when they closed 

I :i; that door or when he closes the door, its ’ his private 

; 19;office and I 

;zo;to come in. 9 

uess youd ’ hsve to knock if anybody was going 

dont ’ think she ever told me that that was 

[2l;an issue. 

I::; 

Q Okay. And during subsequent conversations that 

ou had with her and well ’ confine our discussion now to 

[24] r he period when shes ’ workin 

t2sjtell you anything further abo ll 

in the White House, did she 

the nature of her physical 

Page 29 ’ 

111 relationshi 

[2;already to k 

with him thars any different frnm what youve ’

us? 

A Just that - tike details of what he - how he 

i :; touched her or somethin ? 

Q Well the !est you can, just describe the nature of 

f 2 1 the contact as best vou can. .~I ~~ 

iiifondling 

A I mein, what Ive ’ told you is 

ou know. He put his face in her 

retty much. I mean, 

&St. And, you 

t 9; know, JUS 3 orarsex on her part. you know, to him. 

Q Okay. Did you tell an one at the time that she was 

i:iitelling you these things, about what x onrca was telling you? 

1121 

II31 

; ’ &ti~~dll~,n yone? 

I141 

I151 

A Yes. 

Q who did you tell? 

I161 A 

. I 17 I my husband. 

I told my husband, although she knew I was telling 

I251 A Charles. 

Page 30 

Q Charles what? 

I::iShe. I think, was mostly saWed ph sical 

I think at that time. it was happy lt was good. 

wrth what was 

rls;goin cr 3; 

[~?;wtth R. 

on, although she wanted to a ually ave rntercourse 

rm, but she had said that he felt that there were 

I I 8 I reperwssrons to that that I guess, 

s other than infercourse. 

werent ’

t 19 ; doing 

as serious as 

thin 

.I201 % he talked about wanting to be able to see him 

t21;more. wishing they could see each other freely. You know, 

;22;she was crazy about him. 

1231 

r::i!gy 

Q. 

see 

pii you have an understanding of how often she 

him in the nature of pnvate vurts dunng thrs 

OlCStarr Page26foPage30 
1067 

Bu Neysa Erbland, 2/12198 xuu(w 

Page 31 

.,. 

1 I j month. 

A Yes. tt was - I would say it was at least once a 

tt may have been a little bit more often that 

:3j 0 Oka And a ain. you said that these discussions 

rglbetween you and M&ca tboa{lace during the pericdwhen she 

: s lwas an intern and also when s e was a permanent employee of 

: 61 the White House. 

;7labout? 

Do you remember what years were ’ talking 

A Were ’ talking about - I think were ’ just talking 

iiiabout really like a 

::olshe was moved to IJle 

ood solid year. She started in 95 and 

::Ilmiddle of95 ’

Pentagon I think some time m 96, ‘

Q Okay. And. again, you probably testi5ed to this 

ii:;earlier but I dont ’ recall your answer, when was your first 

:~clconveisation wrth her about this? 

::51 A A few months after she started woting there. 

:!6] Q So in95? ’

::71 A In 95. 

:I81 0 

A 

To the best of your memory? 

;191 YW. 

Q All ht. Now, you mentioned a moment ago that 

iffithere came a time Tie w n Monca went on to work in the 

:231 

;tz]Pentagon.Ak th&ri&hsht. 

Q Do you now the circumstances under which she left 

i::;the White House? 

Page 32 

i:2jLiiberman orjust Eve 

'131 A 

:14; Q 

‘i5! A 

:i6 jwomen, I remembei. 

::,I Q 

A 

What did she tell you about Evel n? 

That she, I guess, had a hunch tx at something was 

iit; oing on and wasnt ’ too thnlkd about it. Wasnt ’ too 

.zo&itted about Monicas ’ - you know. 

::1: Q Did she ever tell you whether Evelyn had seen her 

.z:,with the President? 

:23j A No. 

:241 0 Dd she ever tell 

J 

ou whether anyone had ever seen 

::s!her or caught her wrth the Press ent? 

Page 34 

: : lthat that was why, because rumors were floating about that 

:2]things were going on. 

:31 Q 

A JUROR 

Drd ou know who Nancy - 

(4: Excuse me. Your voice kind of trails 

rrrnff ,a,-... 

161 A JUROR: We cant ’ hear. 

[?I MS. WIRTH: Im ’ sorry. 

1s: BY MS. WlRTH: 

r91 Q Do YOU know what Nancvs ’ iob was? 

A 

- . 

:iO] Im ’ not sure. 

Q 

I ii 1 Hemreich? 

Okay. Have you ever heard the name Nancy 

I131 A I dont ’ think so. 

I141 Q Okay. And she spoke mostly in first names to you? 

Okay. Did the name Jocetyn ever come up? 

I dont ’ think so. 

iOlS 

Page 35 

Ill BY MR. WISENBERG: 

121 Q 

A 

Like an aidedecamp? 

i:;had sus 

Somethin like that. Like an aide. -Yes. Who also 

tslto her, tt! 

icions and I thin a 

at - you know. 

may have even mentioned something 

i%ell? 

Q In that light, does the name Steve Gooden ring a 

iej A Steve - 

(91 Q Etther Steve or Steve Gooden? Or Andrew Friendty? 

110: A Andrew I think it was. 

Ilil MR. WlSENBERG: Okay. 

I&l. 

THEWITNESS: Andrew Friendly actually rings a 

(141 BY MS. WlRTH: 

0 Oka Dii she ever tell 

::ziabout that she left t rl e White House? vs 

ou exactly how it came 

ri7jreassigned? 

as she fired? Was she 

I181 A 

Il9lSOmeI think she was reassigned, that they had given 

that the 

1201and thatqwhat ’ $7 b 

were ust reworking how things were there 

ey to her, although underlyrng that she 

121 ~sard, obviously, you know, people knew what was going on and 

I 22 1 they krnd of ushered her out quietly, you know, in order not 

(23lto cause a stir. 

Q 

I::lif she went to work at the Old Executive office Building? 

Do you know if she went directly to the Pentagon or 

A To m 

iii”Oh. my God, we go r 

knowledge, I dont ’ remember her ever saying, / 

I31 Q When 

caught.” 

ou said a moment a o that Eve n had a hunch 

!P Ido 

r 

ou remember an y! hmg more specific a &I .ut what s !?e said 

_ :5 ltha Evelyiwas bunking? Drd she ever mention Betty? 

/’ 

:6i Betty clJme? 

iii 

0 Yes. 

A Yes. 

::6) 

:;;I i 

: 18 I cat-0 assume. 

I%& that she knew afterwards, but I -well, I 

::91 Q Okay. Did the name Nan 

; 2 o 1 who may y ve yEn upset or concerned %o a 

ever corns up as a persc 

ut this? 

:::I 

:221 0 

A 

Okay. What did she tell you? 

Just that that it was - ou know she was one of 

i::lthe few women that. you know, weren 1 as nice I ‘ guess as 

:zslthe other women who worked there were and that she.thought Q And what did she tell you about that? ., 

-, . 

Page 31 to Page 36 

. OiC-Sh~ 

Page 36 

III A 

I , ‘ 1 Patsy? 

Q 

She went directly to the Pentagon, to my knowledge. 

Dii you ever hear the name Patsy Thomassen or 

[41 A I dont ’ remember. 

151 Q 

I6 1 about this that 

Did she ever have direct conversation with Evelyn 

ou know of? 

171 A 

i “, ; kaving? 

0 

Lot that I could say with any certain 

Do you know who gave her the wo 2 that she was 

t101 A 

Q 

I think it was Evelyn, but I dont ’ know for sure. 

i :: i Do you remember what 

Okay. So she went then to work in the Pentagon. 

I131 A i 

ear were ’ talking about now? 

I141 

t i 5 I about 

Q 

Were ’ tal ing about 96. ‘

working 

Okay. And do you remamber how she was feeling 

rl6lthem? 

at the Pentagon at the time when she first got 
1068 

SSA Neysa Erbland, 2/12!98 

Page 37 

A She told me that he was ooinc to helo her oet a job 

1: 1 back in the White House. 

- - - 

Did she tell you a;gFg more about that? 

when or in what cap; 

As soon as possibk,*you know. he would try and get 

iz;her a job back in there without anyone - not soon enough so 

t7lthat people WOUM raise their eyebrows. 

IR, 0 And did the sub&t of after the et&ion - this 

i 9 jwoutd take place after the elechon ever come up? 

I101 A Yes. This would take lace afler the election. 

1111 Q That she would corns g ack into the White House? 

1121 A Yes. 

1131 Q And thats ’ what the President told her? 

(141 A That is what the President to@ her. 

I151 Q And what was her reaction to that? 

A She was looking forward to it and she understood, 

;:76iyou know the timing because of the election. that it would 

t,g,L seeing him at that 

r 18 1 robably be best for heri;.t to be near him, for them not to - 

0 NW d%ng the time that she first went to work at 

I:!ithe Penta on, do you know if she saw the President at all 

t 22 ]during thaiime&wse me? 

[231 

Q When she first went to work at the Pentagon, was 

I::;she still seeing the President? 

Page 39 

A Was that at the same time the election was held? 

I: i I guess the election was - 

Q Well you told us a moment ago that it was in 1996 

I:ithat she left the Whhe House and she went to work at the 

t5lPentagon. 

161 A Right. 

Q And when she first started working there, the first 

iii few months doJou know tf she continued to see the President 

I gjdunng that time. 

A I dont ’ know about the time. All I remember is 

i:!;that right before and up until the election. he didnt ’ want 

I 12110 see her, but that after the election was over with, they 

113)would see each other. 

Q Okay. So you dont ’ know tf from the time that she 

i ::; left the White House up until the election whether she ever 

[16]SaW him at all. 

!17; A Rght. 

.~~. IIBI 0 Did thev talk on the Dhone? 

1191 A Yes. * 

IZO! Q Oka Throu hout that period? Do you know? Or at 

;;; isome point dunnf &at penJ? 

A 

I231 Q 

A some point. Im ’ not sure if it was often. 

But it was prior to the election? 

:24) 

i25! 

A Yes. 

0 Did she tell you anything about those 

Page 39 

i i 1 conversations? 

I21 A Yes. 

l3i Q 

A 

What did she tell you? 

I41 They were like 

[s ~woutd. you know, talk about w P 

hone sex conversations. They 

- [ 6 ] other SeXUahy. 

at they wanted to do to each 

171 Q Did she tell you what tii of day those 

t 8 1 conversations took place? 

191 A They were late at night, four, three. two in the 

~:olmoming. 

Q 

i :: i made those calls? 

Did she tell you that she knew where he was when he 

I131 A I think she had said he was in his bedroom. 

I141 Q Okay. And where was she? 

[I51 A Monica? 

[16l 0 If she told you that. 

[I71 A She was in bed. 

(181 Q Oka 

rwthy hod of time w i 

Im ’ going to take you bade for a moment to 

120jDid 

en she was working at the White House. 

onica ever tell you during that time whether the 

[ 2 I 1 President ave her an gifts or presents? 

[221 i At that r me? I think so. I think it was then. 

[231 Q What do you remember? 

I241 A 

[251 her birthday. 

I remember him giving her a hat pin, I think, for 

I 

olcstarr 

. . 1 *-, 

:2: 

:3: 

:4: 

:5! 

176; 

tei 

191 

Page 40 

Q When is her birthda ? 

A 1 3rd. 

0 

Her birthday is July 

Do you remember - did you ever see that hat pin? 

a ~;rk;did. 

A On her hat. 

Q I mean where were you when you taw it. 

A Oh. In California. 

Q What did it look like? 

Thank you. He gave her - you know what? Im ’

r231JOy. t? 

lt mi ht have been this past Christmas. A book of 

[24]pI? ry, Wa, Whrtman. It was a first edition, I think. lt 

t25lwas very nice. 

Page 41 

[11 Q Do you remember what the tile of the book was? 

I21 A I dont. ’

I31 Q Does Leaves of Grass sound familiaR 

I41 A Yea, tt was. 

[51 Q Did YOU ever see that book? 

I61 

I71 

181 

I91 

A No. - 

Q An other presents? 

A .&abrooch. 

Q dnd ‘ a brooch? What kind of brooch? 

[101 A I dont ’ know. 

[111 Q Did you ever see that brooch? 

I121 A * No. 

I131 Q Do you know when he gave her that brooch? 

[141 

1151 

t llU$k that was also Chnshnas? 

t Christmas? If you know. 

1161 A I don v= know. 

Q And these are presents that you would hear about 

~:~~durtng your conversations with her? 

A 

~:~~Chrtstmas 

Yes. And, you know, it must have been the 

r211Chtistmas. 

before because we never got to talk about this past 

%dl? 

Q And that is the case with the book of poetry as 

;&>,..w... 

1241 

I251 

A Right. So it must have been 96. ‘

Q Drd she ever tell you about any items of clothing 

Page 42 

[I lthe President ave her? 

A 

I:ibrought her 

%hen he came back from Marthas ’ Wneya$, he 

- I think just a couple of T-shirts, you know, 

t I 1 like token - token thmgs. And a dress. 

rs,dress. 

He gave her a 

161 Q mat do you know abut that? 

-171 A I remember she liked it. I never saw 1 Im ’

rs1sony. 

191 Q 

A 

Did she describe It to you in an 

I101 

Q 

She ma have, but I couldn? te x 

way7 The dress. 

you. 

1111 Okay. &id she ever discuss any presents that she 

r121gave to the Prestdent? 

_,-“,-. -.-.. 

Q AU right Now Im ’

%&tint weve ’ discuss4 atready ea 1, 

oing to take you back to a 

w)r Shes ’ at the Pentagon 

123lfiOW. And YOU told the annd iuw a moment aoa that at ha& 

iz4 j to your kndwkdge dud - 

rzslthat she spoke on the te 93 

the pi&t&l ‘ prior to t&e-&&~-- 

phone with the President but that 

. 

Page 37 to Page 42 
BSA 

1069 

Neysa Erbland, Yl2198 

Page 43 

[I lshe did not see him until after the election, to your 

[zjknowledge. 

I31 A 

Q 

To my knowledge. 

141 And were ’ tabng about the election in 1996 

151 A Correct. 

161 Q What happened after the election, K you know, that 

[Tjshe 11 t&J you? 

A Thev saw each other a few times. She would ao 

it;there to the White House and under the assumption that she - 

[lolwas bringing some kind of documentation for hrm. You know, 

I I I I like as a courier. And thev woukf. vou know. have sexual 

; ;; j relations and then they talked on the phone as well. - 

Q 

I::ithe White House for these visits. 

Did she ever tell you how she managed to get inside 

A She would arrange it with Be 

~:~]call Betty and theyd ’ set up a time and thats ’ 3: ‘

I guess she would 

ow shed ’ get - 

(17jin. 

,lRl 0 Bettv beina Bettv Currie? 

of day or what days 

[221 A 

Q 

At the time, she may have, but I don7 know. 

And did she describe the nature of the 

i::icontact that occurred during that time between her an 8 

hysical 

the 

[251Preskfent? 

Page 44 

Ill A Yes. 

t.21 Q 

A 

What did she tell you? 

She told me it was - it was usually the same 

i:jthing. She would, you know, perform oral sex and, you know, 

tslthey would fondle each other and things of that ,natum. 

~~~~~~~~~~~~~~ And in the same location as youve drscussed 

. 

[El -A Yes. 

[ :,; ‘

Q Did she continue to discuss with you during this 

r 

nod of time her prospects for gettin back into the White 

[ 111 ouse? And Im ’ talking about now a f? er the election. 

123! She was u set. 

~241 $HE FOREPEF!SDN: Let me just state for the record 

[ 2 5 ; one of our grand jurors had to leave out. 

Page 45 

II, ~ ’ : mnert, MR. WlSENBERG: But we still have a quorum, 

-131 ‘-‘“~-. ‘ THE FOREPERSON: 

[41 MR. WlSENBERG: 

We still have a quorum. 

And there are no unauthorized - 

. _ [5: THE FOREPERSON: There am no unauthortzed - 

[6i MS. WIRTH: Should we take a break? 

[71 THE FOREPERSON: Yes. Lets ’ do that. 

161 MS. WIRTH: Thank you. You can step outside and 

rslwell ’ take a break for 10 minutes. 

rioj 

,111 .--, 

~i;m~~~u~d. Wtiness recalled.) 

..-. . 

Q Ms. Erbland youve ’ discussed the nature of 

i::iphysical contact between Monica and the President as she 

[ 1 I 1 described it to you. Was there any other 

[15]that you haven t already menboned to us P hat she told you 

hysical contact 

[16]abOUt? 

[I71 A Well I donY know K I did mention what he did to 

I 16 I her. He did manual stimulation on her and there was one time 

[ 191that she did tell me of - he took a cigar from his desk 

[zojand - and inserted inside of her in a sexual way. 

I211 Q Inside her vagma? 

1221 A Yes. - 

Q 

i::;President? 

Okay. Dii Monica have a nickname for the 

1251 A Yes. 

Page 46 

Ill Q What was it? 

[21 A She calted him “the big creep’ 

131 Q 

A 

Did she have a nickname for the First Lady? 

I41 You know, a few of them did. 

151 0 What do ou mean. a ‘ few of them did”? 

A Afewof tie women who worked in the office did. 

I76; And I was trying to remember what it was just because its ’

[s)funny. It was someth~ like POTUS but with a twist. 

Page 47 

A She went there - she had written him a letter, 

i :i; I think it was a lot to do about the job you know that he 

I 19 1 hadnt ’ come throuoh for her like he s&d he woub and. vou 

Page 48 

r11 Q And what did she tell ou about the a 

A Just - I dont ’ know. 4l 

ument? 

i:!she was angry, “How could you not res 

at he yelled. ? ou know 

nd to my letter? You 

r4)know, #oured miheart out to you a&l Ed&zust not 

rs]say an hrng and ow could you do that? 

And he got upset and said. you know, you dont ’

.~.~~;:“,.r$and, I try to be good and, you know. its ’ just very 

I91 Q Now, did she ever tell 

t I 01 mentioned that she sent him a letter. 

u - a moment ago you 

f% ~~sy$;!he t 11 sent him this letter? Did she mail it, did s 

rlzlelse with it? 

A I would doubt she mailed it. I dont ’ think she 

IE;ever mailed things because how would she know K they got to 

I 151 him. 

jlsjthem. 

I think when she sent things she atways messengered 

(171 Q Okay. And did she ever mention to you that she 

rlslsent a tape to him wfth her voice on it? 

1191 A 

Q 

She might have. Like a sex tape? 

I?01 

r2l)memory. 

I didnt ’ ask that question. Im ’ asking for your 

1221 A Im ’ not sure. 

0 

i::iyou know of? 

Did she ever send a message to him on a tape that _ 

I251 A I dont ’ know. 

.I . 

Page 43 to Page 48 

. 

0lcsfarT 
1070 

SSA Neysa Erbland, 2/12/98 

Page 49 

Q Oka 

I: i something with the b 

Dii there come a time when you .heard 

restdents ’ voice on it? 

131 A I heard an answering machine message 

[41 Q 

A 

And how did that torna about that you heard that? 

We were talkin on the phone and she sati. “Do you 

tziwant to hear his voice?” I sa idl 

r7la message on her machine that was - she said was 

Of ‘ course.” So she Gtirn. 

I81 Q 

A 

And what did you hea!? 

I heard “Monrca are you there? Its ’ me. Bill.” 

t:iiAnd then she picked up. And then there was a second message, 

[11 jlike “Hello, are ou there?” And thats ’ it. 

0 

I::ivoice on t%kviste;and so on. radro. 

bkay. And I take it upuve ’ heard the Presdents ’

1141 

Q Was there anything that ou could tell from 

i:iilistening to that over the telephone whe K 

[17jthe Presidents ’ voice? 

er you recognnedA It sounded like him. You know it kind of a 

~:~jscruffy voice and it had a little twang. You know. I mean. 

i 

tzolshe said it was him, so I thought it was him. 

. 

Q Now during the time that Monica was tatig to you 

I::;about her relationship ’ with the President did she discuss 

1231with you other 

A ro,. 

ople who she told aboui this? 

[241 

[251 0 Did she ever tell you whether - go ahead. 

Page 50 * : 

[?I A Her mother. 

I21 Q 

A 

Okay. Tell me about that. 

t:iknew and she said, “Yeah, I told mv mom.” But that her dad 

She just said - I think I had asked her K her mom 

[sldidnt ’ know. But shes ’ notvery cl& with her dad. 

[61 Q 

A 

Did she tell you what she toM her mother? 

/;;I didnt ’ know how man 

No, not details. I would have thought - u know, 

tglmother. I mean, Im ’ c? 

details she wouM get into with ?Zr 

[ 1olwant to tell her 

ose wrth my mother, but I wouldnt ’

[ 11 I had told her tha 9 

ory details, but I just assurrtad that she 

she was having an affair with the 

r121President. 

0 Oka 

f ::jdiscussed with you 

[lslthan once? 

[I61 A More than once. On one other occasion, she was 

I 17 1 talking about - it might have been the job or some kind of 

I 18 I problem or not beina able to see him and that she had spoken 

[ 19 jto her mom about it-and her mom had just made her feei better 

[zolabout it. You know - I dont ’ know. Or maybe had said to 

/ 

12 11 call him or to - just - you know, shes ’ been in the sams 

[ 22 I boat before. so she understood how her dau hter felt. 

(231 Q so 

124i A 

And when you say “the same at” what do you mean? 

Well, shes ’ also had affairs with married men. 

125; Q She being Monicas ’ mother? And you know that 

- -__.- -__ 

Page 51 

t 1) because Monica told 

x 

ou that? 

IZ! A Yes. 

i3i 0 

nd she wrote a book about it, too. 

Now, other than her mother, do you know of any 

[ I 1 other person that Monica discussed this wrth based on her 

[ 5 1 wnversatp wrth 

161 

0 

No, 7 

ou or any other knowledge that you have? 

dont ’ know. 

171 

A 

Did Monica ever mention Linda Tripp to you? 

Iii Well, I was talkin 

She mentioned her just like in passing, you know, 

to Linda the other day.” 

1101 Q Bu? she never toM ou that she told Linda 

[ 111 confided inAher;Eyt her relations k IP wtth the President?’ 

111 ’

Q Did she tell you whether she had told Ashky about 

1: :i her relatioFhrpN2ith the President? 

I151 

1161 Q Have you ever met Ashley? 

[171 A 

0 

No. I dont ’ think Ive ’ ever heard her name. 

1181 What about Monicas ’ brothen Did she ever tell you 

[ 19: whether she told him about this? 

[201 A 

Q 

She never told me. I wouldnt ’ think she would. 

Now, did there come a tima when Monica started to 

I:: { talk to you about leaving Washington, about her leaving 

[23lWashington? 

1241 A Yes. 

1251 0 Tell me about that. 

Page 52 

[II A That was actual one of the last conversations 

[zlwe had before Chnstmastims. !&he said that she was thinking 

[2labout T her mom had recently moved to New York and she 

[41was thinking about moving then and I thought that was 

t 5 I great. 

i76iof here, D.C. and you know 

I atways said she should get out then get out 

9 

away from the hsident 

[eland, you know, kind of start a rfs of her own. And she 

[slsad she had been thinking about it and it was pending. 

[loIShe was thinkin about a ob and all that. 

[ill. Q 8id she te ri you anything about her plans to get a 

[ 12 jjob in New York, places that she was interviewing or thinkrng 

[13labout? 

A 

i::iinterview with Bill Richardson. 

She said that the President had arranged for an 

(161 Q And who is Bill Richardson? 

1171 A I forget. 

;::;with? 

Q What organization does he have something to do 

A 

i:!isomething. And I remember her sayin 

Hes ’ - hes ’ a - like a government jqor? know 

because 

1221who ha was at the time when she said III Richardson and she 

[22]said, Oh. ‘ my God, Im ’ going for a meeting wtth Bill 

t241Richardsor1, who is the -” ypu know - 

1251 Q Does the Unrted Nations refresh your recollection 

Page 53 

t 11 at all? As the organization hes ’ associated with? 

[21 A 

[31 Q 

Hes ’ like the head guy over there, tight? 

I 4 3 memorv? 

Well, Im ’ asking you. But does that refresh your 

I 

.-, - ,- 

[51 A Yes. 

,CI RY MR WtSENBERG: 

I71 u 1 , ou recall her mentionin 

te~been the U.S. n,nsentatiie to the United R 

that he might have 

[ 9 J something likethat? 

ations or 

[lOI A Something like that. Which sounded very big and 

t lllsaid, “No wonder youre ’ nervous to go meet him.” 

(121 BY MS. WlRTH: 

1131 Q You mentioned a moment ago that the President 

I 14 J arranged this interview. 

rlsjthat personally or throu 

Dii she tell you whether he did 

h someone else? 

[161 A She didn t‘ say. 

I171 Q Da she ever mention the name John Podesta? 

r1sj A I donY know. 

I191 Q Did she ever mention the name Vernon Jordan? 

I201 _ A I dont ’ think so. 

Q Did she tell you that her interview with Mr. 

I::; Richardson had taken place? 

1231 A No. I dont ’ think I spoke to her after she had 

t24lsaid she had the meeting. 

I251 0 Did she tell you whether she ever got an offer from 

Page 54 

[ 1 j the United Nations or from Mr. Richardson? 

[21 A 

I31 Q 

She didnt ’ say. 

t 4 I with the United Nations or &. R&a&on? 

Did she tell ou an other job prospects besides 

I51 A No. 

I61 Q Ddshe 

-171 A Ineverk 

relthattookplace-Iwas 

[91 Q Wherewe.. 

[lOI A I was in Mexico. 

I111 Q When was that? 

A Over Christmas vacation so from - actual 

i::iin Houston and in Mexico. It was from the lgth of Deam !L 

I was 

$e&d+ I believe. 

r ‘

ildjand we ca$e b$ 

1151 

[I61 -A Of: 

I:i;at all? 

QAI-K k%?t period of time, did you speak to her 

,191 A Nc 

them-yme a time when Monica discussed wfth 

-/ have but nothing - nothin intcrutina 

..*everdiisswithyouthats%e 

y in the Paula Jones case? 

OlCStan 

. 

Page 49 to Page 54 
1071 

Neysa h-bland, 2112196 uI*x(w 

Page 55 

Q Did she ever tell you that she had to submit an 

iE i affidavit in that case? 

.:- A No. She told me - but I dont ’ know if it was in 

:i i connection with the Paula Jones case. she told me something 

::.about Karen Wiliey - Karen Wi 

16: Cl YW~lley? 

What did she tel you? 

.-. A She had said - it was a while back. She had said 

;: ;there was some kind of stir going on, that this woman was 

:;. oin to come forward with some kind of an allegation towards 

:fl: to 

.: ::%ej%+dent and that - I think it was Linda who was trying 

et n touch v&h - the 

.::.ea nx, the kind of aide, s It 

uy I was telling you about 

e was trying to get in touch - 

:z:with him to warn them or somethin 

It was a big mLx of all d if? erent peoples ’ names 

,izjand it was very confusing when she was telling me and she 

- ‘ ;.ke t havin to 

:z:~o? &at9 

o back over it because I said 

f 

ou know, 

You know, I didnt ’ understan because I dont ’

f~ iknow any of these people. And that the aide wasnt ’ calling - 

:g:back, that nobody was calling her back and she was - 

mm. -I. Q Her being Linda? 

T.. A Her being Linda. So she was, you know, angry 

Iiibecause of that and angry because, well, she vas .ust trying 

:j;to help and I dont ’ know whatever hap 

0 Do you remember wha 

$n@ tih bat. 

penod of brne those 

ificonversations took place or conversation with Monica? 

Page 56 

. . 1 

i;jearly 97. ‘

A Well. she was at the Pentagon. so it was probably 

:3. Q Did Monica ever discuss with you any conversations 

F I:she may have had with the President about her ever bein 

: 5: asked uestions about her relationship with the President 

91 

% y 

:s:anyone 

I?’ A I dont ’ think so. 

C‘ ’ Q A while ago we talked about the gifts that Monica 

i ij received from the President. 

:: ::drscussions with her regardin 

Did you ever have any 

s : :: ; presents, ;heri;!ey are now. 

what happened to those 

,.... / --, 

!:?: Q What she did with them ifan 

:14: A From the last time I spoke to Ii-L‘ 

hlng? 

[ I 5’ kept them. 

r, you know, she 

. . _. Q Earlier, you told us !hat the last time you spoke 

ifrLfo Monicay FeFary 16. 1998. r-2: 

,.-_ 

Page 57 

. I said. “Hey, its ’ me.” And she said, “Hi. Im ’

if :gonna call you tn a few days.” And I said “Is everything 

:3.okay?” Because that was just stran 

;c.days.““You know.,its ’ usually a few ours. 

p, Call ‘ you In a few 

- I: j And Ill ’ call you in a few days. 

Everything s fine. Happy New Year 

And I said %&it. Watt. 

b the way. 

.- : Wan. Let me ive ou my new phone nuniber.’ Gave it to her 

$and thats ’ the !ast &e spoken to her. 

So, I mean, d sounded to me like somebody was 

[ 1: ;there and I knew something was wrong and then I think it was 

1:: : two days or the nqxt day that, ou 

: :: : the paper, Im ’ dnvmg to schoo r 

know, the front page of 

and I hear it on Howard 

::j:Stem. 

::4: Q Did Monica have a page0 

..z. 

L--. A No. 

::6: Q That you know of? ,.-* /- A Not that I know of. 

Q 

/:4:her? At work or at home? 

When you called her, where did you generally call 

ixi A Both. 

(2:: Q And you mentioned that the last tima that you saw 

:2:: Monica was Thanksgiving. 

A The last t~rne I was sup 

i::jThanksgiving. but I was staying out in 

sed to see her was 

%libu in California 

[ 2 s 1 and theres ’ two main streets and if anything goes wrong on 

Page 56 

[61 Q And was that in California? 

A 

/ijThanksgiving. 

Yes. lt was the last time she cama before 

Q Other than your lawyer is there anyone V&IO youve ’

r:ijdiscussed your testimony with, your t&timony today with, 

[l~lother than 

1121 x 

our lawyen 

I discussed it with my husband. 

(131 Q Anyone else? 

I141 A No. 

I151 I, c, mothen Q Have you ever discussed any of this with Monicas ’

,_” ,_._______. 

A 

i:i{talked about with the la 

No. I did discuss with my parents just what I had 

er. 

[I91 BY MR. WISSBERG: 

Q YOU mentioned that Monica told you the President 

I:?; had givenpr a&timgition of Leaves of Grass. 

[221 

Q Was it your understanding that a first edition 

i::iwould be lp a;&?inal first edition? 

(251 

Page 59 

A 

[:z! box or just like a box to keep 

ttlwas some kind of a box. It was either a cigar 

ou know s cial thin s. 

(111 Q Do YOU remem 4e rwhat 6oorshesa1 p” .%. Rwas? 

l12i A 

Q 

\::imad bacaz 

1151 

[I61 

I171 AQ 

rlslbetter. 

I191 

[ZOI 

1211 

1 dont. ’

You said at some point in time she ap ared to be 

she didnt ’ have access to the Presiden r . 

Mm-hmm. 

Is that a yes? 

Upset, I would say. That would characterize it 

Okay. Upset? And did that appear to be genuine? 

Yes. 

Okav. Not faked? 

i22j A No. - 

1231 Q 

124 lshootin 

All right. You mentioned earlier when we were 

[zslthat An % 

Out names about a particular aide, you indicated 

rew or Andrew Friendly might ring a bell. Is that 

Page 60 

I 1 I correct? 

I21 A Yes. 

Who Linda Tripp didnt ’ get to in time. Do you 

1101 A 

Q 

Yea. He didnt ’ call her back. 

He didnt ’ call her back. In connedion with that 

[ :: i information that was told to you b 

rwthe name BNIX Lindsey ring any L 

your friend Monica does 

[I 4 I have not gotten bade in time? 

Ils as the person &IO might 

1151 A I couldnt ’ say. 

I161 0 ,my. Did she ever indicate - lets ’ not just 

117 ]tie it t? a @wsult.liie Jones v. Clinton or any other 

I 18 I lawsufi, did Momca evqr appear to be wornad about havii 

rlslto talk or answer quesbons about her relationship with 

12o)the President? 

1211 A 

12211 was talki 

I dont ’ think so. I dont ’ think in the times that 

r23]had gotten “a 

to her that any of this was going on or that it 

~Z~country 

0 

0 the point where it is. 

Okay. And I think you said you were out of the 

or Out of the California area from December l$tth 

I ‘ . 

Page 55 to Page 60 

. OlC-StW 
BSA 

1072 

Neysa Erbland, 2112198 XWfll 

Page 61 

[ 11 until January 2nd. 

(21 A Correct. 

I31 Q WouM ou have spoken to her, if you recall, 

[rlbetween the 17th andk l%h? 

I51 A OfDecembs~ 

I61 

(71 E I%% think so. 

Q All ri 

it; being called in the 9 

ht. So assumin that she didnt ’ learn about 

ones case until &a cember 17th it% 

I ifi r 

ssrble that before you left the States, she wouldnt ’ have 

ad a chance to talk to you about it. 

[I21 A Exactly. 

Q And you mi ht have answered this I just want to 

I ::: make sure I understand. 3 

ilsjJanuary 2nd. 

ou get back in the country on 

I161 A Mm-hmm. 

Q 

i:iiconversation on the 16th. 

Did you syak to her between coming back and this 

A 

I:i:on mv machine and then I had the stranae conversatron with 

No. She had left a message a few days before that 

ii;jher. ’ 

1221 Q A few days before the 16th? 

[231 A R ht. 

0 

I::ithe President? 

O!ay. When did she say the relationship began with 

Page 62 

(11 A A few months after she started working there. 

(21 Q Did she relate the beginning of the relationship to 

[ 31 any particular event? 

A She related there was a ball or some kind of big 

i:idinner event that she attended where she wore her green suit 

161and that was the first suit he noticed her in, where thev 

r7jactually made eye contact and, you know, she - I guess 

[e 1 decided she fancied him. But thats ’ - 

[91 0 Did she ever mention the furlough? The furlough 

I 10 I and govezmen;oJ,hutdown? 

ill1 

I121 Q Do you recall her discussing, Ms. Wirth mi ht have 

!;3jasked this., do you recall her ever discussing having to w I-# e 

~14lan affidavit? 

:151 A No. 

I161 Q Did she ever say an htng. again, not in 

: :7 1 relationship to any case and Ms. vf rrth touched on this in her 

: lslquestion, but just in eneral in talking about what to sa 

i I slabout what she shou 3 d say about the relationship with rv he 

: zo 1 President? Do you ever recall her sayin the 

: 2 11 lines of, you know, “The President just to % 

anything alon 

:zzlanything like that? 

me to deny i9. 

:231 A No. 

:24j 0 Did she ever mention the concept of if there are 

: 2s 1 only two witnesses to an event, theyre ’ the only two who know 

Page 63 

!: labout it and if theyre ’ okay about it, theres ’ nothing to 

[z !wony aboz? ANnoythIng kke that? 

!-i, .-a 

I41 0 

: 5 1 your testimony 

Who are some of your - and I haven? heard all 

so I apologize if youve ’ been asked this, 

: 6 1 you’re a ciy fnend? 

iii 

Yes. 

101 

t-1 

2 $fig-time friend of Ms. Lewinskys? ’

1101 a D:-you know of any other &se friends long-time 

[ 11 jfriends, who she mrght be as intimate with as she is with you 

. I 12 1 in terms of confidin in them? 

A Wel ? I know she has - I would sa 

i::lfriends. And one of them Ive ’ never met. I dont ’

two other close 

Ll ow if 

[ls~she would tell them, you know, what she told me. 

[I61 

I171 

9 

A 

,l.!s ‘ poss$$? __ 

:I81 Q 

11-s poss~ore: Yes. 

A 

Theyre ’ friends from California? 

j:i;but Im ’ not sure. 

One is and the other one I think is from Portland, 

Q 

i::;narnes are? 

And do you know who those people are? What their 

1231 A The one from California. I iust know her first 

rztlname. 

. 

1251 Q And who is that? 

Page 64 

::’ 

;:i 

A Natalie. 

0 Oka . And then the Portland person? 

;3: A L 

Q 

May Cheryl? 

Okay. And you continued to be a friend of hen, 

i: i obviously after she went to Washington? Of Monicas? ’

161 

i7i 

A ‘ Yes. 

Q Youve ’ known her since you were how old? 

181 A Fiieen. I uess. 

riiifriend of Monicas? ’

Q All right. it er mother knows that youre ’ a close 

A Yes. 

Her mother knows that youve ’ continued to be a 

I151 MR. WISENBERG: 

[16]right now. 

Okay. I think thats ’ all Ive ’ got 

I171 BY MR. BINHAK: 

Page 65 

1:; 

A She was interested in drama. I think she was in a 

lay or two or a musical. What subjects she took? I mean, I 

131 iii Ink we all took the same things an 

[Cl. Q Was there an area s=s particularly interested 

[slrp. like science or math or history or writing or somethrng 

r61like that? 

[71 A I wouMnY know. 

Q 

I”, 1 okay in school? Dii she do well? 

.Oka What about school? Dii she do generally 

A Yes. Shes ’ very smart. She did well in school. 

I:f;She wanted to o to ood schools. 

Q ’ ind did she have friends? Did she have boyfriends 

i::iin high school? Well, first, did she have a lot of friends 

[~rlin high school? 

[15! A She had - I think she was part oflike a group of 

[16]giris who werent ’ very nice kind of situation. 

1171 0 When you say “werent ’ very nice,” you mean werent ’

I 18 1 very nice to other people or - 

I191 A. And in&din 

[zolwith h$,wereht. you know, 81 

her. You know, she did struggle 

1211 hgh s 

rough h 

ool Ids arent ’ very nice abo 

3 h school and, you know, 

that. But she s - 

[zzlypu.knqw, she was atways a very warm and sweet 

[23]girl in high school but, a ain, we werent ’ very good 

ou know, 

;;;;in the earl&days,. so 

&nds ‘

- t I! ats ’ the best I can give you. 

Drd she have boyfriends? Did she go out on dates? 

Page 66 

Ill A I know she had a boyfriend in eighth grade. 

(21 Q Before ou knew he0 

A 

i:iended up bein 

Before r knew her. But I know that because he 

m 

I 51 But other than 9 r 

boyfriend for a while then in tenth grade. 

ha , I dont ’ really think so. 

161 Q So wquM you basicalfy say she was just sort of a 

j 7 j normal higl s~xII;J.? 

(81 

Q Okay. And then I know 

r!:iher when she went off to college and 

ou didnt ’ go to school with 

[ 11 I Clark, but did you 

la r er to Lewis and 

rl2]coliege and stuff Ii r 

t a chance to meet her friends from 

e that? 

A Well I went to Lewis and Clark to visit her once 

i::;and I mat her roommates. She lied with - I think three 

I met them, but we didnt ’ spend an time with them 

I met a couple of people from schoo r , but, again, we 

spend time with them, tt was uat ‘ inboducbons and 

rlslthen she and I did our own thin f dut she - you know, she 

w~;w~wd to be enjoying 1. She ook me to psychology class of 

.__,.. -.-. 

;::;Clark? 

Q And do you remember how well she did at Lewis and 

[231 A 

Q 

I think she did fairly well. 

IZ;college kid? 

And did she seem to you like a perfectly normal - 

OlCStarr Page 61 to Page 66 
1073 

Nevsa E&land. 2112198 

- --- XII&X,,,\ ._, 

Page 67 

[II A Yes. 

Q Do you know - I assume she got rn!erested in 

geopolitics if SF caM~~m~~hington. 

I41 

151 Q Can ou lace a particular time v&en she kind of 

[6] 

w 

ot interested in pol 8 ICS B Was she always interested or 

(71 ats ’ somethin that developed in col 

[El A !donY know when it wou 

e? 

?I be. I thmk it would be 

rslin col e. Coke 

tlolwant 3 

maybe at Santa Monica 

to be tn the FBI. That was some 

[II ~she was interested in and when she went to 

tlzlthink the FBI thing kind of went out but somethrng m 

tl3lgovemment was where she wanted to be. 

Q Do you think thats ’ why she started to focus her 

~::~attention on Washington? 

[I61 A Yes.- 

I171 0 Do you know whether she was interested in the WtGte 

t I 5 j House because she wanted to work in the White House or - 

[lglbecause she had an op 

ttolthe answer to that ques r 

ortunity to work there? Do you know 

Ion? 

1211 A 

rzzlopportun 

,You mean as oppoqed to if she had had an 

y, lets say, in the begrnnrng to work at the 

.--, r231Pentaoon. 

[241 

[251 

- Q Right. I meanA I thank she definitely wanted to be in the White 

Page 68 

111House. 

0 Okay. And then - so the interest in the White 

I:;House came before the opportunity. Thafs what you think. 

[41 A Yes. I would think. 

[51 Q Okay. When Monica got to the White House and she 

[s]was an intern. you said that she told you a little about her 

17 jjob and you sand that she would couner packages and do small 

[B jerrands and stuff like that. Did she tell you whether she 

19 1 hked her job? 

I101 A I dont ’ know. I think it was all so exciting and 

[ii ISO new at that time that she would have - yes, that she 

[lzlliked it. 

I131 Q 

(14 1 House? 

Did she tell you about the people at the White 

[I51 A Not really. 

Cl61 Q Did she sa that she made friends at the White 

[ 17 1 House among the other tn 4 ems? 

[lEl 

1191 

izoi 

A - Yes. 

0 

A 

And was she basically happy in Washrngton? 

Yes. I mean, shes ’ verv souable. shes ’ verv 

[:llamiable. 

I 

i.221 Q You had said earlier to the grand jury that you 

[ 23 ] had -. at one pornt. you advised Monica that she should leave 

(24 IWashIngton. I assume that at this time you werent ’ advising 

(2 5 1 her to leave Washrngton. 

r11 

I-‘1 

131 

Page 69 

A No. 

Q 

A 

kgi;hats ’ because she seemed happy, right? 

.-. 

I41 Q AIrright. And then you said at sorns point you 

[ 5 1 knew that she moved to a 

- t 6]She ever tzl you how that 1 

aid job at the White House. Drd 

appened? 

I71 

Q 

No. She may have. I don1 remember. 

181 You dont ’ remember an hmg about it? 

[91 A I just think it was kind o ?’ how things went. If 

I lolyou started at the White House as an intern and you did well, 

t I 1 Ieventually ou would be moved into a paying .ob. 

I121 i 

[ 13 1 at the White House 

ou get the impression tha she was doing well 

[I41 A Yes. 

Q And is that from thin 

i:zl]friends and the res onsibilitiis she 8 

s she told you about her 

ad? 

I171 A Jus P I think more that she was just shtl there and 

[ 15 j still seemed to be flourishin 

0 

I:z{she was living with her mother in Washington 

You said tha 9 you knew - did ou say that you knew 

5 

I211 A Mm-hmm. I did 

Q 

i::{to live with her mom? 

Did she ever tell you about that, what it was like 

A 

i::jdays she was going to get her own place but she - she 

Sometimes she talked about you bKm one of these 

Page 70 

[lldidnt ’ - l think her brother sometimes got in her way and, 

t 2 1 you know, wed ’ be talking on the phone and somebody would 

[ 3 1 come knockrng at the door and R would irritate her. 

f41 Q You said that you met her mom, right? 

I51 A Yes. 

I61 0 And have you met her father? 

L71 

181 

A Yes. - 

Q And have vou met her brother? 

A Yes. * 

Q Whats ’ her mom like? 

isi 

[IO1 

t 17 1 ner mom-l uunng nr n scnoor? 

I181 A Yes. e es. She was living with her mom. 

I191 Q Do vou know if her mom was married at that time? 

I2Oi 

I211 

1221 

A No.she ‘ wasnt. ’

Q How did she get alon witn her mom? 

A She got along well WI II her. 

i23j /era thev dose? 

PO 

I251 

Q i7 

A Yes, I think so. 

Q Did they seem to talk about - you said you dont ’

Page 72 

tllthink she talked about the actual details of this affair with 

t 2 I President Clinton, but lets ’

t3jDrd they seem to talk abo ur 

ut that aside for a moment. 

14 lgorng on in her lii? 

the various things that were 

151 A I thinkso. Yes. 

[Cl 

171 

AQ lDti,fkhXoMlk to her mom about her friends? 

Q 

ii!because her mom knew you, right? 

You think she obviously talked to her mom about you 

1101 A Right. 

Q 

iii/doing in school? 

And do you think she told her mom about how she was 

1131 A 

I:!; brothefl 

Q 

-I would think yes. 

What about her brother? Did she get along with her 

1161 A 

I;;; brother bu 

Uh-huh. You know, just kind of the normal little 

&Ry BikH4K: 

s ou but for y$$ rt she loves him. 

t191 THE WITNESS: 

8 brother by the way. 

MR. BINHAK: 

Im ’ a little siste;. 

if!iAnd thats ’ not evidence. 

But I never bothered my sister. 

1221 

I231 iWl%~NHAlC 

0 

I::;dynamic is that its ‘ a pretty nomral family, then, I would 

So basically is your impression of the basic family 

-, . 

Page 67 to Page 72 

. : 

OlCStan 
 

1074 

Neysa Erbland. 2llY98 Xuu(lJI 

Page 73 

[6: 

t7; 

I;; 

r1oj 

111: 

112: 113: 

A Corrad. 

Q I would assums you talked about - 

A Me. Yes. 

AQ Annij0bs and school. 

Q And life in general? 

A Yes. 

Q So this was not an overwhelmina portion of what YOU 

ii4 iwere talkin about. 

. . 

I151 R 

Q 

The Clinton thing? 

116; The Clinton thing. Yes. 

[I71 A I mean it was pntty big. 

[I81 Q I would assume. 

[I91 A 

i:yiwas not the on 

I221 

,” 

Yes. It was juicy gossip, 

&air.a$rough. But you styI - even with this, this 

thin you talked about right? 

Q Ooksy And ‘ befora this before this affiir with the 

$:;President began. you said that she &ke to you about her 

[25]0thcr romances and boyfriends and stuff like that. 

A Yes. 

Page 74 

did you find her to be truthful about 

Did you get the impression that she would fabricate 

Izithings about different man or boys that she mat from the tan 

t 7 1 that you knAsw hao? 

iii Q Did 

tlolshe spoke to you a g 

ou get the sense that she was truthful when 

out other things, like school and jobs and 

t I I 1 other frienp ante;yff like that? 

r12: 

1131 Q 

[ 14 1 she would 

So did you basically rely on Monicas ’ words, what 

tell you? 

115: A Absolute1 

Q And you i, ad also testii before that you believed 

::76iher when ihe t;!syou about th&. 

1181 

I19! Q 

f201over time? 

And is that because youd ’ had this relationship 

[:I: A 

I:?: 0 

Right. I had no reason not to. 

iz,*toid YOU. 

This must have been pretty shocking when she first 

i24j . A Yes. 

125; Q What did you think? 

Page 75 

A I thought - I thought a lot of things. I thought, 

iii you know atta girl on one hand. I thought - you know I 

t 3 jcanY be&e that shes ’ actual1 

t 4 j relationships with, you know, txk 

you know, having sexual 

man who runs our country. 

[S~YOU know, it was huge. It was just - I mean, it was huge. 

161 Q When ou described the conversation onginally to 

[ 6 !sa 

[TlthJra; jury where Monica first told you about this., y; 

that at rrst she had told yqu that - she was sayrn 

[ glflattenn 

t 101 kind of 

things about the President and you said that 

d up and then finally she said “I m havin an 

t I 11 affair.” At that point, did you kind of sense that s It e was 

t 12 1 having an affair when she was talking about the President in 

[ 13 1 this flattering wa ? 

1141 A f&. I mean, I knew she thought he was vary 0ute 

tlstand sexy and all those things, but 

[ 16 ] could think that about anybody a 

ou know I mean you 

r 9 

nfit doesnt’’ mce&ri~ 

tl7trnsan that ou are havin an affair. Mayba - I thought 

t 16 jshe would Ike to. but JUS when she said all these things 

tlg~about him, at that 

tzolhavrng an affair w ir 

oint - I mean, until she said, “Im ’

rzllaffair with him. 

h him,” I didnt ’ think she was having an 

0 All tight. Did she over conversations - kts ’

~::~call that conversation number one, okay? 

I241 A Okay. 

I251 Q Is there anything previous to conversation number 

Page 76 

I41 .Q S!%at was a theme that ran throqr, sorna of your 

t 5 1 wnversatiTs p~noxJnvarsatron number one. 

[Cl 

Q Did that seem uncommon? Did it seam out of tha 

Iiiordinary or unusual in those previous wnversatiom? 

(91 A Not at all. 

Q When she told 

i:iihow long was that call? Was t 

ou about this affair the first time. 

K 

rlzlfor you. 

at a particularty tory call 

[::;I would think like 20 or 

A Probabs Whenwes~ke,wesp&egenemllyfor0 minutes, w ch IS long fume to 

[15lbe on the phone anyway, so it was probably a long 

[16]WnVersatin. 

1171 Q Mavbe more than an ho& iisj A Ma*. 

Q 

f:ilwhat she had to sav? 

And is that in part because you were interested in 

.-~. 

1211 A Yas: 

Q 

i::ione subject. Would this come up - 

And then I asked you before whether this was just 

after conversation one, 

t241woufd this 00me up in every conversation or 

1251 conversations where you just wouldnt ’ nach 

Page 77 

A IthinkitwoukJwrneup. lmaan itwasasif1:; ou know this was an o 

r3>&friend*so ifthere wa%u%la with a bo)+riend. w would 

oin relationship you know like a 

t 4 ] probably always talk about it at some poin . 

Q 

I ~~,&ut how to handk the situation? 

When them was trouble, did you offar her advice 

A Yes. I maan not - I guess during - you know, 

ii;she said Well I havent ’ se&i him in a long time. or 

t slsomethir! 

rlojbecause 8le 

like&at, I wouldnt ’ have anything realb to offer 

n was an unusual situation, so its ’ not like you 

[1110+ld just sa Well, you know.,call.him and, you kncw,,make 

rlz!hrmgo o.utdhJ ou 

1131the rasrdent 

or somathrng like that becausa he IS 

ut 1 did, you know, towards the end of it 

114 jwhen she was. you know, upset about not seeing bin and upset 

t lslabout, you know, not 

[16]she should get out of %I 

ettrng a job bade there, you know, that 

Q 

era. 

All right. Dldyc~u ever tell her “You shouMnY be 

~~~~involvad wJh aNyrrmd man In this context? 

t191 

0 Okay. Did you not do that becauss you ust ‘ didnt ’

i:Fithink itwas your place or was there some other reason 4 

A I just - I maan I just dont ’ think it - I dont ’

i::ithink its ’ my place. I guess. What two people do is - you 

124 I know, whoeveh rnamed, thats ’ his probkm. 

[251 Q Okay. But uttimately, you told the grand jury that 

Page 78 

I I 1y0u were ~wutt~,ing her to leave Washington, am&? 

[21 

I31 Q Was it in part because of this? 

I41 A Yes. ' 

Q 

I:Lvhat the conversation was? 

Can you just sort of elaborate how that came up and 

i7j A 

rslgetti 

Well, she was just very unhap 

the job back in the Whrte House like s L 

y and she wasnt ’

tslwas%thavry 

wanted. She 

t 101 wanted and 

vie relationship with the President that she 

was just always leaving her frustrated. So I 

t I I 1 thought? you know, after so many years. you know, ti 

I 12 I nothing s workrng out where you are, move on. 

1131 Q 

1141 A 

When you told her move on what was her response? 

r151t0: 

She sad, 1 know. I know. You kmrw, Im ’ going 

0 Did she tell you - I know you said that she told 

;:76iyou that she d&ussed this generally with her mother. 

I181 A Mrn-hmm. 

1191 Q Did she ever tell ou that her mothar had an 

!;;!rE$iin about whether she shou t kave the Washington area or 

,L’,..V.. 

1221 A She never real said, I dont ’ think. 

~~~~~~~~ of & Dqffh~gnfi~ dws~ m w mdher tb 

%s. Because she did say that if sha did move she 

_ 

A 

*_ . 

OlC-stam Page 73 to Page 78 
1075 

asA Neysa Erbland, 2112198 XWU) 

Page 79 

i llwas going to sta 

Q c)6 

with her mom, at least at the beginning. 

121 

A 

you know where her mom was at that point? 

I31 Somewhere in Manhattan. 

0 Okay. And you said you went to school in Manhattan 

Illand lived there right? 

(61 A Mm-hmm. 

[71 _ Q 

t B 1 like? 

Did you guys ever talk about New York, what it was 

[91 A 

I101 Q 

Yes. Well, when she came to visit me - 

In New York. 

A 

[::ilt there a lot. 

In New York. And, yes, because I really - ! liked 

(131 Q And so did you encourage her to o to New York? 

1141 A 3 

Q 

You mean when I was living then. 

,151 No. Let me ask a different auestion. 

.--a 

[I61 A Sure. 

Q When 

r 

ou were encouraging her to leave Washington: 

i:iidid she ever mention hat she was thinking of going to New - 1 

r191York? .-~, 

1201 A Yes. 

[211 0 

A 

Okay. How did that come up? 

She ust - I spoke to her one afternoon and she 

I::lsaid, “Im ’ thinkin a b 

Q V!as this in the context of her discussion of how 

out moving to New York.’ 

i::ishe was meeting Bill Richardson or was this before that? 

Page 80 

A 

i:ione. Maybe Im ’ thinking about moving to New York. Im ’ not 

It was probably in maybe two conversations, if not 

13lsure. 

I41 Q So it m’ 

A It might R 

ht have spilled over into two. 

I51 

Q 

ave spilled over into two conversations. 

Did she ever told you what she thought she might 

17”; like to do in New York? Did she say that she was interested 

[e 1 in sta ing with the ovemment or movin 

[ 91 indus r ry or any a rf ocular part of industry s 

into private 

A &ell when job talk came up it was I think because 

/ :ii of the Bill Richardson opportunity, but she had said she 

[ 12 jwasnt ’ sure that she wanted to be workin 

r13jUnited Nations or still in government. tha ? 

for somebody in the 

maybe she 

[lfjwould - 

Q Do you remember why she said that? Did she 

1 :~iarti&late any reason why she wanted to work at the United 

I 17 1 Nations? 

I181 A No. 

r19: Q And at that 

P 

oint. I.assume you were talking about 

[:o! New Yorkind zh;thtimw;,s ike to ltve In New York, nght? 

121: ^ _. _. . . .- 

(22: Ana were ou enwura ing ner to move to New York? 

(231 A” Yes. I saidl “I think tha? would be great.” But 

124 lshe sard she didnt ’ want to wme back to L.A. because she 

: 2 5 1 doesnt ’ like it there. 

Page 81 

11: Q arhcular about New York? 

i2; A 

Did she say anything in 

Just that her mom was t/L re and that shed ’ have a 

[ 3 1 place to stay for as long as she liked? 

1:; 

Q As she excited about t 

A Not at that point. I don ? thank I would 

ing New York City? 

- [ 6i CharacterIZe her as being excited about it. 

Q 

1 i i Washington? 

Did you get the sense that she wanted to stay in 

[91 A I got the sense that she probably would have 

[ lolpreferred to stay in Washington if she could be in the White 

[lllliouse. 

I121 0 But if she couldnt ’ be in the White House? 

1131 A 

1141 Q 

Then - well, she didnt ’ like the Pentagon. so no. 

[ I 5 1 Angeles? 

And did she tell you why she didnt ’ like Los 

:161 A 

t 17 1 just kind of - 

Just - I mean, she didnt ’ have to say it. it was 

[ 18 land just all r’ 

ust L.A. is a certain way and fake people 

o the stereotypical things that one hears about 

r191L.A. are true and, you know, she just doesnt ’ like it. 

tzo]Doesnt ’ like that. 

f211 Q You said a little bit about this and I just would 

122 1 like you to elaborate a little more if ou can. You said 

[23jthat you s 

124 ldetarls of P he sexual contact that she had with the 

oke with Monica when s rl e was describing the 

t25,President. right? 

Page 82 

[II A Mmhmm. 

Q And you also said that Monica said to 

I:iwanted to have sex with the PreSident, intercourse w 1 

ou that sne 

r 4 ~President. 

h the 

isi A Coma& 

0 But that the President didnt ’ want to have 

[76~interwurss wtthher. Is that correct? 

181 

3 %t?~ou described a little bit about her 

t:iiexplanation for wha r the Presidents ’ thinking was about 

[ 11 Ithat. Could you ust ‘ ex lain that agarn? 

I121 A He ’ felt &at having actual intercourse had 

t 131 repercussions that having,, say, oral sex didnt ’ have 

t I. I 1 and that - I mean, to me. tt sounded like just some 

tlslkind of P”M”,’ uy cop out thing you know? 

I::ithought she’ 

b$-lmean- I don? know. 

want to 1. et p 

Maybe he 

t 15 1 when youre ’ a man in IS pos Ion and 

qnant. you. know. I mean, 

t 191 know, I guess you have to take preca 

ou re mamed, you 

1201 having an affair. 

ions d youre ’

0 

IZ:iprecautiins? 

So you think this was one of his ways of taking 

1231 A 

Q 

I think it was a precaution. Yes. 

[::ithat with Monica? 

Was that your interpretation or did you discuss 

Page 83 

111 A Thats ’ m interpretation.. 

[21 Q If 

[slother than 

Okay. rd Monica give you any specific reason l 

that there were repercussions? 

A Well maybe also because he - you know he has a 

I:;bond with Hillary arid he didnt ’ - he just had a hard time 2 

t 61 I guess saying no after the fact, that he wanted to be, you 

t 7 1 know truer to his wife than he had been and intercourse 

t 6 rwould make it that much more difficult. 

t:z{Monica? 

Q And you got that impression from speaking to 

(111 A Yes. 

Q 

~i:~aspezts of her relationship with the President. 

All ‘ right. Did Monicaever ’ tell qou about other 

Dii she ever 

t 14 1 mention any other aspects? 

tlsldd she tell you other thin 

Putting aside sex for a moment. 

s that the would talk about or 

tls]other thingi tha+;fy wou 9 d do toge il er or - 

1171 

I:iiplease? 

Q Can you describe those things to the grand jury, 

A 

I:y:when they saw each other, R was just you know there in the 

I mean, they,didnt ’ really do other things because 

122 1 White House. So they didnt ’ go out or an 

r23ltatked.abqut - I mean, they talked about t;!q. ‘

hrn But ‘ they 

IS re ahonshrp 

tzrlwdh his wrfe and they talked about - you know, she loves 

tzslhim. 

Page 84 

Q Who is “she”? 

A Monica loves the President. 

Dii she tell you that? 

1151 Q Oka . 

A And r hat - what she took as he doesnt ’ know if ha 

ii76iwould - you know, once hes ’ out of oftice will he stay with 

ris~Hillary. you know, which she then took to 1 you know, well, 

rlglrnaybe she will be his wife. 

1201 Q This is Monica? 

A 

I::; his wife because she loves him and she understood that he 

This is Monica. Because she woukt have liked to be 

123lb~ed her tO0. And that RIaybe, you know, who knows. Nobody 

t2c~sard anything but who knows what will happen four years from 

r25mwwhen I am out of offrce. 

-: . 

Page 79 to Page 84 

. OlCStarr 
BSA 

1076 

Neyu Erbland, 2112198 xyu(w 

Page 85 

.. 1 Q So do you think that that was an aspiration of 

1 s ; Monicas ’ was perhaps one day to marry the President and be 

:3]with him? 

!I1 A Perhaps. 

iSI Q Did she ever articulate that to you? 

!61 A Not in so many words. 

:71 Q Did you sense that from the way she spoke to you? isi A Yes.- 

:jz;things? 

Q Dii Monica say whether they ever talked about other 

:::I A 

Q 

Not to my knowledge. 

ii:; him suggestions about po tcy or thrn 

Did she sar, for ins,tance. whether she wbuld giw 

s that would make the 

: 14 laovemment better or the country be P er? 

,ISi' A I dont ’ think so. - 

I161 Q Okay. You said that Monica would tell you alii 

; :7 j bit about the relationship with the President and Mrs. 

: 1s 1 Clinton. Can you elaborate on that a little more? What did - 

; 19 1 Monica tell you about that? 

A She told me that she understood their relationship 

i:!ito be they were like best friends and that he loved her, but 

i 22 j I dont ’ know how their sex life went, I guess. 

;231 Q 

:241 A 

Thats ’ what Monica wouM say? 

ijsjbetween them. 

Mm-hmm. But that they had a very strong bond 

Page 86 

_ 

I 

Q Was Monica hostile to the Presidents ’ wife? Did 

iii she exhibit some hostile feelings toward her when you talked 

: io jcareer with the President and-her own career goals? 

ii:] A I think she did. 

::21 Q What did she tell you about that? 

1:33 A I think it was more along the lines of, 

i 14 1 where she ‘ wanted to be and that he was going to 

ou know, 

he p her get r 

;: 5 1 back into the White House, which is where she wanted to be. 

: : 6 IThings of that nature. 

.._~ Q After it became clear that Monica would not go back 

i f 9 i to the White House, did she tell you whether the President 

: : 9 !encouraged her to, for nstance, go to the UN. or not go to 

:Ts:the U.N.. Did she chat wrth ou about that? .^. . A I dont ’ remem L r. She may have, you know, said 

i >I j that he had offered some options, not obs. ‘ but sard, you 

:; 3 1 know, you could do this or you could d 

;:a Icome back here. 

o that if you cant ’

.-=. L--J Q Do you remember if those were government jobs or 

, 

Page 87 

:s: 

161 BY MR. WISENBERG: 

.-I Q Im ’ not sure I understood the answer or the 

i 8 1 question. Are you sa ing that she wasnt ’ interested in 

: gworklng anp-y~s+$e&~~~ ycp& 

- ,9 i-*> 

.::I BY MR. BINHAK: 

il21 Q 

r 13 1 youre ’ sayin 

And do I understand correctly when I interpret what 

; i 4 ! government % 

is that the President encouraged her to say in 

ut that she wasnt ’ really that interested in 

: : 5 rgovemment unless she coukf worir at the White House? Is that 

: : 6 1 a fair characterization of what youre ’ sayin 

i:Tj A I dont ’ know. I couldnt ’ say ? hat. 

? 

::ej Q Okay. You said that you told 

WI! 

our husband about 

: : 9 1 this which obviously is a normal reaction. 

it o 1 husbands ’ reaction to all this? 

at was your 

,-. , 

tsi;shocked. 

A Similar to mine. I mean, he was, you know, 

1231 Q 

A 

Does your husband know Monica? 

1241 He knows her. Yes. 

125: Q Hes ’ met her? 

OlCStarr 

Page 88 

ill A Mm-hmm. 

Q And was his reaction - did he believe this 

i : j sequence of events that Momca was descnbn-g? 

L41 A 

Q 

Yes, I think so. 

Did he give you any advice about what to do or 

iZ;to say to Monica? 

(71 A No. 

Q 

lSgiyou told your parents? 

And what about - I think you said your parents 

- A Yes. 

what 

i17j A Yes. 

Q 

I:!;high school? 

And theyve ’ known her since you were friends in 

I201 A Yes. 

I211 Q What was their reaction? 

I221 A Kind of - like - tak, tsk, tsk. You know. 

[23]“0h. my goodness, what is this grrl getting herself into” 

(zrlkind of - 

I251 Q Do you think they believed the sequence of events 

Page 89 

r I j you were tellin them about? 

[21 A ?es. ‘

Q Did the give you any advice about things to say to 

/:;Monica ab;ut tkorho Ii affarr? 

[51 

161 Q And what about your sister? What was her reaction? 

I71 A The same. Oh. ‘ my goodness.” You know. Wow.” 

[e 1 But no advice from her. 

Q IOkay. Did Monica ever mention -well, let me put 

[:iiit this way. You sard that - you have described Betty 

r~l~Currie as a person who. I guess, would help her visit the 

rlz]White Hou;e arttcrlrtate the vrstts. Is that correct? 

I131 

Q Did Monica ever mention anyone else at the White 

i::iHouse who would help her get into the White House to see the 

[IslPresident? 

I171 A 

Q 

No, I dont ’ think so. No. 

Are you familiar with a name Nel or Bayani Net&? 

[ :i; Have you ever hear that name? 

I201 _ A Nel? Yes. I have. 

Q 

i::iremember about that name Nel? 

Okay. Why dont ’ you tell the grand jury what you 

I231 A Not much. Idon ’ t ’ know. 

I::iHouse? 

Q Could that be a person who worked at the White 

Page 90 

A That actual 

i:;that that was the person w 3: 

makes me think but i could be wrong, 

o was like the aide. 

131 Q Okay. Could it have been someone - when you say 

t I 1 “aide” do you mean someone who sort of serves things to the 

[ 51 President, helps him with food and that kind of stuff? Or do 

rslyou mean someone who carries his briefcase and gives him 

r7jmoney when he needs to spend money and shuttles around from 

r 8 1 meeting to meeting? 

[91 A Yes. Yes. 

1101 Q So thats ’ what you mean by aide. 

Ill1 A B aide. Yes. 

Q C& .But 

I :: bte White House atopposed ’ to a friend? 

you think Nel ia somebody who worked at 

1141 A I think so. 

Q Oka 

!::;the White House z 

Did Monica ever tell ou that after she left 

w en she was working a r the Pentagon did 

r 17 1 Monica ever tell ’ ou that she would get sort of knickknacks 

n~;w~n~itealfuse from other people kke candles or 

r 1 gIglasses or matchbooks or things rke hat with the 

-i21i- A She sent me some. 

1221 Q Oh, oka . Whatdidshesendyou? 

I231 A She sen r 

(20 Q Okay. 

me a couple of boxes of presidential M&MS, 

1251 A A couple of matchbooks. And Lifesavers. 

.i . 

. 

Page 85 to Page 80 
1077 

asA Neysa Erbland, 2112198 

Page 91 

Xux(l5) 

-. 

Page 94 

::. Presidential Lifesavers. 

.-. Q And when you sa 

Ii.normal Lifesavers and normal M I 

Lifesavers and M&MS. are those 

MS? 

If; A In presidential wrappin 

[;.from? 

0 Okay. Did she ever te 0 you where she got those 

r-- A I ust ‘ - no. 

IF: Q dti she say she got them from friands at the White 

: 5: House or someone who worked at the White House? 

1::: A 

Q 

She got them from the White House. 

iii;Monica would contact at the 

other man ~~~,p~s~~Ry,~~~~;~~~~ 

;;;:see the Pyide;;? 

- 

!?:I Q I knm from our testimony that Monica would see 

i:i:the President in his office. 6J ould she see him anywhere - 

I:-else? ‘ Did she ever describe seeing him on a trip or outside 

[;e:the White House? i 

115: A 

12:: Q 

Seeing him with contact? 

No, even without contact. 

A She may have seen him - I think it would be - no, 

[:iishe didnt ’ go with him when she was in the Penta on. I dont ’

[23:know. The only time they had sexual relations as !a r as I 

[24:know was when they were in this office. 

125: Q Do you know why Monica called him %e big creep”? 

Page 92 

,.. 

,-. A Yes. Because, you know, when she couldnt ’ get to 

ii:See him or he - ou know, like when she sent that letter and 

:3:he didnt ’ respon J 

1.1 

ou 

i4:him, YOU knowknow it was a nicer way of calli 

I e an as&ok ou know? Like hes ’ %e 

I 5.b~ creep and men atso it was B. t so Bill Clinton. bio 

[~fcr&ep, that was how she came up &ih big creep. - 

1: ‘ 9 Did she tell you that? 

16: A Yes. 

^*‘ ‘ Q So obviously at some point Monica would get - she 

ii E would ‘ express anger and frustration with the President, 

.~~. r::.correct? 

IiT' A Yes. 

Ii?: Q And she wouM also express admiration and love. 

Iii: A Yes. 

!iS‘ Q And would these iust swina back and forth. these 

iii:moods? 

ii” A Yes I mean whenshe ’ saw him, thin s were 

rhe missed him an c? would 

ii?:6e unhapp 

12:’ 1; 

:;: -about this. 

You said before that you think she told her mother 

Did she ever tell you what her mother said .- about -- 

i-r.the relatlOnShlD? 

She mqht have but I - I know her mother wasnt ’

ry about d or anythmg like that. I think she 

Page 93 

I., 

/ _ BY MR. WISENBERG: 

I:‘ Q Let me interrupt for ust ‘ a second becau& I want 

I 3to ’ make sure I understand your tes 1. imony. I had thou ht - 

I 4 not ‘ that she told her mother, but I had thou ht that ea er 

_ _ ; s.that you had said she told you that she ha c? told her mom a. 

j 6.about R. you dont ’ think she discussed explicit details with 

:-.her mother. 

15: A Correct 

!5: Q Is that correct? 

1::: A 

:il.tOld me. 

Yes. I know that she told her mother from what she 

ii;‘ MR. WISENBERG: Okay. Thanks. Sorry. 

112. .~~. BY MR. BINHAK: 

114: Q And th?t her .mothe! - as-far as you know, her 

1: 5: mother didit ’ teioyr. Stop Immediately ? 

.--. ,?E’ 

I:-: Q 

[ le :her situation. 

And that her mother expressed a certain empathy for 

[l?: A I think so. 

[ZG‘ Q Was her mother also encouraging her to move to 

[r::New York: Do you know? . 

122: I dont ’ know. 

123: Q Do. you. know if her mother was encouraging her to 

;;:;end the relationship ti the President? 

A I don? know. 

Page 91 to Page 96 

- 

. . . 

.-. Q Do 

: 2 ; the relationship wrt 4 

ou know if an 

the Presiden P ? 

ody was encouraging her to end 

:31 A I dont ’ know. I dont ’ know. 

:4: Q Is there any 

:s]tell her brother about this I! 

articular reason wh she wouldnt ’

ot er than it was her I it&! 

!s]brother? 

:71 A I dont ’ think she really talked about, you know, 

: 8 I boyfriends or those kinds of matters with her brother. 

Q 

: i :; Jones to you? 

Did Monica ever express any opinion about Paula 

;:?I A That she was u ly. 

!X] Q Other than the 9 act that Paula Jones was ugly, did 

! :31 Monica ever ex reaa any feelings towards Paula Jones? 

ii4: A fdont ’ think so. 

!I51 Q Dii ou ever discuss what Monica would do if she 

::6]got cau 

& 

ht having t x. IS affair with the President? Dii you 

::7]ever as her? 

:iB] A I never asked her. 

1191 Q Did she ever indicate to you that she thought she 

iiolmight get caught? 

i211 A No. 

Q 

j::idid it just never come up in conversation? 

Did she just assume that she wouldnt ’ get caught or 

1241 A It ust ‘ never came up. 

1251 Q V&at do you think Monica would have done, based on 

Page 95 

: 1 lthe >h of time that youve ’ known her? What do you think 

12 1 Monica would have done if she got cau ht? 

:31 A You mean red handed? 1. Ike if somebody walked in or 

i 4 j something? 

Q Well not red handed. What do you think Monica 

~~~would do, based onthe ’ relationship youve ’ had with her over 

[ 7 1 the past ten years, I guess, maybe ion er 

I B 1 that she was havino an affair wtth the 

if it came out 

B resident? I. What do 

: 91 you think her rea#i%&ild be? 

I101 A I think she would be devastated. 

[Ill Q Devastated because of her 

! : 2 I because she h8d an effect on the Presiden f” 

rsonal situation or 

[:3]embarrassed? Can you elaborate? 

or because shes ’

ii41 A I think all of the above. I mean, she wanted 

I :slto have a career in the government. which I would sa 

r::lwantto hurthimorherself. y$think- you know! 

ii6lat this point is probably not oin to happen. She di nt ’

: : 8 land probably that she woukln ba able to see him any 

r:slmoti. _ 

:201 -Q 

% 

Do you consider Monica a loyal person? 

I211 

:221 !% to her friends? 

(231 A Yes. 

I241 MR. BINHAK: 

rzslquestions. 

All right. Thanks. I have no further 

Page 96 

111 BY MS. WIRTH: 

471 Q 

181 A 

Okay. Do you know based on what you say that? 

From what she told me, that there were a few 

[slwho were close to the President and, you know, just around, $ 

opb 

11o1guess. where she worked who were suspicious of her always, 

ii1 jyou k&v, running in there. - 

1121 Q And the name Nel comes to mind as someone who she 

rl31said was susrhcious? 

il4j A-- Ithinkso. 

I151 MS. WIRTH: Okay. Thars all I have. 

I161 . 

I171 

MR. WISENBERG: What Im ’ goin to do is - 

MR. BINHAK: Are you finishing up 

MR. WISENBERG. 

s 

iii&e witness to bave for ust ‘ a few moments while we 

;:;;~~y matters and then II 

Well, actually. I was jping to ask 

ISCUSS 

ave her in for just a brief period of 

1221 

1231 

MR. BINHAK: I have one last quick question. 

BY MR. BINHAK: 

1241 Q Youve ’ told the rand jury now on a couple of - 

r2spccasiOnS that Monica thought 1 hat people at the White House 

OlCStarr 
 

1078 

Nevsa Erbland, 2112198 

( i 1 were suspicious 

(21 A Yes. 

[31 0 What was her ma&on to that? 

A Well it made her uncomfortable because, you know, 

i:iif people are sus idous, 

r 6 1 being scooted 

bad things can happen, such as 

0 # to the Pentagon. 

[71 MR. BINHAK: Okay. Thanks. 

MR. WISENBERG: 

Ii;few moments? 

May the witness be excused for a i 

I101 THE FOREPERSON: Yes, she may. 

1111 MR. WISENBERG: And if I could ask YOU to close the ’ 1 

- 

1 

I 

i 

Did Ms. Lewinsky ever mention White House stewards, 

~:~~people who helped bring food to the President, anything like 

rzljthat? 

(221 A Not tom knowledge. 

Q Okay. vy ou were mentionin 

i::ithe President had arranged a job interview 4 

that she told 

I7 

ou that 

or her with Bi 

r2slRichardson. Do you recall testifying to that? 

Page 98 

[II A I do. 

r21 Q Did she ever tell you why the President was 

r~~arranging this interview? 

[41 A 

Q 

Because he had promised to hel 

[Sl Okay. Help her out in what way ? 

her out. 

A In etting her a job. He had 

~76~would help her ge 9 a job back in the White It 

romised her that he 

ouse and when 

LB 1 that didnt ’ work out or he wasnt ’ able to work that out, 

rslthat. you know, the next best thing. 

Q 

/:F]other ob ‘ interviews that s e had that she told you about, 

ih 

Okay. Do \ou recall any other interviews, any 

[ 12 1 other an BIII Rich&on? 

I131 A I dont ’ think so. No. 

Q 

i::;who was helpin 

Did she say anybody else other than the President 

to 

I161 A 8he 8idnY mention any other names. 

et her a job during this period? 

1171 Q All right. Does Monicas ’ mother have any health 

[ 1 B 1 problems that youre ’ aware of? 

i::i 

A Not that Im ’ aware of. 

Q 

rzliaware? 

Has she ever had to have a nurse as far as youre ’

f221 A No. 

1231 Q Has she ever had to have a wheelchair as far as 

r24jyou’re aware? 

I251 A No. 

I111 A 

Cl21 Q 

Im ’ soy, could you say that again? 

You ve estrfied rn response to questions by 

[ 13 1 Mr. Binhak, I think, that shes ’ told you in the past about 

r I 4 j mlationshrps that shes ’ had and those things shes ’ told you 

[ 15 1 have turn? out$ol$rue. 

L161 

I171 Q All ri$rt. I want to. just. ask you at .a gut level. 

[I B 1 she told you about t IS relabonshrp mth the Pnsrdent over 

I 19 I several months - actually, over years. is that correct? 

[201 A Thats ’ correct. 

0 At a gut level 

I :: i she was telling you was true? 

did you have any doubt that what 

[231 A No doubt whatsoever. 

I241 

I251 

AQ iz;,“r~ didnt ’ know her to fantasize. did you? 

Page 100 

. 

.-. 0 Did she ever say who was keeping her from getting 

:I : back into tp W%;e House? 

3 ‘

i4: Q 

:i:her from getti 

Did she ever sa why she thought they were keeping 

back into the b&de House? 

A 

/“reason, real 

“9 dont ’ think she ever thought that there was any 

:E%rst place. s 

The onty reason was wh she left in the 

rsjdiscussed it. 

he may have thought that, 6 ut we never 

(i-1 Q Okay. Did she ever talk to you about other women 

[:.:that she thought the President might be having sexual 

r ;; : relationshi s 

7: i‘ L.-. x 

with? 

114: Q %?t$:Kat ‘ would she say about that? 

115: A She said that she would tease him sometimes about 

rlr: his other girtfriends, to which he would respond, you know, 

r I 7: Dont ’ be silly,’ or something like that. 

116: Q Pont ’ be silly” as if dont ’ oke ‘ about that or 

I 15: Don ‘ t ’ be sily as if I don? have other gr/friends? ‘

12:: A 

Q 

As if I dont ’ have other girtfriends. 

f:l&s President miqht have other oirthiends? 

Did she appear to be concerned about the idea that 

i23j A 6. 

[24: Q Did you ever remember her talking about a meeting 

[ 2s: on July 4th with the President of any particular year, a 

Page 101 

1::meetin 

2 rz;fondly. 

that she was particularly excited about or remembered 

I:; 

A 

Q 

She may have, but I dont ’ know. I couldnt ‘ say. 

You cant ’ call it up in memory right now? 

[5i A I cannot. 

I61 BY MR. BINHAK: 

17: Q Was there any particular meetin 

r e 1 put a date to that she was parbcularly excited % 

that she didnY 

a out? 

r9; A 3 dont ’ know. I dont ’ remember. 

Q 

i:Pirelationship with the President. About entering into it or 

Did she ever express any qualms about the 

[ 12 1 having entered into it? 

A You mean did she wish she never started this whok 

i::jthing kindzf a thh? 

115: 

i16: A No. 

I:ii 

Q All ht. 

x 

our relationship wrt 9 

You said to you Monica Lewinsky during 

at correct? 

her over many years. was truthful, is 

119: 

c2c; - A Yes. 

[2:: Q 

122: A 

Shes ’ atways been truthful to you, is that correct? 

Q 

She has always been truthful. 

Would it be farr to sa that at least with some of 

(zs~about. particular&th married me$they wouM obviously 

ii::these relationshi she has had an that shes ’ told you 

Page 102 

r 1; have to involve some deceit on her part, not to you, but to 

I 2 I other people? 

131 A Yes. 

iri Q 

r5jmat to you? 

Did she ever express any concern or remorse over 

(61 A Yes 

I71 Q 

A 

Can you tell us about that? 

Ii{she befriended his wife and she used to feel guilty that you 

When she was having an affair with Andy Bkiler, 

rlo~know, on one hand she was friendly with his wife and on the 

(11 jother hand she was sleeping with her husband. 

[I21 Q pid she express similar remorse wtth respect to the’ 

r 13 I affair with Apresett Clinton? 

ri4i 

iisi Q You mentioned that she referred to him at timas as 

rls~=the biq creep.” 

I171 - A- Yes. 

Q And, of course B.C b’ 

i$tere other things in her fii not jusi re 7 ated tothis ’ where 

creep Bill Clinton. Are 

~201she gave ~op~o~icknames based on acronyms? 

I211 

Q 

!%e White House if she thought people were still suspicious 

Okay. Do you know why she would want to go back t 

(24 ]afUlt the relationshi ? 

_ 

1251 A No. !! he just wanted to be back there. 

*. . 

OlCStarr Page 97 to Page 102 
1079 

Neysa Erbland, 2l12lSB XWW 

Page 103 

..I---- - 

151 A Yes. 

176ibeen 

1 B 1 that s x 

191 

I101 Q 

clllfarni 

r 

Did you ever have any fears. you or an 

have any fean for Monicas ’ safety after she tol J 

body in your 

r12labou the Flabonshrp? 

you 

[I31 No. I dont ’ think so. 

il41 0 Did Monica ever e ress any fears to ou about her 

/:56iKsident? 

rsonal safety in connection with 3 er relationship wd 3 the 

.~~. 

!I71 A I dont ’ remember. 

Q Okay. Do you think you would remember if she ever 

I:iisaid anything like that? 

I mean, I YouId unless she really .ust said it in 

[f%!ras$ng, Ii& rou know, I hope, I wouldnt ’ get killed over 

[221 hrs, or some hrng rn passrng, like almost as a joke. 

i241 2 %a% she would have said it seriously, I would 

i25jhave remembered. 

Page 104 

;20; 

;::; 

:221 

:231 

L241 

i25i 

A Yes. 

Page 105 

111 A Yes. All of them are home. 

7 

ki 

Q Okay. How abouta work number? 

A There isnt ’ one. 

[4! Q 

A 

Okay. There hasnt ’ been one for a while? 

_ is1 0 

Q 

I mean, my husbands, but Im ’ never there. 

~76icall you on? 

Do you have a cell phone that Monica would ever 

181 A No. 

I91 Q Okay. Beeper, pager? 

;101 A I have a pager but she never used it. 

1111 Q Okay. Do you - I had another question that one of 

I lzlthe grand jurors wanted to ask and it escapes me right now. 

1131 Just a second. 

!I41 BY MR. BINHAK: 

Q While Sol thinks about that along the lines 

i:ziof one of the questions a couple of times ago that there 

r171might be other things that you remember, in Ibht of our 

: 16 idiscussions today are there an 

! lg)rec.eived that 

2 

ou still have tha r 

items that ou m’ ht have 

would be re t vant 9 ‘ o our 

: 20 1 investigation 

1211 A No., I did et - a while back she had given me 

: 22 ~a color Xerox of - rt was 9. Ike a standard White House, you 

:22j know, of all the em loyee - a photograph. lt was her and 

I24 IClinton. But since P he move, I looked for it, I dont ’ know 

[25jwhere it is. Its ’ really a standard one. so I didnt ’ think 

Page 106 

~i]itwouMberelevantan a 

[21 BY MR. WlS&!ERG: 

131 Q She played the answering machine tape to you over 

I 4 I the phone. coned? 

ISI A Correct. 

I61 Q You never saw it? 

171 A No. 

181 Q You never had it? 

191 A No. 

rioi 0 

A 

Do you have any idea if anybody has a copy of it? 

1111 I would doubt it. 

Q Okay. Have you heard directly or indirectly in 

i::;recent weeks or even before that Monrca has attempted to get 

r 14 1 rid of any ifts she mi 

Just in 3 

ht have gotten from the Presrdent? 

I151 s 

I161 Q 

he paper. 

Okay. This tn 

r 17lsay YOU went before YOU wen P 

that you took to -where did you 

to Mexico? 

il81 - - A Houston. 

1191 Q Houston. Dii you plan that trip ahead of time? 

I201 A Yes. 

1211 Q All aspeds of it? 

[221 A Yes. 

1231 0 

r24lTexas? 

Okay. You actually desired to go to Houston, 

i25j (Laughter.) 

Ill 

(21 

[31 

[41 

ISI 

[61WlfT 

i71 

181 

191 

1101 

SON: Yes, she is. 

G: Thank you very much. 

Thank you. 

1111 

I121 

1131 

5: 

Have a safe trip back. 

Thank ou. 

?~:%~!dy&e taking of testimony 

il4jin the presence of a full quorum of the Grand 

w;~ndude$). . . . 

ury was 

Page 107 

A No but I went. 

MR. WISENBERG: 

less fr 

All right. With that, is the 

ii7j 

1181 

Cl91 

I201 

I211 

(221 

I231 

I241 

[251 

Page 103 to Page 107 

. OlCStan 
1080 
1081 

OK-302 iRev. 8-19-94) 

- 1 - 

OFFICE OF THE INDEPENDENT COLNSEL 

Date of transcnption 08/23/98 

KATHLEEN ROBIN ESTEP, Licensed Certified Social WorkerClinical, white, female, date of birth May 6, 1945, place of 

birth Washington, DC, Social Security Account Number - 

home address 

home telephone number 

Rockville, Maryland, 20852, work telephone number - 

was interviewed at the Office of the Independent Counsel (OIC) 

1001 Pennsylvania Avenue, Washington, D.C. The interview was 

conducted after a waiver of the patient/therapist privilege was 

executed by MONICA LEWINSKY, ESTEP's patient at one time. ESTEP 

was provided a copy of the waiver signed by LEWINSKY. 

Present for the interview were Associate Independent 

Counsel (AIC) MIKE EMMICK and AIC IMMERGUT. Present representing 

ESTEP was MAC EHRLICH, her attorney. ESTEP, being apprised of 

the official identities of the interviewers and the nature of the 

interview, provided the following information: 

ESTEP advised that she has a Master's degree in Social 

Work and has conducted 3,000 hours of supervised therapy and 

passed a licensing exam to be considered Licensed Certified. 

ESTEP first met MONICA LEWINSKY in November of 1996, 

while ESTEP was working at the GREEN MEDICAL CENTER in Tyson's 

Corner, Virginia. LEWINSKY was a patient of Dr. MICHAEL GREEN, 

who had a weight loss clinic at that location. GREEN referred 

LEWINSKY to ESTEP because it appeared LEWINSKY was undergoing a 

lot of depression and anxiety. 

ESTEP provided the OIC with a copy of her file on 

LEWINSKY and referred to the file during the course of the 

interview. 

LEWINSKY's first appointment with LEWINSKY was on 

November 9, 1996. At their first meeting, LEWINSKY said there 

was something she would not tell ESTEP. LEWINSKY said she would 

tell ESTEP everything but that one thing. ESTEP found that 

intriguing. 

During this first meeting, LEWINSKY advised she was 

Investigation on 08/23/98 at Washington, DC File # 29D-OIC-LR-35063 
1082 

OK-302a (Rev. 8-19-94) 

29D-OIC-LR-35063 

Continuanon of OIC-302 of KATHLEEN ROBIN ESTEP ,oz 08/23/98 , Pa_er 2 

depressed because she had terminated a pregnancy. LEWINSKY went 

into details of her relationship with someone other than the 

President, who was the father of the-child and with whom LEWINSKY 

had a short relationship. 

c * 

ESTEP'S analysis after this first meeting was that 

LEWINSKY was depressed and was suffering from low self-esteem. 

ESTEP thought LEWINSKY was very self aware, was not delusional 

and was fairly stable. 

At their second meeting, on November 15, 1996, LEWINSKY 

told ESTEP she felt she could trust ESTEP and disclosed her 

relationship with President WILLIAM JEFFERSON CLINTON. LEWINSKY 

spoke about CLINTON for nearly the full one to one and one half 

hours. 

LEWINSKY felt she was not in control cf the 

relationship. LEWINSKY mentioned her early contact with CLINTON 

and how she immediately felt a bond with him. LFWINSKY could not 

concentrate on work and would wait for CLINTON to come by her 

office. LEWINSKY told her mother and her aunt about the 

relationship. ESTEP recalls LEWINSKY saying her mother and aunt 

told her that LEWINSKY was one of many women CLINTON is involved 

with and they questioned his sincerity. 

LEWINSKY asked ESTEP to take very few notes during this 

session because LEWINSKY did not want much written about her 

affair with CLINTON. As a result, ESTEP's notes are not very 

complete. ESTEP recalls LEWINSKY mentioning her relationship 

with CLINTON starting at a pizza party. LEWINSKY mentioned going 

to the restroom and CLINTON leading her into the Oval Office and 

to a little room off of the Oval Office where they engaged in 

sexual activity. 

LEWINSKY said they kissed, she performed oral sex on 

CLINTON and that he fondled her breasts. ESTEP assumes CLINTON 

ejaculated, though she is not certain LEWINSKY was specific about 

that. LEWINSKY went into a lot of detail about what lead up to 

her sexual encounters with CLINTON, but she did not go into the 

details of what he did during the sexual activity. 

LEWINSKY mentioned that, after their first encounter, 

CLINTON continued to come to her office to see her. LEWINSKY 

also saw CLINTON at various functions. LEWINSKY mentioned one 

function where LEWINSKY waited for CLINTON at a rope line and he 

gave her a very "sexuar""hug. LEWINSKY said that CLINTON said he 
1083 

31C-302a (Rev. 8-19.9-L) 

29D-CIC-LR-35063 

Continuation of OIC-302 of KATHLEEN ROBIN ESTEP ,on 08/23/98 , Papr 3 

was worried that people would notice their relationship, so she 

was transferred to the Pentagon. LEWINSKY thought she was 

protecting CLINTON by working at the Pentagon. LEWINSKY felt 

CLINTON initiated their encounters, but LEWINSKY was a willing 

participant. 

ESTEP thinks LEWINSKY mentioned one time when CLINTON 

called LEWINSKY. ESTEP advised the phone call was during a 

blizzard and HILLARY CLINTON,was out of town. ESTEP thinks 

LEWINSKY said that CLINTON called in the middle of the night. 

ESTEP thinks LEWINSKY went to the White House in the middle of 

the night that night. LEWINSKY did not mention phone sex during 

her consultation with ESTEP. 

ESTEP said LEWINSKY mentioned that, on one occasion, 

CLINTON was brought to LEWINSKY's apartment by the United States 

Secret Service at approximately 2 a.m. ESTEP advised that this 

is the only thing she can recall about that. ESTEP recalls 

thinking LEWINSKY may have made this up because the scenario of 

the President doing that seemed so incredible. Other than this 

one instance, ESTEP felt LEWINSKY was credible and well-grounded. 

During her meetings with LEWINSKY, ESTEP focused on the 

issue of whether LEWINSKY was fantasizing or exaggerating. ESTEP 

concluded LEWINSKY had her feet in reality and was credible 

because she told her stories in sequence, they were very detailed 

and when ESTEP would go back to ask follow-up questions, LEWINSKY 

provided the same answer she had previously provided. 

ESTEP advised that because LEWINSKY was providing so 

much information in just their second meeting, she did not ask 

LEWINSKY follow-up questions. ESTEP advised that it normally 

takes more time to build rapport with a patient, so she did not 

ask many questions of LEWINSKY. ESTEP was, instead, empathetic 

to LEWINSKY. 

LEWINSKY was very anxious. ESTEP believes LEWINSKY's 

anxiety can be attributed to: her failed relationships; her fear 

of relationships not lasting, especially her relationship with 

CLINTON; and her relationship with her father. 

At their November 23, 1996 session, LEWINSKY mentioned 

seeing GEORGE STEPHANOPOULOS at a STARBUCK's coffee shop the 

previous Sunday. LEWINSKY said that she was friends with 

STEPHANOPOULOS's assistant LAURA. LEWINSKY said that 

STEPHANOPOULOS recognized her as working for KEN BACON. LEWINSKY 

said she asked STEPHANOPOULOS if his boss was the type of person 
1084 

OIC-302a (Rev. 5-19-94 

29D-OIC-LR-35063 

Continuation of OK-302 c? KATHLEEN ROBIN ESTEP .On 08/23/98 ,Page 4 

who wc*Lld lead anyone on. STEPHANOPOULOS said he did not think 

so. LZWINSKY then said that STEPXANOPOULOS said that CLINTON was 

a very powerful, complex man. LEWINSKY then asked STEPHANOPOULOS 

what he would do if he found out CLINTON was stringing someone 

along. STEPHANOPOULOS said he would not take it seriously. 

ESTEP is not positive and cannot tell by her notes, but 

she thinks LEWINSKY said she told STEPHANOPOULOS some of the 

details of her relationship with CLINTON. ESTEP's notes reflect 

that LZWINSKY "would never have told him-no details." ESTEP 

interpreted these notes to mean that LEWINSKY said that she never 

would have gone into the details if CLINTON had called her 

regularly. ESTEP recalls thinking to herself at the time that 

LEWINSKY should not be revealing the relationship to anyone and 

that LZWINSKY might make the situation worse by being a "blabber 

mouth." 

ESTEP advised that in their November 23rd session, 

ESTEP had LEWINSKY talk about her family life. ESTEP advised 

that she is trained to take a patient back to a "safer" place 

when they disclose too much information too soon, as LEWINSKY had 

in the November 16th session. 

LEWINSKY's relationship with CLINTON did not seem onesided to LEWINSKY. LEWINSKY was not at all delusional and she 

was very introspective and insightful. LEWINSKY never mentioned 

being called a "stalker1 and she never mentioned a White House 

steward. 

ESTEP said her three sessions with LEWINSKY were not 

enough to make a sound diagnosis on LEWINSKY. ESTEP did say that 

LEWINSKY had a lot of the indicators which might lead to a 

diagnosis of clinical depression. According to ESTEP, a 

diagnosis of clinical depression has no bearing on one's 

truthfulness or whether one fantasizes. ESTEP advised that a 

diagnosis of clinical depression does not indicate someone is 

delusional. 

- 

ESTEP moved her practice to its current location in 

December of 1996 and had no further sessions with LJZWINSKY. 

ESI'EP called LEWINSKY and provided her names of other therapists 

in the INorthem Virginia area, but ESTEP is unsure if TIEWINSKY 
1085 

OIC-302a (Rev. 8-19-94) 

29D-OIC-LR-35063 

Contmuation of OIC-302 of KATHLEEN ROBIN ESTEP 

went to any of them. 

.On 08/23/92 .Page 5 
1086