1203 

TIWOTWY SUSANIN 

TCMZ?.NCE GALLIGAN 

1001 Pm~ylvGda A".""., Y.Y. 

Suite 490 North 

w.,hLnqton. D.C. 20004 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

T 

Page 2 

PROCEEDINGS 

-pan. 

NELSON ULYSSES GARAEKI-0 

was caIkd as a witness and, having b&n fast duly sworn by 

the Fompa-son of tbe Grand Jury, was examined and testified 

as follows: 

Q 

A 

Q 

EXAMINATION 

BY h4R. SUSAN-IN: 

Good morning. sir. 

Good morning. 

Could you please state your full name for the 

record? 

A Nelson Ulysses Garabito. 

Q Could you spell your last name for us? 

A G-a-r-a-b-i-t-o. 

Q We’ve been tnisspclling your name. so I’ve got to 

write tbis down. 

A JUROR: Could you spell that again? 

BY h4R. SUSANIN: 

Q Once more. 

A Last name is Garabito. G-a-r-a-b-i-t-o. 

THE DEPUTY FOREPERSON: Sir. we would ask you to 

keep your voice up. The lady in the back also itas to bear 

every one of your answers. 

THE WITNESS: Thank you. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

Page : 

BY MR. SUSANTN: 

Q It’s Mr. Gatabito is how you pronounce that; u 

that ri.g?lt? 

A That’s cxxrect. 

Q And you are a Special Agent with the PPD in -Cz 

secret Service? 

A Yes, sir. 

Q Sir. we just met briefly outside, let me 

rcintrodua myself. My name is Timothy Susanin. 1’3 an 

Associate Independent Counsel. To my left is my co&gue 

from tbz Independent Counsel’s Off&, Tcmmcc GaQan. 

Across from me is the court reporter and to Mr. GallQn’s 

left arc two members of tbc gr;md jury, and the ladies md 

gentlemen to your right there comprise the rest of the pand 

jury that you’re tcxifying in front of today. 

Before we begin, I briefly want to review some 

rights and obligations you have as a witness before tk grand 

jury today. 

First, as our Deputy Foreperson has already stazd, 

we are going to ask you to keep your voice elevated so 

everyone in the back can hear. We are also going to ask that 

you give us verbal answers as opposed to nods or shrqs so 

that the court reporter can take everything down. 

As you know, you were just sworn in, you’re u&r 

oath. You have an obligation to testify truthfully befar: 

I 

2 

3 

4 

5 

6 

7 

8 

9 

0 

I 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

Page 4 

tbc gtand jury. Do you understand that. sir? 

A Ycs,Ido. 

Q And do you understand that includes not misleading 

tbc grand jurors in any way. For instance. saying you don’t 

know or you don’t remember something when in fact you dc know 

or do remember that something. Do you understand that? 

A Yes. I do. 

Q You have the tight to counsel. You do not have the 

right to have counsel in the room with you IIIZ, but you do 

bavc tk right to have counsel outside and to stop tbc . 

proceedings if you fael you nacd to go out and consult with 

your attomcy or attorneys. Do you understand that? 

A Ya, I do. 

Q And is Mr. Tom Doughty. D-o-u-g-b-t-y. &xc 

from Secret Service Chmscl’s Office on your behalf today? 

A Yes. hc is. 

Q .hdthaeisanotbuattomeybytbenameofMan 

from tbc Offtct as well? 

A That’s correct. 

Q &tit’s his last name? 

A Spades? Spaeta? Somctbing along those lines. 

Q Axtbueanyoti-rrSecretSuviceattorneyshex 

on your MaIf, sir? -4.: 

A No, sir. 

Q And do you have a private attorney tbat you’ve 

Page I - Page 4 

Diversified Raorting Services. Inc. (2021296-2929 
1204 

In rc: Grand Juxv Proccedinas Multi-Page lM Thursday, July 30, 1998 

1 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

I 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

Page ! 

bid to represent you ke today? 

A No. I do not. 

Q Spaial Agcm Garabito. you aha have under the 

Fifth hxndment of tk Constitution a right against selfincrimination. What that means is if a truthful ansHa to a 

question posed by me would tend to incriminate you YOU have 

the right to nfusc to answr that qUesIjO0. Do you 

understand that? 

A Yes, I do. 

Q Do you have any questions for me about thcx rights 

or obligations before begin? 

A No. sir. 

Q I want to begin by asking you about your 

employment. as you said earlia, with tbc Presidential 

Protective Detail with the Secret Scrvia; is that correct? 

A Tbat is corrcc1. 

Q How long have you b&n with tk PPD? 

A Tbru years and tbrec months. 

Q How long have you ban with tbc Secret %-vice 

altog&cr. sir? 

A Itwillbe IO years August 1st. 

Q And you’ve ban an agent tbc mtire 10 years? 

A Yes. sir. 

Q You’ve never been with tbc Unifomxd Division? 

A No, sir. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

6 

7 

B 

9 

0 

I 

2 

3 

4 

Page 6 

Q How many of those 10 years have you worked in 

Washington? Did you start right out 10 years ago here in 

D.C.? 

A No, sir. I began in Newark, New Jersey, then San 

Jdan, Puerto Rico, and I arrived in Washington April 29th of 

1995. 

Q So you arrived here to start directly with the PPD; 

is that right? 

A Yes, sir. 

Q Now let me start off by asking you if you know a 

woman by the name of Monica L&n&y. 

A Yes, I do. I know her by name since the press 

releases came out. 

Q Would that be in January of this year, roughly? 

A That’s correct. 

Q That this story fust hit the media? 

A Ihat’s Cornet. 

Q Did you know her before you knew her by name in 

January of this year, did you know her to see? 

A Yes, sir, I did. 

Q How long before January did you know her to see? 

A I would he unclear on that. I would remember 

seeing her often through the White House delivering what 

appeared to he papers or documents from one office to 

5 another, from one side of the White House to another. 

I 

2 

3 

4 

5 

6 

7 

8 

9 

0 

I 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

page7 

Q Let me a& it from a different end, then. Do you 

know how soon after you started at the White House in April I 

of ‘95 you first saw Ms. Lewinsky? Whether it’s a month 

later, a year later, two years later? 

A Probably a year later. 

Q So you think you might have sxn her by spring of 

‘96? 

A That’scorrect. 

Q Do you know before the story broke in January of 

this year, 1998, how far back from that date was the last 

time you saw her? 

A No, sir. That would bc very unclear to me. 

Q Can you tell the grand jurors at least whether it 

was a matter of months or a year or two? 

A No. Several months, two to three months, I’d say. 

Q So is it fair to say you saw her sometime towards 

the end of 1997? 

A That would be a fair guess, yes. 

Q Now I believe you said that you had sear Ms. 

Lewinsky often delivering papers ani that type of thing in 

the White House. 

A That is right. 

Q Did you see her in the West Wing? 

A Yes, sir. 

Q DidyouseeherinareasotherthantbeWestWii? 

I 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

6 

7 

8 

9 

D 

1 

2 

3 

4 

5 

Page b 

A Yes. sir. 

Q What ms would those be? 

A Tbc area we call tbc colonnade and walking towards 

the residence part or sometimes in tbc residence section 

walkirig through the residence coming from the East Wing of 

the White House. 

Q All right. Let me back up a bit. The West Wing is 

where the Oval Office is; is that correct? 

A That’s corm% 

Q And you’ve sun Ms. Lewinsky tbac? 

A Yes. 

Q In and around the Oval Ofice? 

A Yes, sir. 

Q Explain what tbe colonnade is for tbe lad& and 

gent- of tk grand jury. 

A It’s an mxa that’s outside. You can walk - it’s 

apavcdarcathetyoueanwaIkfromtbcWcstWingarcaofthe 

White House what the Oval Office is. it takes you towa& 

the residential part of the white House wixae tht private 

quarxrs art. 

Q And is that kind of like a sidewalk with a liti 

roof ovu it? 

A Yes. sir. it is. 

Q Are that columns on one side? 

A Yes.thaeare. 

Pages-Page8 

Divcrsificd Rc~orting Scrviccs. Inc. (202) 296-2929 
Page 

I Q And that’s why it’s called the colonnade? 

2 A I don’t know that but, ys. you arc coTTtC1. 

3 Q And you bad sari Ms. Lewinsky out on the colonnade. 

4 A Sure. 

5 Q And, again, that connects the West Wing complex to 

6 thcrsidence? 

7 A That’s conu.X 

8 Q AndthcrsidcnccisintbemainpartoftbcWhitt 

9 House? 

0 A That’s co-t. 

1 Q You also said you saw Ms. Lcwinsky walking towards 

2 tbe residence. Would that be some area other than tbe 

3 co&Made? 

4 A Not towards Ihe residence - we& walking towards 

5 tbc laidence from t& West Wii back towards tbe residence. 

6 I’m assuming she would come from somewhere in the East Wing 

7 oftbtWhitcHousebccauscattimcsIwoulds&hcrwalking 

8 through the residence towards tbc West Wing. And sometimes 

9 if wz wem stational at the West Wing parf we could sclc her 

0 departing the West Wing going back towards the rsidence. 

1 Q But that’s all inside? 

2 A I don’t understand. 

3 Q Well. if you saw Ms. Lcwinsky walking towards tbc 

4 rsicknce on the colonnade, she’s outside. 

5 A Yes. 

Page IC 

1 Q My question is when you saw Ms. Lcwinsky walking 

2 from the East Wing through tbe nsidence to the West Wing, 

3 that’s inside. 

4 A That is corrtzt. 

5 Q And did you ever see her walk. making that same 

6 trip in the opposite direction? In other words -- 

? A Yes. 

5 Q - from the West Wing through the residence back to 

3 the East Wing, but inside as opposai to out on the colonnade? 

1 A Yes, sir. 

I Q Thanks. Now just to pick up on your use of the 

1 word. “often,” and I know tkse dates are rough and you’re 

1 giving us the best you can. if you saw Ms. Lcwinsky roughly 

I from April of ‘96 to maybe September or October of ‘97. which 

5 would be two or thru months before this story broke in 

i January - 

I A I’m sorry. That is nof what I intended to say. I 

i think more like ‘96, towards the end of ‘96. 

) Q Would be the last time you saw - 

1 A Right. Spring of ‘96 towards fall of ‘96. 

Q Okay. Ld me back up then to make sure I have this 

! right. I bad askal you bow long before tbe story broke in 

I January of this F. ‘98. was tbe last time you saw Ms. _ .- 

I Lcwinsky. I tbougbt you bad said two to three months before 

i that. meaning towards the end of ‘97. 

Diversified Re~ortinp: Services. Inc. (2021296-2924 n 

Page II 

1 A I might have said that. but I was Lncorrec1. 

2 Q Okay. And you want 10 comt rhat now? 

3 A Yes. 

4 Q Okay. Go abead and corrozt Ihat. 

5 A Somet& as I said, spring of ‘96 to fall of ‘96 

6 isthctimeInmembcr. 

7 Q Okay. And would that roughly be tbz same months. 

8 October of ‘96. somewhere in there roughly? 

9 A Yes. sir. 

0 Q And la me go back using those new parameters and I 

I appreciate you correcting Ihat. From roughly the spring of 

2 ‘96 towards tbe end of ‘96. wben you say that you bad s&n 

3 Ms. Lcwinsky often, try to give tbe grand jurors a bench 

4 SQISC if you could, of what you mean by “ofren.” Would you 

5 s&bcronadailybasis? Wouldyouscckronawakiy 

6 basis? A monthly basis? That kind of thing. 

7 A At the time I was assigned to what’s called our 

8 Transportation Section. we drive the limousines and so forth 

9 and during that time. m would be assignal to come back and 

0 work - let me back up. 

I The Transportation Section is away from the White 

2 House. It’s approximately six blocks.away. During that 

3 time. we would be assigned once or twice a week to come baEk 

4 to tbc White House and work with the shift. which are tbc 

5 people around fhe President that follow bim throughout tk 

Page 1; 

I White House. So, once or twice a week you didn’t have a 

2 driving assignment, you would be sent to help out the shift. 

3 It was during this time that I remember seeing her, so if I 

1 was there once or twice a week, and being posted in different 

5 areas, 1 could see her going back and forth maybe twice, 

5 three times a day -- not necessarily every day 1 was then, 

7 but I do recall her, you know -- especially, if she went in 

3 one direction, I could anticipate seeing her coming back in 

) the other direction ten minutes later. So two or three times 

1 a day that days that I did happen to see her. 

I Q Can you give us an idea of when you worked the 

1 Transportation Section? Did you start with them as soon as 

1 you arrived in D.C. in April of ‘95? 

1 A No, sir. I think I went to Transportation 

i approximately February of ‘96, and I was in Transportation 

i until approximately March of ‘97. 

1 Q And let me ask you during the occasions that you 

I saw Ms. Lewinsky, do you know what her status was in the 

1 White House? 

1 A No, not at that time. I’ve learned it since. At 

the time, I just thought she was another staff person. 

1 Q Did you ever see anything that she was wearing to 

I indicate whether she was authorized to be in the locations 

where you would see her? 

A Yes. We all have to carry a pass that indicates 

Page 9 - Page 12 
1206 

n re: brand Jury YrOCCCQlLtgS mm-rage Ihursday, July 30, lYYL( 

I 

2 

3 

4 

5 

6 

I 

8 

9 

10 

1 

2 

3 

4 

5 

6 

I 

8 

9 

!O 

!I 

12 

13 

14 

:5 

Page 1: 

that ycr.: have access to walk throughout. I Can’t recall ever 

loohnf at it specifically to determine if she was staff or 

intern CT something, just I would look at it to realize that 

she was authorized to walk back and forth. 

Q Is it fair to say you could see the pass from a 

distance just to make sure she was authorized? 

A Ihat’s correct. 

Q But you would have to maybe read the pass to see 

whether she was an intern or an employee or staffer? 

A That’s correct. 

Q And are you saying you never read the past, but 

from a &stance, you verified she had a pass? 

A Yes, sir, that’s correct. 

Q Is it the same color pass that a staffer and an 

intern would have? 

A I think they would have different colors. Again, I 

never stopped to look at what color she had, but I think 

there wnuld be different passes. 

Q As long as she had a pass, that was good enough for 

you if you were on post? 

A That’s correct. 

Q And you don’t remember as you sit here what color 

pass sbe had? 

Let me ask you this, was it part of your job when 

you would come back on occasion to work shift work or to 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

I 

2 

3 

4 

5 

6 

7 

8 

9 

0 

I 

2 

3 

4 

5 

Page I4 

stand post in the White House, was it part of your job to 

make sure people in the West Wing or other parts of the White 

House had a pass? 

A Yes, sir. 

Q And did she have a pass on those occasions when you 

saw her? 

A yes. 

Q Do you know if you ever saw Ms. Lewinsky in the 

White House, any part of the White House when she did not 

have a pass? 

A I do not recall that, no. 

Q And aside from the pass, was there ever a time when 

you saw Ms. Lewinsky in the White House that after, to your 

knowkxige, she had stopped working there? 

A I believe, I believe I might have seen her on one 

occasion. I cannot be 100 percent certain because I did not 

see a frontal view, I just saw a side view and a rear view. 

I thought it might have been her, but I can’t be 100 percent 

certain. 

Q Let me ask you what makes you think that occasion 

-- I understand you to say you believe it was her -- what 

makes you think that that was after her employment at the 

White House? 

A Because I didn’t see her for a long period of time, 

so I knew that she wasn’t working there. Also, on a -- I 

3 

Diversified Rcportinn Services. I~c. (202) 296-292~ 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

I 

2 

3 

4 

5 

Page 15 

think on a movement to tk Pentagon. again I was driving one 

of tk vehicies. I don’t rcmanbe~ if it was limo or back-up 

limo: so, obviously, we park at - wz arrive at our location 

and all tk drivers stay with tkir vebiclcs. Tk pcopk 

going inside go inside. WbiJe I was outside I saw ha and, 

you know, just smiled and said. “Hello.” and assumed tbat sk 

was, what’s calkd “working.” doing tk advance for tk site. 

Tbc staff sends out someone to pmparc every&q so wbai tk 

President arrives everything is pretty much coordinated. 

I assumed sk was setting up tk advance for that 

site. And 1 don’t rsall exactly bow. tkre wue several of 

us in a conversation and I kard bu say that sk was no 

longer working for the white House. tkt sk was working for 

tk Pentagon now. And that’s when I xalizai that sk 

wasn’t. Because we didn’t work evay day at tk white House, 

Ididn’ttcalizctbatskkdalteadykft. WbatIkaxd 

that conversation is when I realipd sk was no longa 

working for tk white House, but working at tk Pentagon. 

Q So at some point you bad personal know* from 

her diteetly that sk no longu worked at tk white House? 

A That’s correzt. 

Q And tkn let me ask you about tk occasion wkre 

you kkve it was sk that you bad sari at tk white House 

after employment. was that before or after this movement to 

tk Pentagon you just described? 

Page lb 

1 A Way before -- I’m sorry. Way after. Way after. 

2 Q AU right. We’ll come back to tbat in a link 

3 bit. Let me move back to the occasions that we were speaking 

4 about where Ms. Lewinsky is still working at tk white House. 

5 During those occasions, did you know kr name? 

6 A No. I did not. 

7 Q Did sk know your uame? 

B A I don’t think so. 

9 Q Did you have any kiod of contact or conversation 

3 with her on tk occasions wkn you would see ha7 . 

1 A Sk was vmy fricndIy: beside kilo, good morning, 

2 good afternoon, whatever. that was it. 

3 Q So sk was friendly in demcenrx? 

4 A Yes. 

5 Q But tbae was no conversation otkr than greetings? 

5 A Correct. Tbat is cotxct. 

7 Q DidyoueversatkxwitbtkPmsidattwbiksk 

3 was an anploy& of tk white House? 

3 A Sabuwalking? TaIking? 

3 Q Didyoucvcrs&hainanywaywithtbcRsidcnt? 

I A TkonlytimeIreeaIlseeinghawitbtk 

2 Prcsidcnt is on ok occasion wbcrr: sk - I kkvc - I 

1 klieveitmustknb&na~donlybecausethcwaythe 

I OvalOffi~arcaissdup,thar:isadoorthatlcsdstothc 

5 sccld~~y’s offa and if tk secretary is tbae, that door 

Page 13 - Page 16 
1207 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

Page 1: 

is open. And WC are always in that area. 

At this point, to tk best of my rccolkction. that 

door was closai and Mrs. Curric tk Prcsidcnt’s recrcm. 

was not tkxe; so, for that reason I klicvc it was c&7 a 

w&end or a holiday hecause sk wasn’t &rc. And tbuc 

wcrrn’t - it wasn’t a normal day. Tkrc wasn’t tk usual 

traaffic of pa& going back and forth. It was kind of a 

w&ad holiday day. And sk came I assume from tbc East 

Wing and sk approackd with some documents and papawork. 

Obviously, if Mrs. Curric waz tkxc, sk would go into tk 

secretary’s oftice and cnta wkrcva sk o&dcd to go. That 

door was cl& so sk came to me. 

Iwasstandinginfrontoftbtdoortbat~oo 

tk Rcsidcnt’s office, and sk indicatal - I don’t know tk 

exact words, but sk indicated sbc bad some papawork for tk 

P&dent. 

I knocked on tbc door, acud mysdf. I indicati 

to tbc Rcsidcnt tbat there was samcone to sa him. Not 

exact words, but something to that effect. Hr to sotnc 

effect said, ‘Thank you.” Or “Pkasc come in.” I allowed 

bu in. I closal tbc door and that was it. 

Q All right. Let me go tbrougb this incident with 

you again asking you some qucnions. Fit of all_ I know 

you’ve said that you believe this is a weekmd or a holiday 

because tbcrc wasn’t a lot of traffic and Mrs. Cunic was 

Page I8 

I- there; is that right? 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

6 

7 

8 

9 

D 

I 

2 

3 

4 

5 

A Mrs. Cunie was not there. 

Q Mrs. Cunie was not there. 

A That is correct. 

Q Can you place this weekend or holiday for us on a 

time line? 

A No, I can’t. One thing I’ve tried to remember is 

when the government shut down that we worked for a week. I 

don’t recall those dates, that is the only other time that I 

could possibly think that this could have occurred. If it 

wasn’t a week&d or a holiday, then it might have been aroum 

the time the govcrnmen t shut down; hecause all 1 recall is it 

wasn’t a regular workday. We didn’t have the usual people 

moving back and forth. It was like a down day where the 

president had some work in the Oval Off&. We were there 

with him, but it was very low key and there weren’t that man] 

people going back and forth as it would usually be. 

Q Now, Special Agent Garabito, I take it you’re not 

saying you recall it was during the shutdown. 

A No, no, no. No, no. I’m not saying that at all. 

Q You’re saying it was during the shutdown or a 

holiday or a weekend; is that fair to say? 

A That is correct. My main recollection is that it 

was not a normal working day. That’s what I’m trying to 

clarify. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

Page 1’ 

Q .tid let me ask you if perhaps you can at least 

place ir cting the time frame that you spoke about earher 

when yc%: would see Ms. Lewinsky in the White House. 

h other words, can you place this incident dunng 

her penti of employment at the White House? 

A I *?iink so. It would be between that spring 

‘96/fail ‘96 period. I don’t know what her term of 

employt was, but this is the time that I remember. 

Q So to your recollection, she was working at the 

White House either as an intern or employee, but at any tate, 

working at the White House when this happened? 

A Yes. It was at a time where it was customary, 

usualformetoseeher,yes. 

Q Do you remember what time of day this took place? 

A I&, sir, I do not. 

Q Anddoyou remember where you were working when 

this incitit took place? 

A Yes. Directly in front of the door that leads from 

the Oval Off& to the Roosevelt Room, directly in front of 

that door. 

Q Okay. So that’s a door from a hallway into the 

Oval Office? 

A Tbar is correct. 

Q And as you stand and look at this door, is there a 

little table to the right with a telephone on it? 

1 

2 

3 

4 

5 

6 

7 

8 

9 

D 

1 

2 

3 

4 

5 

5 

7 

B 

9 

3 

I 

2 

3 

1 

5 

A Yes, there is. 

Page 2c 

Q And as you stand and look at this door, would Mrs. 

Currie’s, the secretary’s desk and office space be down a 

little waj5 to your left? 

A ‘Ihat is correct. 

Q And is there another door into the Oval Office from 

Mrs. Currie’s area? 

A Yes, sir. Yes, there is. 

Q And as you’re back at the door we were just talking 

about with the little table and the telephone in front of it, 

down a ways to your right as you look at that door, would 

there be another door into the Oval 0tX.x pantry and dining 

room area? 

A Yes, there is. 

Q So the door you are talking about is really in the 

middle of the dining room-pantry room door which is to the 

right and Sirs. Currie’s area and door to the Oval Office 

which is down to the left. 

A That is correct. 

Q And is there a letter and number designation giveo 

to this door that we’re talking about? 

A Yes. 

Q Vt’hat is that? _ . .._. . . 

A m. 

Q V, And you were on post at- correct? 

Page 17 - Page 20 

Diversified Rcportinn Services. Inc. (202) 296-2929 
Page 2 I 

I A [WaS. 

2 Q And given that you’re a PPD as opposed to Unifomxd 

3 Division, 1 take it the fact that you’re at- means the 

4 President is in the Oval Office? 

5 A That’s correct. 

6 Q And that’s because you go where the President is as 

7 a member of the PPIX is that correct? 

B A That is CUfECt. 

9 Q Now was there another PPD wt working with YOU 

Q during this incident? 

I A Again, since it wasn’t a rcguiar working day, the 

2 door to the secretary’s office was locked. On those 

3 occasions, we -- the supentisor, not “w,” the supervisor has 

4 the Iatitude to move the posts. If that door is locked, 

5 thereisnoreason_ 

6 _c directly in front of the ssxretary’s door. If 

‘0 Andon thisoc~~.~ion,I jusrdm'tmemberthe 

1 other agent being there 

2 the door that comes from the F&S Wing through the Press 

3 area, from that area, I femembef seeing her as that door 

4 opened and she came direcrly 10 me. Had there been another 

S agent over there, she would have stopped there first before 

t 

2 

3 

4 

5 

6 

7 

8 

9 

!I 

I 

2 

3 

1) 

5 

6 

7 

8 

9 

D 

Page 22 

getting to me. So I remember the door opened, I looked, she 

came over to me and she had -- she showed me the documents 

she had to take inside. 

Q Okay, I’m going to put Ms. Lewinsky aside for a 

minute, but we’ll get to that in a second. L.ef me ask you if 

there were any Uniformed Division ofticers _ 

in the area, maybe even down the hallway that day. 

A When we are stationed, When a PPD Agent is 

stationed _ ar you said, 

you know, that pantry door to my -- if I’m looking at the 

door, to my right. If I’m standing as I should he, then it’s 

to my’ Left. 

Q In other words, it’s to your left if your back is 

tom door; is that correct? 

A That is corxet. 

Q Doyvti tmrrem6er if thee was a &formed Division 

officer at the pantry door during this incident? 

A I donot rCfnfzm& qIec;fica\\y. I’m saying then? 

usually is. There should he someone there. They usually 

hold our posts. When the President comes, _ 

1- 

2 Q And yoa~ don’t reca\\ as yw sir here today who the 

3 Uniformed Division officer was? 

4 A No, sir. 

s Q All right. Getting back to Ms. Lewinsky, could you 

I 

2 

3 

4 

5 

6 

7 

s 

9 

0 

I 

2 

3 

4 

5 

6 

7 

8 

‘9 

d 

, 

Oval Office -. When thee doors 

1 

op~~~&iswhenIJ0ok~mdI.5i3Wbz ?baf'Sthcfvsttimc 

I saw her approaching, approaching the ofi&. 

Q And where do those doors lead to? Do those lead 

towards the residence in the E&t Wing? 

A That is correct. If you go down tit and make a 

right_ it will take you right into the c&mnade, right 

LoKatds the I;ast wing. 

Q So, Ms. Lewinsky is coming from that genesal 

di8Sicm. 

A timzct. 

Q And can you tell us what you rememtm about how she 

looked v&en you saw her? Could you &scribe what she was 

yearia& how she aJl& what she was CalYying? 

A No, I don’t mall much about i&at she was WZU&. 

I just remember it was a large ~l~~wisanila tm&qtc which I 

; assumed bad doeument.s in it. 1 don’t TCY&~ speCifically how 

‘3 sbewasdre?SSi. 

.4 Q And did she walk tight up to you? 

:s A Yes. That’s my mcollfxtion, that them was no 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

i 

2 

3 

4 

5 

6 

7 

8 

9 

0 

I 

2 

3 

4 

5 

Page 23 

otba agaIt there. so that’s why she came &xuAy b nu?. 

Q And had you recq&ai bcr by &at point? Had you 

SCUI ba around the. White House by that time? 

A Ys, yes, sir. 

Q What bsppens when sk gets up to you? 

A S& indiccrtes in one fatmat ot anoW &at sbc has 

documents that tbc Prcsidcnt is waiting far or asked for. 

Q And during tk course of your stifi work in the 

West Wing, did that strike you as usual oc umsual &et 

~wouldc~in~~smanapwi~papcrs~s&tbc 

PlYSi&St7 

A No. iz was not unusual. T&e only d&g unusual 

ahot it is Itrat they would eppftxicb xne. Usually, Mnr. 

Cltrritisrbaeanddxzygothmut&bcr. SiMrs.Cuxrie 

wasaottbac.~wastbcon&paoatbatc#uJdgiwba 

acars to ti Office. lbat was rb: only thing ululsuat 

Q Didh5.s.L&nskyknwtbcFrcsiitwas~~tbc 

Offcctoyo~knowk&c? Ordidsbcinquirctrowktbu 

bc war in rbc oval UfCx? 

A ftap~tometbatsbeknew,be#u.Sba 

indication was, “I have these papss fcrr %cYVr&iulV: so, 

it’s an assumption on my part. but it felt fikc she had brm 

calJed and told ta bririg some&@ ova or ordarart to bring 

sorndbing ovct, you know. Sbc did not ask tnc is tb: 

prtsident in. tVa sk did DOZ. 

Page21 -Bge24 

Divcrsificd Rcoortin~ Scrviccs. Inc. (202) 296-2929 
1209 

I 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

6 

7 

8 

9 

Q 

J 

2 

3 

4 

5 

Page 2 

Q And I take it at some point then you turned towards 

the door and opened the door; is that right? 

A That’s correct. 

Q Did you have any additional conversation with Ms. 

Lewinsky after she tells you she has the papers, but before 

you turned to open the door? 

A No, sir. 

Q All right. Now you’re at this door because you’re, 

of course, guarding the President; correct? 

A Yes, sir. 

Q And you knew him to be in the Oval Office before 

you opened that door? 

A Yes, that’s why I’m standing there, yes. 

Q Okay. Was anyone in there with him at that time, 

or was he alone? 

A I Can’t -- I don’t know that. When you open the 

door, obviously, I didn’t have to open the door totally. I 

justopeneditenoughtoseehimandifI’matthedoorand1 

open it, his desk is right there, so I could open the door a 

third of the way, see him, and I just said something to the 

effect, “Mr. President, there’s someone here to see you.” 

Q All right. Let me interrupt you there before we 

pick up again. How long had you been on post to the best of 

your recollection by the time this incident takes place? 

A Perhaps -- I remember being there only a short time 

Page 26 

I after that, so I would say maybe 10 to 15 minutes. 

2 Q And how long are you typically on that post’? 

3 A We may be there, again, depending on what type of 

1 day it is, we may be there approximately 20 minutes. 

5 Q So, if that was a 20-minute shift and you recall 

5 leaving the shift a few minutes after Ms. Lewinslcy goes in, 

? you, therefore, are assuming this happened 10 or 15 minutes 

s into the shift; is that what you’re saying? 

9 A Yes. Yes, sir. 

0 Q And do you have any recollection as to whether this 

I was the morning shift or the night shift? Do you recall 

2 daylight? Darkness? 

3 A Daylight, yes. Daylight, yes. 

4 Q It happened during the day? 

5 A Daylight. 

6 Q Do you remember what time of day? 

7 A No, sir, I do not. 

3 Q InthelOto 15minutesthatyouhadbeenonduty 

9 there, had anyone else gone into the Oval Office? 

I A No, sir. 

I Q Do you recall where you had been before you took 

2B 

; A What we call “down,” so I wasn’t - I was 

5 0 Is that on a break? 

Pse 27 

1 A You’re never on a break. but you’re down. You’re 

2 not standing nt a post. You’re down. ready but down. 

3 downstairs. 

4 Q Okay. And bow long is the down shift? 

5 A It depends on bow many posu we’re holding. 

6 Usually. I’d say may& 40 minutes. 

7 Q Doyouiememberwbemyouwerebeforeyouwemdo~~ 

8 &at&y? 

9 A Again, depending on tbe rotation. I would have been 

0 on a post that’s outside on the colonnade. 

Q Okay. Do you runembcr seeing tbc Resident on this 

: da:-b? 

3 A No, sir, I can’t remember that specifically. 

4 Q All riglit. Do you know bow long before you took 

5 the E-6 post. the President moved to the Oval Oflicc? 

6 A No. sir, 1 cannot recall that. 

7 Q Now, you said you don’t recall if you saw the 

3 President that day2 A Correct. 

1 Q If you bad ban out on the coionnadc before you 

I WCE down, would YOU have seea hc President if he was in tk 

1 Oval Office? 

s A No, because for me to be on the colonnade. he would 

I already be in the office. 

j Q All right. And do you remember that you were in 

Page 28 

I the colonnade before you wex down? 

1 A No. For cxampk. if we v.ue in the residential 

I part of the house and I were down on that side and hc moved 

I attbatpoint.\_)soIwouldbave 

i b&n on the other side when he walked over. And when it was 

I my turn to come on pas- so I would 

’ not have seen him on the walkover or been on post as hc 

1 walked ova. 

J Q Now in the 10 or 15 minutes you WQelll) 

1 before Ms. Lewinsky came, you did not let anyone else into 

the Oval Office? 

A I do not recall anyone else entering. 

Q When you assumed tire post. are you ever told by tk 

person you’re replacing. “Everything’s fine. Tk Resident’s 

in with so-and-so.” Or given any information like tbat? 

Status type of information. 

A Usually vay brief. If it’s a regular staff 

person, I don’t think any comment would be made. If it’s out 

of the ordinary. sometimes we’ll have 10 or I5 press peopk 

in there because they’re taking some photo op. that we’re 

advised of: but if it’s a usual - I wouldn’t be told Mrs. 

Currie’s in tlxre. I wouldn’t be told a staff puson is in 

there. 

Q Do you teeall wixtlxr you were told anything about 

Page 25 - Page 

Diversified Reporting Services. Inc. (2021296-2929 
4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

6 

7 

8 

9 

!O 

!I 

12 

!3 

14 

:5 

Page 25 

1 A I do not recall. 

Q You don’t recall whether you saw the President 

A I cannot be certain of that, no. 

0 Is the first time YOU saw the President after you 

1210 

In rc: Grand Jury Procccdmgs Multi-Page “.’ Thursday, July 30, 1998 

1 

I would say yes. 

And did you knock, first? 

Yes. 

Did you wait to get a response? 

Yes, sir. 

What did you hear? 

“Yes?” 

And then you opened the door? 

Yes, sir. 

Tell the ladies and gentlemen of the grand jw 

what you see when you open the door. 

A If you were to open the door completely you would, 

obviously, see the entire Oval Office. I think I’m 

disturbing the President, so I just open it as much as I 

needed to get his attention to me to inform him of why I had 

disturbedhim. Itoldhimsomeonewastheretoseehim,he 

acknowledged and I let the person in and then I cIosed it. 

So I could -- I only opened the door enough to see where his 

desk was. I did not hold the door open. 

Page 30 

1 Q Let me ask you a few questions about that. Was the 

2 President at his desk? 

3 A Yes. he was. 

4 Q Do you recall how he was dressed? 

5 A I would say casual. Casual, maybe a golf shirt, 

6 something to that effect. 

7 Q Okay. And what makes you say that? 

8 A Just I don’t recall it being a suit. 

9 Q All right. And what was he doing at his desk? Do 

0 you remember in any more detail? 

I A Just at his desk, this position. (Indicating.) 

2 Not necessarily a pen, but at his desk. 

3 Q And tell the ladies and gentlemen what you see Ms. 

4 Lewinsky do up until the time you shut the door. 

5 A She stood behind me as I opened the door. Once I 

6 got the President’s acknowledgement, she walked in. 

7 Q 

8 A 

9 Q 

0 A 

1 Q 

2 A 

3 Q 

And where was she when you closed the door? 

Beyond the door. I closed the door behind me. 

Was she walking? 

Yes, walking towards, towards him. 

Towards the desk? 

Yes, sir. 

And before she did that, you said to the President, 

4 “You have a visitor.” Or something to that effect? 

5 A “Someone here to see you.” Something like that. 

Page31 

1 

2 

3 

4 

5 

6 

7 

8 

9 

,O 

;I 

.2 

.3 

4 

5 

6 

7 

8 

9 

!O 

!I 

12 

!3 

14 

15 

Q Did you use Ms. Lewinsky’s name? 

A Ididn’tlmow-Ididnat. Ididnotknowkrby 

name. 

Q Was there any point at which the l%esi&nt e&r 

asked who it was or you even with your body Language kind of 

turnal to signal who it was to su wbethu be in&cd wanted 

to see the visitor? 

A That’s exactly what I did. I turned to make stun 

that bc could see who was standing ther% and bc acknowledged 

to some effect. ‘Yes, please come in.” someming to that 

effect. And that’s wbcn I allowed ha through. 

Q All right. Now did you kind of gesttue in her 

direction as you’ve just done now? 

A Yes, sir. 

Q You turned and kind of gesuned towards Ms. 

Lewinsky? 

A Mm-bmm. bIni-bmrn. 

Q And what did tk President say tbcn? 

A Something to tbc effect of. ‘Yes?” Or “Please come 

in.” Something like that. 

Q And did you bear Ms. Lewinslcy say nnytbing during 

this whole evolution while you’re opening the door or talking 

to tbc FVesident, gesturing to Ms. Lzwinsky, up until the 

time you closed the door? 

A No, sir. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

Page 3L 

Q And did Ms. Lewinsky leave that door to your 

knowledge in the remaining minutes of your shift? 

A No, sir. 

Q And do you recall who replaced you on the shift? 

A’ No, sir. 

Q Do you recall where you went next? 

A No, not specifically, again, because it wasn’t a 

normal day. Normally, I would have gone to _ the 

door in front of the secretary. I don’t think I went there. 

I think I went to one of the outside posts. 

Q Now, just getting back to your earlier testimony 

that you had seen Ms. Ixwinslcy often during this period in 

the White House and you’ve just finished telling us about 

this specific incident where you saw her. Were there other 

incidents during this time - again, this is the period when 

you had seen her at several locations around the White Houst, 

the colonnade, walking to and from the East Wing, on tk 

interior, in the West Wii wuz there any other incidents 

other than the one you just described that involved both Ms. 

Lewinsky and the President? 

A No, sir. 

Q Did you ever see her with the President on any 

other occasion? 

A No, sir. 

Q Did YOU ever see her go into an area where you knew 

, 

Divcrsificd RcDorting Scrviccs. Inc. (202) 296-292~ 

Page 29 - Page 32 
1211 

in re: irrana Juty rroceciungs mutt-rage Thursday, July 30, 1998 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

Page 3: 

tk President to be on any otk occasion? 

A No, sir. 

Q DidyoueverbearthatsbewaswiththePresident 

on any other occasion? 

A No, sir. 

Q Did you ever bear any rumors about her being alone 

with the Resident? 

A No, sir. 

Q On the other occasions where you saw Ms. Ltwinsky 

inthtWhiteHouseand,again.Iwanttogetbacktotheones 

you described as “often,” wlxn you were f_ in at the 

White House from your Transportation duties. Other than the 

Oval Office incident you just &scribed, was there anything 

noteworthy or significant that tbe grand jury should know 

about those other occasions where you would see her at 

various locations in the White House? 

A No, nothing I can recall, no. 

Q Were each of those other instances basically of a 

similar nature as with regard to what you saw? 

A I saw her just walking by with documents. 

Q Well, just in terms of &nerally what you saw. 

A Similar in nature to what? All the incidents 

amongst themselves, were they similar? 

Q Right. 

A Yes. Basically transporting documents back and 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

A Yes. 

Page 3: 

Q Wastbattbelasttimeyoubadseenberwbensbe 

worked at the White House? 

A No. 

Q SoyouhadseenherattheWhiteHousewearinga 

pass after the Oval Office incident? 

A Sure. 

THE REPORTER: Please keep your voice up, sir. 

THE WITNESS: I’m sorry. 

BY MR. SUSAm: 

Q Now moving back to the Pentagon trip, I believe you 

said that you and several other !3ecret Service Agents who 

were working the Transportation detail there waited outside 

the Pentagon while the President was at an event or a meeting 

of some sort in the Pentagon; is that correct? 

A That is comect. 

Q Do you remember what time of year this was? 

A Hot. Very hot. Summertime. 

Q And how do you remember it was summertime? 

A Just the heat, being outsid 

Q How many agents are on the Transportation detail 

that would have been with you that day waiting by the caf? 

A Perhaps four, four drivers and four different 

vehicles. 

Q And were you a driver of one of the vehicles? 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

6 

7 

B 

3 

1 

I 

2 

3 

4 

s 

Page 34 

forth. 

Q Now. I want to move to tbc incident wbere you’re on 

a Transportation detail to the Pentagon. IS it possible for 

you to estimate for the grand jurors bow long, bow much time 

wenf by bclw&n that incident wbue you see Ms. Lcwinsky af 

the Pentagon and tk last time you had seen kr at the white 

House? 

A No, sir. I can’t. That is why it was surprising to 

me that sk was no longer employed tbaz. because I didn’t 

know how, you know, I didn’t notice that sk was gone. Then. 

again, I wasn’t thae cvay day to SC2 to notice Ihat sbe 

was missing. 

Q Let me shift gears back to tbc Oval Office incident 

we were speaking about where Ms. L&n&y went into the Oval 

Office. Let me just ask you a follow-up question there on 

timing. 

You had talked about sahg Ms. Lcwinsky on a 

numba of occasions. as you say. “often.” in this period 

wkrc sk worked at tk white House. Was tk incident wba-c 

you let ha in on a holiday or a tid into E-6. was that 

tk fust time you had ever seen her while sk workal at tk 

White House? 

A No. sir. -. . 

Q So then were o&r times you bad seen her kfore 

that. 

1 

2 

3 

4 

5 

6 

7 

B 

3 

3 

I 

2 

3 

1 

5 

5 

7 

3 

? 

I 

I 

1 

1 

I 

5 

Page 36 

A Yes, I was. 

Q What were the names of the other individuals you 

were with? 

A I do not recall. 

Q Do you recall any of them? 

A No, sir. 

Q Do you recall roughly how long you waited outside 

the Pentagon during this? 

A Probably over an hour, an hour-and-a-half. 

Q How soon after you got to the Pentagon -- do you 

remember what time of day it was, incidentally? 

A I would say 11:OO or 12:O0. I want to say high 

noon, again, because of the heat and the sunlight. 

Q Do you know where the President was going in the 

Pentagon? 

A No. 

Q Do you remember what the event was he was 

attending? 

A No, sir. 

Q How long in that hour or hour-and-a-half period 

that you’re waiting outside the Pentagon was it that you 

first saw Ms. Lewinsky? 

A Oh,no. Wesawhcrassoonaswearrived. Shewas 

at the door. ‘Ihat is why I assumed that she was part of the 

advance team for this particular event. Once we arrive, we 

Page 33 - Page 36 

Diversified Re~ortinn Services, Inc. (202) 296-2929 
1212 

In re: th-and Jury Yrocccdings Mulh-rage 1 humlay, July 3U, lYY5 4 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

I 

2 

3 

4 

5 

Page 3; 

have to reposition the vehicles and so forth, and it was 

during that time that I saw her. and I heard the 

conversation. 

Q And when you say you saw her right at the door. IS 

that the door to the car? The door to the Pentagon? 

A The door to the Pentagon. 

Q So you drive right up to the Pentagon? 

A Yes. 

Q And when you say you thought she was part of the 

advance, are you saying you thought she was part of a U’hite 

House Office that went out to prepare the trip? 

A That is correct. 

Q So you thought she was still an employee. of the 

White House? 

A That is correct. 

Q Can you remember with specificity when you first 

saw Ms. Izwinsky during this incident? In other words, did 

you see her as the car was still moving, pulling up to the 

door? Did you see her befoE or after the President gets out 

of the car? Before or after the President actually goes into 

the Pentagon? That type of thing. 

A After. After the President had entered. 

Q So you don’t see her while the car’s moving? 

A No. I’m driving, no. 

Q And the car stops, the President gets out and 

I 

2 

3 

4 

5 

h 

7 

8 

3 

D 

1 

2 

3 

1 

5 

5 

7 

3 

J 

1 

I 

2 

3 

8 

5 

enters the building. 

A Yes. 

Page 38 

Q And then you are first aware of Ms. Lewinsky? 

A Correct. At that point, we need to reposition the 

vehicles and get ready for the departure, so that’s when 1 

can step out and that’s when I noticed her. 

Q You noticed her when you stepped out of the car? 

A Yes, to the best of my recollection. 

Q After you repositioned the car? 

A No, no. We’re there. Then we have to, you know, 

we can all get out and start talking about, “Hey, let’s go 

turn around there.” Or whatever we need to do. So we 

usually come out and discuss the way we want to do it. 

“Let’s put this one first. second,” whatever. And at that 

point when we were speaking is when I noticed that she was 

there. 

Q All right. 

A There was still some staff people going in, 

especially the press is way behind in the motorcade, so 

they’re still going in. And I recall her holding the door 

open as other people went through. 

Q Was the President abzady in the building by the 

time you first saw Ms. Lewinsky? 

A Oh, yes. 

Q Did you see any contact between the President and 

1 

2 

3 

4 

5 

6 

7 

8 

9 

.O 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

!I 

12 

:3 

4 

5 

Page 3s 

Ms. Lcu;nsky? 

A So. sir. 

Q And is she still holding tbc door ujcn you first 

see kr” 

A Yes. I think she was still bold& !!x door. I 

think tbcx waz still some people coming through. 

Q Allright. Howfarareyoufromkzattbat 

point? 

A Tk Pentagon has scvaal steps that come down - 

shcwaswayupatthcdoor,HII:Uadounonthcs~kvtl 

50 f&t mayix. 

Q Allrigbt. Sotbueaxsomesteprgoingupto 

this door? 

A Yes. 

Q ti at some point, you and tbc C&T agents speak 

with Ms. Lewinsky? 

A That is correct. 

Q Howlongaftcritisfromwhcnyoufustsuber 

until you’re speaking with her? 

A U’batevertimeittookfortberestofthtpress 

peopktoorwboevcrwaslaggingbebindtogotbrougb. At 

that point everybody is through. I’m assuming sbc probably 

kt tbz door go and, you know, she approached us and we might 

have spoken I&n. 

Q Anddidyoueverkavewbcxeyouwuespeakingwitb 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

Page 4b 

the agents to go closer to her or did sk come up to the 

agents’ location? 

A I think she came down to us. We wouldn’t go away 

from tbe cars. 

Q And tell us about the conversation from the moment 

she approaches. 

A Nothing in particular, just that she was no longer 

at the White House, that she was now working for the 

Pentagon. And the only reason I remanberishecausc1 

realized at that point that she was no longer at the White 

House. That’s the only part that struck me. 

Q Did she come over to speak with you, specifically? 

A No. Idon’tthinkso. Ithinktherewas,asI 

said, a group of us. 

Q But you recognized her. 

A Yes. 

Q And she recognized you? 

A I would assume so. 

Q Did sbe ever say hi to you individually or use your 

name? 

A Idon’tthinkso. 

Q Did she recognize the other agents? 

A It appeared -- it appeared that way, yes. 

Q Didthcyrecogniaeher? 

A It appeared that way, yes. 

I 

Page 37 - Page 40 

Divcrsificd Rmorting Scticcs. Inc. (202) 296-2929 

_ 
1213 

AlI SC. “‘UU ,uly r‘“Lck-up I.&uA.. 1 05” ILILyauuJ, 4-J 2”. 1//t 

Page 41 Page 41 

1 Q All right. And was there any conversation after I holidays, so I’m thinking it was either late November or 

2 &e says, “Hello,” and before she says, “I no longer work at 2 early December of ‘97. 

3 the White House.” 3 Q Now this story all bit the media January of ‘98; 

4 A I assume there was. Perhaps I wasn’t paying 4 correct? 

5 attention at that point or it’s not that’s memorable. 5 A That’s my UnderStanding. 

6 Q And how did it come up that she no longer worked at 6 Q AnddidyouseereportsofthisontheTVorhear 

7 the White House? Do you recall? 7 about it on the radio? 

8 A No, I don’t. 8 A Yes. 

9 Q Okay. But you remember her addressing that topic 9 Q And at the time you saw the story break, did you 

0 at some point. 10 recognize Ms. Lewinsky? 

1 A ‘Ihat’s CorTect. 11 A Yes. 

2 Q Tell the ladies and gentlemen to the best of your 12 Q And did it occur to you when the story broke that 

3 knowledge wbat you remember her saying. 13 you had xen her fairly recently? 

4 A That she was no longer WOrking at the white House, 14 A Yes. 

5 that she was now working for the Pentagon doing pretty much 15 Q And you were able to tie that towards the holidays 

6 the same thing, doing advances, preparing events but doing it 16 or your vacation roughly? 

7 for the Pentagon now. 17 A I think that’s what made me remember that that 

8 Q And, Special Agent Garabito, let me ask you, did 18 particular incident which wouldn’t have been of any 

9 she say how long she had been at the Pentagon? 19 importance prior to that. Then when 1 saw the report is wba 

0 A I don’t think so, no. 20 I rememM “You know, I think that was her I saw the otbe 

1 Q Did she mention whether she liked ber job at the 21 day.” 

2 Pentagon? 22 Q All right. Now, you finished up with the 

3 A I don’t think the conversation was that long. 23 Transportation Section earlier in ‘97, in March of ‘97; 

4 Q Did she mention whether she missed the White House? 24 correct? 

5 A No. 25 A Yes, March of ‘97. . 

Page 42 Page 44 

1 Q What was discussed after she talked about working 1 Q Where did you go in March of ‘97? 

2 at the Pentagon? 2 A I went back to what’s called shift work. working 

3 A That’s all I recall. Tben she had to - she went 3 around the Rsidcnt. 

4 inside -- she went ins& to finish whatever her duties were 4 Q So if the President was not traveling, you were in 

5 and then we got busy with our responsibilities. 5 the West Wing during your workday? 

6 Q And how long, all told, from the moment she 6 A Yes. sir. 

7 approached you and the agents to the moment she left you and 7 Q Is that con-ax? 

8 the agents would you say she was there? 8 A Thatiscomct. 

9 A I’d say a few short minutes. She bad to finish or 9 Q Tell the ladies and gcntkmen of the grand jury 

0 continue with what she was doing. 10 what you remanber about tis incident from late November or 

1 Q And asI’ve been asking you questions about this I1 Decanber of ‘97? 

2 group conversation with you, other agents and Ms. Ixwinsky, 12 A Again. I was positional at _ pontq door 

3 have you been able to recall in any way who was with you of 13 that you speak of is to my left. 

4 the PPD? 14 Q5 A No, sir, not in particular, no. I5 A _justsawMrs. 

6 Q If you do recall that as a result of being here 16 Currie and a female with black hair. about the same size and 

7 today at any time in the future, will you contact my office? 17 build as h4.s. Lewinsky. depart and walk towards - if you know 

8 A No problem, yes. 18 the area, towards the Vice Resident’s Off~cc away - 

9 Q How long after the Pentagon incident would you say 19 towards tbe Chief of Staffs Of-Ii 

o it was until tbe occasion at the White House where you Q So if you come out the pantry door and take a left. 

I believed you saw her? :: 91. 

2 A I think that was December Of ‘97. 22 A That is correct. 

3 Q And what makes you say that? 23 Q And hirs. Currie is wbo? 

4 A That’s all I remember. I remember I went on 24 A The Pmsident’s secretary. 

5 vacation after that throughout the whole, the entire 25 Q Is that &ny C&c? 

Page41 -Page44 

Diversified Reporting: Services. Inc. (202) 296-2929 
1214 

m rc: urana ~urv rrocecamm mm-rage .- Thrsdav. July 30. 1998 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

Page 4 

A Yes. 

Q And do you recall what time of day this was? 

A No. sir. 

Q Do you raall if anyone from the PPD was with you? 

A At my post? No. 

Q How about in the area of your post? 

A No. not at my post. \I 

which is far enough away that they can? see the hallway. 

They would not be abk to see what I saw. 

b 

A Tbat is directly in front of Mrs. Currie’s offkc. 

0 Do vou remember anv Uniformed Division officers who 

pantry door being in the aTea during this incident? 

A Yes. I do member an officer. I do remember the 

white uniform standing there. yes. 

Q 

A 

Q 

A 

Q 

A 

Do you know who tbe officer was? 

No. sir. 

Can you describe him? Was it a mak? 

Yes. probably a male. 

Can you.describe him for us? 

Looking. seeing. tbe movement and at tbe same time 

visualizing an offica tlxxe but not tbat I stopped to look 

to sa who be was. Again, at that point it wasn’t anything 

to think about. not until tbe reports came out a couple of - 

Page 46 

maybe four weeks later. 

Q I believe you said earlier today you didn’t get a 

full frontal look of this person with Mrs. Cunie during this 

incident. but you saw a side view and a m view. Would you 

have seen a side view as they’re coming out the pantry door? 

A Tbar is correct. 

Q And then you saw a rear view because they turned 

away from you? 

A That is correct. 

Q All rigbht. Tell us what you saw w&n you got tbe 

side view. Did you gent a profile of this woman? 

A. A pmty quick profile. yea. 

Q And describe what you saw? 

A Just black hair. short black hair. white femak. 

about the size and build of Ms. Lcwinsky. quickly turned and 

from tben on it was just a rear view of Mrs. Cunie. whom I 

recognize easily. and this female walking away. 

Q And did it appear to be Ms. Lcwinsky as you watched 

from behind? 

A From behind I wouldn’t -- if I bad just sari ber 

from behind. I wouldn’t have known. 

Q Okay. Let me ask that a different uay. then. Did 

it match Ms. Lcwinsky from behind? 

A Yes. yes. 

Q Okay. Now base on all the times that you bad sax 

5 

1 

1 

1 

1 

1 

I 

I 

1 

1 

1’ 

21 

2 

2: 

2: 

21 

21 

i 

f 

5 

I( 

II 

1; 

12 

14 

IS 

IC 

I7 

18 

19 

20 

21 

22 

23 

24 

25 

Page 47 

1 Ms. Lcwinsky wbcn sk worked at the White House and tbe time 

2 you’ve s&n her subquently, did it appear to lx ha from 

3 the side view of bu face? 

4 A Yes. Tbe only thing that made me beIiex it was 

5 ber was that quick sick view. That was it. 

6 Q And I undastand you believe this to be Ms. 

7 Lewinsky, but you can’t be sure. 

8 A That is correct 

9 Q Is tlxx an@ing that makes you b&ant m say 

0 tbat it was her? Anytbingspccific? 

I A Tbe fact that it was so quick. It was just - I’m 

2 not looking in that dixction genaally. I probably out of 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

tbe coma of my eye su a movement I look. and it’s a vay 

quick. boom. and tbcy walk away. So it wasn’t - 

Q Did you get a - I’m sorry. 

A So it wasn’t sanetbing that I was expecting someone 

to come out of that door. It’s just I’m looking in all 

directions and I think I probably spotted out of the comer 

of my eye, movements and look and then see a very quick, 

boom. and they’re out 

Q So you tumal and looked befon the individual 

coming out turns to walk away? 

A I look before tbe individual gives me hu back, is 

tbat wbar you mean? 

Q Yes. 

Page 4a 

I A Yes. I see a quick side view, a quick profile. 

2 Q And at that time, did you believe it to be Ms. 

3 Lewinsky based on that quick profile? 

t A That’s right. At that time, I really didn’t think 

5 about it. I thought about it after the report came out. 

5 Q I see. Do you know a Uniformed Division Offker by 

I the name of Lewis Fox? 

t A Yes. 

) Q Tell the grand jurors how you know Mr. Fox? 

1 A I did not know him by name until the interview on 

1 television. I recall that he lives in Pittsburgh and that he 

! was interviewed. 

L Q When you say the interview on television, was this 

I an interview in regard to the Monica Lewiusky case? 

, A Yes, it was. 

, Q When you saw Mr. Fox give an interview with regard 

’ to the Ms. L.&n&y case, did you recognize him? 

1 A Yes,havingscenhimnumeroustimesattheWhite 

’ House. 

I Q All right. By the time of the interview. he had 

retired. Do you recall that? 

A From the interview, not that I knew that_ 

Q All right, but you learned that during the 

interview? 

A Yes. 

Divcrsificd Rc~orting Scrviccs. Inc. (2021296-2929 

Page 45 - Page 48 
1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

2 

2 

2 

2 

2 

2 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

6 

7 

8 

9 

!O 

!I 

I2 

13 

!4 

!5 

Q AsaresultofsuingMr.FoxonTV,didyouevcr 

recall a time wh you saw Ms. Lewinsky in tbe West Wing on 

an occasion when Mr. Fox was on duty? 

A No,IdonotrecallMr.Foxbeingtkreonthat 

occasion. 

Q Did you ever tell soy of your superiors at tbe 

Sazret !&&cc after saiog Officu Fox’s interview something 

to tk effwt of, “I saw that interview and I think I was 

tbcre that day.” 

A Yes, Idid. 

Q Ail right. Explain that to the grand jury, please. 

A when I saw, when I saw Mr. Fox intcrvicwcd and 

heard what hc alIcgaiIy statal, that is what brought back tbc 

manory of allowing Ms. Lewinsky in on one occasion. 

Q Okay. 

A And I wQlt to my supervisor, Lany Cockle, and I 

said, “I doo’t know if this is the same exact day, because I 

don’t know if it occumd several times or not, but I do 

recall on one occasion I allowed Ms. Lewinsky into the Oval 

OfficC.” 

Q Okay. 

A “And I do not know if Mr. Fox was working that 

particuIar day.” 

Page 5C 

1 Q All right. That’s what I want to get at. Let me 

2 back up and ask that in a little more detail. Give the basic 

3 gist of what you saw Mr. Fox say to the ladies and gentlemen 

4 of the grand jury, if you would. 

5 A That it was somewhat surprising to me. And I think 

6 be indicated that be allowed Ms. Lewinsky into the Oval 

7 Office and _ 

8m 

9-“’ _ 

OW 

1 \_a So when be said that, it 

slarrled me and I said. ‘Wait a minute. I member doing 

that once.” 

The fact that he said something that didn’t sound 

normal to me is what caused me to remember that I had allowed 

her io on one occasion. 

Q And that’s not sounding normal bccause once the 

I8 President arrives in the Oval Office. 

!l 

!2C 

!3 A l-bat’s correct. 

!4 Q Ail right. Is it your testimony that hearing 

!5 Fox’s story on TV trigpacd this weekend or holiday or 

Page 45 

Q &iogtbeintaviewonN. 

A Co-t. 

Page51 

1 govanment shutdown event you’ve discusd dere yol 

2 -let Ms. Lewinsky in? 

3 A That is contct. 

4 Q Did it hgger a recollection of Lou Fox in any 

5 way? 

6 A No, it did not. 

7 Q And it causal you to go to Special &at in Charge 

8 Cockle. 

9 A Yes. sir. 

0 Q And what did you tell Special Agent in Charge 

1 cockle? 

2 A Exactly. exactly what I said here. I said. “I 

3 zunanbaul an occasion where Ms. Lewinsky caa~ to the door 

4 with some documcots and I allowai ha into tk Oval Office.” 

5 Q What did Mr. Cockle tell you to do? 

6 A HeaskedmeifIhadwimessedanytypeof 

7 inappropriafe khavior or anything to that effect I said 

8 “No. sir. The door was closed and I departed shortly after 

9 that wlrn I was pushed.” 

0 Q Did k advise you what to dobeyond that? 

l- A No. sir. 

2 Q Allright. 

3 A As long as I hadn’t witnessed anything illegal or 

4 inappropriate. 

5 Q Now with the incident that you’ve dcscrii tbc 

1 holiday or government shutdown or weekend incident, do you 

2 recall Lou Fox being in the White House in any location 

3 during any part of that day? 

4 A No, 1 don’t -- I don’t have any recolkclion of 

5 that. 

6 Q Does Lou Fox -- do you recall Lou Fox b&g present 

7 during any of tk other times you’ve told us about were you 

8 saw Monica Lewinsky. wkther it was just walking around the 

9 White House. the time this November or hcemba ‘97 you saw 

0 hnorthetriptotbePcntagon? 

1 A No, sir. 

2 Q Is it possible that Lou Fox was the Unifh 

3 Division oflica on duty during *incident that you’ve 

4 described? 

5 A Sure. 

6 Q Is it possible k was not tbc Uniforr& Division 

7 officer on duty? 

8 A Yes, it is possibk. 

9 Q I want to ask you next, Special Aga~t Garabito, 

10 about some of the 0th posts. If Ms. Lcwinsky had the type 

!I of pass that you described carlier. that is an iotan or 

12 staffer pass, to your knowledge, would that prohibit her from 

13 enting certain gates or amanccs to the complex? Or would 

14 she otkawise k limited to certain entrancea to the complex? 

Page 52 

:5 A I am not fully aware of what the restrictions are. 

Page 49 - Page 52 .^ Diversified Reporting Services. Inc. (202) 296-292~ 
1.216 

In rc: Grand Jury Proceedings Mlil 

Page 5 

I I think tbe Uniformed Division officers have much more 

2 specific guidelines to that. We ate so concerned with who’s 

3 around tbe President tbat we don’t - I don’t know if that 

4 pass allows you this access. that access. We’re just 

5 concernad if anyone approaching him. 

6 Q And as a practical matter as a PPD. you don’t work 

7 a gate anyway: is that correct? 

8 A That is correct. 

9 Q Have you heard of an entrance or a gate designated 

1 0 ACB? 

1 I A No. sir. 

1 2 Q How about a gate or an entrance -7 

I 3 A No. sir. 

1 4 QI 5 A No. sir. 

1 6 Q Special Agent Garabito. I’m going to ask you to 

1 7 step outside the grand jury room for a moment or two and 

1 8 we’ll be with you in a few moments. 

1 9 (Witness was excused. Witness was recalled.) 

21 0THE FOREPERSON: Mr. Garabito, you understand you 

2 I are still under oath? 

2 2 THE WITNESS: Yes. ma’am. 

2 3 THE FOREPERSON: Thank you. 

2, 4 BY MR. SUSANIN: 

2. 5 Q Special Agent Garabito. a few follow-up questions 

Page 54 

for you from the grand jurors. First. with tegard to the 

incident you talked about where you let Ms. Lewinsky in 

_ on this holiday or weekend or government shutdown 

date. do you recall who you relieved -when 

you arrived tbere? 

A No. sir. 

I 

, 

I( 

1. 

1: 

1: 

Id 

I! 

I( 

1: 

It 

IS 

2f 

21 

2; 

2! 

24 

25 

Q Do you recall whether it was a Uniformed Division 

officer or a PPD agent? 

A I would say it was another agent because if it 

would have b&n an offica it would have meant that I would 

have walked from the residence to the Oval Office part in 

order to push bim to tbe next post. and I don’t recall that. 

So my assumption would be it was another agent. 

Q I might have asked you this earlier and I forgot 

just as a follow-up to that question. Do you recall that the 

President was altcady in the Oval Offrce when you atrived on 

the shift? 

A Yes. tbat is correct. 

Q So is it fair to say you are assuming since there 

was a PPD person to relieve - let me ask you that a 

different way. Strike that. 

So is it fair to say you’re assuming since the 

President was already in the Oval Offtce and you didn’t 

accompany him to the OvaI Offtce there was abeady a PPD 

person to dicve? 

PagC’” Thrsday, July 30,1998 4 

3 Page 55 

Diversified Reporting Services. Inc. (202) 296-2929 

7 A I feel ashamed but I don’t. 

8 Q DO you tunemberayearoramontbtimeofyear? 

9 A Iwanttosay’96,towardsthctime~tbcyha~ 

0 to do tbe budget which is SeptemberKktobu. you know. 

1 August maybe. 

2 Q Let me ask you with regard to your testimony that 

3 you would see Ms. Lewinsky walking, say, from the East Wing 

4 tbrougb the residence to the West Wing or around tht 

5 colonnade, was it unusual to have someone of her level 

6 walking, say, thtougb the White House or tbmugb the Ptess 

7 area or thmugb the colonnade to go back and forth? 

8 A No, sir. Tbe areas that I have indicatai sbe 

9 walked througb are areas tbat alI staff peopk aII interns 

3 would have to walk tbrougb. Tbat’s the’way to get from one 

1 side to tbe other. 

2 Q Let me ask you a follow-up based on that. Wbar you 

3 actually used the word, “rcsidmcc” wben you say someone is 

1 going from the East Wing tbrougb the tesidenee to the West 

5 Wing, is it a pubic part of tk residence tky’re walking 

I A Tbat is correct. 

2 Q But do you have a specific nxolkction one way or 

3 the otber. tbat assumption aside? 

4 A No. sir. 

5 Q Secondly, do you remember when the government 

6 shutdowr~ was? 

Page 5lJ 

I through or are they walking through the Clintons’ residence? 

2 In other words, are they walking through the private 

; quarters, the living room, their dining room, that part of 

I the residence? 

5 A No, sir. It’s totally the public area. It is the 

i only way to get from one side to the other. Evetyhocly takes 

I that route. 

1 Q But it is still called the residence? 

P A Well, I’m using that tf%minObgy SO that you know 

1 what part of the building it is. 

I Q So is “residence” used to deserihe the main White 

! House in that eontext you’re using it? 

I A That’s the terminology we would use. Officially. I 

I think the residence begins on the second floor above the 

i State Floor and the State Floor and the ground floor, which 

i is what I’m referring to, the ground floor of the residence 

1 is a very public area. That’s what everyone has to walk 

1 through. 

1 Q You would see Ms. Lcwinsky on the ground floor? 

1 A Yes. 

Q And the State Floor above that is also public? 

A But I don’t, I don’t ever recall seeing her there. 

Q Andthenthehvofloorsahovethatstattthe 

residence? 

A Considered the private part of the residence, yes. 

Page 53 - Page 56 
A 

1 

2 

3 

4 

5 

6 

7 

8 

9 

IO 

I1 

:2 

,3 

14 

15 

16 

17 

18 

!9 

!O 

!l 

!2 

!3 

!4 

!S 

u rc: uranu Juv rruc;cxxmit?s MULl-rage 1 nursaay, July 50, lwa 

1 

Page 5’ 7 Page 5! 

Q AndistkgroundfloortakmuptotbcStatcFlmr 1 A Not at tk sbouldcrs. Right about tkrc. 

by tourists? 2 Q Okay. So. for tbc ncord. Spczial Agent Garabito 

A Yes. 3 is pointing to his suit collar. right under tk shirt Collar. 

Q AndwhcnyougettotbcStarcnoor.istbattht 4 Help me out bcre. What else is k doing. 

bulkoftktour? Tbat’swbucyousatkdiningroomand 5 A JUROR: Sbouldcr laigtb. 

thcStateRoomandthcRcdRoomandtbcBlucRoomandall 6 THE WITNESS: Sbouldcr kngtb to mc means this. 

that7 7 (Indicating.) 

A Thatisconcct. 8 MR. SUSANIN: You can all tell somebody in my boat 

Q Anotbcr question for a grand juror, M tk 9 doesn’t nail to worry about a description of hair. 

occasion wbcrc you saw Mrs. Ctnric leading somainc out that 1 0 (La&=.) 

may or may not have ban Ms. -sky. was Mrs. Curt-k’s door 1 1 MR. SUSANIN: Thank you vuy much Thank you for 

locked? 1 2 tk klp. 

A I do not recall. I would say no, but I do not 1 3 Special Agent Garabito. I’m going to ask you to 

recall. ThatwasIthittkatcgularworkingday,soIwould 1 4 step outside for anotbcr momcnt sir. 

say no, it was not lockal. It was opened. 1 5 (lk witness was excusal at 11:3&i a.m.) 

Q And what makes you think it was a regular working 1 6 (Wbucupon. the taking of tbc testimony kforc a 

day? 1 7 full quorum of tbc Grand Jury was c~cludal at 11:38 a. m.) 

A Justbccauscofthcwholc-tkdaywbac1 1 8 +*++* 

allowcd Ms. Lewinsky into the offi stands out as an 1 9 MR. SUSANIN: 

abnormal day; wbcrcas, this other day was just a normal day. 2 0 A JUROR: Sbouldcr length. 

Q How was the amount of traffic in the West Wing? 

A Normal, you know, pcoplc going back and forth. 

Q Do you tccall wbcthcr you saw h&s. Curric bcforc 

the incident wkm Mrs. Cur& and somconc you say might bavc 

been Ms. Lowinsky came out of tbc pantry door? 

Page 58 I Page 60 

1 (The witness was excused at lo:06 a.m.) 

2 (Whereupon, the taking of the testimony before a 

3 full quorum of the Grand Jury was concluded at lo:06 a.m.) 

4 a**** 

5 

I A No, I don’t think so. I don’t mmcmbcr it 

2 actually. but I don’t think so. 

3 Q You don’t think that you saw bcr carliu? 

4 A Correct. 

5 Q Do you know if you saw bu after that inciclcnt? 

6 A Yes. Sk rctumcd from down in that direction 

7 somewhere. from tk Chief of Staffs direction. sk RUT& 

8 this way. 

9 Q How much later -- 

0 A See. there you go. Tbc door was opcncd bccausc sk 

1 rctumal from that section, walked by me and wQIt into kr 

2 office. Yeah. it was open. 

3 Q All right. How much time went by from the time you 

4 saw bcr lcavc with tk woman until you saw Mrs. Curric 

5 coming back? 

6 A A short paiod of time, 2-3 tnlnutcs. 

7 Q And sk walkcd back to ha office so ha off& 

8 was unlockal. 

9 A Yes. 

10 Q And tk last question I baw for you. when you say 

!I you saw the woman with short dark hair walking out of tk 

:2 pantry with Mrs. Currie. can you show us what kmgth you mean 

:3 wlxn you use tk word, “short.” 

14 A About kx. (Indicating.) Neck line. 

15 Q Okay. 

Page 57 - Page 60 

Diversified Rmortine; Services, Inc. (202) 296-292~ 
1218 
1219 

OK-302 I Reb 8- 19-94) 

1 - 

OFFICE OF THE IKDEPENDENT COUNSEL 

Dare of uanscription 2/2/98 

PETER A. GEORGESCU, Chairman and Chief Executive 

Officer, YOUNG and RUBICAM, INC. (YRI), 285 Madison Avenue, New 

York, NY, was made available for interview by his attorneys, MARK 

T. MCENROE and MARK DILLER, Legal Counsels for YRI, telephone 

number (212) 210-3427. MCENROE and DILLER were present during the 

interview which was arranged to take place at the Millinium 

Hotel. All persons present were advised of the purpose of the 

interview and the official identit 

m and FBI Special Agent 

of OIC Investigator _ 

by_ GEORGESCU 

thereafter provided the following information: 

A few days before December 11, 1997 Georgescu recalls 

receiveing a telephone call from 'an old friend and business 

acquaintence since 1979" VERNON JORDAN who asked that he take a 

look at a “young person from the WHITE HOUSE" for possible work 

in the New York area. GEORGESCU responded that 'we'll take a look 

at her in the usual way". GEORGESCU explained that both he and 

JORDAN knows that the "usual way" means that if we have an 

opening that she can qualify for. The conversation was only a 

few minutes in length and JORDAN closed the telephone call with a 

committment to send her resume to his office. 

A resume with a cover letter and fax sheet was recieved 

at GEORGESCU's office on December 11, 1997. GEORGESCU saw these 

documents on December 12, 1997 and wrote on the fax transmittal 

page the following note to TOM BELL, president of BURSONMARSTELLER, a division of YRI: 

"Dear Tom, 

Our good pal called personally to ask us to look 

with care at this young lady. I know it would mean 

lots if we can help. Could you arrange for her to 

meet the right people. Let me know what they 

think. Thanks, Peter" 

Near the bottom of the page GEORGESCU wrote the 

following note: 

"P.S. I'll have JANE follow up with RHONDA to see 

who MONICA should see in N-Y." 

tnvestigarion on l/29/98 at New York City, NY File X 29D-LR-35063 

by v m Datedmated z/2/97 
1220 

OK-302a (Rev. 8-19-94) 

29D-LR-35063 

Continuation of OK-302 of Peter A. Georgescu .~n l/29/98 . Page 2 

Some time before January 21, 1997 GEORGESCU remembers 

that he happened to think about the referral from JORDAN and so 

he rechecked with BELL to see if she had been interviewed by 

BURSON-MARSTELLER. BELL replied that LEWINSKY had been 

interviewed. 

A short time following the newspaper stories about the 

President and LEWINSKY (approximately January 21, 1997) GEORGESCU 

learned for the first time from an unrecalled company associate 

that LEWINSKY was not offered a job with BURSON-MARSTELLER. 

GEORGESCU remembers on the day of VERNON JORDAN‘s press 

conference about his part in the job search for MONICA LEWINSKY, 

he received a telephone call from JORDAN at about 2:00 pm which 

was about 1 hour before the press conference. JORDAN informed 

GEORGESCU that he was going to hold a press conference and he was 

simply giving GEORGESCU advance notice. JORDAN explained that he 

was going to tell about his involvement and he wanted to do it 

soon. JORDAN's main concern seemed to be that GEORGESCU had 

prior warning that he would mention YRI in his press release. 

GEORGESCU remembers it being a short phone call and he did not 

see the press conference. 

GEORGESCU is described as follows from observation and 

interview: 

Home Address: 

Home Telephone: 

Business Telephone: 

Business FAX: 
1221 

OK-X Rev. 8-19-94) 

- 1 - 

OFFICE OF THE INDEPENDENT COUNSEL 

Daa of transcriptton 3/26/98 

PETER A. GEORGESCU, Chief Executive Officer, YOUNG & 

RUBICAM (Y&R), New York, New York, telephone number 

was interviewed telephonically at his place of business. -?? 

present in New York during the conversation was MARK DILLER, a 

corporate attorney for Y&R. Present in Washington at the time of 

interview was THOMAS BIENERT, Assistant Independent Counsel, 

Office of Independent Counsel. Y&R is an advertising company. 

At the outset, it was re-affirmed that Y&R was not a 

target of investigation. It was also stated that this interview 

was a follow-up to GEORGESCU's earlier interview for the purpose 

of clarification and coverage of additional issues. 

GEORGESCU and VERNON JORDAN have been friends and 

business associates for about twenty years. They originally met 

in Chicago. JORDAN has no formal connection.to Y&R or any of its 

subsidiary companies. JORDAN may have done some work for Y&R in 

the past, however GEORGESCU has no knowledge of it. 

Y&R's subsidiary companies are: 

BURSON MARSTELLER (B-M) 

WONDERMAN, VITO & JOHNSON 

LONDON & ASSOCIATES 

STODLER & HENNESSEY 

BRAVO 

COHN & WOLFE 

CHAPLAIN 

These companies have varying interests such as public 

relations, advertising, and direct marketing. 

During the calendar year ending with December 1997, 

GEORGESCU saw VERNON JORDAN in person one or two times. 

In 1997, GEORGESCU had only one telephone conversation 

with VERNON JORDAN which occurred in December, exact date not 

recalled. The topic of the conversation was singular in nature 

with only one apparent motivation. 

-_ JORDAN called GEORGESCU at 

(telephonically) 

Invesngation on 3/25/98 at New York, New York FileA 29D-OIC-LR-35063 

b,- Date dictated 3/26/98 
1222

OK-302a (Rev. 8-19-94)

29D-OIC-LR-35063

Continuanon of OK-302 of PETER A. GEORGESCU ,on 3/25/98 .hpe 2

his office to ask if they (Y&R) would take a look at a certain

young woman for the purpose of potentia'-1 employment with one of

their companies. He asked if they would.provide her with an

employment interview. JORDAN suggested that her experience might

fit well with B-M, a public relations company. JORDAN mentioned

that this request would be in accordance with "the usual

conditions.' This meant that GEORGESCU would arrange to initiate

the employment interview process, but from there on GEORGESCU's

involvement would be from arm's length. The interviewee would be

on their own from that point.

JORDAN said that GEORGESCU would shortly receive a

facsimile communication from the person in question, MONICA

LEWINSKY. During this conversation JORDAN did not characterize

LEWINSKY's qualifications other than to mention that she was a

young person. JORDAN did not engage in a "sales pitch" about

LEWINSKY. GEORGESCU inferred that LEWINSKY would be qualified

for an entry level position. JORDAN's remarks gave no indication

as to whether the favor was on behalf of any other person.

GEORGESCU could not recall if there was a White House connection

mentioned during the conversation with JORDAN. He took no notes

during their discussion.

GEORGESCU recalled that JORDAN made a similar request

to Y&R on a previous occasion more than five or six years ago.

He was unsure; however, it was possible JORDAN made a request in

the past for more than one person. GEORGESCU could not recall

the level of experience of the last recommended person. In

addition to these instances, JORDAN and GEORGESCU have exchanged : .

opinions of several people in the industry on an informal basis.

Soon after the telephone call, GEORGESCU's office

received a fax from LEWINSKY,consisting of a Department of

Defense cover page, a letter to GEORGESCU, and a resume. Upon

receiving it, he read through the document.

GEORGESCU referred the matter of LEWINSKY to TOM BELL,

Chief Executive Officer (CEO), B-M, a public relations firm. He

did this because he recalled JORDAN mentioning public relations

as a possible area of employment. JORDAN may have specifically

mentioned B-M; however, GEORGESCU was unsure of this point.

GEORGESCU pointed out that as a matter of practice, if he were
1223

OIC-302a (Rev. S-19-54,

29D-OIC-LR-35063

Continuation of OK-302 of PETER A. GEORGESCU ,On 3/25/98 .page 3

recommending someone to B-M, even at the entry level, he would

make the initial contact with TOM BELL.

Regarding GEORGESCU's handwritten notes on the

Department of Defense facsimile cover sheet received by Y&R from

LEWINSKY, he said the following:

The phrase "our good pal" is a reference to JORDAN

which BELL would understand, not only because of JORDAN's

familiarity with the company, but the attached documents

contained his name. GEORGESCU added that he attached

significance to the request from JORDAN because he had not spoken

with JORDAN on the telephone on any matter for approximately one

year. The referral obviously meant a lot to JORDAN. The term

"meet the right people" indicated that she should get an

interview. BELL would decide what would be done from that point.

The mention of the name JANE is a reference to

GEORGESCU's secretary, JANE TRESE. RHONDA is a reference to

BELL's assistant. The initials PAG refers to PETER A. GEORGESCU.

The note on the side of the page is probably BELL's

handwriting. The note in the middle of the page may be the

writing of PATTY FOX, BELL's assistant.

GEORGESCU did not make any other notes about this

matter and had no further involvement. Between December 12, 1997

and the follow-up call from JORDAN, GEORGESCU received no other

feedback on LEWINSKY. In addition, he did not receive any other : -

communication from LEWINSKY. JORDAN'S December telephone call to

GEORGESCU was made to -or1-t which are his

hone numbers. His secretary's telephone number is

.

GEORGESCU initiated one inquiry about LEWINSKY after

his first referral to BELL. At some point prior to January 21,

1998, he had his secretary call someone (exact person not

recalled) about the matter. He did not recall what prompted him

to do this, but he believed he may have seen some written

reference to LEWINSKY. He learned, as a result, that LEWINSKY

had been interviewed; however, he did not hear about any

assessment of her. GEORGESCU believed that his obligation to
1224

OIC-302a (Rev. 8-19%)

29D-OIC-LR-35063

ContinuationofOIC-302 of PETER A. GEORGESCU .On 3/25/98 .Page L

JORDAN was fulfilled. He made no effort to inform JORDAN of what

had happened or the status of LEWINSKY's employment prospects.

GEORGESCU had no further dealings with the matter until

receiving a telephone call from JORDAN a couple hours before his

(JORDAN's) statement to the press on or about January 21, 1998.

In this call, JORDAN said he wanted GEORGESCU to know about his

impending comments. He said he planned to announce that he had

asked three organizations, including Y&R, to interview LEWINSKY.

While GEORGESCU was on the telephone with JORDAN, he recalled

that he had seen news stories about the LEWINSKY matter; however,

he had not, unfil that moment, connected the news reports to the

request from JORDAN.

GEORGESCU did not ask JORDAN any questions about the

matter of the LEWINSKY referral. The issue as to why the request

was made seemed to be self-evident. GEORGESCU neither made nor

received any calls from JORDAN about this subject after the news

became public.

Since approximately January 21, 1998, GEORGESCU has

seen JORDAN on one occasion. This occurred at the end of

January, when they were present

Davos, Switzerland. He did not

during that encounter.

At no time did JORDAN

:'le got involved with LEWINSKY.

at the same economic forum in

recall any references to LEWINSKY

offer any explanation as to how

GEORGESCU has had no contact with any attorneys

connected with CLINTON about LEWINSKY or JORDAN.

__
1225

FD-302 (Rev. 10-6-95)

- 1 -

FEDERAL BUREAU OF INVESTIGATION

Date of transcription I/ 7 7 / 9 8

LUCY GOLDBERG, 8s

was served with a Grand

Jury subpoena, issued in the United States District Court, 401

Courthouse Square, Alexandria, Virginia. The subpoena which was

addressed to GOLDBERG requested her appearance before the Grand

Jury and documents referring or relating to LINDA TRIPP and

MONICA LEWINSKY.

Investigation on l/22/98 al New York, New York

Date dictated l/22/98

This document contains neither recommendarions nor conclusions of I& FBI. II is the property of the FBI and is loaned IO your agency;

it and its contents are not IO be distributed outside: your agency.
1226
1227

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

- 1 -

OFFICE OF THE INDEPENDENT COUNSEL

LUCIANNE STEINBERGER

birth April v place of

GOLDBERG, white, female, date of

Social SecurZty Account Number unknown,

birth _

Corporate Identification

number-, 1,_ I _

W, home telephone number' sol; propriet&

LUCIANNE S. GOLDBERG LITERARY AGENTS, Incorporated, telephone

number a-1, was interviewed at the New York office of

the Federal Bureau of Investigation, 26 Federal Plaza, New York,

New York, 10278. Also present for the interview was Associate

Independent Counsel (AIC) STEPHEN BINHAK. GOLDBERG was apprised

of the official identities of the interviewers and the nature of

the interview and thereafter provided the following information:

Date of transcription 07/17/98

GOLDBERG advised that in the Summer of 1996, she was

introduced to LINDA TRIPP. GOLDBERG and TRIPP share TONY SNOW as

a mutual friend. SNOW contacted GOLDBERG and said he had a

friend interested in doing a book. TRIPP talked with GOLDBERG

and explained she was interested in writing a book on her

experiences working in the BUSH and CLINTON White Houses.

GOLDBERG and TRIPP arranged a meeting sometime later in the

Summer of 1996.

GOLDBERG and TRIPP met in the Washington, DC home of

GOLDBERG's son, JONAH GOLDBERG, who was present for the meeting,

which lasted a couple of hours. TRIPP brought some documents and

notes to the meeting to provide a snap-shot of TRIPP's experience

at the White House, which gave GOLDBERG an idea that TRIPP knew

what she was talking about. TRIPP did not have any official

White House documents at this meeting.

GOLDBERG suggested TRIPP procure a ghost-writer for the

project. GOLDBERG got the idea that TRIPP thought the CLINTON

administration was unusual and she wanted to write about it.

TRIPP indicated she liked the style of the BUSH White House, but

did not like the style of the CLINTON White House. GOLDBERG

advised that TRIPP did not provide a warm and fuzzy portrait of

the CLINTON administration.

GOLDBERG did not initially have a specific ghost-writer

in mind, so she called around to other agencies and was provided

the name MAGGIE GALLAGHER. TRIPP knew the way the ghost-writer

Investigation on 07/17/98 at New York, New York File f 29D-OIC-LR-35063

Date dictated 07/17/98

/
1228

OIC-302a (Rev. S-19-94)

29D-OIC-LR-35063

lrion of OIC-302 of LUCIANNE STEINBERGER GOLDBERG .On 07/17/98 ,p;lgc 2

II game I' was played. Money was not discussed at this point.

GALLAGHER was not going to charge money to write the proposal.

At that point, GOLDBERG and TRIPP

touch through a handful of phone calls. It

informally kept in

took several weeks

for GALLAGHER to finish the proposal, which she sent to GOLDBERG

when it was completed. GOLDBERG thought it was interesting.

GOLDBERG submitted the proposal to LIZA DAWSON, a

friend of GOLDBERG's who works at PUTNAM, a New York publishing

house. DAWSON said the management at PUTNAM was too liberal to

touch such a product. Only two pages referred to women in the

White House who were involved sexually with President WILLIAM

JEFFERSON CLINTON. One of the women was KATHLEEN WILLEY, whose

name was not revealed in the book and the other was DEBBIE

SCHIFF, whose name was revealed in the book.

GOLDBERG advised the book was about the Travel Office

matter, l'FilegateV'

Counsel's Office.

and other things going on in the White House

GOLDBERG advised that before she could submit the

proposal to other publishing houses, TRIPP called and she had

changed her mind and she did not want to write the book. TRIPP,

advised that she thought publishing such a book was too big a -

risk and TRIPP was afraid she would lose her job. GOLDBERG

advised that money was not discussed with TRIPP, no llballparkll

figures were given. GOLDBERG advised she typically does not

mention dollar amounts because she does not like to promise what

she can not deliver.

GOLDBERG advised that TRIPP was not thrilled with

GALLAGHER's product. GOLDBERG sensed that TRIPP and GALLAGHER

did not get along personally.

the Fall of 1996.

TRIPP called the project off in

GOLDBERG advised the TRIPP project was not a

priority item in GOLDBERG's business.

for calling the project off.

TRIPP was very apologetic

TRIPP felt as if she wasted

GOLDBERG's time. GOLDBERG advised TRIPP was a "straight arrow"

who was embarrassed for dropping the project.

GOLDBERG had no contact with TRIPP until fourteen

months later. In August of 1997, GOLDBERG traveled to Russia.

Upon returning, GOLDBERG had a message from TONY SNOW, who said

that TRIPP would like to get back in touch with GOLDBERG.

GOLDBERG recalls the time frame as late August or early September

when she contacted TRIPP.
1229

OK-302a (Fz. a-19-94)

;3D-OIC-LR-35063

Continuation d OK-302 of LUCIAblNE STEINBERGER GOLDBERG .On 07/17/98 .Rge 3

GOLDBERG assumed TRIPP was interested in renewing the

book deal. When GOLDBERG spoke with TRIPP, TRIPP indicated she

had found herself in an extraordinary situation. TRIPP indicated

zhat MIKE ISIKOFF, a reporter from Newsweek showed up at her

cffice, asking questions about KATHLEEN WILLEY. TRIPP indicated

that ISIKOFF wanted to sit down with TRIPP to discuss a young

woman that TRIPP was familiar with. TRIPP did not mention the

woman's name during this telephone conversation with GOLDBERG.

WLDBERG believes that TRIPP wanted to discuss matters with a

.wiser head" before agreeing to meet with ISIKOFF.

TRIPP provided just enough information for GOLDBERG to

be interested in the story. According to TRIPP, TRIPP had been

friends with a woman, who also worked at the Pentagon, who now

found herself at a "critical juncture" because of the PAULA JONES

lawsuit.

TRIPP was convinced she would be called to testify and

that no one would believe her. TRIPP reminded GOLDBERG that

C3INTON's attorney, ROBERT BENNETT, had already called TRIPP a

liar. TRIPP told GOLDBERG that TRIPP pleaded with the young

woman to tell CLINTON that TRIPP knew about their relationship.

TXPP felt this would cause CLINTON to settle the JONES case,

freeing TRIPP from having to testify. J

TRIPP advised that,

it would be explosive.

if the information she had got out,

GOLDBERG suggested TRIPP go to a tabloid.

TRIPP declined, indicating she felt that was U'sleazy.ll TRIPP

wanted the story to come out in Newsweek

be protected.

so her credibility could

TRIPP knew she would not get any money if the

story came out in Uewsweek. GOLDBERG advised that there was no

book deal mentioned during this time period.

GOLDBERG recalls three conversations with TRIPP during

the Fall of 1997.

19th.

The first was on either September 18th or

GOLDBERG advised she recorded this telephone call.

GOLDBERG cannot recall the date of the second conversation with

TRIPP, but it was not recorded by GOLDBERG. GOLDBERG advised her

third telephone call with TRIPP was on September 28th and it was

recorded by GOLDBERG.

GOLDBERG advised she told TRIPP to tape the telephone

conversations with the young woman from the Pentagon. TRIPP did

no'L want to tape the calls as she thought it was "sleazy.U1

GOLDBERG told TRIPP that the 'lmachine"

TRIPP had irrevocable proof.

would destroy TRIPP unless

by the young woman.

TRIPP felt she was being betrayed
1230

OK-302a (Rev. 8-19-94)

29D-OIC-LR-35063

tion of or-302 of LUCIANNE STEINBERGER GOLDBERG .on 07/17/98 .pagc 4

TRIPP must have made the decision to record after the

second conversation with GOLDBERG in September of 1997. GOLDBERG

and TRIPP met in Washington, DC prior to TRIPP meeting with

ISIKOFF. GOLDBERG was present to witness TRIPP's meeting.

GOLDBERG suggested she and TRIPP meet at JONAH GOLDBERG's house.

GOLDBERG feels her presence made.TRIPP comfortable meeting with

ISIKOFF.

TRIPP brought two audiotapes of telephone conversations

with the young woman. TRIPP wanted JONAH GOLDBERG to duplicate

the tapes. TRIPP gave the tapes to LUCIANNE GOLDBERG, who put

them in her purse. GOLDBERG did not listen to the tapes until

after the LEWINSKY story broke. GOLDBERG advised that TRIPP gave

her the tapes twenty minutes before ISIKOFF was to show up, so

there was no time to duplicate the tapes.

ISIKOFF showed up and began interviewing TRIPP. TRIPP

told ISIKOFF of a Pentagon employee who was involved in a sexual

relationship with CLINTON. TRIPP told ISIKOFF of numerous visits

to the White House by this woman, love letters sent from the

woman to CLINTON and other fairly specific information. TRIPP

did not tell ISIKOFF the woman's name. GOLDBERG advised she did

not know the woman's name at this time, either.

ISIKOFF sat stone-faced while TRIPP told her story.

ISIKOFF told TRIPP he needed more information. TRIPP advised

ISIKOFF of the tapes she had. ISIKOFF did not listen to the

tapes. GOLDBERG advised this meeting was on a weeknight and

ISIKOFF was rushing so that he could appear on a television show

that night.

After meeting with ISIKOFF, TRIPP and the GOLDBERGs

went to dinner at a Thai restaurant in Washington, DC. GOLDBERG

advised that money was not discussed during this meeting.

After this meeting,

situation,

TRIPP kept GOLDBERG apprised of her

as it related to the young woman. GOLDBERG soon

learned the woman's first name was MONICA. TRIPP advised the

situation was becoming more intense. TRIPP showed GOLDBERG some

e-mails written by MONICA. GOLDBERG had no reason to doubt

MONICA existed.

TRIPP did not play any tapes for GOLDBERG. TRIPP and

GOLDBERG spoke daily, except when GOLDBERG traveled. TRIPP felt

sorry for LEWINSKY. TRIPP also worried about LEWINSKY's mental

health. TRIPP, LUCIANNE GOLDBERG and JONAH GOLDBERG were all

angry at CLINTON for allowing the situation to continue.
1231

OIC-302a (Rev. S-19-94)

29D-OIC-LR-35063

Continuation of OIC-302 of LUCIANNE STEINBERGER GOLDBERG .on 07/17/98 .hgc 5

GOLDBERG advised she gave TRIPP no further suggestions

regarding documentation. TRIPP advised that MONICA would

complain about the cost of sending items via FEDERAL EXPRESS.

GOLDBERG suggested TRIPP tell MONICA about GOLDBERG's brother's

courier service, because it was cheaper than FEDERAL EXPRESS.

GOLDBERG made the remark in an off-handed way, with the only

intention of steering some business to her brother.

In November, TRIPP called GOLDBERG in a panic, and said

that someone from PYKE's office called. GOLDBERG told TRIPP that

she would return the call on behalf of TRIPP. GOLDBERG told PYKE

who she was, that she was calling on behalf of TRIPP and that

TRIPP was afraid of being subpoenaed. GOLDBERG advised she did

not call anyone anonymously. PYKE told GOLDBERG he was very

interested in TRIPP and that TRIPP knew "stuff." PYKE did not

mention KATHLEEN WILLEY. GOLDBERG does not know if TRIPP then

called PYKE or if PYKE then called TRIPP.

GOLDBERG did not have much contact with TRIPP during

the holidays. GOLDBERG advised that a week prior to TRIPP going

to Independent Counsel KENNETH STARR's office, TRIPP took a tape

mentioning VERNON JORDAN to TRIPP's attorney, KIRBY BEHRE.

According to TRIPP, BEHRE went "ballistic," because BEHRE had

told TRIPP to stop taping phone calls from her home in Maryland,,

BEHRE said he was going to call BENNETT and get BENNETT to settle

the JONES case. TRIPP said that BEHRE said she could go to jail.

TRIPP became very nervous and told GOLDBERG she needed

a new attorney. TRIPP provided the prerequisites the attorney

would have to meet to satisfy her.

work for free,

The attorney would have to

take the job now and be based in Washington, DC.

In the meantime, because TRIPP was so nervous about

being prosecuted under the Maryland wiretap laws, she wanted to

go to the Office of the Independent Counsel (OIC) to get immunity

for making the tapes. GOLDBERG called around to friends she has,

including one in Chicago who works at the same firm KEN STARR

does. This person recommended GOLDBERG call JACKIE BENNETT at

the OIC. GOLDBERG advised that the OIC knew who this person is

and that this person is very nervous at this time. GOLDBERG

called JACKIE BENNETT sometime before TRIPP did.

GOLDBERG made telephone calls to attorneys in

Washington, DC, New York, Los Angeles and Chicago. GOLDBERG

eventually came up with JIM MOODY, and recommended him to TRIPP.

After meeting with TRIPP, MOODY took a letter to BEHRE,
1232

OK-302a (Rev. 8-19-94)

29D-OIC-LR-35063

Continuation of OlC-302 of LUCIANNE STEINBERGER GOLDBERG .On 07/17/98 .Page 6

indicating BEHRE was being dismissed by TRIPP and MOODY was now

representing TRIPP. The letter was signed by TRIPP. BEHRE

apparently said he needed seventy-two hours to finish typing

transcripts to all the tapes,

TRIPP told GOLDBERG about her meeting with the OIC.

TRIPP told GOLDBERG she was going to be "wired" to go into a

lunch meeting with MONICA. After this lunch, TRIPP spoke with

GOLDBERG and advised that everything went fine. After another

meeting with the OIC that same week, TRIPP told GOLDBERG that the

OIC said that TRIPP should not be talking to a press agent. At

that point, TRIPP and GOLDBERG decided not to speak to each

other.

GOLDBERG was recently contacted by TRIPP, the night

before TRIPP's first grand jury appearance. TONY SNOW called

GOLDBERG and said TRIPP wanted to talk to GOLDBERG. GOLDBERG

advised the talk was mostly "girl-talk" and about the media.

GOLDBERG has spoken to TRIPP approximately five or six times

since, including the night before this interview. GOLDBERG

advised that now the topic is mostly about the grand jury.

GOLDBERG advised that when she recently was quoted

saying that LINDA TRIPP knew who prepared the "talking points,"

she was misquoted. GOLDBERG advised that she was on the show

"Hardball," hosted by CHRIS MATTHEWS. Also appearing on the show

was MATT DRUDGE. GOLDBERG said that she could not imagine that

TRIPP does not know who prepared the talking points. When asked

by MATTHEWS if she knew and if so, how she knew. When GOLDBERG

did not answer, MATTHEWS filled in that GOLDBERG heard a tape.

DRUDGE picked up on it and ran with the story the following day.

TRIPP gave GOLDBERG permission to say that LEWINSKY

told TRIPP that CLINTON knew LBWINSKY would lie and that LEWINSKY

said TRIPP should lie. Everything GOLDBERG said publicly was

with the permission of TRIPP.

GOLDBERG said that TRIPP did not specifically mention

tapes, except for one referring to JORDAN and the two she gave

GOLDBERG. GOLDBERG assumes TRIPP was taping from October through

January. GOLDBERG believes the tape referring to JORDAN was made

in January.

GOLDBERG advised that she has been offered $750,000 to

sell the transcripts of the two tapes she made of conversations

with TRIPP. GOLDBERG thinks all of TRIPP's tapes are worth

approximately $2 million.
1233

.______ ~~____

Steve Goodin, 2/l 7198

Grand Jury

Page 1 to Page 106

CONDENSED 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: 202-5 14-8802
Page 1

_ UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

Page 5

; : ,self-incrimination which means

::.question if a truthful answer to tX

ou may refuse to answer any

e questjon would tend to

!-r ;X~ncrlminate you. Do you understand that?

Zj‘ A- Ido

:l:In re: I;-

ii: GRAND JURY PROCEEDINGS I7

z-e_ ‘ _____________ _x -

:5< Grand Jury Room No. 4

[i:: United States District Court

1::: for the Distnct of Columbia

[::: 3rd 8 Constitution, N.W.

[:i Washington. D.C. 20001

[1: Tuesday, Februa

1:::

1: 5: the

The testimony of DA7

17, 1998

ID STEPHEN GOODIN was taken in

resence of a full uorum of Grand Ju 97-2. impaneled

[:7:on zeptember 19. 199 f‘ , commencing at 1:77 p.m., before:

[!9; SOLOMON WISENBERG

115: STEPHEN BINHAK

[2r,: MARY ANNE WIRTH

I::: Associate Independent Counsel

[21:

[23:

[:4:

125: Washington. D.C. 20004

Page 2

1::

[z:Whereupon,

DAVID STEPHEN GOODIN I:i was called as a witness and, after having been duly sworn by

15 : the Foreperson of the Grand Jury, was examined and testified

16: as follows:

[7: EXAMINATION

!% BY MR. WISENBERG:

!4: Q Good afternoon. Would you state and spell your

[ : 0: name for the record, please, sir?

i::: A Full name?

Q Sure.

A David Stephen Goodin, D-a-v-id S-1-e-p-h-e-n

[i4:G-O-O-d-tn.

114’ Q Occasionally, I will ask you whether or not you

I z 5: understand certain things and well need an audible response, ’

Page 4

: :.a yes. a no, a maybe, as opposed to a shaking of the head, so fL..- -that the court reporter can et it down.

:j: A I understa8n

0 This is a

: i j district judge here in the B

rand jury empaneled by a United States

istrict conducting an

: r. investigation of possible violations of federal criminal laws

: -. involvin possible perjury, obstruction of justice and

!~:subom&on of peFty. i j

Im ’ goin

[ii: order from the U.

to read to you from a portion of the

r 1: : its authority.

Court of Appeals granting this grand jury

[?:‘ The ‘ Independent Counsel shall have jurisdiction

[ f j:and authority to investigate to the maximum extent authorized

[ i 4 : b

K

the independent Counsel Reauthorization Act of 1994

[ 15 :w ether Monica Lewinsk

,lI

or others suborned perjury,

[ 16 : obstructed ustice, ‘ intim, ated witnesses or otherwise f; - : violated federal law other than a Class B or C misdemeanor

[ 13 or infraction in dealing with witnesses,, potential witnesses.

t : 3. attorneys or others concerning the CIVII case Jones v.

r:z:Clinton.”

1::: Do

ty

ou

r:r:courts’ or er?

understand that I just read to you from the

[Z3‘ A Yes. Ido.

I:;’ Q Let me tell you a little bit about

L 2 5: responsibilities.

our rights and

You have whats called a ’ pnv~r ege against

oIc&tarf

(3: A Ido

. Q If you have retained counsel. he cannot set In the

~~~~grand jury room wdh you, but the grand jury will permit you

[ 1 I 1 a reasonable opportunity to step outside the grand jury room

[lz;to consult with

[ I 3 ; understand thar

our counsel if you so desire. Do you

?

:1:. A Ido i.c/*- Q Are you reoresented here today _ bvI

 counsel7

116: A Yes.-1 am.

(1:’ Q And tell us who that might be.

113: A

[15l Q

Mr. Rick Gripley.

All right. And are you involved in a joint defense

[z~lagreement with any other individuals in relation to what we

[ 2 I ! are doing here today?

(221 -A No, Tam.

Q Let me tell you a little bit about grand jury

ii:lsecrecy. Myself, my collea

a,

ues, the court reporter and the

125 lgrand jurors are all. with ce ain exceptions. well

1234

BSA Steve Goodin. 2117198 XMAX(1)

__--__________. ._._

Page 6

al exceptions, were all bound by an oath of ’

what goes on here at the grand jury. Do you

I4! A I do understand that.

Q

165:ouf on the courthouse ste

We cant go blab about it to the press we can ’ t go ’

(7iother hand., are not bounlf

s and talk abou! it. You dn the

[ 9 1 talk about II to

!zz

by such an oath. You a;e free to

an

[ 9 1 thats a matter ’ be

y you want to or to not talk about it,

[ 1 o I understand?

n you and your attorney. Do you

Cl11 A Yes, Ido.

c12: Q I sad there are certain exceptions to our oath of

and let me tell ou what some of them are. This

Page 7

[ : : subject to grand u‘ secrecy.

[ 2 1 you understand &%

They cant go blab ’ it. Do

13: A Yes, Ido.

ndent Counsels.

A fes. ‘ I do.

119i Q You are not a target. Do you understand that?

[I91 A Yes, I do.

[?OI Q

[ 2 I : grand jury mi

A subject is somebody whos not a target. but the ’

ht

I 2: 1 WV wants to 3,

have suspicions about him or her, the grand

ear their storv. Do vou understand that?

im3j’ -

i A Yes, I do. a *

124: 0 You are not a subject. Do you understand that?

(25; A Yes, Ido.

. ._ ~~~

Page 1 to Page 7
1235

BSA Steve Goodin.2117198

Page 8

0 A wetness is somebody who is coming m. who is

ji-gN:ng testimony about a subject matter that a grand jury has

!:a‘ rght to inquire about. Do you understand that?

1: A Yes, I do.

I:,- Q You are a witness. Do vou understand that?

[< A Yes, Ido.

Q You understand that we cant guarantee that you ’ ll’

jj.never be a target, we cant make that guarantee to any ’

! ?.wdness? Do you understand that?

11; A Yes, I do.

11:. Q Your status now based on what we know, based on

(l:.what we kTw,Tez yyoess. Do you understand? ::I

[I; 0

;is.correct?

Youre here pursuant to a subpoena. Is that ’

[lE A Thats correct. ’

0 Did that subpoena call just for your person or did

1::. it call for any documents?

(1;. A

Q

I dont believe that it called for ’ any documents.

[1>‘ Let me ask you whether or not you understand

;:i:;th(7you cannot lie to us here today. Do you understand 1-,

IS,: A I do understand that.

[?.I: Q If you lie about a material matter, thats against ’

12 5 ! the law and thats perjury and that ’ s prosecutable. ’ Do you

Page 1 I

i~jrestaurav

iz: Q

[3!when you

And when you moved to Washtng::? what drd you do

I4i w

ot up here?

When I moved to Washrngton, I tow two jobs,

;;i;y;irlng tables, and served a number of Internships 3n the j ”, . . .

/7: Q Okay. Who did you work for on the HiP

LB! A

; 3 1 Campagn

Marbn Frost and the Democratrc Ccngressional

Commfttee.

;:01 Q And what did you do in those rnterrsnrps basically?

Ill1 A

; 12 I office mana

Pretty standard fare. Copying. I wooed with the

er in Con ressman Frosts offke ana so I would

: : 3 1 do projects or ?-him or or the ? congressmans ’ AA

:;I:‘ Q And once you were finished wrth yczr tnternshrps.

~151 I guess there were two of them, what happened next? Where

[16ldrd you go next?

1241 A Durin the New Ham shire primary. I was the deputy

1~5~schedulerfor the sta e campaign o a f?ice.

_____-____

Page 9

{ 1: understand that?

12: A Yes, Ido.

Q Also this is very important. Eve

i 3 i here is important, but if theres any question tha ’ r!’

hrng Ive read ’

IS not

rs;ciear to you, that

[ 6: ask us to repeat ify I

ou ust don ‘ t understand, we need you to ’

so hat theres no question about that. ’

~7: Do you understand that?

I!: A Yes, I do.

[3: 0

[ l:or‘ about

All right. Is there anything about our authority

i ::.wdness tf?

our rights and responsibiltties as a grand jury

at you dont understand? ’

1::. A

[:3’ Q

No. I understand all that youve said. ’

All right. Remember, if you need at any point to

I : 4 -go and speak with your attorney. well allow you ’ a reasonable

r:soooortunrtv ’ to do so. .~ . .

[i6- A

1 iiquestionin ’

MR. %%NBERG:

to Mr. Binhak.

With that, I will hand over the

[:? &.R BINHAK:

- - .just ask the

All right. And before I start, jet me

.-a rand u‘ forewoman do we have a quorum?

:q.. L-A Tt?E FOk&ERSON: ’ Yes we do.

i-l MR. BINHAK: (2 3 In the room?

And are there any unauthorized people

13;. THE FOREPERSON: No, there are not.

[ZS MR. BINHAK: Thank you.

Page 10

BY MR. BINHAK:

(15: Q And what did you study at Austin?

[:E. A Psycholo y .

Q Okay. A#er you graduated from UT Austin did you

iijcome straight to Washington, or did you stop any place along

rrj.the wav? izc: _ A I lived in Austin for a

[ 2:. raduated and then after that year, P

proximately a year after I

+V

moved from Austin to (2:. ashington.

[I?3- Q

(2 4 -that year?

What were you doing while you lived in Austin for

[-5: ‘ A I was bartending and waiting tables at a

Page 8 to Page 13 ~~~_- _-_- ~~~~

.-

Page 12

Ill 0

A

And how long did that last?

t21 That lasted from December of 91 through the ‘

[ 3 1 primary date, February of 92. ‘

t41 0

[5]campaign?

After the primary, did you stay with the Clinton

161 A Yes, I did.

171 Q

A

What did you do at the campaign?

t89iand then I

I did some work in Florida for a couple of weeks

moved to Little Rock, Arkansas and jorned the

[ 1 o I headquarters office staff.

1111 Q

A

And you stayed there until the end of the campaign?

Cl?1 I stayed based out of Little Rock. I stayed

I I 3 I permanently in Lrttte Rock through the primary season, which

: 14 1 was essentlall

! 151 travetmg and cythrough July, and then In August Ibegan

ilfi~Little Rock

olng work in various cities based out o

,__,_ ._ _ .__...

!171 Q And what kind of work was that?

!I91 A Advance work.

0

ii:l]sort of section in the campai

When you were in Little Rock, were you based in any

7

n?

[211 A

[:21 Q

In the schedu rng advance office.

Oka

rz3lthe election, I woult-!

And did you do scheduling through the end of

think?

(243 A

rz5lYes.

I did advance work through the end of the elechon.

--

Page 13

III 0 Oka

[z ]transition, with the z

And did you have any place during the

linton transition team?

[31 A Yes, I did. I was art of the transrtion advance

[ 4 1 team which was a group of peop e based in Little Rock, P

t5lArkansas.

161 Q

t7jto Washin

Okay. And after the transition, did you come back

ton?

181 %, Yes.

Q

[ :z i in the administration?

Okay. Were you offered a job in the White House or

A

I::iWhite House

I was offered a job that I did not take in the

1131 0 ’ Which one was that?

1141 A A job as a staff assistant in the advance office.

[I51 Q And did you take another job instead?

1161 A Yes, I did.

___- ..-______. ..~_~ .-.-.

OlCStarr
1236

ESA Steve Goodin, 2l17l98 XMAx(3)

Page 14

A I traveled within, I oversaw the logistics of his

ii jschedule and his events, his publtc a pearances and speeches.

[3! Q

14: A worked or him in that job for a

How lonp did you worf? for hlrnb

i 5 1 year and then I moved to another job at the D

roximately a

C.

[6i Q And which ob was that? ‘

A I moved to Ihe financ@ department, where I was the

jijchief of staff for the finance department.

Q

LiEtfinance de

And what did you do as the chief of staff in the

R

artment?

I was responsible for kind of all of the political

1:: land administrative aspects of the work that was done in that

: 13 lde artment, budgeting, coordinatm ! I 4 1 a fp-airs office on cities where we 3

with our political

ha events and managing the

11s 1 staff and the ex enditures of the staff of the department.

1161 Q

[I1’ A

Row long did you stay with that job?

1181 Q

Again, approxJmate9 a year.

And what was next.

[191 A And then in October of 1994, I joined the White

1201 House staff as the Presidents ’ aide,

Q Okay. And did you interview for that job? How did

Izi;that come about?

1231 A I did interview for that ob. ‘ I was interviewed by

~24 ~Erskine Bowles. Prior to that. I had done some advance work

[zslfor the White House in my capacity as a DNC employee, as a

Page 15

1 Ivolunteer, and other things that I had done. I had

1 lsubstituted for the gentleman who was then the Presidents’

jlaide when he was out of town on at kast one, but maybe more

4 1 occasions. 1 filled in for him on a temporary basis.

2 i this way.

Q And did you have any other - well, let me ask this

Are you still the President s aide?

I71 A No.

191 Q

[ 9 1 aide?

Okay. So when did you stop being the Presidents’

A At the beginning of December of this past year.

i :y 1 December of 97. ‘

[l!’ Q Did you have any other obs at the White House ‘

[ 13 I between October 94 and December ‘ 9‘ 1?

I141 A No.

Q Okay. So you were always - for the time that you

1 :ziworked at the White House, you were always the Presidents’

:s‘ correct.

rl7laide.

l13!

1141 $ Tdk”,’

,_“I A Well: the Presidents aide. ’ I auess. helos

y. What does the Presidents aide do? ’

; i;i implement the P&dents’ daily schedule aiid helbs ehsure i 22 1 that the President has whatever materials may be necessary to

~23~peffcmi his job.

(241 0 Do you have any input in creating the schedule?

i?51 A No. Its pretty much presented as a final product ’

Page 16

[I Iwith the aide having the responsibility of im

12 IOn occasion, someone in the scheduling

lementing

oR

it.

[ 3 1 together that schedule might ask for

rce who would put

I 4 I structure an event or something like Y

our opinion on how to

i 5 jexperience.

Okay. But most1 kind of guide the President

I; i through his day. r

hat based on your

Q

Is that correct.

I81 A Thats correct. ’

191 0 Kept him on schedule?

1101 A Attempted to, yes.

r111 Q

ilTjtime?

Made sure he was at the right place at the right _

1131 A Yes.

Q With the right - if he needed whatever

I :z i from a pad to Drops or whatever charts. thats your iod. ’

anything

i16i ’ A Exactly. ‘

_ -

1171 0 Okay. You said that you tried your best. Is the [ 18 1 President a difficult person to move along from a meetin

A

Ilil]meeting. Yes.

He can be difficult to move from meeting oB

?

[111 MR. BINHAK: Okay. Ill’ show

rzz)DG-1. DG obviously are your initials. And his here is a r

ou whats marked as ’

[ 2 3 1 floor plan of the West Wing of the White House.

[241 (Grand Jury Exhibit DGl was

[251 marked for identification.)

OIC&arr ~~ _ -- _____-_~_-. __~~~ _ _~ _. _

Page 37

BY MR. BINHAK:

(16.111’ just make an arrow. DG No. 1.

0 Okay. And why dont ’ ou tell the grand jury when

/ia;you would be there at that location

119; A Durihg a typical da

i%G 1.

rzolthat location as lona as we had SCIi

’ if you will. I would be at

eduled meetinss and/or

i2ijeVents.

Q And is that just meetings or events in the Oval

f?23?~Dffice or would that be meetings or events anywhere in the

I 2 4 ]VVhiie House?

[25! A In the Oval Office. within the White House complex,

__~__.___._~ -- -

Page 18

L I ]or within Washin ton but off the White House.

0 A8 ri

Iiigive a rough percen&

ht. Now in the ty ical day if ou will

ge of h&w much elme duni\9 he Y day ;jou

[I Iwould spe;d athz, location DG No. 1.

/51

161 Q

A

Morethan half your time?

Well, the reason I said a typical day was that

ii :every day was very different so its kind of hard to ’ sa

[siaverage. Having said that, Iwould guess maybe ’ -

an

I abnt’

[ 1 o j know, 60 percent or more.

Q Okay. Let me ask the question another way that

I:ijrnight be a little more hel ( 12 : Presidents in the White ’ Rful to you. Assuming that the

ouse, how much time of the time

[I 4 : that the President is in the Whrte House are you spending at

[ls:DG No. l?

116; A Well. again, it varies on how much of that time he

117: ml ht have scheduled appointments or he may just happen to be

rs!inW ’ e Whde House without scheduled appointments, so rt

r Is:would vary. But, again, on balance, Id say 60 percent or ’

[~~rnore ‘ of m time would be there.

121: !zI All right. Lets talk about DG No. 2. First, why ’

[z::dont’ you tell the

I?_iyour ‘ map as DG s

rand jury where that is and mark it on

.

A Well, theres ’ a slight error in your map here tih

i::iregard to the room.

______ ___~~_

Page 19

11: 0 Okay .

I-: A For reference, if you are lookin

: 3: it says First Floor across the top and

at the map where

e Roosevelt

1 I : Room, the room immediately adjacen to the Roosevelt Room to

rj:the lefl-

[6: Q The one that sa

CT: A The one below tr:

s Lobby or the one below that?

e room marked Lobby. To my [e. knowledge there is not a wall. Thats one ’ large room.

[P:

[lo:

& Oka;.

A So t e wall that is represented on this diagram is

112 : not correct.

[l:’ Q Okay .

A WIthin that room, if you make a quadrant out of

i::jthat room, in the upper right-hand quadrant, I would have a

[ls:desk which I will now mark on

0 Okay. And undy

our map as DG No. 2.

er what circumstances would you find

I :t j yourself at the location youve now marked DG ’ 2?

A An time I could get away from DG No. 1.

i:Eiwas - you know, ha was the place where I would ty.

This

9

et any

{zo:work that I needed to get done done that didnt revove ’

[:: : nnmediatel

d(

around the President.

[z:: Okay. And I assume youre ’ bein facetious to at

[-jleast ‘‘ a certain extent when

124 : from DG 1, but what kind o?

ou say you wanted9o get away

[ 2 5 :getting away from DG l?

work would do you when you were

Page 14 to Page 19
1237

Steve Goodin, 2117198 XMAX(4)

Page 20 Page 23

. A Well, I might file any papers, send any E-mails

j i make any telephone calls, catalo ue gift items or break down

j j the briefing materials that we haB

; ;on a previous tnp or assembly m

used on a previous day or

5: trip if we were

own materials to carry on a

f I somethma like9

oing on a trip tharday, that evenin or

hat. Those are the tvpes of thinas 91d do

: j at it and I see that he has amved at the Oval Office

.: :Thats’ one way. The second way is if Im at ’ locatron number

3 11, I would usually see him through the wrndow walkrng across

.4 lthe colonnade from the residence to the Oval Office

-:, Q Okay. Let me just back up for one second. In the

: i i room where DG 2 is, were there other people who had their

.? iwork stations there?

;;I A Oh, yes.

31 Q Who would that be?

.; , A Well the executive assistant to the Deputy Chief

j I? ; of Staff would be one of the

: 12 1 assistant to the Director of CI?

ople in that room. The staff

al Office Operations would be

- : back the&

: : I House. :_.;

--. A Yes, thats correct. ’

.._J;

.--, Cl

: 3; that there real1

Now, I know - obviously youve given us the caveat ’

:: : White House, z

wasnt such a thing as a typical day in the ’

: 15 1 constraints.

ut well try to do the best we can, given those ’

. _. .-01 A Okay .

17‘ ’

; 1s i in Washin

Q Assuming that the President was in the White House,

;:9ltheWhite %

ton, he was in Washington, he was going to work in

ouse -

I?51 Ill’ just for the record that Mr. Wisenberg has

! 2: lentered the room. .-I

i I; { was goin

that the President was in Washington and

in the White

: 24 1 House, a r

rzslthat?

o work on a day like

: 3! one of the other people in that room. An intern from Oval

.: 4 : Office Operations would be in there. And then the

::slPresidents’ records manager would be in there.

Q So its mostly ’ .unior level staff peo i it i assigned to more senior leveI people within the dle who are

; :g 1 Is that correct?

est Wrng.

A Thats correct. Actually, now ’ I just realized as

i:iIve’ talked throu h that that I made a mistake In challenging

1211

g

our diagram. #le wall is correct, but the proportions .

;ZZ 1 etween those two rooms are not accurate, I dont think. So ’

::31DG No. 2 should in fact be in the left-hand room there and

[z41thats’ the room where the five people that I just described

!:s]tO you work.

Page 21

A I would take whatever time his first ap

ii 1 was and back up at least 30 minutes prior to that an8

ointment

make

:31sure I was in the off& by then.

Q

:;‘ vou could make that determination?

Would you get the schedule the evening before so

.~,~

A

i: {evening before

The

bur

would attempt to get the schedule, to me the

most often - there s a weekly versron of

3 j the schedule circulated and I would try to keep myself

i glfamiliar with what time each day of the week started and t

: 3 1 to keep an eye on that as it changed. I may not know whar

1: ! the final schedule says, but I have a eneral idea.

I-1 Q And as a general matper, what time are we talking

i;!about there? Is it more in the 7:00 range, more in the 8:00

: 4 1 range, more in the g:OO range?

:5! A

: 5: in the morning.

Usually I would get to work between 8:00 and 830

--1 Q Now, when you arrived in the morning, would you go

:j i to DG No.2 or would YOU go to typicall DG NO. 2?

:i;

: 2; pick up m

Usually I would go to Dr, No. 2 and there I woukl

briefin

I 11 version oY .s

materials for the day and assembly my

the bne rng book and, you know again, do any

2: Iwork that I might have to do back there before moving to the

I 3 1 other location.

24) Q And would the weekends be any different than the

: s 1 weekdays? Did you work on the weekends, typically?

Page 22

.1! A My supervisor was pretty

: 2! it so that I didnt have to work on the wee ’ &

ood about tryin

P

to make

ends, so I wou d

Page 20 to PB;ge 25

Page 24

Q

I: 1 correct that?

Okay. Do you want to just cross that out and

A Yes. But the left quadrant I think or the left

i:jsection is rough1

f

twice the size of the otherone,so‘ thats’

rsjwhat threw me o .

Q Let me ask you about DG 1. then as well. The same

jtiquestion. Who else, if anybody, was in the area where your ‘

[ 8 1 work station, DG 1, was?

A Well, in that immediate area is also where Betty

: ;,I‘ Curries desk is the Presidents secreta And then if you

; 111 see the small off@ to the left. is where xt e Drrector of

: 2 1 Oval Office Operations sits.

::31 Q And her name is?

::41 A Nancy Hemreich.

::51 Q Okay. Thanks. All right. Now, you had just

: :6 1 identified for the

17‘ 1 mi ht notice that9

rand jury a couple of the ways that you

P

he President was coming to work or

i ! 3 1 ac ually arriving in the Oval Office. Lets assume for the

: 19 1 moment

:zolthat the J

oure in DG No. 2. What do you do when you find out ’

residents arriving for work at the Oval Office? ’

;:11 A ointment or

:::lmeetin is

Well, depending on what his first ap

.q I.I may go down there to make sure that 5:e has his

: 23 1 matena s, d rts’ something that he needs materials for. Or

:;! 4 1 if its a’ meetin

:z 5 1 its not critical ’ 9

that he doesnt need any materials for or ’

hat he start in a timely fashion or

Page 25

: I I necessarilv finish in a timelv fashion, I may not ao down

izjthere at all.

Q Okay. And if youre in DG 1 does that make any ’

I: 1 difference about how you treat the fact that the President is

r51coming in?

!61 A Well, if Im at DG No. 1 and whomever his first ’

17 1 aooointment is is not there readv to see him. if its time ’

i 8 j for that appointment, then I will make sure that that

: 9 1 is either on their way or knows that they should be tk

rson

ere.

Q Okay. Did ou have any responsibilities as far as

! iy 1 setting up the Oval Office or the day? r

-., .--I A In terms of what?

Q Putting out any papers, making sure pads were out i :: 1 or different materials - as a general matter now, as opposed
1238

Steve Goodin, 2117198

Page 29

XMAXGI

Page 26

: idifferent kinds of meetings and oure trained in ’ *Tat those I:

;!

- 1 are and hoT to+;g,lement them.

i/t

0 Okay. So now were at the ’ oin; I guess, in a

,:;xp

ical day where the President comes to t e Ova! Office. I?

hat would

; 1 least for the

[our typical contact be with the Presdent, at

rst tlrne of the da ?

a1 A Id probably tell ’ CI. ‘ Irn “Good mom!?; * If we have a

9 1 major speech to be delivered that day and I know :hat hes’

o 1 been working on that speech draft and it may nM to be

1~ retyped. I might try to

2 1 theres ’ anythmg critica9ly Important that IS occurm

et that speech draft from p.:m. If

that

31morning - agam. lets say for example that Prime ’ %inister

4 I Blair is comm I will remind him what time Pnme Minister

_j j Blair IS expe c?ed. so I can make sure that hes ’ atiare of what -

: : 6 1 his trme constraints are.

Q Would ou on a regular basis have Just regular !:i jconversation wrth the &resident or was it mostty

I 9 1 business-IF conversations?

jO1 ’ I very rarely and almost never woutd engage the

:: 11 President in just idle kind of - you know, did you see the

::z]game bst nght.

:231 Q Is there any particular reason for that or was that

12~ jjust the way your relationship, your professional

i 2 5 1 relationship, developed?

Page 27

A That was a piece of what I deemed to be /i i professionalism. One of my responsibilities I thmk. was to

[ 3 1 make sure that he had efficient use of his tit& and talking [ a 1 tq me about the game is not what I consider an efficient use

[slof his time.

Q

i; i answer to that.

Fair enough. A very self-deprecating but truthful

[RI A Unless it was the Razorbacks. ,-. Q Fair enough. And I guess as far as your contact

: iiifor the rest of the day would it basicall follow alon

i 111 those lines, mostly prbfessional, just ta k related to Y we

: 12 1 particular meetin

%-

s at hand in order to get him through his

: : 3 iday in the~ostY;;~ient way?

::41

0 Let me sort of shift gears for a second. Who has

: i z i access general1

A

to the West Wing in general?

.._,

;;s!

sbu mean to the buildin of the West Wing?

0 Yes. What kind of peop e would have access to 9

::glthat?

.(I‘ ’ _- , A Well, I mean, I dont know what the specific ’

zirs+cur% ‘::z 1 with -

rules are, but its my understanding that people ’

lue pass holders have unrestricted access to the

: 2 3 1 West Win and would go into the West Wing.

-4‘ ‘ 5 And Im not you know, pinnin ’

i! 5 ; what the exact criteria are Ior a blue pass hoII

you down to know

er. but just

Page 28 Page 31

: 11 from your experience from working at the white House ,and

I: 1 I know you s

Is”

nt a lot of time in the West Wmg. what kind of

: 3 1 person wou get a blue pass?

I41 A A rmanent staff person, long-t volunteer or an

15 1 intern. Anybody rom those three categories who has p”

16 1 completed a background check.

:7; 0 All ri ht. If you worked over in, say, the Old

: 3 1 Executive Office Buyding -

A Sorry. I ust ‘ want to correct. A background

iii investigation. not just a background check as someone who

i 1 I 1 comes in the gate.

I“‘ Q Oka

jf;,conducted by the F&

And thats a full ’ field investigation

I?

!I41 A Thats correct. ’

[iSI Q All right. If

! 16 1 say, in the Old Executive &

ou were assigned to a work area,

ce Building, would ou get a

117 1 blue pass or was that resewed for only people Jlo had work

r : 4 I stations in the West Wina?

,:oi’

Q

r

Well, no. I was ust ‘ talkins about the oval area,

ou know, that area of the hall, b

i i 11 hose three rooms, okay?

ut now I m talking about

A Well if I can -just to clarify I was thinking

I :: i in terms of the kindof L shape, if ou will that ’

114 1 the Oval Office complex down to he r Cabinet Fp

oes from

oom.

Q Sort of the hall that surrounds the Roosevelt Room

I: z /on the south end and eastern side?

i17i

,I*, -..-

i ; 9; attention tothe Oval 01

[2o]the urposes of this wnversatidn tobe the Oval ’ 1

121 istu8y and the dining room area and the pantry, that group of

A Southeastern. Thats correct. ’

0 Okav Now, as I said, let me ask you to turn your

Kc-e comolex. which I consider for

Office, the

OlCStarr

; : 1 the West Wing will probably have a blue

.z : need to frequently go over to the West \hp

ass because they may

:3ljob.

ing because of their

Q So is it fair to say that mostly permanent

I Z jemployees, more senior employees, senior level emplo ees.7

A Yes but as Ive pointed out, interns and ’ Y

i~~volunteers who ha;e also gone through this background

ong-time

: 2 1 investigation and their job may give them need to go over to

! 9 1 the West Wing even on occasion may have also have blue

: : 0 1 passes.

Q Okay. Now, on a typical day, again, typical using

I ;i i the understand that were working ’ with are there a lot of

i ;;I

I 4 1 R

eople in the West Wing or is it relativdly free of people?

ow crowded is it?

. r. ] A Its ’ orettv crowded. as the five oeoole in that one

i ;6 ioffice attest to, both &beople whb are permahenfly working

: :T 1 over there, people who are over there for meetings and/or

i :e 1

P

eople who are ust dropping papers off or whatever, passing ‘

! 191 hrough for wha ever reason. 1

Q Okay. Now let me ask ou to turn your attention

1::; more towards the portion ot the West

122 IOval Office. the dining room and the

V,!ing that contains the

rz3lGenerally as you

study and that area.

124 lwith people or is ip

et closer to that area, IS tt more filled

less filled with people?

I251 A Well, theres kind of an unwritten rule that you ’

Page 30

[ 1 I ~officers might challenge someone. They would certainly,

[ 1111 think, I mean, I dont know, I don ’ t remember seeing any ’

[ 13 1 instances of this, but I would think if you did not have a

i 14 1 blue pass and you were walking throu

[ :slwould challenge you. But in general, BI you have a blue

h there unescorted. they

P

ass

: 16 1 and according to your

P

ass you dont require an ’ escort, hey

117 Iwouldnt’ generally cha lenge people. They might give them a

[ :a ldirty look or something like that.

Cl91 Q So theres this unwritten rule but there ’ s also, is ’

~101 it fair to say, a certain institutional discouraging of

[ 2 I 1 people there in the sense that there are guards there a?d

~22 1 its a ’ little less crowded a?d you might feel out of place If

[z31you were there and you didn t have business?

A Yes. If one of my friends who ha

i::i blue pass shows up in that hallway five minutes g,

pens to have a

fore Prime

iz:lrooris. okay? -

I231 A Okay.

Q

is: j Office. who would have access to the Oval Office.

Who would have access? Startinqwith the Oval

Page 26 to Page 31
1239

BSA Steve Goodin,Z17/98 XMAX(6)

Page 32

- A To the Oval Office rtself?

I_’

,-. Q Yes. Who would be able to enter the Oval Office?

A Well it de

i :iPresldent is in the &al 8

ends on the sltuatlon. If the

c 5 1 different d namic than -

ffice. thats a completely ’

!I Lets start with that. Let ’ s say the President is ’

itlin the Oval Office. I assume anybody who has business with

[ 9 1 the President would obviously be allowed in. Would anybody

[ 9: else feel free to o in there under those circumstances.

A dknerally either Nancy Hemreich Betty Currie or

i if jmysetf would usher anyone into the Oval Office. ’ An‘ one would

[ :z 1 be announced, with the kind of exceptions, if you WII.r, of

: : 3 1 the chief of staff, the Vice President and Mrs. Clinton.

; : 4 .Asne from those three, you know, people dont ’ just want in

: 1 s: the aoor.

Q And even for those three peo i if 1 the ike President the chief of staff and the f.le youve identified, ’

Irst Lady

[ 18 iwas ti common forthem to just walk into the Oval ’ Of&

rlqlunannounced while you were workin there?

A Yes. If we know that 9he President is working on

I zy i his speech and that it would be better for them not to walk

1:~ ! in, we might point @at put to them, but were not going to ’

~f:;keep thempmaoing in there.

ow, anybody else you said ou or Be

[zs]Nancy Hemreich would have to escotl in, 1srh at correPnieor ?

Page 33

111 A Yes.

1:: Cl What would haTpen if someone else tried to just

I 3 lwalk riaht into the Oval Office. .-.

I41 ” A

Q

Well, we would stop them.

Now moving dee I z; what about the dining room? WI?r inside the Oval office complex,

o would have access to the

r-l~dintn

[Blbd%ff

room and how would they get access to that area of the

ice corn lex?

A dell, I dont know if it ’ s necessary to review the ’

rf,__j_~~ zidoors- into there

II?‘ -_ a If vou feel its ’ necessarv to answer the auestion.

i;iiplease do. a

c13: A

akin

Let me ust say first of all and more broadly ‘

141s!e ‘ !!

thats ’ cons1 ered a more rivate area and that,

r I Al 1 II e the allwav door to the Oval ” Off& itself. the doors

i ;6 j into that area ire locked with the exception of the pantry [ 17 ;door and theres a pantry between the actual ’ dinin

9

room and

1 I 9 : the hallway. So you would have to run over one o the I 19: stewards in order to ao in that wav. And other doors into

isojthat area would be lo%ked. _

Q All right. So would anybod have access to the

i::iOval Office complex through say the bacX door to the dining

i :;; room there? That second ddor? fhat would be locked all the

[?4 ::lme?

[:5 A Are you talking about the one from the hallway into

Page 34

i 1: the dining room?

[2. Q Yes. The one thats not the pant ’

17’ L- A Yes. I mean, peo le dont ’ just wa k 7.rn that door.

:i: Q

i 2 I enerall

A

Okay. So to rt $ereIn fact even t e Vice President or someone who

(7: 8.nck bu on to J unlockit.’ so he literally cant just walk ’

has access’ the door is locked and theres a little ’

18 ! through it because its locked. ’

i91 Q So for the most

~o;you have to come through the &J

art, then, is it fair to say that

al

:ll:room?

Office to get to the dining

.,^.

i;;jOfRce -

A You would have to either come through the Oval

[I41 Q

A

I : z 1 sornaone who knows about how to doors would have to

[ 17: unlodc the door for you.

Q All right. So is it fair to say, then, the same

I :~~rules ap ly to entering the dining room as the Oval Office

120 3exceot I .Ps a more private area?

iz1; A Yes.

[Xl

r-3; ‘

Q So fewer people, then. would have access to that.

A Yes.

[:P; Q What about the stud

r

?

I 2 s I as a more private area or less priva

Would you characterize that

e area than the dining

Page 32 to Page 37

Page 35

: room?

A Well, I think the area that youre ’ ree3n ’ to as i the Oval Office complex is - as a whole, its just ’ maze3

z as a more

;j; A Yes.

:I i i yourself

Q

in

WouM there be any other occasions when youd find ’

the Oval office alone?

.-_, A I mean. if Im’

if;iPresident has a particular se9

oing in there to make sure that the

of notes or to replace an

1-4 loutdated set of notes with a revised set of notes or if Im’

::jigoing in there to retrieve a speech that either a senr)r

Page 36

:: !advisor has a question about or. as I mentioned earlier as an

:: iexample. that we may need to

: 2 I those are examples of reasons1

pe In changes to that speech.

hat

: I 1 myself.

I would go in there by

--_’ Q Are there an

Y

reasons youd go in there that are ’

i g i not business related? Wou d you ever just go into the Oval

:- 1 Office without a purpose? Z. ‘ A Well, I mean, I would go in there and .ust i ,; appreciate the fact that I was standing in the Oval OA,ce on

1:: ;occasion. I mean.. I wouldnt make it a point to go ’ n there.

: 1:: If the Presidents ’ In the restroom, I ma

J

wait for hti in the

I: ! Oval Office and just appreciate the fa

.:3;there.

that I get to be

Q Oka

: i,’ i that vou had. I wou d assume. r

Thats one of the perks of having the job ’

.151 A Its’ a nice place to be.

.._ Q

I: i your&f in

What about the dining room? Would you ever find

the dining room alone?

13: A Yes.

.-_. _.: Q Okay. Under what circumstances would that be?

-’ /

--. A If the President is having a luncheon in the dining

:I: imorn, for exame.or he has conducted interviews in the

~3‘ !dinlng room be re. I might again make sure that the seating

::a iarrangements are appropriate, the right number of chairs are

.I 5: in there, plan for where - if its an interview, for ’

.____- ____

Page 37

:: lexample. where I may place the stenographer. Those types of

-:;things.

:I i yoursetf

Q

in

And what about the study? Would you ever find

the study?

3. A Yes. I might.

Q. Okay. Could

.I j occasions that ou might findy

ou describe to the grand jury the

A

yourself in the study?

4 Ite gone there - a lot of times we would, as -ii Ive said, have events in the Oval ’ Office and in those cases

: :: audio-visual people and members from the

.::;furniture movers will come into the Oval O f ?

ress office and

ice to rearrange

::lthings for the event. In a case like that I would take the

131 Presidents’

: 1~; his desk in te,

apers, personal papers, off the resolute desk,

e Oval Office, and move them back to his study

: 5 1 so that people will not be prying into them or knocking them

: :j;off or anything like that.

.._, Q

i I: i wouid you ever

If the President were in the study us&g the study

o into the study?

3:

--. .-.1

Aa feF. were in the study?

.-, A Yes, I might. I mean, it depends on what hes’

!f jdoing. If I know that hes napping, I ’ m not ’

: 3 1 there. If hes ’ changin clothes and were la e for an event,

9

9

oing to go in

I 4 i I might go back there o point that out to him. .-:I -i_ Q Okay. To point that out that “Youre bte for an ’

OlCStarr
1240

BSA Steve Goodin,2117198

j;

i:

[6

i7

:fl

[9

iI0

111

~event.” correct?

Page 38

that.

lut

.--,

:121 A In general. Yes.

0 Okay. Im not talking about either of those ’

i iiicategorles of people nqw, Im ’ talkln7-i about sort of medium to

[ I 5 1 low level p;licyMpe$

[16i K

zr$r. the Whrte ouse, okay?

0 Assistants or staff assistants. Would someone like

iI--I:,‘ i that find him or herself in a meeting with the President on a

i 19 1 regular basis?

A Yes. I mean, it depends on what their rank is and

iiy 1 what their position is and what their expertise is. if you

tzzlwill.

Cl Okay. Would someone of that level, relatively

/::ijunior level find themselves or himself or herself in a

1 :s 1 meeting wiih the President alone?

Page 39

A I wouldnt think so. I mean, it wouldn ’ t be very ’

Ii 1 likely, but it might happen.

I31 Q Okay. But it would be unusual?

I41 A Well, it depends again on their expertise. If they

rslare a-if the

Y

are a low level Domestic Policy Council

[ 6 1 assistant, bu they happen to be the expert on Hope

[7 1 Scholarship funding and the congressional state of play for

I 8 I Hooe scholarships. thev mioht be in there answering a

iiiquistion for him: I -

[lOI 0 Okay. So -

[ill A

Q

If theyre an expert or whatever ’ -

Assuming that ou have someone whos not an expert ’

Ii:; in a particular area. is that the 1.rnd of person who would

: 14 1 have a meitin wtth the Presdent alone?

%vell, I mean, you know, the people who answer

i ,z 1 the phones in the press 0ff1c.e dont just sit around in the ’

1:~ ~OvalOffice with the President. I think thats a fair ’

[ :3 icharacterization.

0 What about interns? Do interns generally get to

i h i i meetings with the President?

[2li get to meetings with the President?

[2Z!

; vz;he

8o they have meetings with the Presrdent?

, I would not think that they do. In

have as a usual course

Page 40

1 I 1 of business - let me ut this another way. Would it be i 11 unusual for an indrvr ual Intern to have a meeting alone with ..$

IL-17 1 the President?

!4l A Unusual but not unprecedented.

Q Okay. When you say “unprecedented” and Im putting ’

Iz 1 aside a person named Monica Lewinsky for this moment. can you

~7 1 think of an

dI

other interns?

I mean, he - you know, if the President were to

jzjfind out that intern Joe Smith is Uncle Billy Bob Smiths’

iolnephew from Smith, Arkansas, yes. He might make it a point

1 I I if we see that erson or he may make it a point to say

12 ]“I want Smith o come in here and get a photo, his uncle P s a ’

:3 1 good friend of mine.” Or whatever.

Q Okay. And.so that would be either a photo

:l i opportunitioraybrsTf meeting?

1161

1171 Q All right. So that would be uncommon but not

! 1 e 1 unprecedented.

1191 A Exactly.

[?Ol Q What about a lon

[ill A That would be hig ly unusual. P,

meeting with a person like that?

0 Okay. Have you ever been in the Oval Office -

::;;I assume youve been in the Oval ’ Office with the President

[ 2 4 1 alone?

!'5] A Yes.

OlC-StWf

Page 41

Q And for business reasons?

XMAX(7)

i2: A Yes.

Q Okay. And I assume youve been in the ’ dining room

1 a :wlth the President alone.

ii. A Yes.

[6: Q And for business reasons again?

i7; A Yes.

Ia: Q And the same with the study?

l?i A

Q

Yes. Everywhere except for the bathroom.

Okay. Fair enou

ii: jone-on-one meetings in the

h. Does the President ever take

Ova9, just him and another person?

:?I?; A Oh, yes. Definitely.

il3’ Q

i:4i

Okay. Thats a common thing? ’

A Yes.-

0 And who would have that kind of access? For the ! : 2 i most oat-t. as weve described it before, ’ mostly senior level

1;; j people butAperha _

v\ps someone of our level?

ell, wrth regard o Internal people, youre’

1: i i talking abo$ st+tseople?

r

t201

A Yes. I mean I think a one-on-one sit-down meeting

I:: iwith him with a staff parson is most likely to be the chief

rz3rof staff or the director of one of the maior offices.

ii4jSomething like that.

t251 Q What about in the dining room? Does he ever

Page 42

[ 1 lconduct meetings like that, a one-on-one meeting, in the

tz Idining room? _

A Yes. Quite often - again, when we have these

I: ;events in the Oval Ofhce. we have to shift his normal office

tslfunctions to the dining room, so, yes.

Q Okay. And what about the study? Does he ever hav

:76;one-on-one meetings in the stud

A l!

with any other individuals?

[El He has, but I thin that would be much less common.

191 Q And what kind of oerson would warrant a one-on-one

t;oimeeting in the stud

ty .

?

A Wel, I mean, if he - again, to use my example,

i :i j you know if he has to change clothes or hes putting his tie ’

[ 13 1 on but Erskine Bowles, the chief of staff needs to speak with

! 14 1 him about the budget negotiations, that would be a meeting

t>sithat might occur in there.

I161 Q So more of an unusual kind of thin

A

i :i i lets ’ get to

Yes. I mean, you wouldnt ’ schedu e a meeting, P

8

ether in the study.

Okay. A little earlier you described to the grand

~:~~ury ‘ that part of your job was to log in

[IIIb

ifts. I assume

om that you say, from that statemen a, that President [ 22 1 received gp.Fe;hat correct?

[231

I I”, i about

Q

how the

Can you ust ive a brief outline to the grand jury ‘

Presidentjwou d9 receive a gift?

-___

Page 43

Page 38 to Page 43
1241

Steve Goodin,2117198

Page 44

XU~XILI,

Page 47

et my hands on them before he can, he

15: 0

::!Might Be >i‘

--1 !X

Is there another mechanism for receivin?,gifts?

or Nancy Hernreich keep gifts or log in grfts.

Oh, yes. They might.

::‘ i the way

0

to

Okay. And how would they get a gift that was on

the President?

75,

s:iwhat Ive ’ rtad in the piess about how the

I mean I dont know. I would ’ have to go off of

3 3 1 but, you know, I mean, you can imagine tK

might get gifts

e nqrmal waysthat ’

14 1 anyone might receive a gift, either someone brings it to them

351or It arrives in the mail in care of them. Or a person who

Page 45

: 1. is

rzide%ers it to&em.

iving the ift actually brings it into the complex and

['I A

[ s;that

Well, I mean, thats ’ - if I think about the ways

eople get gifts,,those are some of the ways that they

[ ~~WOU d P happen and I rma

IC lthose gifts and the 9

ine thats exactly how the ’

&

would take

wou d have to address that be er.

0 Of tte gifts that the President kee s

:; assume some of them he keeps in where he wort? I.

I would

s, in the Oval

: 3: Office andaheOval,Office complex, is that correct?

141 That s correct.

Page 46

.. ‘complex as you have defined it or in the residence, the

i?. second floor of the residence or the third floor of the [ 3 j residence or at Camp David. Or on Air Force One.

Q Let me ask you about the study for a second. Did I”5 i the PresidrtkFei,any gifts in the study?

(6:

18: Q

-) -. that would

Did you ever see a mug anywhere in the Oval Office

have said Santa Monica on it? Are you familiar

tY jwith a mug like that? _1_1? --. A A mug?

I!3: Q Yes. A coffee mug.

4.‘ A

zs;such mug.

I may have. I mean, I dont remember seeing any ’

Page 44 to Pige 49

:: 1 j-l Q

r?lthat?

You dont have any independent recollection of ’

A No. I mean, he has all kinds of mugs, so

1: j I wouldnt pay much attention to them. ’

0 Do you know the term “clutch” or “gawker”7 Are

1:; those terms that youre familiar ’ wrth?

I!’ A Yes.

131 Q

!9i A

Whl dont you define those terms to the grand ’ jury

We , gawker IS. I think. a more widespread term.

( io j Ive never used that ’ tisrm. so Im not ’ real1

Y

familiar with

! 1 I 1 that. Clutch is a term thats widely used o define someone ’

[ IZ lwho is trying to clutch onto a pnncipal or tries to make it

I 1318 point to spend time, be around, get face time, as you say.

i 14 j with a principal.

_ .

Q

I:ziextend? Who are the rinci als.

And when you sal “principal.” how far does that

A

i :z j talking about the President and he

Generafywt!en y$esag the principals, theyre’

ice resident. the First

1191 Lady, Mrs. Gore. and Chelsea.

Q Oka

I:: j Lewinsky. Do ou I!

Lets talk about an individual named Monica ’

A /dont’ know her. I know who she is.

now a woman named Monica Lewinsky?

[221

0 All right Now for the next couple of questions

I::; Im going to ask ’

[zslto just put aside he last month at least insofar as wha r

ou or the next few questions, Id like ’

ty

ou

Page 48

[ 11 youve seen on ’ TV or read in newspapers or

A

magazines.

I21

Q

To the degree that I can, I will.

::!please note that in vour answer so that its clear. ’

Okay. And if that becomes a problem doing that,

I51 A Thank you.

Q

176ithat correct?

You said that youve heard of Monica Lewinsky, is ’

I01 A Yes.

191

rioi

Q Did YOU hear about her before the last month?

A Yes.- I knew who she was before the last month.

iiii

Q Okay. Why dont you describe to the grand jury how ’

ou first either heard about her or came into contact with

,,3,Ker, if you ever did.

1141 A I guess the first time I came into contact with her

[lslthat I can recall and Im sure has been somewhat tainted by ’

[ 161what Ive read ’ in the last month to help stimulate my memory,

: 171 but as I sit here now, the first time I recall was durin the

[ le 1 budget shutdown of 1995 when most of the staff of tRe White

[ 191 House were legally forbidden from comin

IZOI Q And that was as a part of IIl

to work.

i2ijwrrect?

e government shutdown.

A Yes. She was working in the chief of staffs

~~~ioffice and therefore since all of his staff were forbidden

[24 Ifrom coming to work and she was an intern at that point, as

[?51 I now know from reading, I didnt know who she was then, she ’

Page 49

[ 11 was helpin

8

staff his office.

I : 1 Leon Panetta

Okay. And the chief of staff at that point was

correct?

[41 A ’ Thats correct. ’

0 And his office on the map that you have woutd be

/Ziroom 111. correct?

I71 A Thats right. ’

Q And when she was workin

1 t ;shutdown do you have a recollection of w3,

there during the budget

ere she was

r1iIthat?ime?

[IO 1 assi ned!’ Or did you just see her around in the West Wing at

1121 A Well, she definitely was staffing one of the desks

[131in there, but since then the desks have been rearranged under I 14 I the new chief of staff. so its kind of hard for me to ’

i 1s; remember exactly how the desks were situated. But she was at

1161 one of the desks in there.

1171 Q Are we talking about room 111 or the room thats’

i~ejjust to the right of it? ”

I191 A Oh, Im sorry. She would be in the unnumbered ’

I:e 1 ;%;rn, not room 111, but the unnumbered room between 111 and

,..., .--.

Q Okay. Now, you said that

~~~~first having contact with her during the bud

ou remember, I guess,

~24 ]Wh dont’

get shutdown.

1act wit.K

ou elaborate on that? Why do you remember having

[ 2s 1 con her under those circumstances?

-____ _ -... olcstiif
1242

BY Steve Goodin, Ul7198

_~~

Page 50

A Because I didnt know ’ -I knew the people who

.t .worked in that office ordrnarily and she was not one of them,

: so she stood out as a new face. She stood out as someone

-:.who - not to sound diched, but looked pre7 starry eyed

:. about being thrust into kmd of an acbng sta posrtron

I:: c&nng this situation. so she stood out to me in that way,

.; Q All right. Other than her sort of being enamored

: i.wrth having greater responsibility than most interns and

I : ::

..‘ . hat vou noticed durina this aovemment shutdown where she P

robably working where she was, was there any other behavior

:IZ&sworking?

_ _

” : A Well, she seemed -which is not uncommon, she

: ii .seemed enamored of the President. I mean, Im sure that ’

::~~would have made her stand out in my mind.

> ;. Q And you said that

~~~&orkedinthatroomjusttotheng ,6tofroomlll.

ou saw her - you knew that she

Didyou

: : 9 see ‘ her during that period of the government shutdown any

;: ?:other places in the West Win ?

I-:‘ A Not that I reca I. 9

,-. Q Okay. Have you ever seen - well. after the

1:; j ovemment shutdown. did you have occasion to see Monica

iz31P. ewrnsky in the West Wang on other periods, at other times?

!24' A I mean, I dont remember a specific day, but I ’ m’

;2s;sure I did. Yes.

Page 51

1.. Q

! i i nm8mber?

Okay. And what kind of situations, if you

:3: A Well. I mean. she - she - again, at the time,

! 4 ! I didnt know what, but I would see her on occasion passing ’

: 5: in the colonnade between the West Wing and the residence or

:f ;the East Win

.-: Legislative Aw -

As I now know, she was working in the

airs Office so I would sea her passing from

: - ;the Le islative Affairs Office to the West Wing or you know,

;:;I mighfsee her at an event that we had within the complex.

: i ~ I dont remember anv ’ soecific event. but I have a vaaue

ii:j recollection of seeing her at events..

.._. Q Now, at this time, were talking about ’ - when you

{ !i \ see her occasionally around the White House, this is after

: : 4 : the budget shutdown?

. . :. A Definite1 after the bud et shutdown.

.i‘ Q Okay. 20 after the bu8get shutdown and up until

i I- iwhenever you stopped seeing her around the complex. Dd you

; : 5 : have a name placed to her face, or did you ust ‘ know her as a

: : 2: parson who worked in the White House and belonged there?

.__. A I think I knew that her name was Monica. I did not

i z I i know what her last name was.

.__. Q Okay. Do you know how you knew that? Were you

i::iever introduced to hef?

._. A I recall vaguely introducin

if ; j the shutdown because. as I said, I didnt’ a

mysetf to her during

now who she was.

Page 52

. .

~iQffice?

Q Have you ever seen Monica Lewinsky in the Oval

7‘ ’

.-.

I‘’

A Yes.

Cl Okav. Can you describe the occasions or the

i 5 i occasion that youve seen that? ’

,z. A Theres only one occasion that ’ I can think of

i z i specifically and that was a radio address on - I dont’

: I 1 remember the date or even the year or season, but she was at

i 3 i a radio addnss at 5ome point. _

,.-. 0 And were there other peopk in the Oval office 8t

: f ! 1 that time with her?

_._.

.--. ::j:

A Yes.

Q Was the President in the Oval Office at that time?

::r: A Yes. I-;- Q Was there anythin about her visit to the Oval

! Iii Office on that occasion that was 8rfferent from any of the

: : - : other guests of the radio address?

residents request, was that at ’

XYAXIS)

Page 53

[I ! her reque: was rt ?t someone elses request ’ ’

I don t know whose request it was at, blit whenever

15 iwe have guests for a radio address they will sit as an

[ 4 1 audience and watch the President either broadcast or In thus

I s 1 case,, since I recall it being an afte.moon as opposed to a

(6,momrng. he had to have been taping the radio address. so

[ 7 1 they sit and they view this taping, and after the taping. ne

[B 1 will - the tapin

[slin the Rooseve91

may occur in the Oval 0ff1c.e. it may occur

Room, it may occur in the Cabinet Room.

[ 1 o 1 wherever, but his usual practice IS to then receive the

[ 11 Iguests in a receiving line in the Oval Office and so the

[ 12 1 guests will come by one b one, hello, have a p~dure.

(13lvrsit with him briefl

sa

en exd tKe offce and depart

114; I rernem r her coming throu h the line and

[ Islremainin in the outer office where the

9,

sG 1 desk IS marked

I lslafter she ad aona throuqh the receiving line. And then she

j;;istayed lovr.- -. -

Did that stnke you as odd at the time?

(191 A A littkbii.

s--1

[201 Q Wh?

A Wei

I:: jenamored, she wou

ou know as I said she had seemed kind of

kl kind of stare at him. which was not

[23]UncOmmon for anybody in the complex. but particularly for

~24 1 oun

Ir 9

er staff

(251 don

r”.opkr or interns to look at him that way. And

know 8 thra pornt d she was 8n intern or a younger

-_____ _._

Page 54

[z seven

rllStaff Orson. As,,l;nboned also I had seen her at these

on orx8sron. I might see her at an event. And 50 it

[31seemed that she [ 4 1 scara whenever

ou know, was not making sure that she was

e President was around, which is kii of,

rsiagain. one of these unwritten rules, which IS how peopk get

i6 jt6b8 termed 8 dlJtch.

Q Fair enough. So here you are, its after the ’ radio

ii; 8ddress I assume

[ 9 1 DG 1 b&use you

oure’ somewhere near the location marked

1:now that shes in the location marked ’ DG 1

[I o 1 and it seem8d a little - I think. its ’ fair to say unusual to

[ ll~you that SF stizaround. Did you do anything about that?

(121

1131 Q

A

What did you do?

I went in and I told the President that she was

~:!~still here and she was waitin to see him.

[I61 0 i?

A

How did you now that she was waiting to see him?

I dont remember. Either I overheard her say or ’

I :i ]1someone else said to me or I asked her about it directty

[lg]l h8Ve no id88.

[ZOI Q But somehow ou determined that?

I211 A Somehow I de rermrned that she was expecting to see

(22lhim again.

1231 0

A

And what was the President8 response to that?

He said, you know, “Yeah, shes going to visit with ’

i::irrte for a minute.” You know, whenever I come back tell Betty

-- -_-___ _-..__-..-

Pilge 55

[llto bring her in.

Q When ou say “Whenever I come bar%.’ do you mea

! s I the President said yx,enever (4 lwhat did you mean b that?

I come back” or whenever you -

A Well rdont’ know whether I was leaving the room

I z; or he left the room or what, but you know - he was going to

[7 ldo somethin else or I was oin

(81~s was and t3,en he said to P&ell

to do something etse. one of

Q

tty to bring her In.

Okay. And do you know ff that ever occurred? Do

r i 01’ you know if that happened?

A I have a vague recollection of Betty ushering her

I :: 1 into the QV8l Qffice going in then with her.

[131 Q Okai. So at the ve

[ 14 1 President. Betty Curria and Monica1

least, you know that the

8winsky were in the Oval

I 15 I office for some period of time at th8t point.

I161 A Yes.

0 Do i : ii &te hSidt?fIt and dou know if Betty Currie left the rwm such that

r131ome?

Onlca Lewinsky were alone in the 0181

[ZOI A I do not know.

Q Okay. Did you get a chance to see Monica Lewinsky

if f 1 leave the Oval Office at that time? At any time during that

iziday.

t241 A I dont recall. ’

1251 Q Okay. So is 1 fair to say, then, that you dont’

bic;sts~-_.---_---_-__--._~ .-...- -

Pige 56 to Page 55
IS& __-

1243

Steve Goodin, 2U7t88

Page 56

: 1, know how long the were In there together. I-, A Its rue. ’ ty I do not know how long the three of

i; j them were in there together

141 0 Okay. And you dont know whether there was two or ’

ii ] three or three for the whole hme or two for the whole trme? I do not know that either. As I recall. I went -

Page 59

Okay. How did he signal his familrarity with her?

Well, I was again in my role of kind of protecting

j : S! his time. When I went In to ask him about this. I .was

,;e] basically offerin ( 17 1 that was a goodgto chase her away because I didnt’ know if

use of his time, but he told me that no, In

118 1 fact she is connected to someone. Now I think its Walter ’

[ 191 Kaye. I dont know if he said Walter Kaye on that da ’

rzolbecause Ive read stuff in the paper ’ I thmk it was Wai

or

er

[ 2 I J Kaye. He may or may not have mentioned the name in

~~z~particular. but he did rndicate that shes a fnend of a ’

[ 2 3 1 political supporter and I just need to, you know, be nice to

- A No.

Q Have

:. President would shox

ou ever seen her enter a room where the

ly enter the same room?

:;

.:

: ;

A0 Ayleos?e?

A No.

._ Q

i 3 .just left?

Okay. What about in a room where the President had

A No.

I. _ Q Okay. And the converse. Have you ever seen her

jL.~.f i. leave a room where the Presrdent was alone?

(12. A

Q

Im sorry, say ’ -

I.>‘ Have you ever seen her leave a room where you knew

ii; the Presidyt to,??

r.:

,--.

I:-:: ‘ 0

[ :- : about Monica

Okay. And did the President ever speak to you

Lewinsk ?

[:3: A Just in hat one conversation. r

ii;: Q That one time

A Mm-hmm.

[?I; Q No other times?

I::: A No.

[23; Q Okay. Did you evers ak to -

124: A Well, not that I rememge r.

[25; Q Okay. Fair enough. Did you ever speak to the

XMAX(l0)

[zdlher.

I251 0 Just for the benefit of everybody and the record,

Page 57

[ 1 r who is Walter Ka e?

A W%ter Kaye is a Democratic political supporter of

I:ithe Presidents’

L4i 0 Did you know at that time when you went in to see

[ 5 1 the President, did you know Monica Lewinsky by name at that

I.-,, 6 I ooint? Did vou sav Monica Lewinskv?

A’ Just by-Monica. -

I;; Q Okay. And he knew exactly who you were talking

[ 91 about when you said Monica? Or did you say theres a person ’

I o 1 out here or Monicas out here or do you remember? ’

Ill A I dont remember exactly how ’ I phrased it.

.lI! Q Okay. But he understood who you were talking

[ 2 1 J strike me as unusual.

Q Did you ever see her any other times in the Oval

1 i,’ i Office? Not the Oval 0ffrc.e complex, now Im’ talking about

[?41the Oval Office.

(251 A No. I dont recall seeing her there. ’

Page 68 Page 61

[II 0 What about the dining room? Did you ever see

f 2 1 Monica Lewinsk

[31 A t&.

in the dinrng room.

[4! Q And what about the study? Have you ever seen

! 5 I Monica Lewinsky in the study?

i61 A No.

Q Okay. Do you know whether shes ever been in the ’

i z i Oval Office other than the times that you might have seen

19 1 her, the time you saw her?

(101 A

Q

No, I do not know.

What about the study? Do you know if shes ever ’

/.~~. if i been in the studv?

I131 A I do not know.

I141 0

A

What about the dining room?

1151 I do not know.

I161 Q Okay. Have you ever seen the President alone with ( 17 I Monica Lewinsky?

il8j A No.

Q Okay. Have you ever seen her enter a room where

I;,;vou ‘ knew the President to be other than the time that youve’

iz I j just described?

[?I ‘ A

Q

Well, Ive seen her at events, as I mentioned. ’

Alone? Have you ever seen her enter a room where

1:: i the President was alone or you knew the President to be

[ 2 5 I alone?

: : : r-es onsibilities included the kind of mana

;-:of tR. ement or runninge White House, as opposed to the po 9.. itics and the policy I 2 1 of different agencies.

I41 Q Did she have a reputation as sort of being a

: 5: traffic cop, kind of a tough Person who -

[6: A

:7:Yes.

She definitely has a reputation as a tough person.

0 Oka And one of her areas of concern was who was

iijwhere in the West XI.rng?

A Yes. Just

Is that fair to say?

113: ple being where they should be.

11:: Q R”

;::lto her?

Okay. Is t at one of the reasons you went to speak

(131 A Yes. I mean. the combination of this bein an

i14;isSUe Of

f;”

ople not being where they should be and the act P

r:s;ttrat this ad to do with someone who, as I recollect, at that

!I61,point was a staff rnon that I thought was goin out of

1:: ; heir way to be w erever we were. So I went to?ler as a

f I 3; management issue.

0 And, second why was that a concern of yours? Was

Ii ;j that part of your job descripbon or did you take that upon

[ :: ’

-b

oursetf or IS that connected with your mission to keep the

12:: resrdents’ time as sacred as possible?

A Yes. Its directly related. I mean it seems like ’

i::an insignificant piece, but if we spend two seconds sa

[ :C : hello to a staff person on the colonnade instead of looi.

ing

ng

Page 60

: I; President about Monica Lewinsky aside from this one time in

iz; the Oval Office at the radio address?

131 A

Q

No. That was the only time.

Did anyone at the White House ever speak to you

I: i about Monica Lewinsky?

!61 A You mean in the whole history of up until now?

17; Q

A

Yes. Can you remember anything in particular?

I mean, &arty in the past couple of months,

Ii:several hundreds of people have spoken to me about her.

Q I can imagine. I think many of us are in that

i i!iposition. Can you remember any particular conversations that

L 12: you had with anybody at the White House before the last

! : :! 1 couple of months?

A Yes. I va uety remember at some point oing to

i il i Evelyn Lieberman and te 7.lmg her about seeing Monica a these 9

(:i;events and it seemed to me. as I said, that she was kind of

I 17; going out of her way to be walking down the colonnade the

ifs 1 same time that we were. [ 19; that to happen for me toI mean, which was not uncommon for

[:z!about somethin like thaP

o to a supervisor or someone else

iii lfirst one

0 akay. To me that sort of begs two questions. The

is whv would YOU 90 to Evelvn Lieberman of all

iz3ipeople to expiess that-con&m? -

A Evelyn Lieberman was the Deputy Chief of Staff for 1:: ioperations at that point and, as such, her job

Page 56 to Page 61 OlCStarr
XMAX(l1)

1244

BSA Steve Goodin. 2U7l98

Page 62 Page 65

1: I at a briefing card, thats a waste of his time. And so if ’

[ 2 ! I think people are

B

omg out of their way to have those

(3 1 chances to say he lo or whatever. then Im gorng to say ’

[ 4) somethmg about It, either to them directly or to someone in

: s 1 the management.

Q Okay. Now, from October 94 to December ‘ 97 ‘ wniie

I;i ou were at the White House how many people dtd ou s eak to

I 3 I iivelvnLieberman about regarding this particular pro6lem.f

igi - A I have no idea. -

!I01 Cl More than lo?

!I I, A I have no idea.

[221a clutch?

A

If:iYou know, its the staff not ’

[ 2 s 1 something that needs to be ad

1 I 1 supervisor and whomever their immediate supervisor was on an

[ 2 I issue like that, they were answering to Evelyn.

Q So as near as you can sort of recall. what did you

I: 1 say to Evelyn Lieberman at this meeting about Monica?

A I mean to say that we had a meeting is definitely

izlnot ’ a good characterdation. I mean, if I had this

[ 7 1 conversation, which I va

[sIran down the hallway to R

uely recall havin.%, ,l, protab& just

rglsomething

er office and sat , Hey, can you do

about so and so.” And that was It.

101

111 2 l”k%n there wouldnt have been -you know, a big ’

12 Idrawn out - schedulemeeting with her, sit down and talk ’

I 3 1 about it. It wouldnt be that formal. ’

141 0 Okay. Do you remember what her response was?

151 A I do not.

:;itold her?

Q Okay. Did she seem receptive to the fact that you

A I mean I dont remember this conversation but she ’

:t i was generally receptiie to my suggestions and my point o?

20lview.

Page 64

ii,’

A Yes. And I would o to Evel n with all manner of

!!

roblems. Yes. Sometimes just o vent or o complain. a Y

i31 O0 As a result of that - I called it a meeting,

I “, ] I know you said its less formal but let ’ s just for the ’

! 6 1 moment use the term meeting. as a result of that meeting or

(7 ]discussionAwhatever, did yqu notice any change?

i?:

Q

I never ave it another thought.

Okay. 8..

o IS It fatr to say that because you never

it another thought Monica Lewinsky at least as far as

emg around the President too much, that problem was solved7

A I mean I dont have a good sense of the time line ’

kind of stuff sd I dont really know. I mean, ’

[ I 4 1 I dont remember like going to her and ’ havin this

I 15 I conversation several times. so I assume tha9that means that

i ;; i the proble;we$a;ab.

id you ever speak to anyone else at the

[ 18 1 White House about Monica Lewinsky other than Evelyn

f19iLieberman?

1201 4 Prior to the last few months?

[211 0 Yes.

A Not that I remember. I mean, I probably did.

Ii: 1 I dont remember any ’ s

0 Okay. B”

cific conversations thou

Press c?

h.

Id you ever see the I z lj Lewinsky have any physical contact?ent and Monica

OlCSian ~_ .~-..___

:

- A No.

Q Okay. Have you ever heard -

3’ A Well, as- from - let me just correct that.

J iAside from seeing footage of them hug

jlwhich I know from seein: mvself in the3

ing on this rope line

OOtaoe that I was

ijthere. but I,dont’ even re?allthat happenmg. -Im’ sure Ive’

7 jwltnessed it. but I dont ’ reinerr$er it. Because of that film.

Q And youre talking about that sort of ’ wide1 played z j footage that you see on CNN and other networks where here Y IS

3.1 the rope line and the President -

11 A The black beret and - yes. :_ .:

_--1

“3’

’ fq icomplete

AQ $;tsd. ts nuy at that !itie.

&I would like to point out. though, is

Y

not uncommon for the President to hug, ou know, a

: :3jwoman o any age, a man of any a f!

::6lwoman. a 25-year-old woman, a 38

e, you know, a O-year-old

: : 7 I Whatever.

-year-old man. You know.

I mean hes ’ a very huggrn

: 19 1 bothers me a little bit that that footage %

kind of guy, so - it

eeps coming up in

::slthis.

-

Q It bothers you that its taken on a sort of ’

j::lsinister .~.. context?

:221 A Yes. Like its some kind of secret hu ’

2

or

:23lsomethina. I mean, Ive seen the man hua ’ literallv t ousands

i24lOf people:

;251 0 Okay. So Vs fair to say, then, when you see that

Page 66

: 11 hu

[ 2 1 a I 8

based on the contad youve had with the President over ’

le over three [ 31 thats not unusua ’ 7ears, that thats not an unusual thing, ’

behavior on a rope line.

I41 A Thats ’ axrect.

i:ialone with

Q Have you ever heard about Monica Lewinsky being

the President either at the White House or

; 7 1 anywhere else?

!81 A

~9lOfficer Fox.

No, not aside from current press reports of this

Q Okay. So other than what youve read about what ’

1 iy i Officer has said, you have no other knowledge.

[l?] A

0

I have no other knowledge.

Okay. Do you have any indirect knowledge about the i :: 1 relationship or any relationship between Monica Lewinsky and

: 1s 1 the President?

!:61 A

!:7lthat?

You mean like gossip? Have I heard gossip about

:131 0 Puttin

?

aside the last month, were there rumors

; : 9 1 about that at the Whi e House?

:!I]‘ A No.

::11 Q Was there any gossip? .1-, _--2 A No.

::31

[-141 A” 2% them having some kind of physical

: 25 1 relationship, I assume, is what youre saying. ’

i l l

Page 67

Q Well, lets ’ just start with a relationship at this

~2lpoint.

i31 A I heard no rumors about that.

:41 Q Okay. Then I would assume if there was none about

[ 5 1 a general relationship, then there was none about a specific

(63one.

i?]

i91

A Correct.

Q Okay. Do you know why Monica Lewinsky was

: 9 1 ultimately transferred from the White House?

[IO] A I do not.

-:11 Q Okav. Do YOU know whv she was hired at the White

i : 2 j House?

_ .

;;31 A I do not.

Q

i ,: 1 the President was travekna outside of Washinaton or outside

Did you ever see Monica Lewinsky at a place where

iisjthe White House? -

:171 A I remember seeing her at an event here in

f i 9 1 Washington outside the White House.

::51 0 And where was that event?

A It was at one of the hotels. We go to all of them if:; so many times I dont remember. ’ I think it was one - a

: :z I hotel on Capitol Hill, bti I dont remember which one it was. ’

::31 Q Okay. And durin

: :4 1 ou have in mind right now. did t e President and Monica

I!

3, that, this particular event that

: 25 I ewinsky ever spend any Ume alone?

Page 62 fo Pige 67
Page 66

1245

Steve Goodin, 2tl?I98 XMAXHZ)

Page 71

Q

ii{weeks. oka

Now lets focus a ’ little bit on in the last four

13 1 since tha

? Has an body from the White House spoken to you

sr Y

I P I Lewinskyy

ory baslca ly broke in the me&a about Monica

[51 A Oh. Im sure. You know, again, hundreds of people. ’

[ 6,You know. staff people talk to each other about what their

17 Itake on it IS, et cetera.

A No.

.-.

(151 0 In any way?

(161 A No. You mean was I ever assigned to keep Monica

rl7laway?

r,!2, 0 Yes. L-I1

1191 A No.-

1201 Q Did anybody ever talk to you about that?

I:11 A No. Not that I recall.

l?-I.‘ 0 Okay. Is that something that you would recall if

[23, It had happened?

124) A Its hard to say. I ’ mean. given the events of the

L 15 1 last couple of months, it seems like I wouldrecall ’ it, but

Page 69

[I 1 I dont recall ever being assigned to keep ’ any specific

~2 1 individual way from the President. so thats why I make that ’

[ 3 1 assumption.

f41 Q Okay. Do you know if the President ever received

[ 5 1 gifts from Monica Lewinsky?

161 A I do not know.

Q Okay. Do you know if the President ever gave gifts

Iii to Monica Lewinsky?

191 A I do not know.

In, Q

;;;Lewinsky?

Did vou ever have anv social contact with Monica

a .

121 A Did I date her?

Q

iijevergotoapa

Well, lets start with the more general. ’ Did you

rt~ that she was at or go out to dnner wdh a

15 I group of prple

161 I dont’ recall ever seeing her,at a social event

17; Q A n

I 8 1 kind of evytlike t$

hing like Christmas parties at work or some

at?

191 Q

I don t recall seeing her at any events like that.

Okay. And then I assume at that pomt then you

g: inever went out on a date with her or anything like that?

221 A No. Absolutely not.

Q Did you ever go out to dinner in a group of people

gtiand she wrinAFt group?

:5.

_ .~ - -~~ -- .----

Page 70

2 Grirks or something like that? Happy hour?

Q Okav. Did vou ever soeak to Tim Keatina about

1 Monica LeFnsky?~ -, ’

I don t remember speaking to Tim about her.

,jwould not be out of the question for me to have done so

It.

1 because he - I probably would have viewed Tim, if in fact he

lwas still in his position during the time that I recall this

,I going on with Monica showing up at

P

laces, I might have

1 addressed it with him because I wou d have viewed him as her

1 more direct supervisor between her and Eve1 n, but I dont’

I recall speciftcally having a conversation with K.im about it.

il3j Q Okay. -

I141 A I assume that everybody back there knows tie Tim

(15 1 Keating is.

I161 Q

A

Why dont you tell everybody? But I think they do. ’

Tim was the staff director for the Office of I : ,i‘ Legislative Affairs during some of this period. I dont’

[ 191 remember exactly when he left the White House staff. He no (2 o 1 longer is in that osition.

1211 Q

A

8kay. And lets not forget ’ the people over there.

r221 Sorry. I didnt know he was such a ’ househoM name.

1231 Q Some people are better known than others m certain

i 2 4 j circumstances.

[?51 A In certain circles.

Page 68 to Page 73

_ ~______

- ____ -.. .-

Page 72

As

I: i loosely caP.

art of what youve been hearing now, and ’ 111’

I tt the buzz like you did, is there anything that

[jltakes on new s. nificance In that way to you? Any events?

[41 A psounds like youre kind of asking i-f I ’ ve’

[ 5 1 remembered something that ma

I 6 I before that has beep drawn out g

be din? seem significant to me

y thus prpcess.

Q Thats$betterwayofputbTIt.,

I think d s always hard and efimtely subjective

ure out did I remember this because it was

Ill I21

Page 73

; $I%; I received my subpoena?

i3i A No.

141 Q

A

Did anybody before you received your subpoena?

I had a conversation with Bruce Lindsey pnor to Izi being subpoenaed.

(71 Q

A

Okay. And what was that conversation about?

Well I dont want to ’ discuss the conversation with

i:l him. Im told ’ that it&’ protected by an attorney-Client

[ 10 1 privilege.

Q Okay. So youre now ’ - in response to m

i :i jwhat was that conversation about, youre ’ saytng that thar

question

was [ 13 1 an attome -client privilege?

I141 & I consider that discussion privileged. Yes.

1151 Q Okay. As an attorney-client privtlege.

L161 A Yes.

[I71 MR. BINHAK: Okay. Lets put ’ that astie.

iii/that?

MR. WSENBERG: Steve, could I ask a question about

[ZOI MR. BINHAK: Absolutely. Absolutely.

1211 BY MR. WISENBERG:

Q We need to make this cJear for the record,

I::iMr. Goodin. Do you believe this is attorney-client

[251orthe&i

[24 1 privile ed because you have been told this is the Presidents’

de House s position or are you saying that you went
1246 

BSA Steve Goodin, 2117198 XMU. 13) 

Page 74 

.to hrm as 

i I ; pnvileged Y 

our personal attorney and that’s why you feel it’s 

We ‘ust need to know. 

!?’ A MY counsel has advised me that that particular 

: i. conversation is a privileged conversation, that I have an 

c 5 j attorney-client privilege wrth Mr. Ltndsey and that’s what 

! 5. I’m basrng it upon. 

[-. Q Do you know whether or not that is based on the 

! 4 .White House asserting it as attorne 

r 

-client privilege? 

‘i A 

i i 0 j conclusion is. 

I have no idea what he basis of my counsels 

That’s what he told me. 

(1:: MR. WISENBERG: Oka 

[::: MR. BINHAK: I assume J we would explore that at the 

: :3,end. 

“< MR. WISENBERG: Yes. 

i;5: BY MR. BINHAK: 

(16: Q Other than that contact with Mr. Lindse did 

i 1 :.anybody at the White House or anybody on behalf oft 6, e 

[ 13 iPresident - 

[le! A I also want to say that I went to Mr. Lindsey to 

(20) have this conversation. 

[-‘iI Q Okay. Fair enough. 

ii5irequest it. 

A I think that’s important to note. He didn’t 

I241 Q Okay. Well, let me just reiterate the question 

Izs] that I was asking then. Did anyone at the White House or on 

Page 75 

11 jbehatf of the President or on behalf of the,White House other 

t 2 1 than Mr. Lindsey speak to you about this nvesbgabon, your 

i 3 1 subpoena or your appearance today or your testrmony today? 

A Not about the substance of an of this stuff. I 

i:imean, clearly, as I mentioned, you know, sta x people have 

[s!discussions about the potenhal implications and 

I 7 1 what the press is sayin 

(8 i had no conversations a % 

and all that kind of stuff, 

ou know, 

II ut I’ve 

Q 

out the substance. 

Okay. Have any of 

Y 

our fnends. people that you’ve 

iiibeen friend with, later become emp oyees of the White House? 

11: A 

Q 

I’m sorry, say that again. 

Do you have any friends who have become employees 

:; j of the White House? In other words, you know a guy named 

14) Joe, he’s a friend of yours, you went to school together, job 

15; opened up at the White House - 

A Well, I have several friends from my cam ai 

: t j experience who have become staff members at the Whi PI3 e 

n 

ouse 

I Q !in varvina dearees of whether I oreceded them as a staff 

Page 77 

11; Q 

[ 2 1 December? 

All right. Is that what you’ve been doing srncs 

A Yes. 

.--, 

rl3lthe chain? 

A Well, I think that’s in the eye of the beholder 

i :ii but, you know, certainly a promotion for me. 

0 I uess it would be fair to say you have less 

I ::; contact with the B resident. 

I181 A Yes. If you want face time with the President. 

i 19 j it’s not a promotion. 

I201 Q Okay. But substantively, are you doing more 

[211chaltengin work? 

1221 %, I am doing more substantive work, so that’s why I 

[ 2 3 1 view it as a promotion. 

Q Fair enough. But I guess it’s fair to say that 

i : : 1 many people in the White House vrew proximity to the 

Page 78 

t I j President or the principals as you would call them the most 

t2jimportant thing. 

171 A I think there are a lot of neo~le who have that 

iii point of view. Yes. 

MR. BINHAK: 

i 2 jquestions at this time. 

Mr. Goodin, I have no further 

It’s possible that my colleagues 

r7lmay. 

IR, THE FOREPERSON: 

isjtake a break. 

h’s time for the arand iutv to ~ - 

I101 MR. BINHAK: 

il1ja break. 

Okay. Well, in that case, we’ll take 

MR. WISENBERG: I need to ask one question related 

! :: i to the invocation of the attorney-client privilege before we 

i1.1 jtake a break. 

I151 THE FOREPERSON: Yes, sir. 

I161 BY MR. WISENBERG: 

Q Mr. Goodin, when ou went to see Mr. Lindsey, I 

I:; itake it this is fairly recently, since r- hrs has become a 

[ 19 1 public matter? 

(201 A Yes. 

1211 Q Were 

~2-11 opinion holding that t 

’ 

ou aware when you went of the 6th Cucuit 

ere IS no attome 

(231for discussions with members of the W&e House Counsels 

cltent pnvllege 

[24]dfi~? 

I251 A No, I’m not even familiar with what the 6th Crwit 

Page 76 

[!I 

IL‘) 

!31 

I41 

:5: 

!<: 

r-. 

,,. 

;'gi 

I101 

Cl!: 

I::! 

[i3i 

I141 

115: 

116: 

[I?‘ 

[?lj 

li4' Now, you left the White House in December of 

iZSi1997, correct? _ 

A No I left my job as the Presidents aide in 

ii;jDecember of 1997. 

Q Oh excuse me. I’m sorry. That’s what I meant to 

t:: _ say. And where are you working now? 

[:5; A Now I am employed by the chief of staffs office. 

Page 79 

1 Ij encompasses. 

l?, MR. WISENBERG: Okay. That’s all I’ve got prnor to 

ghe break.gMR, WISENBERG: - 

dness excused. Witness recalled.) 

- 

161 Q 

[ 7 1 all afternoon? 

You’re the same Steve Goodin who’s been testifying 

at was the peneral subject matter of what 

i:ijto advise him of my contacts with 

to seek his legal advice and 

t21lcourse of my job. 

onica Lewinsky through the 

Q Without saying what it is, is there anything yw 

[z:;spoke_to Mr. Lindsey about that you haven’t spoken to us 

12 4 1 about? 

I251 A There are no facts that I talked to him about that 

OlCStarr Page 74 to Page 79 
m+*

1247

Steve Goodin, 2l17198 XMAX(14)

Page 83

j : : Offce corn lex

I!

ou know this as the dining room, correct?

I::

i?‘ Q

gs I do. That is the dinma room.

Okay. All right. Let me as you to write dinino

Page 80

_. have not been covered in this session as,far,as I can recall. ^ Q Okay. And so youre ’ contlnuln

.i to the subject matter of the conversatlon,

, then, with respect

wha?pu actually

L -said to him and what he sald to you, you re con i?I+ng on

J. advice of counsel to invoke the attorney-client privilege on

; -that?

._ A Yes, lam.

:;. Q Okav. Now. let me ask -we might ask you back or

i:mi ht not &k you bzack at a Later date for future-discussIons

_:: -orB. itlgattonAabo;;;!at. Do you understand?

. .

_--.

.._. Q Okay. Ive ot some other uestions for you and we ’

:I? j have some questions that R grand jurors9,ave asked us to

.-;-ask.

1s A Okay .

f if1 of a thin

Q You mentioned early on a First Famil

r

Locator, kind

:: : ; would te9I

that you could both hear and perhaps see hat

.--_ vou where the First Family was?

::3: A Yes. .^_. Q Is there any - how shall I hrase this - hard

: - : i copy for want of a better word, version oPthat any

; z: : histokal version of the First Family Locator where you can

[ 2 4 jwhere theyve been ’ 3 all times?

is;: go and find out throu h that bcator or a similar type device

!71c- _--. A I dont know exactly the answer to that, but it ’ s’

____ ..___.___ ______.

Page 81

::my ‘ understanding that the Secret Service logs whjch that box

:: j is reflective of become a part of the permanent dally record

; :; thats ’ com&iled;t;[s diarist.

,<: A

i 6 f the diarist.

In ot er words. that I goes on a daily basis to

I also think its important o point out that ’ o?

::the ‘ locator box is not fool roof aqd, in fact, pn sevelal F 5 f occasions I can recall loo 1

.s.wrong. that they mi ht show

I : 1 : in the Oval Office w en I know that hes been over in the ’

a g.ytIt and nothing that it was

e President on the lqcator box

: : : : residence for 45 minutes because its maintained by the ’

1 f f i uniformed division offken and therefore theres human error ’

: : 3 : involved.

:::: Q How generally - did you find it to be generally

: reliable?

A I mean, for the most part. In the example that

: Ive mentioned it, when he ’ s coming over to the office for ’

-the first time of the day, it was very reliable. Even then,

.‘ it would still be - the time documented would @ten be off

; by a matter of minvtes, but it was enerally reliable in that

f situation. iQwouldn t use !t as the 8,ipIe,

You mentioned the dlarist. Would that be Janice

:__ .- : Kearney o;Ms. McCatherine?

:z:’ A McCatherine.

._=.

--. Q Okay. There are two diarists, correct? Or do you

Page 82

: iwsw Ms. McCatherine as the diarist?

,-

-_ A Well, I know Ms. McCatherine as the diarist only.

.:- Q Okay. I want to talk about something here: I

:; : mi ht have missed It when I stepped out of the room and If I {; :di8 I apologize. Were ’ lookin at DG No. 1. I want to show

: c:

!

od whats called the Oval ’ Of#ce complex in this map is also

._. nown I?. as the dining room by you, is that correct?

A As I heard the other counsel describe it, the

: ; j dining room is a component of the Oval OffIce complex.

1; :Thats’ my understanding.

.

__ Q All right. Im talking about this room on this ’

1: : map, just to the left of the stud

And the Oval office itself.

,-:. THE WITNESS:

! Iij Offce from m

Okay. I was excluding the Oval

own oint of view. ._^.

_-- BY K~R. VS~SENBERG:

._.

.-- Q Okay. Well, *ats’ not how Im referring to it as. ’

.__.

.--_

,--_.

A Okyy., Thats ’ !mprt@.

.--.

._.. .-7.

2

0

gkyylust call tit e dining room, okay?

._:. :..-_ You know this room that on this map says Oval

Page 80 to Page 85

_

i 4 : rwm on there. _

[51 A Okay.

I&: Q All right. This would be to the left of that,

r;~whose room when you were working there, to the left of the. .._

isjdinlng room? ’

A To the left of the dining room, this room would be

[ :i: the office of the senior advisor who has been George

[II! Stephanopoulos or current1 Rahm Emmanuel.

i12: Q Okay. And ow do you spell Rahm. R-o-h-m? i

r13: A R-a-h-m

!14 Q Okay. And there is a door between the dining room

I .~~. Isrand the Stephanopoulos office, correct?

[16:

[17!

llS,

A’ Thats’ correct.

.--1 Q All iight.- Based upon your time served as the

!:~iaide. how common was it for access to the Oval Office, thm. . ._

;;;$%rn’g’ room, to the study, to be obtained by.anybodyb7 going

12~ Ithrough the Ste hanopoulos door into the dining room.

[231 A l%etty much never.

t241

[251

Q Okay

A The resident might use that door to step in there

~____ _ ~~______ _____ _

Page 84

f 11 to ask Mr. Emmanuel or Mr. Stephanopoulos a question, but,

~2 lyou know peo le - you dont use the ’ doqr t.he other way

l3laround. I think lhfa$It may be locked similar to the

[4 lother doors. I dont know particularly, but I think that it ’

I5lis.

[6? Q In other words, the President can go fetch, you

17 1 cant go fetch the President. ’

[El A Exact1

K

That was the rule.

Q All rig 1. You mentioned this incident that you

~:~irecall where Ms. Lewinsk sta ed around after a radio

[ 11 laddress was hovering in)6G 7, the room that DG 1 is in. Is

rlzlthatco&ct?

[I31 A Yes.

0 And ultimately I believe you said that Betty Cunie

i::iushered her in. Is that correct?

1161 A Thats how I recall it. Yes. ’

0 Do you recall roughly when that was? Can you put

I :i 1 any kind of timeframe on it?

[19! A

Q

Time of day?

No I think

1 :y i perhaps a Frida (aping oY

ou said it was right after the taping,

the radio address?

A dell Im assuming that it was a taping of the ’

1:: j radio address. I knbw that it wasnt morning time. And ’

~24 ltypically we would do that on a Friday or maybe a Thursday if

[15!we were traveling Friday, so Im not sure which day of the ’

11 ;week it was, but that would be a natural guess.

Page 85

[Z’

r3imomina?

0 If theyre done live, they ’ re done Saturday ’

i4j - A Yes.

[Si Q

A

What makes you think it wasnt a Saturday morning? ’

I dont know. I recall it being a ’ tapin I

I ti recall it being a weekday. It was more like a norma9 day [e! instead of [ gjrelaxed. I*l

ou know, a sunny Saturday. Saturdays are more

ont remember anybody ’ bein

(lolthats’ probably what makes me think tha..?

in casual attire, so

Q Okay. And would it be fair to say youre not sure ’

i : 5 ; what time of da it was?

1131 A ?rn not sure.

Q Okay. On this articular da in question, yqu saw

i::lBetty usher in Ms. Lewinsky. &en Be? &pically ushen In

(161a guest to the Oval Office, and I take it s e ushered her n

[ 171through the door from the DG 1 area, correct?

118: A Yes. Thats what I recall. ’

Q When Betty does that, does she typically then leave

i:zithe guest there and go back out to her desk?

IZl? A It would depend entirely upon who the guest is.

122: Q Okay. How soon did you leave the area after Betty

i z 3: ushered in Ms. Lewinsky?

[24i A Almost immediately, as I recall it.

[I51 Q Okay. So basically, youre not really in a ’

olcstarr
q BA

1248

Steve Goodin. 2117198 XMAXflSl --.

Page 86

; ;. position to tell us how long Ms. Currie stayed in there f

-Ishe ‘.- stayed in there 39 seconds or if she stayed in thee 15

! ;I mrnutes? tAs that a farr statement?

Yes. She could have been in there % seconds, 15

j;,minutes or an hour.

(6: Q is there some reason that you didnt want to see if ’

[ - 1 Mrs. Currie sta ed in there or not?

A Lo. I mean I dont recall thinking ’ Qco ‘ I want

lijto hide my eyes from this.“’ I dont ’ recall thinkinganytnrng ’

r~o:like that.”

[li] Q Im sorry? ’

i iii natural for%e at that poin to go back to my other desk. As

I was goin

s

to say as we talked about. rt would be

[ 14. I said, thats ’ my only chance to krnd of

[ 1 s :everythmg that s gomg on, the chaos o?

et away from

the schedule and In

tls;fact do quret work, sit down at my desk.

11,: Q It didnt make you uncomfortable in any way and ’

I I B 1 that didnt have any effect on why you left the area? ’

I191 A No.

I?01 Q Thats a two-part question. Did it make you ’

[: 11 uncomfortibteIn any way? I don t recall it makin

~~~idont’ think that I went back to the D8

me uncomfortabte and I

2 area because I

rzpldidnt’ want to be there to see what happened.

[?Sl 0 And DG 2. you would sometimes be at DG 2 even if

Page 87 Page 90

1 I ! the President was in the Oval Office?

,

I;!

A Yes.

Q

[J : time of ye: or

other question is do ??u know what

month, this occurred.

1;; 0 Do you know whether or not Ms. Lewinsky was still

[ 7 i either an igem or a staffer in Legislattve Affairs?

[9: I do not know.

,I,“i

Q

A

As op

Yes. P

osed to her later job at the Pentagon

have no idea where that fell in the time

( I 1 i line of her employment.

q Q Did Evelyn Lieberman ever ive you general

1 :;j instructions about clutches, clutchers or clu9ches. and what

11 J : you were to do about them?

[:S: A

[: E: about it.

I dont remember having any conversations with her ’

It would not be out of character for her to tell

[:I‘ me, you know, ou tell me when

[ 19 : take care of it. 1% .Reople are doin thus and 111’t s consistent wit how I reacted o9.rt.

About that lawsuit with anybody at the White House

[li: A Thats correct. ’

I:3’ Q Why did you go to Evelyn Lieberman? You said that

[I 3: ou went to Evelyn Lieberman at some point bout Ms. Lewinsky.

[:o;%n thus particular occasion, why did you o to her rather

rz::than maybe the immediate supervisor orI4s. Lewinsky? Because

1 x 1 I think you told us sometimes youd go to the ’ clutcher. youd’

L 2 3; go to the individual directly and say cut that out or

~2: jsomething.

[Li5: A Yes.

Page 88

: 1: campai n. Issues involving women, things like Gennifer

[z;Flowers.9

A Well I dont recall Mr. Panetta Ms. Lieberman or ’

I :; an one else pointing that out to me or havinga discussion ’

i j iwit4 me about it. As a matter of common sense, wrth regard

I 6 i to politics, you know, young attractive women or women n

[Tjgeneral around a male principal is a matter of concern about

re:perception.

Q There was no particular concern at the Clinton

1 :ii White House about that? Im not saying there would be ’

[ I I ; anything wrong with that, just because of his particutar -

[ 12 ;the allegations against htm. That was not something that you [ I 3 1 all were particularly alert about?

I havent served ’ in another administrabon so I

I::idont’ knothow to compare that.

Q Well even aside from comparison, were there

i : s i special instructions in that regard?

A There were no special instructions. I mean a

I:iias a matter of common sense, you know, people are aware o3

ain,

[ 20 : charges that get levelled at any

o!

adicular principal.

12 1; certainly those levelted at Press ent Clinton. and therefore (2: 1 that mi ht

[ 23) works t3,

be an issue that they would be - anybody who

ere would be more sensitive to.

l:Swant to

0

be

Has anybody ever said to you one of the reasons we

careful about the clutches or the clutchen I

Page 89

: 1. because of President Clintons ’ - what he has suffered in the

:: -media?

: A I mean, I consider that to be such a base element

; 1 of common sense -

.- AQ Nobody would have to say anything7

.c -that no one would have to say that to me. I

-.‘ mean, thats ’ - thats my opinion. That would be my opinion. ’

1~ : I dont need someone to tell me that. ’

,: Q And no one has told you that?

..--

.-- A Not that I remember. (. Q Has the President talked to you in the last

iIi.approximaflyEi, months about Monica Lewinsky?

_ Q The President never had a conversation with you :q

i I G : approximately the last two or three months or even lets take ’

: : 6. ti back SIX months where he talked to you about, for

: :-: instance, the times he might have been with Monica or you

[ : 3 : remember Monica was only here at such and such a trme? No

: 14: conversation along those Itnes?

il?: A No. No conversations like that.

Q Anybod have any conversation with you in relation

I:, i to the Jones v. Clinton ramutt?

A

i:atits’ a matter of

I mean not a substantive conversation. Im’ sure

a

t:s;is an element of %

ain it‘s’ one of the tactical things that

e administration. No.

__~..___--... _ __~.__. _

Page 91

I : 5: on purpose.

[I61 A No. I had a very good relationship with him.

[i?: Q Bright guy, able administrator?

[is:, A Very capable. Yes.

Q Knows whats going on around the White House ’ as

ii ,’ j much as a;ybo;;selse?

I;:;

[1:: Cl B

1 t 3! time period that t&

the way, did you hear an

?’

hrng during this same

s. Lewinsky is there and hat youre’

I: 4 : noticing that shes trying to get quality time with a ’

iZs!pnncipalolcstafr Pa& 86 to Page 91
1249

PPA I.,,.Steve Goodin, 2117198 xhuX(16)

Page 92

il! A Well, I didnt say quality time. Face time. ’

1 Q Face time. Okay. My words, qualit

I;itime wr!h a rincipal. Did ou hear anythrng about i

time. Face

Hp ” z.

er work

[ 4 1 abilittes~ er abrlrttes at t e job she was actually

: 5 j assrgned to?

A No. I dont recall. ’ I dont recall being involved ’

isi in any a6cussions about her work capabilities, nor would I

i 9 1 generally know what her work product was or how to evaluate

[slit.

ilOi

ill1

[I21

1:31 ,lPl

0 Do you know Nel?

A Nelvis?

Q Yes. The steward.

A Mm-hmm.

Q Do vou know him as Nelvis or Nel or -

I _ 1

i:51

1161

A I call him Nel or Nelvis.

Q Okay. Have you ever spoken with him about Monica

i 17 i Lewinsky?

1181 A No.

0

i i ,’ 1 Lewinsky?

All right. Has he ever spoken to you about Monica

1211 A No. Not that I remember.

0, Do you know anything about his relationship to

[Z!Monica Lysk&

I251 Q How about Glen Mays? Isnt he the other steward? ’

Page 93

[II A

Q

Yes. Glen Mays is the other steward.

Same uestions for him.. Do you recall any

i:~discussSnr wit;;,im a%out Monica Lewtnsky?

[41

[51 Q Either you talking or him talking?

[61 A I dont recall conversations in ’ erther direction.

Q Do you ever recall an incident where either one of

Iz ithose individuals were upset about somethin

[ 9 1 related to Monica Lewinsky and relayed that 9

that somehow

o

;;;;or indrrect~?

you directly

No I mean, over the course of three years, I had

[ ~zlseveral conversations with them about things that the

[ 13 1 have been upset about and I dont ever recall Monica ’ r.

may

ewmsky ( 14 1 being one or even involved in anything that they were upset

[ 15 I about.

0 All right. Were there ever any - you were asked

I if jabout hearing thin s rumors about a relationship. Were

[ 19 1 there any events CVurrng the time that she was workin [ 19 1 intern. as a staffer or over at the Pentagon, any even8

as an

s that [ 2 o 1 occurred which led you to conclude there mi ht be a

[?I 1 relationshi between Monica Lewinsky and Bresident Clinton?

[?I] g No There was nothing that would lead me to

~~3~conclude that.

Q Assuming that she wanted to have time alone with

ii: i the President, that that was one of her goals in life, would

Page 94

[I 1 ou and Nancy Hernreich be an impediment to that goal? And (: 1 1’m.not implying there would be anything wrong wdh you being ( 3 1 an impediment.

I41 A I think its ’ - Nan

[ 5 1 considered an im

c:

ediment to 3JUS about anybody wanting to

Hemreich and I would be

[ 6 Ispend trme with t e President.

I71 0

[gl A

And why is that?

Because its our job to make sure that his time is ’

19 1 used efficiently and what other people want of his time is

I I o 1 often not consistent with whats an efficient use of his ’

i 11 j time.

[I21 0 Was Nancy your superior?

:131 A Yes.

r14: Q

~i~~K&Z%tt?

And did she give you any srcial jnstructions in

ard about people trying to get face me wdh the

A I dont recall ever ’

I :ii her. tt would be more likely that P

etting any instruction from

wouM describe to her

(lslwhat I do or how I do things and make sure that she didnt’

[ 20 1 have a problem with it. Something like that. I dont recall ’

[ 211 her ever telling me how to do that.

Page 92 to Page 97

Page 95

I :y i inadent youve described where ’

Do you recall talking lo anybody about this

onrca lrnaered around after

112 1 the radio address and Mrs. Currie ushered er into the Oval

113 1 Oftice? Who did you tell about that?

[!,jHemreich:bout that. I vague1

I probably would have had a conversahon wrth Nancy

recall that I did.

(161 .~~. 0 Do YOU recall w at her response was? K

[171 A No, 1 dont.’

Q

I :i { been somethin

Based on what you know about her, would this have

that would have concerned her7

[201 A 6;1sed ‘ on what I know about Nancy Hemreich?

[211 0 Nan Hemreich.

A Yes.r

,

mean I would ima ine that it would be for

ji:ithe same reasons that Ive outlined that ’ QI would be a point

i2;jof wncem for me.

I251 Q You mentioned that sometimes the President will

Page 96

jjiothem? - ’ _

1 A I dont recall the names of any of them. I can ’

; of that happening and see their faces. so

It that it happened, but I cant give you a ’

And thats during your ’ -

During my tenure. And thats people that I would ’

15:; know about or that I was familiar with. I mean, you know

~Z:~eNvar%towing about it, so -

may have asked Uncle Jeds nephew to wme by without ’ me

Page 97

I:; Wrn

Q Okay. How often did you see Monica in the West

on the weekends during the whole time that you were at [ 31 the &rite House? Can you recall?

A I dont recall ’ s

1 :i its the weekend and there ’ s’ Knica.”

citically ever thinking, Oh. ‘

/7”; her on

Q

the

All right. So you really cant recall when you saw ’

weekends as opposed to other times?

i81 A I mean I dont remember ’ ever seeing her on the

i 9 jweekend. let alone how many times, if at all. -

;:;;her?

Q How did you speak of Monica when you spoke about

A Well, I probabty didnt have occasion to ’

I ::i her much except in this conversation I imagine that I

ak of

hze (14 Iwith Ms. Lieberman. but I would - I would probably have

[ 1 s 1 characterized her as a dutch.

1161 Q But you dont remember that for sure? ’

1171 A No. I dont remember usina that term in reference ’

i is j to her. I certain think that her behavior was consistent

[lslwith the wa we d %a talked a$o”$ that term.

I:yldeposition in the Jones v.

Has anybod s oken toJou about the Presidents’

Irn on case.

[221

[231

~241

[251

A No.

MR. WtSENBERG: I think thats all I ’ ve got ’

Ms. Wirth?

MS. WIRTH: I just have a few.
1250

--

Page 98

Steve Goodin, 2l17198 XMAX117,

Page 101

.

- BY MS. WIRTH: .?. Q You testified earlier about the budget shutdown

:;;You were working then? You were not one of the people -

c4. A I was deemed essentral. Unlucky for me. All my

i 5 i other friends were having mar aritas at lunch somewhere.

Cl You told us a II

! i: i On the average, how Ion

4le brt about when our da

would your day last at her WhtI e

began

r 3 J House? I know there pro ably % IS no precise answer to that,

i 3 1 but what was your ran e of hours?

.‘“i A I think rom 8:00 to P 8:30 I would often start until

:‘: 1; isome time between 7:00 and 8:00 at night when we did not have

: : 2 1 any evening events and as late as until we got home, if j

’ :; 1 accompanied the President to an event off campus at nrght.

: : 4 1 In those cases, it would be until 1090, 11:OO at night.

0 On the radio address day that you described, do you

j i zi have any recollection of whether Monica Lewinsk . was alone or

: : 7 1 wrth other

R

ople like family or friends in terms ofy

! I 3 1 attending t e address?

;:91 A I dont remember one way or the other. ’

i-'Ol Q When she was waiting to see the President, she was

I,-ltalone?

I:]’ A It seems like she was alone at that point.

Q The hotel event that you described

I;: 1 memory ofAattenMdz *.r

ou have some

area?

[251 R

raatel event in the Capitol HII

Page 99

Ill 0

A

Do you remember what that event was, by any chance?

I21 I think it was a DNC saxophone club recepbon.

Q And do you remember whether that event took place

I: 1 before or after you had your conversation with Evelyn

[ 5 1 Liiberman about Monica Lewinsky?

[61 A I dont remember that one way or the other. ’

171 Q Did vou notice whether Monica Lewinskv spoke to the

i 3 i President on that occasion?

_

A I dont remember watching them speak. I don ’ t’

iziremember one way or the other.

: ? I Q Was that an event that -

:zj A Im sorry. I will say that she was on the front ’

: 3 1 row of the rope line, as at this other event, so it would -

:.I 1 I would assume that the

rson who would have&s

spoke as he spoke with every other

iz;!freire or up to three, four, five, six people deep into the

en either on the front of the rope

:Tjcrowd.

:?’

: 9 i that day?

Q Is there any particular reason why you noticed her

A Well not knowin temporally how these thin s

i y ioccurred its possible that I ha ’ Bbeen observing her aroun

:z 1 prior to this and therefore she stood out to me.

Pp

But as I

z3~recall. she stood out because she was wearing a bright pink

24 jacket, a bri ht pink dress, and she was right smack dab in

2 5 1 he i 3 center o the room. And as I often do at off-campus

: 1 :events. I will skip ahead of the principals and take a look

:: iat the room, what are we walkin

: 3 1 and I just remember going into ta

into, what is the situation.

e room to take a quack look i J Iaround and that she o ped out at me. I dont even know that ’

i 5; I knew her name at tl?P a pant, but I recognized her.

Q Do you remember anything about what she was wearing

! ,“; the day of;he r;$o address?

91

191 Q Oka Putting aside anything that youve read in ’

iz! the paper or heard $0, the media, do you know anything at

; 11 all about Monica Lewinsky getting a ob in New York? ‘

121 A I think the only thing know about that at all is fj

: 3 1 what has been in the media accounts. I dont have any ’

i ; 4 i independent knowledge of that at all.

::51 Q Anythin about her gettin a job at the U.N.?

ii6! A No. NoPasrde from what ve read in the media P

;~71accounts.

:?9! 0 An thin about her moving to New York?

:131 A Norat a!

Q Do you know anything at all, again, aside from

/:1ianything ’ that youve heard in the media about Monica Lewinsky ’

::?lbetng asked to sign an affidavit in the Paula Jones case?

i231 A No. Not aside from what Ive read. ’

;-'4i Q Do you know an

:: 5 1 between Monica Lewinsky and y;!

hrng at all about any contact

emon Jordan?

OlCStirr Page 98 to Page1 03

;:;

1-1

A

a

KmlkIzanythrng about contact between them7

,-.

[3! x No. Not asde from what Ive read ’ in the media

!.~laccounts

0 Aside from the hotel event and the incident that Iz i youve ’ described In the Oval Office, the radio address da

[; ado you have any knowledge whatsoever about any time !ie

19 1 President was with Monica Lewinsk whether alone or with

: 9 1 others? Either of your own knowle ge dy -

:iO! A Whether alone or with others?

[Ll] 0 Mm-hmm. Leaving aside the hotel event and leaving

[ 11 laside the radio address.

!I31 A Let me just recap to make sure Im not ’ getting

: :4 Imyself in trouble here, but the short answer is I dont think ’

! : 5 1 so. Theres the radio address, there ’ s ’ the event at the

; 16 1 hotel. Ive mentioned instances that I can ’ t remember ’

[ 1~ 1 specific trnes but seeing her at events within the complex

[ I B 1 where other people were there. And I have learned from

[ 19 1 seeing thrs vrdeo that she was at the South Lawn event which

[zoldidnt’ even register with me at the time

1211 Q Other than those occasions?

I-21‘ A

Q

I dont recall any other occasions. ’

Either of your own personal knowledge or anything

i::;anybodyetse told you?

[251 A Of other people telling me things like that?

Page 102

[II Q Yes.

A No. I dont recall other ’ people saying anything

I: 1 like that. I mean, more oflen than not, I would have been

~4 Iwith him to witness it firsthand, so, no.

[51 MS. WtRTH: All n ht. Thats ’ all I have.

161 MR. BINHAK: As Qey say, youre on the ’ =--. noat tim. . . -

i; i Just a “~~$T~~~~~i,_, the iione?

191 .-. MR. BINHAK: Riaht. In the red zone.

c:01 BY MR. BINHAK: ”

0

! :i 1 of the President?

Do you keep whats known as the annotated ’ schedul

.__,~

[131 A Yes, I do.

[I41 0 Okay. Why dont you just explain to the grand jury ’

s that I referred

tz~lscheduied to start at

[ 2~ 1 start at 9:40, 9:20.

[2 3 1 National Securi

It says that the chief of staff and the

12 4 1 chief of staff antr .’

Advisor were goin

National Secun

to be here, were they

ifdvisor here. And to

[ 2 5 1 the best of my abilities I try to ma e that an accurate

Page 103

1 I 1 reflection of how the President spent that day with regard to

[ 2 1 the schedule as it was produced.

I then turn the annotated schedule over to the

I: 1 diarist who compiles my record alon

I 5 1 basically a chronological database ?

with other records into

o what the President did

I 6 I on a parbcular day.

[;I 0 And now oure ’ talkin about Ms. McCatherine.

[El A Ellen McC!atherine. &s..

Q All right. Now, can you remember any instances

riz;where the name Monica Lewinsky wouM have shown up on the

i 1 I 1 annotated schedule?

(121 A

0

I dont remember any instances. ’

Thats not a name that you remember ever writing ’

i :: i down on the annotated schedule?

[ISI A No. As Ive mentioned, I didn ’ t know her last ’

[16lname.

0 I take it that you have been following this story

I :I: 1 in the py,at;g;K;,certain extent

1191 Q So you are familiar, then, with the fact that

~~~~fvls. Lewinsky at least as its been reported had an ’

(~2 1 opportunity to discuss gettin

[ 13 1 that she had an interview wd.pI

a new job with Vernon Jordan,

Ambassador Richardson in New

; 2 .I 1 York and that she had interviews at several companies in New

I 2 5 1 York City, private companies.
1251

ESA

Page 104

Steve Goodin, 2/17/98 i 12 ; unprecedented. 0 Would i ii 1 someone lrke Vernon Y

ou expect to have a conversation with

ordan if you decided to leave now the [ 15 1 White Hour anyde:ok for work yourself?

116;

117; MR. BINHAK: Okay. Last two questions.

[18i

[I91

MR. WfSENBER$romTem you.

MR. BINHAK:

120: MR. WISENBERG: Let me just 

- can I ask one real

rz:!quick?

I221 MR. BINHAK: Sure. Absolutely.

I231 BY MR. WISENBERG:

Cl Would ou expect Vernon Jordan to take you in his

iz: i car to an attorney that

Ke recommended for you?

Page 105

A

ilithat for me.

It would not surprise me if he were willing to do

131 BY MR. BINHAK: Q Is there anything

- lets start this way. You ’ ve’

I: i now sat for about two hours or maybe three discussing the

[slvarious subjects that were ’ talkin about, so I think ou

~7 1 have a good sense of the areast3,at weve been ’ as!.

[slabout._

rng you

191 A Yes.

CiOl

0 Is there anything that you can think of that is

(II! relevant to the areas that were asking about that we have ’ [ 12 I not elicited from you through our questioning? Any f 13 1 information?A Well, nothing comes to mind and not having a better i ::i understanding of the approach that you all are taking, no. [ 16 1 Nothing does come to mind.

1171 BY MR. WISENBERG: Q Well, you heard me describe our authority and read i i zi a part of the courts order about what were looking at at ’ [ 2 o 1 the beginning of your session, correct? A Yes. I thjnk youre talking about looking into ’

jiijperjury orsQubor&nfiperlu~

[id i Jones v. Clinton.

onrca ewtnsky or anybody having to do with

So I guess the question is is there any [ :: 2 I rnlevant information that you havent told us, anything ’

Page 106

1: : relevant to our inquiry?

I;:

A No, I dont think so. ’

BY MR. BINHAK:

I; jcould ask

Q Is there a question that you could think of that we x

ou that could trigger a memory that you have?

Barring hypnosis no. I dont think there is. I ’ m’’

j~idefinitelv not a prosecutor, so I hope that I dont get held ’ i 8 j to this, but. no..

MR. BINHAK: Fair enough. As far as Im concerned. ’

now passed the goal line. If any of my colleagues

I dont. Do you? ’

MR. BINHAK: Any other uestions from grand jury?

MR. WISENBERG: Ques 1.Ions from the grand jury?

go, response.&

R WISENB RG: Okay. Thirty seconds to spare.

ilSi Ma the witness be excused?

_

THE FOREPERSON: Yes, he may. 9

of testimony

ury was

rz3lconctuded.) .***.

XMAX(l8)

Page 104 to Paie 106 Old-Sta~
1252

l

ii 1
1253

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

- 1 -

OFFICE OF THE INDEPENDENT COUNSEL

Date of transcription 05/11/98

PATRICK JOSEPH GRIFFIN, white, male, date of birth m

-, place of birth

Account Number i-v

1, Social Security - _

I home telephone number i-L,

home address _h P

President, GRIFFIN & JOHNSON, 1300 Connecticut Avenue, NW, 6'"

Floor, Washington, DC was apprised .of the official identity of

the interviewing Agents and the nature of the interview. Also

present for the interview was GRIFFIN's attorney, ROBERT F. BAUER

with the law firm of PERKINS, COIE, LLP, Washington, DC. GRIFFIN

provided the following information:

GRIFFIN began working in the White House in January of

1994 as the Assistant to the President and Director of

Legislative Affairs. GRIFFIN worked in that position until

February of 1996, when he left the White House to return to

private industry.

GRIFFIN first met MONICA LEWINSKY in November of 1995

during the Government shutdown. LEWINSKY spent time in the

office outside of LEON PANETTA's office answering telephones

during the shutdown.

GRIFFIN described LEWINSKY as a little too eager and

effervescent. GRIFFIN advised that LEWINSKY's attire and

demeanor indicated she was not aware of where she worked.

GRIFFIN advised that LEWINSKY's dresses were too short and her

blouses were too tight. LEWINSKY went out of her way to get

noticed.

GRIFFIN recalls one occasion during the shutdown when

LEWINSKY met the President. GRIFFIN described LEWINSKY as being

flirtatious. In response, the President was friendly.

GRIFFIN advised he played no role in LEWINSKY receiving

a paid position in the Office of Legislative Affairs. GRIFFIN

advised that TIM KEATING, GRIFFIN's Chief of Staff, was

responsible for hiring LEWINSKY. GRIFFIN is not aware of how

KEATING came to know LEWINSKY. GRIFFIN may have signed the form

which approved LEWINSKY getting the paid position, but GRIFFIN

did so at the recommendation of KEATING.

Washington, DC File I 29D-OIC-LR-35063

05/7/98
1254

OK-302a (Rev. 8-19-W)

29D-OIC-LR-35063

Continuation of OIC-302 of PATRICK JOSEPH GRIFFIN .On 05/07/98 .~age 2

GRIFFIN stated he had no supervisory duties over

LEWINSKY. GRIFFIN advised that he had a one on one meeting with

LEWINSKY when she worked in the Office of Legislative Affairs.

GRIFFIN felt sorry for LEWINSKY as she was overweight and selfconscious about it. GRIFFIN told LEWINSKY to "chill," that she

did not have to make it a point to get noticed. GRIFFIN recalls

LEWINSKY nodding when he said this.

GRIFFIN did not hear any stories about LEWINSKY and the

President having a relationship. GRIFFIN has some recollection

as to why LEWINSKY was transferred to the Pentagon. KEATING .

advised GRIFFIN that JOCELYN JOLLEY, LEWINSKY's supervisor in the

Correspondence Unit of the Office of Legislative Affairs, was not

doing a very good job. KEATING told GRIFFIN that LEWINSKY's

performance was not helping the overall operation of the office.

GRIFFIN recalls seeing LEWINSKY at a going away party

for STEVE GOODIN held near BETTY CURRIE's office, just outside

the Oval Office. GRIFFIN recalls seeing the President there, but

does not recall seeing LEWINSKY and the President together.

GRIFFIN thought GEORGE STEPHANOPOLOUS was one of approximately

sixty people at that party.

GRIFFIN recalls a going away party thrown for him in

the White House. The President, Vice President and LEWINSKY were

there among the fifty or so people in attendance. GRIFFIN

recalls a photograph being taken of the President with the junior

staff of the Office of Legislative Affairs, including LEWINSKY.

and

GRIFFIN advised he remains in contact with many current

former White House employees. GRIFFIN advised he has limited

his conversations about the LEWINSKY matter to the political

impact the situation is having. GRIFFIN has not discussed with

anyone the details of any of the stories related to LEWINSKY that

have appeared in the press in the past four months. GRIFFIN has

not asked if any of the stories are true, and no one has

volunteered such information.

.

GRIFFIN advised that the practice in government was to

transfer peoplelwho would probably be terminated in private

industry.
1255

OK-302 (Rev. B-19-94)

- 1 -

OFFICE OF THE INDEPENDENT COUNSEL

Date of transcriptton l/29/98

On l/29/98, a federal Grand Jury subpoena was served on

DAVID GROBAINE, owner of Briarwood Bookstore, Maryland Avenue,

Annapolis, Maryland. Service of the subpoena was effected at his

place of business. The subpoena specified his appearance before

the Grand Jury on February 3, 1998 as well the production of

documents relating to the sale of a book as specified in the

subpoena.

Investigation on l/29/98 ar Annapolis, Maryland File X 29D-OIC-LR-35063

by Date dictated l/29/98
1256
1257

OIC-302 (Rev. 8-19-p11

- 1 -

OFFICE OF THE INDEPENDENT COUNSEL

Dare of nanscnpoon l/29/98

DAVID GROBAINE, owner of Briarwood Bookstore, Maryland

Avenue, Annapolis, Maryland, was interviewed at this place

business at which time he provided the following information:

During March or April of 1997, the President of the

United States along with an entourage, which included among

others, Governor Parris Glendenning, visited his bookshop. At

that time, he recalled that President Clinton looked around the

shop and looked at some of the books that were for sale. At one

point, the President read aloud some poetry from one of the

books. The President was interested in one of the other books,

however, GROBAINE could not presently recall the exact item.

GROBAINE stated that the President did not at any time read any

limericks. He is sure of that fact because the book which he was

reading was written in the mid-19th century and the limerick was

not invented until around the turn of the 20th century.

At some point after the visit, GROBAINE received a

telephone call at his shop from an unknown female who advised she

wanted to purchase a book. She advised that her father or uncle

(GROBAINE could not recall which) worked with the President and

that she and her relative wanted to give the book to the

President as a present. GROBAINE described the woman as adamant

that she find the book the President liked and obtain it.

During the call GROBAINE advised the woman the book

recalled as the one of interest. She said she was located in

Washington, DC and that she was going to come to Annapolis to

make the purchase. GROBAINE recalled that she was unable to

arrive at the shop prior to the 6:00 PM closing time. As an

accommodation, he provided her with a telephone number where he

could be reached that evening. GROBAINE said that he played the

mandolin and banjo and was scheduled to practice with his musical

group that night.

The woman did, in fact, call him from what he believed

was a cellular telephone, said she was ten minutes away, and that

she wanted to meet him. GROBAINE met her at his store whereupon

she purchased the book. GROBAINE recalled that she paid either

by check or credit card. He further stated that would have a

record of the credit payment. If she paid by bank check, he

e L<"

Invesrtgation on l/29/98 It Annapolis, Maryland File I 29D-OIC-LR-35063

by Date dicfated l/29/98
1258

OIC-302a (Rev. 8-19-W)

29D-OIC-LR-35063

Continuation of OIC-302 of DAVID GROBAINE .on l/29/98 .page 2

bank deposit slips which note the amount of each check along with

the last name of the customer.

GROBAINE does not recall the name of the customer. He

was displayed a newspaper photo of MONICA LEWINSKY at which time

he stated it was possible that it was the same person, but he was

not sure. He said that he has not been reading any newspapers or

watching much television, so he was not familiar with the

individual or the situation in general.

He described the woman as an attractive person about 5

feet 4 or 5 inches tall.

GROBAINE further stated that he would inquire with his

music group associate as to the name of the woman customer in

that he discussed the matter with him.
1259

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

- 1 -

OFFICE OFTHEINDEPEXDEhT COUNSEL

Date of transcription 3/6/98

DAVID GROBANIE, owner of the BRIARWOOD BOOKSHOP,

Maryland Avenue, Annapolis, Maryland, telephone number _

was interviewed, at which time he provided the

information:

A book entitled The Presidents of the United States,

published by D. APPLETON AND COMPANY in 1898, bearing Office of

Independent Counsel Bate stamp number V002-DC-00000471, was

displayed to GROBANIE. He examined the book and stated with

certainty the book was never in his store and specifically that

he did not sell the book to anyone, including President CLINTON

on the occasion of his visit to BRIARWOOD BOOKSHOP, or the woman

customer who told him she was purchasing a book for the President

of the United States.

GROBANIE said he has purchased every book which has

been for sale in his store and the book described above has never

been in his inventory.

GROBANIE also examined the first page of the book and

noted a faint pencil marking which indicated a price of $45.00.

The price marking was located about one inch from the top of the

page and about one and one half inches from the right side of the

page- GROBANIE said he always, without fail, places the price of

a book in pencil in the uppermost portion of the right corner of

the first page leaving virtually no margin between the marking

and the corner of the page. He displayed several examples of his

technique on books currently for sale in the store.

Regarding the woman with whom he made arrangements to

meet at his shop after normal business hours to purchase a book

for the President, GROBANIE stated that he has recalled that the

woman purchased a book entitled Historv of Peter the Great, 1814

edition. The price of the book was $200.00, however, GROBANIE

recalled that he thinks he charged her $150.00.

Within a few weeks of the President's visit to his

shop, GROBANIE received a series of four telephone calls from an

unknown woman over a period of two weeks. During the first call,

Investigation on 3/5-6/98 at Annapolis, Maryland File I 29D-OIC-LR-35063

by Date dictated 3/6/98
1260

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

29D-OIC-LR-35063

Continuation of OIC-302 of DAVID GROBANIE .~n 3/6/99 .page 2

she asked GROBANIE if he had any suggestions for a book to be

given as a present for President CLINTON. She next called and

asked him about the hours of operation of the store. During the

third call, she made arrangements with GROBANIE to meet him at

his store after normal business hours, in view of the fact that

she was traveling from Washington, DC, or Virginia, and was

unable to to arrive at the Annapolis location before the shop's

6:00 p.m. closing time. The fourth, and last, telephone call

GROBANIE received was on the evening of their appointment. She

called from what he believed was a cellular telephone, advising

him that she had arrived in Annapolis and would be at the store

in about ten minutes.

During their meeting at the store, she made several

comments to GROBANIE about President CLINTON, from which he

inferred that she was quite enamored of CLINTON. Referring to

CLINTON's visit to the store, she said, “wasn't it just wonderful

meeting him? I think he's a wonderful man." GROBANIE recalled

thinking at the time that she was interested in either getting a

job or pursuing a career in politics.

GROBANIE could not recall the method of payment used

for the purchase of the book, saying that it could have been by

credit card, check, or cash. GROBANIE has examined his credit

card sale records for calendar year 1997, and could not find any

record of a sale in the name of MONICA LEWINSKY. He has also

checked his bank deposit slips reflecting records of purchases

made by check, with negative results. He displayed his bank

deposit slip forms indicating where he writes the last name of

the person writing the check. GROBANIE also reviewed sales by

credit card in 1997, in the name of MARCIA LEWIS; however, he was

unable to locate any such record.

During his record search of purchases (other than

cash), he located only one sale which fit the criteria of the

correct price, time frame, and female purchaser. This was a sale

on March 27, 1997, to a BETTIE DEEN for $157.50 ($150.00 purchase

price and $7.50 state sales tax). He could not recall the name

of the book bought by DEEN. GROBANIE said that the name BETTIE

DEEN did not seem to fit with his recollection of the name the

woman in question provided to him at the time.
1261 

OIC-302a (Rev. 8-19-W) 

29D-OIC-LR-35063 

Continuation of OIC-302 of DAVID GROBANIE .on 3/6/98 ,Page _ 3 

GROBANIE has seen several pictures of MONICA LEWINSKY 

and said that although he was not sure, the woman customer could 

have been her. He recalls she may have been about 5' 4" or 5' 5" 

tall with long brown hair. He described her as pretty. 
1262